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Topsoil Replacement Thickness <br />The Division's Guideline ReYardrnt~,SelectedCoa(~Lline Bond Release Issuer, dated April l8, 199, <br />calls for verification of replaced topsoil thicknesses in a Phase [I bond release evaluation. Trapper's <br />approved reclamation plan specifies that topsoil is to bz replaced to a minimum thickness of 13 <br />inches on rangeland sires A, B and C. Trapper's bond release submittal contains field data on topsoil <br />thicknesses collected by Trapper and the Division; the data were verified by the Division. <br />IV. OBSERVATIOYS AND FINDINGS <br />Reclamation History of Phase II Bond Release Parcels <br />Reclamation work on the parcels included in the current bond release request was performed from <br />1980 through 1993. The work included topsoiling and revegetation. The only areas that had not <br />been drill seeded were all of pazcels D-A-89 and D-B-89 and two-thirds of pazcel D-C-89.On those <br />three pazcels, revegetation was accomplished by the seed left in the live hauled topsoil. All of the <br />pazcels were disturbed during mining activities in the following pits: Ashmore, Colt\Browning, <br />Derringer and Enfield. The drainages that were mined through and subsequently reclaimed as <br />permanent drainages aze: West Buzzazd, East Buzzazd, Far East Buzzazd, Coyote, No Name, <br />Johnson and West Pyeatt. All of the reclaimed lands submitted for Phase II bond release are <br />designated as rangeland A, B and C. <br />Tonsoil Thickness <br />Required thickness and replacement history. The permit application, page 3-82 of Volume 3, <br />requires that 12 inches of topsoil be replaced on all reclaimed lands designated as rangeland A, B <br />and C. Trapper replaced topsoil contemporaneously with backfilling and grading operations, drawing <br />from live haul and stockpiled sources. Topsoiling efforts were continuous, from 1980 through 1993. <br />All of the pazcels had phosphate fertilizer applied to the topsoil at a rate of 100 pounds per acre. <br />Some pazcels also had similaz phosphate fertilizer applied to the spoil before topsoil was applied; <br />these pazcels are: A-C-82, A-C-84A, D-A-84, D-A-92, D-B-84, D-C-34, E-A-83,E-A-84 and E-B- <br />83. <br />Confirmation of topsoil thickness. Trapper and the Division confirmed topsoil thicknesses. <br />Trapper field sampled the lands retopsoiled in the 1930-1934 period. Trapper counted scraper loads <br />for the lands retopsoiled in 193 and from 1989 through 1995. The Division verified Trapper's Field <br />sampling and load counts by hand augering topsoil during the July 1996 inspection. The Division's <br />measurements confirmed that Trapper's methods were reasonable. Trapper could not locate their <br />field sampling data for the 1986 through 1933 time period, and consequently relied on hand auger <br />sample data for those areas that was collected by tkte Division. <br />Trapper Mine Page 5 12/14/98 <br />Phase II Bond Release <br />