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number of whitetop patches were observed in the areas of 03 -1j, 03 -1i, 99 -1b, and 03 -1k. These <br />areas were a part of the weed control plan spraying conducted the week of the June 12, 2012 <br />bond release inspection. Based on the inspection, the Division considers the weed patches <br />observed and the sporadic noxious species observed to be maintenance items, which will be <br />monitored in the field and reviewed during future inspections. <br />A follow -up inspection was conducted on July 9, 2012 to check completed repair work on areas <br />noted by the Division on the initial inspection and repair work on permanent drainage SIIPM -8 <br />due to a 100 /year storm event that occurred in August 2011, during the review process of the <br />SL -5 application. All sites requiring repair, as noted by the Division, were repaired adequately <br />with no further problems noted. <br />Topsoil Redistribution <br />Permit topsoil depth requirement is 9 -15 inches (C- 1980 -005, Tab 13, Postmining Land Use) for <br />soil replaced after 1993. Soil replacement depth sampling has been conducted and reported <br />annually by SCC over the course of the mine life, and verification sampling has been <br />periodically conducted by the Division. Summary documentation was provided by SCC in <br />Attachment D of the SL -5 application, presenting the results of 933 sample holes over the entire <br />1793.5 acre area for which Phase 11 bond release was requested. With the exception of a small <br />number of outliers, soil thickness ranged from 9" to 30 ", with an average thickness of 15.6 ". <br />Topsoil verification was conducted during monthly inspections as documented in DRMS <br />inspection reports dated 8/15/1996, 9/25/1997, 7/8/1998, 12/1/1998, and 10/21/2003. All <br />parcel areas verified by the Division had adequate topsoil replacement thickness. <br />Cover and Diversity <br />Vegetation cover success criteria and success demonstration methods for the BBB's are <br />presented in Appendix 13 -13 and Volume 14 of the approved SCC permit. Summary <br />statistics and narrative evaluation are included in Part 11 of the SL -05 bond release <br />application. Transect data tables are presented in Attachment E of the SL -05 bond release <br />application document. The supporting basis for an alternative approach to establishing the <br />first -hit herbaceous cover standard is presented in Attachment H of the SL -05 bond release <br />application document. Vegetative cover was sampled during July and August of 2010. <br />Demonstration of vegetation cover success for BRB -3 and 4 requires statistically adequate <br />sampling and comparison to a reference area standard, with hypothesis testing if necessary to <br />demonstrate that reclaimed block herbaceous cover is not less than 90% of the reference area <br />standard (weighted based on 83% original extent of the Mountain Brush reference area and <br />17% original extent of the Sagebrush reference area) (Permit Appendix 13 -13 and Volume <br />14). For the Phase 11 bond release block, all -hit cover is sampled and the first -hit herbaceous <br />cover value is derived. The allowable first -hit herbaceous cover is determined by adjusting <br />for woody plants, noxious weeds and excessive annual /biannual cover. <br />Seneca II Mine Page 8 September 10, 2012 <br />Phase 11 Bond Release <br />