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of the SL -04 application. <br />IV. OBSERVATIONS AND FINDINGS <br />The following discussion of observations and findings focuses on the results of the revegetation, <br />topsoil replacement and soil loss demonstration for the Partial Phase II Bond Release. <br />The evaluation of the bond release application included the bond release inspection, an office <br />review of the permit requirements and regulatory criteria and review of past inspection reports. The <br />bond release inspection was conducted on 19 -20 June and 7 August 2012. Several items including <br />topsoil replacement, revegetation success and soil loss that were included in the bond release <br />application were reviewed by the Division in the office during the technical evaluation of the <br />bond release application before, during and after the inspection. <br />Topsoil Replacement <br />All of the reclaimed areas included in the West Elk SL -04 application were small, linear areas. <br />In each case the topsoil was salvaged and stored locally, either adjacent to the respective drill <br />pad or windrowed along the applicable light -use road. No soils were hauled to and stored at a <br />common location for any of the disturbances. As such, all of the topsoil material that was <br />salvaged from a specific location was available for the reclamation at only that location. Since <br />all of the topsoil salvaged at a given location was replaced only at that location, the Division did <br />not take any topsoil depth measurements, as the topsoil depths would be dependent on the <br />depth/volume of topsoil encountered at each location (which could be highly variable). The <br />Division's inspection of topsoil replacement on the drill pads and light -use roads was focused on <br />three distinct areas. First, was there topsoil present on the pad and /or road location? Second, <br />was the topsoil replacement adequate to allow for the growth of vegetation? And third, were <br />there any remaining piles of topsoil that were not spread on any location? <br />The Division found that there was topsoil spread at each of the reclaimed areas. This topsoil <br />appeared to be spread as evenly as practicable as there were no large piles or depressions on any <br />of the reclaimed areas. The topsoil was adequate to provide a growth medium for the approved <br />seed mix (see also the "Revegetation" section below). Finally, there were no visible piles or <br />windrows of topsoil that remained at any of the sites. The Division finds that the West Elk Mine <br />has replaced topsoil at all of the SL -04 locations in accordance with their approved reclamation <br />plan and the Rules. <br />Revegetation <br />There were 61 locations, totaling 67.6 acres, included in the West Elk SL -04 application. A <br />detailed list of the locations, acreages and years of reclamation can be found in the partial Phase <br />Proposed Decision and Findings of Compliance 7 July 2013 <br />Partial Phase II Bond Release SL -04 Page 4 <br />