I usually try to maintain about 12 to 15 feet of overburden above the beginning of the bond length. This usually is not a problem because most tieback anchors are installed at about 6 to 9 feet below the top of the sheeting wall. Then, at an angle of 15 to 45 degrees below horizontal, you will usually have enough cover. The important thing to conside is the grouting pressure if the anchor is shallow. You don't want to heave the ground surface. If you don't heave the ground and if the anchors test OK, then you must have enough cover.