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Memorandum <br />24 August, 2012 <br />To: Marcia Talvitie, DRMS <br />From: Jared Ebert, DRMS <br />RE: New Horizon Mine, C- 1981 -008; Soil Sampling Analysis <br />Enclosures: 1.) Appendix A; November 2011 Undisturbed Area Samples Charts <br />2.) Appendix B; December, 2012 Soil Stockpile Samples, Morgan Property Charts <br />3.) Appendix C; 1998 IRI Soil Samples Charts' <br />CC: Sandy Brown, DRMS w/ enclosures <br />David Berry, DRMS w/ enclosures <br />I conducted an analysis of the raw data submitted to the Division from KeyAg from the 2011 soil <br />sampling program. This included an analysis of the soil samples from the undisturbed areas of the <br />Morgan property, the stockpile soil samples, and the samples taken from test pits conducted in the subsoil <br />substitute redistribution area. Also, an analysis is included at the end of this memo of the 1998 soil <br />samples taken on the Morgan property by Intermountain Resource Inventories, Inc. (W. Using the raw <br />data, the Division was able to chart the parameters measured through the lab analysis of the soil samples <br />and the threshold limits for these parameters based on the approved spoil and soil suitability criteria <br />approved in the permit. The analysis focused on the suitability parameters (as listed on Table <br />2.05.4(2)(d) -lA of the permit) since these are the thresholds currently approved to evaluate the soils <br />quality and use for reclamation. These charts are included in Appendix A, B and C attached to this <br />memo. A discussion of the Division's findings is below. Also, a review was conducted in regards to the <br />OSM Technical Compliance Evaluation of Colorado State Permit C- 008 -81 as revised by the PR -6 Permit <br />Revision Application; Prime Farmland Reclamation, Soil Salvage and Redistribution, Graded Spoil and <br />Soil Sampling — Morgan Property; signed July 15, 2011. There are several concerns outlined in this <br />document that are addressed by the sampling that was conducted; a discussion of this is below. <br />Data Analysis: November 2011 Undisturbed Area Sampling Program <br />Sampling of undisturbed areas occurred in November of 2011. Five Test pits were excavated in two <br />undisturbed parcels on the Morgan property (TPO1- TP05). Samples were taken to be analyzed from each <br />horizon that was identified during the sampling and in predetermined increments in inches. Using the <br />results of the lab testing conducted on each sample provided by KeyAg, the Division compared the data <br />obtained for each soil horizon to the suitability criteria supplied in the permit on Table 2.05.4(2)(d) -lA. <br />Using the criteria, the Division was able to ascertain at what depth in the soil profile certain parameters <br />breached the suitability thresholds for the different growth media types (Lift A, Mixed, Lift B and Bench <br />1 material). A discussion of each parameter is below. <br />pH <br />Each of the horizons sampled, were found to be within the pH minimum and maximum thresholds. <br />Page 1 of 10 <br />