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Sample Pile E, Lift A <br />The average pH found in Sample Pile E; Lift A topsoil is 7.42. After charting the pH that was measured, <br />none of the data points are above or below the approved threshold. The average EC was 3.46mmho /cm, <br />two out of thirteen samples yielded EC values above the 4mmho /cm threshold. The saturation percentage <br />of each of the sample was found to be within the threshold limits. The SAR was found to be below the <br />threshold limits. The ESP was found to be well below the threshold. The CCE average 11.81 % within <br />the stockpile, and none of the samples yielded a CCE percentage above the approved threshold. There is <br />currently not a rock fragments percentage threshold for the Lift A or Mixed Topsoil material, however the <br />rock fragment levels within this stockpile was well below the threshold for Lift B materials. <br />The majority of Sample Pile E consisting of Lift A topsoil material does meet the suitability criteria <br />approved in the permit. Only two out of thirteen samples yielded EC values outside of the approved <br />threshold, but the overall average for the pile was below the threshold. <br />Substitute Subsoil Redistribution Area; Mixed Topsoil and Bench I material analysis <br />The average pH found within the Mixed topsoil that has been placed in the Substitute Subsoil <br />Redistribution Area was 7.67, and 7.63 for the Bench 1 material. After charting the pH measured for this <br />area, none of the pH measured were above or below the approved threshold. The average EC for the <br />Mixed topsoil was 4.17 and 4.57mmho /cm for the Bench 1 material. The EC measured for the mixed <br />topsoil material were above the approved suitability thresholds in two out of the three samples taken. <br />None of the samples yielded EC levels above the threshold set for the Bench 1 material. However, if the <br />threshold was 4mmhos /cm for the Bench 1 material all of the samples would be greater than this value. <br />The saturation percentage of each of the samples were found to be within the threshold limits. The SAR <br />was found to be below the threshold limits for both types of materials. The ESP was found to be well <br />below the threshold for the Mixed topsoil samples. There is not an ESP threshold set for the Bench 1 <br />material; however the measured amount for the Bench 1 material was well below the threshold set for Lift <br />A material (15 %). The CCE averaged 9.78% for the Mixed topsoil and 4.05% for the Bench 1 material, <br />and none of the samples yielded a CCE percentage above the approved threshold. For the Bench 1 <br />material, the rock fragments percentage is well below the threshold set for this material. <br />The Mixed topsoil material that has been placed for reclamation does not meet the currently approved <br />suitability criteria. The primary reason behind this is the EC found within the samples is above the <br />threshold for both materials. The Bench 1 material meets the current suitability standards. <br />OSM Technical Compliance Evaluation of Colorado State Permit C- 008 -081 as Revised by the PR- <br />6 Permit Revision Application; Prime Farmland Reclamation, Soil Salvage and Redistribution, <br />Graded Spoil and Soil Sampling — Morgan Property <br />1.) OSM's review finds that the permit lacks sufficient detail to determine that the C Horizon is <br />suitable for salvage and use in prime farmland reclamation; therefore the permit is not in accord <br />with the requirements of Regulation 2.04.9(1). <br />Based on how the permit is written, it is worded to indicate that portions of the C horizon may be <br />salvaged with Lift B material. OSM's details their concern that C horizon material could increase the <br />calcium carbonate levels and rock fragment amounts degrading the soil quality. Based on the data <br />obtained from the November 2011 sampling in the undisturbed areas of the Morgan property, it appears <br />that calcium carbonate level's do increase as the soil depth increases. However, based on the lab data for <br />these soil samples, the calcium carbonate (CCE) percentage only breached threshold levels from Lift A <br />material, not lift B material. Also, only in two test pits did the calcium carbonate breach the Lift A <br />Page 5 of 10 <br />