2012-01-20_INSPECTION - C1981008

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carbonate presence) and placed each soil core in a plastic bag. Each bag was labeled to identify its origin stockpile, hole, and depth increment. OSM had intended to take split samples from these cores. Due to soil moisture, clay content, and cold temperatures, we were unable to thoroughly mix the material and take representative split samples. We elected to have Key Ag dry and sieve the samples and send splits to the lab of OSM's choosing. This was our best option for obtaining scientifically valid well -mixed samples. The permitted sampling and analysis plan (SAP) did not include OSM's intention to take split samples. The split samples are being taken as part of OSM's oversight process. Analyzing a subset of the soil samples will provide OSM a scientific basis for accepting or questioning Key Ag's laboratory results. The two small stockpiles were too small to operate the geoprobe in a safe and proper manner. The stockpiles were not tall enough to take core samples in 5' increments (the depth of geoprobe casing and core tubes). Instead, a WFC representative dug three test pits in the small mixed stockpile and four test pits in the small A Lift stockpile using a backhoe. Three samples were collected from each test pit. The SAP indicated that half of the boring locations would be excavated with a backhoe for visual observation of coarse fragments and other features that may impair reclamation success. Because of the extremely low coarse fragment content found in initial stockpile test pits and drill locations, all parties agreed to decrease the number of test pits to be dug in the large soil stockpiles. Because rock fragments were not present, no information would have been gained by continuing to sample in this manner. Large soil clods were present, but were easily broken by hand. Rock fragments that were found were poorly cemented and could be broken by hand or easily with a rock hammer. This type of rock is sometimes referred to as "melting rock" because it will break down easily when exposed to chemical or mechanical weathering. ACI and Key Ag representatives took care to collect complete and valid samples in accordance with the approved SAP. All decisions to field- revise the SAP were made collectively (DRMS, Key Ag, OSM) without objection from the landowner. These revisions were necessary for the safety and accuracy of the sampling activities. Key Ag and OSM soil scientists agreed that these changes would not detract from the integrity of the approved sampling plan. Key Ag will send the samples to its laboratory in Illinois. Split samples will be sent to a lab of OSM's choosing. Analysis results are expected by late January.