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KEY AkKey Agricultural Services, Inc. <br />114 Shady Lane - Macomb, IL 61455 - (309) 833 -1313 <br />Introduction <br />The following Soil /Overburden Sampling and Analysis Plan (SAP) was developed by Certified <br />Professional Agronomists and Soil Scientists experienced in prime farmland and western <br />reclamation. The intent of this SAP is to evaluate the chemical and physical properties of the <br />native and disturbed soils on the Western Fuels — Colorado (WFC) mine site near Nucla, CO <br />(New Horizon Mine — Permit No. C- 1981 -008). Once the SAP is approved by all interested <br />parties a Quality Assurance Plan (QAP) will be completed by WFC to identify all respective <br />quality control parameters that will be followed to ensure quality data is being utilized for <br />decision making purposes. The following SAP has been designed with the specific purpose of <br />evaluating the reclamation potential for prime farmland located in Western Colorado and has <br />modifications to both western (arid region) rangeland reclamation protocols and traditional <br />eastern US prime farmland reclamation protocols. The following SAP is intended to fulfill Office <br />of Surface Mining (OSM) and Colorado Division of Reclamation, Mining and Safety (DRMS) <br />requirements requested in the letter dated August 8, 2011 from DRMS to WFC. <br />Project Understanding <br />Currently at the site there are three general soil resources that can assist in determining the <br />most appropriate reclamation strategies for the disturbed areas that may be considered prime <br />farmland at the WFC site. These areas include undisturbed native soil, stockpiled soil resources, <br />and Substitute Subsoil Redistribution Areas. The stockpiled soil resources and Substitute <br />Subsoil Redistribution Areas have been altered by the mine therefore it is the intent of this SAP <br />to determine what the current chemical and physical status of the soil resource. The native soil <br />resources at the site will be sampled to determine the soil chemical and physical status prior to <br />mining activities. The native soil resource will be used as baseline and all other soil resources <br />will be evaluated based on baseline conditions. The new samples will be combined with <br />previous data to better define the baseline conditions. The following SAP is designed to outline <br />the soil resource sampling structure and identify laboratory analysis that will be completed on <br />all soil resources sampled. <br />Soil Resource Sampling Protocol <br />Undisturbed Native Soil <br />The undisturbed native soil resource will be visually evaluated and sampled using traditional <br />soil test pits. Within the permit area approximately five test pits will be excavated with a <br />backhoe to a depth of 60 inches in multiple locations across the undisturbed areas. Sampling <br />locations are shown on Map 2.04.9 -3. At each soil test pit a soil profile description will be <br />performed in accordance with USDA -NRCS protocols. Soil samples will be obtained from at least <br />Page 2 <br />