DERR-2024-006806

www.rbwhitepe.com

March 28, 2024

Gary Crocker
Silver Reef Investment Holdings, LLC
2825 Est Cottonwood Parkway
Suite 330
Salt Lake City, UT 84121

Subject: Silver Pointe Estates - Report of Site Maintenance
Following September 2023 Inspection

Dear Gary:

On September 18, 2023 I conducted the annual inspection of Silver Pointe Estates in accordance with
the requirements of the location’s Site Management Plan. The final report associated with that
inspection was issued on November 30, 2023. That report identified the following four items requiring
attention:

• Remove small piles of waste rock and adjacent soil discovered in an area north of the large
headframe.
• Post a sign and place soil and gravel at the entrance to a closed mine adit.
• Move a group of large boulder into the adjacent “glory hole.”
• Place additional soil and gravel on locations where erosion has occurred in areas required by the
Site Management Plan to maintain a minimum of 6 inches of soil cover.

The purpose of this report is to present the results of the above maintenance efforts. These efforts
were observed in the field by myself and by David Bird, Project Manager in the Voluntary Cleanup
Program/Brownfields Section of the Utah Division of Environmental Response and Remediation
(“DERR”).

Waste Rock Removal

During the September 2023 site inspection, Mr. Bird and I observed approximately 40 to 50 yd3 of waste
rock that existed in three adjacent piles located approximately 230 feet north of the large headframe.
To assist with cleanup of this material, I scanned the area of this waste rock and adjacent soil on January
29, 2024 using a Ludlum 2221 scaler with a 49-10 gamma detector. I then placed pin flags at the extent
of areas where gamma radioactivity exceeded background.

Removal of the waste rock and soil began on January 29, 2024. Substantial precipitation during the
prior few weeks left the soil in a moist condition, thereby precluding the need for dust control during
removal operations. The soil was excavated by Raintree Landscaping using a trackhoe and placed in a
stockpile adjacent to Bonanza Flat Road. The soil was then loaded from the stockpile into haul trucks
which were tarped prior to hauling the material to the Washington County landfill.

Richard B. White, PE, PLLC 13441 South Lone Peak Lane  Draper, Utah 84020  801-673-6647

Gary Crocker
March 28, 2024
Page 2

I occasionally scanned the excavated area for gamma radiation as waste rock and soil were being
removed to ensure that background conditions were achieved. I marked areas with pin flags where
additional soil removal was required. Those areas were then re-excavated.

We had previously understood that the waste rock and soil from the site could be hauled to the landfill
without special approval. However, the first loads of material were rejected since paper work had not
been filed. Therefore, I submitted a Special Waste Profile to Republic Services (the landfill operator) on
January 31, 2024. A copy of that profile, together with the supporting information submitted at the
request of Republic Services, is provided in Attachment A. In the interim, as we were awaiting approval
from the landfill, I covered the excavated soil stockpile with 6-mil black polyethylene sheeting to protect
the stockpile against wind and water erosion during the delay. The sheeting was weighted down with
rocks on the top and a soil berm on the south (uphill) side.

Approval to dispose of the material at the Washington County landfill was issued by Republic Services on
February 9, 2024. A copy of this approval is provided in Attachment B. Hauling of the waste rock and
impacted soil resumed on February 13, 2024 and was completed that day. Copies of the transport
manifests are provided in Attachment C. Photographs of the removal effort are provided in Attachment
D.

Following removal of all excavated waste rock and soil from the site, I again scanned the area for gamma
radiation and found levels to be consistent with background. I then collected soil samples from the
excavated area for laboratory analyses to confirm that the extent of excavation was sufficient. These
samples were collected in accordance with the 2010 Remedial-Action Plan (“RAP”) used for prior
cleanup of the area.

Based on field measurements, I determined that the excavated zone covered an area of 6,290 ft2. The
RAP requires that confirmation samples be collected from remediated areas at a frequency of at least
one composite per 10,000 ft2 of excavated area. With an affected area of less than 10,000 ft2, I collected
one composite sample from the excavated area. In accordance with the RAP, I marked locations for
subsample collection by laying a measuring tape along the northern boundary of the excavated area and
then, using a random number generator, I selected 10 locations west and south of the starting point
within the excavated area and marked those locations with pin flags.

Prior to collecting each subsample, I measured the concentrations of several of the contaminants of
potential concern (as identified in the RAP) using a SciApps X200 x-ray fluorescence (“XRF”) analyzer.
The analyzer had been calibrated in the laboratory prior to receipt and I conducted field calibrations in
accordance with the manufacturer’s recommendation prior to use. I scanned each sample location by
pressing the face of the analyzer against the soil for a minimum of 50 seconds (the rate set by the
company from which I rented the analyzer). The results of those analyses are provided in Table 1.
These analyses, together with the post-excavation gamma radiation measurements, suggested that
sufficient rock and soil had been removed for the residual soil to meet the RAP remediation goals.

Gary Crocker
March 28, 2024
Page 3

After obtaining field gamma and XRF measurements, I collected each subsample in accordance with the
RAP as follows:

• At each location, I collected a subsample with a stainless steel spoon to a depth of 2 to 3 inches
and placed the subsamples in a stainless steel bowl.
• Following the collection of all subsamples, I mixed the subsamples in the bowl using the
stainless steel spoon.
• I then filled sample containers with the mixed soil to provide three confirmation samples - one
representing the original sample, one representing a blind duplicate, and one that I provided to
Mr. Bird for analyses at another laboratory selected by DERR.

I submitted the original and blind duplicate samples to Eurofins at their laboratory in Earth City,
Missouri. Mr. Bird submitted the DERR split sample to Pace Analytical at their laboratory in Mount
Juliet, Tennessee. The results of the laboratory analyses are presented in Attachment E and summarized
in Table 2.

Comparisons of the primary sample with the blind duplicate and the laboratory duplicate are provided
in Table 3. Some comparisons exceeded the precision goal of 15% as stated in the 2010 Quality
Assurance Project Plan that was prepared for sampling of the Phase 1 and Phase 2 development areas.
Such exceedances are not unusual in cases where concentrations are low. Given the fact that the
maximum concentrations detected in all samples (primary and duplicate) are substantially below the
remedial-action goals, it is apparent that sufficient waste rock and soil were removed from the area to
meet the remedial-action goals of the RAP. Therefore, I consider concerns about this location to be
resolved.

Adit Sign and Cover

On January 29, 2024 I posted a sign on the grate covering the face of the adit indicating that elevated
radiation levels exist in the area. Raintree Landscaping then placed a minimum of 6 inches of soil and 2
inches of 2-inch minus gravel on the floor of the portal leading to the adit on February 13, 2024.
Photographs of that effort are included in Attachment D.

In a meeting on March 11, 2024, Mr. Bird requested that a line item be added to the annual inspection
form addressing the status of the sign that was hung on the adit grate. The revised form with that
added line item is provided in Attachment F. With these efforts having been completed, I consider
concerns about this location to be resolved.

Boulder Removal

During the September 2023 site inspection, Mr. Bird and I observed a large boulder on the ridge near
the “glory hole” that exhibited high gamma radiation levels. At the request of Mr. Bird, this boulder and
the adjacent boulders were placed into the bottom of the “glory hole” on January 29, 2024.
Gary Crocker
March 28, 2024
Page 4

Photographs of this effort are provided in Attachment D. With this work having been completed, I
consider concerns about this location to be resolved.

Erosion Repair

During the September 2023 site inspection, Mr. Bird and I observed rill erosion in some areas where the
Site Management Plan requires maintenance of a minimum of 6 inches of soil cover. The erosion of
concern occurred in the following areas, as labeled on Figures 8 and 9 of the 2016 Remedial Action
Report (see Attachment G for copies of the figures):

• PCA5-0
• PCA6-SE
• PCA8-SE
• PCA8-NEA-R
• PCA8-NEB-R
• PCA10-0
• PCA12-0

Prior to repair, I scanned the areas of concern for gamma radiation. Gamma radiation across most of
the areas of concern was consistent with background. I then placed pin flags at the edges of the areas
of concern based on aerial photographs included in Attachment G.

Based on my pre-maintenance observations, I estimated that an average of at least 3 inches of soil
remained at each area of concern. Therefore, I instructed Raintree Landscaping to regrade each area
and added a minimum of 3 inches of soil and 2 inches of 2-inch minus gravel as an erosion protection
cover. This was accomplished during the period of January 29 through February 13, 2024, with breaks
during that period when precipitation made working conditions difficult. Based on my observations
during this work, I estimate that 4 to 5 inches of soil and 2 to 3 inches of gravel were added to most of
the areas of concern, thus exceeding the requirements.

Soil added to the areas of concern consisted of clean soil obtained from a location in St. George and
from a stockpile in Leeds. Prior to borrowing from the Leeds stockpile, I scanned the stockpile for
gamma radiation and conducted XRF analyses of three arbitrary locations on the pile. I found the
gamma radiation levels to be consistent with background. The results of the XRF analyses are provided
in Table 4. The XRF results were all substantially below site remedial-action goals.

Photographs of the erosion repair efforts are provided in Attachment D. Based on my field
observations, the repair efforts resulted in a minimum of 6 inches of clean soil and a minimum of 2
inches of gravel over the areas of concern. Therefore, I consider concerns about these locations to be
resolved.

Gary Crocker
March 28, 2024
Page 5

Please contact me if you have any questions or need additional information.

Sincerely,

Richard B. White, P.E.
Consulting Civil and Environmental Engineer

Tables and Attachments

Gary Crocker
March 28, 2024
Page 6

TABLE 1

Results of Field XRF Analyses in
Waste Rock Removal Area

Subsample
Number
Concentration (ppm)
Arsenic Copper Lead Mercury Vanadium
1 4.0 12.9 11.4 <1.2 57.8
2 3.7 17.6 11.2 <1.0 <30.2
3 3.7 7.7 11.4 <1.0 47.8
4 2.7 18.5 9.0 <1.0 42.2
5 3.4 27.3 13.6 <1.0 53.2
6 4.9 9.1 13.2 <1.0 44.8
7 4.4 31.2 10.2 <1.0 49.0
8 3.4 17.6 10.3 <1.0 35.0
9 <2.0 13.8 10.3 <1.0 35.9
10 <2.2 15.20 13.3 <1.0 36.3
RAP Remedial
Action Goal 35 3,100 400 23 390
Note: The XRF analyzer used on this project was not configured to measure thallium or uranium.

TABLE 2

Results of Laboratory Analyses of Confirmation Samples
Collected From the Waste Rock Removal Area

Analyte
Concentration(a)
RAP Remedial-
Action Goal
Original Sample
(SILV-1)
Blind Duplicate
(BD-1)
DERR Split
(SILV-1-DEQ)
Arsenic 35 2.5 2.3 2.09
Copper 3,100 12 17 12.8
Lead 400 5.4 5.8 4.35
Mercury 23 0.27 0.21 0.244
Radium-226 5.6/15.6(b) 1.24 1.21 1.68
Thallium 5.1 0.11 0.097 <2.00
Uranium 230 2.2 3.3 <15.0
Vanadium 390 19 22 21.2
(a) All analytical results expressed in mg/kg dry weight except Radium-226 which is expressed in pCi/g dry weight.
(b) Upper 6 inches and deeper, respectively.

Gary Crocker
March 28, 2024
Page 7

TABLE 3

Results of Relative Percent Difference Calculations

Sample Arsenic
(mg/kg)
Copper
(mg/kg)
Lead
(mg/kg)
Mercury
(mg/kg)
Radium-
226 (pCi/g)
Thallium
(mg/kg)
Uranium
(mg/kg)
Vanadium
(mg/kg)
Comparison with Blind Duplicate
SILV-1 2.5 12 5.4 0.27 1.24 0.11 J 2.2 19
BD-1 2.3 17 5.8 0.21 1.21 0.097 J 3.3 22
Primary RL 0.94 0.94 0.28 0.092 1.0 0.47 0.094 0.94
Blind Duplicate RL 1.00 1.00 0.30 0.11 1.0 0.50 0.10 1.0
RPD (%) 8.3% 34.5% 7.1% 25.0% 2.4% 12.6% 40.0% 14.6%
Comparison with Laboratory Duplicate
SILV-1 2.5 12 5.4 0.27 1.24 0.11 J 2.2 19
SILV-1-DEQ 2.09 12.8 4.35 0.244 1.68 ND ND 21.2
Primary RL 0.94 0.94 0.28 0.092 0.2 0.47 0.094 0.94
Duplicate Lab RL 1.00 5.00 2.00 0.04 NR 2.00 15.0 2.50
RPD (%) 17.9% 6.5% 21.5% 10.1% 30.1% NA NA 10.9%
Remedial Action Goal 35 3,100 400 23 5.6/15.6 5.1 230 390
Max Concentration as %
of Rem Action Goal 7.1% 0.5% 1.5% 1.2% 30.0% 2.2% 1.4% 5.6%
RL = Reporting limit. RPD = Relative percent difference. RPDs greater than 15% are shown in bold red. NA = Not applicable; ND = Not detected at the reporting limit; NR = Not reported J = Results is less than the reporting limit but greater than or equal to the method detection limit and the concentration is an approximate value

TABLE 4

Results of Field XRF Analyses of
Borrow Soil Used as Cover Material

Subsample
Number
Concentration (ppm)
Arsenic Copper Lead Mercury Vanadium
1 5.0 17.1 13.1 <1.0 48.4
2 5.7 22.2 12.7 <1.0 42.1
3 3.8 14.7 11.4 <1.0 51.4
RAP Remedial
Action Goal 35 3,100 400 23 390
Note: The XRF analyzer used on this project was not configured to measure thallium or uranium.

ATTACHMENT A

Documentation Submitted to Republic Services
for Waste Rock and Soil Disposal Approval

INFORMATION REGARDING SOIL AND ROCK
EXCAVATED FROM SILVER POINT ESTATES TO BE
DISPOSED OF AT THE WASHINGTON COUNTY LANDFILL

An area east of I-15 in Leeds, UT is being considered for residen�al development as Silver Pointe Estates.
Because this area was the subject of substan�al mining ac�vity from the 1860s through the 1950s, the
land owner (Silver Reef Investment Holdings, “SRIH”) entered into the Voluntary Cleanup Program with
the Utah Division of Environmental Response and Remedia�on. Under that program, SRIH contracted
with an environmental engineering company to collect mul�ple soil samples from the area and
recommend a course of ac�on to remediate past contamina�on. Substan�al work has been directed
during that remedia�on effort.

A limited amount of uranium mining occurred in a por�on of Silver Pointe Estates during the 1950s. The
resul�ng ore was hauled off site for processing. Although substan�al remedia�on work has been
conducted on the property, a small amount of waste rock with elevated gamma radia�on was recently
discovered. In order to ensure that the land is acceptable for residen�al development, SRIH has decided
to remove this waste rock and the adjacent soil. SRIH desires to dispose of this material at the
Washington County Landfill.

Atached to this summary are the results of laboratory analyses of several samples that were collected in
the vicinity of the uranium mining opera�on. These samples were collected prior to site remedia�on
and are, therefore, considered representa�ve of the material from which the subject waste rock was
generated. In addi�on, Richard B. White (consul�ng civil and environmental engineer) analyzed the
waste rock at three arbitrary loca�ons using X-Ray Fluorescence and gamma spectroscopy on January 31,
2024. These results of these analyses are presented below:

Analyte Concentra�on
Sample #1 Sample #2 Sample #3
Gamma 59,000 ct/min 39,000 ct/min 23,000 ct/min
Arsenic 4.3 + 1.5 ppm 2.4 + 1.5 ppm 4.7 + 1.6 ppm
Copper 26.5 + 5.2 ppm 19.0 + 4.9 ppm 49.4 + 5.9 ppm
Lead 12.0 + 2.3 ppm 14.2 + 2.4 ppm 14.9 + 2.4 ppm
Mercury <1 ppm <1 ppm 1.3 + <1 ppm
Vanadium 45.5 + 4.9 ppm 40.7 +5.0 ppm 45.1 + 5.3 ppm

Prepared by:

Richard B. White, P.E.
Consul�ng Civil and Environmental Engineer
Richard B. White, PE, PLLC
13441 South Lone Peak Lane
Draper, UT 84020
801-673-6647
www.rbwhitepe.com
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Gary Crocker
March 28, 2024
Page 9

ATTACHMENT B

Landfill Disposal Approval

INVOICE TO (Generator Billing Information)
GENERATOR NAME (the “Generator”)
Silver Reef Investment Holdings
ATTN:
Gary Crocker
ADDRESS
2825 E cottonwood Parkway

Suite 330
CITY, STATE ZIP CODE
Salt Lake City, UT 84121
TEL. NO. FAX NO.
801-209-3349

LEGAL ENTITY NAME
Washington County Landfill
ADDRESS
325 N Landfill Rd
CITY, STATE ZIP CODE
Washington, UT 84780
TEL. NO. FAX NO.
435-674-7623
AUTHORIZED BY: TITLE

CONTACT TITLE
Craig Hilliard MESE

1. Special Waste Services. Subject to the terms and conditions contained in this Agreement (as defined in Section 4), Company agrees to accept, at
the Facility designated above, Acceptable Waste (as defined in Section 6).

2. Rates:

A. Rates for Disposal:
Waste Disposal Method Disposal Rate: Fees / Taxes / Misc. Transportation
CONTAMINATED
SOIL LANDFILL
$50.00 PER TON

N/A
N/A

Additional Information:
MATERIAL CODE: VG-SW-CONT SOIL | PROFILE EXPIRES: 1/31/2025 | EAV: 100 CUBIC YARDS

Cannot Exceed Daily Volume of N/A Without Prior Approval of Company.

B. Incorporation by Reference. In addition to Special Waste Profile(s), the following documents are incorporated by reference into this
Agreement as if fully set forth herein.
1)
2)

C. Taxes, Fees & Other Charges. Generator shall also be liable for all taxes, fees, or other charges imposed by federal, state, local or provincial
laws, ordinances and regulations, and all charges set forth in Section 9, including, without limitation, site specific fees, host fees, fuel recovery
fees, environmental recovery fees and administrative fees.

3. Term of Agreement. This Agreement is effective for 12 months beginning on August 19, 2021 (the “Initial Term”) and shall automatically renew for
successive 0-month periods (each, a “Renewal Term”), unless written notice of non-renewal is delivered in accordance with Section 19 by one party
to the other party at least 30 days before the expiration of the Initial Term or any Renewal Term.

Except for requests for bids that Generator must send to multiple parties under any Applicable Laws, Generator grants to Company the right to bid
and/or compete for any future services sought by Generator, whether by means of competitive bids or otherwise, that are for services comparable
to those provided under this Agreement.

COMPANY AND GENERATOR, IN CONSIDERATION OF THE MUTUAL OBLIGATIONS CONTAINED IN THIS AGREEMENT, AGREE THAT THIS
IS A LEGALLY BINDING AGREEMENT WHICH IS SUBJECT TO THE TERMS AND CONDITIONS SET FORTH ON THIS PAGE, AND ON THE
REVERSE SIDE OF THIS PAGE. IN ADDITION, GENERATOR IS CERTIFYING THE TERMS AND CONDITIONS ON THE REVERSE SIDE OF THIS
PAGE HAVE BEEN REVIEWED AND INITIALLED AT THE BOTTOM OF THE PAGE.

GENERATOR REPUBLIC SERVICES/COMPANY/ALLIED WASTE SYSTEMS OF COLORADO, LLC

_______________________________________________ ___________________________________________________
SIGNATURE (AUTHORIZED REPRESENTATIVE) SIGNATURE (AUTHORIZED REPRESENTATIVE)

_______________________________________________ ___________________________________________________
NAME AND TITLE (PLEASE PRINT) NAME AND TITLE (PLEASE PRINT)

DATE:___________________________ DATE:_______________________________
SPECIAL WASTE DISPOSAL SERVICES AGREEMENT FOR
NON-HAZARDOUS WASTES
Special Waste Profile No: 4039241686
____________________
Consultant
02/09/2024

GENERATOR: ________________ REPUBLIC SERVICES/COMPANY: ________________June 2021

4. The Agreement. This agreement of the parties (“Agreement”) for the disposal of Acceptable Waste shall
consist of this Agreement, riders to the Agreement (if any), any Special Waste Profiles (including any
approved changes and re-certifications) and any Application, permit and approval that may be applicable
to the disposal of such Acceptable Waste (“Acceptable Waste Documentation”).

5. Waste Accepted at Facility. Generator represents, warrants and covenants that the waste delivered to
Company at its Facility hereunder will be Acceptable Waste and will not contain any unacceptable
quantity of hazardous materials or substances, radioactive materials or substances, or toxic waste or
substances, as defined by applicable federal, state, local or provincial laws or regulations. Any waste
which does not meet these requirements shall hereinafter be referred to as “Unacceptable Waste”. The
Generator shall in all matters relating to the collection, transportation and disposal of the Acceptable
Waste hereunder, comply with all applicable federal, state and local laws, regulations, rules and orders
regarding the same (collectively, “Applicable Laws”).

6. Acceptable Waste. Only waste that satisfies each of the following criteria shall be accepted for disposal
at the Facility (“Acceptable Waste”): (a) the waste conforms to the description set forth in the Acceptable
Waste Documentation; (b) the waste does not contain any Unacceptable Waste; (c) the waste is
accurately reflected on any Special Waste Profile(s) as directed by the Company pursuant to Section 7;
(d) the waste is acceptable for disposal at the Facility under all Applicable Laws; and (e) the transportation
to and disposal of the waste at the Facility is otherwise in accordance with this Agreement. The parties
may incorporate additional Acceptable Waste as part of this Agreement if prior to delivery of such Waste
to Company, Generator has provided an Application for such Acceptable Waste and Company has
approved disposal of such Acceptable Waste within the limitations and conditions contained in
Company’s written notice of approval of Special Waste Disposal. Title to and liability for any and all
Acceptable Waste handled or disposed of by Company shall at all times remain with Generator and
Broker (if a Broker is involved).

7. Rights of Refusal/Rejection. The Generator shall inspect all waste at the place(s) of collection and
shall remove any and all Unacceptable Waste. Company has the right to refuse, or to reject after
acceptance, any load(s) of waste(s) delivered to its Facility including if the Company believes (a)
Generator has breached (or is breaching) its representations, warranties, covenants or agreements in
this Agreement or any Acceptable Waste Documentation, or any Applicable Laws; or (b) that the waste
contains Unacceptable Waste. The Company has the right to refuse, or to reject after acceptance, any
load(s) of waste(s) delivered to its Facility if the Company has reason to believe, in its sole discretion,
that the waste: (1) emits excessive odors; and/or (2) negatively impacts operations at the Facility.
Company shall have the right to inspect all vehicles and containers of waste haulers, including the
Generator’s vehicles, in order to determine whether the waste is Acceptable Waste pursuant to this
Agreement and all Applicable Laws. The Company’s exercise, or failure to exercise, its rights hereunder
shall not operate to relieve the Generator of its responsibilities or liability under this Agreement.

8. Limited License to Enter. This Agreement provides Generator with a license to enter the Facility for
the limited purpose of, and only to the extent necessary for, off-loading Acceptable Waste at the Facility
in the manner directed by Company. Except in an emergency, Generator’s personnel shall not leave the
immediate vicinity of their vehicle. After off-loading the Acceptable Waste, Generator’s personnel shall
promptly leave the Facility. Under no circumstances shall Generator or its personnel engage in any
scavenging of waste or other materials at the Facility. The Company reserves the right to make and
enforce reasonable rules and regulations concerning the operation of the Facility, the conduct of the
drivers and others on the Facility premises, quantities and sources of waste, and any other matters
necessary or desirable for the safe, legal and efficient operation of the Facility including, but not limited
to, speed limits on haul roads imposed by the Company, and the wearing of hard hats and other personal
protection equipment by all individuals allowed on the Facility premises. Generator agrees to conform
to such rules and regulations as they may be established and amended from time to time. Company
may refuse to accept waste from and shall deny an entrance license to, any of Generator’s personnel
whom Company believes is under the influence of alcohol or other chemical substances. Generator shall
be solely responsible for its employees and subcontractors performing their obligations in a safe manner
when at the facility of Company.

9. Charges and Payment. Payment shall be made by Generator within twenty (20) days after receipt of
invoice from Company. If any amount is overdue, the Company may terminate this Agreement.
Generator agrees to pay a finance charge equal to the maximum interest rate permitted by law.
Generator shall be liable for all taxes, fees, or other charges imposed upon the disposal of the Acceptable
Waste by federal, state, local or provincial laws and regulations. Company, from time to time, may modify
its rates upon thirty (30) days written notice to Generator. For the purposes of this section, written notice
may be provided via email, certified mail, or overnight courier.

10. Termination/Suspension. Company shall have the right to immediately terminate and/or suspend this
Agreement upon the occurrence of any of the following events of default: (a) Generator’s failure to timely
pay any amounts due under this Agreement to Company; (b) Generator’s breach of any of its obligations,
representations, warrants or covenants under this Agreement or any Acceptable Waste Documentation;
or (c) the filing of a voluntary or involuntary petition for reorganization or bankruptcy against Generator.
Generator shall be liable for any losses, claims, expenses and damages incurred by Company as a result
of suspension or termination hereunder. Generator’s obligations, representations, warranties and
covenants regarding the Acceptable Waste delivered and all indemnities contained in this Agreement
shall survive expiration and termination of this Agreement. Additionally, Company shall have the right to
terminate this Agreement for convenience at any time on 30 days notice to Generator.

11. Personnel Knowledge and Authority. Generator represents, warrants and covenants that its drivers
who deliver Acceptable Waste to Company’s Facility have been advised by Generator of the Company’s
prohibition on deliveries of hazardous materials or substances, radioactive materials or substances, or
toxic waste or substances or any other Unacceptable Waste to the Facility of Company’s restrictions on
deliveries of Special Waste to the Facility, of the definitions of “Hazardous Waste and Hazardous
Substances” as provided by applicable federal, state and local law, rules and regulations and “Special
Waste” as provided herein, and of the terms of this license to enter Company’s Facility.

12. Indemnification. Generator agrees to indemnify, defend and hold harmless Company, the legal entity
owning and/or operating the Facility, their subsidiaries, affiliates and parent corporations, as applicable,
and each of their respective officers, directors, lenders, employees, subcontractors and agents
(collectively, the “Company Indemnified Parties”) from and against any and all claims, suits, losses,
liabilities, assessments, damages, fines, costs and expenses, including reasonable attorneys’ fees
(collectively, “Losses”) arising out of or related to (a) the transportation to and/or disposal of any
Unacceptable Waste at the Facility, whether or not Generator or Company was negligent in failing to
identify the Unacceptable Waste; (b) the reloading and/or removal of Unacceptable Waste at the Facility;
(c) any penalties, fines or remediation activities incurred by or imposed as the result of the transportation
and/or disposal of Unacceptable Waste; (d) any increased inspection, testing, study and analysis costs
made necessary due to reasonable concerns of Company as to the content of the waste transported
and/or disposed of at the Facility following discovery of potentially Unacceptable Waste; and (e) the
Company’s inability to use the Facility due to the presence of Unacceptable Waste including without
limitation any consequential damages. Company may also, in its sole discretion, require Generator to
promptly remove the Unacceptable Waste at Generator’s sole expense. The indemnification and other
obligations stated in this Section 12 shall survive the expiration and termination of this Agreement.

13. Insurance. Generator shall maintain in full force and effect throughout the term of this Agreement the
following types of insurance in at least the amounts specified below:

Coverages Minimum Amounts of Insurance
Worker’s Compensation Statutory
Employer’s Liability $1,000,000
General Liability $1,000,000 combined single limit
Automobile Liability (if Generator hauling) $1,000,000 combined single limit

All insurance will be by insurers authorized to do business in the state in which the Facility is located.
Generator shall deliver the Certificates of Insurance evidencing the foregoing policies to Company before
Generator delivers any waste to the Facility pursuant to this Agreement. In addition, the (i) Commercial
General Liability (including the Umbrella/Excess policy) policy must include Contractual Liability coverage
specifically covering Generator’s indemnification of Company, and (ii) The Commercial General Liability,
Automobile Liability and the Umbrella/Excess Liability policies must be written on an “occurrence form”.
Said polices shall not thereafter be canceled, be permitted to expire or laps, or be changed without 30
days advance written notice has been given to Company. With the exception of workers’ compensation,
Company shall be shown as additional insureds under all of the insurance policies required by this
Section 13. The policies required by this Section 13 shall be primary and non-contributory with respect
to Company, and the insurance providers shall agree to waive their rights of subrogation against
Company.

14. Failure to Perform. Except for Generator’s obligation to pay amounts due to Company, neither party
shall be liable for its failure to perform due to circumstances that are both not its fault and beyond its
reasonable control, including, but not limited to, strikes or other labor disputes, riots, protests, civil
disturbances or sabotage, changes in law, fires, floods, compliance with government requests,
explosions, accidents, weather, lack of required natural resources, or acts of God affecting either party.
If any of the circumstances provided for in the preceding sentence occur, including, without limitation,
whether any federal, state or local court or governmental authority takes any action that would (a) close
or restrict operations at the Facility; or (b) limit the quantity or prohibit the disposal of Acceptable Waste
at the Facility, Company shall have the right to reduce, suspend or terminate Generator’s access to the
Facility immediately, without prior notice; provided, however, that Generator’s payment and
indemnification obligations shall survive such reduction, suspension or termination. Neither Party is
required to settle any labor dispute against its own best judgment.

15. Assignment; Performance of Services. Generator may not assign, transfer, subcontract or otherwise
vest in any other company, entity or person, in whole or in part, any of its rights or obligations under this
Agreement without the prior written consent of Company, which Company may withhold in its sole
discretion. Company may freely assign this Agreement or any of its rights or obligations thereunder, to
any other company, entity or person, in its sole discretion. Additionally, Company may freely use any of
its affiliates to provide the services and fulfill Company’s obligations under this Agreement.

16. Right of Disposal. This Agreement does not grant any rights to dispose of waste other than as
specifically set forth in this Agreement.

17. Continuing Compliance. The Generator has a continuing obligation to inform the Company of any new
information, or information not previously provided to the Company by Generator which may affect the
acceptability of the waste by the Company. Further, the Generator shall comply with all Company
requests for evidence of Generator’s continuing compliance with the terms of the Agreement including
but not limited to the following: (i) providing new, updated Special Waste profiles on the waste(s) offered
for disposal or, (ii) providing appropriate certification that the waste being offered for disposal is
accurately reflected by the appropriate Special Waste Profile or, (iii) re-sample the waste at Generator’s
expense if reasonable cause exists as to its acceptability under the terms of this Agreement or, (iv) allow
the Company to re-sample the waste at Generator’s expense if reasonable cause exists as to its
acceptability under the terms of this Agreement or any Acceptable Waste Documentation.

18. Miscellaneous.

(A)This Agreement shall be governed by the laws of the State in which the Facility is located.

(B) No waiver of a breach of any of the obligations contained in the Agreement shall be construed to be
a waiver of any prior or succeeding breach of the same obligation or of any other obligation of this
Agreement.

(C) Unless otherwise provided for herein, no modification, release, discharge or waiver of any provision
or obligation hereof shall be of any force, or effect, unless in writing signed by all parties to this
Agreement.

(D) Generator shall treat as confidential and not disclose to others during or subsequent to the terms of
this Agreement, except as is necessary to perform this Agreement, or to comply with any applicable
law or regulation any information (including any technical information, experience or date) regarding
the Company’s plans, programs, plants, processes, products, costs, equipment or operations which
may come within the knowledge of the Generator or its employees in the performance of this
Agreement, without in each instance securing the prior written consent of the other Company.

(E) If any term, phrase, obligation or provision of this Agreement shall be held to be invalid, illegal or
unenforceable in any respect, this Agreement shall remain in effect and be construed without regard
to such term, phrase, obligation or provision.

(F) This Agreement constitutes the entire understanding between the parties, replacing and amending
any prior agreements between the parties, and shall be binding upon all parties hereto, their
successors, heirs, representatives and assigns. Any provision, term or condition in any
acknowledgement, purchase order or other response by Generator which is in addition to or different
from the provisions of this Agreement shall be deemed objected to by the Company and shall be of
no effect.

(G) Generator represents, warrants and covenants that it is and, during the term of this Agreement will
remain, in compliance with and will perform its obligations pursuant to all applicable laws and
regulations and shall indemnify, defend and hold harmless the Company from any breach thereof.

(H)It is the understanding and agreement of the parties that the Company is an independent contractor,
and is not an agent, nor an authorized representative of the Generator.

(I) Company may provide any of the Services covered by this Agreement through any of its affiliates or
subcontractors, provided that Company shall remain responsible for the performance of all such
services and obligations in accordance with this Agreement

19. Notices. All notices required under this Agreement shall be considered as having been given upon being
placed in the mail, certified postage prepaid, addressed to Company or Generator at the address herein
set forth in this Agreement or to such other address as may be given to the other party in writing.

20. Liquidated Damages. If Generator terminates this Agreement before its expiration other than as a result
of a breach by Company, Generator shall pay Company an amount equal to the most recent month’s
monthly charges multiplied by the lesser of (a) six months or (b) the number of months remaining in the
term. Generator acknowledges that in the event of such a termination, actual damages to Company would
be uncertain and difficult to ascertain, such amount is the best, reasonable and objective estimate of the
actual damages to Company, such amount does not constitute a penalty, and such amount is reasonable
under the circumstances. Any amount payable under this paragraph shall be in addition to amounts
already owing under this Agreement
Document History
SignNow E-Signature Audit Log All dates expressed in MM/DD/YYYY (US)
Document name:Washington County LF Generator SA - Silver Reef
Document created:02/09/2024 18:13:36
Document pages:2
Document ID:3573841bbe8e4014a231a848858f2e78bfa4c30f
Document Sent:02/09/2024 18:15:37 UTC
Document Status:Pending
02/09/2024 19:08:47UTC
Sender:[e-mail]
Signers:[e-mail], [e-mail]
CC:
Client Event By Server Time Client Time IP Address
SignNow Web Application Uploaded the Document [e-mail] 02/09/2024 18:13:36 pm UTC 02/09/2024 18:13:34 pm UTC 163.116.253.47
SignNow Web Application Viewed the Document [e-mail] 02/09/2024 18:13:40 pm UTC 02/09/2024 18:13:40 pm UTC 163.116.253.47
SignNow Web Application Document Saved [e-mail] 02/09/2024 18:15:30 pm UTC 02/09/2024 18:15:30 pm UTC 163.116.253.47
SignNow Web Application Invite Sent to:
[e-mail] [e-mail] 02/09/2024 18:15:38 pm UTC 02/09/2024 18:15:37 pm UTC 163.116.253.47
SignNow Web Application Viewed the Document [e-mail] 02/09/2024 19:05:33 pm UTC 02/09/2024 19:05:32 pm UTC 107.191.0.103
SignNow Web Application Added a Text [e-mail] 02/09/2024 19:08:47 pm UTC 02/09/2024 19:08:47 pm UTC 107.191.0.103
SignNow Web Application Document Saved [e-mail] 02/09/2024 19:08:47 pm UTC 02/09/2024 19:08:47 pm UTC 107.191.0.103
SignNow Web Application Signed the Document [e-mail] 02/09/2024 19:08:47 pm UTC 02/09/2024 19:08:47 pm UTC 107.191.0.103
SignNow Web Application Signed the Document [e-mail] 02/09/2024 19:08:47 pm UTC 02/09/2024 19:08:47 pm UTC 107.191.0.103
SignNow Web Application Added a Text [e-mail] 02/09/2024 19:08:47 pm UTC 02/09/2024 19:08:47 pm UTC 107.191.0.103
SignNow Web Application Invite Sent to:
[e-mail] [e-mail] 02/09/2024 19:08:48 pm UTC 107.191.0.103
Gary Crocker
March 28, 2024
Page 10

ATTACHMENT C

Copies of Transport Manifests

Gary Crocker
March 28, 2024
Page 11

ATTACHMENT D

Photographs

Waste rock cleanup area, pre-excava�on, showing pin flags at extent of impact

Waste rock cleanup area, soil and rock removal opera�ons

Waste Rock
Waste rock removal area, haul truck loading opera�ons

Waste rock removal area, prepara�on of interim cover

Waste rock removal area, showing interim cover in place

Waste rock removal area, final stockpile removal

Mine adit, showing emplaced cau�on sign

Mine adit, showing emplaced soil and gravel cover

Big Hill ridge, showing boulder removal

Big Hill ridge, showing boulder placement in “glory hole”

PCA5-0 soil and gravel cover, view to the southwest

PCA5-0 soil and gravel cover, view to the east

PCA6-SE soil and gravel cover, west end, view to the north

PCA6-SE soil and gravel cover, view across site to the northeast

PCA10-0, placement of gravel cover on east side

PCA10-0, completed soil and gravel cover on west side

PCA10-0, completed soil and gravel cover on north side

PCA10-0, completed soil and gravel cover, showing large headframe and east side diversion

PCA12-0, placement of soil cover

PCA12-0, placement of gravel cover

PCA12-0, completed soil and gravel cover
Gary Crocker
March 28, 2024
Page 12

ATTACHMENT E

Results of Laboratory Analyses

ANALYTICAL REPORT
PREPARED FOR
Attn: Richard White
Richard B White, PE, PLLC
13441 South Lone Peak Lane
Draper, Utah 84020
Generated 3/14/2024 4:01:23 PM
JOB DESCRIPTION
Silver Pointe Estates, Leeds, UT
JOB NUMBER
160-53183-1
See page two for job notes and contact information.
Earth City MO 63045
13715 Rider Trail North
Eurofins St. Louis
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Eurofins St. Louis
Eurofins St. Louis is a laboratory within TestAmerica Laboratories, Inc., a company within Eurofins Environment Testing Group of Companies
Job Notes
This report may not be reproduced except in full, and with written approval from the laboratory. The results relate only to the
samples tested. For questions please contact the Project Manager at the e-mail address or telephone number listed on this
page.
The test results in this report relate only to the samples as received by the laboratory and will meet all requirements of the
methodology, with any exceptions noted. This report shall not be reproduced except in full, without the express written
approval of the laboratory. All questions should be directed to the Eurofins TestAmerica Project Manager.
Authorization
Generated
3/14/2024 4:01:23 PM
Authorized for release by
Casey Robertson, Project Manager
[e-mail]
[phone]
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Table of Contents
Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Laboratory Job ID: 160-53183-1
Page 3 of 16
Eurofins St. Louis
3/14/2024
Cover Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Case Narrative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4
Chain of Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6
Receipt Checklists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
Definitions/Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8
Method Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
Sample Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
Detection Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
Client Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
QC Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13
QC Association Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
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Job Narrative
160-53183-1
All soil/sediment sample results for radiochemistry analyses are based upon sample as dried and disaggregated with the exception
of tritium, carbon-14, and iodine-129 by gamma spectroscopy unless requested as wet weight by the client."
Any minimum detectable concentration (MDC), critical value (DLC), or Safe Drinking Water Act detection limit (SDWA DL) is
sample-specific unless otherwise stated elsewhere in this narrative.
Radiochemistry sample results are reported with the count date/time applied as the Activity Reference Date.
The matrix for the Method Blank and LCS/LCSD is as close to the samples as can be reasonably achieved. Detailed information
can be found in the most current revision of the associated SOP.
Receipt
The samples were received on 2/16/2024 10:20 AM. Unless otherwise noted below, the samples arrived in good condition, and,
where required, properly preserved and on ice. The temperature of the cooler at receipt time was 0.6°C.
Metals
Method 6020A: preparation batch 160-649028 and analytical batch 160-650466
The following samples were diluted due to the abundance of non-target analytes: (550-214278-H-6-A), (550-214278-H-6-B MS),
(550-214278-H-6-C MSD) and (550-214278-H-6-A SD). Elevated reporting limits (RLs) are provided.
Method 7471B: preparation batch 160-649952 and analytical batch 160-650052
The matrix spike / matrix spike duplicate (MS/MSD) recoveries for mercury were outside control limits. See QC Sample Results for
detail. Sample matrix interference and/or non-homogeneity are suspected because the associated laboratory control sample (LCS)
recovery is within acceptance limits. (160-53082-C-1-F MS) and (160-53082-C-1-G MSD)
Gamma Spectroscopy
Method GA_01_R_Ra: Gamma Prep batch 160-649025
Many isotopes requested by gamma spectrometry analysis do not have any gamma emissions, the gamma emissions they do
have are very poor, and/or are reported by assuming secular equilibrium with a longer-lived parent (or vice-versa). For example,
Th-232 (which does not have a good gamma-ray) is often reported assuming the shorter-lived Ra-228 daughter is in equilibrium
with the Th-232 parent. Or, Pb-214 and/or Bi-214, daughters of potentially volatile Rn-222 in the Ra-226 decay chain, may not be
in equilibrium with the parent unless sufficient time has been allowed since the break in equilibrium (e.g. 21 days in the case of
Ra-226-supported ingrowth). The client should ensure that such inference is acceptable for their sample based upon process
knowledge.
The following assumptions were made for this report:
Inferred from Reported to Analyte
Th-234 Pa-234
Th-234 U-238
Pb-210 Po-210
Pb-210 Bi-210
Cs-137 Ba-137m
Pb-212 Po-216
Xe-131m Xe-131
Sb-125 Te-125m
Ag-108m Ag-108
Rh-106 Ru-106
Pb-212 Th-228
Pb-212 Ra-224
U-235 Th-231
Ac-228 Th-232
Ac-228 Ra-228
Th-227 Ra-223
Th-227 Ac-227
Th-227 Bi-211
Th-227 Pb-211
Bi-214 Ra-226
Case Narrative
Client: Richard B White, PE, PLLC Job ID: 160-53183-1
Project: Silver Pointe Estates, Leeds, UT
Eurofins St. Louis
Job ID: 160-53183-1 Eurofins St. Louis
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No additional analytical or quality issues were noted, other than those described above or in the Definitions/ Glossary page.
Case Narrative
Client: Richard B White, PE, PLLC Job ID: 160-53183-1
Project: Silver Pointe Estates, Leeds, UT
Eurofins St. Louis
Job ID: 160-53183-1 (Continued)Eurofins St. Louis
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Login Sample Receipt Checklist
Client: Richard B White, PE, PLLC Job Number: 160-53183-1
Login Number: 53183
Question Answer Comment
Creator: Awalt, Jayna K
List Source: Eurofins St. Louis
List Number: 1
TrueRadioactivity wasn't checked or is </= background as measured by a survey
meter.
TrueThe cooler's custody seal, if present, is intact.
TrueSample custody seals, if present, are intact.
TrueThe cooler or samples do not appear to have been compromised or
tampered with.
TrueSamples were received on ice.
TrueCooler Temperature is acceptable.
TrueCooler Temperature is recorded.
TrueCOC is present.
TrueCOC is filled out in ink and legible.
TrueCOC is filled out with all pertinent information.
TrueIs the Field Sampler's name present on COC?
TrueThere are no discrepancies between the containers received and the COC.
TrueSamples are received within Holding Time (excluding tests with immediate
HTs)
TrueSample containers have legible labels.
TrueContainers are not broken or leaking.
TrueSample collection date/times are provided.
TrueAppropriate sample containers are used.
TrueSample bottles are completely filled.
N/ASample Preservation Verified.
TrueThere is sufficient vol. for all requested analyses, incl. any requested
MS/MSDs
N/AContainers requiring zero headspace have no headspace or bubble is
<6mm (1/4").
TrueMultiphasic samples are not present.
TrueSamples do not require splitting or compositing.
N/AResidual Chlorine Checked.
Eurofins St. Louis
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Definitions/Glossary
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Qualifiers
Metals
Qualifier Description
F1 MS and/or MSD recovery exceeds control limits.
Qualifier
J Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value.
Rad
Qualifier Description
U Result is less than the sample detection limit.
Qualifier
Glossary
These commonly used abbreviations may or may not be present in this report.
¤Listed under the "D" column to designate that the result is reported on a dry weight basis
Abbreviation
%R Percent Recovery
CFL Contains Free Liquid
CFU Colony Forming Unit
CNF Contains No Free Liquid
DER Duplicate Error Ratio (normalized absolute difference)
Dil Fac Dilution Factor
DL Detection Limit (DoD/DOE)
DL, RA, RE, IN Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample
DLC Decision Level Concentration (Radiochemistry)
EDL Estimated Detection Limit (Dioxin)
LOD Limit of Detection (DoD/DOE)
LOQ Limit of Quantitation (DoD/DOE)
MCL EPA recommended "Maximum Contaminant Level"
MDA Minimum Detectable Activity (Radiochemistry)
MDC Minimum Detectable Concentration (Radiochemistry)
MDL Method Detection Limit
ML Minimum Level (Dioxin)
MPN Most Probable Number
MQL Method Quantitation Limit
NC Not Calculated
ND Not Detected at the reporting limit (or MDL or EDL if shown)
NEG Negative / Absent
POS Positive / Present
PQL Practical Quantitation Limit
PRES Presumptive
QC Quality Control
RER Relative Error Ratio (Radiochemistry)
RL Reporting Limit or Requested Limit (Radiochemistry)
RPD Relative Percent Difference, a measure of the relative difference between two points
TEF Toxicity Equivalent Factor (Dioxin)
TEQ Toxicity Equivalent Quotient (Dioxin)
TNTC Too Numerous To Count
Eurofins St. Louis
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Method Summary
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Method Method Description LaboratoryProtocol
SW8466020AMetals (ICP/MS)EET SL
SW8467471BMercury (CVAA)EET SL
EPAMoisturePercent Moisture EET SL
DOEGA-01-R Radium-226 & Other Gamma Emitters (GS)EET SL
SW8463050BPreparation, Metals EET SL
SW8467471BPreparation, Mercury EET SL
NoneDry and Grind Preparation, Dry and Grind EET SL
NoneFill_Geo-21 Fill Geometry, 21-Day In-Growth EET SL
Protocol References:
DOE = U.S. Department of Energy
EPA = US Environmental Protection Agency
None = None
SW846 = "Test Methods For Evaluating Solid Waste, Physical/Chemical Methods", Third Edition, November 1986 And Its Updates.
Laboratory References:
EET SL = Eurofins St. Louis, 13715 Rider Trail North, Earth City, MO 63045, TEL [phone]
Eurofins St. Louis
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Sample Summary
Client: Richard B White, PE, PLLC Job ID: 160-53183-1
Project/Site: Silver Pointe Estates, Leeds, UT
Lab Sample ID Client Sample ID Matrix Collected Received
160-53183-1 SILV-1 Solid 02/13/24 13:10 02/16/24 10:20
160-53183-2 BD-1 Solid 02/13/24 13:40 02/16/24 10:20
Eurofins St. Louis
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Detection Summary
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Client Sample ID: SILV-1 Lab Sample ID: 160-53183-1
☼Arsenic
RL
0.94 mg/Kg
MDL
0.11
Analyte Result Qualifier Unit Dil Fac D Method Prep Type
Total/NA22.5 6020A
☼Copper 0.94 mg/Kg0.20 Total/NA2126020A
☼Lead 0.28 mg/Kg0.068 Total/NA25.4 6020A
☼Thallium 0.47 mg/Kg0.022 Total/NA20.11 J 6020A
☼Uranium 0.094 mg/Kg0.010 Total/NA22.2 6020A
☼Vanadium 0.94 mg/Kg0.38 Total/NA2196020A
☼Mercury 0.092 mg/Kg0.036 Total/NA10.27 7471B
Client Sample ID: BD-1 Lab Sample ID: 160-53183-2
☼Arsenic
RL
1.0 mg/Kg
MDL
0.12
Analyte Result Qualifier Unit Dil Fac D Method Prep Type
Total/NA22.3 6020A
☼Copper 1.0 mg/Kg0.21 Total/NA2176020A
☼Lead 0.30 mg/Kg0.072 Total/NA25.8 6020A
☼Thallium 0.50 mg/Kg0.023 Total/NA20.097 J 6020A
☼Uranium 0.10 mg/Kg0.011 Total/NA23.3 6020A
☼Vanadium 1.0 mg/Kg0.40 Total/NA2226020A
☼Mercury 0.11 mg/Kg0.042 Total/NA10.21 7471B
Eurofins St. Louis
This Detection Summary does not include radiochemical test results.
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Client Sample Results
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Lab Sample ID: 160-53183-1Client Sample ID: SILV-1
Matrix: SolidDate Collected: 02/13/24 13:10
Percent Solids: 91.0Date Received: 02/16/24 10:20
Method: SW846 6020A - Metals (ICP/MS)
RL MDL
2.5 0.94 0.11 mg/Kg
☼02/21/24 11:15 02/29/24 18:39 2
Analyte Dil FacAnalyzedPreparedUnit DResult Qualifier
Arsenic
0.94 0.20 mg/Kg 02/21/24 11:15 02/29/24 18:39 2
☼12Copper
0.28 0.068 mg/Kg 02/21/24 11:15 02/29/24 18:39 2
☼5.4Lead
0.47 0.022 mg/Kg 02/21/24 11:15 02/29/24 18:39 2
☼0.11 JThallium
0.094 0.010 mg/Kg 02/21/24 11:15 02/29/24 18:39 2
☼2.2Uranium
0.94 0.38 mg/Kg 02/21/24 11:15 02/29/24 18:39 2
☼19Vanadium
Method: SW846 7471B - Mercury (CVAA)
RL MDL
0.27 0.092 0.036 mg/Kg
☼02/27/24 09:45 02/27/24 14:23 1
Analyte Dil FacAnalyzedPreparedUnit DResult Qualifier
Mercury
Method: DOE GA-01-R - Radium-226 & Other Gamma Emitters (GS)
Analyte
1.24
(2σ+/-)
0.237
(2σ+/-)
103/13/24 06:2302/21/24 11:07pCi/g0.1271.00
RL MDC
0.199
Dil FacAnalyzedPreparedUnitResult Qualifier
Count Total
Uncert. Uncert.
Radium-226
Lab Sample ID: 160-53183-2Client Sample ID: BD-1
Matrix: SolidDate Collected: 02/13/24 13:40
Percent Solids: 90.4Date Received: 02/16/24 10:20
Method: SW846 6020A - Metals (ICP/MS)
RL MDL
2.3 1.0 0.12 mg/Kg ☼02/21/24 11:15 02/29/24 18:43 2
Analyte Dil FacAnalyzedPreparedUnit DResult Qualifier
Arsenic
1.0 0.21 mg/Kg 02/21/24 11:15 02/29/24 18:43 2☼17Copper
0.30 0.072 mg/Kg 02/21/24 11:15 02/29/24 18:43 2☼5.8Lead
0.50 0.023 mg/Kg 02/21/24 11:15 02/29/24 18:43 2☼0.097 JThallium
0.10 0.011 mg/Kg 02/21/24 11:15 02/29/24 18:43 2☼3.3Uranium
1.0 0.40 mg/Kg 02/21/24 11:15 02/29/24 18:43 2☼22Vanadium
Method: SW846 7471B - Mercury (CVAA)
RL MDL
0.21 0.11 0.042 mg/Kg ☼02/27/24 09:45 02/27/24 14:37 1
Analyte Dil FacAnalyzedPreparedUnit DResult Qualifier
Mercury
Method: DOE GA-01-R - Radium-226 & Other Gamma Emitters (GS)
Analyte
1.21
(2σ+/-)
0.222
(2σ+/-)
103/13/24 07:4602/21/24 11:07pCi/g0.1271.00
RL MDC
0.183
Dil FacAnalyzedPreparedUnitResult Qualifier
Count Total
Uncert. Uncert.
Radium-226
Eurofins St. Louis
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QC Sample Results
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Method: 6020A - Metals (ICP/MS)
Client Sample ID: Method BlankLab Sample ID: MB 160-649028/1-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650466 Prep Batch: 649028
RL MDL
Arsenic ND 0.92 0.11 mg/Kg 02/21/24 11:15 02/29/24 18:32 2
MB MB
Analyte Dil FacAnalyzedPreparedDUnitResult Qualifier
ND 0.190.92 mg/Kg 02/21/24 11:15 02/29/24 18:32 2Copper
ND 0.0660.28 mg/Kg 02/21/24 11:15 02/29/24 18:32 2Lead
ND 0.0210.46 mg/Kg 02/21/24 11:15 02/29/24 18:32 2Thallium
ND 0.0100.092 mg/Kg 02/21/24 11:15 02/29/24 18:32 2Uranium
ND 0.370.92 mg/Kg 02/21/24 11:15 02/29/24 18:32 2Vanadium
Client Sample ID: Lab Control SampleLab Sample ID: LCS 160-649028/2-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650466 Prep Batch: 649028
Arsenic 96.3 96.9 mg/Kg 101 80 -120
Analyte
LCS LCS
DUnitResult Qualifier %Rec
Spike
Added
%Rec
Limits
Copper 96.3 101 mg/Kg 104 80 -120
Lead 96.3 92.5 mg/Kg 96 80 -120
Thallium 19.3 18.3 mg/Kg 95 80 -120
Uranium 96.3 96.5 mg/Kg 100 80 -120
Vanadium 96.3 101 mg/Kg 105 80 -120
Client Sample ID: Matrix SpikeLab Sample ID: 550-214278-H-6-B MS
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650466 Prep Batch: 649028
Arsenic 2.9 J 89.6 89.8 mg/Kg 97 75 -125☼
Analyte
MS MS
DUnitResult Qualifier %Rec
Spike
Added
Sample
Result
Sample
Qualifier
%Rec
Limits
Copper 22 89.6 107 mg/Kg 95 75 -125☼
Lead 8.1 89.6 102 mg/Kg 105 75 -125☼
Thallium ND 17.9 19.1 mg/Kg 107 75 -125☼
Uranium 0.83 89.6 99.2 mg/Kg 110 75 -125☼
Vanadium 45 89.6 128 mg/Kg 93 75 -125☼
Client Sample ID: Matrix Spike DuplicateLab Sample ID: 550-214278-H-6-C MSD
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650466 Prep Batch: 649028
Arsenic 2.9 J 102 104 mg/Kg 99 75 -125 14 30
☼
Analyte
MSD MSD
DUnitResult Qualifier %Rec
Spike
Added
Sample
Result
Sample
Qualifier
%Rec
Limits LimitRPD
RPD
Copper 22 102 125 mg/Kg 101 75 -125 15 30
☼
Lead 8.1 102 118 mg/Kg 108 75 -125 14 30
☼
Thallium ND 20.3 21.5 mg/Kg 106 75 -125 12 30☼
Uranium 0.83 102 112 mg/Kg 110 75 -125 12 30☼
Vanadium 45 102 159 mg/Kg 111 75 -125 21 30☼
Eurofins St. Louis
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QC Sample Results
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Method: 7471B - Mercury (CVAA)
Client Sample ID: Method BlankLab Sample ID: MB 160-649952/1-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650052 Prep Batch: 649952
RL MDL
Mercury ND 0.089 0.034 mg/Kg 02/27/24 09:45 02/27/24 14:02 1
MB MB
Analyte Dil FacAnalyzedPreparedDUnitResult Qualifier
Client Sample ID: Lab Control SampleLab Sample ID: LCS 160-649952/2-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650052 Prep Batch: 649952
Mercury 0.929 0.914 mg/Kg 98 80 -120
Analyte
LCS LCS
DUnitResult Qualifier %Rec
Spike
Added
%Rec
Limits
Client Sample ID: Matrix SpikeLab Sample ID: 160-53082-C-1-F MS
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650052 Prep Batch: 649952
Mercury ND F1 1.49 1.02 F1 mg/Kg 68 80 -120☼
Analyte
MS MS
DUnitResult Qualifier %Rec
Spike
Added
Sample
Result
Sample
Qualifier
%Rec
Limits
Client Sample ID: Matrix Spike DuplicateLab Sample ID: 160-53082-C-1-G MSD
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 650052 Prep Batch: 649952
Mercury ND F1 1.47 0.999 F1 mg/Kg 68 80 -120 2 30☼
Analyte
MSD MSD
DUnitResult Qualifier %Rec
Spike
Added
Sample
Result
Sample
Qualifier
%Rec
Limits LimitRPD
RPD
Method: GA-01-R - Radium-226 & Other Gamma Emitters (GS)
Client Sample ID: Method BlankLab Sample ID: MB 160-649025/1-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 652341 Prep Batch: 649025
Radium-226
Analyte
U 103/13/24 06:2302/21/24 11:07pCi/g0.235
MDC
1.00
RL
0.1330.133
(2σ+/-) (2σ+/-)
MB
-0.01544
MB
Dil FacPrepared AnalyzedUnitResult Qualifier
Uncert.
Count
Uncert.
Total
Client Sample ID: Lab Control SampleLab Sample ID: LCS 160-649025/2-A
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 652337 Prep Batch: 649025
Americium-241
Analyte
125-759691.6395.9 9.61 0.951
RL MDC(2σ+/-)
LCS LCS
pCi/g
UnitResult Qual %RecAdded
Spike
Limits
%RecUncert.
Total
Cesium-137 24.8 23.49 2.50 0.147 pCi/g 95 75 -125
Cobalt-60 6.18 6.022 0.682 0.0589 pCi/g 97 75 -125
Client Sample ID: SILV-1Lab Sample ID: 160-53183-1 DU
Matrix: Solid Prep Type: Total/NA
Analysis Batch: 652341 Prep Batch: 649025
Radium-226
Analyte
10.121.2901.24 0.221 1.00 0.119
RL MDC(2σ+/-)
DU DU
pCi/g
UnitResult Qual LimitResult
Sample Sample
Qual
Uncert.
Total
RER
RER
Eurofins St. Louis
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QC Association Summary
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Metals
Prep Batch: 649028
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid 3050B160-53183-1 SILV-1 Total/NA
Solid 3050B160-53183-2 BD-1 Total/NA
Solid 3050BMB 160-649028/1-A Method Blank Total/NA
Solid 3050BLCS 160-649028/2-A Lab Control Sample Total/NA
Solid 3050B550-214278-H-6-B MS Matrix Spike Total/NA
Solid 3050B550-214278-H-6-C MSD Matrix Spike Duplicate Total/NA
Prep Batch: 649952
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid 7471B160-53183-1 SILV-1 Total/NA
Solid 7471B160-53183-2 BD-1 Total/NA
Solid 7471BMB 160-649952/1-A Method Blank Total/NA
Solid 7471BLCS 160-649952/2-A Lab Control Sample Total/NA
Solid 7471B160-53082-C-1-F MS Matrix Spike Total/NA
Solid 7471B160-53082-C-1-G MSD Matrix Spike Duplicate Total/NA
Analysis Batch: 650052
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid 7471B 649952160-53183-1 SILV-1 Total/NA
Solid 7471B 649952160-53183-2 BD-1 Total/NA
Solid 7471B 649952MB 160-649952/1-A Method Blank Total/NA
Solid 7471B 649952LCS 160-649952/2-A Lab Control Sample Total/NA
Solid 7471B 649952160-53082-C-1-F MS Matrix Spike Total/NA
Solid 7471B 649952160-53082-C-1-G MSD Matrix Spike Duplicate Total/NA
Analysis Batch: 650466
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid 6020A 649028160-53183-1 SILV-1 Total/NA
Solid 6020A 649028160-53183-2 BD-1 Total/NA
Solid 6020A 649028MB 160-649028/1-A Method Blank Total/NA
Solid 6020A 649028LCS 160-649028/2-A Lab Control Sample Total/NA
Solid 6020A 649028550-214278-H-6-B MS Matrix Spike Total/NA
Solid 6020A 649028550-214278-H-6-C MSD Matrix Spike Duplicate Total/NA
General Chemistry
Analysis Batch: 648794
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid Moisture160-53183-1 SILV-1 Total/NA
Solid Moisture160-53183-2 BD-1 Total/NA
Solid Moisture160-53152-A-1 DU Duplicate Total/NA
Rad
Leach Batch: 648812
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid Dry and Grind160-53183-1 SILV-1 Total/NA
Solid Dry and Grind160-53183-2 BD-1 Total/NA
Solid Dry and Grind160-53183-1 DU SILV-1 Total/NA
Eurofins St. Louis
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QC Association Summary
Job ID: 160-53183-1Client: Richard B White, PE, PLLC
Project/Site: Silver Pointe Estates, Leeds, UT
Rad
Prep Batch: 649025
Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch
Solid Fill_Geo-21 648812160-53183-1 SILV-1 Total/NA
Solid Fill_Geo-21 648812160-53183-2 BD-1 Total/NA
Solid Fill_Geo-21MB 160-649025/1-A Method Blank Total/NA
Solid Fill_Geo-21LCS 160-649025/2-A Lab Control Sample Total/NA
Solid Fill_Geo-21 648812160-53183-1 DU SILV-1 Total/NA
Eurofins St. Louis
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ANALYTICAL REPORT
March 12, 2024
Richard B. White PE PLLC
Sample Delivery Group:L1706077
Samples Received:02/15/2024
Project Number:
Description:Silver Pointe VCP
Report To:David Bird / Richard B. White
13441 S. Lone Peak Lane
Draper, UT 840116
Entire Report Reviewed By:
March 12, 2024
[Preliminary Report]
John Hawkins
Project Manager
Results relate only to the items tested or calibrated and are reported as rounded values. This test report shall not be
reproduced, except in full, without written approval of the laboratory. Where applicable, sampling conducted by Pace
Analytical National is performed per guidance provided in laboratory standard operating procedures ENV-SOP-MTJL-0067 and
ENV-SOP-MTJL-0068. Where sampling conducted by the customer, results relate to the accuracy of the information provided,
and as the samples are received.
Pace Analytical National
12065 Lebanon Rd Mount Juliet, TN 37122 615-758-5858 800-767-5859 www.pacenational.com
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
Richard B. White PE PLLC L1706077 03/12/24 10:33 1 of 11
March 14, 2024
John Hawkins
Project Manager
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
Richard B. White PE PLLC L1706077 03/14/24 15:06 1 of 11
TABLE OF CONTENTS
Cp: Cover Page 1
Tc: Table of Contents 2
Ss: Sample Summary 3
Cn: Case Narrative 4
Sr: Sample Results 5
SILV-1-DEQ L1706077-01 5
Qc: Quality Control Summary 6
Total Solids by Method 2540 G-2011 6
Mercury by Method 7471A 7
Metals (ICPMS) by Method 6020 8
Gl: Glossary of Terms 9
Al: Accreditations & Locations 10
Sc: Sample Chain of Custody 11
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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SAMPLE SUMMARY
Collected by Collected date/time Received date/time
SILV-1-DEQ L1706077-01 Solid RBW 02/13/24 15:10 02/15/24 08:00
Method Batch Dilution Preparation Analysis Analyst Location
date/time date/time
Total Solids by Method 2540 G-2011 WG2227547 1 02/16/24 15:21 02/16/24 15:37 KDW Mt. Juliet, TN
Mercury by Method 7471A WG2228172 1 02/17/24 15:48 02/18/24 12:55 SDG Mt. Juliet, TN
Metals (ICPMS) by Method 6020 WG2227764 5 02/16/24 12:37 02/17/24 21:44 SJM Mt. Juliet, TN
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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CASE NARRATIVE
All sample aliquots were received at the correct temperature, in the proper containers, with the
appropriate preservatives, and within method specified holding times, unless qualified or notated within
the report. Where applicable, all MDL (LOD) and RDL (LOQ) values reported for environmental samples
have been corrected for the dilution factor used in the analysis. All Method and Batch Quality Control
are within established criteria except where addressed in this case narrative, a non-conformance form
or properly qualified within the sample results. By my digital signature below, I affirm to the best of my
knowledge, all problems/anomalies observed by the laboratory as having the potential to affect the
quality of the data have been identified by the laboratory, and no information or data have been
knowingly withheld that would affect the quality of the data.
[Preliminary Report]
John Hawkins
Project Manager
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
Richard B. White PE PLLC L1706077 03/12/24 10:33 4 of 11
John Hawkins
Project Manager
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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SAMPLE RESULTS - 01
L1706077
SILV-1-DEQ
Collected date/time: 02/13/24 15:10
Total Solids by Method 2540 G-2011
Result Qualifier Dilution Analysis Batch
Analyte %date / time
Total Solids 90.7 1 02/16/2024 15:37 WG2227547
Mercury by Method 7471A
Result Qualifier RDL Dilution Analysis Batch
Analyte mg/kg mg/kg date / time
Mercury 0.244 0.0400 1 02/18/2024 12:55 WG2228172
Metals (ICPMS) by Method 6020
Result Qualifier RDL Dilution Analysis Batch
Analyte mg/kg mg/kg date / time
Arsenic 2.09 1.00 5 02/17/2024 21:44 WG2227764
Copper 12.8 5.00 5 02/17/2024 21:44 WG2227764
Lead 4.35 2.00 5 02/17/2024 21:44 WG2227764
Thallium ND 2.00 5 02/17/2024 21:44 WG2227764
Uranium ND 15.0 5 02/17/2024 21:44 WG2227764
Vanadium 21.2 2.50 5 02/17/2024 21:44 WG2227764
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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QUALITY CONTROL SUMMARYWG2227547
Total Solids by Method 2540 G-2011 L1706077-01
Method Blank (MB)
(MB) R4034940-1 02/16/24 15:37
MB Result MB Qualifier MB MDL MB RDL
Analyte %%%
Total Solids 0.000
L1706034-07 Original Sample (OS) • Duplicate (DUP)
(OS) L1706034-07 02/16/24 15:37 • (DUP) R4034940-3 02/16/24 15:37
Original Result DUP Result Dilution DUP RPD DUP Qualifier DUP RPD
Limits
Analyte %%%%
Total Solids 81.2 81.0 1 0.330 10
Laboratory Control Sample (LCS)
(LCS) R4034940-2 02/16/24 15:37
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte %%%%
Total Solids 50.0 50.0 100 90.0-110
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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QUALITY CONTROL SUMMARYWG2228172
Mercury by Method 7471A L1706077-01
Method Blank (MB)
(MB) R4035106-1 02/18/24 12:07
MB Result MB Qualifier MB MDL MB RDL
Analyte mg/kg mg/kg mg/kg
Mercury U 0.0180 0.0400
Laboratory Control Sample (LCS)
(LCS) R4035106-2 02/18/24 12:14
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte mg/kg mg/kg %%
Mercury 0.500 0.500 100 80.0-120
L1706250-03 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1706250-03 02/18/24 12:16 • (MS) R4035106-3 02/18/24 12:19 • (MSD) R4035106-4 02/18/24 12:21
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte mg/kg mg/kg mg/kg mg/kg %%%%%
Mercury 0.500 ND 0.579 0.611 110 116 1 75.0-125 5.46 20
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
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QUALITY CONTROL SUMMARYWG2227764
Metals (ICPMS) by Method 6020 L1706077-01
Method Blank (MB)
(MB) R4035077-1 02/17/24 20:28
MB Result MB Qualifier MB MDL MB RDL
Analyte mg/kg mg/kg mg/kg
Arsenic U 0.100 1.00
Copper U 0.133 5.00
Lead U 0.0990 2.00
Thallium U 0.0650 2.00
Uranium U 0.0478 15.0
Vanadium U 0.187 2.50
Laboratory Control Sample (LCS)
(LCS) R4035077-2 02/17/24 20:31
Spike Amount LCS Result LCS Rec. Rec. Limits LCS Qualifier
Analyte mg/kg mg/kg %%
Arsenic 100 96.1 96.1 80.0-120
Copper 100 94.8 94.8 80.0-120
Lead 100 92.5 92.5 80.0-120
Thallium 100 90.6 90.6 80.0-120
Uranium 100 93.6 93.6 80.0-120
Vanadium 100 94.8 94.8 80.0-120
L1704561-01 Original Sample (OS) • Matrix Spike (MS) • Matrix Spike Duplicate (MSD)
(OS) L1704561-01 02/17/24 20:35 • (MS) R4035077-5 02/17/24 20:45 • (MSD) R4035077-6 02/17/24 20:48
Spike Amount Original Result MS Result MSD Result MS Rec. MSD Rec. Dilution Rec. Limits MS Qualifier MSD Qualifier RPD RPD Limits
Analyte mg/kg mg/kg mg/kg mg/kg %%%%%
Arsenic 100 ND 93.7 91.7 93.0 90.9 5 75.0-125 2.22 20
Copper 100 ND 89.3 88.6 87.6 86.9 5 75.0-125 0.848 20
Lead 100 ND 88.4 87.0 87.2 85.7 5 75.0-125 1.61 20
Thallium 100 ND 86.2 84.7 86.2 84.7 5 75.0-125 1.77 20
Uranium 100 ND 93.1 91.9 90.7 89.5 5 75.0-125 1.30 20
Vanadium 100 ND 92.4 90.9 92.1 90.6 5 75.0-125 1.72 20
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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GLOSSARY OF TERMS
Guide to Reading and Understanding Your Laboratory Report
The information below is designed to better explain the various terms used in your report of analytical results from the Laboratory. This is not
intended as a comprehensive explanation, and if you have additional questions please contact your project representative.
Results Disclaimer - Information that may be provided by the customer, and contained within this report, include Permit Limits, Project Name,
Sample ID, Sample Matrix, Sample Preservation, Field Blanks, Field Spikes, Field Duplicates, On-Site Data, Sampling Collection Dates/Times, and
Sampling Location. Results relate to the accuracy of this information provided, and as the samples are received.
Abbreviations and Definitions
MDL Method Detection Limit.
ND Not detected at the Reporting Limit (or MDL where applicable).
RDL Reported Detection Limit.
Rec.Recovery.
RPD Relative Percent Difference.
SDG Sample Delivery Group.
U Not detected at the Reporting Limit (or MDL where applicable).
Analyte The name of the particular compound or analysis performed. Some Analyses and Methods will have multiple analytes
reported.
Dilution
If the sample matrix contains an interfering material, the sample preparation volume or weight values differ from the
standard, or if concentrations of analytes in the sample are higher than the highest limit of concentration that the
laboratory can accurately report, the sample may be diluted for analysis. If a value different than 1 is used in this field, the
result reported has already been corrected for this factor.
Limits
These are the target % recovery ranges or % difference value that the laboratory has historically determined as normal
for the method and analyte being reported. Successful QC Sample analysis will target all analytes recovered or
duplicated within these ranges.
Original Sample The non-spiked sample in the prep batch used to determine the Relative Percent Difference (RPD) from a quality control
sample. The Original Sample may not be included within the reported SDG.
Qualifier
This column provides a letter and/or number designation that corresponds to additional information concerning the result
reported. If a Qualifier is present, a definition per Qualifier is provided within the Glossary and Definitions page and
potentially a discussion of possible implications of the Qualifier in the Case Narrative if applicable.
Result
The actual analytical final result (corrected for any sample specific characteristics) reported for your sample. If there was
no measurable result returned for a specific analyte, the result in this column may state “ND” (Not Detected) or “BDL”
(Below Detectable Levels). The information in the results column should always be accompanied by either an MDL
(Method Detection Limit) or RDL (Reporting Detection Limit) that defines the lowest value that the laboratory could detect
or report for this analyte.
Uncertainty
(Radiochemistry)Confidence level of 2 sigma.
Case Narrative (Cn)
A brief discussion about the included sample results, including a discussion of any non-conformances to protocol
observed either at sample receipt by the laboratory from the field or during the analytical process. If present, there will
be a section in the Case Narrative to discuss the meaning of any data qualifiers used in the report.
Quality Control
Summary (Qc)
This section of the report includes the results of the laboratory quality control analyses required by procedure or
analytical methods to assist in evaluating the validity of the results reported for your samples. These analyses are not
being performed on your samples typically, but on laboratory generated material.
Sample Chain of
Custody (Sc)
This is the document created in the field when your samples were initially collected. This is used to verify the time and
date of collection, the person collecting the samples, and the analyses that the laboratory is requested to perform. This
chain of custody also documents all persons (excluding commercial shippers) that have had control or possession of the
samples from the time of collection until delivery to the laboratory for analysis.
Sample Results (Sr)
This section of your report will provide the results of all testing performed on your samples. These results are provided
by sample ID and are separated by the analyses performed on each sample. The header line of each analysis section for
each sample will provide the name and method number for the analysis reported.
Sample Summary (Ss)This section of the Analytical Report defines the specific analyses performed for each sample ID, including the dates and
times of preparation and/or analysis.
Qualifier Description
The remainder of this page intentionally left blank, there are no qualifiers applied to this SDG.
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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Pace Analytical National 12065 Lebanon Rd Mount Juliet, TN 37122
Alabama 40660 Nebraska NE-OS-15-05
Alaska 17-026 Nevada TN000032021-1
Arizona AZ0612 New Hampshire 2975
Arkansas 88-0469 New Jersey–NELAP TN002
California 2932 New Mexico ¹TN00003
Colorado TN00003 New York 11742
Connecticut PH-0197 North Carolina Env375
Florida E87487 North Carolina ¹DW21704
Georgia NELAP North Carolina ³41
Georgia ¹923 North Dakota R-140
Idaho TN00003 Ohio–VAP CL0069
Illinois 200008 Oklahoma 9915
Indiana C-TN-01 Oregon TN200002
Iowa 364 Pennsylvania 68-02979
Kansas E-10277 Rhode Island LAO00356
Kentucky ¹ ⁶KY90010 South Carolina 84004002
Kentucky ²16 South Dakota n/a
Louisiana AI30792 Tennessee ¹ ⁴2006
Louisiana LA018 Texas T104704245-20-18
Maine TN00003 Texas ⁵LAB0152
Maryland 324 Utah TN000032021-11
Massachusetts M-TN003 Vermont VT2006
Michigan 9958 Virginia 110033
Minnesota 047-999-395 Washington C847
Mississippi TN00003 West Virginia 233
Missouri 340 Wisconsin 998093910
Montana CERT0086 Wyoming A2LA
A2LA – ISO 17025 1461.01 AIHA-LAP,LLC EMLAP 100789
A2LA – ISO 17025 ⁵1461.02 DOD 1461.01
Canada 1461.01 USDA P330-15-00234
EPA–Crypto TN00003
ACCREDITATIONS & LOCATIONS

¹ Drinking Water ² Underground Storage Tanks ³ Aquatic Toxicity ⁴ Chemical/Microbiological ⁵ Mold ⁶ Wastewater n/a Accreditation not applicable
* Not all certifications held by the laboratory are applicable to the results reported in the attached report.
* Accreditation is only applicable to the test methods specified on each scope of accreditation held by Pace Analytical.
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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Richard B. White PE PLLC L1706077 03/14/24 15:06 10 of 11
ANALYTICAL REPORT
March 14, 2024
Richard B. White PE PLLC
Sample Delivery Group:L1706079
Samples Received:02/15/2024
Project Number:
Description:Silver Pointe VCP
Report To:David Bird / Richard B. White
13441 S. Lone Peak Lane
Draper, UT 840116
Entire Report Reviewed By:
March 14, 2024
[Preliminary Report]
John Hawkins
Project Manager
Results relate only to the items tested or calibrated and are reported as rounded values. This test report shall not be
reproduced, except in full, without written approval of the laboratory. Where applicable, sampling conducted by Pace
Analytical National is performed per guidance provided in laboratory standard operating procedures ENV-SOP-MTJL-0067 and
ENV-SOP-MTJL-0068. Where sampling conducted by the customer, results relate to the accuracy of the information provided,
and as the samples are received.
Pace Analytical National
12065 Lebanon Rd Mount Juliet, TN 37122 615-758-5858 800-767-5859 www.pacenational.com
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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March 14, 2024
John Hawkins
Project Manager
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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TABLE OF CONTENTS
Cp: Cover Page 1
Tc: Table of Contents 2
Ss: Sample Summary 3
Cn: Case Narrative 4
Sr: Sample Results 5
SILV-1-DEQ L1706079-01 5
Qc: Quality Control Summary 6
Radiochemistry by Method DOE Ga-01-R/901.1 (21 day) 6
Gl: Glossary of Terms 7
Al: Accreditations & Locations 8
Sc: Sample Chain of Custody 9
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SAMPLE SUMMARY
Collected by Collected date/time Received date/time
SILV-1-DEQ L1706079-01 Solids and Chemical Materials RBW 02/13/24 15:10 02/15/24 08:00
Method Batch Dilution Preparation Analysis Analyst Location
date/time date/time
Radiochemistry by Method DOE Ga-01-R/901.1 (21 day)WG2237769 1 02/21/24 08:28 03/13/24 08:46 ZRG Mt. Juliet, TN
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CASE NARRATIVE
All sample aliquots were received at the correct temperature, in the proper containers, with the
appropriate preservatives, and within method specified holding times, unless qualified or notated within
the report. Where applicable, all MDL (LOD) and RDL (LOQ) values reported for environmental samples
have been corrected for the dilution factor used in the analysis. All radiochemical sample results for
solids are reported on a dry weight basis with the exception of tritium, carbon-14 and radon, unless wet
weight was requested by the client. All Method and Batch Quality Control are within established
criteria except where addressed in this case narrative, a non-conformance form or properly qualified
within the sample results. By my digital signature below, I affirm to the best of my knowledge, all
problems/anomalies observed by the laboratory as having the potential to affect the quality of the data
have been identified by the laboratory, and no information or data have been knowingly withheld that
would affect the quality of the data.
[Preliminary Report]
John Hawkins
Project Manager
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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John Hawkins
Project Manager
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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SAMPLE RESULTS - 01
L1706079
SILV-1-DEQ
Collected date/time: 02/13/24 15:10
Radiochemistry by Method DOE Ga-01-R/901.1 (21 day)
Result Qualifier 2 sigma CE TPU MDA Lc Analysis Date Batch
Analyte pCi/g + / -+ / - pCi/g pCi/g date / time
Actinium-228 (Ra-228)0.947 0.203 0.203 0.310 0.139 03/13/2024 08:46 WG2237769
Bismuth-214 (Ra-226)1.68 0.205 0.205 0.162 0.0732 03/13/2024 08:46 WG2237769
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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QUALITY CONTROL SUMMARYWG2237769
Radiochemistry by Method DOE Ga-01-R/901.1 (21 day)L1706079-01
Method Blank (MB)
(MB) R4045591-1 03/13/24 12:45
MB Result MB Qualifier MB 2 sigma CE MB MDA MB Lc
Analyte pCi/g + / - pCi/g pCi/g
Actinium-228 (Ra-228) 0.104 U 0.0875 0.238 0.0900
Americium-241 0.116 J 0.135 0.243 0.111
Bismuth-214 (Ra-226) 0.0197 U 0.0668 0.142 0.0577
Cesium-137 0.0453 J 0.0369 0.0610 0.0230
Cobalt-60 0.0329 U 0.0290 0.0837 0.0298
L1707215-01 Original Sample (OS) • Duplicate (DUP)
(OS) L1707215-01 03/14/24 08:37 • (DUP) R4045591-4 03/14/24 09:49
Original Result Original 2
sigma CE Original MDA Original Lc DUP Result DUP 2 sigma
CE DUP MDA DUP Lc DUP RPD DUP RER DUP Qualifier DUP RPD
Limits DUP RER Limit
Analyte pCi/g + / - pCi/g pCi/g pCi/g + / - pCi/g pCi/g %%
Actinium-228 (Ra-228) 0.227 0.102 0.192 0.0821 0.183 0.0817 0.157 0.0660 21.4 0.336 20 3
Americium-241 0.0312 0.0677 0.115 0.0531 200 0.988 U 20 3
Bismuth-214 (Ra-226) 0.108 0.0650 0.120 0.0534 0.125 0.0511 0.0711 0.0300 14.2 0.200 20 3
Cesium-137 -0.0199 0.0214 0.0494 0.0215 200 0.967 U 20 3
Cobalt-60 0.0111 0.0133 0.0441 0.0169 200 1.38 U 20 3
Laboratory Control Sample (LCS) • Laboratory Control Sample Duplicate (LCSD)
(LCS) R4045591-2 03/13/24 12:46 • (LCSD) R4045591-3 03/13/24 13:44
Spike Amount LCS Result LCSD Result LCS Rec. LCSD Rec. Rec. Limits LCS Qualifier LCSD Qualifier RPD RPD Limits
Analyte pCi/g pCi/g pCi/g %%%%%
Americium-241 47.3 48.3 52.1 102 110 75.0-125 7.53 20
Cesium-137 72.4 80.2 81.2 111 112 80.0-120 1.33 20
Cobalt-60 86.9 92.7 91.5 107 105 80.0-120 1.29 20
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GLOSSARY OF TERMS
Guide to Reading and Understanding Your Laboratory Report
The information below is designed to better explain the various terms used in your report of analytical results from the Laboratory. This is not
intended as a comprehensive explanation, and if you have additional questions please contact your project representative.
Results Disclaimer - Information that may be provided by the customer, and contained within this report, include Permit Limits, Project Name,
Sample ID, Sample Matrix, Sample Preservation, Field Blanks, Field Spikes, Field Duplicates, On-Site Data, Sampling Collection Dates/Times, and
Sampling Location. Results relate to the accuracy of this information provided, and as the samples are received.
Abbreviations and Definitions
MDA Minimum Detectable Activity.
Rec.Recovery.
RER Replicate Error Ratio.
RPD Relative Percent Difference.
SDG Sample Delivery Group.
Analyte The name of the particular compound or analysis performed. Some Analyses and Methods will have multiple analytes
reported.
Limits
These are the target % recovery ranges or % difference value that the laboratory has historically determined as normal
for the method and analyte being reported. Successful QC Sample analysis will target all analytes recovered or
duplicated within these ranges.
Original Sample The non-spiked sample in the prep batch used to determine the Relative Percent Difference (RPD) from a quality control
sample. The Original Sample may not be included within the reported SDG.
Qualifier
This column provides a letter and/or number designation that corresponds to additional information concerning the result
reported. If a Qualifier is present, a definition per Qualifier is provided within the Glossary and Definitions page and
potentially a discussion of possible implications of the Qualifier in the Case Narrative if applicable.
Result
The actual analytical final result (corrected for any sample specific characteristics) reported for your sample. If there was
no measurable result returned for a specific analyte, the result in this column may state “ND” (Not Detected) or “BDL”
(Below Detectable Levels). The information in the results column should always be accompanied by either an MDL
(Method Detection Limit) or RDL (Reporting Detection Limit) that defines the lowest value that the laboratory could detect
or report for this analyte.
Uncertainty
(Radiochemistry)Confidence level of 2 sigma.
Case Narrative (Cn)
A brief discussion about the included sample results, including a discussion of any non-conformances to protocol
observed either at sample receipt by the laboratory from the field or during the analytical process. If present, there will
be a section in the Case Narrative to discuss the meaning of any data qualifiers used in the report.
Quality Control
Summary (Qc)
This section of the report includes the results of the laboratory quality control analyses required by procedure or
analytical methods to assist in evaluating the validity of the results reported for your samples. These analyses are not
being performed on your samples typically, but on laboratory generated material.
Sample Chain of
Custody (Sc)
This is the document created in the field when your samples were initially collected. This is used to verify the time and
date of collection, the person collecting the samples, and the analyses that the laboratory is requested to perform. This
chain of custody also documents all persons (excluding commercial shippers) that have had control or possession of the
samples from the time of collection until delivery to the laboratory for analysis.
Sample Results (Sr)
This section of your report will provide the results of all testing performed on your samples. These results are provided
by sample ID and are separated by the analyses performed on each sample. The header line of each analysis section for
each sample will provide the name and method number for the analysis reported.
Sample Summary (Ss)This section of the Analytical Report defines the specific analyses performed for each sample ID, including the dates and
times of preparation and/or analysis.
Qualifier Description
J The identification of the analyte is acceptable; the reported value is an estimate.
U Below Detectable Limits: Indicates that the analyte was not detected.
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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Pace Analytical National 12065 Lebanon Rd Mount Juliet, TN 37122
Alabama 40660 Nebraska NE-OS-15-05
Alaska 17-026 Nevada TN000032021-1
Arizona AZ0612 New Hampshire 2975
Arkansas 88-0469 New Jersey–NELAP TN002
California 2932 New Mexico ¹TN00003
Colorado TN00003 New York 11742
Connecticut PH-0197 North Carolina Env375
Florida E87487 North Carolina ¹DW21704
Georgia NELAP North Carolina ³41
Georgia ¹923 North Dakota R-140
Idaho TN00003 Ohio–VAP CL0069
Illinois 200008 Oklahoma 9915
Indiana C-TN-01 Oregon TN200002
Iowa 364 Pennsylvania 68-02979
Kansas E-10277 Rhode Island LAO00356
Kentucky ¹ ⁶KY90010 South Carolina 84004002
Kentucky ²16 South Dakota n/a
Louisiana AI30792 Tennessee ¹ ⁴2006
Louisiana LA018 Texas T104704245-20-18
Maine TN00003 Texas ⁵LAB0152
Maryland 324 Utah TN000032021-11
Massachusetts M-TN003 Vermont VT2006
Michigan 9958 Virginia 110033
Minnesota 047-999-395 Washington C847
Mississippi TN00003 West Virginia 233
Missouri 340 Wisconsin 998093910
Montana CERT0086 Wyoming A2LA
A2LA – ISO 17025 1461.01 AIHA-LAP,LLC EMLAP 100789
A2LA – ISO 17025 ⁵1461.02 DOD 1461.01
Canada 1461.01 USDA P330-15-00234
EPA–Crypto TN00003
ACCREDITATIONS & LOCATIONS

¹ Drinking Water ² Underground Storage Tanks ³ Aquatic Toxicity ⁴ Chemical/Microbiological ⁵ Mold ⁶ Wastewater n/a Accreditation not applicable
* Not all certifications held by the laboratory are applicable to the results reported in the attached report.
* Accreditation is only applicable to the test methods specified on each scope of accreditation held by Pace Analytical.
1 Cp
2 Tc
3 Ss
4 Cn
5 Sr
6 Qc
7 Gl
8 Al
9 Sc
ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
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ACCOUNT:PROJECT:SDG:DATE/TIME:PAGE:
Richard B. White PE PLLC L1706079 03/14/24 15:06 8 of 9
Gary Crocker
March 28, 2024
Page 13

ATTACHMENT F

Revised Site Inspection Form

Site Inspection Form Page 1 Silver Pointe Estates

SITE INSPECTION FORM
Silver Pointe Estates Phase I Development
Leeds, Utah

Area Point of Observation Yes No
Soil Repository Does the surrounding fence serve as an effective barrier to human entrance?
Is the riprap cover continuous across the top of the repository?
Is there evidence of deep-rooted vegetation (i.e. shrubs and trees) growing on
the surface of the repository?
Is there evidence of animal burrows (greater than 6 inches deep) in the
repository?
Is there evidence of runoff from the cover of the repository to areas outside of
the fence?
Is the perimeter berm effective in preventing off-site drainage from flowing onto
the repository?
Is there evidence of off-site wind-blown material accumulating on the
repository or adjacent areas?
Is there evidence of any other disturbance that might affect the integrity of the
site?
Large Headframe Does the surrounding fence serve as an effective barrier to human entrance?
Is the riprap and gravel cover continuous across the top and sides of the
headframe area?
Is there evidence of deep-rooted vegetation growing on the surface of the
headframe area?
Is there evidence of animal burrows (greater than 6 inches deep) inside the
fence line?
Do the diversion channels effectively prevent runoff from flowing onto the
headframe cover from adjacent areas?
Is there evidence of runoff from the cover of the headframe area to areas
outside of the fence?
Is there evidence of any other disturbance that might affect the integrity of the
site?
Small Headframe Is the riprap cover continuous across the top and sides of the headframe area?
Is there evidence of deep-rooted vegetation growing on the surface of the
headframe area?

Is there evidence of animal burrows (greater than 6 inches deep) through the
headframe cover?

Do the diversion channels effectively prevent runoff from flowing onto the
headframe cover from adjacent areas?
Is there evidence of runoff from the cover of the headframe area to areas
outside of the berm?
Is there evidence of failure of the riprap in the channel adjacent to the
headframe?
Is there evidence of any other disturbance that might affect the integrity of the
site?
General Site
Conditions
Has soil excavated from general site development been properly sampled and
handled?
Has soil excavated from individual lot development been properly sampled and
handled?
Is there evidence that groundwater beneath the Phase I area is being used for
drinking water, irrigation, or bathing?
Is there evidence that the surface of the soil repository, the large headframe,
or the small headframe is being used for any purpose other than open space?
Is a minimum of 6 inches of uncontaminated soil maintained over areas shown
on Plate 1 as requiring such a cover?
Is the sign posted at the entrance to the mine adit still in place?
Is there evidence of other disturbance in the Phase I area that could affect
human health?

Site Inspection Form Page 2 Silver Pointe Estates

Comments (Provide details regarding deficiencies discovered, remedies used to address deficiencies, documentation
of corrective actions, etc. Add pages and photographs as appropriate):

Inspector: ________________________________
Signature

________________________________
Printed Name

________________________________
Title

________________________________
Date

Conduct inspections annually. Send the completed form within 10 business days of the inspection to:

Utah Division of Environmental Response and Remediation
Voluntary Cleanup Program
195 North 1950 West
P.O. Box 144840
Salt Lake City, UT 84114-4840
Phone: [phone]
Gary Crocker
March 28, 2024
Page 14

ATTACHMENT G

Figures 8 and 9 from 2016 Remedial Action Report