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HomeMy WebLinkAbout20241330.tiffJ&T Consulting, Inc. May 21, 2024 Mr. Rob Zuber Environmental Protection Specialist State of Colorado Division of Reclamation, Mining, and Safety Physical Address: 1313 Sherman Street, Room 215 Denver. CO 80203 Mailing Address: Division of Reclamation, Mining and Safety, Room 215 1001 East 62nd Avenue Denver, CO 80216 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025, 112c Permit Application, Second Adequacy Review Dear Mr. Zuber, VVW Clyde & Co. (VVW Clyde) has received the Division's Second Adequacy Review letter dated April 17, 2024. Below are the comments and the corresponding responses that we have provided to address the comments. Comments 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land 3) The South Platte River must be shown and labeled on maps C-1 and C-2, per Rule 6.4.3(b). No additional response required, but it is suggested that the symbology and legend on the maps in Exhibit C be improved. The same symbol is used for the dewatering trench and the edge of the river; this is confusing. Also, the term "Edge of River" is not clear; should it be "West Bank" instead? The 400 -foot setback is not included in the legend. Response: Acknowledged. See updated maps. 6.4.4 Exhibit D - Mining Plan 4) Please discuss if processing will entail washing of the product and if a pond or ponds will be included in the process area. If so, add a discussion to the text of Exhibit D and to Map C-2. The Direction of Mining arrows on Map C-2 imply that mining will occur in the area where the Sediment Pond and Clearwater Pond will be constructed. Please explain in Exhibit D if these ponds will be constructed after this area is mined and how that impacts the process of washing material. Will the ponds need to be constructed twice during the life of the mine? Response: The ponds will be constructed once and the area will be mined at the R071,ic.,-Rtuiao '1,1 vet cc PL(Ex 1Wu: DADRIMK) , 7k> CtMICA<lvvtt*ifSB) el Z`6 )2- L{ 2024-1330 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application. Second Adequacy Review May 21, 2024 -2- end of the mining when no washing will be occurring once the final mining is completed with the final reclamation. 6) Exhibit D needs to include a discussion of stabilization of topsoil stockpiles (Rule 3 1 9(3 )) It does not appear that this text was added to Exhibit D. (It does appear that the text for Item #5 was added twice.) Please revise Exhibit D to discuss stabilization of topsoil stockpiles. Response: See updated Exhibit D with the following text: "For topsoil stockpiles, the stabilization includes roughening to help with wind erosion as well as re - vegetating with appropriate seed mixes to minimize erosion and establish more rapidly to stabilize the stockpiles. If a stockpile remains more than one growing season, it will be seeded with the seed mix as recommended by the DRMS and in the reclamation plan in Exhibit E" with cyan highlighting. 7) Exhibit D should include a discussion of the structures that will be constructed for the mining operation, including buildings and roads. The discussion must include dimensions and general construction methods. (For example, will foundations include rebar reinforcement?) The text needs to include dimensions for the concrete pads that will serve as foundations for the scale and scale house. Response: See updated Exhibit D with the following text: "The scale house will be founded on typical trailer type jacks and tiedowns on top of concrete pads that are typically 2 feet x 2 feet x 1.5 feet deep with minimal rebar to provide reinforcement. The scale will also be founded on concrete pads with reinforcement where load cells are located for the scale, these are typically 12' long by 3 feet wide and 3 feet deg . These foundations would be removed once the pit is fully mined" with cyan lighfing. 6.4.7 Exhibit G - Water Information 16) The McGrane report and associated conclusions will be reviewed by a groundwater hydrologist with the Division, and an additional adequacy letter will be sent in October or November 2023. Please see the enclosure with a review by a Division Groundwater Hydrologist, Patrick Lennberg. Response: Acknowledged. See below responses for Groundwater Review Memo. 17) To ensure that the Bernhardt Pit does not impact the hydrologic balance of the river, the application needs to include a water quality monitoring plan, specifically for the alluvium. The groundwater monitoring plan should be developed in accordance with Rule 3.1.7(7)(b) and should include a Quality Assurance Project Plan (QAPP) for the collection of groundwater samples. The plan should provide mitigation steps if there is an exceedance at a groundwater or surface water monitoring location. Potential impacts to quality and/or quantity of nearby domestic wells should also be addressed. A copy of the Division's enclosure to this letter for your reference. Please see the enclosure with a review by a Division Groundwater Hydrologist. Patrick Lennberg. Vi 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE • Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21, 2024 -3- Response: Acknowledged. See below responses for Groundwater Review Memo. 6.4.8 Exhibit H — Wildlife Information 19) The applicant must address the comments of the Colorado Parks and Wildlife Division (CPW), which are enclosed with this review letter. Each of the comments must be directly addressed in your response letter, and, as applicable, comments must also be addressed by revising Exhibit H. Where necessary, add commitments for future studies or other actions. Note that CPW recommends a setback from the river of 500 feet. While this would be preferable in the context of wildlife protection. the Division believes that the 400 -foot setback described in Exhibit G, above, is sufficient. Please consider the 400 -foot option to protect wildlife as well as protect the riverbanks from erosion. The Division has consulted with Colorado Parks and Wildlife, and we are requiring that another raptor survey be conducted prior to mobilization of earth -moving equipment or excavation at the site. In Exhibit H, please commit to conduction this survey and providing the results to the Division. These results need be submitted to the Division as a Technical Revision and submitted at least 30 days prior to mobilization of earth -moving equipment or excavation. Response: WW Clyde commit to conducting a raptor survey prior to mobilization of earth -moving equipment or excavation at the site. The survey will be conducted and results submitted to the DRMS as a technical revision 30 days prior to mobilization of earth -moving equipment or excavation. (See highlighted text in updated Exhibit H withryan highlighting) 6.5 Geotechnical Stability Exhibit DRMS is reviewing the geotechnical analysis and our comments will be sent in October or November 2023. DRMS is reviewing the geotechnical analysis and responses. Our comments will be sent under separate cover. Response: Acknowledged. Also, the Division will be working on the reclamation cost estimate in the near future and will be in touch with questions. Response: Acknowledged. Groundwater Review Memo No. 2 1 The Applicant proposes to only collect groundwater samples from two locations, one downgradient and one upgradient. The Applicant will need to expand groundwater sampling to include all four monitoring well locations to demonstrate that existing and reasonably potential future uses of groundwater are protected (Rule 3.1.7(8)) and no unauthorized release of pollutants to groundwater shall occur from any materials mined. handled, or disposed of within the permit area (Rule 3.1.5(11)). Response: The sampling plan has been updated to include all the monitor wells. 2. Pursuant to Rule 3.1.7(7)(b)(ii) and (iv), please provide the method of well sampling and a description of the quality control and quality assurance methods (e.g., duplicate samples, rinsate samples) to be used during groundwater sampling. VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE: Bernhardt Sand and Gravel Pit. File No. M-2023-025 112c Permit Application. Second Adequacy Review May 21, 2024 -4- Response: The sampling plan has been updated to include the methods as well as the quality control and quality assurance methods to be used during groundwater sampling. See the updated text in Exhibit G with cyan highlighting. 3. Please commit to providing the quarterly groundwater monitoring results along with the monthly groundwater level measurements by the following deadlines: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report should, at a minimum. include a site map with well locations, tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified, and graphs and tables of measured groundwater levels for all locations. The Applicant should be prepared to submit field sheets that demonstrate monitoring wells were purged and sampled according to the approved plan. At the end of five quarters, the Applicant may submit a Technical Revision to reduce the analyte list and frequency of monitoring with sufficient justification. Response: WW Clyde commits to providing the quarterly reporting as stated. 4. Please commit to establishing a point(s) of compliance following five (5) quarters of baseline monitoring in accordance with Rule 3.1.7(6). Response: WW Clyde commits to establishing points of compliance following five quarters of baseline monitoring. Monitor Well 3 located on the west side of the permit boundary will be used as a background water quality sampling location and the remaining three monitoring wells as points of compliance (POC), the POCs will be Monitor Wells 1, 2, and 4. See the updated Exhibit G and updated text with cyan highlighting. 5. Exhibit G needs to be updated with a discussion of mitigation measures regarding groundwater mounding approaching the surface. Include in the discussion triggers for the initiation of mitigation measures. Response: The first mitigation measure will be the construction of a groundwater drain as detailed in the McGrane response attached. The design and construction of the groundwater drain will be at the same time the slurry wall design and construction are completed so there will be minimal affect on the groundwater elevations. The drain will be constructed to a depth deep enough to control groundwater mounding from surfacing. Stop logs will be used to control groundwater elevations such that the drain does not drop the elevation to much or raise the elevation where mounding could occur. The trigger points would be levels of plus or minus 2 feet of difference from the baseline seasonal groundwater levels in MW -1 through MW -4 where stop log elevations could be adjusted to either lower or raise groundwater levels to their historic seasonal elevations. See the updated Exhibit G and updated text with a VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21. 2024 -5- cyan highlighting. 6. Please clarify whether or not the results presented in the SGS table are total or dissolved. Response: The results are dissolved for the metals. Groundwater Model Review 7. The Division was not able to review Attachment 11 - McGrane Groundwater Model Update and Responses, as it appears it was not included with the adequacy review responses. Please submit the missing attachment. Response: The McGrane response is attached. WW Clyde appreciates your consideration of this adequacy review response. Please feel free to contact me with any questions or comments. Sincerely, J.C. York, P.E. J&T Consulting, Inc. Attachments: 1. Updated Exhibit C-1, C-2, F-1 and F-2 Maps 2. Updated Exhibit D 3. Updated Exhibit G 4. Updated Groundwater Monitor Well Readings 5. Updated Groundwater Quality Testing Readings 6. McGrane Groundwater Model Update and Responses 7. Updated Exhibit H V1 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 1 D C -76 4/ A ,/ . -/// / ��/ / �, s ,, e „/ . i/_ - o // - tI ,. T / 5' nr ...Sat It, %ubu • 1$311.M1 I MW_ PUBLIC SERVICE COMP LAT: N40.303936 LONG: W104.834394 '—s!/At; t• ' POWER POLES/LINES / A w. .MMO -- �ia i-.IMM• POC ENERGY, INC. OIL/GAS WELL l r" ----JOHNNY 1" PLUGGED AND ABANDONED UNION PACIFIC RAILROAD RAIL LINES CURE TON/GILCREST MIDSTREAM Olt/GAS LINE .(DISCONNECTED) MW -3 LAT 1440.301151 LONG. W104.838891 W.W. CLYDE/HIDDEN PLATTE RANCH FENCE PDC ENERGY, INC. • OIL/GAS WELL CJENNIFER PLUGGED AND ABANDONED CURETON/GILCREST MIDSTREAM O1[/GAS TINE (DISCONNECTED1/ I L / W.W. LYDE / DIRT OAD / C ifaL/ W.W CLYDE WATER PUMPS / / / / 417J y • / 4 / . N ajur -ale a Sal ENERGYt. IIL/GAS LINE / —L1 // w / I / KRISTIN 1" PLUCIGED AND ABANDONED/ b / / i, W.W. CLYDE ELECfRI/ 7 fr / { 1 (ABANDONED) Ime -110a— • / IN...7NPDC ENERGY. INC. o OIL/GAS WELL / "BERNHARDT 24C" PLUGGED AND ABANDONED / G H — re ICI' //I 1 j /r III ,T' I .I0II I CHEVRON/ \� --Xis.. `i NOBLE MIDSTREAM c , 9 / •� PDO ENERGY, INC. ,� .OIL/GAS WELL f ‘A \\l\II OIL/GAS LINE • / CHEVRON/ NOBLE MIDSTREAM / OIL/GAS LINE DCP MIDSTREAM OIL/GAS LINE TO BE RELOCATED OUTSIDE OF MINING AREA CURETON/GILCREST MIDSTREAM OIL/GAS LINE (ABANDONED) DCP MIDSTREAM Call/GAS LINE L MW -2 LAT. N40.301374 LONG *104.830132 1 I I , CURETON/Gn.CREST iII I MIDSTREAM 4 I I' OIL/GAS LINE 141 1 If 4 1 I 4 719 CURETON/GILCREST MIDSTREAM OIL/GAS UNE (ABANDONED) PDC ENERGY, INC. OIL/GAS WELL SARAH 1' / PLUGGED MID ABANDONED 400F7 (MIN.)Thi SETK FROM RR W.W. CLYDE/HIDDEN PLATT/NCH FENCE DCP MI EAU OIL/ INE impale ittr MW -4 UV: N40 297884 LONG: W104.834826 200 100 0 200 J A uy kWEST r/ B BANK OF l• RNFR e % / 4' 7 _ Q' nom. 400 C 800 i _ 4 SCALE IN FEET B I I V A I 1 LEGEND: - 5280 - - - - - Of L , EXISTING CONTOURS PROPERTY LINE EXISTING EXISTING EXISTING EXISTING EXISTING EXISTING EXISTING FENCE ROADS OVERHEAD ELECTRIC UNDERGROUND ELECTRIC POWER POLE OIL/GAS LINE RIGHT -OF- WAY a a ant _ �alD A PROPERTY OWNERS WITHIN 200 FEET MAP ID NAME/ADDRESS ASSESSORS ID NO. A B C PUBLIC SERVICE COMPANY OF COLORADO 105924000019 TAX SERVICE DEPARTMENT PO BOX 1979 DENVER, CO 80201-1979 HALFLICHT LAND & MINERALS, LLC 4420 SUMAC LANE LITTLETON. CO 80123-2743 HIDDEN PLATTE RANCH, LLC PO BOX 331 MILLIKEN, CO 80543-0331 D CHERYL KASTEN KAREN CURRIER CARLENE STROH 511 N SHOLDT DRNE PLATTEVILLE. CO 80651-7583 105729100002 105924000039 105924000036 VEGETATION: ALL AREAS 'S •'ERMI1 BOUNDARY ARE CURRENTLY AGRCULIUNAL :;HUN AhL PASTURE LAND NOTE W.W. CLYDE & CO. IS THE SURFACE AND SUBSURFACE OWNER WITHIN THE PERMIT AREA SECTION LINE EXISTING 100 YR FLOODPLAIN EXISTING 100 YR FLOODWAY PERMIT BOUNDARY MINING LIMIT WEST BANK OF RNER 400FT SETBACK FROM RIVER BANi SLURRY WALL DEWATERING TRENCH STOCKPILE AREA PROPERTY OWNER MAP ID • Oti O C .r yr tqfTGi c mac � C w tc-� y r gg t U E ca on Bernhardt Sand And Gravel Pit Exhibit Cl - Pre -Mining Plan Map W.W. Clyde & Co. REVISIONS I d Y r, U Ji T Consulate, Inc. Ark __ s. I` RAN.? • -+rr Mrs As Shown Sheet: 1 2 1; i t dab air • .` / 1 S. • • MW -3 LAT N4O.3O1151 LONG: W1O4.838891 • rJr __ i // - -_-�- • / • LA i: N4U.3O3S3b / 0 LONG. w104.834394 i �, ♦ ACCESS 30 FT WIDE ROAD / . I --- 50 FT WIDE ACCESS. SCALE. TAFtPINC ROAD SCALE v I CLEARWATER POND FOR RECYCLE WATER TO WASH PLANT SEDIMENT POND FOR WASH WATER FROM PLANT HOUSE AND SCALE / PROCESSING AND PRODUCT STOCKPILES cC> DIRECTION OF MINING / • I / i ,/ / / / w/ 4 /T / / a DIRECTION OF MINING 4%.-�.� .rte �LI�.L MW -4 LAT: N4O.297684 LONG: *104.834826 200 100 V / I in .-ANTI S. ISIIrII I ,t:IY', _"T • V OFFSITE ACCESS ROAD c= DIRECTION OF MINING 4OOFT (MIN.) SETBACK FROM RIVER PERMIT AREA = 111.01 AC MINING AREA = 98.24 AC 200 1 SLA:i IN FEE ' C) / % Y • / / MW -2 LAI N40.301374 LONG: *104.830132 8 DEWATERING TRENCH �. d / / . . . S. • • • / I t � � r ) Ili /N_ WEST BANK ,/ / I I OF RIVER V�Q � tic COO a. ytk • / 1 / 1 / r / F LEGEND: a L tua f— EOGE OF RIVER PERMfT aDUNDWRY EXISTING _ mum)\ EXISTING CONTOURS PROPERTY LINE EXISTING FENCE EXISTING ROADS EXISTING OVERHEAD ELECTRIC EXISTING UNDERGROUND ELECTRIC EXISTING POWER POLE EXISTING OIL/GAS LINE EXISTING RIGHT-OF-WAY 40W? (Wt) IY A SECTION LINE EXISTING 100 YR FLOODPLAIN EXISTING 1OO YR FLOODWAY PERMIT BOUNDARY MINING OMIT WEST BANK OF RIVER 400FT SETBACK FROM RIVER BANK SLURRY WALL DEWATERING TRENCH STOCKPILE AREA PROPERTY OWNER MAP ID 15/09 • r SLURRY SALE 1 SAND AND GRAVEL 75 2• si CROCK TYPICAL MINING SECTION DEMAT L'RING 1011/201 - 3l' Bernhardt Sand And Gravel Pit Exhibit C2 • Mining Plan Map W.W. Clyde & Co. REVISIONS f CE A JILT Contain; In. 7e- c./„p ,0 * 22036 .t 03 12 24 D.M 61 TPY TPY Iiascioa mar As Show - Sheet 0' 2 2 • 1 START PERFORATED DRAIN PIPE I 4 / I ci • • / • // 4 ," not—. 171-b4 - ( 1' IS 111• am ei Mk Nt -IRK. oak s• If a 11 3111%131 Sime �- - LAT N40 303936 C-wi-41% r LONG W104 834394 �- a- a a aa _ "eater -- '� ,!L . t / r MW -3 LAT. N40.3011 LONG: W104.838Ct} END PERFORATED , DRAIN PIPE HERE. -W START SOLID PIPE ow e r - -et -c -- MW-4 LAT N40 297684 LONG: w104.834825 200 100 0 200 4.00 MOM ASSESS S Seen S .0 FT GRAVEL ACCESS ROAD RECLAIMED RESERVOR WATER SURFACE ELEV = 4715 WATER SURFACE AREA = 88.88 AC In / / • _1 END SOLID DRAIN PIPE HERE. START PERFORATED DRAIN PIPE / 000 4 SCALE IN FEET • 7 II, : • OFFSITE I,1 44 I „ ACCESS 1. ROAD A / A END PERFORATED DRAIN PIPE I-. I I LEGEND: a. K - EXISTING CONTOURS PROPOSED CONTOURS PROPERTY LINE `at EXISTING EXISTING EXISTING EXISTING EXISTING EXISTING bier_ 400FT (MIN,) W FENCE ROADS GAS LINE OVERHEAD ELECTRIC UNDERGROUND ELECTRIC POWER POLE TYPICAL RECLAMATION SECTION N1`, a • a•� JIB ~•�f!=fM :.. r4 BACKFILL EXISTING TRENCH WITH NATIVE MATERt4LS EXISTING RIGHT-OF-WAY SECTION LINE EXISTING 100 YR FLOODPLAIN EXISTING 100 YR FL000WAY PERMIT BOUNDARY WEST BANK OF RIVER 400FT SETBACK FROM RIVER BAN• SLURRY WALL RESERVOIR WATER SURFACE PERIMETER DRAIN (IF NEEDED) SCARIFY. TOPSOIL, SEED AREA 3,-5' VARIES ASTM C33-7 CONCRETE AGGREGATE ASTM C33 CONCRETE SAND (If REOUIRED) 1 S' TYP. • 1 'VP • f(TYP J 1 f 2' (MIN) .05' 4.0' 3' 4. PERIMETER GROUNDWATER DRAIN [TYPICAL SECTION IF REQUIRED' SANDY CLAY OVERBURDEN SAND AND GRAVEL ALLUVIUM m g049111 0 Bernhardt Sand And Gravel Pit • W.W. Clyde & Co. REVISIONS a I c U V 0 I./ ar• Orr 03 12 74 Oita. s! TPY 2203t, Deal le TRY Omen 1. ,ICY pro 41491.8 Smrnlr in Xs Sul. A& Shown Sher START trORATED DRAIN PIPE �. • I • r -a- - 01- v_ _ i T' - -arc -al -rte . . a :T .T. a. -ime -so -I+ n :e a re. -is. es as so t. ;ern.; _ ._ :.. .-'. - oak ,..- •, :- t gm" .,..,ai3-.ate,-r-•._.. --.C -4„.. ALAI, Air 4 .-. ',.M 1„ ', • 'l r/ ••J!/.'.-.;: r - 04 IN\ END PERFORATED DRANJ PIPE a START SOLO PIPE 20011 WIOL RIPiRAP RUNDOWN TYPE N (0I.- 12') 24- THICK W11H Ty uC.r rvi>I a Hi7hi11G • • 200 Ir 100 RECLAIMED RESERVOR WATER SURFACE ELEV a 4715 WATER SURFACE AREA = 88.88 AC__ 400 END SOLID DRAIN PIPE HERE. START PERFORATED OR/UN PIPE I ,.-.ALE IN FEET / / a dm 6ot I: III it 1 „elf , 01 /r / NY - g II OFFSITE ACCESS ROAD c I I I END PERFORATED DRAIN PIPE I I I.0.- . i i LEGEND: 5280 5280 C- I EXISTING CONTOURS PROPOSED CONTOURS PROPERTY LINE EXISTING EXISTING EXISTING EXISTING EXISTING EXISTING FENCE ROADS GAS LINE OVERHEAD ELECTRIC UNDERGROUND ELECTRIC POWER POLE NOTE: a IMO C EXISTING RIGHT -Of' -WA" SECTION LINE EXISTING 100 YR FL0ODPLAII, EXISTING 100 YR FLOODWAY PERMIT BOUNDARY WEST BANK OF RIVER 40011 SETBACK FROM RIVER BANK SLURRY WALL RESERVOIR WATER SURFACE PERIMETER DRAIN (IF NEEDED) SCARIFY. TOPSOIL. SEED AREA ALL DISTURBED AREAS OUTSIDE OF THE WATER SURFACE WILL BE SEEDED AND MULCHED, WITH THE EXCEPTION OF THE ACCESS ROAD, WHICH WILL BE GRAVEL SURFACED. RECLAIMED AREA TABULATION: WATER SURFACE = 92.35 AC GRAVEL ACCESS ROAD = 3.59 AC SCARIFY, TOPSOIL, SEED AREA = 15.07 AC TOTAL AREA = 111.01 AC Bernhardt Sand And Gravel Pit a 2 0 01 Tz C .Q S Q LL D L x w • W.W. Clyde & Co. REVISIONS y: r 22036 Qa 17.14 •1W T TPV /*asOf TN ti litclIsirran Asst.* Scab As Snows v4 Sheet 2 2 .. EXHIBIT Mining Plan Mining Limits WW Clyde proposes to mine in the land located in the parcel of land situated in the northeast 1/4 of Section 24, Township 4 North, Range 67 West of the 6th Principal Meridian, in Weld County, Colorado The proposed mining site is located within the Town of Milliken CR 46 is north of the property and an access road from the property connects to CR 46 near the intersection of CR 46 and CR 25 The South Platte River is adjacent to the property and approximately 880 feet south of the site on the south side of the permit boundary and 140 feet from the east side of the permit boundary The dominant land use surrounding the property is agricultural use and industrial use An aggregate processing plant will be located in Phase 1 These areas will contain stockpiles, portable equipment, storage bins, and silos as necessary to support the plant operations Mining will start from the northeast corner of the mining limit then moving south approximately to one third of the property then west, then moving south to another third of the property back to the east, then moving south to the final third of the property to the west to complete mining and reclamation All local, State, and Federal rules and regulations will be followed for the storage and handling of any petroleum products The permit boundary will encompass approximately 111 01 acres which will all be affected acreage, and approximately 98 24 acres being mined The remaining area will consist of access roads and disturbed land The following table depicts the different affected acreage Affected Acreage Mining Plan Area (acres) Mined Area 98 24 Access Roads 2 36 Disturbed Land 10 41 TOTAL 111.01 Various setbacks from adjacent roads, adjacent structures, and oil and gas infrastructure will be maintained as mining occurs The final executed agreements are expected to be obtained in the near future and will be forwarded to the Division when they are available A minimum 200 -foot setback from any existing oil/gas facility will be maintained until that time See Exhibit C, Mining Plan Map, and the Slope Stability Report for the mining limit configuration and information on setbacks and their locations The abandoned wells would be cutoff after mining has reached the bedrock surface or the reclaimed slope surface where a new cap and any additional concrete for the existing plug would be needed Petroleum Development Corporation (PDC) is the leaseholder and operator of the existing abandoned wells Discussions with PDC have indicated they would cut down the existing casings as mining occurs We have also worked'with McCarty Engineering, LLC to provide this service at other mining permit locations for other operators If PDC does not want to perform this work then McCarty Engineering, LLC would be contacted to do it They are licensed and bonded to obtain approvals from the COGCC to do these types of re -plug services on abandoned oil and gas wells Products Sand and gravel will be the primary product produced from the Bernhardt Sand and Gravel Pit. The principal intended use for the sand and gravel is for road base and construction aggregates. Subsurface drilling and testing have verified that the Bernhardt Sand and Gravel Pit property contains a significant commercial deposit of sand and gravel. The depth of clay, interbedded sandy clays and clayey to silty sands at the surface range from 1 to 8 feet. The thickness of the aggregate material ranges from 4 to 37 feet where bedrock contact occurs. Mining Methods The deposit will be dry mined and a slurry wall will be constructed around the perimeter of the mining area for Phase 1. Mining will not expose groundwater prior to the slurry wall being constructed around the perimeter of Phase 1. Design specifications for the slurry wall and quality control procedures used during construction will ensure that the reclaimed reservoir meets State Engineer's Office (SEO) performance standards. Dewatering trenches will be excavated around the perimeter of each mining area prior to mining operations commencing. The depth of the ditches will vary as the mining progresses deeper into the alluvium in order to maintain the groundwater level below the active mining bottom surface, and therefore minimize the exposed groundwater surface area. The dewatering ditches will flow to a collection pond, from which the water will be pumped and discharged into recharge areas where overflow will reach a ditch that flows to the South Platte River. The equipment and facilities may include. but are not limited to the following: Scaling Equipment A scale house and scale will be used to weigh trucks and product leaving the pit. The dimensions of the scale house are 40' x 12' and the scale will be 70' by 10'. The scale house will be founded on typical trailer type jacks and tiedowns on top of concrete pads that are typically 2 feet x_reetrITTret deep with minimal rebar to provide reinforcement. The scale will also be founded on concrete pads with reinforcement where load cells are located for the scale. these are typically 12' long by 3 feet wide and 3 feet deep. These foundations would be removed once the pit is fully mined. Processing Equipment Screens. wash plant, crusher, conveyors, stackers, and other miscellaneous processing equipment. All processing equipment will be mobile and temporary without fixed foundations. Washing will occur at the wash plant and excess water from the washing will be recycled to the wash water ponds within the processing area, there will be a sedimentation pond that will receive the excess water first and then and overflow from the sedimentation pond to the clear water pond for re -using the water and pumping back to the wash plant. Earth Moving Equipment Dozers, loaders, scrapers, excavators, and compactors will be used for mining and earth moving operations. Haul Roads and Access Roads Haul roads will be graded and constructed using the existing pit run where needed outside the processing area in order to move material from the mine using haul trucks, loaders. or scrapers. These roads will be mined and removed as the mining is completed. Access roads to the processing plant will be constructed with aggregates made at the site where the entrance to the permit boundary is located to the scale house and through the scaling area until the access reaches the stockpile locations. The roads around the stockpiles will be constructed from the existing pit run similar to the haul roads. Miscellaneous Equipment Dewatering pumps, electrical trailer, generator trailer, small portable generators and watering trucks will be used as needed. As mining progresses; topsoil and overburden will be stripped to expose the aggregate product below. Topsoil will be stripped and salvaged from areas where overburden material will be stockpiled. All soil and overburden material will be used on -site for reclamation: so long-term stockpiling of these materials is not anticipated. Overburden stockpiles will be located within the proposed mining area. The stockpiles will be placed parallel to the floodplain to mitigate impacts to the floodplain. Mining of the aggregate will progress down to the underlying bedrock. Since reclamation will occur concurrently with mining, it is not anticipated that overburden material will be stockpiled long-term prior to use in the slope reclamation and also the production of road base. During mining the mining face for Phase 1 will have a 2H:1V slope to bedrock or the bottom of the future reclaimed reservoir and the reclamation slope will be constructed using the excess overburden to a 4.5H:1V slope. The processed aggregate material will be temporarily stockpiled near the portable processing plant. Recommendations for monitoring of slope stability, including, conducting a visual inspection of the excavated slopes on a weekly basis for the duration of mining. conducting a visual inspection after a major precipitation event that has saturated the ground using the same procedures, contacting qualified personnel to evaluate and recommend remediation work to stabilize the area in the event a visual inspection detects signs of potential slope failure, and if no visible signs of slope failures are detected during mining, reducing visual inspections to once every six months after mining completion, or after every major precipitation event. All local, State, and Federal rules and regulations will be followed for the storage and handling of any fuel for the facilities. Topsoil Handling Plan As stated previously the topsoil will be stripped to expose the aggregate product underlying the topsoil. The topsoil will be stripped using scrapers and stockpiled in the topsoil stockpile as de ictedinExhibit C. or topsoil stockpiles, the stabilization includes roughening to help with wind rosion as well as re -vegetating with appropriate seed mixes to minimize erosion and establish more rapidly to stabilize the stockpiles. If a stockpile remains more than one growing season. it will be seeded with the seed mix as recommended by the DRMS and in the reclamation plan in Exhibit E. The volume of topsoil for all the mining phases is approximately 13,000 cubic yards. The depth of the topsoil is approximately six inches over the majority of the mining area. The topsoil will be stripped and stockpiled during each phase of mining where topsoil will only be removed for Phase 1 as Phase 1 is mined. Mining will start from the northeast corner then moving south approximately to one third of the property then west, then moving south to another third of the property back to the east, then moving south to the final third of the property to the west to complete mining and reclamation The height of the topsoil stockpile will be approximately 15 feet to 20 feet Mine Phasing WW Clyde anticipates mining and reclaiming the Bernhardt Sand and Gravel Pit in 1 phase, progressing through this phase as shown on the Mining Plan Map The overall time required to complete the mining and reclamation is estimated to be 11 years based on an average rate of 650,000 tons per year The initial production is expected to be 300,00 tons per year with the maximum production expected to be 1,000,000 tons per year However, it is possible that due to demand fluctuations, mining could progress slower than anticipated and additional time may be required for mining and reclamation of the site Phase 1 is 98 24 acres and the estimated time for mining Phase 1 is approximately 11 years `The mining will progress beginning at the outer edge of the phase where material will be moved toward the interior of the phase such that the mining slope can be established The mining slope will be established for the entire perimeter of the phase in 3 to 6 feet intervals Dewatenng Dewatenng trenches will be placed along the perimeter of Phase 1 The dewatenng trench around the perimeter of the phase being mined will be placed at the toe of the mining slope As the phase is mined deeper the dewatenng trench will be lowered and moved laterally along the mining slope toward the center of that phase A slurry wall is anticipated to be installed around the perimeter of Phase 1 prior to exposing groundwater and ,mining will continue to commence and it is expected minimal dewatenng will be required after the slurry wall is installed due to the slurry wall cutting off groundwater infiltration into the pit WVV Clyde will have 'an approved substitute water supply plan and well permit prior to exposing groundwater The substitute supply plan will be updated annually to account for water that is consumed due to exposing groundwater by the mining operation Explosives Explosives will not be used during mining EXHIBIT G Water Information Introduction WW Clyde proposes to mine in the land located in the parcel of land situated in the northeast 1/4 of Section 24, Township 4 North, Range 67 West of the 6th Principal Meridian, in Weld County. Colorado. The proposed mining site is located within the Town of Milliken town limits. CR 46 is north of the property and an access road from the property connects to CR 46 near the intersection of CR 46 and CR 25. The South Platte River is adjacent to the property and approximately 880 feet south of the site on the south side of the permit boundary and 180 feet from the east side of the permit boundary. The operation will consist of sand and gravel production and will impact the South Platte River in the form of depletions due to evaporation and operational losses associated with mining. Mining of the Bernhardt Sand and Gravel Pit mining site will last for approximately 11 years. Once reclamation is complete a reservoir will be created with a total surface area being 92.35 acres. The depth to groundwater ranges from 3 to 7 feet seasonally within the permit boundary (measured in MW -1 through MW -4, See the attached piezometer measurements table). The site will be mined down to a depth of 37 feet at the deepest depth thus exposing groundwater to the atmosphere. This exposed groundwater. along with the operational losses associated with the e xtraction of sand and gravel deposits. will impact the South Platte alluvial aquifer. These impacts will cause river depletions that must be augmented. Groundwater will be exposed during the mining once the mining depths reach an elevation of approximately 4713.8. To enable dry mining at the Bernhardt Sand and Gravel Pit mining site, there will be dewatering trenches around the perimeter of Phase 1. These dewatering trenches will change in length throughout mining. The maximum length will occur when Phase 1 is completely mined. The maximum size of dewatering trench will be 5,430 feet long and 5 feet wide, or 0.62 acres of e xposed surface area. water will be pumped into dewatering ditch, which traverses the site, and u ltimately into the South Platte River. As mining progresses, the dewatering trenches will shift as mining slopes are reclaimed. The gravel pit will have a slurry wall liner being constructed as mining commences in Phase 1. Water Requirements Water use at the Bernhardt Sand and Gravel Pit mining site will include evaporation from exposed groundwater, dust control of haul roads and stockpiles, water for the wash plant (i.e. wash screen for concrete rock and sand) and water retained in material removed from the site. Evaporative Loss Evaporative losses are dependent on the exposed water surface area, which may shift throughout the mining operation, but will not exceed the maximum. Exposed surface area at the Bernhardt Sand and Gravel mining site will include groundwater exposed in the dewatering trenches. The maximum exposed surface area at the site during mining is estimated at 1.80 acres. WW Clyde plans to keep the site dewatered throughout the life of the mine. Evaporation data was taken from NOAA Technical Report NWS 33. Evaporation Atlas for the 48 Contiguous United States. The annual gross evaporation was determined to be 45 inches for this location. Monthly evaporation percentages are established by guidelines set by the State Engineer's Office. To determine precipitation, data from the National Weather Service for Greeley, CO (UNC) (1967-2022) was used. The long-term average precipitation at the Bernhardt Sand and Gravel Pit mining site is estimated at 14.26 inches. Effective precipitation is calculated as 70% of the total precipitation. The net evaporation is the difference between gross annual evaporation and effective precipitation. The resulting net evaporation is 2.56 feet. The maximum evaporative loss from the 1.80 acres is 4.61 ac -ft. Operational Loss The average annual production from the Bernhardt Sand and Gravel Pit mining site is estimated at 650,000 tons. Using 4% moisture content (2% for moisture in the product and 2% for water used to wash). the total associated consumptive use for water retained in the material mined and water used for washing is 19.13 ac -ft. Dust control and water use is 10,000 gal/day, 6 days/week, 4 weeks/month for 10 months of the year. This equates to 7.4 ac -ft. Maximum annual operational loss is estimated to be 26.53 ac -ft for Phase 1. Consumptive Use The maximum annual consumptive use (operational loss + evaporation loss) at this site during the mining operation is estimated to be 31.14 ac -ft for Phase 1. Replacement Water The replacement of consumptive uses at the site is will be accounted for in a substitute water supply plan (SWSP) approved by the State Engineer. The SWSP will be obtained prior to any mining activities occurring that expose groundwater. Surrounding Water Rights The attached Figure A-1 Well Permits in the Bernhardt Sand and Gravel Pit — Groundwater Evaluation by McGrane Engineering, LLC shows the permitted wells within 600 feet of the mining limits and permitted wells within the boundaries of the groundwater model/evaluation. The well information and locations were obtained from the Division of Water Resources online mapping well permit locator. This well and water rights information was cross checked with the State's CDSS. Between the sources. all permitted and decreed wells are included. Table G-1 below is a corresponding list of wells as numbered in the Bernhardt Sand and Gravel Pit — Groundwater Evaluation by McGrane Engineering, LLC that is attached that are within 600 feet of the mining limits. Table G-1 - Permitted and Decreed Wells Within 600 Feet of Mining Limits Zip No. Permit No WDID Well Name Owner Address City State Code 14477 -F -R (Replaced 014477F Cheryl L. • Shows Kasten, Expired on Stroh Well Carlene M. DWR 0208226 (Irrigation) Stroh, Karen 511 North 1 Website) S. Currier Sholdt Drive Platteville CO 80651 WW Clyde Bernhardt (Purchased 10303 E. Dry Well Property in Creek Road, 2 42519-F 0205536 (Irrigation) 2022) Suite 300 Englewood CO 80112 WW Clyde Bernhardt (Purchased 10303 E. Dry Well #5 Property in Creek Road, 3 85 -R -R 0205392 (Irrigation) 2022) Suite 300 Englewood CO 80112 No Zip No Street Code Address Provided Violet Provided on on 4 5-WCB No WDID CWCB Well Montgomery Permit Eagle CO Permit 13701-F (Red Tag in Photos Showing Do Not Divert Bernhardt dated Well #6 Herbert B. 500 Broad 5 2019) 0205393 (Irrigation) Bernhardt Street Milliken CO 80543 At the time of SWSP application/approval, a new gravel pit well permit will be applied for/obtained to include the evaporative and operational losses from the property. If the proposed use of groundwater at the Bernhardt Sand and Gravel Pit mining site results in material injury to surrounding wells. VVW Clyde will ensure that all necessary measures are taken to address the issues. Water Quality An NPDES permit will be obtained from the Water Quality Control Division at the Colorado Department of Public Health & Environment for the Bernhardt Sand and Gravel Pit mining site prior to discharging any groundwater that is dewatered from the site. This permit will be kept current and amended as necessary to ensure that any water discharged from the site will meet the permitted water quality standards. Impacts to Groundwater/Hydrologic Balance WW Clyde will monitor the groundwater levels surrounding the site and provide groundwater recharge via a groundwater drain as shown on the reclamation plan. The groundwater drain size will be provided with the groundwater drain plan and profiles prior to installation of the slurry wall at the same time that the slurry wall design/construction drawings are provided to the DRMS prior �toUfl1Wter'iain will to installation of the slurry wall. VVW Clyde will discharge dewatering flows into existing adjacent irrigation laterals where possible to limit the disturbance to the surrounding land or obtain an agreement with one of the adjacent land owners to discharge the dewatering flows directly to the South Platte River. A slurry wall liner is proposed around the individual phase and will be installed prior to mining starting The first mitigation measure will be the construction of a groundwater drain as detailed in the McGrane response attached. The design and construction of the groundwater drain will be at the same time the slurry wall design and construction are completed so there will be minimal affect on the groundwater elevations. The drain will be constructed to a depth deep enough to control groundwater mounding from surfacing. Stop logs will be used to control groundwater elevations such that the drain does not drop the elevation to much or raise the elevation where mounding could occur. The trigger points would be levels of plus or minus 2 feet of difference from the baseline seasonal groundwater levels in MW -1 through MW -4 where stop log elevations could be adjusted to either lower or raise groundwater levels to their historic seasonal elevations. To summarize the mitigation process, as each phase of mining/dewatering occurs, WW Clyde will monitor the groundwater levels adjacent to mine as each phase progresses. If groundwater levels drop to a level that prevents an adjacent well from performing acceptably, according to that well's owner, VVW Clyde will either implement a groundwater recharge ditch/pond near the well in order to raise the groundwater level in the vicinity of the well and hence return it's operation to acceptable standards, or will negotiate an agreement with that well owner to replace the well or provide replacement water via other means until the mining and reclamation activities are concluded but it is not anticipated that any groundwater levels will drop since the slurry wall be installed prior to exposing groundwater. and Groundwater wells that are not owned by WVV Clyde (Table G-1) are potentially located within 600 feet of the mining limits. The exact physical location of these wells will be determined during the SWSP and well permit application processes. If wells are found to be within 600 feet of the mining limits, WvV Clyde will either obtain a well waiver from the owner of the well, or provide an agreement with the well owner that VVW Clyde will mitigate any material damage to the well that is directly attributable to the mining and reclamation of the site. All other wells within 600 feet of the mining limits are either owned by VVVV Clyde, or are monitoring wells therefore groundwater impacts to these wells do not need to be addressed. See the attached Piezometer Location Map, and Piezometer Data Summary. which show the locations of monitoring wells around the perimeter of the site that WW Clyde has either installed or has access to, and the groundwater level data that has been collected for each well. The groundwater monitoring data will be provided for what has been done to date with this permit application/adequacy review and then submitted at the following frequency to the DRMS: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report will include a site map with well locations. tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified. and graphs and tables of measured groundwater levels for all locations. The field sheets will be included in an appendix that demonstrates monitoring wells were purged and sampled according to the approved plan. Groundwater Quality Monitoring Plan The majority of the mining operations at this site will be within the slurry wall lined area. The areas outside of the slurry wall will be limited to the scale house and haul roads for trucks coming into and out of the pit, which are not likely to affect groundwater quality. To establish pre -mining groundwater quality at the site WVV Clyde will have four monitor wells sampled quarterly. The samples will be taken by a qualified consultant and then tested by SGS Laboratories for the analytes listed in Tables 1-4 of the `Basic Standards for Groundwater." The quarterly sampling will continue until 5 quarters of data has been established. Once the baseline has been established. we would recommend annual sampling to monitor the groundwater quality and a technical revision will be submitted to request the change. WW Clyde commits to establishing points of compliance following five quarters of baseline monitoring. Monitor Well 3 located on the west side of the permit boundary will be used as a background water quality sampling location and the remaining three monitoring wells as points of compliance (POC). the POCs will be Monitor Wells 1, 2, and 4. When obtaining a monitor well sample typically at least 3 well volumes will be taken from the well to make sure a true groundwater sample is obtained. During the purging time. measuring pH. temperature, EC will occur at different times until stabilization occurs. Then the sample will be collected and placed in the lab provided bottle(s) for unfiltered samples. The sample will then be filtered prior to placement into the lab bottle(s) for SGS to run the testing on for the dissolved metals from Table 41. Sampling and collection of the groundwater from the monitor wells will reference the USGS National Field Manual for Collecting Water Quality Data Chapter A.4 Collection of Water Quality Samples and EPA Region 9 Groundwater Sampling Guide. The groundwater quality sampling data will be provided for what has been done to date with this permit application/adequacy review and then submitted in the quarterly report for the pit to the DRMS after approval of the permit application. WW Clyde will notify the DRMS within 7 days of receiving a lab report that indicates any of the standards set forth in Tables 1-4 have been exceeded. If a lab report shows an exceedance, a new sample will be taken to verify exceedance or discount potential lab contamination. The groundwater quality testing data will be provided for what has been done to date with this permit application/adequacy review and then submitted at the following frequency to the DRMS: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report will include a site map with well locations. tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified, and graphs and tables of measured groundwater levels for all locations. The field sheets will be included in an appendix that demonstrates monitoring wells were purged and sampled according to the approved plan. Bernhardt PR Monitor Well Readmgs Well Destgnation Descdptlon JT MW -1 North S tie 4722 96 4719 92 Top of Well Elevation (ft) Ground Elevation (8) Date March 29 2023 April 21 2023 May 18 2023 June 12 2023 July 14 2023 August 14 2023 September 13 2023 October 16 2023 November 17 2023 December 22 2023 leo.. 20 2024 Feb... 2024 March 30 2024 Apr1130 2024 May 31 2024 June 30 2024 July 31 2024 Dopmm Grovnawamr hom rop of Well 7 46 7 60 8 29 5 67 5 00 5 75 767 783 7 50 7 50 7 83 7 67 6 58 721 Dvpm to croumvnmr Imm GlvuM w 4 42 4 58 3.25 263 1 96 271 4 63 4 79 4 46 4 46 4 79 4 63 3 54 4 17 EbwLon of Gro,F, w 4715 50 4715 36 4716 67 4717 29 4717 96 4717 21 471529 471513 4715 48 471546 471513 471529 4716 38 4715 75 JT MW -2 East 9de 472315 4720 09 Awrago Ebnavn alGrounMamrlor Mvnl (N (awngo readnas ror each mvM far deerenl yearsie March]@Jab 2@4 amaea q �) 4715 50 4715 36 4716 67 4717 29 4717 96 4717 21 4715 29 4715 13 4715 46 4715 46 471513 4715 29 4715 94 4715 55 Dopm to r CrouMx+br Irom Tap of Well w 9 27 604 00 92 6 92 817 33 83 8 00 B 38 13 29 6 88 ovph Iv GrouMxamr LemG t w 621 5 04 2 98 294 208 3 88 5 11 5 27 477 4 94 5 32 5 07 4 23 3 82 EbwLen vl GrouMvamr lro 4713 88 4715 05 471711 4717 15 4717 23 4716 23 4714 98 4714 82 4715 32 4715 15 4714 78 4715 03 4715 86 4716 28 JT MW -3 West Slde Awnpv EbwLon of Growdwabrlor Mont p9 (avenge reatlinpa for eaN mareh far d4eron[years le MaroM1 3@]vrd 2034 ameae q 2) 4713 BB 4715 05 4717 11 471715 4717 23 4716 23 4714 98 4714 82 4715 32 4715 15 4714 78 4715 03 4714 87 4715 68 ooPm b Grommwabr eom Top of Wcll w 10 92 10 02 8 54 7 50 6 58 7 33 9 92 10 17 1000 9 83 1017 10 02 9 83 9 58 DopIM1 b Groubwabr fromri- d w B 00 82 66 41 00 25 91 25 10 66 4727 70 4724 78 Ebvagan of CrourtlwaMr w 4716 78 4717 88 4719 16 4720 20 4721 12 4720 37 4717 78 4717 53 4717 70 4717 87 4717 53 4717 68 4718 08 471812 JT MW -4 South Side Awnge Ekwlun of GrounMalvr for Mont N) (awrago rtaGipa forvaeh moM for tlmorcntycars I o March 2(t2] aM 2024 mwea q 2) 4716 78 4717 68 4719 16 4720 20 4721 12 4720 37 4717 78 4717 53 4717 70 4717 87 4717 53 4717 68 4717 43 4717 90 Wpm. rouMnet Irom Top of Wvll w 10 38 9 02 6 58 8 33 621 B 58 9 00 9 17 8 58 B 00 9 08 8 92 8 13 7 96 DOPm b GrouMwabr from Gmimtl w 29 93 3 49 3 24 3 12 5 49 591 6 08 5 49 91 5 99 5 83 04 4726 65 4723 58 Ebweon al GrouMnbr w 4716 28 4717 83 4720 07 4720 32 4720 44 4718 07 4717 65 4717 48 4718 07 4718 65 4717 57 4717 73 4718 53 4718 69 Awra4a EbwLan of Grountlwamrler Menl w (awnga roaGrMa broach imrah for 4iearvnlyvars lv Marth 2@]aN 3@4 bveoa q2) 4716 28 4717 63 4720 07 4720 32 4720 44 4718 07 4717 65 4717 48 4718 07 4718 65 4717 57 4717 73 4717 40 471818 August 31 2024 September 30 2024 October 31 2024 November 30 2024 Oecember 31 2024 Minimum 5 00 7 83 6 97 1 96 4 79 3 93 MW 2 LAT N40301374 LONG W304830132 N71.41 W 3 LATN40301151 LONG W164:38891 MW 4 lAT N40297684 LONG W304834826 4715 13 4717 96 4715 99 5 92 9 27 7 52 2 es 621 4 46 4713 BB 471723 4715 63 6 58 10 92 9 30 3 66 8 00 63B 4716 78 4721 12 4718 40 21 10 38 8 28 3 12 729 5 19 471628 4720 44 4718 37 SGS North America Inc Report of Analysis Page 1of1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID DA62542-3 Matrix AQ - Ground Water Project Material Sites WQ Testing Date Sampled 03/01/24 Date Received 03/01/24 Percent Solids n/a General Chemistry Analyte 9056A Fluoride Chloride Nitrogen, Nitrite Nitrogen, Nitrate Sulfate Result RL Units DF Analyzed By Method 0 80 0 20 mg/1 2 03/01/24 21 45 MB SW846 9056A 135 5 0 mg/1 10 03/01/24 22 28 Ms sws46 9056A 0 11 - 0 040 mg/1 10 03/01/24 22 28 Ms sw846 9056A 5 7 0 25 mg/1 25 03/02/24 17 00 MB SW846 9056A 320 , 13 mg/1 25 03/02/24 17 00 MB SW846 9056A 9056A NO2 + NO3O Nitrogen, Nitrate + Nitnte a 5 8 _ 0 29 mg/1 Solids, Total Dissolved 888 10 mg/1 (a) Calculated as (Nitrogen, Nitrate) + (Nitrogen, Nitrite) 03/02/24 17 00 MB sw846 9056A 03/04/24 07 00 JW SM 2540C-2011 RL = Reporting Limit V 17 of 61 DA62542 SGS North America Inc Report of Analysis Page 1 of 1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID DA62542-3F Matrix AQ - Groundwater Filtered Project Material Sites WQ Testing Date Sampled 03/01/24 Date Received 03/01/24 Percent Solids n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Prep Analyzed By Method Prep Method Aluminum 0 0193,B 0 10 0 015 mg/1 1 03/12/24 03/14/24 CDL sm. soi0C 2 SW846 3010A 4 Antimony 0 0068 U 0 030 0 0068 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Arsenic 0 0046 U 0 025 0 0046 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Barium 0 0557 0 010 0 0013 mg/1 '1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Beryllium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Boron ,0 206 0 050 0 0063 mg/I 1 03/12/24 03/19/24 CDL sws46 6o1oC 3 SW846 3010A 4 Cadmium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Chromium 0 0013 U 0 010 0 0013 mg/I 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Cobalt 0 0024 B 0 0050 0 00063 mg/I 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Copper 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Iron 0 012 U 0 070 0 012 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Lead 0 0063 U 0 050 0 0063 mg/I 1 03/12/24 03/14/24 CDL SW846 60100 2 Sws46 3oltA 4 Manganese 0 322 0 0050 0 00063 mg/1 1 03/12/24 03/14/24 CDL Sws46 ttltC 2 Sws46 3010A 4 Mercury 0 000050 U 0 00010 0 000050mg/1 1 03/13/24 03/13/24 CDL SW846 7470A 1 SW846 7470A 5 Molybdenum 0 0031 B 0 010 0 0028 mg/I 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Nickel 0 0040 B , 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Selenium 0 022 U 0 050 0 022 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C2 SW846 3010A 4 Silver 0 0038 U ; 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C'2 SW846 3010A 4 Thallium 0 0043 U 0 010 0 0043 mg/1 1 03/12/24 03/14/24 CDL SW846 soloC 2 SW846 301tA 4 Uranium 0 0319 B 0 050 0 0085 mg/I 1 03/12/24 03/14/24 CDL sw846 60100 2 SW846 3010A 4 Vanadium 0 0013 U , 0 010 0 0013 mg/I 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Zinc `0 0038 U 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 (1) Instrument QC Batch MA17745 (2) Instrument QC Batch MA17751 (3) Instrument QC Batch MA17763 (4) Prep QC Batch MP39056 (5) Prep QC Batch MP39057 RL = Reporting Limit U = Indicates a result < MDL MDL = Method Detection Limit B = Indicates a result > = MDL but < RL s* 18 of 61 DA62542 SGS North America Inc Report of Analysis Page 1 of 1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID DA62542-3FC Matrix AQ - Groundwater Filtered Project Material Sites WQ Testing Date Sampled 03/01/24 Date Received 03/01/24 Percent Solids n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Prep Analyzed By Method Prep Method Lithium a '0 0189 0 010 0 0043 mg/I 03/07/24 03/08/24 ALA SW8a6 6010C 1 SW8a6 3010A 2 (1) Instrument QC Batch L MA27325 (2) Prep QC Batch L MP27849 (a) Analysis performed at SGS Scott, LA RL = Reporting Limit MDL = Method Detection Limit U = Indicates a4result < MDL B = Indicates a result > = MDL but < RL 19of61 DA62542 SGS North America Inc Report of Analysis Page 1 of 1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID DA62542-4 Date Sampled 03/01/24 Matrix AQ - Ground Water Date Received 03/01/24 Percent Solids n/a Project Material Sites WQ Testing General Chemistry Analyte 9056A Fluoride Chloride Nitrogen, Nitrite a Nitrogen, Nitrate Sulfate Result RL Units DF Analyzed By Method 0 77 ' 0 20 mg/I 2 03/01/24,22 42 MB SW846 9056A 77 6 5 0 mg/I 10 03/01/24 22 56 MB SW846 9056A < 0 040 e 0 040 mg/1 10 03/01/24 22 56 , MB SW846 9056A 0 54 0 020 mg/1 2 03/01/24 22 42 MB SW846 9056A -237 , 5 0 mg/I 10 03/01/24 22 56 MB SW846 9056A 9056A NO2 + NO3O Nitrogen, Nitrate + Nitrite b 0 54 0 060 mg/I Solids, Total Dissolved 655 r 10 mg/1 (a) Elevated detection limit due to matrix interference (b) Calculated as (Nitrogen, Nitrate) + (Nitrogen, Nitrite) 03/01/24 22 56 MB - SW846 9056A 03/04/24 07 00 JW SM 2540C-2011 RL = Reporting Limit e 20of61 DA62542 SGS North America Inc Report of Analysis Page 1 of 1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID DA62542-4F Matrix AQ - Groundwater Filtered Project Material Sites WQ Testing Date Sampled 03/01/24 Date Received 03/01/24 Percent Solids n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Prep Analyzed By Method Prep Method Aluminum 0 0177 B 0 10 0 015 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Antimony 0 0068 U 0 030 0 0068 mg/I 1 03/12/24 03/14/24 CDL SW846 6o10C 2 SW846 3010A 4 Arsenic 0 0046 U 0 025 0 0046 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Barium 0 0329 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Beryllium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Boron 0 202 ` 0 050 0 0063 mg/1 1 03/12/24 03/19/24 CDL SW846 6o10C 3 SW846 3010A 4 Cadmium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Chromium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Cobalt 0 0045 B 0 0050 0 00063 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Copper 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Iron 0 012 U 0 070 0 012 mg/I 1 03/12/24 03/14/24 CDL Sw846 60100 2 SW846 3010A 4 Lead 00063 U 0 050 0 0063 mg/I 1 03/12/24 03/14/24 CDL SW846 6010C 2 sw846 3010A 4 Manganese 0 582 0 0050 0 00063 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Mercury 0 000050 U 0 00010 0 000050mg/1 1 03/13/24 03/13/24 CDL SW846 7470A 1 SW846 7470A 5 Molybdenum 0 0087 B 0 010 0 0028 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Nickel 0 0038 U 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 Selenium 0 022,U 0 050 0 022 mg/1 1 03/12/24 03/14/24 CDL sw846 60100 2 SW846 3010A 4 Silver 0 0038 U 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 sw846 3010A 4 Thallium a 0 0043 U 0 015 0 0043 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 sw846 3010A 4 Uranium 0 0190 B 0 050 0 0085 mg/I 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Vanadium 0 0013 U 0 010 0 0013 mg/1 1 03/12/24 03/14/24 CDL SW846 6010C 2 SW846 3010A 4 Zinc 0 0192 B 0 030 0 0038 mg/1 1 03/12/24 03/14/24 CDL SW846 60100 2 SW846 3010A 4 (1) Instrument QC Batch MA17745 (2) Instrument QC Batch MA17751 (3) Instrument QC Batch MA17763 (4) Prep QC Batch MP39056 (5) Prep QC Batch MP39057 (a) Elevated reporting limit due to matrix interference RL = Reporting Limit MDL = Method Detection Limit B = Indicates a result > = MDL but < RL U = Indicates a result < MDL 21 of 61 DA62542 SGS North America Inc Report of Analysis Page 1of1 Client Sample ID BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID DA62542-4FC Matrix AQ - Groundwater Filtered Project Material Sites WQ Testing Date Sampled 03/01/24 Date Received 03/01/24 Percent Solids n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Prep Analyzed By Method Prep Method Lithium a 0 0105 ' 0 010 0 0043 mg/1 03/07/24 03/08/24 ALA SW846 60100 1 SW846 3010A 2 (1) Instrument QC Batch L MA27325 (2) Prep QC Batch L MP27849 (a) Analysis performed at SGS Scott, LA RL = Reporting Limit U = Indicates a result < MDL MDL = Method Detection Limit B = Indicates a result > = MDL but < RL .73 30$ 22 of 61 DA62542 SGS Wheat Ridge, CO Metals Analysis Section 5 QC Data Summaries Includes the following where applicable: • Method Blank Summaries • Matrix Spike and Duplicate Summaries • Blank Spike and Lab Control Sample Summaries • Serial Dilution Summaries SGS32 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing - QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/,24 Methods SW846 6010C Units ug/1 MB Metal RL IDL MDL raw final Aluminum Antimony 30 14 Arsenic 25 22 Barium 10 3 1 3 Beryllium 10 1 3 Boron 50 3 3 6 3 Cadmium 10 1 9 1 3 -0 10 <10 Calcium 400 6 6 50 Chromium 10 11 13 010 <10 Cobalt 5 0 2 7 63 0 30 <5 0 Copper 10 4 6 1 3 -1 4 <10 Iron 70 8 9 12 0 30 <70 Lead 50 13 6 3 4 2 _<50, Lithium 5 0 1 3 Magnesium 200 50 25 Manganese 5 0 63 0 50 <5 0 Molybdenum 10 8 5 2 8 -0 10 <10 Nickel 30 6 2 3 8 0 40 x30 Phosphorus 100 16 Potassium 1000 130 Selenium 50 22 20 5 <50 Silicon 200 150 Silver 30 3 8 -0 10 <30 Sodium 400 13 50 Strontium 5 0 63 Thallium 10 4 3 <10 Tin 60 51 Titanium 10 1 3 Uranium 50 8 5 -5 4 <50 Vanadium 10 1 3 -0 10 <10 Zinc 30 3 8 '<30 100 46 15 6 8 1 4 <100 -9 9 <0 3 1 <25 - 0 10 <10 0 0 <10 - 3 9 <50 - Associated samples MP39056 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (.) Outside of QC limits Page 1 SG$ 33 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal RL IDL MDL raw final (anr) Analyte not requested Page 2 SGS 34 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal DA61679-1F Original MS s=lat 8 Rec QC Lirtuts Alumi4ium Antimony Arsenic 0 0 211 200 Barium 0 0 414 400 Beryllium 0 0 105 100 Boron 0 0 409 400 Cadmium 0 0 102 100 Calcium Chromium 0 0 105 100 105 0 75-125 Cobalt 0 0 104 100 104 0 75-125 Copper 0 0 105 100 105 0 75-125 Iron 15 6 1 1040 1000 102 4 75-125 Lead 0 0 201 200 100 5 75-125 Lithium Magnesium Manganese 0 80 210 200 104 5 r 75-125 Molybdenum 0 0 102 100 102 0 75-125 Nickel 0 0 101 100 101 0 75-125 Phosphorus Potassium Selenium 0 0 215 200 107 5 75-125 Silicon Silver 0 0 41 6 40 104 0 775-125 ti Sodium am Strontium Thallium 0 0 199 200 99 5 75-125 Tin Titanium Uranium 0 0 209 200 104 5 75-125 Vanadium 0 0 104 100 104 0 75-125 Zinc 15 8 125 100 109 2 _ 75-125 Associated samples MP39056 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F 0 00 0 0 1010 98 1 1000 100 101 0 98 1 75-125 105 5 75-125 103 5, , 75-125 ,105 0 75-125 102 5 75-125 '102 0 75-125 75-125 Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits Page 1 35 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal DA61679-1F Spikelot QC Original MS ICPALL5 % Rec Limits (N) Matrix Spike Rec outside of QC limits (an, Analyte not requested Page 2 O14 36 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J5T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal DA61679-1F Spikelot MSD QC Original MSD ICPALL5 $ Rec RPD Linu t Aluminum Antimony Arsenic 0 0 218 Barium 0 0 415 400 Beryllium 0 0 106 100 Boron 0 0 413 400 Cadmium 0 0 104 100 Calcium 0 00 0 0 1020 106 1000 100 200 102 0 1 0 106 0 7 7 109 0 3 3 103 8 0 2 106 0 0 9 20 103 5 1 0 20 104 0 1 9 20 Chromium 0 0 107 100 107 0 1 9 20 Cobalt 0 0 106 100 106 0 1 9 20 Copper 0 0 107 100 107 0 1 9 20 Iron 15 6 1060 1000 104 4 1 9 20 Lead 0 0 206 200 103 0 2 5 20 Lithium Magnesium Manganese 0 80 211 200 105 0 0 5 Molybdenum 0 0 107 100 107 0 4 8 20 Nickel 0 0 101 100 101 0 0 0- 20 Phosphorus Potassium Selenium 0 0 218 200 109 0 "1 20 Silicon Silver 0 0 41 8 104 5 0 5 20 Sodium am Strontium Thallium 195 200 97 5 20 Tin Titanium Uranium 0 0 218 200 109 0 20 Vanadium 0 0 106 100 106 0 1 9 20 Zinc 15 8 111 100 95 2 ,11 9 20 Associated samples MP39056 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits 0 Page 3 N 37 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 DA61679-1F Metal Original MSD Spikelot IC PALLS 8 Rec MSD QC RPD Limit (N) Matrix Spike Rec outside of QC limits (anr) Analyte not requested Page 4 N 38 of 61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal BSP Spikelot QC Result ICPALL5 % Rec Limits Aluminum Antimony Arsenic 220 200 Barium 415 -400 Beryllium 106 100 Boron 407 400 Cadmium 104 100 Calcium Chromium 105 100 Cobalt 106 100 Copper 106 -100 106 0, _, 80-120 Iron 1040 1000 104'0 80-120 Lead , 209 200 104 5 80-120 Lithium Magnesium Manganese 213 200 106'5' 80-120 Molybdenum 104 100 104 0 80-120 Nickel 101 100 101-0, 80-120 Phosphorus Potassium Selenium 219 200 109 5 „i 80-120 Silicon Silver 41 5 40 103 8 ', 80-120 Sodium am Strontium Thallium 203 200 101 5, 80-120 Tin Titanium Uranium 209 200 104 5 " 80-120 Vanadium 106 100 f106 0 } 80-120 Zinc 109 100 109_0 80-120 995 102 1000 100 99'5' , 80-120 102-0 ' 80-120 .1100 ,80-120 103 8 80-120 106,0 80-120 102 0` 80-120 104 0 , 80-120 105 0 , 80-120 106 0 80-120 Associated samples MP39056 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (•) Outside of QC limits Page 1 39 of 61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal BSP Spikelot QC Result ICPALL5 % Rec Limits (anr) Analyte not requested Page 2 40 of 61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - JGT Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal DA61679-1F QC Original SDL 1 5 %DIF Limits Aluminum Antimony Arsenic Barium Beryllium Boron 0 00 0 00 NC� 0-10 0 00 0 00 NC, - 1 0-10 0 00 0 00 0-10 0 00 0 00 NC 0-10 0 00 0 00 NC 0-10 0 00 0 00 Cadmium 0 00 0 00 NC 0-10 Calcium Chromium 0 00 0 00 NC 0-10 Cobalt 0 00 0 00 ANC-- 0-10 Copper 0 00 0 00 NC 0-10 Iron 15 6 0 00 237 (a) 0-10 Lead 0 00 0 00 NC 0-10 Lithium Magnesium Manganese Molybdenum Nickel 0 00 0 00 ,NC _ 0-10 Phosphorus Potassium Selenium 0 00 0 00 Silicon Silver 0 00 0 00 NC` 0-10 >> i Sodium am Strontium Thallium 0 00 0 00 -NC ' 0-10 Tin Titanium Uranium 0 00 0 00 NC , 0-10 NC 0-10 0 800 0 00 100 0(a) 0-10 ,F 0 00 0 00 "NCB 0-10 0-10 Vanadium 0 00 0 00 NC ' 0-10 Zinc 15 8 , 0.00 10 -1 (a); 0-10 Associated samples MP39056 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (') Outside of QC limits Page 1 sG 41 of 61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - JST Consulting Project Material Sites WQ Testing QC Batch ID MP39056 Matrix Type AQUEOUS Prep Date 03/12/24 Methods SW846 6010C Units ug/1 Metal DA61679-IF QC Original SDL 1 5 %DIF Limits (anr) Analyte not requested (a) Percent difference acceptable due to glow initial sample concentration (< 50 times IDL) Page 2 42of61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number DA62542 Account JTCOCOW - JST Consulting Project Material Sites WQ Testing QC Batch ID MP39057 Matrix Type AQUEOUS Prep Date 03/13/24 Methods SW846 7470A Units ug/1 MB Metal RL IDL MDL raw final Mercury 0 10 015 0 0087 <0 10, Associated samples MP39057 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (') Outside of QC limits (anr) Analyte not requested Page 1 43 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J&T Consulting Protect Material Sites WQ Testing QC Batch ID MP39057 Matrix Type AQUEOUS Prep Date 03/13/24 Methods SW846 7470A Units ug/1 Metal DA62542-4F Original MS 2WSpikeot SRI 8 Rec QC Limits Mercury 0 0 1 1 110 0 7 75-125 Associated samples MP39057 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes ( ) Outside of QC limits (N) Matrix Spike Rec outside of QC limits (anr) Analyte not requested Page 1 44 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing QC Batch ID MP39057 Matrix Type AQUEOUS Prep Date 03/13%24' Methods SW846 7470A Units ug/1 Metal DA62542-4F Original MSD Spikelot HGWSRI Rec MSD QC RPD Limit Mercury 0 0 1 1 110 0 0 0 20 Associated samples MP39057 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec outside of QC limits (anr) Analyte not requested Page 2 45 of 61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY QC Batch ID MP39057 Matrix Type AQUEOUS Prep Date Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing Methods SW846 7470A Units ug/1 03%13/2, Metal BSP Spikelot QC Result HGWSRI % Rec Limits Mercury 1 0 100 0 80-120 Associated samples MP39057 DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (t) Outside of QC limits (anr) Analyte not requested Page 1 iV 46 of 61 DA62542 SGS Wheat Ridge, CO General Chemistry Section 6 QC Data Summaries Includes the following where applicable: • Method Blank and Blank Spike Summaries • Duplicate Summaries • Matrix Spike Summaries 0) SGS47 of 61 DA62542 METHOD BLANK AND SPIKE RESULTS SUMMARY GENERAL CHEMISTRY Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing MB Spike BSP BSP QC Analyte Batch ID RL Result Units Amount Result %Recov Limits Bromide Chloride Fluoride Nitrogen, Nitrate Nitrogen, Nitrate Nitrogen, Nitrite Nitrogen, Nitrite Solids, Total Dissolved Sulfate GP36124/GN62778 0 050 0 0 mg/1 GP36124/GN62778 0 50 0 0 ,' mg/1 GP36124/GN62778 0 10 '0 0, mg/1 GP36124/GN62778 0 010 0-0 mg/1 GP36126/GN62780 0 010 0 0 mg/1 GP36124/GN62778 0 0040 0 0 , mg/1 GP36126/GN62780 0 0040 0 0 - mg/1 GN62770 10 0 0,' mg/1 GP36124/GN62778 0 50 0"0 , mg/1 Associated Samples Batch GN62770 DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36124 DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36126 DA62542-1, DA62542-2, DA62542-3 Outside of QC limits 0 5 0 1 0 1 0 05 '32°05 5 0 474 4 71 0 951 , 0 0923 0 0985 0 0508 0 0525 241 4 75 94 8 _ 94 2 95 1 92 3 98 5 101 6 105 0 96 4 95 0- 90-110% , 90-110% 90-110% 90-110% 90-110% 90-110% 190-110% ' 90-110% 90-110% Page 1 48 of 61 DA62542 DUPLICATE RESULTS SUMMARY GENERAL CHEMISTRY Login Number DA62542 Account JTCOCOW - J6T Consulting Project Material Sites WQ Testing Analyte Batch ID QC Sample Units Original DUP Result Result RPD QC Limits Solids, Total Dissolved GN62770 DA62542-6 mg/1 723 Associated Samples Batch GN62770 DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 (.) Outside of QC limits 748 3 4 448 Page 1 N 49 of 61 DA62542 MATRIX SPIKEL CHEMRESULTSISTRY SUMMARY GENERA Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing QC Analyte Batch ID Sample Units Original Spike MS QC Result Amount Result %Rec Limits Bromide Chloride Fluoride Nitrogen, Nitrate Nitrogen, Nitrate Nitrogen, Nitrite Nitrogen, Nitrite Sulfate GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36126/GN62780 DA62560-6 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36126/GN62780 DA62560-6 mg/1 GP36124/GN62778 DA62422-1 mg/1 0 0 302 0 0 1 7 2 4 0 0 0 25 287 Associated Samples Batch GP36124 DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36126 DA62542-1, DA62542-2, DA62542-3 (*) Outside of QC limits (N) Matrix Spike Rec outside of QC limits 12 5 125 25 2 5 2 5 1 25 1 25 125 12 0 416 24 5 3 9 4 8 1 0 1 4 405 '96 0' „912 '98 0 88 0 96 0 , 80-120% 80-1208 80-1208 80-120% ' 80-120% p, 80 0 80-1208 G1 920` i80-120%, 94,4 80-1208 try Page 1 50 ,of 61 DA62542 MATRIX SPIKE DUPLICATE RESULTS SUMMARY GENERAL CHEMISTRY Login Number DA62542 Account JTCOCOW - J&T Consulting Project Material Sites WQ Testing Analyte Batch ID QC Sample Units Original Spike MSD Result Amount Result RPD QC Limit Bromide Chloride Fluoride Nitrogen, Nitrate Nitrogen, Nitrate Nitrogen, Nitrite Nitrogen, Nitrite Sulfate GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36126/GN62780 DA62560-6 mg/1 GP36124/GN62778 DA62422-1 mg/1 GP36126/GN62780 DA62560-6 mg/1 GP36124/GN62778 DA62422-1 mg/1 0 0 302 0 0 1 7 2 4 0 0 0 25 287 Associated Samples Batch GP36124 DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36126 DA62542-1, DA62542-2, DA62542-3 (*) Outside of QC limits (N) Matrix Spike Rec outside of QC limits 12 5 125 25 2 5 2 5 1 25 1 25 125 12 1 418 24 8 4 0 4 7 1 0 1 4 407 0 8 '91 2 5 2 1 0'0 0 0 0 5 , 20% ,20% 20% 20% 20% 20% 20% 20% Page 1 51 of 61 DA62542 SGS! Wheat Ridge, CO Misc. Forms Section 7 Custody Documents and Other Forms (SGS Scott, LA) Includes the following where applicable: • Chain of Custody scs52 of 61 DA62542 CHAIN OF CUSTODY Page 1 of 1 4036Young0eld ;treat Wheat Ridge C060031 _1_O131,4_ TEL 303426-6021 FAX ]01-0256854 www ags eoMehsusa Client/Reporting FeoFar ra.gv some oquD.rme s.a.e. srsaa. DA62542 Information com;a'ry Name SGS North America Inc Project Infonnatien Prge.'Nam. Materiel Sites WO Ted, Requested '' K '2 Malys s ( see TEST CODE sheet, Matrix Codes ow D.m4rp wafer cw 0mena wme. KW tamer SW SWaz Wa.er 50 (iel 5L sZ's SEDcrdc enl a of W post UgW4 AW .Ur 60L Omar 6elq wP Wqe Fes wtaum EB-Equgmem Blen4 RBRT Dar" TBTw Bun\ sues' Adwe.s 4036 Youngfield Street ' .veal - &I'Ne lnfomuEor'(1l dinenmfrem Ropen ref Ley stab Lp Wheat Ridge CO 6003 Gy Sul. CmnpsM Nerve Pre eacvnl.n Emaa elry lanchard(fi2sgs wm,1 Feq.e1. Sae.t A..n.. plme• Fve JOS-02541021 Ckml Pvrlu.e O..er. q4Y 61.4 2N SL;-.1.N.nro(al Plane TT prgvq Alaneper ......n ..4. Feld ID / Point of Collechon oEo. w. is . r.n '7...' u.ar, v a I>dM 1 1 y 5 4 I 2 LAB USE ONLY 1FC OGILVY RIVER FARM PIT (MW 1) 31124 10 1300 AM TT AO _ X 1 2FC OGILVY RIVER FARM PIT(MW-0) 3/124 10 35 00 AM TT AG X 3FC 'BARNHARDT SAND AND GRAVEL PI' 311/24 124000 PM TT AO X ( 4FC BARNHARDT SAND AND GRAVEL PI. 311/24 12 3000 PM TT AO X 14 5FC SWEET VALLEY PIT (MW 1) 3/1/24 125500 PM TT /to 6FC SWEET VALLEY PIT (MW 3) 3/1/24 1 10 00 PM TT AC X ivnamugT lnfonnakn e(eu.mesa aar.l Appew. ellwePN4(D.b SUnda.d 10 D.Y Inuslmul � � 5 Buainou Dap RUSN Oa'a DeWeraDle O DommarWl'A Ileral ll a 54b Fame Q Commerc4l'9' ( l..al ]I p EDD Fama1 0 pEDTt ( Le.el ]I Q ONer _ Canmenrs/SDena Inseudnns /// � a I O I1 n, { �— v _J hilp/Avxw 4g9[Dm/eniterms-andtendlllon4 ] su.lneaa D.p flU5H Q FUL11 ( Level.. Q : aWnau Dap push i su.Lr.a Dry EMEItGFNC � 0 CommemLl'D' Q% LL Comrem.i A . Re.ues ONr Q eN.r Duo ]lerzeu EmeryenryaRu.h TlAda.a..e.a,mUM. App... noeded for RUMEmerye"*y TAT cualedy Convneroal F'=RnNb •Oq Siamnary C Z.','C.Reswu. Dgeuwnary P......0 onP'n IegWY.dhr ''''''',/7 in. �� WaT'n. 3",/2Y Sample must 6v tl.cumenlad 0elow.ach hma p'��°-7f. 1 FT II �/ eamplas chango posaos.lon includmp courier dolivery p."naunM 9{ '� 2 1= r7( �'I (5 ;"*.'M'r(l1 2 `i�rY P.nw.a.aar...... 1 O.a.i ;ar.tl er 1�-'QS..Y,�"I p.4...1er 4 Ds n... oor Br R iequld.dbr 6 Dam T6ec R.....1 ar 5 d.bs. .ya. ❑ Oeb eedesTwP ❑ Na.oe ❑ ream ❑ 3. DA62542: Chain of Custody Page 1 of 3 SGS Scott, LA SGsi53 of 61 DA62542 II Ailgasv eCEU 03 i A62542: Chain of Custody Page 2 of 3 54 of 61 DA62542 Job Number da62542 SGS Sample Receipt Summary Client SGS NORTH AMERICA Project MATERIALS SITE WQ TESTING Date / Time Received 3/5/2024 9 15 00 AM Delivery Method FEDEX Airbill Ws 646648977174 Cooler Temps (Raw Measured) °C Cooler 1 (3 6) Cooler Temps (Corrected) °C Cooler 1 (3 6), Cooler Security Y or N Y or N 1 Custody Seals Present 0 ❑ 3 COC Present 0 ❑ 2 Custody Seals Intact 0 ❑ 4 Smpl Oates/Time OK D Cooler Temperature Y or N 1 Temp criteria achieved ❑.� ❑ 2 Cooler temp verification 3 Cooler media 4 No Coolers Ice (direct contact) Quality Control Preservatio Y or N N/A 1 Tnp Blank present/cooler ❑ ❑ ❑r 2 Tnp Blank listed on COC ❑ O 0 3 Samples preserved properly 0 O 4 VOCs headspace free O O 0 Sample Integrity - Documentation 1 Sample labels present on bottles 2 Container labeling complete 3 Sample container label / COC agree Sample Integrity - Condition 1 Sample recvd within HT 2 All containers accounted for 3 Condition of sample Sample Integrity - Instructions 1 Analysis requested is clear 2 Bottles received for unspecified tests 3 Sufficient volume recvd for analysis 4 Compositing instructions Gear 5 Filtering instructions dear Y or N O O ID O 0 O Y or N ❑✓ O Intact Y or N O O ❑ 0 O 0 N/A ❑ • 0 O O Test Strip Lot #s pH 1-12 pH 12+ Other (Specify) Comments NP metals (6-250m1 bottles) expired upon receipt Samples taken 3/1/2024 between 10 13-13 10 SM0B9-03 Rev Date 12/7/17 DA62542: Chain of Custody Page 3 of 3 55 of 61 DA62542 Wheat Ridge, CO Metals Analysis Section 8 QC Data Summaries (SGS Scott, LA) Includes the following where applicable: • Method Blank Summaries • Matrix Spike and Duplicate Summaries • Blank Spike and Lab Control Sample Summaries • Serial Dilution Summaries 00 SGS56 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number DA62542 Account ALMS - SGS Wheat Ridge, CO Project JTCOCOW Material Sites WQ Testing QC Batch ID MP27849 Matrix Type AQUEOUS Prep Date 03/07/24 Methods SW846 6010C Units ug/1 Metal RL IDL MDL raw final Aluminum Antimony Arsenic 10 2 4 8 6 Barium ,10 36 1 7 Beryllium 4 0 06 Boron 100 72 42 Cadmium 5 0 14 Calcium 100 ,3 8 32 Chromium 10 39 1 2 Cobalt 10 26 1 1 Copper 10 77 2 8 Iron 100 2 9 Lead 1 4 3 7 Lithium 2 4 4 3 Magnesium 100 22 Manganese 11 Molybdenum 16 Nickel 29 Potassium 500 50 120 Selenium 1 5 Silver 57 Sodium 500 20 120 Strontium Thallium 1 5 4 6 Tin Titanium Zinc 100 6 0 13 25 3 6 10 74 1 7 10 41 10 39 1 5 20 18 12 1 5 <10 Associated samples MP27849 DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (.) Outside of QC limits (anr) Analyte not requested Page 1 57of61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account ALMS - SGS Wheat Ridge, CO Project JTCOCOW Material Sites WQ Testing QC Batch ID MP27849 Matrix Type AQUEOUS Prep Date 03/07/241 Methods SW846 6010C Units ug/1 Metal-, LA98821-13 Original MS Spikelot ICPSPIKi% Rec QC Limits Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum Nickel Potassium Selenium Silver Sodium Strontium Thallium Tin Titanium Vanadium Zinc am am am am am am am am am 0 0 1740 2000 87,0 75-125 am am am am am am Associated samples MP27849 DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec outside of QC limits (anr) Analyte not requested Page 1 58of61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number DA62542 Account ALMS - SGS Wheat Ridge, CO Project JTCOCOW Material Sites WQ Testing QC Batch ID MP27849 Matrix Type AQUEOUS Prep Date ,03%07/24 Methods SW846 60100 Units ug/1 Metal LA98821-13 Original MSD Spikelot MSD QC ICPSPIKEI$ Rec RPD Limit Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum ' Nickel Potassium Selenium' Silver Sodium Strontium Thallium Tin Titanium Vanadium Zinc am am am am am am am am ant' 0 0 1740 2000 87 0 am am am am am 0 0 ( 20 Associated samples MP27849 DA62542-1FC, DA62542-2FC,- DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown ,as zero for calculation purposes (*) Outside of QC lirtuts (N) Matrix Spike Rec outside o£ QC limits (anr) Analyte not requested ' Page 59 of 61 DA62542 - SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number DA62542 Account ALMS - SGS Wheat Ridge, CO Protect JTCOCOW Material Sites WQ Testing QC Batch ID MP27849 Matrix Type AQUEOUS Prep Date 03/07/24 Methods SW846 6010C Units ug/1 Metal BSP Spikelot QC Result ICPSPIKEl% Rec Limits Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum Nickel Potassium Selenium Silver Sodium Strontium Thallium Tin Titanium Vanadium Zinc am am am am am am am am 915 1000 91 5 80-120 am am am am am am Associated samples MP27849 DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (+) Outside of QC limits (anr) Analyte not requested Page 1 60of61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number DA62542 Account ALMS - SGS Wheat Ridge, CO Project JTCOCOW Material Sites WQ Testing QC Batch ID MP27849 Matrix Type AQUEOUS Prep Date '03/07/24 Methods SW846 6010C Units ug/1 Metal .198821-13 QC Original SDL 1 5 %DIF Limits Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum Nickel Potassium Selenium Silver Sodium Strontium Thallium Tin Titanium Vanadium Zinc am am am am am am am am am 0 00 13 2 NC 0-10 am am am am am am Associated samples MP27849 DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested Page 1 61 of 61 DA62542 MEMORANDUM To: From: Date: Project: Subject: JC York — J&T Consulting, LLC Dennis McGrane, P.E., C.P.G. — McGrane Water Engineering, LLC February 23, 2024 Bernhardt Pit Groundwater Model Response to Questions by DRMS (10/20/23) BACKGROUND McGrane Water Engineering, LLC (MWE) prepared a report dated May 31, 2023 titled, "Bernhardt Pit — Groundwater Evaluation" to support a mine application permit for the Bernhardt Pit prepared by the applicant by J&T Consulting, Inc (J&T). The Colorado Division of Reclamation, Mining and Safety (DRMS) reviewed the report in an internal memorandum dated October 20, 2023, titled, "Bernhardt Sand and Gravel Pit, New Permit Application, Groundwater Review, File No. M2023-025. JC York (J&T Consulting) requested MWE address DRMS's questions no 6 and 7. DRMS QUESTION No. 6 "In review of Figure l0A along with the predicted mounding of feet on the upstream side of the proposed permit boundary, it appears the predicted mounding combined with high groundwater levels seen in July 2023 will bring groundwater elevations to within 0.5 feet of ground surface at MW -3. Additionally, extrapolating the potential mounding groundwater elevations during high groundwater levels away from the permit boundary in the southwestern area, it appears that the mounding will result in groundwater being exposed at the surface. Please update the groundwater model using the highest groundwater elevations to evaluate the potential of groundwater being exposed at the surface along the boundary of the permit. It should be noted that groundwater elevations approaching the surface can cause offsite land user issues due to saturated ground conditions. When updating the groundwater model figures, please label the individual well location I.D. 's. " Response: We can do this calculation without creating a transient groundwater model due to the principal of superposition (Reilly and Others, 1987), which means that the solution to a problem involving multiple inputs (or stresses) is equal to the sum of the solutions to a set of simpler individual problems. This is accomplished by first measuring water levels at monitoring wells surrounding McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons. CO 80540 • Phone: (303) 917-1247 E -Mail: dennis a mcgranewater.com Web: http://www.mcgranewaterengineering.com Page 1 of 5 the proposed pit to record and evaluate the factual variability. Second, we determine how the predicted modeled change in water levels affects the seasonal depth measurements. Third, we used the model to determine how effective various drain depth designs mitigate upgradient mounding; and lastly we add the changes from the various model runs to the observed seasonal water level values using the concept of superposition. By using the superposition approach, we do not need to spend additional time creating and calibrating a transient groundwater model. Such a model would require estimating or measuring other variables such as precipitation, river stage and evapotranspiration and estimating seasonal recharge which have their own range of measurement error and variability. Then, the process of calibration, which is to match observed to modeled heads in a transient condition would be a waste of time. Since groundwater flow is primarily a function of aquifer properties and gradient, we can use the steady state model and the principal of superposition to achieve an accurate result. Water levels were initially measured in March 2023 and used as model water level targets in the pre -pit model simulation (Report Figure A4). Coincidentally, the levels happen to be when seasonal water levels were deepest. The March 2023 depth to water ranged from 4.42 ft at MW - 1 to 8.0 ft at MW -3. By July however, water levels had risen to within 1.96 ft at MW -1 and 3.66 ft at MW -3. The maximum seasonal water table fluctuation (ie. change) between March and July (highlighted) ranges from 2.46 (MW -1) to 4.33 ft (MW -3). The observed depths to water at various monitoring wells are shown in the Table 1 below. Table 1 — Bernhardt Pit Monitoring Well Water Level Depths and Elevations. Well Designation JT MW -1 JT MW -2 JT MW -3 JT MW -4 Location North Side East Side West Side South Ssde Top of Well Elevation (ft) 4722 96 4723 15 4727 70 4726 65 Ground Elevation (8) 4719 92 4720 09 4724 78 4723 56 Depth to Depth to Depth to Groundwater Depth to Depth to Depth to Groundwater Depth to Groundwater Depth to from Top of Groundwater Elevation of Groundwater Groundwater Elevation of from Top of Groundwater Elevabon of from Top of Groundwater Elevation of Well from Ground Groundwater from Top of Well from Ground Groundwater Well from Ground Groundwater Well from Ground Groundwater Date (f!) an (ft) (tt) On on (ft) (k) Ito (ft) (R) (ft) March 29, 2023 746 4 42 4715 50 9 27 6 21 4713 88 10 92 8.00 4716 78 10 38 729 4716 28 April 21, 2023 760 456 4715 36 8 10 504 4715 05 10 02 7 10 471768 9 02 5 93 471763 May 18, 2023 629 3 25 4716 67 604 298 471111 854 5 62 4719 16 6 58 3 49 4720.07 June 12, 2023 5 67 2 63 4717 29 600 294 4717 15 7 50 458 4720 20 6 33 3 24 4720 32 July 14, 2023 500 196 4717 96 5 92 4 286 471723 658 366 4721 12 6 21 3 12 4720 44 August 14, 2023 5 75 2 71 4717 21 6 92 386 4716 23 7 33 4 41 4720 37 8 58 5 49 4718 07 September 13, 2023 7 67 4 63 4715 29 8 17 5 11 4714 98 992 7 00 4717 78 9 00 5 91 4717 65 October 16, 2023 7 83 4 79 4715 13 8 33 5 27 4714 82 10 17 7 25 4717 53 9 17 6 08 4717 48 Max Fluctuations (ft) = 2 46 3 35 4 33 4 17 As requested in this question, we will evaluate the depth to water relative to the ground surface in our response to question No. 7 below and reference the monitoring well locations on the accompanying figures. QUESTION No. 7 "Please provide a groundwater model analysis to demonstrate how effective installing the proposed underdrainwill he to mitigate the predicted groundwater mounding on the upstream side of the proposed slurry wall." McGrane Water Engineering, LLC 1669 Apple Valley Rd. • L) cans. CO 80540 • Phone: (303) 917-1247 E -Mail: Bennis a mcgranewater.com Web: http://www.mcgranewaterengineering.com Page 2 of 5 Response: We used the model to evaluate pit liner impacts as discussed in our modeling report. For drain runs, we used the MODFLOW "Drain" package which simulates a drain using a cross sectional area, assumed permeability around the drain and a specified setting depth. The deeper the pipe, the more it lowers the water table and therefore flows (removes water from the model). Water level flow into a drain is controlled by the conductance term (COND) which is a function of the drain area, permeability of the gravel fill around the drain and depth below the water surface. We assume a 1 -ft cross-sectional drain surrounded by gravel with a hydraulic conductivity (K) of 400 ft/day. For a 200 -fl long model cell, COND = 80,000 ft^2day (400 ft/day x 1 ft x 200 ft). COND is calculated internally by the model using the digitized length of drain across each model cell. After running the model with a MODFLOW drain, we iteratively reinject the cumulative drain volume (divided by the number of cells) using the MODFLOW "Well" package which allows us to "inject" groundwater in adjacent cells similarly to how a horizontal drain would release water into the aquifer along the drain. Note: drain flow from a horizontal exfiltration drain would occur more in response to gravity and be a function of aquifer levels, whereas injecting through wells causes a more equal distribution. Regardless, positive water level changes reflect mounding on the upgradient side of the proposed pit and negative (-) reflect shadowing on the downgradient side of the pit. Table 2 shows the measured depth to water in July (Column "a") which is when the depth to water is shallowest. Modeled "Mounding (+) and Shadowing (-) "changes" were determined by calculating the differences in water table elevation for model cells where monitoring wells are present. MW -3 is where shallow groundwater is most vulnerable to reach the surface which is why those levels are highlighted in red. Table 2 — Modeled Changes Due to Pit Lining and Drain Installation Well Measured Depth (ft) July to Water Modeled Mounding (+)/Drawdown (-) Forecast July Depth to Water (ft) With Pit With Drain (Elev. 4718 ft) With Drain (Elev. 4717 ft) With Drain (Elev. 4718 ft) With Drain (Elev. 4717 ft) (a) (b) (c) (d) (a+c) (e ) (f) (a+d) Run: <Bern_SS7> <Bern_SS9_d4> <Bern_SS9_d5> Upgradient (MW -3) = -1.96 2.52 1 0.33 -0.67 -1.63 -2.63 Upgradient (MW -4) _ -2.86 0.86 0.52 0.2 -2.34 -2.66 Downgradient (MW -1) = -3.66 -2.61 -2.54 -2.61 -6.2 -6.27 Downgradient (MW -2) _ -3.12 -0.68 -0.44 -0.72 -3.56 -3.84 Drain flow (gpm) = 260 -400 Column "b" is the calculated modeled change caused by the pit liner (Run Bern_SS7), which causes mounding at upgradient wells MW -3 (2.52 ft) and MW -4 (0.86 ft), and downgradient shadowing at wells MW -1 (-2.61 ft) and MW -2 (-0.68 ft) as shown in report Figure A-10 and Figure 1 below. McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons. Co 80540 • Phone: (303) 917-1247 E -Mail: dennisiar mcgranewater.com Web: http://www.mcgranewaterengineering.com Page 3 of 5 Figure 1 — Change Associated with the Pit Liner (Report Figure A10 with Labels) 4 155687 U _b} 279 155687-A 14523 -R -R 18 14524-R 841-WCBEt .13701-F aThvests• W-1 ;MW -3 14477-F -S, (] 5 -R -R 8 s-wcB,.�._ e -185-R �* -1.'42519°Fe W-2 19924-X 13703-R- 275938 ' 1 232159; 185466-A 19924 -V -R 1C As discussed in the modeling report, the contours show upgradient mounding and downgradient shadowing in the range of +/- 2.5 feet. Drain Runs In drain run <Bern_SS9d4>, we establish an upgradient drain at elevation 4718 ft (yellow cells). The resulting mounding (Figure 2) compared to the pre -pit run at MW -3 (+0.33) and MW -4 (+0.52 ft) are insignificant, but the downgradient shadowing in MW -2 (-0.44 ft) and MW -1 (-2.54 ft) provides only a minor improvement over the non -drain pit impact run (Figure 1). We suspect that most of the exfiltrating groundwater recharges the SPR instead of filling up the shadow zone further to the west. We believe this is not a big problem since there are no downgradient wells within the shadow zone. The modeled drain flow is approximately 260 gpm. Figure 2 — Drain Run (Drain Elev. 4818 ft.) ■!!!■ T, /s ■EM ■!!!!■ ■w; ■!!!!!!1►' ■!!!A! 12101! Il111 Z S SSW lirtin11O11111 ■! ■!'.►T'a'i ■■ ■!Srlr! SIM ■!!!!!! 1111 1111 h'igVI11II11Hh10 flu' ! /!!!!! ■n ■fl• ■0 ■!!!!► ■n. ■!!i ■... If we add the maximum "change" caused by the drain to the observed shallowest level measurement in July, then the predicted depth to water in upgradient wells (MW -3 to MW -4) McGrane Water Engineering, LLC 1669 Apple Valley Rd. • L} ons. Co 80540 • Phone: (303) 917-1247 E -Mail: dennis a mcgranewater.com Web: http://www.mcgranewaterengineering.com Page 4 of 5 ranges from -1.63 to -2.34 ft as shown in Table 2 (column e) above. The predicted July depth to water at MW -3 will likely therefore be shallower than observed in 2023. On the downgradient side, the expected depths to water at both MW -1 and MW -2 will likely be deeper than recently measured because the exfiltrating groundwater will likely flow to the SPR instead of filling the shadow zone. Again, we believe this is not a problem since there are no downgradient wells within the shadow zone (>0.5 ft). To be conservative, we recommend installing a deeper drain (at the 4,717 ft elevation) to reduce seasonal upgradient water level depths. Not surprising, by lowering the drain 1 -ft, the predicted water level drop at MW -3 is the same amount. Overall, the predicted water level at MW -3 will be drop -0.67 ft compared to pre -pit conditions. MW -4 still rises 0.2 ft because there is no drain in that model cell. Downgradient shadowing at M W-2 (-0.72 ft) and MW -1 (-2.61 ft) increases due to the increased drain flow (-400 gpm). We did not include the modeled drawdown because it looks very similar to Figure 2. If we add the modeled "change" to the original depth to water, we predict the upgradient depth at wells MW -3 (-2.63ft) to be a foot deeper than observed and MW - 4 (-2.66 ft) to be about the same as measured (-2.86). On the downgradient side, the expected depths to water at both MW -1 and MW -2 will likely be deeper than recently measured. Again, we do not expect this to be an issue since no wells are within the shadow zone in excess of >0.5 ft as shown on Figures 1 and 2. Conclusion We conclude: 1. Using the concept of superposition, we can use the steady state groundwater model to estimate seasonal groundwater conditions. A drain can be installed that stabilizes the seasonal fluctuations such that groundwater will not reach the ground surface and upset the hydrologic balance. 2. A drain installed at a depth of 4,817 ft (across model cells shown in Figure 2) could reduce seasonally high water levels at upgradient well MW -3. Most exfiltrating groundwater will return directly to the SPR thereby leaving downgradient shadowing unmitigated. However, this should not be a problem since there are no downgradient wells within the shadow zone. 3. Based on a simulated drain elevation of 4717 ft bgl, we predict drain flow to be approximately 400 gpm. To account for uncertainty, we recommend that it be designed to flow approximately 800 gpm. Sources Reilly, T.E., O.L. Franke, and G.D. Bennett, 1987. The Principal of Superposition and its implication in Ground -water Hydraulics. U.S. Geological Survey Techniques and Methods 3-B6. Reston, Virginia. McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons. CO 80540 • Phone: (303) 917-1247 E -Mail: dennis'r .mcgranewater.com Web: http://www.megranewaterengineering.com Page 5 of 5 EXHIBIT H Wildlife Information The project area was surveyed for general wildlife habitat by Ecological Resource Consultants (ERC) The Screening Report for Federal and State Listed Threatened and Endangered Species from ERC, is attached which describes the wildlife habitat present on the site and the common species that may be found in the habitat area ERC conducted this screening for federal and state threatened, endangered and species of concern for the approximately 134 -acre survey area The following provides key items identified as part of the report Two primary land use class/vegetation cover type exists within the survey area Habitat within the survey area is characterized as the Great Plains Ruderal Grassland and Shrubland (98%) and disturbed (2%) Historic land use for agricultural practices has led to degradation of the native vegetation community 2 Generally, there are features on the survey area and the surrounding area that provide general habitat for local songbirds, raptors, and small to mid -size mammals However, habitat within the survey area is somewhat degraded and of lower ecological value from a wildlife perspective due to historic and current land use for agriculture, which has restricted overall growth and establishment of vegetation The South Platte River and adjacent eastern cottonwood floodplain and woodland, provides suitable habitat for wildlife species and MBTA species The South Platte River and associated vegetative community will not be impacted by the proposed project 3 Non -raptor birds No non -raptor migratory bird nests were observed within the survey area However, prior to vegetation removal a nest survey should be completed to ensure that no nests have become established within the survey area and active nests, if any, are not disturbed Non -eagle Raptors No non -eagle raptor nests were observed and no CPW mapped non -eagle raptor nest protection zones are located 'within the survey area (CPW 2023a) However, nest activity status can vary seasonally and from year-to-year Future land use changes may require additional nest surveys (generally between February 1 and September 15 (CPW 2020)) to determine activity status within 'A to 'A mile of the survey area to ensure compliance with CPW recommendations Eagles CPW SAM data identifies a bald eagle nest listed as "destroyed" being directly northeast of the survey area Per CPW monitoring logs, the eagle nest has been inactive from 2019-2021, and destroyed in 2022 A field visit by ERC on January 25, 2023 confirmed the identified nest no longer exists and the nest area is no longer being utilized with no efforts by eagles to rebuild the nest Therefore, the nest site and the survey area is not subject to any restriction per CPW protective buffer zone recommendations or USFWS Bald Eagle Protection Act 4 No federally listed threatened and endangered species and/or habitat protected under the ESA were identified within the survey area The survey area is not within designated critical habitat of any federally listed species The vegetation community and features within the survey area were investigated as potential habitat for federally listed species. Any future land use changes will result in No Take on any federal listed species, their habitats, or proposed or designated critical habitat. 5. No State listed threatened or endangered species and/or habitat protected by CPW under Colorado Statute Title 33 were identified within the survey area. The vegetation communities within the survey area were investigated as potential habitat for state listed species. Any future land use changes will have no effect on any state listed species, their habitats, or proposed or designated critical habitat. ERC 2023 provided a detailed evaluation of potential critical wildlife habitat and use within the Permit Area. The Permit Area was determined to be comprised of 100% ruderal grassland and disturbed lands which is generally considered low -value wildlife habitat. No federal or state listed threatened and endangered species/habitat were identified. Following the preparation of ERC 2023. CPW issued (March 2023) new wildlife Species Activity Mapping (polygons) that depict the Permit Area within Mule Deer High Priority Habitat (HPH). This CPW polygon encompasses more than 955 square miles (611,000 acres) acres along the South Platte and Big Thompson Rivers (refer to Figure 1 in ERC's Adequacy Review Responses to CPW below). The Permit Area represents less than 0.02 % of this entire HPH polygon. In order to minimize potential disturbances to the HPH, the project will implement CPW recommendations addressed in Item 10 of their comment e-mail to DRMS also attached below. No other critical habitat or seasonal wildlife use has been identified within the Permit Area. It is not anticipated that operations (increased traffic, noise. light) will have a significant effect on wildlife in the area. Refer to ERC 2023 for further explanation. Attached are ERC's Adequacy Review Responses to CPW's comments and the Screening Report for Federal and State Listed Threatened and Endangered Species. W.W. Clyde & Co. commits to conducting a raptor survey prior to mobilization of earth -moving equipment or excavation at the site. The survey will be conducted and results submitted to the DRMS as a technical revision 30 days prior to mobilization of earth -moving equipment or excavation. Hello