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
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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
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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
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NOTE
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OWNER WITHIN THE PERMIT AREA
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W.W. Clyde & Co.
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RESERVOIR WATER SURFACE
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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
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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
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4036 Youngfield Street '
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Ley stab Lp
Wheat Ridge CO 6003
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CmnpsM Nerve
Pre eacvnl.n Emaa
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'7...' u.ar,
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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
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C Z.','C.Reswu. Dgeuwnary P......0
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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)
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232159;
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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.)
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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.
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