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Home My WebLink About20231499.tiff40 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources September 26, 2021 Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, Incomplete Submittal of 112 Construction Materials Reclamation Permit Application Package Mr. Fancher: On September 13, 2021, the Division of Reclamation, Mining and Safety (Division/DRMS/Office) received the 112 Construction Materials Reclamation Permit Application package from Loveland Ready -Mix Concrete, Inc. for the Dunn Pit, File No. M-2021-059. Preliminary review of the information received determined the following additional information must be received before the Division can consider the application as being submitted and technical review can begin: Application Form 1. On Page 1, Items 3.1 and 3.2, the Applicant indicated a change in acreage and the total acreage in the permit area as 118 acres. The Applicant submitted a new permit application, therefore there is not a change in permitted acreage. Please revise Items 3 and 3.2 to indicate the total proposed acreage of 118 acres and do not enter a value for Item 3.1. 2. On Page 1, Item 5.1, the Applicant indicated 200,000 tons per year of incidental commodity to be mined. The Applicant failed to provide the anticipated end use of the incidental commodity to be mined on Item 5.3 of the application form. Please provide the anticipated end use of the incidental commodity on the application from. 3. On Page 2, Item 9, the Applicant failed to provide the quarter/quarter location information for the center of the area where the majority of mining will occur. Please revised the application form to indicate the quarter/quarter location information. 4. On Page 4, Item 16, the Applicant states a DRMS number was historically assigned to the pit, but the pit was never mined. The Division's believes the Applicant is referring to the Milliken 1313 Sherman Street, Room 215, Denver, Co 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov Jared S. Polls, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Dunn Pit 112 Incompleteness Page 2 of 4 September 26, 2021 Site permit application, File No. M-1999-065, which appears to have been withdrawn by the Applicant. Please confirm the previous application was withdrawn by the Applicant. 6.4.1 Exhibit A - Legal Description 5. Rule 6.4.1(1) states the legal description shall be by, township, range and section, to at least the nearest quarter -quarter section. The Applicant provided the legal description to the nearest quarter section only in Exhibit A for the three (3) parcels. Please provide the legal description to the nearest quarter -quarter section as required by Rule 6.4.1 in Exhibit A. 6.4.3 Exhibit C - Pre -mining and Mining Plan Maps of Affected Area 6. The Applicant submitted Mining Plan Maps (Exhibits C-1 through C-16) labeled as "drafts". The Division does not review draft copies of application exhibits. Please provide final copies of the Exhibit C maps for Division review. 7. The Exhibit C maps must be prepared and signed by a registered land surveyor, professional engineer or other qualified person pursuant to Rule 6.2.1(2)(b). Please provide signed copies of the Exhibit C maps. 8. The Exhibit C maps do not comply with all of the requirements of Rule 6.4.3. Please update the Exhibit C maps to include the following requirements as needed: a. all adjoining surface owners of record b. the name and location of all creeks, roads, buildings, oil and gas wells and lines, and power and communication lines on the area of affected land and within two hundred (200) feet of all boundaries of such area c. the existing topography of the area with contour lines of sufficient detail to portray the direction and rate of slope of the affected land d. the total area to be involved in the operation, including the area to be mined and the area of affected lands (see definition of "Affected Land") e. the type of present vegetation covering the affected lands f. in conjunction with Exhibit G - Water Information, Rule 6.4.7, if required by the Office, further water resources information will be presented on a map in this section g. Show the owner's name, type of structures, and location of all significant, valuable, and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land h. In conjunction with Exhibit I - Soils Information, Rule 6.4.9, soils information may be presented on a map in this section i. Aerial photos, if available, may be included in this section Dunn Pit 112 Incompleteness Page 3 of 4 September 26, 2021 6.4.4 Exhibit D - Mining Plan 9. On Page 6, Exhibit D, the Applicant states the entire site consists of approximately 114 acres. The Applicant listed the proposed permitted acreage on the application form as 118 acres. Please explain this discrepancy the revise Exhibit D or the application form accordingly. 6.4.6 Exhibit F - Reclamation Plan Map 10. The Applicant submitted Reclamation Plan Maps (Exhibits R-1 through F-3) labeled as "drafts". The Division does not review draft copies of application exhibits. Please provide final copies of the Exhibit F maps for Division review. 11. The Exhibit F maps must be prepared and signed by a registered land surveyor, professional engineer or other qualified person pursuant to Rule 6.2.1(2)(b). Please provide signed copies of the Exhibit F maps. 6.4.17 Exhibit Q - Proof of Mailing of Notices to Board of County Commissioners and Conservation District 12. The Applicant stated proof of notice to the Weld County Commissioners and the West Greeley Soil Conservation District were attached with the permit application. The Division received copies of the notice letters and application form without proof the permit application was received by the Weld County Commissioners or the West Greeley Soil Conservation District. Typically, Applicants provide the Division a copy of the notice letter stamped as received by the Board of County Commissioners and Conservation District or tracking verification from USPS. Please provide proof of notice to the Weld County Commissioners and the West Greeley Soil Conservation District. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 13. Please provide an affidavit or receipt indicating the date on which the revised application documents were placed with the Weld County Clerk and Recorder in response to this letter. Public Notice 14. On Page 1 of the application, the Applicant states Appendix A contains copies of the certification of the public notices that appeared in the local newspaper. Pursuant to Rule 1.6.2(1)(d), within ten (10) days after the Division notifies the Applicant that the application is considered filed, publish a public notice in a newspaper of general circulation in the locality of the proposed mining operation. The Division has not called the Dunn Pit application complete, therefore the Applicant is not required to begin publication. The Division recommends the Applicant cease the current newspaper publication until the Division notifies the Applicant the application is considered filed by the Division. Dunn Pit 112 Incompleteness Page 4of4 September 26, 2021 The application will not be considered submitted until the information listed above is received and found sufficient to begin our review. A decision date will be established 90 days from the date of receipt of all of the requested information. Additionally, if you have already published notice you will need to republish notice, after the Division considers the application submitted. This notice must be published once a week for four (4) consecutive weeks, starting within ten (10) days of the date your application is considered submitted. We will notify you when you should initiate republication of your notice. The final date for receiving comments is the twentieth (20th) day after the fourth publication or the next regular business day. You have sixty (60) days from the date of this letter to submit all necessary documents the Office needs for the application to be considered filed. If, at the end of the sixty day period, the application has not been determined to be filed with the Office, the Office shall deny the application and terminate the application file. The response due date is November 25, 2021. This letter shall not be construed to mean there are no other technical deficiencies in your application. The Division will review your application to determine whether it is adequate to meet the requirements of the Act after submittal of all required items. Peter S. Hays Environmental Protection Specialist Ec: Jared Ebert; Division of Reclamation, Mining & Safety 40 October 26, 2021 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, Second Incomplete Submittal of 112 Construction Materials Reclamation Permit Application Package Mr. Fancher: On October 14, 2021, the Division of Reclamation, Mining and Safety (Division/DRMS/Office) received the 112 Construction Materials Reclamation Permit Application incompleteness response from Loveland Ready -Mix Concrete, Inc. for the Dunn Pit, File No. M-2021- 059. Review of the information received determined the following additional information must be received before the Division can consider the application as being submitted and technical review can begin: 6.4.4 Exhibit D - Mining Plan 9. On Page 6, Exhibit D, the Applicant states the entire site consists of approximately 114 acres. The Applicant listed the proposed permitted acreage on the application form as 118 acres. Please explain this discrepancy the revise Exhibit D or the application form accordingly. The Applicant's response stated, "We have updated the application to reflect the survey - verified 114.25 acres as reported in Exhibits A and D." Please provide a copy of a revised Exhibit D indicating a proposed permit acreage of 114.25 acres. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 13. Please provide an affidavit or receipt indicating the date on which the revised application documents were placed with the Weld County Clerk and Recorder in response to this letter. The application will not be considered submitted until the information listed above is received and found sufficient to begin our review. A decision date will be established 90 days from the date of receipt of all of the requested information. Additionally, if you have already published notice you will need to republish notice, after the Division considers the application 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Dunn Pit 112 Second Incompleteness Page 2 of 2 October 26, 2021 submitted. This notice must be published once a week for four (4) consecutive weeks, starting within ten (10) days of the date your application is considered submitted. We will notify you when you should initiate republication of your notice. The final date for receiving comments is the twentieth (20th) day after the fourth publication or the next regular business day. You have sixty (60) days from the date of the first incompleteness letter to submit all necessary documents the Office needs for the application to be considered filed. If, at the end of the sixty day period, the application has not been determined to be filed with the Office, the Office shall deny the application and terminate the application file. The response due date is November 25, 2021. This letter shall not be construed to mean there are no other technical deficiencies in your application. The Division will review your application to determine whether it is adequate to meet the requirements of the Act after submittal of all required items. Peter S. Hays Environmental Protection Specialist Ec: Jared Ebert; Division of Reclamation, Mining & Safety TELESTO S O L U T I O N S• I N C C R P O R A T C U October 26, 2021 Via Hand Delivery Mr. Peter Hays Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Subject: Knox Pit, DRMS Permit Application No. M-2021-059 Incomplete Submittal Response and Errata Dear Mr. Hays: Thank you for your review of Loveland Ready -Mix's Dunn Pit response to incompleteness letter number 1. This letter documents how Loveland Ready -Mix Concrete Inc. (LRM) corrected the item identified in "...Second Incomplete Submittal... " from the Division of Reclamation, Mining and Safety (DRMS), dated October 26, 2021. For convenience, we repeat the inadequacy item in italics followed by the corrections/updates made to address the item. The replacement page is attached. The receipt from Weld County of this errata page is also attached. Comment 1 The Applicant's response stated, "We have updated the application to reflect the survey - verified 114.25 acres as reported in Exhibits A and D. " Please provide a copy of a revised Exhibit D indicating a proposed permit acreage of 114.25 acres. Response 1 We modified the language on page 6 of Appendix D from "approximately 114 acres" to simply (114.25 acres). If you have any questions or concerns with this update, please contact Stephanie Fancher- English or me at your earliest convenience. Sincerely, Telesto Solutions, Inc. Walter L. Niccoli, PE Principal/Senior Engineer WLN:wsc Enclosure Colorado Office (Corporate) New Mexico Office 750 14th Street SW Loveland, Colorado 80537 970-484-77041970-484-7789 (FAX) 1303 Pope Street Silver City, New Mexico 88061 575-538-56201575-538-5625 (FAX) 6.0 EXHIBIT D — MINING PLAN This exhibit provides the information required by Section 6.4.4 of the Rules and Regulations. 6.1 Mining Methods and Surface Disturbance Section 6.1 provides the information required in Sub -section 6.4.4(a) Rules and Regulations. The entire site consists of 114.25 acres. There are approximately 76 acres that LRM will utilize for mining. Approximately 38 acres of the site will consist of boundary offsets, perimeter buffering the main access road, the Big Thompson River corridor, and stormwater management areas. 6.1.1 Site Preparation The site will first be cleared of unneeded existing structures (old fencing and cattle chutes). The topsoil, if present, material will be stripped as each Cell is mined. Stripping will occur in phases or "strips" approximately 1/8th to 1/4th of the size of the Cell to expose the active mining area. The stripped material will be stockpiled adjacent to the active mining area. Scrapers, front-end loaders, excavators, and bulldozers may be used for stripping. Topsoil stockpiles, ditches and grading may be used to direct stormwater into the mining cells. Exhibit C shows the quantities of topsoil for each phase. A typical topsoil stockpile berm size will be 36 feet in width, 10 foot high, or 6.6 sq-yd per ft. The topsoil stockpiles will be stabilized, and erosion control devices will be installed. If the topsoil stockpiles will be in place for an extended amount of time it will be seeded to produce a vegetated cover. An access bridge across the Big Thompson River will require a 404 Permit to construct. As part of the 404 Permit the bridge will be installed and analyzed to certify that it does not create a rise in the floodway. Haul roads will be established and stabilized during site preparation. Loveland Ready -Mix, Concrete, Inc. 6 30310913_master_application_Inn_drompit_final draft.docx September 2021 TELESTO Receipt From Weld County Clerk and Recorder {or: Knox pit, DR/M5 Permit / pplica tio,7 No • /M2027-059 2nd Mcomple to Submittal Resp rase wd Errata dated 10/26/21 WED CLERK & RECORDER Received. te.1 ' , by (stamp rn 1 signature): 40 January 4, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Adequacy Review Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS/Office) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application for the Dunn Pit, File No. M- 2021-059 and submits the following comments. The Division is required to issue an approval or denial decision no later than January 30, 2022, therefore a response to the following adequacy review concerns should be submitted to the Division as soon as possible. The review consisted of comparing the application contents with the specific requirements of Rules 1, 3, 6.1, 6.2, 6.4 and 6.5 of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials effective date July 15, 2019. Any inadequacies are identified under the respective exhibit heading along with suggested actions to correct them. Comments 1. The Division received state agency comments from History Colorado and the Division of Water Resources. The letters are attached for review. Please address the comments submitted for the application and revise the application accordingly. 1.6 Public Notice 2. Pursuant to Rules 1.6.2(1)(d) and 1.6.5(2), please submit proof of publication in a newspaper of general circulation in the locality of the proposed mining operation. 3. Pursuant to Rule 1.6.2(e), please submit proof of the notice to all owners of record of surface and mineral rights of the affected land and the owners of record of all land surface within 200 feet of the boundary of the affected land including all easement holders located on the affected land and within 200 feet of the boundary of the affected land. Proof of notice may be return receipts of a Certified Mailing or by proof of personal service. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Dunn Pit Adequacy Review Page 2 of 7 January 4, 2022 6.4 Specific Exhibit Requirements - Regular 112 Operations The following items must be addressed by the Applicant in order to satisfy the requirements of C.R.S. 34-32.5-101 et seq. and the Mineral Rules and Regulations of the Mined Land Reclamation Board: 6.4.1 Exhibit A - Legal Description 4. The main mine entrance location listed in Exhibit A - Legal Description, 40.341275, -104.872903, differs from the entrance location listed on the application form, 40.341276, -104.874737. Please explain this discrepancy the revise Exhibit A or the application form accordingly. 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land 5. The Applicant indicated the type of structures and the location of significant, valuable and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land on the Exhibit C-17 map. Pursuant to Rule 6.4.3(g), please show the owner's name for the permanent man-made structures on the map. 6.4.4 Exhibit D - Mining Plan 6. On Page 6, Section 6.1.1, the Applicant states if the topsoil stockpiles will be in place for an extended amount of time it will be seeded to produce a vegetated cover. Please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. 7. On Page 7, Section 6.1.2, the Applicant states since the material is mined "wet", mined slopes will be 1.5V:1H. Please explain how the Applicant will verify the "wet" mined slopes are mined at a 1.5V:1H slope. 6.4.5 Exhibit E - Reclamation Plan 8. On Page 12, Section 7.0, the Applicant states seeding/vegetating overburden and topsoil stockpiles that will be exposed longer than one year will occur. As noted in Item #6, please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. 9. On Page 12, Section 7.0, the Applicant states the backfilling and sloping sides of mining cells with excess topsoil will occur during reclamation. Please explain the earthmoving processes the Applicant intends to implement to backfill and compact the mined slopes and shorelines with topsoil during reclamation. 10. On Page 12, Section 7.1, the Applicant states the Dunn Pit will be returned to a post -mining land use of wildlife habitat with groundwater sources ponds as each of the three phases are completed. Please commit to providing the Division with a copy of the final groundwater augmentation plan approved by the Division of Water Resources (DWR), when available. Dunn Pit Adequacy Review Page 3 of 7 January 4, 2022 11. The Applicant has not obtained the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. Therefore, the Division will require the Applicant to provide a reclamation bond to include the backfilling of the exposed groundwater until the final augmentation plan is obtained from the DWR. The Division calculated the reclamation bond based on this requirement. 12. On Page 12, Section 7.1, the Applicant states slopes of 3:1 will be established above the water surface and slopes of 2:1 will be established at or below the water surface. Rule 3.1.5(7) states, "In all cases where a lake or pond is produced as a portion of the Reclamation Plan, all slopes, unless otherwise approved by the Board or Office, shall be no steeper than a ratio of 2:1 (horizontal to vertical ratio), except from 5 feet above to 10 feet below the expected water line where slopes shall be not steeper than 3:1." Please revised Exhibit E to comply with the requirements of Rule 3.1.5(7). 13. On Page 13, Section 7.3.1, the Applicant states the final grading will be no steeper than 2H:1V below water surface and 3H:1V above water surface which will create a final topography that is appropriate for natural open space or wildlife habitat. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H:1V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit E accordingly. 14. On Page 15, Section 7.3.4, the Applicant states the stockpiles that will remain in place for more than one season will be seeded to stabilize them and minimize erosion. As noted in Item #6, please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. 15. Pursuant to Rule 6.4.5(f)(iii), please provide a description of the fertilization to be implemented during reclamation, if applicable, and specify the types, mixtures, quantities and time of application. 16. On Page 16, Section 7.4.2, the Applicant states grass or straw will be crimped in place with a mechanical crimper made for such purposes or using a farm -type disc plow set straight with adequate weigh to crimp the material to a depth of approximately 4 inches. Please provide the tons per acre of mulching proposed during reclamation. 17. Please provide a Weld County approved Noxious Weed Management Plan including at minimum the target species, mitigation measures and treatment schedule. 6.4.5 Exhibit F - Reclamation Plan Map 18. On Exhibit F-1, Section A -A', the Applicant indicates a final reclamation slope of 1.5H:1V below the water line and 3H:1V above the waterline. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H:1V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit F-1 accordingly. Dunn Pit Adequacy Review Page 4 of 7 January 4, 2022 Additionally, in the proposed Reclamation Plan the Applicant states slopes of 3H:1V will be established above the water surface and slopes of 2H:1V will be established at or below the water surface. Please explain this discrepancy and revise Exhibit F-1 accordingly. 19. On Exhibit F-3, Sections B -B' and C -C, the Applicant indicates a final reclamation slope of 1.5H:1V below the water line and 3H:1V above the waterline. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H:1V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit F-3 accordingly. Additionally, in the proposed Reclamation Plan the Applicant states slopes of 3:1 will be established above the water surface and slopes of 2:1 will be established at or below the water surface. Please explain this discrepancy and revise Exhibit F-3 accordingly. 6.4.6 Exhibit G - Water Information 20. A constructed well is indicated on Figure 2 - Water Rights Structures located in the southeast corner of the site, however the owner of the well is not indicated on the map. Please revise the Figure 2 map to indicate the owner of the well and provide proof of notification to the well owner. 21. On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. Please confirm the list includes all wells within 600 feet the permit boundary. 22. On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. The following wells were not indicted on Figure F-2. Please explain this discrepancy and revise Exhibit G accordingly. a. Mad Russian Well (59968-F) b. Loveland Ready Mix (61849-MH and 61850-MH) 23. On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. The Applicant did not submit proof of notification to the following well owners. Please explain this discrepancy and revise Exhibit G accordingly. a. Hall Irwin (248398) b. Mad Russian Well (59968-F) 24. The Applicant provided proof of notification for well no. 12892-R owned by Paul and James Nelson. Please revise the list of constructed wells in Section 9.2.3 of Exhibit G to include the well owners. 6.4.9 Exhibit I - Soils Information 25. The Applicant provided a figure and map of the NRCS soils report for the proposed mine site. Please provide a copy of the complete NRCS soils report for Division review. Dunn Pit Adequacy Review Page 5 of 7 January 4, 2022 6.4.12 Exhibit L - Reclamation Costs 26. The Division calculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant in the application and the Division's requirement to include the cost to backfill the exposed groundwater until the final augmentation plan is obtained from the DWR at $3,018,000.00. A copy of the Division's bond estimate is attached for review. 6.4.13 Exhibit M - Other Permit and Licenses 27. Please commit to providing copies of all required and approved permits and licenses to the Division, when available. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 28. Please provide an affidavit or receipt indicating the date on which the revised application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). 6.4.19 Exhibit S - Permanent Man-made Structures Where the affected lands are within two hundred (200) feet of any significant, valuable and permanent man-made structures, the Applicant may either: a. provide a notarized agreement between the Applicant and the person(s) having an interest in the structure, that the Applicant is to provide compensation for any damage to the structure; or b. where such an agreement cannot be reached, the Applicant shall provide an appropriate engineering evaluation that demonstrates that such structure shall not be damaged by activities occurring at the mining operation; or c. where such structure is a utility, the Applicant may supply a notarized letter, on utility letterhead, from the owner(s) of the utility that the mining and reclamation activities, as proposed, will have "no negative effect" on their utility. The Division will require the Applicant to demonstrate they attempted to obtain notarized structure agreements with all owners of the structures within 200 feet of the affected area of the proposed mine site, pursuant to Rule 6.4.19, prior to the Division's consideration of a stability analysis. 29. The Division did not receive proof of notification for the following permanent man-made structures owners within 200 feet of the boundary of the affected land as identified by the Applicant in Exhibit S. Please provide proof of notification for the following owners of record: a. Telecommunications (TDS Telecom and Zayo Bandwidth) b. Overhead Powerline (Xcel Energy and Century Link) c. Natural Gas (Xcel Energy and DCP Midstream) Dunn Pit Adequacy Review Page 6 of 7 January 4, 2022 d. Water (Little Thompson Water District) e. Coulson Excavating f. Dunn Residence, outbuilding g. Martin Del Campo Residence, outbuilding h. Nelson Family LLC i. Paul Wagner Residence j. Mad Russian Golf Course 30. Please provide the Division with copies of all signed structure agreements with the owners of permanent man-made structures within 200 feet the proposed affected area boundary. 31. The Applicant submitted a copy of the structure agreement cover letter for Janice Knaub. Ms. Knaub is not listed as a permanent man-made structure owner in Exhibit S or on Exhibit C-17. Please explain this discrepancy and revise the Exhibits as required. 32. The Inlet Protection report submitted for the Dunn Pit application was reviewed by Rob Zuber with the Division. A copy of Mr. Zuber's review memo dated December 17, 2021 is attached. Please respond to the adequacy questions contained in the memo. 33. Exhibits F, G and Appendix D for the Dunn Pit application were reviewed by Patrick Lennberg with the Division. A copy of Mr. Lennberg's review memo dated December 9, 2021 is attached. Please respond to the adequacy questions contained in the memo. 6.5 Geotechnical Stability Exhibit 34. The Applicant submitted a Factor of Safety calculation based on assumed soil properties to demonstrate the geotechnical stability of the mined and reclaimed slopes. The Division will require the Applicant to provide an engineering stability analysis for the proposed mined and reclaimed slopes. The model must be performed using stability analysis software to allow verification of the models by the Division. The stability analysis model must assume the worst - case scenario for the mined and reclaimed slopes. 35. The Geotechnical Stability cover letter states the analysis shows that LRM can excavate the pits wet using a large excavator, but that the excavator will require a working platform roughly 16'x20' to distribute the load. The platform requirement is not discussed in Exhibit D - Mining Plan. Please revise Exhibit D to incorporate the requirements of the geotechnical stability report. 36. The Applicant selected a required factor of safety (FOS) of 1.3 from Table 1— Recommended Minimum Factors of Safety for Slope Stability Analyses for Operations and Reclamation. The selected FOS is for strength measurements resulting from multiple tests. The Division does not agree the Applicant's utilization of the results of particle -size distributions and boring logs qualifies as tests. The Division will require the Applicant to meet a factor of safety of 1.5, unless laboratory strength tests were performed on soils at the site. Dunn Pit Adequacy Review Page 7 of 7 January 4, 2022 37. In the Conclusions section of the stability report, the Applicant states it is safe for DRMS's reclamation slope of 2H:1V, and can be steepened to 1.78H:1V during mining as long as a platform is used beneath the excavator to distribute the weight. The Applicant proposed a mining slope of 1.5H:1V in Exhibit D - Mining Plan. Please revise Exhibit D to incorporate the requirements of the geotechnical stability report. Please be advised the Dunn Pit application may be deemed inadequate, and the application may be denied on January 30, 2022, unless the above mentioned adequacy review items are addressed to the satisfaction of the Division. If more time is needed to complete the reply, the Division can grant an extension to the decision date. This will be done upon receipt of a written waiver of the Applicant's right to a decision by January 30, 2022 and request for additional time. This must be received no later than the decision date. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Sincerely, Peter S. Hays Environmental Protection Specialist Enclosures - History Colorado Comment Letter Division of Water Resources Comment Letter Reclamation Cost Estimate dated December 22, 2021 Zuber Review Memo dated December 17, 2021 Lennberg Review Memo dated December 9, 2021 Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. History Colorado Peter Hays Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Re: Dunn Pit, File No. M-2021-059 (HC# 80573) Dear Mr. Hays: We received your letter dated November 01, 2021 initiating consultation with our office on the subject action pursuant to the Colorado State Register Act — Colorado Revised Statute (CRS) 24-80.1 et. seq. A search of our database indicates that two sites (5WL.10 and 5WL.841) are located within or adjacent to the permit area. Site 5WL.10 did not have an assessment provided on the form, and site 5WL.841 is a segment of the officially eligible Great Western Railroad. As there are no properties of historical significance included or nominated for inclusion in the state register currently documented within the proposed permit area, a finding of no adverse effect to significant properties is appropriate. As most of Colorado has not been inventoried for cultural resources, our files contain incomplete information. Consequently, there is the possibility that as yet unidentified cultural resources exist within the proposed permit area. The requirements under CRS 24-80 part 13 apply and must be followed if human remains are discovered during ground disturbing activities. Please note that if the fill or disposal site location is associated with a Federal undertaking, it is the responsibility of the federal agency to meet the requirements of Section 106 as set forth in 36 CFR Part 800 titled "Protection of Historic Properties". This includes not only reasonable and good faith identification efforts of any historic properties located within the area of potential effects, but determining whether the undertaking will have an effect upon such properties. The State Historic Preservation Office, Native American tribes, representatives of local governments, and applicants for federal permits are entitled to consultative roles in this process. We thank you for the opportunity to comment. If we may be of further assistance, please contact Holly McKee -Huth, Cultural Resource Information/Section 106 Compliance at (303) 866- 4670/holly.mckee@state.co.us. Sincerely, °L'eFeill12--frL-1 Dawn DiPrince State Historic Preservation Officer SG COLORADO Division of Water Resources Department of Natural Resources Response to Consideration Construction Materials Reclamation Permit Conversion Application DATE: November 16, 2021 TO: Peter S. Hays, Environmental Protection Specialist FROM: Javier Vargas -Johnson, Water Resources Engineer RE: Dunn Pit, Permit No. M-2021-059 Applicant/Operator: Loveland Ready -Mix Concrete, Inc. Phone Number: (970) 667-1108 NE' Section 3, Twp. 4 North, Rng. 67 West, 6th P.M., Weld County Water Division 1, Water District 4 CONDITIONS FOR APPROVAL ❑x The proposed operation will consume groundwater by: ❑x evaporation, ❑x dust control, ❑x reclamation, ❑x water removed in the mined product, ❑ processing, ❑ other. ❑x Prior to initiation of these uses of groundwater, the applicant will need to obtain either a gravel pit or other type of well permit, as applicable. However, prior to obtaining a permit, an approved substitute water supply plan or decreed plan for augmentation is required. ❑x Prior to approving a well permit, the applicant must conduct a field inspection of the site and document the locations of wells within 600 feet of the permit area. The applicant must then obtain a waiver of objection from all well owners with wells within 600 feet of the permit area or request a hearing before the State Engineer. ❑x Any stormwater runoff intercepted by this operation that is not diverted or captured in priority must be released to the stream system within 72 hours; otherwise the operator will need to make replacements for evaporation. COMMENTS: The subject application is for a surface mining operation on 118 permitted acres located approximately 1 mile northwest of the Town of Milliken. The primary commodities to be mined at the site are sand and gravel. The site is proposed to be reclaimed to a land use of wildlife habitat, groundwater sourced ponds, and mitigated wetlands and open space. The site is proposed to be wet mined. An excavator will be used to mine material wet down to the bedrock, estimated to be approximately 30 feet below ground surface. Prior to the exposure of any groundwater at the site, the applicant must first obtain a well permit and valid substitute water supply plan or decreed plan for augmentation. The applicant has submitted a request for a substitute water supply plan to this office and an application for a gravel pit permit. The requested start date of the substitute water supply plan is January 2023, when the applicant expects to have obtained approval of all necessary permits. The consumptive use of groundwater at the site by evaporation, dust control, water retained in the mined product, and reclamation vegetation establishment is estimated total 21.80 acre-feet during the first year of operation. The applicant has an agreement with the City of Loveland for the supply of replacement water necessary for the operation and approval of the substitute water supply plan. I.;' S • .:...ii._i. ,,,.:- - F.!:::.-i 's:" . •) 11LlGls:; J•: c c.:}. ':.r: L.:rta r:: ::.1 1 ;. I I:•s.. c c .I i4 : I]r: •: i : Ia:i r C.. Peter Hays Page 2 of 2 November 15, 2021 The final reclamation plan includes unlined ponds of exposed groundwater at the site. The ponds will be required to be included in a plan for augmentation prior to final release of the site. Stormwater will be diverted into the mining cells or be allowed to flow through the site using historical channels in undisturbed portions of the site. If stormwater runoff is intercepted by this operation and is not diverted or captured in priority, it must be released to the stream system or infiltrate into the ground within 72 hours; otherwise the operator will need to make replacements for evaporation from the surface area of the intercepted stormwater. The Applicant has conducted a baseline groundwater assessment to determine support geotechnical analyses, wetland mitigation decisions, and to assess potential impacts associated with the proposed sand and gravel mine. As part of the baseline groundwater assessment the applicant has constructed four monitoring wells. The Division of Reclamation Mining & Safety and/or the applicant may contact the State Engineer's Office with any questions. COST SUMMARY WORK Task description: Site: Dunn Pit Dunn Pit Bond Estimate PROJECT IDENTIFICATION Task #: 000 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado County: Weld Agency or organization name: DRMS TASK LIST (DIRECT COSTS) Abbreviation: None Filename: M059-000 Task Description Form Used Fleet Size Task Hours Cost 001 002 003 004 005 006 007 008 Revegetate Cl Shoreline REVEGE 1 1 1 1 1 1 1 1 40.00 $1.884 $6.114 $1.110 $629 $132 $564 $3.649 $2,420,000 Topsoil Cl Shoreline TRUCK1 13.06 Revegetate Cl Wetlands REVEGE 20.00 Slope Cl West Slope DOZER 3.72 Rip Access Road RIPPER 0.73 Revegetate Access Road REVEGE 20.00 Mob / Demob MOBILIZE 5.37 Bond to Backfill Cl until Augmentation Decree SITEMAINT ENANCE 160.00 SUBTOTALS: 262.88 $2,434,082 INDIRECT COSTS OVERHEAD AND PROFIT: Liability insurance: 2.02 Total = Performance bond: 1.05 Total = Job superintendent: 131.44 Total = Profit: 10.00 Total = $243,408 TOTAL 0 & P = $327,602 CONTRACT AMOUNT (direct + O & P) = $49,168 $25,558 $9,468 LEGAL - ENGINEERING - PROJECT MANAGEMENT: $2,761,684 Financial warranty processing (legal/related costs): $500 Total = $500 Engineering work and/or contract/bid preparation: 4.25 Total = $117,372 Reclamation management and/or administration: 5.00 $138,084 CONTINGENCY: 0.00 Total = $0 TOTAL INDIRECT COST = $583,558 TOTAL BOND AMOUNT (direct + indirect) = $3,018,000 (Rounded) Page 1 of 2 REVEGETATION WORK Task description: Revegetate Cl Shoreline Site: Dunn Pit PROJECT IDENTIFICATION Task #: 001 Date: 12/21/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado County: Weld Agency or organization name: DRMS FERTILIZING Materials Abbreviation: None Filename: M059-001 Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Blue Grama - Hachita 0.75 12.24 $11.98 Alkali Sacaton 1.00 39.03 $28.48 Alkaligrass, Fult's 0.50 13.77 $1.81 Canada Wildrye 3.00 7.92 $32.52 Bottlebrush Squirreltail 2.25 9.92 $36.51 Western Wheatgrass - Arriba 10.00 25.25 $65.00 Saltgrass, Inland 0.50 6.93 $21.40 115.06 $197.70 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 001 Page 2 of 2 Totals Seed Mix 18.00 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D @ 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Weed spray, truck, non -aquatic area, nox. [DMG] $62.72 Weed spray, truck, non -aquatic areas, ann. [DMG] $22.81 Total Mulch Application Cost/Acre $157.10 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 1.47 Cost /Acre: $1,102.46 Estimated Failure Rate: 25% Cost /Acre*: $715.56 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $1,620.62 Reseeding Job Cost: $262.97 Total Job Cost: $1,884 Job Hours: 40.00 CIRCES Cost Estimating Software Page 1 of 4 TRUCK/LOADER TEAM WORK Task description: Topsoil Cl Shoreline Site: Dunn Pit PROJECT IDENTIFICATION Task #: 002 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059-002 Agency or organization name: DRMS HOURLY EQUIPMENT COST Truck Loader Team -Truck: -Loader: Equipment Description Generic 7-8 cy, 4x4 CAT 928Hz Shift basis: 1 per day Support Equipment -Load Area: -Dump Area: Road Maintenance —Motor Grader: -Water Truck: Cat D6T XL NA CAT 14M NA Cost Breakdown: Truck/Loader Team Support Equipment Maintenance Equipment Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 15 50 NA 75 NA Ownership cost/hour: $16.03 $30.09 $64.38 NA $85.80 NA Operating cost/hour: $25.50 $4.48 $32.31 NA $45.30 NA %Utilization -riper: NA 0 NA NA NA NA Ripper own. cost/hour: NA $0.00 $0.00 NA $0.00 NA Ripper op. cost/hour: NA $0.00 $0.00 NA $0.00 NA Operator cost/hour: $0.00 $35.97 $40.04 NA $46.87 NA Unit Subtotals: $41.53 $70.54 $136.73 NA $177.97 NA Number of Units: 2 1 1 0 1 0 Group Subtotals: Work: $153.60 Support: $136.73 Maint: $177.97 Total work team cost/hour: $468.30 MATERIAL QUANTITIES Initial volume: Loose volume: 2,378 CCY Swell factor: 1.000 2,378 LCY Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: Division of Reclamation, Mining & Safety Cat Handbook $0.00 $0.00 HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: 1,600 Pounds/LCY Description: Top Soil Rated Payload: 20,300 Pounds CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 002 Page 2 of 4 Payload Capacity: 12.69 LCY Truck Bed (volume) Basis: Struck Volume: 7.00 LCY Heaped Volume: 8.00 LCY Average Volume: 7.50 LCY Adjusted Volume: 8.00 LCY Final Truck Volume Based on Number of Loader Passes: Loading Tool Capacity Rated Capacity: Bucket Fill Factor: Adjusted Capacity: 3.000 LCY (heaped) Loose material - mixed moist aggregates (95-100%) 0.975 LCY 5.85 LCY Bucket Size Class: NA 0.975 2.925 Job Condition Corrections: Site Altitude (ft.): 4745 feet Truck Loader Source Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: NA Number of Loading Tool Passes Required to Fill Truck: Selected Value within this Basic Rating: NA Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA 2 passes Maneuver: NA Dump: 0.100 Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): 0.475 minutes Cycle Time Factors Factor (min.) Source Material: Material up to 1/8" diameter 0.02 0.020 (Cat HB) Stockpile: Conveyor or dozer piled 10 ft. high or less 0.01 0.010 (Cat HB) Truck Ownership: Common ownership of trucks and loaders - 0.04 -0.040 (Cat HB) Operation: Constant operation -0.04 -0.040 (Cat HB) Dump Target: Nominal target 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: Adjusted Loader Cycle Time: Net Load Time per Truck: Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 0.525 Minutes Truck Maneuver and Dump 0.80 Minutes Time: -0.050 0.425 0.525 minutes minutes minutes Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 0.525 Minutes Adjusted for site altitude: 0.800 Minutes CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 002 Page 3 of 4 Truck Travel (Haul & Return) Time: Road Condition: Firm, smooth, rolling, dirt/lt. surfaced, watered, maintained 3.0 CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 002 Page 4 of 4 Haul Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (min) 1 1200.00 5.00 3.00 8.00 1381 0.898 Haul Time: Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (min) 1 1200.00 -5.00 3.00 -2.00 2938 0.476 0.898 minutes Return Time: 0.476 Total Truck Cycle Time: 3.199 minutes minutes Loading Tool unit Production 342.44 LCY/Hour Adjusted for job efficiency: 284.22 LCY/Hour Truck Unit Production 109.72 LCY/Hour Adjusted for job efficiency: 91.07 LCY/Hour Optimal No. of Trucks: 3 Truck(s) Selected Number of Trucks: 2 Truck(s) Adjusted hourly truck team production: 182.14 LCY/Hour Adjusted single truck/loader team production: 182.14 LCY/Hour Adjusted multiple truck/loader team production: 182.14 LCY/Hour JOB TIME AND COST Fleet size: 1 Team(s) Total job time: 13.06 Hours Unit cost: $2.571 /LCY Total job cost: $6,114 CIRCES Cost Estimating Software Page 1 of 2 REVEGETATION WORK Task description: Revegetate Cl Wetlands Site: Dunn Pit PROJECT IDENTIFICATION Task #: 003 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado County: Weld Agency or organization name: DRMS FERTILIZING Materials Abbreviation: None Filename: M059-003 Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Indiangrass - Cheyenne 1.20 3.66 $13.56 Switchgrass - Blackwell 1.50 13.40 $17.25 Alkali Bulrush 1.50 14.81 $60.75 Creeping Spike Rush 0.60 8.54 $108.60 Needle Spike Rush 0.40 5.69 $90.80 Canada Wildrye 1.50 3.96 $16.26 Softstem Bulrush 0.60 7.58 $78.63 Hardstem Bulrush 0.60 5.58 $89.82 Three Square Bulrush 0.60 4.13 $103.05 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 003 Page 2 of 2 Cordgrass, Prairie 0.70 2.94 $56.00 Nebraska Sedge 0.60 12.57 $99.90 Woolly Sedge 0.20 1.48 $30.30 Totals Seed Mix 10.00 84.33 $764.92 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D @ 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Weed spray, hand, aquatic area, annuals [DMG] $199.47 Weed spray, hand, aquatic area, nox. [DMG] $183.16 Total Mulch Application Cost/Acre $454.20 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 0.47 Cost /Acre: $1,966.78 Estimated Failure Rate: 25% Cost /Acre*: $1,579.88 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $924.39 Reseeding Job Cost: $185.64 Total Job Cost: $1,110 Job Hours: 20.00 CIRCES Cost Estimating Software Bulldozer Worksheet Cont'd Task # 004 Page 1 of 2 BULLDOZER WORK Task description: Slope Cl West Slope Site: Dunn Pit Permit Action: Bond Estimate Permit/Job#: M2021059 PROJECT IDENTIFICATION Task #: 004 Date: 12/22/2021 User: PSH State: Colorado Abbreviation: None County: Weld Filename: M059-004 Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat D6T XL Horsepower: 185 Blade Type: Semi -Universal Attachment: NA Shift Basis: 1 per day Data Source: (CRG) Cost Breakdown: Ownership Cost/Hour: Operating Cost/Hour: Ripper own. Cost/Hour: Ripper op. Cost/Hour: Operator Cost/Hour: $64.38 Utilization % NA $64.62 100 $0.00 NA $0.00 0 $40.04 NA Total unit Cost/Hour: $169.04 Total Fleet Cost/Hour: $169.04 MATERIAL QUANTITIES Initial Volume: Swell factor: Loose volume: 1,564 1.000 1,564 LCY Source of estimated volume: Source of estimated swell factor: HOURLY PRODUCTION Average push distance: Unadjusted hourly production: Division of Reclamation, Mining & Safety Cat Handbook 50 feet 444.6 LCY/hr Materials consistency description: Partly consolidated stockpile 1.1 Average push -30 % gradient: Average site altitude: 4,745 feet Material weight: 1,600 lbs/LCY Weight description: Top Soil Job Condition Correction Factor Operator Skill: 0.750 Source (AVG.) Bulldozer Worksheet Cont'd Task # 004 Page 2 of 2 Material consistency: Dozing method: Visibility: Job efficiency: Spoil pile: Push gradient: Altitude: Material Weight: Blade type: Adjusted unit production: Adjusted fleet production: 1.100 (CAT HB) 1.000 (GEN.) 1.000 (AVG.) 0.830 (1 SHIFT/DAY) 0.600 (FND-SF) 1.601 (CAT HB) 1.000 (CAT HB) 1.438 (CAT HB) 1.000 (PAT) Net correction: 0.9459 JOB TIME AND COST Fleet size: Unit cost: 420.55 LCY/hr 420.55 LCY/hr 1 Dozer(s) $0.402/LCY Total job time: 3.72 Hours Total job cost: $629 Task description: Site: Dunn Pit BULLDOZER RIPPING WORK Rip Access Road PROJECT IDENTIFICATION Task #: 005 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059-005 Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat D6T XL Ripper Attachment: 3 -Shank Ripper Cost Breakdown: Ownership Cost/Hour: Operating Cost/Hour: Ripper Ownership Cost/Hour: Ripper Operating Cost/Hour: Operator Cost/Hour: Total Unit Cost/Hour: Horsepower: Shift Basis: Data Source: 185 1 per day (CRG) $64.38 Utilization % NA $64.62 100 $5.99 NA $4.30 100 $40.04 NA $179.33 Total Fleet Cost/Hour: $179.33 MATERIAL QUANTITIES Alternate Methods: Seismic: NA Selected estimating method: Area Bank Volume: NA Area: 0.44 acres Rip Depth (ft): 0.50 Source of estimated quantity: Permit Application HOURLY PRODUCTION Seismic: Area: BCY NA Volume: 355 BCY or CCY Seismic Velocity: Average Ripping Depth: Average Ripping Width: Average Ripping Length: Average Dozer Speed: Average Maneuver Time: Production per unit area: Job Condition Correction Factors Unadjusted Hourly Unit Production: Site Altitude: Altitude Adj: Job Efficiency: Net Correction: NA feet/second 1.64 6.58 200.00 88.00 0.25 0.719 feet/pass feet/pass feet/pass feet/minute minutes/pass acres/hour 0.719 Acres/hr 4,745 1.00 0.83 0.83 Adjusted Hourly Unit Production: Adjusted Hourly Fleet Production: feet (CAT HB) (1 shift/day) multiplier 0.60 Acres/hr 0.60 Acres/hr JOB TIME AND COST Fleet size: 1 Grader(s) Total job time: 0.74 Hours Unit cost: $300.695 Per acre Total job cost: $132 CIRCES Cost Estimating Software Page 1 of 2 REVEGETATION WORK Task description: Revegetate Access Road Site: Dunn Pit PROJECT IDENTIFICATION Task #: 006 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado County: Weld Agency or organization name: DRMS FERTILIZING Materials Abbreviation: None Filename: M059-006 Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Blue Grama - Hachita 0.75 12.24 $11.98 Alkali Sacaton 1.00 39.03 $28.48 Alkaligrass, Fult's 0.50 13.77 $1.81 Canada Wildrye 3.00 7.92 $32.52 Bottlebrush Squirreltail 2.25 9.92 $36.51 Western Wheatgrass - Arriba 10.00 25.25 $65.00 Saltgrass, Inland 0.50 6.93 $21.40 115.06 $197.70 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 006 Page 2 of 2 Totals Seed Mix 18.00 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D @ 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Weed spray, truck, non -aquatic area, nox. [DMG] $62.72 Weed spray, truck, non -aquatic areas, ann. [DMG] $22.81 Total Mulch Application Cost/Acre $157.10 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 0.44 Cost /Acre: $1,102.46 Estimated Failure Rate: 25% Cost /Acre*: $715.56 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $485.08 Reseeding Job Cost: $78.71 Total Job Cost: $564 Job Hours: 20.00 CIRCES Cost Estimating Software Page 1 of 2 EQUIPMENT MOBILIZATION/DEMOBILIZATION Task description: Mob / Demob Site: Dunn Pit PROJECT IDENTIFICATION Task #: 007 Date: 12/22/2021 User: PSH Permit Action: Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059-007 Agency or organization name: DRMS EQUIPMENT TRANSPORT RIG COST Shift basis: Cost Data Source: 1 per day CRG Data Truck Tractor Description: GENERIC ON -HIGHWAY TRUCK TRACTOR, 6X4, DIESEL POWERED, 400 HP (2ND HALF, 2006) Truck Trailer Description: GENERIC FOLDING GOOSENECK, DROP DECK EQUIPMENT TRAILER (25T, 50T, AND 100T) Cost Breakdown: Available Rig Capacities 0-25 Tons 26-50 Tons 51+ Tons Ownership Cost/Hour: $21.28 $37.94 $47.67 Operating Cost/Hour: $26.55 $50.48 $56.21 Operator Cost/Hour: $20.54 $20.54 $20.54 Helper Cost/Hour: $0.00 $23.53 $23.53 Total Unit Cost/Hour: $68.37 $132.49 $147.95 NON ROADABLE EQUIPMENT: Machine Description Weight/ Unit (TONS) Owner ship Cost/hr/ unit Haul Rig Cost/hr/uni t Fleet Size Haul Trip Cost/hr/ fleet Return Trip Cost/hr/ fleet DOT Permit Cost/ fleet Cat D6T XL 25.01 $70.37 $68.37 1 $138.74 $68.37 $250.00 CAT 14M 23.57 $85.80 $68.37 1 $154.17 $68.37 $250.00 CAT 928Hz 13.91 $30.09 $68.37 1 $98.46 $68.37 $250.00 Subtotals: ROADABLE EQUIPMENT: $391.37 $205.11 $750.00 Machine Description Total Cost/hr/ unit Fleet Size Haul Trip Cost/hr/ fleet Return Trip Cost/hr/ fleet Generic 7-8 cy, 4x4 $66.35 2 $132.70 $132.70 Light Duty Pickup, 4x4, 1 T. Crew $121.54 1 $121.54 $121.54 Subtotals: $254.24 $254.24 CIRCES Cost Estimating Software Mobilization Worksheet Cont'd Task # 007 Page 2 of 2 EQUIPMENT HAUL DISTANCE and Time Nearest Major City or Town within project area region: Total one-way travel distance: Average Travel Speed: Total Non-Roadable Mob/Demob Cost * `* two round trips with haul rig: Total Roadable Mob/Demob Cost ** ** one round trip, no haul rig: Transportation Cycle Time: Haul Time (Hours): Return Time (Hours): Loading Time (Hours): Unloading Time (Hours): Subtotals: JOB TIME AND COST GREELEY, CO 12.00 35.00 $3,474.49 $174.34 Non- Roadable Equipment Roadable Equipment 0.34 0.34 0.34 0.34 1.00 NA 1.00 NA 2.69 0.69 Total job time: miles mph 5.37 Hours Total job cost: $3,649 CIRCES Cost Estimating Software SITE MAINTENANCE Task description: Bond to Backfill Cl until Augmentation Decree Site: Dunn Pit PROJECT IDENTIFICATION Permit Action: Bond Estimate Permit/Job#: M2021059 Task #: 008 State: Colorado Date: 12/22/2021 County: Weld User: PSH UNIT COSTS Agency or organization name: DRMS Abbreviation: None Filename: M059-008 Maintenance Item Hours per Year Menu Selection Quantity Unit Unit Cost Total Cost Backfill Cl 160.00 USER PROVIDED ITEM 242,000.00 1 $10.00 $2,420,000.00 Job Hours: 160.00 Total Cost: $2,420,000.00 S0 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Interoffice Memorandum Date: December 17, 2021 From: Rob Zuber RDZ To: Peter Hays Subject: Dunn Pit (Permit No. M-2021-059), Adequacy review of application with focus on inlet protection design and HEC-RAS 2D model The submittal for this new application requires additional information for the inlet protection design and associated 2D HEC-RAS model. This includes the following adequacy items: 1. Please explain why the 9,000 cfs event is used for determining maximum velocities for weir designs. Were flows and velocities for larger storms not considered? In particular, the 100 -year storm is listed as 20,309 cfs. 2. Please provide design drawings for the pit inlet weirs, or reference other reports associated with this submittal that contain the drawings. 3. Please explain why bridge decks and piers are not included in the model. It appears that these structures could impact the velocities of flows into Cell 3, which is relatively close to the railroad bridge (approximately 200 feet upstream). 4. Please explain why there is no outlet protection for flood flows at the lower end of Cell 1. Include a discussion of velocities estimated with the 2D HEC-RAS model. 5. Please explain why no inlet protection is needed in areas other than the control points for each cell (shown on page 6 of the Inlet Protection Calculations). For example, for Cell 1 there is an area 250 - 300 feet east of the southwest corner where velocities in RAS Mapper (9,000 cfs) are greater than 13 feet per second. 6. Please explain the apparent discrepancies between pages 6 and 7 in terms of the sequence of flooding of the three cells. The table on page 6 suggests that flooding of Cell 2 occurs during smaller storm events than flooding of Cell 3; flooding of Cell 2 starts at 2000 cfs and flooding of Cell 3 starts at 4000 cfs. The discussion on page 7 states that flooding of Cell 2 and flooding of Cell 3 begin with approximately the same storm, approximately the 8 -year event. 7. The last page of the Inlet Protection Calculations (page 7) states that "riprapped inlet weirs were sized and included in Exhibit C of the mine plan." Can you be more specific where this is in the application? 8. Please elaborate on item 6 on page 7. Do the modeling results indicate the flows from backwater conditions will be low enough that additional bank protection (e.g., riprap) will not be needed, and vegetation will be sufficient? 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining. st ate. co. us Jared S. Polis, Governor Dan Gibbs, Executive Director I Virginia Brannon, Director ISe) DNR COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Date: December 9, 2021 To: Peter Hays, DRMS From: Patrick Lennberg, DRMS RE: Dunn Pit New Permit Application, Exhibits F, G and Appendix D Review Memo, File No. M2021-059 On September 25, 2021, I was requested to review Exhibits F, G and the Groundwater Baseline Study (Appendix D) of the Dunn Pit new permit application M2021-059, below are follow-up questions that should be addressed. Exhibit F 1. Please show the Hill and Brush Ditch orientation on the Reclamation Plan Map. Exhibit G 1. On Figure 2 the decreed surface water feature for the Hill and Brush Ditch is missing, please update the figure. 2. On Figure 2 the decreed groundwater feature for the Mad Russian Well (0405661) and constructed well (59968-F), and the 10 monitoring wells are missing please update. Appendix D 1. The applicant states, page 6, they will measure water levels in the 10 monitoring wells, installed in Summer 2021, monthly for one year then quarterly thereafter. The Division believes monthly water level monitoring should occur for at least one year after mining activities have begun to verify the numerical models predictions and monitor the effects of mining on the surrounding groundwater system. 2. How will the proposed open groundwater pond effect the surrounding ditches, Brush Ditch and the Big T and Platte Ditch in both the near term and long term? 3. What is the supposed source of toluene that was detected in MW -5? 4. In Section 5.3.1, it is stated the drawdown in the Dunn well is not expected to be greater than 2 feet. However, in Figure 16 the graphed drawdown approaches 4 feet. Please reconcile this discrepancy. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov/ Jared Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director 0037[;. Peter Hays Dunn Pit (M2021-059) Page 2 of 3 5. In Figure 16 three of the four wells graphed have a starting point that indicates increased water levels, shouldn't all wells begin at 0.0 indicating no mining influence? 6. All groundwater sample results need to be compared to the Water Quality Control Commission's (WQCC) Regulation No. 41 — The Basic Standards for Groundwater (Reg 41) and the most conservative values in Tables 1 thru 4 for all analytes listed for minimum of five consecutive quarters. The sample results from the June/August 2021 sampling event only compared results to WQCC Reg 41 Tables 1 and 2. Table 3 of Reg 41 are agriculture standards which contain a few analytes that Tables 1 and 2 omit. 7. Did the applicant sample for radionuclides that are part of Reg 41 Table 1? 8. Nitrate/Nitrite as N was sampled, Appendix B, in some wells but not others, why? 9. Nitrate, Nitrite, and Total Nitrate + Nitrite are Reg 41 Table 1 values that appear to have not been sampled in all wells, please comment. 10. The Division recognizes there will become a point when a reduction in groundwater level and quality monitoring frequency becomes reasonable. The reduction requests and approvals will be completed through submittal of a Technical Revision. 11. Section 6.1.5, the Dunn well is not an on -site monitoring well but rather an adjacent private well that may be influenced by mining. Is it the applicant's intent to extend the 5 foot trigger to this well? If so, are there historic groundwater level data to support this trigger value? 12. In Monitoring Well Drilling Summary Report, Section 2.1, it is stated during drilling soil samples were collected for SPLP testing. Please provide the results of these analysis? 13. In the text, Section 2.2, it is stated the monitoring well screen size used was 0.01" but on the boring logs the screen size indicated is 0.1", please clarify. Please note the discrepancy appears to have made onto the forms submitted to DWR. 14. In the Groundwater Sampling and Analysis Plan Section 1 it references a water management pond. Please provide more details of the pond and clearly show it on Figure 1. 15. Please update Table 2 to include the WQCC Reg 41 concentrations each analyte is compared to. 16. Please provide copies of the completed groundwater data sheet(s) for each well sampled. In the future the Division will require submittal of these sheets along with other sample data. Peter Hays Dunn Pit (M2021-059) Page 3 of 3 17. Field blanks, Section 7.2.2, the applicant proposes to collect a field blank once annually and the Division does agree this is appropriate. The purpose of the field blank is to assess contamination from field conditions during sampling. At least one field blank should be collected during each sampling event. Please revise to reflect at least one field blank will be collected during each sampling event. 18. Rinsate sample, Section 7.2.3, the applicant proposes to collect a rinsate sample twice annually and the Division does agree this is appropriate. The purpose of the rinsate sample is to assess the adequacy of the decontamination process. It assess contamination from the total sampling, sample preparation and measurement process, when decontaminated sampling equipment is used to collect samples. Please revise to reflect at least one rinsate sample will be collected during each sampling event as appropriate. 19. As mentioned in #6 above, the Division will require at least five consecutive quarters of baseline water quality measurements with samples results compared to the most conservative values in Reg 41 Tables 1-4. Additionally, quarterly groundwater monitoring will continue for at least one year after the mining activities started at the site. After one year of mining the operator may, through a Technical Revision, request decreasing both the list of analytes samples are analyzed for and the frequency of monitoring. If you need additional information or have any questions, please let me know. Sincerely, 44 -90 -- Patrick Lennberg Environmental Protection Specialist cc: Jared Ebert, DRMS TELESTO SOLUTIONS* INCORPORATED February 21, 2022 Via Electronic Mail Mr. Peter Hays Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Subject: Dunn Pit, File No. M-2021-059 Responses to 112c Permit Application Adequacy Review Dear Mr. Hays: We appreciate the Division's thorough and thoughtful adequacy review of Loveland Ready -Mix Concrete, Inc.'s (LRM's) 112c Permit Application for the Dunn Pit. This letter summarizes our responses, corrections, and clarifications regarding the Division's comments. We list the Division's comment in italics, followed by our response. Attachments 1 through 18 support our responses and/or update the required exhibits and documents. RULE 1 Comment I The Division received state agency comments from History Colorado and the Division of Water Resources. The letters are attached for review. Please address the comments submitted for the application and revise the application accordingly. Response 7 We subsequently address responses in this letter. RULE 1.6 Comment 2 Pursuant to Rules 1.6.2(1)(d) and 1.6.5(2), please submit proof of publication in a newspaper of general circulation in the locality of the proposed mining operation. Colorado Office (Corporate) New Mexico Office 750 14th Street SW Loveland, Colorado 80537 970-484-7704 / 970-484-7789 (FAX) 1303 Pope Street Silver City, New Mexico 88061 575-538-5620 / 575-538-5625 (FAX) To: Mr. Peter Hays Date: February 21, 2022 Page 2 Response 2 Proof of publication is provided as Attachment 1 to this response letter. Comment 3 Pursuant to Rule 1.6.2(e), please submit proof of the notice to all owners of record of surface and mineral rights of the affected land and the owners of record of all land surface within 200 feet of the boundary of the affected land including all easement holders located on the affected land and within 200 feet of the boundary of the affected land. Proof of notice may be return receipts of a Certified Mailing or by proof of personal service. Response 3 Attachment 2 provides proof mailing to 18 neighboring land and mineral rights owners within a 200 foot boundary of the Dunn Pit project. 6.4 SPECIFIC EXHIBIT REQUIREMENTS - REGULAR 112 OPERATIONS 6.4.1 Exhibit A - Legal Description Comment 4 The main mine entrance location listed in Exhibit A - Legal Description, 40.341275, - 104.872903, differs from the entrance location listed on the application form, 40.341276, -104.874737. Please explain this discrepancy the revise Exhibit A or the application form accordingly. Response 4 Discrepancies in the mine entrance latitude and longitude locations were the difference between the site's current entrance and the site's proposed entrance during the life of the mine. The correct location of the mine entrance is 40.341275, -104.872903. 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land Comment 5 The Applicant indicated the type of structures and the location of significant, valuable and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land on the Exhibit C-17 map. Pursuant to Rule 6.4.3(g), please show the owner's name for the permanent man-made structures on the map. 20220209_1045_DRMS AdequacgReview Response_MASTE R. do TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 3 Response 5 Adjacent property owners have been added to the figure, which is included as Attachment 3. 6.4.4 Exhibit D -Mining Plan Comment 6 On Page 6, Section 6.1.1, the Applicant states if the topsoil stockpiles will be in place for an extended amount of time it will be seeded to produce a vegetated cover. Please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. Response 6 LRM commits to seeding temporary stockpiles left in place longer than 180 days with a western wheat pasture grass seed mix (see Attachments 4 and 5). Comment 7 On Page 7, Section 6.1.2, the Applicant states since the material is mined "wet", mined slopes will be 1.5V:1H. Please explain how the Applicant will verify the "wet" mined slopes are mined at a 1. S V: 1 H slope. Response 7 LRM will used trained and experienced operators versed in the excavator specified for use. Based on boom placement, angles and digging depths, a trained operator can tell where the bucket is at any time, thus determining the ultimate slope beneath the water table. LRM plans to utilize GPS mounted equipment to also assist the operator. 6.4.5 Exhibit E Reclamation Plan Comment 8 On Page 12, Section 7.0, the Applicant states seeding/vegetating overburden and topsoil stockpiles that will be exposed longer than one year will occur. As noted in Item #6, please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. Response 8 LRM commits to seeding temporary stockpiles left in place longer than 180 days with a western wheat pasture grass seed mix (see Attachments 4 and 5). 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 4 Comment 9 On Page 12, Section 7.0, the Applicant states the backfilling and sloping sides of mining cells with excess topsoil will occur during reclamation. Please explain the earthmoving processes the Applicant intends to implement to backfill and compact the mined slopes and shorelines with topsoil during reclamation. Response 9 LRM will either tram or truck -haul topsoil to its location for placement. They will grade material out with a track mounted dozer to the water's edge. Utilizing the same track -hoe utilized for mining, an experienced operator will push/place material at the proper grade below the water's surface. LRM will also take advantage of the fluctuating groundwater table to push material beneath the water surface at the lowest groundwater elevation of the season. Once mining of a cell is complete, LRM will perform a bathymetric and verify compliance with the rule. Comment 10 On Page 12, Section 7.1, the Applicant states the Dunn Pit will be returned to a post -mining land use of wildlife habitat with groundwater sources ponds as each of the three phases are completed. Please commit to providing the Division with a copy of the final groundwater augmentation plan approved by the Division of Water Resources (DWR), when available. Response 10 LRM will provide the Division a copy of the final Augmentation Plan, once approved. LRM commits to use its Walters and Bokelman Pits site as the point of replacement (Decree 2009CW0105), which is already approved for augmenting the Dunn Pit site. LRM submitted a Gravel Pit Well Permit application and Substitute Water Supply Plan (SWSP) on September 1, 2021 to the DWR (invoice order #10256). The SWSP request covers January 2023 through December 2023 and describes estimated consumptive use from pit evaporation, dust suppression, aggregate entrainment, and reclamation vegetation establishment. The augmentation plan will include these components along with the water commissioner's shrink to move water down the Big Thompson. Comment 11 The Applicant has not obtained the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. Therefore, the Division will require the Applicant to provide a reclamation bond to include the backfilling of the exposed groundwater until the final augmentation plan is obtained from the DWR. The Division calculated the reclamation bond based on this requirement. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 5 Response 11 Decree 2009CW0105 approves water for augmenting the Dunn Pit. LRM is initiating the application process for a decreed augmentation plan for this committed water. LRM understands DRMS's position on the bonding requirement, and will commit to a place - holder bond prior to mining. LRM recommends a placeholder bond for this item of $300,000. This amount covers the estimated cost of the water court process. Comment 12 On Page 12, Section 7.1, the Applicant states slopes of 3:1 will be established above the water surface and slopes of 2:1 will be established at or below the water surface. Rule 3.1.5(7) states, "In all cases where a lake or pond is produced as a portion of the Reclamation Plan, all slopes, unless otherwise approved by the Board or Office, shall be no steeper than a ratio of 2:1 (horizontal to vertical ratio), except from 5 feet above to 10 feet below the expected water line where slopes shall be not steeper than 3:1." Please revised Exhibit E to comply with the requirements of Rule 3.1.5(7). Response 12 We have updated the text to incorporate the language from Rule 3.1.5(7) as presented in the updated Exhibit E (Attachment 5). We also updated the cross-section views on Exhibits F-1 and F-3 (Attachment 6). Comment 13 On Page 13, Section 7.3.1, the Applicant states the final grading will be no steeper than 2H.•1 V below water surface and 3H.•1 V above water surface which will create a final topography that is appropriate for natural open space or wildlife habitat. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H.•1 V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit E accordingly. Response 13 LRM commits to this requirement and has updated Exhibit E (Attachments 5 and 6). Comment 14 On Page 15, Section 7.3.4, the Applicant states the stockpiles that will remain in place for more than one season will be seeded to stabilize them and minimize erosion. As noted in Item #6, please commit to seeding stockpiles which have been in place for 180 days and provide a seed mixture as pounds of pure live seed (PLS) per acre. Response 14 LRM commits to seeding temporary stockpiles left in place longer than 180 days with a western wheat pasture grass seed mix (see Attachments 4 and 5). 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 6 Comment 15 Pursuant to Rule 6.4.5 Wall), please provide a description of the fertilization to be implemented during reclamation, ([applicable, and specify the types, mixtures, quantities and time of application. Response 15 LRM plans not to use fertilizer as our agronomist recommends against its use when establishing native vegetation. Comment 16 On Page 16, Section 7.4.2, the Applicant states grass or straw will be crimped in place with a mechanical crimper made for such purposes or using a farm -type disc plow set straight with adequate weigh to crimp the material to a depth of approximately 4 inches. Please provide the tons per acre of mulching proposed during reclamation. Response 16 Mulch will be applied at a minimum rate of approximately one ton per acre. For slopes exceeding 5V:1 H, mulch will be applied at a minimum rate of approximately 2 tons per acre. Comment 17 Please provide a Weld County approved Noxious Weed Management Plan including at minimum the target species, mitigation measures and treatment schedule. Response 17 Please see Attachment 7 for the Weed Inventory, Monitoring, and Control Plan for Dunn Pit. As a note, Weld County Weed Division does not require approval of this plan. 6.4.5 Exhibit F - Reclamation Plan Map Comment 18 On Exhibit F-1, Section A -A, the Applicant indicates a final reclamation slope of I.SH.• 1V below the water line and 3H.•1 V above the waterline. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H.•1 V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit F-1 accordingly. Additionally, in the proposed Reclamation Plan the Applicant states slopes of 3H.•1 V will be established above the water surface and slopes of 2H:1V V will be established at or below the water surface. Please explain this discrepancy and revise Exhibit F-1 accordingly. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 7 Response 18 LRM commits to meeting the reclamation slope rule. The 1.5H: 1 V was a typo from the mining plan. Attachment 6 presents the updated Exhibit F-1. Comment 19 On Exhibit F-3, Sections B -B' and GC', the Applicant indicates a final reclamation slope of I.SH.•1 V below the water line and 3H.•1 V above the waterline. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H.•1 V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit F-3 accordingly. Additionally, in the proposed Reclamation Plan the Applicant states slopes of 3:1 will be established above the water surface and slopes of 2:1 will be established at or below the water surface. Please explain this discrepancy and revise Exhibit F-3 accordingly. Response 19 LRM commits to meeting the reclamation slope rule. The 1.SH:1V was a typo from the mining plan. Attachment 6 presents the updated Exhibit F-3. 64.6 Exhibit G - Water Information Comment 20 A constructed well is indicated on Figure 2 - Water Rights Structures located in the southeast corner of the site, however the owner of the well is not indicated on the map. Please revise the Figure 2 map to indicate the owner of the well and provide proof of notification to the well owner. Response 20 Attachment 8 updates Figure 2 with the addition of the Bradley Petroleum well (300650). A notification has been sent to Bradley Petroleum (also shown in Attachment 8). Comment 21 On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. Please confirm the list includes all wells within 600 feet the permit boundary. Response 21 A corrected list of wells within 600 feet of the permit boundary includes: • Dunn, Thomas G & Alice E (47255) • Nelson, Paul & James (12892-R) • Wagner, Henry (226967A and 226967B) 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 8 • Bradley Petroleum (300650) • Loveland Ready Mix Monitoring Holes — 322566 (MW -01) 322567 322568 322569 322570 322571 322572 322573 322574 322575 Comment 22 (MW -02) (MW -03) (MW -04) (MW -OS) (MW -06) (MW -07) (MW -08) (MW -09) (MW -10) On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. The following wells were not indicted on Figure F-2. Please explain this discrepancy and revise Exhibit G accordingly. a. Mad Russian Well (59968-F) b. Loveland Ready Mix (61849-MH and 61850-MH) Response 22 • A well construction permit was issued for the Mad Russian Well (59968-F); however, no completion reports exist and field reconnaissance indicated no well constructed. Attachment 8 (updated Figure 2) reflects no well constructed. • LRM's 10 monitoring holes are included in the updated Figure 2 Comment 23 On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. The Applicant did not submit proof of notification to the following well owners. Please explain this discrepancy and revise Exhibit G accordingly. a. Hall Irwin (248398) b. Mad Russian Well (59968-F) Response 23 • Site investigation shows no Hall Irwin well (248398) located where the DWR Map Viewer locates Hall Irwin well. This was likely mis-recorded in the DWR database 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n•c . �wlll: To: Mr. Peter Hays Date: February 21, 2022 Page 9 • A permit was issued to construct the Mad Russian Well (59968-F); however, no record of the well being constructed exists. Comment 24 The Applicant provided proof of notification for well no. 12892-R owned by Paul and James Nelson. Please revise the list of constructed wells in Section 9.2.3 of Exhibit G to include the well owners. Response 24 The well list is revised (Item 21). A notice was sent to Paul and James Nelson as shown in the proof of notifications in the original DBMS submittal: r~ m tt �...:� ff pp ¢ $3.75 1 I t I - J tuA6 s e -Aims a refs g o= ant D�� Rani "l in UctrusorsiaA Fkiettivol Damn, 4. tit ili ; imia L sgi n! -ti 004E 'ei $ ,.1 ° Posing, F.91 load Postage a ind rites 1$3!16 -U.S. Postal Service" CERTIFIED .MAIIP RECEIPT Dartttalt qty ror (!nliwtar y illeiattgaiOni ylilt our weew le at wwnri.IiBP91cQrrTr!'. 'L' 0 fel Q N hi 1 . i r m Th haciiidati Ave - nit? * �� .a �.1:err----. i� *Milx711114-1r, PS ram R 1,ur), Apra le.515 Pf.t1 Alp 413, } I..(If - ar t ir FFina sEp 'Mr ir I 6.4.9 Exhibit 1 -Soils Information Comment 25 The Applicant provided a figure and map of the NRCS soils report for the proposed mine site. Please provide a copy of the complete NRCS soils report for Division review. Response 25 The entire NRCS soils report is included as Attachment 9. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© $01.11 1 1 0 M f. I n C O n. O. A To: Mr. Peter Hays Date: February 21, 2022 Page 10 6.4.72 Exhibit L - Reclamation Costs Comment 26 The Division calculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant in the application and the Division's requirement to include the cost to backfill the exposed groundwater until the final augmentation plan is obtained from the DWR at $3,018,000.00. A copy of the Division's bond estimate is attached for review. Response 26 Our request, which we discussed, is the opportunity to put up a place holder bond between the time of DRMS/MLRB approval and actual mining. The largest component of the bond is for backfill of the first 5 acres of mining Cell 1 of $2,420,000. For a placeholder bond, LRM offers a placeholder value to replace the backfilling of $300,000. This is the amount estimated by LRM's legal counsel for the augmentation plan water court process. Thus, the requested placeholder bond would be approximately $394,000 as summarized in Table 1: Minor comments or questions on the bond include: • The job superintendent rate seems high. The RS Means (013113200260) average rate for a superintendent (with location adjustment to Greeley, Colorado) is $2,325 per week, before O&P. • Under Revegetation Work for C 1 Shoreline, C 1 Wetlands, and Access Road, weed control spraying application is double counted (under Tilling and under Mulching and Miscellaneous Application) • 3 trucks are listed under "roadable" equipment in Mob/Demob but only 2 are listed in the other sheets 6.4.73 Exhibit M I. Other Permit and Licenses Comment 27 Please commit to providing copies of all required and approved permits and licenses to the Division, when available. Response 27 LRM commits to providing copies of all required and approved permits and licenses to the DRMS as they become available. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %OLOt'ON$.,p c nrp.wlll: To: Mr. Peter Hays Date: February 21, 2022 Page 11 Table 1 Requested Placeholder Bond Amount Task description: Site: Dunn Pit COST SIMENIARY WORK Dunn Pit Hand Estimate PROJECT IDES.:iitlCATION Task: 000 Date: 11.12021 User: PSH Permit Action: Bond Estimate Pennit'Job#: M2021059 State Colorado Count Weld Agency or organization name: DRAMS TASK LIST (DIRECT COSTS) Abbreviation: N one Filename: M059-000 Task Description Form Used Fleet Size Tas k Hours Cost 001 OO? 003 O04 005 006 007 003 Revegetate Cl Shoreline REVEGE 1 1 1 1 1 1 1 1 40.0O S1,884 56,114 51,110 5629 5132 S564 53.,649 Tops oil Cl Shoreline TRUCKI 13.06 Revegetate C1 Wetlands REVEGE '.0.0O Slope. Cl West Slope DOZER 3.72 Rip Access Road RIPPER 0.73 Revegetate Access Road RE\''EGE 20.00 Mob : Demob 5.37 MOBILUF Bond to Bacidill Cl until Augmentation Decree 160.00 S300,000 SITEM.A.ENTT ENANCE Placeholder SUBTOTAL S: 262.88 S314,082 L Z-DIl ECT COSTS OVERHEAD AND PROFIT: Liability insurance: 2.02 Peifonnance bond: 1.05 Job superintendent: 1.a 1.44 Profit: 10.00 Total = Total = 53;298 Total = 59a;8 Total= 56344 531,408 TOTAL. O & P = 550,519 CONTRACT AMOUNT (direct + O & P) = 5364;601 LEGAL - ELNG iG - PROJECT MANAGEti' ENT: Financial warrant r processing (legal/related costs): 5500 Engineering work and/or contract•bid preparation: 4.25 Reclamation management and/or administration: 5.00 Total= 5500 Total = 813_.48 515:, 04 CONi NGENC ': 0.00 Total = SO TOTAL INDIRECT COST = 529,553 TOTAL PLACIHOLDER BOND AMOUNT (direct + indirect) = $394,O0O Rounded 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 12 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder Comment 28 Please provide an affidavit or receipt indicating the date on which the revised application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). Response 28 Please see Attachment 10. 6.4.79 Exhibit S - Permanent Man-made Structures Comment 29 Where the affected lands are within two hundred (200) feet of any significant, valuable and permanent man-made structures, the Applicant may either: a. provide a notarized agreement between the Applicant and the person(s) having an interest in the structure, that the Applicant is to provide compensation for any damage to the structure; or b. where such an agreement cannot be reached, the Applicant shall provide an appropriate engineering evaluation that demonstrates that such structure shall not be damaged by activities occurring at the mining operation; or c. where such structure is a utility, the Applicant may supply a notarized letter, on utility letterhead, from the owner(s) of the utility that the mining and reclamation activities, as proposed, will have "no negative effect" on their utility. The Division will require the Applicant to demonstrate they attempted to obtain notarized structure agreements with all owners of the structures within 200 feet of the affected area of the proposed mine site, pursuant to Rule 6.4.19, prior to the Division's consideration of a stability analysis. Response 29 LRM initiated item (a) with adjacent landowner (now including those identified in Comment 29 that are within the 200' boundary), and have not received confirmation or signed agreements. LRM also completed (b), as Appendix B in the updated filing of the 112c Permit Application. Comment 29 The Division did not receive proof of notification for the following permanent man-made structures owners within 200 feet of the boundary of the affected land as identified by the 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 13 Applicant in Exhibit S. Please provide proof of notification for the following owners of record: a. Telecommunications (TDS Telecom and Zayo Bandwidth) b. Overhead Powerline (Xcel Energy and Century Link) c. Natural Gas (Xcel Energy and DCP Midstream) d. Water (Little Thompson Water District) e. Coulson Excavating f Dunn Residence, outbuilding g. Martin Del Campo Residence, outbuilding h. Nelson Family LLC i. Paul Wagner Residence j. Mad Russian Golf Course Response 29 We have sent notices to the following owners of record. a. Telecommunications (TDS Telecom and Zayo Bandwidth) b. Overhead Powerline (Xcel Energy and Century Link) c. Natural Gas (Xcel Energy and DCP Midstream) d. Water (Little Thompson Water District) e. Coulson Excavating f. Dunn Residence, outbuilding g. Martin Del Campo Residence, outbuilding h. Nelson Family LLC i. Paul Wagner Residence j. Mad Russian Golf Course Attachment 11 provides proof of certified mail service and copies of the notifications/agreements. Comment 30 Please provide the Division with copies of all signed structure agreements with the owners of permanent man-made structures within 200 feet the proposed affected area boundary. Response 30 As described in Comment 29, we sent notarized agreements to the landowners, but have received no responses, and we do not anticipate any. Regardless, the agreements sent commit LRM to compensate for any damage to structures should they fail due to slope stability issues. We also completed geotechnical stability evaluations showing stable banks, and we anticipate no damage. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 14 Comment 31 The Applicant submitted a copy of the structure agreement cover letter for Janice Knaub. Ms. Knaub is not listed as a permanent man-made structure owner in Exhibit S or on Exhibit C-17. Please explain this discrepancy and revise the Exhibits as required. Response 31 Ms. Knaub's property is partially within the 200 -foot offset of the Project's boundary, while her structures are over 200 feet from the Project boundary. Comment 32 The Inlet Protection report submitted for the Dunn Pit application was reviewed by Rob Zuber with the Division. A copy of Mr. Zuber's review memo dated December 17, 2021 is attached. Please respond to the adequacy questions contained in the memo. Response 32 We respond to the comments on the inlet protection report subsequently. Comment 33 Exhibits F, G and Appendix D for the Dunn Pit application were reviewed by Patrick Lennberg with the Division. A copy of Mr. Lennberg's review memo dated December 9, 2021 is attached. Please respond to the adequacy questions contained in the memo. Response 33 We respond to the comments by Mr. Lennberg subsequently. 6.5 Geotechnical Stability Exhibit Comment 34 The Applicant submitted a Factor of Safely calculation based on assumed soil properties to demonstrate the geotechnical stability of the mined and reclaimed slopes. The Division will require the Applicant to provide an engineering stability analysis for the proposed mined and reclaimed slopes. The model must be performed using stability analysis software to allow verification of the models by the Division. The stability analysis model must assume the worstcase scenario for the mined and reclaimed slopes. Response 34 As documented in the calculation set provided in Appendix B of the 112c Permit Application update (October 2021) and the updated Appendix B1 (Attachment 12), Telesto completed a slope stability analysis of the planned mined and reclaimed slopes utilizing 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 15 Slide -2D. We can provide the modeling files to DRMS upon request. The analysis utilized the characterization from over 35 boreholes that show the materials are at sandy gravels and gravely sands. Telesto used the minimum shear strength (with no cohesion) from literature values for those materials. Thus, the analysis meets the "worst -case scenario" request indicated in Comment 34 (although the regulations do not require worst -case scenarios). Comment 35 The Geotechnical Stability cover letter states the analysis shows that LRM can excavate the pits wet using a large excavator, but that the excavator will require a working platform roughly 16'x20' to distribute the load. The platform requirement is not discussed in Exhibit D — Mining Plan. Please revise Exhibit D to incorporate the requirements of the geotechnical stability report. Response 35 Attachment 13 updates Exhibit D. Updates in Sections 6.1.2 and 6.2 specify that LRM mine at slopes and with appurtenances indicated by the slope stability analyses presented in Appendix B 1 (Attachment 12). Comment 36 The Applicant selected a required factor of safety (FOS) of 1.3 from Table 1 — Recommended Minimum Factors of Safety for Slope Stability Analyses for Operations and Reclamation. The selected FOS is for strength measurements resulting from multiple tests. The Division does not agree the Applicant's utilization of the results of particle -size distributions and boring logs qualifies as tests. The Division will require the Applicant to meet a factor of safety of 1.5, unless laboratory strength tests were performed on soils at the site. Response 36 It is our experience that laboratory testing will produce strength parameter results weaker than the lowest literature values for the identified materials, and that identifying the types of materials present is extremely important. Regardless, we have re -calculated the stability analysis utilizing a FOS of 1.5. As infrastructure is designed for construction (e.g., bridge abutments, access roads) and mining commences, LRM will collect samples for laboratory strength tests. They will update the slope stability analysis based on those results and submit a technical revision at that time to use a FOS of 1.3 and update safe mining slopes. Comment 37 In the Conclusions section of the stability report, the Applicant states it is safe for DRMS 's reclamation slope of 2H.•1 V, and can be steepened to 1.78H.•1 V during mining as long as 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 16 a platform is used beneath the excavator to distribute the weight. The Applicant proposed a mining slope of I.SH.•1 V in Exhibit D - Mining Plan. Please revise Exhibit D to incorporate the requirements of the geotechnical stability report. Response 37 Attachment 13 corrects the discrepancy. Updates in Sections 6.1.2 and 6.2 specify that LRM mine at slopes and with appurtenances indicated by the slope stability analyses presented in Appendix B1 (Attachment 12). 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 17 HISTORY COLORADO (HC) LETTER HC Comment 7 Consequently, there is the possibility that as yet unidentified cultural resources exist within the proposed permit area. The requirements under CRS 24-80 part 13 apply and must be followed if human remains are discovered during ground disturbing activities. HC Response 7 LRM commits to follow requirements under CRS 24-80 part 13 should they uncover human remains during mining. HC Comment 2 This includes not only reasonable and good faith identification efforts of any historic properties located within the area of potential effects, but determining whether the undertaking will have an effect upon such properties. The State Historic Preservation Office, Native American tribes, representatives of local governments, and applicants for federal permits are entitled to consultative roles in this process. HC Response 2 LRM requested a jurisdictional determination from the US Army Corps of Engineers on the proposed mine. LRM will support the requirements of the National Environmental Policy Act and associated consultative roles should the project be deemed jurisdictional. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 18 CDWR RESPONSE TO CONSIDERATION CONSTRUCTION MATERIALS RECLAMATION PERMIT CONVERSION APPLICATION CDWR Comment 1 The final reclamation plan includes unlined ponds of exposed groundwater at the site. The ponds will be required to be included in a plan for augmentation prior to final release of the site. CDWR Response 1 LRM plans to file an Augmentation Plan with the Water Court. LRM holds shares for water storage rights at their Walters and Bokelman Pits site under Decree 2009CW105, which will be used as the replacement source. See response 10 of the DRMS comments, included with this letter for more details. CDWR Comment 2 If stormwater runoff is intercepted by this operation and is not diverted or captured in priority, it must be released to the stream system or infiltrate into the ground within 72 hours; otherwise the operator will need to make replacements for evaporation from the surface area of the intercepted stormwater CDWR Response 2 LRM has already submitted a request for a Substitute Water Supply Plan (SWSP) and will provide an Augmentation Plan once approved. See response 10 of the DRMS comments, included with this letter, for more details. Pit lake evaporation is estimated for the first year of operations and will be updated and calculated monthly. Because the pits are unlined, stormwater that is intercepted by the pit lakes will be included in the monthly consumptive loss accounting reported to the DWR and replaced as described in the SWSP. Also, any excess stormwater not evaporated quickly returns to the groundwater system, of which the lake is a part. Stormwater entering the lake immediately raises the head, which immediately results in an increased outflow. Given that the travel distance is only 100 feet, response in the river is also immediate. Thus, there should be no reason to replace evaporation from the surface area of the intercepted stormwater. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 19 CDWR Comment 3 The Applicant has conducted a baseline groundwater assessment to determine support geotechnical analyses, wetland mitigation decisions, and to assess potential impacts associated with the proposed sand and gravel mine. As part of the baseline groundwater assessment the applicant has constructed four monitoring wells. CDWR Response 3 Point of clarification, LRM installed 10 monitoring wells as shown in Figure 4 of the Dunn Pit Groundwater Baseline Report and well construction permits are included in Appendix A of the application. DUNN PIT (PERMIT NO. M-2021-059), ADEQUACY REVIEW OF APPLICATION WITH FOCUS ON INLET PROTECTION DESIGN AND HEC-RAS 2D MODEL - MEMO FROM ROB ZUBER, DRMS TO PETER HAYS, DRMS Comment 7 Please explain why the 9,000 cfs event is used for determining maximum velocities for weir designs. Were flows and velocities for larger storms not considered? In particular, the 100 year storm is listed as 20,309 cfs. Response 7 The DRMS Permit Application Appendix B2 - Inlet Protection calculation documentation incorrectly states in the data and assumptions that the 100 -year flood flow is 20,309 cfs (this is from other regulatory requirements). The table located in the revised inlet protection calculations correctly states that 9,000 cfs is associated with an -402.8-year recurrence interval. Return interval calculations for this analysis were derived from historical records obtained from gauging station "BIGLOVCO" located approximately 10 miles WNW (upstream) of the proposed Dunn Pit. Attachment 14 presents the revision to this calculation set (Appendix B2). Comment 2 Please provide design drawings for the pit inlet weirs, or reference other reports associated with this submittal that contain the drawings. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 20 Response 2 Pit inlet weir designs are shown on reclamation plan Exhibit F-3 (Attachment 6). Comment 3 Please explain why bridge decks and piers are not included in the model. It appears that these structures could impact the velocities offlows into Cell 3, which is relatively close to the railroad bridge (approximately 200 feet upstream). Response 3 Two hydraulic models were completed under this project: HEC-RAS 1D (1D) and HEC- RAS 2D (2D). The 1D model calculated the anticipated back water affects associated with the project's proposed construction and mining activities, and to meet Weld County's no - rise condition during their dictated flow event (estimated by the Colorado Hazard Mapping Program, CHAMP). The 2D model was used primarily to predict where and at what flow rates water would enter the proposed pits, and to calculate location specific velocities, flow depths and shear stresses so that flows into and out of the pits could be managed. Before the release of HEC-RAS 6.0 (December 2020) a bridge could not be modeled in 2D unless it was modeled as a culvert. In addition, HEC-RAS bridge scour calcs have historically been calculated in 1D. The use of 1D vs 2D is slowly evolving and we have not fully made the switch between 1D and 2D (this analysis was started just after December 2020 and was completed in HEC-RAS 5.0.7). Therefore, bridge decks and piers were not included in the 2D model because it was not possible to do so at the time. The effects on flow velocities into mining Cell C3 calculated in the 2D model as a result of existing railroad and Highway 257 bridge decks and piers are inconsequential because: The flood stage during the 100 -year event is below the elevation of the bridge girders for both the railroad and highway bridges. Therefore, there would be no hydraulic effects caused by bridge decks The railroad and highway bridge piers are hydraulically downgradient of Cell C3. Therefore, any upstream hydraulic effects caused by downstream obstructions during subcritical flow would only decrease upstream flow velocities making the predicted 2D cell C3 flow velocities and shear stress estimates conservative The cross-sectional area of the bridge piers is small compared to the overall un- obstructed area between the bridge abutments. Therefore, any backwater effects that would occur due to the bridge piers are assumed to be relatively negligible 20220209_1045_DRMS AdequacgReview Response_MASTE R. do TELESTO To: Mr. Peter Hays Date: February 21, 2022 Page 21 Comment 4 Please explain why there is no outlet protection for flood flows at the lower end of Cell 1. Include a discussion of velocities estimated with the 2D HEC-RAS model. Response 4 During development of our erosion protection plan, we assumed that established grassy vegetation will conservatively tolerate shear stresses of up to 2.1 lb/ft2. This shear tolerance was referenced from the Washington State Aquatic Habitat Guidelines Program, Integrated Streambank Protection Guidelines, 2003, and the wetland seed mix specified in Attachment 4 most closely corresponds to the Class B vegetation referenced in the Integrated Streambank Protection Guidelines. Therefore, all shear stresses below 2.1 lb/ft2 required grassy revegetation but did not require hard armor. As seen in the revised 2D model, shear stresses at the east end of Cell 1 are below 2.1 lb/ft2 for all river flow rates below 9,000 cfs including when Cell 1 is discharging to the river. Comment 5 Please explain why no inlet protection is needed in areas other than the control points for each cell (shown on page 6 of the Inlet Protection Calculations). For example, for Cell 1 there is an area 250 - 300 feet east of the southwest corner where velocities in RAS Mapper (9,000 cfs) are greater than 13 feet per second. Response 5 Thank you for pointing out this deficiency. In order to reduce the potential for erosion caused by water entering the pits, we've made the following changes (Attachment 6): • Reduced the slopes of the pit walls above the waterline from 3:1 to 5:1 in the following general areas: Cell 1 — West and south sides Cell 2 — West, north and east sides — Cell 3 — West and north sides • Expanded the extent of the "pit inlet weirs" at the crests of the inlets to cover the following areas: Cell 1 — Southwest, and southern sides Cell 2 — Northwest, north and northeastern sides — Cell 3 — Northwest, north and northeastern sides • Added hardened inlet protection so that the following areas are now covered: 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %OLOt'ON$.,p c nrp.wlll: To: Mr. Peter Hays Date: February 21, 2022 Page 22 — Cell 1 — West side Cell 2 — West side Cell 3 — North side The pit inlet weirs are low, flat, rip rap or vegetated crests to the pit inlets that serve to spread out flows entering the pits, and to prevent flows from entering the pits in a concentrated fashion. These weirs help to reduce local shear stresses and assist in preventing the river from permanently establishing a new flow path through the pits. The flattening of the pit wall slope on the south side of Cell 1 has effectively reduced shear stresses in the area 250-300 feet east of the southwest corner so that peak shear stresses are less than 2.1 lb/ft2 for all flow rates less than 9,000 cfs. Therefore, it is our opinion that adequate erosion control in this area can be achieved by grassy revegetation and that hard armor is not required. Comment 6 Please explain the apparent discrepancies between pages 6 and 7 in terms of the sequence of flooding of the three cells. The table on page 6 suggests that flooding of Cell 2 occurs during smaller storm events than flooding of Cell 3; flooding of Cell 2 starts at 2000 cfs and flooding of Cell 3 starts at 4000 cfs. The discussion on page 7 states that flooding of Cell 2 and flooding of Cell 3 begin with approximately the same storm, approximately the 8 -year event. Response 6 Please see the revised 2D HEC-RAS model and Attachment 14 for updated hydraulics. The control of flows into the pits has changed slightly from the previous submittal. As stated in Attachment 14, water begins to enter: • Cell 1 during river flows of approximately 1,000 cfs (peak flow rate of ,,z1 --year event) • Cell 2 during river flows of approximately 3,000 cfs (peak flow rate of '10 - year event) • Cell 3 during river flows of approximately 8,000 cfs (peak flow rate of ,70 - year event) Comment 7 The last page of the Inlet Protection Calculations (page 7) states that "riprapped inlet weirs were sized and included in Exhibit C of the mine plan. " Can you be more specific where this is in the application? 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© % O I O t' O N$., p c c. � w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 23 Response 7 The Inlet Protection Calculations incorrectly referenced Exhibit C instead of Exhibit F. Please see the plan view and sections on Attachment 6 Sheet F-3, and Attachment 14 for the location and design of the riprapped inlet weirs. Comment 8 Please elaborate on item 6 on page 7. Do the modeling results indicate the flows from backwater conditions will be low enough that additional bank protection (e.g., riprap) will not be needed, and vegetation will be sufficient? Response 8 Please see the inlet/outlet protection calculations presented in Attachment 14. The analysis found that hard armoring (riprap) is only required for the pit inlets where shear stresses are in excess of 2.1 lb/ft2 and that revegetation using the wetland seed mix presented in Attachment 4 is adequate for lower shear stresses. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %OLOt'ON$.,p c nrp.wlll: To: Mr. Peter Hays Date: February 21, 2022 Page 24 DUNN PIT NEW PERMIT APPLICATION, EXHIBITS F, G AND APPENDIX D REVIEW MEMO, FILE NO. M2021-059: MEMO FROM PATRICK LENNBERG, DRMS TO PETER HAYS, DRMS Exhibit F Comment 1 Please show the Hill and Brush Ditch orientation on the Reclamation Plan Map. Response 1 The Hill and Brush Ditch is labeled on all revised plates of Exhibit F (Attachment 6). Exhibit G Comment 1 On Figure 2 the decreed surface water feature for the Hill and Brush Ditch is missing, please update the figure. Response 1 Hill and Brush Ditch has been added to Figure 2 (Attachment 8). Comment 2 On Figure 2 the decreed groundwater feature for the Mad Russian Well (0405661) and constructed well (59968-F), and the 10 monitoring wells are missing please update. Response 2 DWR Map Viewer shows a permit issued for Mad Russian Well (0405661); however, no record or physical identification of a constructed well was found. Updated Figure 2 contains the 10 LRM monitoring wells (Attachment 8). Appendix D Comment 1 The applicant states, page 6, they will measure water levels in the 10 monitoring wells, installed in Summer 2021, monthly for one year then quarterly thereafter. The Division believes monthly water level monitoring should occur for at least one year after mining activities have begun to verify the numerical models predictions and monitor the effects of mining on the surrounding groundwater system. 20220209_1045_DRMS AdequacgReview Response_MASTE R. do TELESTO To: Mr. Peter Hays Date: February 21, 2022 Page 25 Response 1 After establishing a pre -mining pattern of groundwater elevations, monthly monitoring provides no additional benefit. Because there is no dewatering, the effects on groundwater from pit excavation will occur at a rate such that quarterly monitoring will indicate any effects in the appropriate amount of time. Comment 2 How will the proposed open groundwater pond effect the surrounding ditches, Brush Ditch and the Big T and Platte Ditch in both the near term and long term? Response 2 Sediments in the aforementioned ditches and the change in heads control seepage. Because the drawdown is minimal, the change in seepage is likewise minimal. The groundwater model estimates the following pre- and post -estimated ditch seepage: • Estimated ditch seepage pre -mining: — Hill and Brush Ditch: 9.8 gpm Big T and Platte Ditch: 36.5 gpm • Estimated ditch seepage post -mining: Hill and Brush Ditch: 13.4 gpm Big T and Platte Ditch: 42.9 gpm This change is well within the model's uncertainty and thus, is insignificant. Comment 3 What is the supposed source of toluene that was detected in MW -5? Response 3 Toluene in MW -OS is non -detect. We have updated the table. When the database queried the laboratory report, it inadvertently grabbed the method detection quality assurance sample (surrogate parameter) rather than the analyte result. Attachment 15 presents the updated water quality tables. Comment 4 In Section 5.3.1, it is stated the drawdown in the Dunn well is not expected to be greater than 2 feet. However, in Figure 16 the graphed drawdown approaches 4 feet. Please reconcile this discrepancy. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TtELE„ST©.� w l %of..! fr, l l: To: Mr. Peter Hays Date: February 21, 2022 Page 26 Response 4 We are glad to discuss this comment with the reviewer as we are unclear about the comment's reference to two feet. The text from Section 5.3.1 in Appendix D from the October 2021 response to application completeness states: "Figure 16 summarizes the anticipated changes in groundwater levels associated with neighboring wells. Nelson shows approximately two feet of drawdown well within a range that will not negatively change their ability to withdraw irrigation water from the well. The two Wagner wells will likely experience around a foot of mounding, affecting their wells in a positive manner. The largest potential impact shown is to the Dunn well, where it approaches the 10% of well depth criteria. Drawdown is only one component of a well's ability to extract water. The lakes in Cell 2 and Cell 3 will effectively enhance the production of the well by developing a constant groundwater level nearer to the well. Thus, for the same amount of pumping, the required drawdown in the well will be much less and the well will operate more efficiently." The paragraph identifies the Dunn well as one that requires monitoring. LRM is working with the owner to establish baseline and a monitoring approach as the project commences. Comment 5 In Figure 16 three of the four wells graphed have a starting point that indicates increased water levels, shouldn't all wells begin at 0.0 indicating no mining influence? Response 5 Figure 16 starts at the end of Step 01 (mining of the first five acres). All drawdowns prior to this are zero. Comment 6 All groundwater sample results need to be compared to the Water Quality Control Commission's (WQCC) Regulation No. 41 — The Basic Standards for Groundwater (Reg 41) and the most conservative values in Tables 1 thru 4 for all analytes listed for minimum of five consecutive quarters. The sample results from the June/August 2021 sampling event only compared results to WQCC Reg 41 Tables 1 and 2. Table 3 of Reg 41 are agriculture standards which contain a few analytes that Tables 1 and 2 omit. Response 6 We have added comparisons to WQCC Regulation 41 Table 3 to the initial water quality testing results, and have updated the footer (Attachment 15). 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 27 Comment 7 Did the applicant sample for radionuclides that are part of Reg 41 Table I? Response 7 We included uranium in the metals analyses, which in our experience is a good indicator in natural waters for other radiological components. Because there are no nearby, upgradient sources, uranium is naturally occurring on the Front Range, and LRM's activities include only mining, we anticipate sampling for uranium metal to be sufficient. Comment 8 Nitrate/Nitrite as N was sampled, Appendix B, in some wells but not others, why? Response 8 Nitrate/Nitrite as N was not sampled in some wells, due to miscommunication with the lab. Going forward, all groundwater samples will be tested for Nitrate/Nitrite as N, as well Nitrate as N and Nitrite as N. Please see updated sampling matrix in Table 2 in the revised Ground Water Sampling and Analysis Plan (Attachment 16). Comment 9 Nitrate, Nitrite, and Total Nitrate + Nitrite are Reg 41 Table 1 values that appear to have not been sampled in all wells, please comment. Response 9 Nitrate/Nitrite as N was not sampled in some wells, due to miscommunication with the lab. Going forward, all groundwater samples will be tested for Nitrate/Nitrite as N, as well Nitrate as N and Nitrite as N. Please see updated sampling matrix in Table 2 in the revised Ground Water Sampling and Analysis Plan (Attachment 16). Comment 10 The Division recognizes there will become a point when a reduction in groundwater level and quality monitoring frequency becomes reasonable. The reduction requests and approvals will be completed through submittal of a Technical Revision. Response 10 Thank you for the clarification. LRM puts forth its intentions in this application to file such a revision at the appropriate time. We added language to clarify this point in the revised Groundwater Sampling and Analysis Plan (Attachment 16) 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© %otf..! fr,n• c . �w l l l: To: Mr. Peter Hays Date: February 21, 2022 Page 28 Comment 11 Section 6.1.5, the Dunn well is not an on -site monitoring well but rather an adjacent private well that may be influenced by mining. Is it the applicant's intent to extend the 5 foot trigger to this well? If so, are there historic groundwater level data to support this trigger value? Response 11 LRM intends to work with Mr. Dunn to establish a baseline and monitor for potential drawdown effects. Comment 12 In Monitoring Well Drilling Summary Report, Section 2.1, it is stated during drilling soil samples were collected for SPLP testing. Please provide the results of these analysis? Response 12 We collected the samples as our standard, pre -mining characterization approach. Because mining is to be subaqueous (i.e., no chance of changing the valence state), we have had the lab archive the samples in case of the future need. We will share results with the DRMS when/if they become available. Comment 13 In the text, Section 2.2, it is stated the monitoring well screen size used was 0.01 " but on the boring logs the screen size indicated is 0.1 ", please clarify. Please note the discrepancy appears to have made onto the forms submitted to DWR. Response 13 Thank you for pointing this out. Boring logs showing screen size of 0.1" was incorrect. Boring logs have been updated to show the correct screen size of 0.01." Updated boring logs are attached (Attachment 17). Telesto will contact the DWR to make the appropriate correction on the monitoring well construction forms. Comment 14 In the Groundwater Sampling and Analysis Plan Section 1 it references a water management pond. Please provide more details of the pond and clearly show it on Figure 1. 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 29 Response 14 Reference to water management pond at Dunn Pit was incorrect. No water management pond exists at Dunn Pit. The revised Groundwater Sampling and Analysis Plan (Attachment 16) reflects this update. Comment 15 Please update Table 2 to include the WQCC Reg 41 concentrations each analyte is compared to. Response 15 Please see updated Table 2 in the revised Ground Water Sampling and Analysis Plan. Comment 16 Please provide copies of the completed groundwater data sheet(s) for each well sampled. In the future the Division will require submittal of these sheets along with other sample data. Response 16 Completed groundwater data sheets for each sampled well in June/August 2021 are included in Attachment 18. Future sampling data sheets will be provided to the Division with submittal of other data. Comment 17 Field blanks, Section 7.2.2, the applicant proposes to collect afield blank once annually and the Division does agree this is appropriate. The purpose of the field blank is to assess contamination from field conditions during sampling. At least one field blank should be collected during each sampling event. Please revise to reflect at least one field blank will be collected during each sampling event. Response 17 Section 7.2.2 in the revised Groundwater Sampling and Analysis plan reflects that one field blank be collected each sampling event. Comment 18 Rinsate sample, Section 7.2.3, the applicant proposes to collect a rinsate sample twice annually and the Division does agree this is appropriate. The purpose of the rinsate sample is to assess the adequacy of the decontamination process. It assess contamination from the total sampling, sample preparation and measurement process, when decontaminated 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© To: Mr. Peter Hays Date: February 21, 2022 Page 30 sampling equipment is used to collect samples. Please revise to reflect at least one rinsate sample will be collected during each sampling event as appropriate. Response 18 Section 7.2.2 in the revised Groundwater Sampling and Analysis plan reflects that one rinsate sample be collected each sampling event. Comment 19 As mentioned in #6 above, the Division will require at least five consecutive quarters of baseline water quality measurements with samples results compared to the most conservative values in Reg 41 Tables 1-4. Additionally, quarterly groundwater monitoring will continue for at least one year after the mining activities started at the site. After one year of mining the operator may, through a Technical Revision, request decreasing both the list of analytes samples are analyzed for and the frequency of monitoring. Response 19 Thank you for the clarification. LRM puts forth its intentions in this application to file such a revision at the appropriate time. We added language to clarify this point and acknowledge the regulatory process. Sincerely, Telesto Solutions, Inc. • t Y . Niccoli, PE Principal/Senior Engineer WLN:wsc Enclosure cc: • 20220209_1045 DRMS Adequacy_ Review Response MASTS R.docx TELEST© Attachment 1 Proof of Publication 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® ,OIY„ON,..,, C 4,1•9•• Attachment 2 Additional Notices to Owners of Records 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® ,OIY„ON,..,, C 4,1•9•• Attachment 3 Updated Exhibit C17 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® ,OIY„ON,..,, C 4,1•9•• Attachment 4 Seed Mixes 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® 101.11110.41.0. Pi C 4,1•9•• I es. Attachment 5 Updated Exhibit E 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® 101.11110.41.0. Pi C 4,1•9•• I es. Attachment 6 Updated Exhibit F 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® 101.11110.41.0. Pi C 4,1•9•• I es. Attachment 7 Weld County Noxious Weed Plan 20220209_1045 DRMS Adequacy Review Response MASTS R.docx TELEST® ,OIY„ON,..,, C 4,1•9•• Attachment 8 Updated Figure 2 and Notice to Bradley Petroleum 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 9 Weld County NRCS Soils Report 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® 101.11110.41.0. Pi C 4,1•9•• I es. Attachment 10 Proof of Recording — M-2021-059, Responses to 112c Permit Application Adequacy Review 20220209_1045_DRMS_Adequacy _Review Response MASTS R. doer TELEST® Attachment 11 Notices of Additionally Identified Entities within 200' of Permit Boundary 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 12 Updated Appendix BI Geotechnical Stability Evaluation 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 13 Updates to Exhibit D Include Working Platform in Mining Plan 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 14 Updated Appendix B2 - Inlet Protection 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 15 Revised Initial Water Quality Sampling Result Tables 20220209_1045_DRMS_Adequacy_Review Response MASTE R.docx TELEST® Attachment 16 Revised Groundwater Sampling and Analysis Plan 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® Attachment 17 Updated Well Boring logs 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® 101.11110.41.0. Pi C 4,1•9•• I es. Attachment 18 Water Quality Sampling Field Data Sheets 20220209_1045_DRMS_Adequacy_Review Response MASTE R. docx TELEST® 40 March 9, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Second Adequacy Review Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS/Office) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application adequacy response dated February 21, 2022 for the Dunn Pit, File No. M-2021-059 and submits the following comments. The Division is required to issue an approval or denial decision no later than March 31, 2022, therefore a response to the following adequacy review concerns should be submitted to the Division as soon as possible. The review consisted of comparing the application contents with the specific requirements of Rules 1, 3, 6.1, 6.2, 6.4 and 6.5 of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials effective date July 15, 2019. Any inadequacies are identified under the respective exhibit heading along with suggested actions to correct them. Comments 1. The Applicant's response is adequate. 1.6 Public Notice 2. The Applicant's response is adequate. 3. Pursuant to Rule 1.6.2(e), please submit proof of the notice to all owners of record of surface and mineral rights of the affected land and the owners of record of all land surface within 200 feet of the boundary of the affected land including all easement holders located on the affected land and within 200 feet of the boundary of the affected land. Proof of notice may be return receipts of a Certified Mailing or by proof of personal service. The Applicant submitted Certified Mail Receipt tracking information for the following owners of record of all land surface within 200 feet of the boundary of the affected land, however the 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Dunn Pit Second Adequacy Review Page 2 of 6 March 9, 2022 -- ners of record are not indicated on the Exhibit C-17 map. Please explain these discrepancies `u.; revise the Exhibit C-17 - Permanent Man -Made Structures map accordingly. a. Todd Mason McCarty b. Rearden Minerals c. Robyn Allyson Herman d. Atomic Capital Minerals e. Leo Gilliss f. Naviates Infintes LLC g. Prometheus Minerals LLC 6.4.1 Exhibit A - Legal Description 4. The Applicant's response is adequate. 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land 5. The Applicant indicated the type of structures and the location of significant, valuable and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land on the Exhibit C-17 map. Pursuant to Rule 6.4.3(g), please show the owner's name for the permanent man-made structures on the map. The Applicant added the adjacent property owners to the Exhibit C-17 map in response to the Division's adequacy letter. Please revise the Exhibit C-17 map to indicate the owner's name for all utilities within 200 feet of the affected land boundary. 6.4.4 Exhibit D - Mining Plan 6. The Applicant's response is adequate. 7. The Applicant's response is adequate. 6.4.5 Exhibit E - Reclamation Plan 8. The Applicant's response is adequate. 9. The Applicant's response is adequate. 10. The Applicant's response is adequate. 11. The Applicant has not obtained the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. Therefore, the Division will require the Applicant to provide a reclamation bond to include the backfilling of the exposed groundwater until the final augmentation plan is obtained from the DWR. The Division calculated the reclamation bond based on this requirement. Dunn Pit Second Adequacy Review Page 3 of 6 March 9, 2022 The Applicant proposed a place -holder financial warranty in the amount of $300,000.00 for the cost of backfilling Cell 1 until mining activities commence or the Operator obtains the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. The Division will accept the place -holder bond and require the Operator to submit a revised financial warranty estimate prior to commencing mining activities at the site. 12. The Applicant's response is adequate. 13. On Page 13, Section 7.3.1, the Applicant states the final grading will be no steeper than 2H:1V below water surface and 3H:1V above water surface which will create a final topography that is appropriate for natural open space or wildlife habitat. As noted in Item #12, please commit to reclaiming the pond slopes at a 3H:1V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit E accordingly. The Operator committed to the requirements of Rule 3.1.5(7) in response to the Division's adequacy letter, however Section 7.3.1 was not revised accordingly. Please provide a revised copy of Exhibit E. 14. The Applicant's response is adequate. 15. The Applicant's response is adequate. 16. The Applicant's response is adequate. 17. The Applicant's response is adequate. 6.4.5 Exhibit F - Reclamation Plan Map 18. The Applicant's response is adequate. 19. The Applicant's response is adequate. 6.4.6 Exhibit G - Water Information 20. A constructed well is indicated on Figure 2 - Water Rights Structures located in the southeast corner of the site, however the owner of the well is not indicated on the map. Please revise the Figure 2 map to indicate the owner of the well and provide proof of notification to the well owner. The Applicant identified the well owner as Bradley Petroleum and stated a notification was sent to the owner in the adequacy response. The Division did not receive proof of notification to the well owner as indicated in the adequacy response. Please provide proof of notice to the well owner to the Division,=== Dunn Pit Second Adequacy Review Page 4 of 6 March 9, 2022 21. On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. Please confirm the list includes all wells within 600 feet the permit boundary. The Applicant provided a revised map of wells within 600 feet of the permit boundary with the adequacy response. Please provide a revised copy of Exhibit G, Section 9.2.3 to indicate the revised list of wells. 22. The Applicant's response is adequate. 23. The Applicant's response is adequate. 24. The Applicant provided proof of notification for well no. 12892-R owned by Paul and James Nelson. Please revise the list of constructed wells in Section 9.2.3 of Exhibit G to include the well owner. 6.4.9 Exhibit I - Soils Information 25. The Applicant's response is adequate. 6.4.12 Exhibit L - Reclamation Costs 26. The Division calculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant in the application and the Division's requirement to include the cost to backfill the exposed groundwater until the final augmentation plan is obtained from the DWR at $3,018,000.00. A copy of the Division's bond estimate is attached for review. The Applicant proposed a total place -holder financial warranty in the amount of $394,000.00 until mining activities commence or the Operator obtains the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. The Division recalculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant at $398,000.00. A copy of the Division's bond estimate is attached for review. The Division will accept the total place -holder bond in the amount of $398,000.00 and require the Operator to submit a revised financial warranty estimate prior to commencing mining activities at the site. Minor comments or questions responses: • The Division used the MEANS average superintendent cost at 50% of the total task hours, which is standard procedure for the Division. • The weed control costs under Mulching and Miscellaneous Application were removed by the Division in the revised bond estimate. Please see attached. Dunn Pit Second Adequacy Review Page 5 of 6 March 9, 2022 • Task 002 - Topsoil C1 Shoreline utilizes a team of one (1) loader and two (2) haul trucks, therefore the Mob/Demob sheet accounts for 2 roadable trucks. The third roadable truck listed on the Mob/Demob sheet is a light duty pickup for the superintendent. 6.4.13 Exhibit M - Other Permit and Licenses 27. The Applicant's response is adequate. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 28. Please provide an affidavit or receipt indicating the date on which the revised application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). 6.4.19 Exhibit S - Permanent Man-made Structures 29. The Applicant's response is adequate. 30. The Applicant's response is adequate. 31. The Applicant's response is adequate. Memos 32. The adequacy response for the Inlet Protection report are currently under review by the Division. A copy of the second review memo will be sent under separate cover, if needed. 33. The adequacy response for Exhibits F, G and Appendix D were reviewed by Patrick Lennberg with the Division. A copy of Mr. Lennberg's second review memo dated March 8, 2022 is attached. Please respond to the adequacy questions contained in the memo. 6.5 Geotechnical Stability Exhibit 34. The Applicant states Telesto completed a slope stability analysis of the planned mined and reclaimed slopes utilizing Slide -2D and can provide the modeling files to the DRMS upon request in the adequacy response. Please provide the Slide -2D modeling files in electronic format to allow the Division to verify the stability analysis using Clover Technology's Galena slope stability software. 35. The Applicant's response is adequate. 36. The Applicant's response is adequate. 37. The Applicant states updates in Section 6.1.2 and 6.2 specify that LRM mine at slopes and with appurtenances indicated by the slope stability analyses presented in Appendix B1 in the adequacy response. Section 6.1.2 was revised to include "an excavator stationed on a moveable platform...". Section 6.2 was not revised from the previous version of Exhibit D. Please update both sections to include the language from the adequacy response. Dunn Pit Second Adequacy Review Page 6 of 6 March 9, 2022 New adequacy issues 38. The Applicant provided revised Exhibit F-2 and F-3 maps removing Table 1- Wetland Areas and Volumes with the adequacy response. Please confirm the Applicant intended to provide the revised map and explain why the tables were removed from the map. 39. The Applicant provided revised Exhibit F-4 and F-5 maps with the adequacy response. Pursuant to Rule 6.2.1(2)(b), maps must be prepared and signed by a registered land surveyor, professional engineer, or other qualified person. Please provide signed copies of the Exhibit F-4 and F-5 maps. 40. On Page 6, Exhibit D - Mining Plan (Updated 2/9/22), the Applicant states the entire site consists of approximately 114 acres. The Applicant listed the proposed permitted acreage on the application form as 114.25 acres. Please provide a copy of a revised Exhibit D indicating a proposed permit acreage of 114.25 acres. Please be advised the Dunn Pit application may be deemed inadequate, and the application may be denied on March 31, 2022, unless the above mentioned adequacy review items are addressed to the satisfaction of the Division. If more time is needed to complete the reply, the Division can grant an extension to the decision date. This will be done upon receipt of a written waiver of the Applicant's right to a decision by March 31, 2022 and request for additional time. This must be received no later than the decision date. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Peter S. Hays Environmental Protection Specialist Enclosures — Revised Reclamation Cost Estimate dated March 8, 2022 Lennberg Review Memo dated March 8, 2022 Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. COST SUMMARY WORK Task description: Revised Bond Estimate Site: Dunn Pit PROJECT IDENTIFICATION Task #: 00R Date: 3/8/2022 User: PSH Permit Action: State: Colorado Revised Bond Estimate County: Weld Agency or organization name: DRMS TASK LIST (DIRECT COSTS) Permit/Job#: M2021059 Abbreviation: None Filename: M059 -00R Task Description Form Used Fleet Size Task Hours Cost 01R 02R 03R 04R 05R 06R 07R 08R Revegetate Cl Shoreline REVEGE 1 1 1 1 1 1 1 1 40.00 $1,726 $6,114 $885 $629 $132 $517 $3,649 $300,000 Topsoil Cl Shoreline TRUCK1 13.06 Revegetate Cl Wetlands REVEGE 20.00 Slope Cl West Slope DOZER 3.72 Rip Access Road RIPPER 0.73 Revegetate Access Road REVEGE 20.00 Mob / Demob MOBILIZE 5.37 Bond to Backfill Cl until Augmentation Decree SITEMAINT ENANCE 160.00 SUBTOTALS: 262.88 $313,652 INDIRECT COSTS OVERHEAD AND PROFIT: Liability insurance: 2.02 Total = Performance bond: 1.05 Total = Job superintendent: 131.44 Total = Profit: 10.00 Total = $31,365 TOTAL 0 & P = $50,462 CONTRACT AMOUNT (direct + O & P) = $6,336 $3,293 $9,468 LEGAL - ENGINEERING - PROJECT MANAGEMENT: $364,114 Financial warranty processing (legal/related costs): $500 Total = $500 Engineering work and/or contract/bid preparation: 4.25 Total = $15,475 Reclamation management and/or administration: 5.00 $18,206 CONTINGENCY: 0.00 Total = $0 TOTAL INDIRECT COST = $84,642 TOTAL BOND AMOUNT (direct + indirect) = $398,000 (Rounded) Page 1 of 2 REVEGETATION WORK Task description: Revegetate Cl Shoreline Site: Dunn Pit PROJECT IDENTIFICATION Task #: 01R Date: 3/8/2022 User: PSH Permit Action: State: Colorado Revised Bond Estimate County: Weld Agency or organization name: DRMS FERTILIZING Materials Permit/Job#: M2021059 Abbreviation: None Filename: M059 -01R Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Blue Grama - Hachita 0.75 12.24 $11.98 Alkali Sacaton 1.00 39.03 $28.48 Alkaligrass, Fult's 0.50 13.77 $1.81 Canada Wildrye 3.00 7.92 $32.52 Bottlebrush Squirreltail 2.25 9.92 $36.51 Western Wheatgrass - Arriba 10.00 25.25 $65.00 Saltgrass, Inland 0.50 6.93 $21.40 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 01R Page 2 of 2 Totals Seed Mix 18.00 115.06 $197.70 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D (a) 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Total Mulch Application Cost/Acre $71.57 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 1.47 Cost /Acre: $1,016.93 Estimated Failure Rate: 25% Cost /Acre*: $630.03 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $1,494.89 Reseeding Job Cost: $231.54 Total Job Cost: $1,726 Job Hours: 40.00 CIRCES Cost Estimating Software Page 1 of 4 TRUCK/LOADER TEAM WORK Task description: Site: Dunn Pit Topsoil Cl Shoreline PROJECT IDENTIFICATION Task #: 02R Date: 3/8/2022 User: PSH Permit Action: Revised Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059 -02R Agency or organization name: DRMS HOURLY EQUIPMENT COST Truck Loader Team -Truck: -Loader: Equipment Description Generic 7-8 cy, 4x4 CAT 928Hz Shift basis: 1 per day Support Equipment -Load Area: -Dump Area: Road Maintenance —Motor Grader: -Water Truck: Cat D6T XL NA CAT 14M NA Cost Breakdown: Truck/Loader Team Support Equipment Maintenance Equipment Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 15 50 NA 75 NA Ownership cost/hour: $16.03 $30.09 $64.38 NA $85.80 NA Operating cost/hour: $25.50 $4.48 $32.31 NA $45.30 NA %Utilization -riper: NA 0 NA NA NA NA Ripper own. cost/hour: NA $0.00 $0.00 NA $0.00 NA Ripper op. cost/hour: NA $0.00 $0.00 NA $0.00 NA Operator cost/hour: $0.00 $35.97 $40.04 NA $46.87 NA Unit Subtotals: $41.53 $70.54 $136.73 NA $177.97 NA Number of Units: 2 1 1 0 1 0 Group Subtotals: Work: $153.60 Support: $136.73 Maint: $177.97 Total work team cost/hour: $468.30 MATERIAL QUANTITIES Initial volume: Loose volume: 2,378 CCY Swell factor: 1.000 2,378 Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: 1,600 LCY Division of Reclamation, Mining & Safety Cat Handbook $0.00 $0.00 Pounds/LCY Description: Top Soil CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 02R Page 2 of 4 Rated Payload: 20,300 Payload Capacity: 12.69 Truck Bed (volume) Basis: Struck Volume: 7.00 LCY Heaped Volume: 8.00 LCY Average Volume: 7.50 LCY Adjusted Volume: 8.00 LCY Pounds LCY Final Truck Volume Based on Number of Loader Passes: Loading Tool Capacity Rated Capacity: Bucket Fill Factor: Adjusted Capacity: 3.000 0.975 2.925 Job Condition Corrections: LCY (heaped) Loose material - mixed moist aggregates (95-100%) 0.975 LCY 5.85 LCY Bucket Size Class: NA Site Altitude (ft.): 4745 feet Truck Loader Source Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: NA Number of Loading Tool Passes Required to Fill Truck: Selected Value within this Basic Rating: NA Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA 2 passes Maneuver: NA Dump: 0.100 Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver) : 0.475 minutes Cycle Time Factors Factor (min.) Source Material: Material up to 1/8" diameter 0.02 0.020 (Cat HB) Stockpile: Conveyor or dozer piled 10 ft. high or less 0.01 0.010 (Cat HB) Truck Ownership: Common ownership of trucks and loaders 0.04 -0.040 (Cat HB) Operation: Constant operation -0.04 -0.040 (Cat HB) Dump Target: Nominal target 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: Adjusted Loader Cycle Time: Net Load Time per Truck: Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 0.525 Minutes Truck Maneuver and Dump 0.80 Minutes Time: -0.050 0.425 0.525 minutes minutes minutes Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 0.525 Minutes Adjusted for site altitude: 0.800 Minutes CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 02R Page 3 of 4 Truck Travel (Haul & Return) Time: Road Condition: Firm, smooth, rolling, dirt/lt. surfaced, watered, maintained 3.0 CIRCES Cost Estimating Software Truck/Loader Worksheet Cont'd Task # 02R Page 4 of 4 Haul Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (min) 1 1200.00 5.00 3.00 8.00 1381 0.898 Haul Time: Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (min) 1 1200.00 -5.00 3.00 -2.00 2938 0.476 0.898 minutes Return Time: 0.476 Total Truck Cycle Time: 3.199 minutes minutes Loading Tool unit Production 342.44 LCY/Hour Adjusted for job efficiency: 284.22 LCY/Hour Truck Unit Production 109.72 LCY/Hour Adjusted for job efficiency: 91.07 LCY/Hour Optimal No. of Trucks: 3 Truck(s) Selected Number of Trucks: 2 Truck(s) Adjusted hourly truck team production: 182.14 LCY/Hour Adjusted single truck/loader team production: 182.14 LCY/Hour Adjusted multiple truck/loader team production: 182.14 LCY/Hour JOB TIME AND COST Fleet size: 1 Team(s) Total job time: 13.06 Hours Unit cost: $2.571 /LCY Total job cost: $6,114 CIRCES Cost Estimating Software Page 1 of 2 REVEGETATION WORK Task description: Revegetate Cl Wetlands Site: Dunn Pit PROJECT IDENTIFICATION Task #: 03R Date: 3/8/2022 User: PSH Permit Action: State: Colorado Revised Bond Estimate County: Weld Agency or organization name: DRMS FERTILIZING Materials Permit/Job#: M2021059 Abbreviation: None Filename: M059 -03R Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Indiangrass - Cheyenne 1.20 3.66 $13.56 Switchgrass - Blackwell 1.50 13.40 $17.25 Alkali Bulrush 1.50 14.81 $60.75 Creeping Spike Rush 0.60 8.54 $108.60 Needle Spike Rush 0.40 5.69 $90.80 Canada Wildrye 1.50 3.96 $16.26 Softstem Bulrush 0.60 7.58 $78.63 Hardstem Bulrush 0.60 5.58 $89.82 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 03R Page 2 of 2 Three Square Bulrush 0.60 4.13 $103.05 Cordgrass, Prairie 0.70 2.94 $56.00 Nebraska Sedge 0.60 12.57 $99.90 Woolly Sedge 0.20 1.48 $30.30 Totals Seed Mix 10.00 84.33 $764.92 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D (a) 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Total Mulch Application Cost/Acre $71.57 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 0.47 Cost /Acre: $1,584.15 Estimated Failure Rate: 25% Cost /Acre*: $1,197.25 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $744.55 Reseeding Job Cost: $140.68 Total Job Cost: $885 Job Hours: 20.00 CIRCES Cost Estimating Software Bulldozer Worksheet Cont'd Task description: Site: Dunn Pit Task # 04R BULLDOZER WORK Slope Cl West Slope PROJECT IDENTIFICATION Task #: 04R Date: 3/8/2022 User: PSH Permit Action: Revised Bond Estimate Page 1 of 2 Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059 -04R Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat D6T XL Horsepower: 185 Blade Type: Semi -Universal Attachment: NA Shift Basis: 1 per day Data Source: (CRG) Cost Breakdown: Ownership Cost/Hour: Operating Cost/Hour: Ripper own. Cost/Hour: Ripper op. Cost/Hour: Operator Cost/Hour: $64.38 Utilization % NA $64.62 100 $0.00 NA $0.00 0 $40.04 NA Total unit Cost/Hour: $169.04 Total Fleet Cost/Hour: $169.04 MATERIAL QUANTITIES Initial Volume: Swell factor: Loose volume: 1,564 1.000 1,564 LCY Source of estimated volume: Source of estimated swell factor: HOURLY PRODUCTION Average push distance: Unadjusted hourly production: Division of Reclamation, Mining & Safety Cat Handbook 50 feet 444.6 LCY/hr Materials consistency description: Partly consolidated stockpile 1.1 Average push gradient: Average site altitude: -30 % 4,745 feet Material weight: 1,600 lbs/LCY Weight description: Top Soil Job Condition Correction Factor Source Bulldozer Worksheet Cont'd Task # 04R Page 2 of 2 Operator Skill: Material consistency: Dozing method: Visibility: Job efficiency: Spoil pile: Push gradient: Altitude: Material Weight: Blade type: Adjusted unit production: Adjusted fleet production: 0.750 (AVG.) 1.100 (CAT HB) 1.000 (GEN.) 1.000 (AVG.) 0.830 (1 SHIFT/DAY) 0.600 (FND-SF) 1.601 (CAT HB) 1.000 (CAT HB) 1.438 (CAT HB) 1.000 (PAT) Net correction: 0.9459 JOB TIME AND COST Fleet size: Unit cost: 420.55 LCY/hr 420.55 LCY/hr 1 Dozer(s) $0.402/LCY Total job time: 3.72 Hours Total job cost: $629 BULLDOZER RIPPING WORK Task description: Rip Access Road Site: Dunn Pit PROJECT IDENTIFICATION Task #: 05R Date: 3/8/2022 User: PSH Permit Action: Revised Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059 -05R Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat D6T XL Ripper Attachment: 3 -Shank Ripper Cost Breakdown: Ownership Cost/Hour: Operating Cost/Hour: Ripper Ownership Cost/Hour: Ripper Operating Cost/Hour: Operator Cost/Hour: Total Unit Cost/Hour: Horsepower: Shift Basis: Data Source: 185 1 per day (CRG) $64.38 Utilization % NA $64.62 100 $5.99 NA $4.30 100 $40.04 NA $179.33 Total Fleet Cost/Hour: $179.33 MATERIAL QUANTITIES Alternate Methods: Seismic: NA Area: 0.44 Selected estimating method: Area Bank Volume: NA BCY NA acres Rip Depth (ft): 0.50 Volume: 355 BCY or CCY Source of estimated quantity: Permit Application HOURLY PRODUCTION Seismic: Area: Seismic Velocity: Average Ripping Depth: Average Ripping Width: Average Ripping Length: Average Dozer Speed: Average Maneuver Time: Production per unit area: Job Condition Correction Factors Unadjusted Hourly Unit Production: Site Altitude: Altitude Adj: Job Efficiency: Net Correction: NA feet/second 1.64 6.58 200.00 88.00 0.25 0.719 feet/pass feet/pass feet/pass feet/minute minutes/pass acres/hour 0.719 Acres/hr 4.745 1.00 0.83 0.83 Adjusted Hourly Unit Production: Adjusted Hourly Fleet Production: feet (CAT HB) (1 shift/day) multiplier 0.60 Acres/hr 0.60 Acres/hr JOB TIME AND COST Fleet size: 1 Grader(s) Total job time: 0.74 Hours CIRCES Cost Estimating Software Unit cost: $300.695 Per acre Total job cost: $132 CIRCES Cost Estimating Software Page 1 of 2 REVEGETATION WORK Task description: Revegetate Access Road Site: Dunn Pit PROJECT IDENTIFICATION Task #: 06R Date: 3/8/2022 User: PSH Permit Action: State: Colorado Revised Bond Estimate County: Weld Agency or organization name: DRMS FERTILIZING Materials Permit/Job#: M2021059 Abbreviation: None Filename: M059 -06R Description Units / Acre Unit Cost / Unit Cost /Acre $ $ Total Fertilizer Materials Cost/Acre $0.00 Application Description Cost /Acre $ Total Fertilizer Application Cost/Acre $0.00 TILLING Description Cost /Acre Chisel plowing {DMG} $96.50 Weed control spraying (MEANS 31 31 16.13 3100) $290.40 Total Tilling Cost/Acre $386.90 SEEDING Seed Mix Rate — PLS LBS / Acre Seeds per SQ. FT Cost /Acre Blue Grama - Hachita 0.75 12.24 $11.98 Alkali Sacaton 1.00 39.03 $28.48 Alkaligrass, Fult's 0.50 13.77 $1.81 Canada Wildrye 3.00 7.92 $32.52 Bottlebrush Squirreltail 2.25 9.92 $36.51 Western Wheatgrass - Arriba 10.00 25.25 $65.00 Saltgrass, Inland 0.50 6.93 $21.40 CIRCES Cost Estimating Software Reveg Worksheet Cont'd Task # 06R Page 2 of 2 Totals Seed Mix 18.00 115.06 $197.70 Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $232.00 Total Seed Application Cost/Acre $232.00 MULCHING and MISCELLANEOUS Materials Description Units / Acre Unit Cost / Unit Cost /Acre Hay, delivered {MEANS 31 25 14.16 1200) 10.00 BALE $12.28 $122.80 Herbicide - 2,4D (a) 1.0 pt/ac 2.00 ACRE $2.98 $5.96 Total Mulch Materials Cost/Acre $128.76 Application Description Cost /Acre Crimping, with tractor {DMG survey data} $71.57 Total Mulch Application Cost/Acre $71.57 NURSERY STOCK PLANTING Common Name No / Acre Type and Size Planting Cost Fertilizer Pellet Cost Cost /Acre $ Totals Nursery Stock Cost / Acre $0.00 JOB TIME AND COST No. of Acres: 0.44 Cost /Acre: $1,016.93 Estimated Failure Rate: 25% Cost /Acre*: $630.03 *Selected Replanting Work Items: SEEDING,MULCHING Initial Job Cost: $447.45 Reseeding Job Cost: $69.30 Total Job Cost: $517 Job Hours: 20.00 CIRCES Cost Estimating Software Page 1 of 2 EQUIPMENT MOBILIZATION/DEMOBILIZATION Task description: Mob / Demob Site: Dunn Pit PROJECT IDENTIFICATION Task #: 07R Date: 3/8/2022 User: PSH Permit Action: Revised Bond Estimate Permit/Job#: M2021059 State: Colorado Abbreviation: None County: Weld Filename: M059 -07R Agency or organization name: DRMS EQUIPMENT TRANSPORT RIG COST Shift basis: 1 per day Cost Data Source: CRG Data Truck Tractor Description: GENERIC ON -HIGHWAY TRUCK TRACTOR, 6X4, DIESEL POWERED, 400 HP (2ND HALF, 2006) Truck Trailer Description: GENERIC FOLDING GOOSENECK, DROP DECK EQUIPMENT TRAILER (25T, 50T, AND 100T) Cost Breakdown: Available Rig Capacities 0-25 Tons 26-50 Tons 51+ Tons Ownership Cost/Hour: $21.28 $37.94 $47.67 Operating Cost/Hour: $26.55 $50.48 $56.21 Operator Cost/Hour: $20.54 $20.54 $20.54 Helper Cost/Hour: $0.00 $23.53 $23.53 Total Unit Cost/Hour: $68.37 $132.49 $147.95 NON ROADABLE EQUIPMENT: Machine Description Weight/ Unit (TONS) Owner ship Cost/hr/ unit Haul Rig Cost/hr/uni t Fleet Size Haul Trip Cost/hr/ fleet Return Trip Cost/hr/ fleet DOT Permit Cost/ fleet Cat D6T XL 25.01 $70.37 $68.37 1 $138.74 $68.37 $250.00 CAT 14M 23.57 $85.80 $68.37 1 $154.17 $68.37 $250.00 CAT 928Hz 13.91 $30.09 $68.37 1 $98.46 $68.37 $250.00 Subtotals: ROADABLE EQUIPMENT: $391.37 $205.11 $750.00 Machine Description Total Cost/hr/ unit Fleet Size Haul Trip Cost/hr/ fleet Return Trip Cost/hr/ fleet Generic 7-8 cy, 4x4 $66.35 2 $132.70 $132.70 Light Duty Pickup, 4x4, 1 T. Crew $121.54 1 $121.54 $121.54 Subtotals: $254.24 $254.24 CIRCES Cost Estimating Software Mobilization Worksheet Cont'd Task # 07R Page 2 of 2 EQUIPMENT HAUL DISTANCE and Time Nearest Major City or Town within project area region: GREELEY, CO Total one-way travel distance: 12.00 miles Average Travel Speed: 35.00 mph Total Non-Roadable Mob/Demob Cost * `* two round trips with haul rig: Total Roadable Mob/Demob Cost ** ** one round trip, no haul rig: Transportation Cycle Time: Haul Time (Hours): Return Time (Hours): Loading Time (Hours): Unloading Time (Hours): Subtotals: JOB TIME AND COST $3,474.49 $174.34 Non- Roadable Equipment Roadable Equipment 0.34 0.34 0.34 0.34 1.00 NA 1.00 NA 2.69 0.69 Total job time: 5.37 Hours Total job cost: $3,649 CIRCES Cost Estimating Software SITE MAINTENANCE Task description: Bond to Backfill Cl until Augmentation Decree Site: Dunn Pit PROJECT IDENTIFICATION Task #: 08R Date: 3/8/2022 User: PSH UNIT COSTS Permit Action: State: Colorado Revised Bond Estimate County: Weld Agency or organization name: DRMS Permit/Job#: M2021059 Abbreviation: None Filename: M059 -08R Maintenance Item Hours per Year Menu Selection Quantity Unit Unit Cost Total Cost Bond to Backfill Cl until Augmentation Decree Placeholder 160.00 USER PROVIDED I IEM 30,000.00 1 $10.00 $300,000.00 Job Hours: 160.00 Total Cost: $300,000.00 ISe) DNR COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Date: March 8, 2022 To: Peter Hays, DRMS From: Patrick Lennberg, DRMS RE: Dunn Pit New Permit Application, Exhibits F, G and Appendix D Review Memo, File No. M2021-059 On September 25, 2021, I was requested to review Exhibits F, G and the Groundwater Baseline Study (Appendix D) of the Dunn Pit new permit application M2021-059, below are follow-up questions that should be addressed after reviewing the Applicant's adequacy responses. Exhibit F 1. Please show the Hill and Brush Ditch orientation on the Reclamation Plan Map. Adequate Exhibit G 1. On Figure 2 the decreed surface water feature for the Hill and Brush Ditch is missing, please update the figure. Adequate 2. On Figure 2 the decreed groundwater feature for the Mad Russian Well (0405661) and constructed well (59968-F), and the 10 monitoring wells are missing please update. Adequate Appendix D 1. The applicant states, page 6, they will measure water levels in the 10 monitoring wells, installed in Summer 2021, monthly for one year then quarterly thereafter. The Division believes monthly water level monitoring should occur for at least one year after mining activities have begun to verify the numerical models predictions and monitor the effects of mining on the surrounding groundwater system. Adequate 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov/ Jared Polis, Governor Dan Gibbs, Executive Director Virginia Brannon, Director 0037[;. Peter Hays Dunn Pit (M2021-059) Page 2 of 5 2. How will the proposed open groundwater pond effect the surrounding ditches, Brush Ditch and the Big T and Platte Ditch in both the near term and long term? Adequate 3. What is the supposed source of toluene that was detected in MW -5? Adequate 4. In Section 5.3.1, it is stated the drawdown in the Dunn well is not expected to be greater than 2 feet. However, in Figure 16 the graphed drawdown approaches 4 feet. Please reconcile this discrepancy. The Division misinterpreted the graph and transposed the Dunn and Nelson wells on Figure 16. 5. In Figure 16 three of the four wells graphed have a starting point that indicates increased water levels, shouldn't all wells begin at 0.0 indicating no mining influence? Adequate 6. All groundwater sample results need to be compared to the Water Quality Control Commission's (WQCC) Regulation No. 41— The Basic Standards for Groundwater (Reg 41) and the most conservative values in Tables 1 thru 4 for all analytes listed for minimum of five consecutive quarters. The sample results from the June/August 2021 sampling event only compared results to WQCC Reg 41 Tables 1 and 2. Table 3 of Reg 41 are agriculture standards which contain a few analytes that Tables 1 and 2 omit. Attachment 15 Revised Initial Water Quality Sampling Result Tables do not appear to have been updated to reflect the most conservative values from Tables 1 through 4. An example is Aluminum, it has a Table 3 concentration of 5 mg/I dissolved. Additionally the footer has not been updated as indicated in the response. Please update the tables. 7. Did the applicant sample for radionuclides that are part of Reg 41 Table 1? Adequate 8. Nitrate/Nitrite as N was sampled, Appendix B, in some wells but not others, why? Adequate Peter Hays Dunn Pit (M2021-059) Page 3 of 5 9. Nitrate, Nitrite, and Total Nitrate + Nitrite are Reg 41 Table 1 values that appear to have not been sampled in all wells, please comment. Adequate 10. The Division recognizes there will become a point when a reduction in groundwater level and quality monitoring frequency becomes reasonable. The reduction requests and approvals will be completed through submittal of a Technical Revision. Adequate 11. Section 6.1.5, the Dunn well is not an on -site monitoring well but rather an adjacent private well that may be influenced by mining. Is it the applicant's intent to extend the 5 foot trigger to this well? If so, are there historic groundwater level data to support this trigger value? Adequate 12. In Monitoring Well Drilling Summary Report, Section 2.1, it is stated during drilling soil samples were collected for SPLP testing. Please provide the results of these analysis? Adequate 13. In the text, Section 2.2, it is stated the monitoring well screen size used was 0.01" but on the boring logs the screen size indicated is 0.1", please clarify. Please note the discrepancy appears to have made onto the forms submitted to DWR. Adequate 14. In the Groundwater Sampling and Analysis Plan Section 1 it references a water management pond. Please provide more details of the pond and clearly show it on Figure 1. Adequate 15. Please update Table 2 to include the WQCC Reg 41 concentrations each analyte is compared to. Table 2 shows the standard for Iron to be 5 mg/I however the most stringent standard is 0.3 mg/I listed in WQCC Reg. 41 Table 2. Please update the table. 16. Please provide copies of the completed groundwater data sheet(s) for each well sampled. In the future the Division will require submittal of these sheets along with other sample data. Peter Hays Dunn Pit (M2021-059) Page 4 of 5 Why are there no field parameters recorded during well purging on the field sheets? If parameters were recorded please update the field sheets. 17. Field blanks, Section 7.2.2, the applicant proposes to collect a field blank once annually and the Division does agree this is appropriate. The purpose of the field blank is to assess contamination from field conditions during sampling. At least one field blank should be collected during each sampling event. Please revise to reflect at least one field blank will be collected during each sampling event. Adequate 18. Rinsate sample, Section 7.2.3, the applicant proposes to collect a rinsate sample twice annually and the Division does agree this is appropriate. The purpose of the rinsate sample is to assess the adequacy of the decontamination process. It assess contamination from the total sampling, sample preparation and measurement process, when decontaminated sampling equipment is used to collect samples. Please revise to reflect at least one rinsate sample will be collected during each sampling event as appropriate. Adequate 19. As mentioned in #6 above, the Division will require at least five consecutive quarters of baseline water quality measurements with samples results compared to the most conservative values in Reg 41 Tables 1-4. Additionally, quarterly groundwater monitoring will continue for at least one year after the mining activities started at the site. After one year of mining the operator may, through a Technical Revision, request decreasing both the list of analytes samples are analyzed for and the frequency of monitoring. Adequate 20. In Appendix D, page 15-16, the Applicant states groundwater level and quality samples will be collected from all monitoring wells on quarterly basis. After one year the Applicant may approach the Division seeking to modify the plan along with justification for the modification. In the Groundwater Sampling and Analysis Plan Section 5.0, page 2, the plan states groundwater quality samples will only be collected from select wells and those wells are listed in Table 1. Table 1 only lists five wells to be sampled. Please explain the discrepancy and update accordingly. The Division is expecting all monitoring wells to be sampled on quarterly basis. Peter Hays Dunn Pit (M2021-059) Page 5 of 5 If you need additional information or have any questions, please let me know. Sincerely, 44 -90 -- Patrick Lennberg Environmental Protection Specialist cc: Jared Ebert, DRMS SG March 10, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Second Adequacy Review - Inlet Protection Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS/Office) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application inlet protection adequacy response dated February 21, 2022 for the Dunn Pit, File No. M-2021-059. A copy of the inlet protection second review memo from Rob Zuber dated March 10, 2022 is attached for review. The Division is required to issue an approval or denial decision no later than March 31, 2022, therefore a response to the following adequacy review concerns should be submitted to the Division as soon as possible. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Peter S. Hays Environmental Protection Specialist Enclosure — Second Inlet Protection Review Memo Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://mining.state.co.us Jared Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director S0 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Interoffice Memorandum Date: March 10, 2022 From: Rob Zuber RDZ To: Peter Hays Subject: Dunn Pit (Permit No. M-2021-059), Second adequacy review addressing responses from Telesto Solutions, Inc., 21 February 2022 After reviewing the responses from Telesto, I am requesting additional information for the inlet protection design and associated 2D HEC-RAS model. This includes the following adequacy items (numbers correspond to the numbers in my memorandum for our PAR, and I included the text for my original adequacy items): 1. Please explain why the 9,000 cfs event is used for determining maximum velocities for weir designs. Were flows and velocities for larger storms not considered? In particular, the 100 -year storm is listed as 20,309 cfs. • No additional response or revision required. 2. Please provide design drawings for the pit inlet weirs, or reference other reports associated with this submittal that contain the drawings. • No additional response or revision required. 3. Please explain why bridge decks and piers are not included in the model. It appears that these structures could impact the velocities of flows into Cell 3, which is relatively close to the railroad bridge (approximately 200 feet upstream). • The Telesto report states that, "The flood stage during the 100 year event is below the elevation of the bridge girders for both the railroad and highway bridges." Does the 1D model confirm this statement? If so, please provide an image from the model results (the cross section at the upper end of the railroad bridge) illustrating this point. If the 1D model does not confirm this statement, please explain the possible discrepancy between the model and the statement. 4. Please explain why there is no outlet protection for flood flows at the lower end of Cell 1. Include a discussion of velocities estimated with the 2D HEC-RAS model. • No additional response or revision required. 5. Please explain why no inlet protection is needed in areas other than the control points for each cell (shown on page 6 of the Inlet Protection Calculations). For example, for Cell 1 there is an area 250 - 300 feet east of the southwest corner where velocities in RAS Mapper (9,000 cfs) are greater than 13 feet per second. • No additional response or revision required. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining. st ate. co. us Jared S. Polis, Governor Dan Gibbs, Executive Director I Virginia Brannon, Director Zuber Memo on Dunn Pit Page 2 March 2022 6. Please explain the apparent discrepancies between pages 6 and 7 in terms of the sequence of flooding of the three cells. The table on page 6 suggests that flooding of Cell 2 occurs during smaller storm events than flooding of Cell 3; flooding of Cell 2 starts at 2000 cfs and flooding of Cell 3 starts at 4000 cfs. The discussion on page 7 states that flooding of Cell 2 and flooding of Cell 3 begin with approximately the same storm, approximately the 8 -year event. • The Telesto response states that flow into Cell 3 starts at 8,000 cfs (70-yr event). In the November submittal this value was 4,000 cfs. Please explain why this changed considerably. 7. The last page of the Inlet Protection Calculations (page 7) states that "riprapped inlet weirs were sized and included in Exhibit C of the mine plan." Can you be more specific where this is in the application? • No additional response or revision required. 8. Please elaborate on item 6 on page 7. Do the modeling results indicate the flows from backwater conditions will be low enough that additional bank protection (e.g., riprap) will not be needed, and vegetation will be sufficient? • No additional response or revision required. TELESTO SOLUTIONS* INCORPORATED March 21, 2022 Via Electronic Mail Mr. Peter Hays Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Subject: Dunn Pit, File No. M-2021-059 Responses to 112c Permit Application Second Adequacy Review Dear Mr. Hays: We appreciate the Division's thorough and thoughtful second adequacy review of Loveland Ready -Mix Concrete, Inc.'s (LRM's) 112c Permit Application for the Dunn Pit. This letter summarizes our responses, corrections, and clarifications regarding the Division's comments. We list the Division's comment in italics, followed by our response. Attachments 1 through 11 support our responses and/or update the required exhibits and documents. RULE 1.6 PUBLIC NOTICE Comment 3 Pursuant to Rule 1.6.2(e), please submit proof of the notice to all owners of record of surface and mineral rights of the affected land and the owners of record of all land surface within 200 feet of the boundary of the affected land including all easement holders located on the affected land and within 200 feet of the boundary of the affected land. Proof of notice may be return receipts of a Certified Mailing or by proof of personal service. The Applicant submitted Certified Mail Receipt tracking information for the following owners of record of all land surface within 200 feet of the boundary of the affected land, however the owners of record are not indicated on the Exhibit C-17 map. Please explain these discrepancies and revise the Exhibit C-17 - Permanent Man Made Structures map accordingly. a. Todd Mason McCarty b. Rearden Minerals c. Robyn Allyson Herman d. Atomic Capital Minerals e. Leo Gillis To: Mr. Peter Hays Date: March 21, 2022 Page 2 f g. Naviates Infintes LLC Prometheus Minerals LLC Response 3 The listed names a through g, are the mineral owners within 200 feet of the permit boundary. Exhibit C-17 now has a complete listing of both mineral and surface/structure owners within 200' of the boundary (Attachment 1). RULE 6.4.3 EXHIBIT C - PRE -MINING AND MINING PLAN MAPS OF AFFECTED LAND Comment 5 The Applicant indicated the type of structures and the location of significant, valuable and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land on the Exhibit C-17 map. Pursuant to Rule 6.4.3(g), please show the owner's name for the permanent man-made structures on the map. The Applicant added the adjacent property owners to the Exhibit C-17 map in response to the Division's adequacy letter. Please revise the Exhibit C-17 map to indicate the owner's name for all utilities within 200 feet of the affected land boundary. Response 5 The legend of Exhibit C-17 (Attachment 1) now lists the utility owner names. RULE 6.4.5 EXHIBIT E - RECLAMATION PLAN Comment 11 The Applicant has not obtained the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. Therefore, the Division will require the Applicant to provide a reclamation bond to include the backfilling of the exposed groundwater until the final augmentation plan is obtained from the DWR. The Division calculated the reclamation bond based on this requirement. The Applicant proposed a place -holder financial warranty in the amount of $300,000.00 for the cost of backfilling Cell 1 until mining activities commence or the Operator obtains the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. The Division will accept the place -holder 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $01.11110100 I i i C O i• O. n It To: Mr. Peter Hays Date: March 21, 2022 Page 3 bond and require the Operator to submit a revised financial warranty estimate prior to commencing mining activities at the site. Response 11 Thank you for the revisions to the bond estimate and acceptance of an interim bond. LRM will provide the final augmentation plan to DRMS once approved. Prior to a final augmentation plan, LRM can also provide the Substitute Water Supply Plan. Comment 13 On Page 13, Section 7.3.1, the Applicant states the final grading will be no steeper than 2H:1 V below water surface and 3H:1 V above water surface which will create a final topography that is appropriate for natural open space or wildlife habitat. As noted in Item 1112, please commit to reclaiming the pond slopes at a 3H:1 V grade from 5 feet above to 10 feet below the expected water line and revise Exhibit E accordingly. The Operator committed to the requirements of Rule 3.1.5(7) in response to the Division 's adequacy letter, however Section 7.3.1 was not revised accordingly. Please provide a revised copy of Exhibit E. Response 13 Exhibit E, Section 7.3.1 now reflects the appropriate reclaimed grades (Attachment 2). 6.4.6 EXHIBIT G - WATER INFORMATION Comment 20 A constructed well is indicated on Figure 2 - Water Rights Structures located in the southeast corner of the site, however the owner of the well is not indicated on the map. Please revise the Figure 2 map to indicate the owner of the well and provide proof of notification to the owner well. The Applicant identified the well owner as Bradley Petroleum and stated a notification was sent to the owner in the adequacy response. The Division did not receive proof of notification to the well owner as indicated in the adequacy response. Please provide proof of notice to the well owner to the Division. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $01.11110100 I i i C O i• O. n It To: Mr. Peter Hays Date: March 21, 2022 Page 4 Response 20 Bradley Petroleum was notified on February 8, 2022 via certified letter. Proof of notification is in Attachment 3.. Comment 21 On Page 21, Section 9.2.3, the Applicant lists the constructed wells in the vicinity of the site. Please confirm the list includes all wells within 600 feet the permit boundary. The Applicant provided a revised map of wells within 600 feet of the permit boundary with the adequacy response. Please provide a revised copy of Exhibit G, Section 9.2.3 to indicate the revised list of wells. Response 21 Attachment 4 provides the updated Exhibit G, Section 9.2.3 as requested. Comment 24 The Applicant provided proof of notification for well no. 12892-R owned by Paul and James Nelson. Please revise the list of constructed wells in Section 9.2.3 of Exhibit G to include the well owner. Response 24 Exhibit G, Section 9.2.3(Attachment 4) now includes the above referenced well owner. 6.4.12 EXHIBIT L - RECLAMATION COSTS Comment 26 The Division calculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant in the application and the Division's requirement to include the cost to backfill the exposed groundwater until the final augmentation plan is obtained from the DWR at $3,018,000.00. A copy of the Division 's bond estimate is attached for review. The Applicant proposed a total place -holder financial warranty in the amount of $394, 000.00 until mining activities commence or the Operator obtains the final augmentation plan for the groundwater exposure of the three groundwater ponds at the conclusion of the Dunn Pit reclamation. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® fO LO t IOM l.Iri COII.O.n It To: Mr. Peter Hays Date: March 21, 2022 Page 5 The Division recalculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant at $398,000.00. A copy of the Division's bond estimate is attached for review. Me Division will accept the total place -holder bond in the amount of $398,000.00 and require the Operator to submit a revised financial warranty estimate prior to commencing mining activities at the site. Minor comments or questions responses: • The Division used the MEANS average superintendent cost at 50% of the total task hours, which is standard procedure for the Division. • The weed control costs under Mulching and Miscellaneous Application were removed by the Division in the revised bond estimate. Please see attached. • Task 002 - Topsoil Cl Shoreline utilizes a team of one (1) loader and Iwo (2) haul trucks, therefore the Mob/Demob sheet accounts for 2 roadable trucks. The third roadable truck listed on the Mob/Demob sheet is a light duty pickup for the superintendent. Response 26 Thank you for the revisions to the bond estimate and explanations. 6.4.18 EXHIBIT R - PROOF OF FILING WITH COUNTY CLERK AND RECORDER Comment 28 Please provide an affidavit or receipt indicating the date on which the revised application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). Response 28 Please see Attachment 5. MEMOS Comment 32 ?he adequacy response for the Inlet Protection report are currently under review by the Division. A copy of the second review memo will be sent under separate cover, if needed. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $01.11110100 I i i C O i• O. n It To: Mr. Peter Hays Date: March 21, 2022 Page 6 Response 32 Inlet protection second review memo comments and responses are included at the end of this letter starting on page 9. 6.5 GEOTECHNICAL STABILITY EXHIBIT Comment 34 The Applicant states Telesto completed a slope stability analysis of the planned mined and reclaimed slopes utilizing Slide -2D and can provide the modeling files to the DBMS upon request in the adequacy response. Please provide the Slade -2D modeling files in electronic format to allow the Division to verify the stability analysis using Clover Technology's Galena slope stability software. Response 34 The attached thumb drive includes the Slide 2D files. We unaware of a conversion program to directly import Slide 2D into Galena. Thus, we also output the geotechnical model framework in DXF and image formats to allow import into Galena for model construction. We can also schedule a working session and allow DBMS personnel to control Slide 2D from our computers (through Microsoft Teams) and exercise the model. Comment 37 The Applicant states updates in Section 6.1.2 and 6.2 specify that LRM mine at slopes and with appurtenances indicated by the slope stability analyses presented in Appendix BI in the adequacy response. Section 6.1.2 was revised to include "an excavator stationed on a moveable platform ... ". Section 6.2 was not revised from the previous version of Exhibit D. Please update both sections to include the language from the adequacy response. Response 37 Attachment 6 contains the updated Exhibit D with the platform language added to Section 6.2. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $O LO t IOM.. Iii COX.O. n It To: Mr. Peter Hays Date: March 21, 2022 Page 7 NEW ADEQUACY ISSUES Comment 38 The Applicant provided revised Exhibit F-2 and F-3 maps removing Table 1 - Wetland Areas and Volumes with the adequacy response. Please confirm the Applicant intended to provide the revised map and explain why the tables were removed from the map. Response 38 Table 1 as previously presented on Exhibit F-2 and F-3 were exact duplicates of the table shown on Exhibit F-1. The tables from Exhibit F-2 and F-3 were removed to eliminate redundancy and to provide additional space for new sections on Exhibit F-3. Comment 39 The Applicant provided revised Exhibit F-4 and F-5 maps with the adequacy response. Pursuant to Rule 6.2.1(2)(b), maps must be prepared and signed by a registered land surveyor, professional engineer, or other qualified person. Please provide signed copies of the Exhibit F-4 and F -S maps. Response 39 Updated Exhibit F-4 and F-5 are included in Attachment 7. Comment 40 On Page 6, Exhibit D - Mining Plan (Updated 2/9/22), the Applicant states the entire site consists of approximately 114 acres. 1 _ he Applicant listed the proposed permitted acreage on the application form as 114.25 acres. Please provide a copy of a revised Exhibit D indicating a proposed permit acreage of 114.25 acres. Response 40 The acreage listed in Exhibit D is now 114.25 acres. An updated Exhibit D is in Attachment 6. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $01.11110100 I i i C O i• O. n It To: Mr. Peter Hays Date: March 21, 2022 Page 8 DUNN PIT NEW PERMIT APPLICATION, EXHIBITS F, G AND APPENDIX D REVIEW MEMO, FILE NO. M-2021-059 Comment 6 All groundwater sample results need to be compared to the Water Quality Control Commission's (WQCC) Regulation No. 41 - The Basic Standards for Groundwater (Reg 41) and the most conservative values in Tables 1 thru 4 for all analytes listed for minimum offive consecutive quarters. The sample results from the June/August 2021 sampling event only compared results to WQCC Reg 41 Tables 1 and 2. Table 3 of Reg 41 are agriculture standards which contain cr few analytes that Tables 1 and 2 omit. Attachment 15 Revised Initial Water Quality Sampling Result Tables do not appear to have been updated to reflect the most conservative values from Tables 1 through 4. An example is Aluminum, it has a Table 3 concentration of 5 mg/1 dissolved. Additionally the footer has not been updated as indicated in the response. Please update the tables. Response 6 The updated Initial Water Quality Sampling Results Tables have been updated to reflect the most conservative values from Tables 1 through 4 and the footer has been updated. Please see Attachment 8. Comment 15 Please update Table 2 to include the WQCC Reg 41 concentrations each analyte is compared to. Table 2 shows the standard for Iron to be 5 mg/1 however the most stringent standard is 0.3 mg/1 listed in WQCC Reg. 41 Table 2. Please update the table. Response 15 Table 2 has been updated to include the most stringent standard for Iron, 0.3 mg/l. Please see Attachment 9. Comment 16 Please provide copies of the completed groundwater data sheet(s) for each well sampled. In the fixture the Division will require submittal of these sheets along with other sample data. Why are there no field parameters recorded during well purging on the field sheets? If parameters were recorded please update the field sheets. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® .O LO t IONS Iri COII.O.n It To: Mr. Peter Hays Date: March 21, 2022 Page 9 Response 16 Field parameters are not measured while purging because over three -borehole volumes are removed from the monitoring well during the sampling events. Field parameters are taken at the time of sampling and recorded on the field sheets. Comment 20 In Appendix D, page 15-16, the Applicant states groundwater level and quality samples will be collected all monitoring wells on quarterly basis. After one year the Applicant may approach the Division seeking to modify the plan along with justification for the modification. In the Groundwater Sampling and Analysis Plan Section S. 0, page 2, the plan states groundwater quality samples will only be collected from select wells and those wells are listed in Table 1. Table 1 only lists five wells to be sampled. Please explain the discrepancy and update accordingly. The Division is expecting all monitoring wells to be sampled on quarterly basis. Response 20 We revised Appendix D to reflect that we will collect water levels from all monitoring wells monthly, and water quality samples from the five wells listed in Table 1, quarterly. We cleaned up language in Appendix D in hopes of clearly showing the purpose of each monitoring well. Attachment 10 provides this revision. DUNN PIT (PERMIT NO. M-2021-059), SECOND ADEQUACY REVIEW ADDRESSING REPONSES FROM TELESTO SOLUTIONS, INC., 21 FEBRUARY 2022 - MEMO FROM ROB ZUBER, DRMS TO PETER HAYS, DRMS Comment 3 The Telesto report states that, "The flood stage during the 100 year event is below the elevation of the bridge girders for both the railroad and highway bridges. " Does the ID model confirm this statement? If so, please provide an image from the model results (the cross section at the upper end of the railroad bridge) illustrating this point. If the ID model does not confirm this statement, please explain the possible discrepancy between the model and the statement. Response 3 The 1D model confirms this statement. Please see the figures in Attachment 11. 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $O LO t IONS. Iii CO..O• n It To: Mr. Peter Hays Date: March 21, 2022 Page 10 Comment 6 The Telesto response states that flow into Cell 3 starts at 8,000 cfs (70-yr event). In the November submittal this value was 4,000 cfs. Please explain why this changed considerably. Response 6 The river flow rate at which water begins to enter Cell 3 changed significantly between the November and the February submittals because the control of flows entering the pits was revised between these two submittals. Specifically for Cell 3, as discussed in Response 5, a pit inlet weir was added to the north and northwest sides of the pit and the inlet weir on the northeastern corner of the pit was modified. This pit inlet weir effectively serves to prevent river water from entering Cell 3 at the northeastern corner at relatively low flow rates. Sincerely, Telesto Solutions, Inc. )44,1,idittat Walter L. Niccoli, PE Principal/Senior Engineer WLN:wsc Enclosure cc: 20220314 DRMS Adeguacy_Review Response MASTER. docx TELEST® $O LO t IONS. Iii COX.O• n It Attachment 1 Updated Exhibit C-17 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ Dale: 3/15/2022 User: dzelmanfahm LEGEND Jill"- - 200 FT OFFSET 11111T in OIL AND GAS WELL O O 0 M N N mai zirs 0 0 a) cn ti a x w U) H co w c.6 z It 0 w 4O- aI a 0 ca C - OWNER: EHRLICH INC � - n- 4 a r � k i7 • WELD COUNTY ROAD 48 /Z -.Carl #At AI �I!•1 �■ �1 ■�! RAILROAD EASEMENT (UNION PACIFIC RR CO) STEEPEN DAVID B KIMBERLY `"wir OWNER: MARTIN I / 1111 11 11 I I IELI`ZArEcETH H) ��■■ STIT - w�.CKLER STEFFEN RESIDENCE s MARTIN DEL CAMP,O RESIDENCES �, • OUTBUILDING I1111111111I111111I111111111I�t�� OWNER:. COBS O N tar RICHARD ,L OWNER: WAGNEIR ■ • L. ■ TELECOMMUNICATIONS (TDS TELECOM AND ZAYO BANDWIDTH) NATURAL GAS LINE (XCEL ENERGY AND DCP MIDSTREAM) OVERHEAD POWERLINE (XCEL ENERGY AND CENTURY LINK) WATER LINE (LITTLE THOMPSON WATER DISTRICT) DIRT ROAD 1 PROPERTY BOUNDARY 1 Mineral Ow ers wit i 200 ft of •ermit :O dary Todd Mason McCarty Ehrlich 1 Inc/Robert Ehdkh Robert Ehrlich Paul Sandra Wagner and Nelson Family Richard Coulson Rearden Minerals Robyn Allyson Herman David G Dunn Atomic Capital Minerals Elizabeth Stickler Martin David Kathryn Terrell and Kenneth Coulson Leo Gilliss Dave B Jennifer VanWormer and Jose Rebugici/Martin DelCampo Naviates Infintas LPL Prometheus Minerals LLC 0 500 SCALE IN FEET NOTE(S) ZONING DATA ACCESSED FROM THE WELD COUNTY PROPERTY PORTAL Coordinate System: NAD 1983 StatePlane Colorado North FIPS 0501 Feet EXHIBIT C-17 PERMANENT MAN-MADE STRUCTURES AND MINERAL RIGHTS DUNN PIT WELD COUNTY, COLORADO PREPARED BY: TELESTQ SOLUYIONS. l N ti O k P Cs Rc s I t L' Loveland, Colorado (970) 484.7704 www.tele.So-Inc_cam PREPARED FOR: osia, 10VRAND READY MIX CONCRETE Attachment 2 Updated Exhibit E 20220314 DRMS Adequacy_Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ 7.0 EXHIBIT E - RECLAMATION PLAN (UPDATED 3/16122) This exhibit provides the information required by Section 6.4.5 of the Rules and Regulations. The proposed mining and reclamation plan focuses on minimizing the ecological impacts of mining, minimizing the time of impact, and maximizing long term benefits. The Reclamation Plan describes all general requirements for the type of reclamation proposed to be implemented. These include: • Establishment of a natural/pasture offset along the property boundary with temporary berms for noise and visual impact mitigation, if needed • Seeding/vegetating overburden and topsoil stockpiles that will be exposed longer than 180 days • Implementation of stormwater diversion into mine cells • Backfilling and sloping sides of mining cells with excess topsoil, replacing topsoil • Seeding/vegetating final reclamation areas immediately after establishing reclamation grades • Mitigating impacted wetlands 7.1 Type(s) of Reclamation Proposed Section 7.1 provides the information required of Sub -section 6.4.5(2)(a) of the Rules and Regulations. The Dunn Pit will be returned to wildlife habitat with groundwater sourced ponds as each of the three phases is completed. See Exhibit F for acreages and details. LRM will establish new wetlands at various locations shown in Exhibit F-3. Approximately 2.55 acres of new wetland are possible. LRM is scheduling a preplanning meeting with the US Army Corps of Engineers to discuss the need for Section 404 permitting regarding the existing wetlands on site. Any subsequent 404 Permit approval and plan will be submitted to DRMS. Specific engineering, grading details, plantings, and timetables will be included with this plan and permit. For typical reclamation, as soon as practicable after an area is mined, topsoil will be pushed into place to cover disturbed areas slopes. Slopes of 3H:1 V will be established from five feet above to ten feet below the average water surface, maximum slopes of 2H:1V will be established elsewhere around the reclaimed ponds. Topsoil will be placed over the Loveland Ready -Mix, Concrete, Inc. 12 updated_exhibits_e. docx September 2021 TELESTO disturbed area and the area will be seeded. The topsoil will be placed in a manner that controls erosion and siltation of the affected lands and areas outside the affected areas. The disturbed areas will be finished to a grade of 3H:1V that is suitable for revegetation. Service roads and the bridge crossing will remain in place so that rangeland maintenance equipment can access the site. Any areas that have been previously reclaimed that are not revegetating properly will be addressed and reseeded. 7.2 Post -Mining Land Use Comparison The historic land use in the vicinity of the Dunn Pit is agricultural, rural residential, recreational golf course, and oil and gas production. The pre -mining use of the affective lands is wildlife habitat. The post -mining land use of wildlife habitat, groundwater sourced ponds, and mitigated wetlands and open space will be compatible with the area. 7.3 Reclamation Plan Implementation Section 7.3 provides the information required of Sub -section 6.4.5(2)(c) in the Rules and Regulations. Mining of the Dunn Pit is proposed to be performed in three Cells ranging from 11 to 36 acres. During the mining of each proposed Cell, reclamation will commence concurrently following behind mining. All reclamation will be carried to completion with all reasonable diligence and each phase of reclamation with a goal to complete within five years from the date that each cell has been completed. As stated in this application, the mined areas are to be reclaimed to provide wildlife habitat, groundwater sourced ponds, or natural open space. 7.3.1 Reclamation Measures — Materials Handling 1. Final grading will be no steeper than 3H:1 V from five feet above to ten feet below the average water surface, while maximum slopes of 2H:1 V will be established elsewhere around the reclaimed ponds. These reclaimed slopes will create final topography appropriate for natural open space or wildlife habitat. 2. No toxic or acid-forming materials are expected at this site 3. All grading will be done to control erosion and siltation of affected and non - Loveland Ready -Mix, Concrete, Inc. 13 updated_exhibits_e. docx September 2021 TELESTO affected lands. Off -site siltation is not expected but if it occurs BMPs will be used to control silt. Final grading will be no steeper than 3H:1 V from five feet above to ten feet below the average water surface, while maximum slopes of 2H:1V will be established elsewhere. 4. Backfilling and grading will be concurrently behind mining as it progresses through each cell and will be completed as soon as practicable 5. Auger and drill holes that are part of the mining operation will be plugged with non-combustible material, which shall prevent harmful or polluting drainage. Monitoring wells and test pits no longer needed for the operation or monitoring will be plugged as soon as practicable 6. All mined material to be removed within the affected area will be handled in such a manner to prevent any unauthorized release of pollutants to the surface drainage system 7. No unauthorized releases of pollutants to the river or offsite will occur from any materials mined, handled or disposed of within the permit area. 7.3.2 Groundwater LRM will comply with all applicable Colorado water laws and regulations governing injury to existing water rights and will comply with all State and Federal water quality regulations. As described in Exhibit G, LRM plans to utilize the available water from their City of Loveland lease to replace depletions from exposed groundwater. LRM filed a substitute water supply plan with the Colorado Department of Natural Resources as required. There will be no discharges from site, and activities will not produce contaminants. Thus, groundwater quality is not anticipated to be an issue. Additionally, LRM will actively monitor site groundwater levels and work to mitigate unacceptable changes caused by mining activity or reclamation. 7.3.3 Wildlife The reclamation and mining plans have been structured to minimize impacts to wildlife. By mining and reclaiming each cell simultaneously, the impact to wildlife will be minimized. Wildlife habitat should be improved by the addition of the groundwater source ponds and revegetation of the banks. The proposed grass seed mix will return cover for wildlife adjacent to the ponds. Loveland Ready -Mix, Concrete, Inc. 14 updated_exhibits_e. docx September 2021 TELESTO 7.3.4 Topsoil Topsoil will be removed and stockpiled in berms around the perimeter of the area being mined. The topsoil berms will be out of the way of the active mining operation and will be near the areas where topsoil will be placed during reclamation. The stockpiles that will remain in place for more than 180 days will be seeded to stabilize them and minimize erosion. 7.3.5 Revegetation The reclaimed areas will be seeded with a grass mix that will be like and compatible with the grass species in the area. The vegetation will be capable of self -regeneration without continued dependence on irrigation or fertilizer. Any wetland mitigation will involve specific seed mixes of approved wetland sod. These may include bull rush, spike rush, and scripts validus. In addition to seeding, LRM plans to plant trees and shrubs in key locations to block sound, dust and mitigate potential erosion. These planting locations are shown in in Exhibit F. 7.3.6 Buildings and Structures Prior to mining, LRM plans to demolish dilapidated fences and structures. LRM will appropriately dispose of the debris and salvage materials of value. No buildings will exist on site after reclamation. 7.3.7 Signs and Markers Appropriate signage, indicating that the area is under reclamation, will be posted at the entrance to the mine site. The permit area will be marked by existing fencing with signage. Once reclamation is established, signage will be replaced with appropriate "No Trespassing" signs. 7.4 Topsoil Management and Revegetation This section provides the information required by the Rules and Regulations, Sub -section 6.4.5(2)(d). Loveland Ready -Mix, Concrete, Inc. 15 updated_exhibits_e. docx September 2021 TELESTO 7.4.1 Topsoil Management 7.4.2 Revegetation LRM plans to utilize the seed mixture presented in Attachment 4 of the response to adequacy review as the basis for reclamation seeding mixtures (Pawnee Butte Seed, 2017). Placed topsoil will be graded to drain, scarified to promote infiltration and air movement into the soil. Seeding will be accomplished by broadcast or drill. Broadcast seeding will be followed by dragging, or light rolling to promote soil contact. Drill seeding will be at the appropriate depth in the soil to optimize germination for the species being planted. In general, seeds should be placed 1/4 inch to 1/2 inch deep in the soil. Following seeding, areas will be protected from erosion by the application of cereal straw or grass mulch, laid and crimped into the soil as to prevent removal by wind and water. Grass or straw will be crimped in place with a mechanical crimper made for such purposes or using a farm -type disc plow set straight with adequate weight to crimp the material to a depth of approximately 4 inches. Mulch will be applied at a minimum rate of approximately one ton per acre. For slopes exceeding 5:1, mulch will be applied at a minimum rate of approximately 2 tons per acre. LRM plans to utilize a diverse grass species that are best adapted for this area based on recommendation from Pawnee Butte Seed Company (Pawnee Butte Seed, 2017). A minimum of four species will be specified for mixes and a mix of cool and warm weather species are included. Attachment 4 of the response to adequacy review shows the temporary soil stockpile, upland and wetland seed mixes. 7.5 Reclamation Schedule For information satisfying Sub -section 6.4.5(2)(e) of the Rules and Regulations, please refer to the timetable for mining and reclamation in Exhibit D Section (e). Also shown in Exhibits D and F are the size and location of each mining Cell/phase' s reclamation area. The sequence of reclamation is described in the previous sections and shown in Exhibits C and F. Loveland Ready -Mix, Concrete, Inc. 16 updated_exhibits_e. docx September 2021 TELESTO Attachment 3 Notice to Bradley Petroleum 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ February 8, 2022 Bradley Petroleum Inc. 7268 South Tucson Way Englewood, Colorado 80112 Subject: EL S O L U T I O N S* I M C: O R i* O Et A T r D Gravel Pit Well Permit and Substitute Water Supply Plan Waiver of Objection Request Loveland Ready -Mix Dunn Pit, Milliken, Colorado NW Corner of Hwy 257 and Weld County Road 48'/z To Whom It May Concern: Loveland Ready -Mix Concrete, Inc. (LRM) has filed an application for a Gravel Pit Well Permit and a Substitute Water Supply Plan for a proposed gravel pit. The proposed operation is known as the Dunn Pit, and is located at or near Section 3, Township 4 North, Range 67 West, 6th Prime Meridian. The proposed date of commencement is January 2023, and the proposed date of completion is September 2045. The proposed future use of the land is wildlife habitat. The Colorado State Engineer's Office regulations require that LRM request a waiver from owners of wells within 600 feet of the proposed pit. Our records show that your well (Permit number 300650) is within 600 feet of the proposed Dunn Pit. As part of the Gravel Pit Well Permit and Substitute Water Supply Plan, a waiver of objection is being requested. If you choose not to sign the waiver, a hearing will be held before the State Engineer at which point you will be asked to submit evidence of injury to your well due to LRM's gravel pit operations. Telesto Solutions, Inc. has designed and calibrated a detailed groundwater model that predicts the effects of all phases of mining on surrounding groundwater and your well. We would be happy to review the results of this model and discuss how it will affect you. Please review the attached application that was submitted to the State Engineer on behalf of LRM. Once you have reviewed the application, sign the attached waiver and return 1t in the enclosed stamped and self-addressed envelope or contact us if you have any questions regarding this form or impacts to your well. If you have any questions or concerns, or would like additional information, please feel free to contact me at 970-484-7704 or ttigges@telesto-inc.com. amarmaa Ll�YIIIWYI n.......... WAVMwLLVVDO ....... .. . = •.......i�ii.i.�.. •.. Colorado Office (Corporate) 750 14111 Street SW Loveland, Colorado 80537 970-484-77041970-484-7789 (FAX) Grand Junction 751 Horizon Court, Suite 109 Grand Junction, Colorado 81506 970-697-1550 xwrwu�i.du�.. New Mexico Office 1303 Pope Street Silver City, New Mexico 88001 575-538-56201575-538-5625 (FAX) To: Bradley Petroleum, Inc, Date; February , 2022 Page 2 Sincerely, Tc/csto Solutions, Inc. ,24 Taryn Tigges, FE Senior Engineer TMT:tjg Enclosure cc: LRM Waiver request letter Bradley TELET a I-RH.rPx P• I A. cI P I It I GWS-38 600 FOOT WELL SPACING STATEMENT (we} Bradley Petroleum Inc. state as follows: 1. I (we) own real property described as ,. in NW the 1/4 of the 1A, Section 2Township 4N Range 67W 6thP.M., WeldCounty,Colorado. We own the right and easement to the following well: Actual Actual Distance from Distance from Permit # 1/4 1/4 Sec. Twp. Rng. NUS Sec. Line ENV Sec. Line 300650 NE SW 2 4N 67W 2516 ft 67 ._.� ft. Loveland Ready -Mix Concrete, Inc.2. I (we) have been apprised that , the present owners of a parcel of land in the NE %, Section 3 : Township 4N , Range 67W a 6th P.M., desire to drill a new well or extend the use of an existing well, I (we) also understand that the purpose of such well is set forth in the well permit application, and that I (we) have reviewed the application that was submitted to the State Engineer and receipted by him under receipt no. 10015077 3, The proposed location for the subject well will be 600 feet or less from my (our) well. 4. By this statement I (we) am (are) specifically waiving any objection to the issuance of a well permit for the subject well, as set forth in the referenced application, and would request that permit issuance not be postponed or denied because of any concerns by the Division or others that the proposed well will materially affect my (our) well or water right. I (we) am (are) also specifically waiving my (our) right I (we) may have to participate in a hearing before the State Engineer pursuant to Section 37-90-137(2), C.R.S. Dated this day of r_, Form GWS-27 01/2020 No. DWR COLORADO DEPARTMENT 1313 Web: Sherman Phone: dwr.colorad�av (303) DIVISION OF St., Ste BCE NATURAL 821, Email; OF Denver, WATER dwrpermitsonline@state.co.us RESOURCES Colorado RESOURCES .2223 80203 For Office Use only REVIEW INSTRUCTIONS PRIOR TO COMPLETING FORM GRA'V'EL PIT WELL PERMIT APPLICATION 1. TYPE OF PERMIT LI.] NEW PIT(S) . 1 PIT(S) EXIST, CONSTRUCTED AFTER DEC. 31, 1980 2. APPLICANT INFORMATION NAME(S) Loveland Ready -Mix Concrete, Inc. (Stephanie Fancher-English) Mailing Address P.O. Box 299 City, St, Zip Loveland, CO 80539 Phone (w/ area code) 970-667-1108 Email: stephanief@Irmconcrete.com PIT NAME Dunn Pit 3. CON LLTANTIATTQRNEY/QPERATOR CONTACT (If different than #2) NAME(S) Telesto !QF4PrI±.Inc.!,_craryn Tigges) Mailing Address 740 14th St SW DRM No, M-1999-065 City,St. Zip Loveland, CO 80536 . Phone (w\ area code)97O-484-7704 Email:ttigges@telesto-inc.com 4. GENERAL LOCATION OF PIT(S): COUNTY Weld 1/4 NE 1/4, Sec. 3 Tw 2 LXA N. Laal S. Range 4N j 1, E. IN W. 5th p.m. . 5. Estimated maximum water surface to be exposed: 75.9 Acres. Number of Pits 3 . 6. Estimated depth of pits) 25 Ft. Estimated depth to groundwater 10 ,Ft. 7. Estimated date to expose groundwater 01/01/2023 ; date to complete mining 09/30/2045 . ATTACHMENTS: (Check which have been attached.) (a) isi Scaled map of pit area with range, township, & section clearly identified (REQUIRED). (b) Copy of the reclamation permit, if applicable. (c) Copy of pre 1./15/89 water conservancy dist. or water user assoc. augmentation agreement, if applicable. (d) Copy of proposed substitute water plan or augmentation plan application, if applicable. (e) Copy of court approved augmentation plan, if applicable, Case No. (f) IOther 9. 1,441 2.5 Detailed diversion acre-ft/yr acre-ft/yr description of any used for reclamation water of for withdrawn dust any use, control; tree other from establishment 5.89 the than. acre-ft/yr evaporation, pond. of water and entrained method of in diversion, mined rate aggregate of diversion, removed and from annual site; amount i 10. Will dewatering occur within the DRMS permit boundary Li Yes I No 11. I (we) knowledge. have read [Pursuant the statements to Section made 24-4-104 herein (13)(a) and know C.R.S., the the contents making thereof, of false and statements that they are herein true to my (our) in the second degree and is punishable as a class 1 misdemeanor.] constitutes perjury Sign or enter name(s) of submitter If Taryn signing Tigges, print name PE & title [bt7mm/dd/yyyy) : 08/30/2021 For Office Court Use Case No. only Div. Co. WD Basin MD Use COLORADO DIVISION OF WATER RESOURCES DEPARTMENT OF NATURAL RESOURCES GWS-27 INST ST (01/2020) GRAVEL PIT WELL PERMIT APPLICATION • INSTRUCTIONS Applications must be computer generated online, typewritten, or printed in BLACK or BLUE INK. ALL ITEMS in the application must be completed. Incomplete applications may be returned for more information. Attach additional sheets if more space is needed. If filing online see online filing instructions! You may also print, scan and email the completed form to: d rperm its li nenstate. co. us This applications is for use in applying for a well permit for a gravel pit that exposes groundwater to evaporation as required under the provision of 37-90-107(6) or 37-90-137(11), C.R.S. If this is not such a gravel pit, use General Purpose Application Form GWS-45. A permit is not required if the pit was constructed prior to December 31, 1980 and has not been operated or reactivated after that date. FEES This application requires a nonrefundable filing fee of $100. One application is required for each DBMS permit area. After submitting this form to dwrpermitsonline@state.co.us, you'll be provided with the payment options. A substitute supply plan or augmentation plan may be required for approval where groundwater was exposed after December 31, 1980. These plans are submitted separately and a filing fee of $1,593.00 is rewired. These plans may not be needed in areas where water is available and all other water rights are satisfied. ITEM 1 ITEM 2 ITEM 3 ITEM 4 ITEM 5 ITEM 6 ITEM 7 ITEM 8 ITEM 9 ITEM 10 ITEM 11 Ww.cr"' . .•p....�,.•. tn.�o.a.... +crrvr "C].v..:: .:C 5I..1. ".nw.;�:. �Gl •7N(Y HMWWII•;•, Win..,... c., ,.�w a_...:.:a"'4�v., ........ ray........a .. .. .. .. �:�• ,. a.,,�. . . . ...Mri�-.,n.. .. '4.'.{4ii.4.`.�•Gll'P:ii�i:. c..S:+W.i'ihWwi�iih i4..�..L a.;r,r _. _ ,_. ,. � �^::r@. !�+++.uM�Y..,,,." ;. TYPE OF PERMIT - Check the appropriate box. APPLICANT INFORMATION - This is the applicant's name and the mailing address where all correspondence will be sent. Include the phone number. CONSULTANT/ATTORNEY/OPERATOR CONTACT - If there is someone different than the applicant to be contacted for additional information, then complete this item. indicate the name of the gravel pit and the assigned DBMS number (include any prior DRMS/MLRD permit numbers that may be assoicated with this pit. LOCATION OF WELL - The general location of the well (pit) must be indicated and include a quarter/quarter, Section, Township, Range and Principal Meridian. An outline of the pit(s) on a USGS 7 1/2 minute quadrangle map is desirable. Indicate the maximum number of acres of groundwater to be exposed to the atmosphere and the total number of excavated areas (pits) covered within the DBMS permit. Indicate the estimated proposed or actual depth of the pit(s), and estimated depth to groundwater. Indicate the estimated dates of beginning to expose groundwater and completing the mining. ATTACHMENTS - The list of attachments to this application provides information which is necessary to the evaluation. A scaled map of the pit area tied to a section corner is required. USE -- Complete this item if water is to be used for any purpose other than evaporation, those uses must be detailed. The information required includes but is not limited to the volume of gravel mined, the method of diversion of water from the pit, the pumping rate in gallon per minute, the average annual amount of water diverted or used in acre-feet, and the proposed use. DEWATERING — Specify whether dewatering will occur within the DBMS permit boundary. SIGNATURE - The individual signing the application or entering their name (and title if applicable) must be the applicant or an officer of the corporation/company/agency identified as the applicant or their attorney. An authorized agent may also sign or enter their name on the application if a letter signed by the applicant or their attorney is submitted with the application authorizing that agent to sign or enter their name on the applicant's behalf. Payment must be received via phone if filing online at 303.866.3581 (Records Office) prior to processing the application. IF YOU HAVE ANY QUESTIONS regarding any item on the application form, please call the Division of Water Resources Ground Water Information Desk (303-866-3587), or the nearest Division of Water Resource Field Office located in Greeley (970-352-8712), Pueblo (719-542-3368), Alamosa (719-589-6683), Montrose (970-249-6622), Glenwood Springs (970-945- 5665), Steamboat Springs (970-879-0272), or Durango (970-247-1845). COLORADO DIVISION OF WATER RESOURCES, 1313 SHERMAN STREET, STE 821, DENVER, CO 80203 (Main) 303-866-3581 • .: • • - - W' rr • I -.▪ 'I ;Ds-.• • ••. .. r-•�� T :ran -1.1:▪ j= • - -, • •-a. i • ..• •I mil 1 E. • P. -• "�a ma • • • — •-, • -_I- Iual4 .+.1• •rte -• - • - F Ir •.,.. --r•'�I""r- ••-• .. rrr i. r H• - • ..'• • .r .•r• r !r Y. S.• .._ •. w tee} 'W -an. . 2.. •. • • _ r •.• J� stair • • ISMS • • sit mr rt -rr'irie iF-• + �• ▪ '-5.- amla • • -•n••••••-. —•_ — . .• • •• • .- • - es. a • Sale war I • • •••'-N T. f. ...M. • -I•. 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V .� eee��iiilwww r ��((.�'' WI 1 t Instructions D � Sce Reverse for FPS Form 38' `s April 2015 rsN 75SO-a2-00P X04' Attachment 4 Updated Exhibit G, Section 9.2.3 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ 9.2.3 Constructed Wells (Well permit No.) The list of wells within 600 feet of the permit boundary includes: • Dunn, Thomas G & Alice E (47255) • Nelson, Paul & James (12892-R) • Wagner, Henry (226967A and 226967B) • Bradley Petroleum (300650) • Loveland Ready Mix Monitoring Holes • 322566 ■ 322567 • 322568 ■ 322569 • 322570 • 322571 • 322572 ■ 322573 ■ 322574 • 322575 (MW -01) (Mw -o2) (Mw -o3) (Mw -o4) (MW -OS) (Mw -o6) (Mw -o7) (MW -08) (Mw -o9) (Mw-io) • A well construction permit was issued for the Mad Russian Well (59968-F); however, no completion reports exist, and field reconnaissance indicated no well constructed. Figure 2 reflects no well constructed. • Site investigation shows no Hall Irwin well (248398) located where the DWR Map Viewer locates Hall Irwin well. This was likely mis-recorded in the DWR database. Loveland Ready -Mix, Concrete, Inc. 22 '0'20310 updated_exhibitg_water_Irm_dunnpit_ September 2021 TELESTO Attachment 5 Proof of Recording — M-2021-059, Responses to 112c Permit Application Second Adequacy Review 20220 31.1_DRMS Adequacy_ Review Response MASTFR. clocx TELEST® Receipt from Weld County Clerk and Recorder For: Knox Pit, DBMS Permit Application No: /Y1-2027-059 Responses to 712c permit Application 2n° Adequacy Review Dated 3/21/2022 Received: Received by: { ZI Z2 (pate) CARLY KOPPES WELD COUNTY CLERK & RECORDER 1250 H STREET P D BOX 459 GRgEI.EY, COLORADO 130632 (Signature) Attachment 6 Revised Exhibit D 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ 6.0 EXHIBIT D - MINING PLAN (UPDATED 3/16/22) This exhibit provides the information required by Section 6.4.4 of the Rules and Regulations. 6.1 Mining Methods and Surface Disturbance Section 6.1 provides the information required in Sub -section 6.4.4(a) Rules and Regulations. The entire site consists of approximately 114.25 acres. There are approximately 76 acres that LRM will utilize for mining. Approximately 38 acres of the site will consist of boundary offsets, perimeter buffering the main access road, the Big Thompson River corridor, and stormwater management areas. 6.1.1 Site Preparation The site will first be cleared of unneeded existing structures (old fencing and cattle chutes). The topsoil, if present, material will be stripped as each Cell is mined. Stripping will occur in phases or "strips" approximately 118th to 114th of the size of the Cell to expose the active mining area. The stripped material will be stockpiled adjacent to the active mining area. Scrapers, front-end loaders, excavators, and bulldozers may be used for stripping. Topsoil stockpiles, ditches and grading may be used to direct stormwater into the mining cells. Exhibit C shows the quantities of topsoil for each phase. A typical topsoil stockpile berm size will be 36 feet in width, 10 foot high, or 6.6 sq-yd per ft. The topsoil stockpiles will be stabilized, and erosion control devices will be installed. If the topsoil stockpiles will be in place for 180 days LRM will seed to produce a vegetated cover. An access bridge across the Big Thompson River will require a 404 Permit to construct. As part of the 404 Permit the bridge will be installed and analyzed to certify that it does not create a rise in the floodway. Haul roads will be established and stabilized during site preparation. Loveland Ready -Mix, Concrete, Inc. 6 updated_exhibits_d. docx September 2021 TELESTQ 6.1.2 Mining The sand and gravel deposit will be mined to bedrock. An excavator stationed on a moveable platform will be used to mine the material wet. The mining excavations will not be dewatered. The mining will be done in three Cells ranging in size from 11 to 36 acres, with excavation conducted to bedrock. A previous geotechnical report (C.E. Maguire Subsoil. Exploration Report, 1978) and the recently installed groundwater monitoring wells have established the bedrock surface at approximately 28 to 30 feet below ground surface. Because the material is mined "wet", mined slopes will be consistent with slope stability calculations provided in Appendix B 1. The operator will develop and comply with a Stormwater Management Plan (SWMP). Berms and sloping of ditches will divert flow from all disturbed areas back into the mined cells. The operator will notify the Division of Mine Safety and Reclamation (DBMS) in the event of a reportable spill. Mined material will be stockpiled adjacent to the mining cells. The material will remain adjacent to the mining cell and drainage water will flow back to the mined cell. The material then will be loaded into haul trucks and transported offsite. 6.1.3 Imported Material Currently there are no plans to import material from other sites. Loveland Ready -Mix Concrete, Inc. (LRM) is aware that in accordance with Rule 3.1.5(9) of the Construction Materials Rules and Regulations, if any offsite material is used as backfill, a notarized letter will be submitted to the DRMS indicating the materials are inert. 6.2 Earthmoving Section 6.2 provides the information required by Sub -section 6.4.4(b) of the Rules and Regulations. Loveland Ready -Mix, Concrete, Inc. 7 updated_exhibits_d. docx September 2021 TELESTQ Topsoil will be excavated with front-end loaders, scrapers, or other similar equipment. The topsoil will be placed in berms at the edge of the active mine phase and stabilized as required. The construction material will be mined with an excavator. The construction material will be transported offsite in 15 -ton tandem dump trucks. 6.3 All Water Diversions and Impoundments Sub -section 6.4.4(c) requirements of the Rules and Regulations are described in this section. The operator plans to mine the material wet; no dewatering activities are proposed. Stormwater that flows on to the site will be captured and contained in the cell(s) or allowed to flow through the site using historical channels in undisturbed portions of the site. Likewise, stormwater generated on site in disturbed areas will flow to the mining cells. Stormwater from the access road will be diverted back to the cell(s). The operator will develop and comply with a Stormwater Management Plan (SWMP). 6.4 Working Area Sub -section 6.4.4(d) of the Rules and Regulations requires a description of the size/areas of the mine to be worked at any one time. The proposed permit site will be divided into three cells and mined in phases. Cell 1 (C2) contains 36.7 acres, Cell 2 (C2) contains 10.9 acres, and Ce113 (C3) contains 28.3 acres. Exhibit C shows the progression of the mining phases through each cell. Table 1 shows cell sizes, aggregate, topsoil, and quantities for each cell. Table 1 Estimated Mining Quantities Cell Area (AC) Total Volume (YD3) Topsoil Volume (YD3) Gravel Volume (YD3) Gravel Weight (Tons) C1 36.7 1,404,361 50,520 1,353,840 2,166,145 C2 10.9 414,877 1,399 413,478 661,565 C3 28.3 1,101,661 28,137 1,073,524 1,717,639 (C1,C2,C3) 75.9 2,920,898 80,056 2,840,843 4,545,348 Loveland Ready -Mix, Concrete, Inc. updated_exhibits_d. docx 8 September 2021 TELESTQ 6.5 Timing of Mining and Reclamation As required by Sub -section 6.4.4(e) of the Rules and Regulations, an approximate timetable to describe the mining operation is needed. The timetable establishes the relationship between mining and reclamation during the different phases of a mining operation. Mining operations are anticipated to begin soon after all permits are in place. The extraction rates are expected to be approximately 200,000 tons of construction material per year. Production rates will vary depending on market demands. LRM plans to conduct concurrent reclamation as mining progresses. Mining and reclamation are planned in five - acre increments. This will allow for safe and efficient operations with detail to slope stability and concurrent reclamation Exhibit C. Cell 1/C1 Mining will begin with Cell Cl for the first 10 to 12 years of operation. Approximately 37 acres will be mined in 7 phases during this time with a total of 2,166,145 tons of gravel. Cell 3/C3 Mining will continue into C3 and will last about 8 years. Cell C3 is approximately 28 acres, will be mined in 5 phases to the mining access road; mining will then begin at Cell 2. As Cell 2 is nearing completion, mining will recommence on Cell 3 along the west side of the access road working from north to south. Cell 3 will generate 1,717,639 tons of gravel. Cell 21C2 Once mining reaches the access road from Cell 3, mining will be focused on Cell 2. Cell 2 will be conducted in 3 phases. Cell C2 is approximately 11 acres, will be mined in 4 phases and take a little over 3 years for a total of 661,565 tons of gravel. The operator will comply with the performance standards of Section 3.1 and this operation is not intended to be an intermittent operation as defined in Section 34-32.5-103(11)(b), C.R.S. Loveland Ready -Mix, Concrete, Inc. 9 updated_exhibits_d. docx September 2021 TELESTQ Reclamation and mining will be conducted concurrently when practicable to minimize disturbance and material handling. See the Mining Plan Map in Exhibit C for Cells and phases to be mined. 6.6 Deposit As described in Sub -section 6.4.40 of the Rules and Regulations, narrative and figures are provided in this section to describe the deposit. Figure 1 provides a generalized cross- section of the deposit. The deposit to be mined is the Big Thompson River alluvium, which consist of unconsolidated silt, sand, and gravels. The deposit ranges from approximately 25 to 28 feet thick and is overlain by approximately 1 to 2 feet of sandy to clay loam topsoil. A conceptual cross-section though the site is shown in Figure 1. The stratum below the target deposit consists of a weathered shale bedrock. 6.7 Commodities Sub -section 6.4.4(g) of the Rules and Regulations requires that the applicant identify the primary and secondary commodities to be mined/extracted and describe the intended use. The primary commodities to be mined are gravel, sand, and fill. The material will be used as aggregate in concrete and construction materials. 6.8 Incidental Products LRM does not plan to produce any incidental products, and thus, there is no information to report under Sub -section 6.4.4(h) of the Rules and Regulations. 6.9 Explosives The Rules and Regulations require a description of the use of explosives [Sub -Section 6.4.4(i)]. No explosives will be used in conjunction with the mining (or reclamation) on this site Loveland Ready -Mix, Concrete, Inc. 10 updated_exhibits_d. docx September 2021 TELESTQ Attachment 7 Updated Exhibit F-4 and F-5 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ 0 0 C Im r` 0 0 0 0im e, M C C C M 0 0 0 to - Co M T N N O N In M Y 0 a E E d ure5-4 Landsca Path: F:IDunn PitIMXDsIRECLAMATYJNIFi PINON PINE ROCKY MOUNTAIN JUNIPER 207 ROCKY MOUNTAIN JUNIPER PINON - JUNIPER GROUPING 7 M PINON PINE 3173000 1 MIN PIN -ON - JUMPER GROUPING 2 DECIDUOUS TREE 44, SHRUB 10' MIN DECIDUOU5 GROUPING I I I I PIRON PINE MIN 3173000 RocKY MOUNTAIN JUNIPER 5HRL'S UPLAND SHRUBS 3174000 I Fourwing Saltbrush 27 Plants 7.7€t average spacing RIPARIAN SHRUBS —77OFT WETLAND American Plum 72 Plants 2Ft average spacing Western Snowberry 47 Plants 0•6Ft average spacing Golden Currant 75 Plants 7.6ft average spacing Chokecherry 27 Plants 7.7T average spacing 3174000 -"tor7- Coyote Willow 72 Plants 3175000 I 3176000 I 3177000 I Street/Neighborhood POTENTIAL SPECIES FOR RECLAMATION Areas Natural Areas Scientific Name OVERSTORY DECIDUOUS TREES (STREET Common Name Scientific Name TREES) UPLAND TREES Common Name & SHRUBS Gym nodadus dotcus 'Espresso' Espresso Kentucky Cofeetree Cerasus pumila ssp. besseyi Bur Oak Chrysothamnus nauseosus Accolade (R) Elm Four -winged saltbush (STREET TREES) Krascheninnikovia (Ceratoides) lanata Toba Hawthorn Pentaphylloides floribunda Spring Snow Crabapple Prunus americana Ribes cereum Bigtooth Maple Symphoricarpos occidentalis Western Hackberry RIPARIAN TREES Sand cherry Quercus macrocarpa Rabbitbrush Ulmus Morton Atriplex canescens UNDERSTORY DECIDUOUS TREES Winterfat. Crategus x mordenensis "Toba" Shrubby cinquefoil Malus x 'Spring Snow' American Plum OVERSTORY DECIDUOUS TREES (BUFFERYARD) wax currant Acer grandidentatum snowberry Celtis occidentalis & SHRUBS Populus acuminata x sargentii Highland Cottenless Cottonwood Symphoricarpos occidentalis snowberry UNDERSTORY DECIDUOUS TREES (BUFFER YARD) Popul us deltoides var. monilifera plains cottonwood Amelanchierx grandiflora Autumn Brilliance Serviceberry Prunus virginiana var. melanocarpa chokecherry Prunus americana American Plum Rosa woodsii Ribes aureum Rocky Mountain Jumper Salix amygdaloides Pinon Pine Salix exigua Ponderosa Pine Salix ligulifolia YARD) WETLAND Western Sand Cherry Spartina pectinata Rocky Mountain Sumac Carex nebrascensis Gwen's Buffalo Currant Carex lanuginosa Juncus baiticus Wood's rose EVERGREEN TREES (BUFFERYARD) golden currant Juniperus scopulorum peachleaf willow Pinus edulis coyote willow Pinus ponderosa Strapleaf willow DECIDUOUS SHRUBS (BUFFER SOD Prunus besseyi Prairie cordgrass Rhus glabra cismotana Nebraska sedge Ribes aureum wooly sedge Baltic rush Western .5nawberry 41 Plants O.6Ft average spacing 3175000 WETL'A'ND ompson WETLAND: PONDEROSA PINE ROOKY MOUNTAIN JUNIPER EVERGREEN GROUPING 3176000 PINON y PINE SCALE IN FEET 3177000 LEGEND RIPARIAN SHRUBS GROUPING U PLAND SHRUBS GROUPING P INON - JUNIPER GROUPING DECIDUOUS GROUPING EVERGREEN GROUPING RECLAIMED POND P ROPERTY BOUNDARY S URFACE TOPOGRAPHY (5FT INTERVALS) FULL MATURE SIZE INITIAL PLANTING/NURSER Y Az- STOCK Planting Notes: 7• Stake plantings per nursery recommendation 2• Planting depth per nursery recommendation 3• Trees may be bare root or balled and burlapped ‘i• Over excavate planting hole 2x diameter of root ball 5• Preferred deciduous tree plantings: a• Sur Oak b• Acolade Elm c• Expresso Kentucky Coffee Tree d• Western l-lackberry 6• Size of nursery stock a Deciduous trees - 6' - 70' tall Ponderosa Pine - 3' - 5' tall c Pinyon Pine - 2' - 3' tall d Rocky Mountain Juniper - 2' - 5' tall e Shrubs - 3 to 5 gallon root ball NOTE(S) Coordinate System: NAD 1983 StatePlane Colorado North FIPS 0501 Feet EXHIBIT F-4 TREE/SHRUB LANDSCAPING PLAN DUNN PIT, LOVELAND READY MIX P.O. BOX 299, LOVELAND, CO, 80539 PREPARED BY: TELESTO LE STO soLuTIoNs.' N e o a e a e e r t u Loveland. Colorado {970}484.7704 www.leleso-rnc.Com PREPARED FOR: LOVELAND RE)IDT MIX CONCRETE C C C M C C O CO CO M T N 0 0 r N, Y 0 a x E c eL 2 a ure5-5 Landsca Path: F:IDunn PitIMXDsIRECLAMATKINIFi 3173000 I BANK RECLAMATION Thompson River I I I I 3173000 WETLAND 3174000 I 4tA'Y 4l -v'.v'_v 3175000 I UPLAND SEED MIX Cornlren Nagle SuIF: Lbs / A Western Viihentgrass .In CI'0fl Aictilll' ass 0.E000 Alkali Samalun ] coon Erie Grarna E•thileDi us i Squ.ri elluil 0.7500 2 2500 Canada Widrya 3.0000 Ward Saltgr s C.E000 0.000 0.000 WETLAND 3174000 BANK RECLAMATION BRID"GE 3175000 3176000 I 3177000 I WETLAND SEED MIX Kind °'o Mix Bulk Lbs pi A Alkali Bulrush 15.00 1.50 Canada Wildnre 15.00 1.50 Switchgrass 15.00 1.50 lndiangrass 12.00 1.20 Prairie Cordgrass 7.00 0.70 Soft Stem Bulrush 6.00 0.60 Three Square Bulrush 6.00 0.60 Hardstem Bulrush 6.00 0.60 Nebraska Sedge 6.00 0.60 Creeping Spikerush 6.00 0.60 Baltic Rush 4.00 0.40 Woolly Sedge 2.00 0.20 OUTLET 3176000 SCALE IN FEET 3177000 LEGEND RIPARIAN SHRUBS GROUPING UPLAND SHRUBS GROUPING PINON - JUNIPER GROUPING DECIDUOUS GROUPING EVERGREEN GROUPING WETLAND GRASSES RECLAIMED POND BANK RECLAMATION (UPLAND SEED MIX) SURFACE TOPOGRAPHY (5FT INTERVALS) 33826 , NOTE(S) Coordinate System: NAD 1983 StatePlane Colorado North FIPS 0501 Feet EXHIBIT F-5 SITE LANDSCAPING PLAN DUNN PIT, LOVELAND READY MIX P.O. BOX 299, LOVELAND, CO, 80539 PREPARED BY: TELESTO LE STO SOLUTIONS. 'N COa rase r t u Loveland. Colorado {970}484.7704 www. feleso-inc.Com Attachment 8 Updated Initial Water Quality Sampling Results 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® ,o.u„ON.. ,,, C c .. Q..: Sampling Dunn Pit: Location: MW -01 Sample Date 6/9/2021 6/9/2021 6/9/2021 6/9/2021 Loveland Ready -Mix Dunn Concrete, Inc. - Pit Sample Type Primary Primary Duplicate Duplicate Depth to Water: 6.38 ft Value Units Total Dissolved Total Dissolved Detection Limit Water Quality Standard * Analyte List ALUMINUM MG/L 4.1 ND 10 ND 0.1 5** ANTIMONY MG/L ND ND ND ND 0.001 _ 0.006 ARSENIC MG/L ND ND 0.0029 ND 0.002 0.01 BARIUM MG/L 0.068 0.028 0.14 0.035 0.005 2 BENZENE UG/L NS -- 0.001 5 **** NS -- 0.0005 0.004 BERYLLIUM MG/L ND ND ND ND BICARBONATE AS CaCO3 MG/L 270 -- 290 -- 20 0.34 0.34 0.15 0.75 ** BORON MG/L 0.38 0.3 CADMIUM MG/L ND ND ND ND 0.002 0.005 1 CALCIUM MG/L 160 160 170 170 CARBONATE AS CaCO3 MG/L ND -- ND -- 20 CHLORIDE MG/L 31 -- 33 -- 1 250 CHROMIUM MG/L ND ND 0.022 ND 0.01 0.1 COBALT MG/L ND ND 0.0056 ND 0.005 0.05 ** COPPER MG/L ND ND ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- NS -- 1 700 **** FLUORIDE MG/L 1.3 -- 1.4 -- 0.5 2 ** IRON MG/L 6.2 1.1 15 1.6 0.1 0.3 LEAD MG/L 0.0026 ND 0.006 ND 0.002 0.05 0.02 2.5 ** LITHIUM MG/L 0.029 0.023 0.043 0.027 TOTAL XYLENES UG/L NS -- NS -- 1 1,400-10,000**** MAGNESIUM MG/L 70 69 77 74 0.1 MANGANESE MG/L 0.38 0.34 0.43 0.33 0.01 0.05 MERCURY MG/L ND ND ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0039 0.0036 0.0052 0.0045 0.002 0.21 NICKEL MG/L ND ND ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L 0.35 -- 0.18 -- 0.02 10 PH PH 8.03 -- 7.97 -- 0.1 6.5-8.5 6.1 3 1 POTASSIUM MG/L 4.2 3.2 SELENIUM MG/L ND ND ND ND 0.01 0.02 ** SILVER MG/L ND ND ND ND 0.0005 0.05 SODIUM MG/L 87 89 96 96 1 SULFATE MG/L 540 -- 600 -- 20 250 THALLIUM MG/L ND ND 0.00016 ND 0.00015 0.002 TOLUENE UG/L NS -- NS -- 1 560-1000 **** 20 TOTAL ALKALINITY AS CaCO3 MG/L 270 -- 290 -- 1300 -- 40 1.25 x background vaule*** TOTAL DISSOLVED SOLIDS MG/L 1100 -- ND -- TOTAL PETROLEUM HYDROCARBONS MG/L ND -- 0.039 0.036 0.0001 0.0168 to 0.03 URANIUM MG/L 0.032 0.031 VANADIUM _ MG/L 0.0076 ND 0.02 ND 0.005 0.1 ** ZINC MG/L ND ND ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table NS 1 = Not and 3, Department 4, A, Table Department Department Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -02 Sample Date 8/5/2021 8/5/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 4.99 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 5.1 0.17 0.1 5** 0.001 ANTIMONY MG/L ND ND 0.006 ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L 0.12 0.059 0.005 2 BENZENE UG/L NS -- 0.001 5 **** MG/L ND ND 0.0005 0.004 BERYLLIUM BICARBONATE AS CaCO3 MG/L 410 -- 20 0.15 0.75 ** BORON MG/L 0.37 0.37 CADMIUM _ MG/L ND ND 0.002 0.005 CALCIUM MG/L 310 320 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 63 -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 1 700 **** 2 ** FLUORIDE MG/L 0.62 -- 0.5 IRON MG/L 6.5 0.23 0.1 0.3 LEAD MG/L 0.0024 ND 0.002 0.05 LITHIUM MG/L 0.06 0.053 0.02 2.5 ** TOTAL XYLENES UG/L NS --• 1 1,400-10,000**** MAGNESIUM MG/L 230 240 0.1 MANGANESE MG/L 0.56 0.41 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0039 0.0037 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L NS -- 0.02 10 PH PH 8.21 a 0.1 6.5-8.5 POTASSIUM MG/L 11 9.6 1 SELENIUM MG/L 0.019 0.021 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L 240 240 1 SULFATE MG/L 1900 a 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS a 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 410 -- 20 1.25 x background vaule*** TOTAL DISSOLVED SOLIDS MG/L 2800 -- 40 MG/L NS -- TOTAL PETROLEUM HYDROCARBONS URANIUM MG/L 0.045 0.044 0.0001 0.0168 to 0.03 VANADIUM MG/L 0.0093 ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 and 3, Department 4, A, Table Department Department 2, Department of Public of of Public Public of Health Health Health, ND Public = and Non Health and WQCC -Detect Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -03 Sample Date 8/5/2021 8/5/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 6.45 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 0.17 ND 0.1 5** 0.001 _ 0.006 ANTIMONY MG/L ND ND ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L 0.032 0.032 0.005 2 BENZENE UG/L NS _ -- 0.001 5 **** MG/L ND ND 0.0005 0.004 BERYLLIUM 20 BICARBONATE AS CaCO3 MG/L 410 -- BORON MG/L 0.43 0.44 0.15 0.75 ** 0.002 0.005 CADMIUM MG/L ND ND CALCIUM MG/L 370 370 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 70 -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 1 700 **** FLUORIDE MG/L ND -- 0.5 2 ** IRON MG/L 0.21 ND 0.1 0.3 LEAD MG/L ND ND 0.002 0.05 LITHIUM MG/L 0.053 0.054 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1 1,400-10,000**** MAGNESIUM MG/L 300 310 0.1 MANGANESE MG/L 0.91 0.91 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0033 0.0034 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L NS -- 0.02 10 PH PH 8.29 -- 0.1 6.5-8.5 POTASSIUM MG/L 6.4 6.5 1 SELENIUM MG/L 0.028 0.027 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM _ MG/L 330 340 1 SULFATE MG/L 2400 -- 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS -- 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 410 -- 20 TOTAL DISSOLVED SOLIDS MG/L 3800 -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L NS -- URANIUM MG/L 0.05 0.051 0.0001 0.0168 to 0.03 0.1 ** VANADIUM MG/L ND ND 0.005 ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 NS and 3, Department 4, A, = Not Table Department Department Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -04 Sample Date 8/5/2021 8/5/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 5.98 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 2.6 ND 0.1 5** ANTIMONY MG/L ND ND 0.001 0.006 ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L 0.05 0.03 0.005 2 0.001 5 **** BENZENE UG/L NS -- 0.0005 0.004 BERYLLIUM MG/L ND ND BICARBONATE AS CaCO3 MG/L 260 -- 20 BORON MG/L 0.25 0.24 0.15 0.75 ** CADMIUM MG/L ND ND 0.002 0.005 CALCIUM M G/L 140 140 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 30 -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 1 700 **** FLUORIDE MG/L 0.85 -- 0.5 2 ** 0.1 0.3 IRON MG/L 3.3 ND LEAD MG/L a0022 ND 0.002 0.05 LITHIUM M G/L 0.032 0.029 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1 1,400-10,000**** 0.1 MAGNESIUM MG/L 110 110 MANGANESE MG/L 0.05 0.021 0.01 0.05 MERCURY M G/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0025 0.0023 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L NS -- 0.02 10 PH PH 8.51 -- 0.1 6.5-8.5 POTASSIUM MG/L 5.5 4.6 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L N D ND 0.0005 0.05 1 SODIUM MG/L 110 110 SULFATE MG/L 780 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 260 TOTAL DISSOLVED SOLIDS MG/L 1400 -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L NS -- URANIUM MG/L 0.013 0.012 0.0001 0.0168 to 0.03 0.005 0.1 ** VANADIUM MG/L 0.0061 ND ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 and 3, Department 4, A, NS Table Department Department = Not Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -05 Sample Date 8/5/2021 8/5/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 5.76 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 5.4 ND 0.1 5** ANTIMONY MG/L ND ND 0.001 _ 0.006 ND ND 0.002 0.01 ARSENIC MG/L BARIUM MG/L 0.077 0.024 0.005 2 BENZENE UG/L ND -- 0.001 5 **** BERYLLIUM MG/L ND ND 0.0005 0.004 BICARBONATE AS CaCO3 MG/L 310 -- 20 BORON MG/L 0.32 0.32 0.15 0.75 ** ND ND 0.002 0.005 CADMIUM MG/L CALCIUM MG/L 200 190 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 44 -- 1 250 CHROMIUM MG/L 0.011 ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L ND -- 1 700 **** FLUORIDE MG/L 0.89 -- 0.5 2 ** 0.1 0.3 IRON MG/L 6.9 ND 0.003 ND 0.002 0.05 LEAD MG/L LITHIUM MG/L 0.033 0.026 _ 0.02 2.5 ** TOTAL XYLENES UG/L ND -- 1 1,400-10,000**** MAGNESIUM MG/L 160 160 0.1 MANGANESE MG/L 0.19 0.094 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0032 0.0031 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L NS -- 0.02 10 PH PH 8.43 -- 0.1 6.5-8.5 POTASSIUM MG/L 6.5 4.7 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L 180 180 1 SULFATE MG/L 1200 -- 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L ND -- 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 310 -- 20 TOTAL DISSOLVED SOLIDS MG/L 2000 -- 40 1.25 x background vaule*** NS -- TOTAL PETROLEUM HYDROCARBONS MG/L URANIUM MG/L 0.03 0.029 0.0001 0.0168 to 0.03 VANADIUM MG/L 0.011 ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 and 3, Department 4, A, NS Table Department Department = Not Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -06 Sample Date 6/8/2021 6/8/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 4.21 ft Value Units Dissolved Detection Limit Analyte List Total Water Quality Standard * ALUMINUM MG/L 1.5 ND 0.1 5** ANTIMONY MG/L ND ND 0.001 _ 0.006 ND ND 0.002 ARSENIC MG/L 0.01 BARIUM MG/L 0.04 0.026 0.005 2 NS -- 5 **** BENZENE UG/L BERYLLIUM MG/L ND ND 0.0005 0.004 BICARBONATE AS CaCO3 MG/L 230 -- 20 BORON MG/L 0.22 0.21 0.15 0.75 ** CADMIUM MG/L ND ND 0.002 _ 0.005 CALCIUM MG/L 84 84 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 57 -- 2 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 * COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 700 * * * * 2 ** FLUORIDE MG/L 0.86 -- 0.1 0.3 IRON MG/L 1.6 ND 0.1 ND ND 0.002 LEAD MG/L 0.05 LITHIUM MG/L 0.021 ND 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1,400-10,000**** MAGNESIUM MG/L 69 68 0.1 MANGANESE MG/L 0.58 0.55 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0042 0.0044 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L 2.2 -- 0.02 10 PH PH 8.22 -- 0.1 6.5-8.5 POTASSIUM MG/L 6.3 6 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L 82 82 1 SULFATE MG/L 360 -- 10 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS -- 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 230 -- 20 TOTAL DISSOLVED SOLIDS MG/L 800 -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L ND -- 5.2 URANIUM MG/L 0.017 0.016 0.0001 0.0168 to 0.03 VANADIUM MG/L ND ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 NS and 3, Department 4, A, = Not Table Department Department Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -07 Sample Date 6/8/2021 6/8/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 3.89 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 1.8 I ND 0.1 5** ANTIMONY MG/L ND ND 0.001 0.006 ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L 0.057 0.039 0.005 2 5 **** BENZENE UG/L NS -- 0.001 BERYLLIUM MG/L ND ND 0.0005 0.004 BICARBONATE AS CaCO3 MG/L 260 -- 20 0.15 0.75 ** BORON MG/L 0.24 0.24 CADMIUM MG/L ND ND 0.002 0.005 CALCIUM MG/L 96 98 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 53 -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** 1 ETHYLBENZENE UG/L NS -- 700 **** 2 ** FLUORIDE MG/L 0.96 -- 0.5 IRON MG/L 2 ND 0.1 03 0.002 0.05 LEAD MG/L ND ND LITHIUM MG/L ND ND 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1 1,400-10,000**** MAGNESIUM MG/L 79 80 0.1 MANGANESE MG/L 0.13 0.12 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0027 0.0026 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L 0.76 -- 0.02 10 PH PH 8.01 -- 0.1 6.5-8.5 POTASSIUM MG/L 11 10 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 1 SODIUM MG/L 100 100 250 SULFATE MG/L 480 -- 20 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS -- 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 260 -- 20 TOTAL DISSOLVED SOLIDS MG/L 1000 -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L ND -- URANIUM MG/L 0.038 0.039 0.0168 to 0.03 0.0001 VANADIUM MG/L ND ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 NS and 3, Department 4, A, = Table Department Department Not Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -08 Sample Date 6/8/2021 6/8/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 4.81 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 0.62 ND 0.1 5** ANTIMONY MG/L ND ND 0.001 0.006 0.002 0.01 ARSENIC MG/L ND ND 0.005 2 0.13 0.12 BARIUM MG/L BENZENE UG/L ND -- 0.001 5 **** BERYLLIUM MG/L ND ND 0.0005 0.004 BICARBONATE AS CaCO3 MG/L 170 -- 20 0.15 0.75 ** BORON MG/L ND ND CADMIUM MG/L ND ND 0.002 0.005 CALCIUM MG/L 61 62 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 34 -- 2 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L ND -- 0.001 700 **** 2 ** FLUORIDE MG/L 0.9 -- 0.1 IRON MG/L 0.63 ND 0.1 0.3 0.002 0.05 LEAD MG/L ND ND LITHIUM MG/L ND ND 0.02 2.5 ** TOTAL XYLENES UG/L ND -- 0.001 1,400-10,000**** MAGNESIUM MG/L 44 44 0.1 MANGANESE MG/L 0.035 0.031 0.01 0.05 0.0002 0.002 MERCURY MG/L ND ND MOLYBDENUM MG/L 0.0047 0.0045 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L ND -- 0.02 10 PH PH 8.24 -- 0.1 6.5-8.5 1 POTASSIUM MG/L 3.2 3.1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L 53 54 1 SULFATE MG/L 310 -- 10 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L ND -- 0.001 560-1000 **** 20 TOTAL ALKALINITY AS CaCO3 MG/L 170 -- TOTAL DISSOLVED SOLIDS MG/L 540 -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L ND -- 5.2 URANIUM MG/L 0.0086 0.0086 0.0001 0.0168 to 0.03 VANADIUM MG/L ND ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 NS and 3, Department 4, A, = Table Department Department Not Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: MW -09 Sample Date 6/8/2021 6/8/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Primary Primary Depth to Water: 3.45 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 4.3 ND 0.1 5** ANTIMONY MG/L ND ND 0.001 _ _ 0.006 ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L 0.06 0.022 0.005 2 BENZENE UG/L ND -- 0.001 5 **** 0.0005 0.004 BERYLLIUM MG/L ND ND BICARBONATE AS CaCO3 MG/L 280 -- 20 BORON MG/L 0.22 0.24 0.15 0.75 ** ND ND 0.002 0.005 CADMIUM MG/L CALCIUM MG/L 130 130 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 35 -- 2 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L ND -- 0.001 700 **** FLUORIDE MG/L 0.69 -- 0.1 2 ** 5.3 ND 0.1 0.3 IRON MG/L 0.002 0.05 LEAD MG/L 0.0021 ND LITHIUM MG/L 0.022 ND 0.02 2.5 ** TOTAL XYLENES UG/L ND -- 0.001 1,400-10,000**** MAGNESIUM MG/L 69 68 0.1 MANGANESE MG/L 0.44 0.39 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.004 0.0037 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L 3.3 -- 0.02 10 PH PH 8.15 -- 0.1 6.5-8.5 POTASSIUM MG/L 5.1 3.8 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 _ 0.05 SODIUM MG/L 78 78 1 SULFATE MG/L 450 -- 10 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L ND -- 0.001 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 280 -- 20 TOTAL DISSOLVED SOLIDS MG/L 970 -- 40 1.25 x background vaule*** 5.2 TOTAL PETROLEUM HYDROCARBONS MG/L ND -- 0.0001 0.0168 to 0.03 URANIUM MG/L 0.027 0.026 VANADIUM MG/L 0.0078 ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table NS 1 = Not and 3, Department 4, A, Table Department Department Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Location: Sample Date 8/5/2021 8/5/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Dunn Pit: MW Sample Type Primary Primary -10 Depth to Water: 7.67 ft Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L 3.8 ° 0.16 0.1 5** ANTIMONY MG/L ND ND 0.001 0.006 ARSENIC MG/L ND ND 0.002 _ 0.01 BARIUM MG/L 0.062 0.028 0.005 2 BENZENE UG/L NS -- 0.001 5 **** BERYLLIUM MG/L ND ND 0.0005 0.004 BICARBONATE AS CaCO3 MG/L 280 -- 20 BORON MG/L 0.27 0.26 0.15 0.75 ** CADMIUM MG/L ND ND 0.002 0.005 CALCIUM MG/L 140 140 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L 27 -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L _ ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 1 700 **** FLUORIDE MG/L 0.87 -- 0.5 2 ** 4.5 0.24 0.1 0.3 IRON MG/L LEAD MG/L 0.0024 ND 0.002 0.05 LITHIUM MG/L 0.036 0.031 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1 1,400-10,000**** MAGNESIUM MG/L 120 120 0.1 MANGANESE MG/L 0.3 0.24 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L 0.0024 0.0022 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L NS -- 0.02 10 PH PH 8.53 -- 0.1 6.5-8.5 POTASSIUM MG/L 5.9 4.8 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L 120 120 1 SULFATE MG/L 710 -- 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS -- 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L 280 -- 20 1.25 x background vaule*** TOTAL DISSOLVED SOLIDS MG/L 1300 -- 40 TOTAL PETROLEUM HYDROCARBONS MG/L NS -- URANIUM MG/L 0.015 0.014 0.0001 0.0168 to 0.03 VANADIUM MG/L 0.0082 ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 NS and 3, Department 4, A, = Not Table Department Department Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted Sampling Dunn Pit: Location: 03 -Blank Sample Date 6/9/2021 6/9/2021 Loveland Ready -Mix Concrete, Inc. - Dunn Pit Sample Type Field Blank Field Blank Analyte List Value Units Total Dissolved Detection Limit Water Quality Standard * ALUMINUM MG/L ND ND 0.1 5** ANTIMONY MG/L ND ND 0.001 _ _ 0.006 ARSENIC MG/L ND ND 0.002 0.01 BARIUM MG/L ND ND 0.005 2 BENZENE UG/L NS -- 0.001 5 **** BERYLLIUM MG/L ND ND 0.0005 0.004 20 BICARBONATE AS CaCO3 MG/L ND -- BORON MG/L ND ND 0.15 0.75 ** CADMIUM MG/L ND ND 0.002 0.005 CALCIUM MG/L ND ND 1 CARBONATE AS CaCO3 MG/L ND -- 20 CHLORIDE MG/L ND -- 1 250 CHROMIUM MG/L ND ND 0.01 0.1 COBALT MG/L ND ND 0.005 0.05 ** COPPER MG/L ND ND 0.02 0.2 ** ETHYLBENZENE UG/L NS -- 1 700 * ** 2 ** FLUORIDE MG/L ND -- 0.5 IRON MG/L ND ND 0.1 0.3 LEAD MG/L ND ND 0.002 0,0.5 LITHIUM MG/L ND ND 0.02 2.5 ** TOTAL XYLENES UG/L NS -- 1 1,400-10,000**** MAGNESIUM MG/L ND ND 0.1 MANGANESE MG/L ND ND 0.01 0.05 MERCURY MG/L ND ND 0.0002 0.002 MOLYBDENUM MG/L ND ND 0.002 0.21 NICKEL MG/L ND ND 0.02 0.1 NITRATE/NITRITE AS N MG/L ND -- 0.02 10 PH PH 8.65 -- 0.1 6.5-8.5 POTASSIUM MG/L ND ND 1 SELENIUM MG/L ND ND 0.01 0.02 ** SILVER MG/L ND ND 0.0005 0.05 SODIUM MG/L ND ND 1 SULFATE MG/L ND -- 20 250 THALLIUM MG/L ND ND 0.00015 0.002 TOLUENE UG/L NS -- 1 560-1000 **** TOTAL ALKALINITY AS CaCO3 MG/L ND -- 20 TOTAL DISSOLVED SOLIDS MG/L ND -- 40 1.25 x background vaule*** TOTAL PETROLEUM HYDROCARBONS MG/L ND -- URANIUM MG/L ND ND 0.0001 0.0168 to 0.03 VANADIUM MG/L ND ND 0.005 0.1 ** ZINC MG/L ND ND 0.1 2 ** ND = Non -Detect * Water Quality ** Water Quality *** Water Quality **** Water Quality Standards Standards Standards Standards are from are are are from from from Table Table Table Table 1 and 3, Department 4, A, NS = Table Department Department Not Measured 2, Department of Public of of Public Public of Health Health Health, Public and Health and WQCC Environment, Environment, and Regulation Environment, WQCC WQCC Regulation WQCC Regulation No. 41 Regulation No. 41 No. No. 41 unless 41 otherwise noted GROUND WATER SAMPLING DATA SHEET IDENTIFICATION Sample Location -vo • l Sample Control Number WEATHER CONDITIONS Ambient Air Temperature: Project Number: Date Start Time = cif Stop tim) Page I of ( Samplers 7? °CD 'FOP Not Measured 0 Wind: Heav 0 Moderate) Light Precipitation: NonelRainD SnowEl Heavy) Moderate) Light) SunnyE Partly CloudyD INITIAL WELL MEASUREMENTS (Measurements in feet made from top of well casing) Static _ • e &fry Total Depth `' Top of Screen - Filter Pack Interval4- 57 Borehole Diameter(inches) 4 4 -inch — 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: gallons 1 Casing ID W11 sing OD Protective Casing Stickup Well Casing Stickup Feet of Water SLf7aJ i) Por) FINAL 'WELL MEASUREMENTS Static Water Level Total Depth Total Volume Purged; Saturated Borehole Volume (gal) Max Pumping Rate INSTRUMENT CALIBRATION 1 `r _ _j I H Meter: Meter Number - 't t "(...&-A`1")'', ,pl�'Ie er t;Conductivity Meter: Meter Number Buffer Measured Value Temp. `'C Standard mS/cm Measured Value mS/cm Temp. °C' Buffer Measured Value Temp. L'IL, Standard mS/cm Measured Value mS/cm Temp, ° Turbidity Meter: Standard I\TU Measured Value NTT,,) Standard NTU Measured Value NYU FIELD PARAMETER MEASUREMENTS DURING PURGING Well purged with: 7 Time Volume (gallons) pH (µSicm) Cond. i Temp. Comments Turbidity Visual Est.D QC D °F S Measured❑ FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge pH (p.S/cm) Cond. Temp. CDC) Est. Turbidity Visual D Measu to" ,, i cfs n1 gp a reds 1/1l b( liVV!! 'Mb i 0 3 7 ul r 1 --?-2 - 7 deer-- IoOa tee u l - Duplicate Sample -02 (sample control number/time ) Field Blank -03 (sample control number/time ) Rinsate Sample -04 (sample control number/time ) Matrix Spike -MS (sample control number/time ) (sample control n tmber/time ) Pal Cleotad VI I AcoocX I titAitti- Notes: tie Sampler's Signature /11 GROUND WATER SAMPLING DATA SHEET IDENTIFICATION nPr ject Number: Sample LocationDunnr Date , 8 1 Start Timer ':. )) Stop time Pag of of Samplers Sample Control. Number . - WEATHER CONDITIONS Ambient Air Temperature: O' 'CO "ItNot Measured O Wind: HeavyEI Moderate❑ Li xhtC Precipitation: None❑ Rain❑ Snow❑ Heavy❑ ModerateD Light© Sunny Partly Cloudy❑ INITIAL WELL MEASUREMENTS (Measurements in 'apt made from top of well easing) . / �r Static Water Level r Total Depth.? O Top of Screen Filter Pack Interval ' ' 3 0 Borehole Diarneter(inehes) 4 -inch = 0.1632 ga M 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: gallons asing ID ell Ca ing OD Protective Casing Stickup Well Casing Stickup Feet of Water Well purged with:i4a'F/occ) , pub FINAL WELL MEASUREMENTS Static Water Level?►Total Depth Total Volume Purged Saturated Borehole Volume (gal) Max Pumping Rate INSTRUMENT CALIBRATION pH Meter: Meter Number Conductivity Meter: Meter Number Buffer Measured Value Temp. °C Standard 111S/cm Measured Value mS/cm Temp. °C Buffer Measured Value Temp. °C Standard _ rnS/cm Measured Value mS/cm Temp. °C Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value FIELD PARAMETER MEASUREMENTS DURING PURGING NTU Time Volume (gallons) pH 0iS/cm) Cond. Temp. Turbidity Comments Visual Est.❑ °C. °F N Measured❑ FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge pH (O/cm) Cond. Temp. CC) Turbidity Visual cf s MI gprc Est. ❑ Measu red U :, (a 633T , 221 1(Ahl Duplicate Sample -02 Field Blank -03 Rinsate Sample -04 Matrix Spike -MS Notes: (sample control number/time (sample control number/time .) (sample control number/time ) (sample control number/time ) (sample control number/time "e\) Peuv cte,,,;) curl -<-3,}Lott,) _40i) 77; } Yul tie bc(p) c'. Sampler's Signature Samplers. Well purged Feet af' fate- _ p12.4eal FINAL WELL MEASUREMENTS Static Water Level . 1 Total Depth. Total Volume Purged Saturated Borehole Volume (gal) Max. Pumping Rate INSTRUMENT CALIBRATION pH Meter: Meter Number Buffer -_ Measured Value Temp. aC Standard mS/cm Measured Value mS/cm Temp. °C Buffer Measured Value Temp. °C Standard mS/cm Measured Value mSicm Temp.. °C NTU Standard NTU Measured Value I TU GROUND WATER SAMPLING DATA SHEET IDENTIFICATION { 1' jest Number• in i Sample Location f ! , Date 4 / A Start Timed ice) Stop time ° , i' Pate of 1 p' Sample Control Number t� 17 WEATHER CONDITIONS Ambient Air Temperature:CO °C❑ °F' Not Measured ❑ wind: Heavy❑ Moderate❑ Li h Precipitation: : None❑ Rain❑ Snow❑ Fleavy❑ ModerateD Light❑ Sunny% Partly Cloudy❑ INITIAL WELL MEA UREMENTS (Measurements in feet made from top of well casing) 4 Static Water Level Total Depth f Top of Screen Filter Pack Interval 4-, - d Borehole Diameter inches) / / -the z = 0. -. :a 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: gallons e Casing I: III-0?Well C sing +DD P atective Casing Stickup Well Casing Stickup with. �� Conductivity Meter: Meter Number _ Turbidi0 Meter: Standard NTU Measured Value FIELD PARAMETER MEASUREMENTS DURING PURGING Time Volume (gallons) PH (BLS/cm) Cond. Temp. Turbidity Visual Est.❑ Comments 'C■ °F❑ Measured❑ , FINAL SAMPLE PARAMETERS Sample Sample Discharge pH Cond. iS/em) Temp. Turbidity Visual (°C) Date Time cfs R' gpmr Est. ❑ Measu red❑ 69/bill\ 3 r I ) #}7,93 t-qiel r----, s i arecr Duplicate Sample -02 (sample control number/time ) Field Blank -03 (sample control numberltime ) Rinsate Sample -04 (sample control number/time ) Matrix Spike -MS (sample control number/time _ ) a Notes: 11) .��, fill) (sample control nuni bedtime C AkoAO i5ii-&viti) co J.55 Quilt\ Sampler's Signature IDENTIFICATION" 4 Project N tuber: 6y 11 J • . � r Start Time � Stop tim 3 Pane f Sample Control Number smote, Samplers`& WEATHER CONDITION Ambient Air Temperature: O r 'CO olA6 Not Measured ❑ Wind: Heavy0 Moderate❑ Ligh Precipitation: None❑ Rain❑ Snow❑ Heavy❑ ModerateD Light❑ SunSunperf Partly Cloudy❑ INITIAL WELL MEASUREMENTS (Measurements in Net made from top of well casing Total Depth 30 Top of Screen - - Filter Pack Intervale& 3o Borehole Diameter(inches) 2 -inch = 0.1632 gaUf 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: gallons Vatg 1. _ -cc Well C , 'ng OD Protective Casing Stickup Well Casing Stickup Feet of Water Well purged with: G a i , POI? FINAL WELL ME UREMENTS Static. Water Levellfrotal Depth Total Volume Purged! Saturated Borehole Volume (gal) INSTRUMENT CALIBRATION pH Meter: Meter Number Buffer� Measured Value Temp. °C Standard mS/cm Measured Value mS/cm Temp. °C Bufter Measured Value Temp. °C Standard GROUND WATER SAMPLING DATA SHEET �_Sample Location Punk Pei— Date , of Max Pumping Rate Conductivity Meter: Meter Number Y�y mS/cm Measured Value mS/cm Temp. °C" Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value TTU FIELD PA►I'TERMEASUREMENTS DURING PURGING Time Volume PH (l.iS/cm) Cond. Temp. Turbidity Comments (gallons) Visual Est.❑ °C❑ °F❑ Measured❑ A FINAL SAMPLE PARAMETERS Sample Sample Time Discharge pi<I Temp. CC) Turbidity Visual — OAS/cm) Cond. Date cfs❑' gpmit Est. ❑ Measu red ❑ 6/g/a\ ;I` 6 cPersi i i/i ((- 1--- 7 -73er 6020 dice I tip Duplicate Sample -02 Field Blank -03 Rinsate Sample -04 Matrix Spike -MS (sample control number/time (sample control number/time y (samplecontrol number/time (sample control number/time (sample control number/time f. Notes: ractiir A Conn V \) 541(q\lCa 1:56 VI) 5aro f s t (A, Stc-0 Sampler's Signature w GROUND WATER SAMPLING DATA SHEET IDENTIFICATION , n n Sample Location Lair e V f) Date i 0_RP( Startetime/6 Sample Control Number ail leVrie O C { WEATHER CONDITIONS Ambient Air Temperature: Samplers 11,2 ore '.r kc'\ . °CO WO Not Measured 0 Wind: Heavy❑ Precipitation: None I Raini Snowfl Heavy❑ ModerateD Light❑ Surma Partly Cloudy0 INITIAL WELL MEASUREMENTS (Measurements in feet made from top of well casing) Static Water Level '; f ZSTotal DepthOci Top of Screen q Filter Pack Interval 9�;- 'T Bor 4 -inch = 0.6528 gal/ft 6 -inch. 1.4688 gal/ft Casing Volume: asing 1D Well Ca i g CAD Protective Casing Stickup Well Casing Stickup Well purged with: Pr ject Number: a Stop time Page of Moderated Ligg6 berr pole Diameter(inches) tz' (4,N) ,iOk) FINAL WE L L MEASUREMENTS Static Water Levelk7c Total Depth Total Volume Purged INSTRUMENT CALIBRATION pH Meter: Meter Number gallons Feet of Water Saturated Borehole Volume (gal) Max Pumping Rate Conductivity Meter: Meter Number Buffer Measured Value Temp. °C Standard mS/cm Measured Value mSicm Temp. °C Buffer Measured Value Temp. °C Standard mS/cm Measured Value rnS/cm Temp. °C Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Turbidity Comments Time ' Volume pH Cond. Temp. (gallons) (t.iS/cm) Visual Est. °C❑ °FD Measured N FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge PH (jiSr'cm) Cond, Temp, (°C) Turbidity Est. Visual E Measu elsE n1,1 ' red❑lag') ( 16 :LI (1 /}j ((::,',1; 717--) /086, 073, ocr c/e,_ r -- le d Blank -03 Rinsate Sample -04 Matrix Spike -MS Notes: or- ,Ikk u (tl Sampler's Signature sample control number/time (sample control number/time ) (sample control number/time ) (sample control number/time ) de49 (sample control number/0ime VUM, cierate) tthi kadred'. .13 /6:i/3 t Loy/ ;a ) kii-776( er Sample Control Number Samplers WEATHER CONDITIONS Ambient Air Temperature: 'CO °Ft Not Measured 0 Wind: Heavy❑ Moderate❑ Light Precipitation: None❑ Rain❑ Snow❑ Heavyr] Moderate❑ Light❑ Sunnyjiii Partly Cloudy❑ INITIAL WELL MEASUREMENTS (Measurements in feet made from to of well casin 'M Static Water Level ` Total Depth Top of Screen , Filter Pack Interval Borehole Diameter(inches) 2 -inch = 0.1632 gal/ft 4 -inch = 0.6528 gallft 6 -inch 1.4688 gal/fl Casing Volume: Well Casing ID ' c11 Casin ODProtective Cas � g S ickup Well Casing Stir) FINAL WELL MEASUREMENTS q5-4541 fl }'7 . ,\ Static Water Level Total Depth Total Volume Purged._ a p Saturated Borehole Volume (gall, INSTRUMENT CALIBRATION CA it tipH I I�et�er: I 'Teter Numberon Luc wily Meter: Meter Number — Bufer Measured Valu€_ Temp, °C Standard mS/can Measured Value _ Buffer Measured Value Temp,. °C Standard mS/cm Measured Value _ GROUND WATER SAMPLING DATA SHEET IDENTIFICATION. Sample Location.. Date l Project N nber: Start Time I• Stop time F �. ague f Well purged with: &'oScA,Ds �'�r s Shi+ �j ��,: �'�" �,�,� _ L'ilU A T [I/Yi T i _ tom._ a __ .n. �H e. gallons Feet of Water I;ia Max Pumping Rate nS/cm Temp. °C mS/cm Temp, °C Turbidity Meter: Standard NTU Measured Value.. NTU Standard , NTH Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Time Volume (gallons) pH Cond. (µSicm) Temp. °❑ °F❑ i Turbidity Visual Est. ❑ Measured 0 Comments FINAL AMPLE PARAMETERS I Sample Date E Sample Time Discharge pH Grill, Cond. (lsS/ern) Temp. (°) Turbidity Visual Est. ❑ ed❑ Measu cfs ❑ gpr911. 5 5 ICI t31 ) Ri (t9 1 Jo ars vitkr4 vow, Duplicate Sample -02 Field Blank -03 Rinsate Sample -04 Matrix Spike -MS Notes: .ti Mei) taLS (sample control number/time (sample control number/time, ) (sample control number/time (sample control number/time (sample control number/t'reL_. alecapa Calle Sampler's Signature Well Casing ID__ W;11 Casing OD Well purged with: &rep 506 FINAL WELL MEASUREMENTS Static Water L.evefU otal Depth INSTRUMENT CA IB1 .ATION pH Meter: Meter Number Buffer Measured Value Temp.°C Buffer Measured Value Temp. °C IDENTIFICATION za Sample Location ,' 63 Sample Control Number WEATHER CONDITIONS Ambient Air Temperature: GROUND WATER SAMPLING DATA SHEET Date e I Start Ta Samplers 2 Project N tuber: Stop time Page ge of 83 c ❑ OF & Not Measured Q Wind: Heavy0 ModerateD Ligh Precipitation: None❑ Rain❑ Snow❑ Hea ►1' Moderate© Light❑ Sunny Partly Cloudy❑ INITIAL WELL MEASUREMENTS easurements in feet made from top of well casing. Static Water LevelUS Total Depth Top of Screen ` f c Filter Pack Interval, , Borehole Diameter(inches) 2 -inch = 0.1632 gal/ 4 -inch = 0.6528 gal/ft 6 -inch =1.4688 galift Casing Volume: gallons Pr€ i ective Casing Stickup Well Casing Stickup Feet of Water r J!f(oIOO?Afr- 51,fritsi Total Volume Purged codepc Saturated Borehole Volume (gal) Max Pumping Rate ctivity Meter: Meter Number Standard mS/cm Measured Value mS/cm Temp, Standard mS/cm Measured Value mS/cm Temp. °C CC Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETEMEASUREMENTS DURING PURGING -_-Temp. I Time Volume (gallons) pH Conde (p,S/crn) Turbidity Comments °C❑ °F❑ Visual Est,❑ Measured ❑ FINAL SAMPLE PARAMETERS Sample Sample Discharge p1 -I Cond, Temp. Turbidity Date Time cfs❑ gpm I 4µS/cmm CC) Visual Est, VIZ1/41/4 Measu �redbnii r�'� ❑ 3 r fidi der‘4.- I Duplicate Sample -02 Field Blank -03 Rinsate Sample -04 Matrix Spike -MS Notes: (sample control number/time (sample control number/time__ (sample control number/time_ (sample control number/time (sample control number/time SQ ti e etertrA. Sampler's Signature GROUND WATER SAMPLING DATA SHEET IDENTIFICATION LA Sample Location w O I Sample Control Number . _... WEATHER CONDITIONS , Ambient Air Temperature: �' ' ❑ °F . Not Measured ❑ Wind: Heavy0 Moderate❑ Li htl - Precipitation: None❑ Rain❑ Snow❑ Heavy❑ Moderate❑ Light.❑ Sunnal Partly Cloudy❑ INITIAL WELL MEASUREMENTS (Measurements in feet made from top of well casin. Static Water Levelci a Total Depth Top of Screen Filter Pack Interval -. Borehole Diarneter(inches) 2 -inch = 0.1632 gal/ft 4 -inch = 0.6528 gal/ft 6 -inch = 14688 gal/ft Casing Volume; gallons Well Casing ID Well Ca.sinDD Protective Casing Stickup Well Casing Stickup Feet of Water Well purged with: r•�ir ,I> "'. ,� Project Number: Date9 I Start Time Stop time Pa of Samplers FINAL WELL MEASUREMENTS Static Water Lev Total Depth Total Volume Purged Saturated Borehole Volume (gal) Max Pumping Rate atipzs1/40 pH Meter: Meter Number _ INSTRUMENT CALIBRATION Conductivity Meter: Meter Number. Buffer Measured Value Temp. _ _ °C Standard mS/cm Measured Value mS/cm Temp. °C Buffer Measured Value Temp. °C Standard. mS/cm Measured Value mS/cm Temp. ° Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Time Volume (gallons) pH Cond. (j.tS/cm) Temp. °CO °F❑ Turbidity I Visual Est, ❑ Measured 0 Comments FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge cfs a gpm r i pH Cond. (PS/cm) Temp. (°) Turbidity Visual .Est,.. Measu zed ❑ /s2Si1 esi)( 5 0 [jj�u ' I C tee-est Duplicate Sample -02 Field Blank -03 Rinsate Sample -04 Matrix Spike -MS Notes: Sampler's Signature (sample control number/time ) (sample control number/time _ (sample control number/time (sample control number/time (sample control number/time Etta �( Saslifies cre((u �?44-v7 ) ) ) it 7 �Yt ) ori no IS GROUND WATER SAMPLING DATA SHEET IDENTIFICATION AAA � Pr3ject Number: Sam le Location/I\IAJa.sI ateILL5 rStart T i e � Stop time � Page of g Sample Control Number Samplers . WEATHER CONDITIONS , •- Ambient Air Temperature: °CD °F$ Not Measured 0 Wind: HeavyD ModerateID Light Precipitation: Noxell RainD Sno Il HeavyD Moderate❑ LightD Sunny ..Partly CloudyD INITIAL WELL XfEASUREMENTS (Measurements in feet made from tgp cif well easing) Static Water Leveria Total Depth Top of Screen Filter Pack Interval Borehole Diameter(inches) 2 -inch = 0.1632 ,gal/tt 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: -- gallons Well Casing ID Well Casing OD Protective Casing Stickup Well Casing Stickup Feet of Water Well purged with: a. FINALWELLi�'IE.ASLREl'�'IE S Static Water Level Total Depth Total Volume Purged Saturated Borehole Volume (gal) Max Pumping Rate INSTRUMENT CALIBRATION QeStel\, H Meter; Meter Number ` Con u tivit Meter: Meter t il)R F� �Number Buffer Measured Value. Temp. °C Standard mS/cm Measured Value mS/cm Temp. °C Buffer Measured Value Temp,_ °C Standard inS/cm Measured Value, mS/cm Temp. °C Turbidity Meter: Standard NT(J Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Time Volume (gallons) pH Cond. Temp. (,AS/can) ; 'CO TO Turbidity Visual Est. D Measured D Comments FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge cfsb gprn pH Cond, (µS/cm) __ Temp. (°C) , Turbidity Visual Est.n Measu - red ❑ tair6/).\3/4 it, t r. Ng\ :� Duplicate Sample -02 (sample control number/time ) Field Blank -03 (sample control number/time ) Rinsate Sample -04 (sample control number/time ) Matrix Spike -MS (sample control number/time ) (sample control number/time Notes: — till Cligu,x.a CV) �� c�k�. r - r. Theirfit) c411k Sampler's Signature GROUND WATER. SAMPLING DATA SHEET IDENTIFICATION AA it Sample Location r Sample Control Number WEATHER CONDITIONS Ambient Air Temperature: j I °C❑ TO Not Measured ElWind: Heavy❑ ModerateD Lightiii Precipitation: None❑ Rain❑ Snowy Heavy❑ Moderate❑ Light❑ Sunny` Partly Cloudy❑ INITIAL WELL MEASUREMENTS (Measurements in feet made from tops of well casing} Static Water Levelll P, Total Depth Top of Screen Filter Pack Interval Borehole Diameter(inches) 2 -inch = 0.1632 gal/ft 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gallft Casing Volume: gallons Well Casing ID Well Casing OD Protectiv Casing Stickup Well Casi g Sti kup Feet of Water purged Well with: yr S/51:7, .. , Date Pr jest Number: Start Time /: 0 Stop time { Pageof FINAL WELL MEA UREMENTS Static Water Level Total Depth Total Volume Purgel Saturated Borehole Volume (gal) Max Pumping Rate INSTRUMENT CALIBRATION �-, . 43 pH Meter: Meter Number Conductivity Meter: Meter Number Buffer Measured Value Temp. °C Standard mS/cm Measured Value YnS/cm Temp. 'C Buffer Measured Value Temp. °C Standard mS/cn1 Measured Value mS/cm Temp. °C Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Samplers Time Volume (gallons) pH Cond. (,µ/cm) Temp. Turbidity *CO TO Visual Est. ❑ Measured ❑ Comments FINAL SAMPLE PARAMETERS Sample Date Sample Time Discharge pH Cond, QiS/cmm Temp. (°C) I Turbidity Visual Est. 0 Measu red ❑ cfs❑ gprl ,,. VI: 07.,isra).0 blic Saketak Duplicate Sample -02 (sample control number/time Field Biank-O3 (sample control number/time ) Rinsate Sample -04 (sample control number, time ) Matrix Spike -MS (sample control number/time (sample control number/time Notes: Pow deco kV ()/istil uc w �l boi4k col(.e�± Sampler's Signature odese- fis- 41.kr } ko o A Attachment 9 Updated Table 2 - Water Quality Sampling Matrix 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® ,o.u„ON.. ,,, C c .. Q..: DUNN PIT - LOVELAND READY -MIX CONCRETE, INC. WATER QUALITY SAMPLING MATRIX LABORATORY TESTS QA/QC REQUIREMENTS ANALYTE FIELD METHOD ANALYTICAL METHOD SAMPLE CONTAINERS PRESERVATIVES STANDARD* METHOD DETECTION LIMIT RINSATE FIELD BLANKS DUPLICATE Aluminum 0.45 µm filter in field EPA 200.7 or SW -846 6000 lx 250 mL poly HNO3 to pH <2 Cool to 4° C 5 mg/I ** 0.0350 mg/I One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Antimony EPA 200.8 0.006mg/I 0.0075 mg/I Arsenic EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW 6020, 6020A 0.01 mg/I 0.0065 mg/I Barium EPA 200.7/200.8 or SW -846 6010 or SW -846 6020 2 mg/I 0.0017 mg/I Beryllium EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A I 0.004 mg/I 0.0007 mg/I Boron 0.45 µm filter in field EPA 200.7 or SW -846 6010 HNO3 to pH <2 Cool to 4° C 0.75 mg.l ** 0.0126 mg/I Cadmium EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.005 mg/I 0.0007 mg/I Chromium 0.45 p.m filter in field EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW 846 6020, 6020A or SW -846 7196A or SW -846 7199 HNO3 to pH <2 Cool to 4° C , 0.10 mg/I 0.0014 mg/I Chloride Unfiltered . EPA 300.0 250 mg/I * 1 mg/I Cobalt 0.45 µm filter in field EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 0.05 mg/I ** 0.0023 mg/I Copper EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 I 0.20 mg/I ** 0.0053 mg/I Cyanide [Free] Unfiltered SW -846 9012B lx 250 -mil Amber -Poly NaOH 0.2 mg/I 0.01 mg/I Fluoride Unfiltered EPA 300.0 or SW -846 9056 or SM 4500 F -C 2x 250-mL poly Cool to 4° C 2 mg/I** 0.0099 mg/I Iron 0.45 µm filter in field EPA 200.7/200.8 or SW -846 6010 or SW -846 6020 lx 250-mL poly HNO3 to pH <2 Cool to 4° C 0.3 mg/I * 0.0141 mg/I Lead EPA 200.8 or SW -846 6010B, 6010C or SW -846 6020, 6020A 0.05 mg/I 0.0019 mg/I Lithium EPA 200.7 or SW -846 6010 2.50 mg/I ** 0.0053 mg/I Manganese EPA 200.7 or SW -846 6010 0.05 mg/I ** 0.0012 mg/I Mercury (inorganic) EPA 245.1 or SW -846 7470A 0.002 mg/I 0.000049 mg/I Molybdenum SW 846 6010B, 6010C or SW 846 6020, 6020A 0.21 mg/I 0.0016 mg/I Nickel EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.10 mg/I 0.0049 mg/I Nitrate Unfiltered EPA 300.0 or EPA 300.1 or SM 4110 B or SW -846 9056 Cool to 4° C 10.0 mg/I as N 0.0227 mg/I Nitrite EPA 300.0 or EPA 300.1 or SM 4110 B or SW -846 9056 1.0 mg/I as N 0.0277 mg/I Total Nitrate and Nitrate as N EPA 353.2 H2SO4 to pH <2 Cool to 4° C 10 mg/I as N 0.05 mg/I pH EP 150.1 or SM 4500-H B or SW-846 9045C Cool to 4° C 6.5 - 8.5 ** --- Selenium 0.45 µm filter in field EPA 200.7/200.8 or SW 846 6010 or SW -846 6020 HNO3 to pH <2 Cool to 4° C 0.02 mg/I ** 0.0074 mg/I Silver EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.05 mg/I 0.0028 mg/I Sulfate Unfiltered EPA 300.0 Cool to 4 250 mg/I* 5 mg/I Thallium 0.45 p.m filter in field EPA 200.8 or SW 846 60106, 6010C or SW -846 6020, 6020A HNO3 to pH <2 Cool to 4° C 0.002 mg/I 0.0065 mg/I Uranium 0.45 µm filter in field EPA 200.8 or SW -846 60106, 6010C or SW -846 6020, 6020A or D5174 HNO3 to pH <2 Cool to 4° C 0.0168 to 0.03 mg/I 1 mg/I Vanadium EPA 200.7 or SW -846 6010 0.10 mg/I ** 0.0024 mg/I Zinc EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 2 mg/I ** 0.0059 mg/I TOTAL DISSOLVED SOLIDS (TDS) QA/QC REQUIREMENTS ANALYTE FIELD METHOD ANALYTICAL METHOD SAMPLE CONTAINERS PRESERVATIVES STANDARD METHOD DETECTION LIMIT RINSATE FIELD BLANKS DUPLICATE Total Dissolved Solids Unfiltered EPA 160.1 or SM 2540 C lx 500-mL poly Cool to 4° C See below *** See below One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event BACKGROUND TDS VALUE (mg/I) MAXIMUM ALLOWABLE TDS CONCENTRATIONS 0-500 mg/I 400 mg/I or 1.25 times the background level, whichever is least restrictive 501-10,000 mg/I 1.25 times the background value 10,001 mg/I or greater No limit FIELD PARAMETERS QA QC REQUIREMENTS TEST MEASUREMENT METHOD METHOD DESCRIPTION RINSATE FIELD BLANKS DUPLICATE pH Meter/flow-through cell Glass sensing and Ag/AgCl reference electrodes One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Temperature Combination pH Electrode with Temperature (Gel -filled) Glass sensing and reference solution calibration One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Conductivity Combination pH Electrode with Temperature (Gel -filled) Glass sensing and reference solution calibration One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event All groundwater samples must be collected and analyzed according to the summary of analytical methods, holding times, sample containers, preservatives, and reporting limits included on WQCC Tables, or equivalent, upon approval by the Supervisor. Unless otherwise noted, standards are from Table 1 of Colorado Department of Public Health and Environment, WQCC Regulation No. 41 * Table 2 - WQCC Regulation No. 41 ** Table 3 - WQCC Regulation No. 41 *** Table 4- WQCC Regulation No. 41 Attachment 10 Revision 2 of Appendix D - Sampling and Analysis Plan 20220314 DRMS Adequacy Review Response MASTER. docx TELEST® ,o.u„ON.. ,,, C c .. Q..: Ground Water Sampling and Analysis Plan Loveland Ready Mix Concrete, Inc. Dunn Pit Prepared for Loveland Ready Mix Concrete, Inc. P.O. Box 299 Loveland, Colorado 80539 Prepared by Telesto Solutions Inc. 750 14t" Street SW Loveland, Colorado 80537 March 2022 TELEST S O L U T I O N S• I N C O R P .O R A T E D Signature Page Ground Water Sampling and Analysis Plan Rev 2 March 2022 ELESTO S O L U T I O N S• I N C O R P O R A T £ D Report Authors and Contributors Telesto Solutions, Inc. u Timothy Gerken — Primary Author Walter L. Niccoli, P.E. — Report Review Loveland Ready -Mix, Inc. i app d_20?200318_up dated_Irm_dunn_g _sap_rev2_final Telesto Solutions, Inc. March 2022 — Rev 2 Table of Contents 1.0 INTRODUCTION 1 2.0 OBJECTIVE 1 3.0 STANDARD OPERATING PROCEDURES 1 4.0 DECONTAMINATION PROCEDURES 2 5.0 GROUND MONITORING 2 5 1 Water Level Monitoring 2 5 2 Water Quality Monitoring 3 6.0 SAMPLE DOCUMENTATION, HANDLING, PACKAGING, AND CHAIN OF CUSTODY 3 7.0 FIELD QUALITY ASSURANCE AND QUALITY CONTROL PROCEDURES 4 7.1 Field Parameter Instrument Calibration and Measurement 4 7.2 Field Quality Assurance/Quality Control Samples 4 7.2.1 Duplicate Samples 4 7.2.2 Field Blanks 5 7.2.3 Rinsate Samples 5 7.3 Laboratory Quality Assurance/Quality Control 5 7.3.1 Matrix Spike Samples 5 7.3.2 Laboratory Replicate 5 8.0 SAMPLING SCHEDULE AND DATA MANAGEMENT 6 List of Tables Table 1 Table 2 Sampling Locations Analyte List and Sampling Matrix List of Figures Figure 1 Site and Monitoring Location Map and Groundwater Contour Map List of Attachments Attachment 1 Standard Operating Procedures Loveland Ready -Mix, Inc. app d_20?200318_up dated_Irm_dunn_avc _sap_rev2_final ii Telesto Soli/dons, Inc. March 2022 — Rev 2 1.0 INTRODUCTION In September 2021, Loveland Ready Mix (LRM) submitted an application to the Colorado Division of Reclamation Mining and Safety (DBMS) to permit the proposed Dunn Pit. As part of the approval process the Division requires LRM submit a groundwater quality monitoring plan and sufficient data to determine baseline groundwater quality and demonstrate the site complies with CDPHE Water Quality Control Commission (WQCC) Regulation 41: Basic Standards for Groundwater during the tenure of the mine and reclamation. This Sampling and Analysis Plan (SAP) describes the sampling and analysis methods and monitoring schedule for collecting groundwater elevation and quality samples at the Dunn Pit (Site). The SAP includes procedures for: • Collecting ground water samples • Chemical analysis of ground water samples • Documenting data collection activities • Analytical methods and detection levels • Quality Assurance and Quality Control (QA/QC Figure 1 depicts the site and monitoring well locations. Groundwater elevation contours for the area are also included in Figure 1. 2.0 OBJECTIVE The objective of this SAP is ensure consistent and accurate data collection for baseline and operational groundwater characterization underlying the Site). Quality data collection helps ensure mining and reclamation activities maintain existing groundwater quality and uses. 3.0 STANDARD OPERATING PROCEDURES Standard Operating Procedures (SOPS) are included in Attachment 1. These SOPs include: Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 1 Telesto Solutions, Inc. March 2022 — Rev 2 • SOP #1 • SOP #2 • SOP #5 • SOP #7 • SOP #9 Equipment Decontamination Monitoring Well Water Level Measurement Ground Water Sample Collection Sample Documentation, Handling, Packaging, and Chain of Custody Field Parameter Instrument Calibration and Measurement 4.0 DECONTAMINATION PROCEDURES Extraneous materials can contaminate water samples during a sampling program. While well development and purging procedures may help to remove contaminants, these procedures may not be completely adequate, therefore laboratory test results of the collected water samples maybe inaccurate due to outside contamination. SOP #1 presents general decontamination procedures. All equipment that will contact sampled media requires decontamination. General procedures that apply to decontamination include: • Dress in suitable safety equipment to reduce personal exposure • Wear clean or new rubber or nitrile gloves during decontamination activities and when handling decontaminated equipment • Use new equipment, such as disposable filters and silicon tubing that is certified clean by the manufacturer • Decontaminate all wash/rinse tubs before initial use • Replace rinse and detergent waters, unless in garden sprayers, with new solutions between sample locations. In some cases, new solutions may be needed between samples in the same location • Following decontamination, place equipment in a clean area or on clean plastic sheeting to prevent contact with contaminated soil. If not used immediately, cover equipment, or wrap it in plastic sheeting or heavy duty trash bags to minimize potential airborne contamination. 5.0 GROUND MONITORING Table 1 lists the site monitoring wells and their purpose. 5.1 Water Level Monitoring Monitoring wells MW -01 through MW -l0 are for depth to groundwater monitoring. Combine depth to groundwater measurements with well stickup and site ground surface elevation to provide accurate portrayal of ground water elevations. Follow SOP #2 when Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 2 Telesto Solutions, Inc. March 2022 — Rev 2 collecting depth -to -water information. Collect depth -to -water information monthly for one year, and quarterly thereafter. 5.2 Water Quality Monitoring Monitoring wells MW -03, MW -05, MW -07, MW -08, and MW -09 serve a dual purpose of depth to water level and groundwater quality sampling. Collect ground water samples from these monitoring wells (also shown Figure 1) on a quarterly basis before and during mining until otherwise determined. Appendix A of the Groundwater Baseline Report includes well completion logs for all monitoring wells. Ensure all ground water sampling equipment which will contact the ground water sample are decontaminated following the procedures specified in SOP #1 or are new and certified clean by the manufacturer. Prior to sample collection, sampler will collect a water well level measurement per the procedures outlined in SOP #2. Purge a minimum of three casing volume prior to sampling. If suspected that a well will not yield three well volumes during purging, collect field pH, specific conductivity, and temperature during purging, and sample once three consecutive measurements are consistent (i.e., stabilized). The monitoring wells listed in Table 1 should yield sufficient water to allow for three casing volumes before sampling. Once field parameters have stabilized and or three well volumes have been removed, collect groundwater samples according to SOP#5 and #7. Table 2 lists the field parameters (i.e., pH, specific conductivity, and temperature) and laboratory water quality parameters for measurement. 6.0 SAMPLE DOCUMENTATION, HANDLING, PACKAGING, AND CHAIN OF CUSTODY The standard operating procedures for sample documentation, handling, packaging, and chain of custody are presented in SOP #7. Follow sample custody procedures to maintain sample integrity during collection, transportation, and storage prior to analysis. Minimize the number of individuals handling the samples. The field sampler is personally Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 3 Telesto Solutions, Inc. March 2022 — Rev 2 responsible for collection and custody of the samples until they are transferred to the laboratory. 7.0 FIELD QUALITY ASSURANCE AND QUALITY CONTROL PROCEDURES 7.1 Field Parameter Instrument Calibration and Measurement Field parameter instruments and calibration/measurement procedures are presented in SOP #9. Ground water field parameters include pH, specific conductivity, and temperature. Calibrate field parameter instruments before initial measurements and as needed throughout the day as required to maintain instrument accuracy. 7.2 Field Quality Assurance/Quality Control Samples The primary sample and field quality control samples are listed in Table 2. Quality control samples include field duplicates, field blanks and rinsate samples. QA/QC samples help identify potential sources of sample contamination and help evaluate potential error introduced by sample collection and handling. Label all QA/QC samples with QA/QC identification numbers (i.e., "02" for duplicate samples, "03" for field blanks, "04" for rinsate) and send to the laboratory with the other samples for analyses. 7.2.1 Duplicate Samples Collect duplicate samples to check for the natural sample variance and the consistency of field techniques and laboratory analysis. Collect duplicate samples side -by -side with primary samples. First collect primary samples, and then collect the duplicate samples. Fill all bottles and submit to the same analysis. Utilize different filter and tubing will be used for the primary and duplicate samples. Handle the duplicate water sample in the same manner as the primary sample. The duplicate sample will be assigned the QA/QC identification number "02," stored in an iced cooler, and shipped promptly to the laboratory so that analyses can be performed within required holding times. Collect one duplicate sample per sampling episode. Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 4 Telesto Solutions, Inc. March 2022 — Rev 2 7.2.2 Field Blanks Collect field blanks by filling sample containers in the field with deionized water (preferably laboratory prepared deionized water). Assign the sample QA/QC identification number "03," store in an iced cooler, and ship to the laboratory with all other samples. Collect one field blank per sampling event. 7.2.3 Rinsate Samples Collect an equipment rinsate sample from sampling equipment to check that decontamination procedures are effective. Collect a rinsate sample from the decontaminated sampling equipment (bailer or pump) and filter equipment before using it to obtain the sample. To collect a rinsate sample from a pump, pump the final deionized water rinse through the discharge hose and clean filter into sample bottles. Analyze rinsate sample for the same parameters to which the groundwater samples are subjected. Assign the rinsate sample the QA/QC sample identification number "04," store it in an iced cooler, and ship promptly to the laboratory so that analyses can be performed within the holding times. Collect one rinsate sample will be collected per sampling event. There is no need to collect a rinsate sample if using disposal bailers or sampling equipment. 7.3 Laboratory Quality Assurance/Quality Control 7.3.1 Matrix Spike Samples Analyze matrix spike (MS) samples to evaluate potential matrix effects on sample analyses for all inorganic parameters. The laboratory will analyze matrix spike samples for the inorganic parameters. The laboratory will split the matrix spike samples an existing sample. 7.3.2 Laboratory Replicate The laboratory will create replicate samples from primary sample splits, and analyze these as part of the laboratory's QA/QC program. The laboratory replicate will not require a separate sample volume. Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 5 Telesto Solutions, Inc. March 2022 — Rev 2 8.0 SAMPLING SCHEDULE AND DATA MANAGEMENT Prior to any mining activities exposing groundwater at the Site, LRM will collect monthly depth -to -water and quarterly baseline water quality samples for a period of five quarters to confirm the baseline water quality of the underlying aquifer (Big Thompson Alluvial Aquifer). If after five quarters of sampling, water quality data indicates no reportable differences to analyte detection levels, LRM will submit documentation to the Division demonstrating the consistency in water quality results provides rational and compelling evidence sufficient to establish baseline conditions. With document submittal, LRM will request a sample reduction through a submittal of a Technical Revision with the Division approval to begin mining and/or dewatering operations without additional background monitoring. During active mining operations and reclamation, LRM will work with DRMS to develop a meaningful program to continue groundwater monitoring on a regular basis and with an annual report submitted each year. Active mining and reclamation are expected to last 30 - years. Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 6 Telesto Solutions, Inc. March 2022 — Rev 2 Table I - Sampling Locations WELL 1D EASTING (UTM: METERS) NAD8S NORTHING (UTM NAD83 PURPOSE OMPLETED DEPTH (FT) ME RS) MW -01 510408.5 4465971.1 33 DTIN MW -02 510407.5 4466335.8 28 DTW MW -03 510255.6 4466620.3 29 DTW & W MW -U4 510701. 8 4466218.0 33 DTI''' MW -05 510742.3 4466037.9 29 DTW & W MW -06 510945.8 4465659. 8 29 DT ' MW -07 511194.3 4465677.4 29 DTVV & VVID 4465868.2 28 DMTW &' mvv-08 511161.5 4465744.3 29 MW -09 510714.2 DTW &' Q MW -10 510744.7 4466291.1 24 DTW DTW = Depth to Water WO = Water Quality Sampling Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 7 Telesto Solutions, Inc. March 2022 — Rev 2 Table 2 - Analyte List Loveland Ready -Mix Concrete, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final 8 Telesto Solutions, Inc. March 2022 — Rev 2 DUNN PIT - LOVELAND READY -MIX CONCRETE, INC. WATER QUALITY SAMPLING MATRIX LABORATORY TESTS QA/QC REQUIREMENTS ANALYTE FIELD METHOD ANALYTICAL METHOD SAMPLE CONTAINERS PRESERVATIVES STANDARD* METHOD DETECTION LIMIT RINSATE FIELD BLANKS DUPLICATE Aluminum 0.45 µm filter in field EPA 200.7 or SW -846 6000 lx 250 mL poly HNO3 to pH <2 Cool to 4° C 5 mg/I ** 0.0350 mg/I One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Antimony EPA 200.8 0.006mg/I 0.0075 mg/I Arsenic EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW 6020, 6020A 0.01 mg/I 0.0065 mg/I Barium EPA 200.7/200.8 or SW -846 6010 or SW -846 6020 2 mg/I 0.0017 mg/I Beryllium EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A I 0.004 mg/I 0.0007 mg/I Boron 0.45 µm filter in field EPA 200.7 or SW -846 6010 HNO3 to pH <2 Cool to 4° C 0.75 mg.l ** 0.0126 mg/I Cadmium EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.005 mg/I 0.0007 mg/I Chromium 0.45 p.m filter in field EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW 846 6020, 6020A or SW -846 7196A or SW -846 7199 HNO3 to pH <2 Cool to 4° C , 0.10 mg/I 0.0014 mg/I Chloride Unfiltered . EPA 300.0 250 mg/I * 1 mg/I Cobalt 0.45 µm filter in field EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 0.05 mg/I ** 0.0023 mg/I Copper EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 I 0.20 mg/I ** 0.0053 mg/I Cyanide [Free] Unfiltered SW -846 9012B lx 250 -mil Amber -Poly NaOH 0.2 mg/I 0.01 mg/I Fluoride Unfiltered EPA 300.0 or SW -846 9056 or SM 4500 F -C 2x 250-mL poly Cool to 4° C 2 mg/I** 0.0099 mg/I Iron 0.45 µm filter in field EPA 200.7/200.8 or SW -846 6010 or SW -846 6020 lx 250-mL poly HNO3 to pH <2 Cool to 4° C 0.3 mg/I * 0.0141 mg/I Lead EPA 200.8 or SW -846 6010B, 6010C or SW -846 6020, 6020A 0.05 mg/I 0.0019 mg/I Lithium EPA 200.7 or SW -846 6010 2.50 mg/I ** 0.0053 mg/I Manganese EPA 200.7 or SW -846 6010 0.05 mg/I ** 0.0012 mg/I Mercury (inorganic) EPA 245.1 or SW -846 7470A 0.002 mg/I 0.000049 mg/I Molybdenum SW 846 6010B, 6010C or SW 846 6020, 6020A 0.21 mg/I 0.0016 mg/I Nickel EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.10 mg/I 0.0049 mg/I Nitrate Unfiltered EPA 300.0 or EPA 300.1 or SM 4110 B or SW -846 9056 Cool to 4° C 10.0 mg/I as N 0.0227 mg/I Nitrite EPA 300.0 or EPA 300.1 or SM 4110 B or SW -846 9056 1.0 mg/I as N 0.0277 mg/I Total Nitrate and Nitrate as N EPA 353.2 H2SO4 to pH <2 Cool to 4° C 10 mg/I as N 0.05 mg/I pH EP 150.1 or SM 4500-H B or SW-846 9045C Cool to 4° C 6.5 - 8.5 ** --- Selenium 0.45 µm filter in field EPA 200.7/200.8 or SW 846 6010 or SW -846 6020 HNO3 to pH <2 Cool to 4° C 0.02 mg/I ** 0.0074 mg/I Silver EPA 200.7 or EPA 200.8 or SW -846 6010B, 6010C or SW- 846 6020, 6020A 0.05 mg/I 0.0028 mg/I Sulfate Unfiltered EPA 300.0 Cool to 4 250 mg/I* 5 mg/I Thallium 0.45 p.m filter in field EPA 200.8 or SW 846 60106, 6010C or SW -846 6020, 6020A HNO3 to pH <2 Cool to 4° C 0.002 mg/I 0.0065 mg/I Uranium 0.45 µm filter in field EPA 200.8 or SW -846 60106, 6010C or SW -846 6020, 6020A or D5174 HNO3 to pH <2 Cool to 4° C 0.0168 to 0.03 mg/I 1 mg/I Vanadium EPA 200.7 or SW -846 6010 0.10 mg/I ** 0.0024 mg/I Zinc EPA 200.7 or EPA 200.8 or SW -846 6010 or 6020 2 mg/I ** 0.0059 mg/I TOTAL DISSOLVED SOLIDS (TDS) QA/QC REQUIREMENTS ANALYTE FIELD METHOD ANALYTICAL METHOD SAMPLE CONTAINERS PRESERVATIVES STANDARD METHOD DETECTION LIMIT RINSATE FIELD BLANKS DUPLICATE Total Dissolved Solids Unfiltered EPA 160.1 or SM 2540 C lx 500-mL poly Cool to 4° C See below *** See below One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event BACKGROUND TDS VALUE (mg/I) MAXIMUM ALLOWABLE TDS CONCENTRATIONS 0-500 mg/I 400 mg/I or 1.25 times the background level, whichever is least restrictive 501-10,000 mg/I 1.25 times the background value 10,001 mg/I or greater No limit FIELD PARAMETERS QA QC REQUIREMENTS TEST MEASUREMENT METHOD METHOD DESCRIPTION RINSATE FIELD BLANKS DUPLICATE pH Meter/flow-through cell Glass sensing and Ag/AgCl reference electrodes One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Temperature Combination pH Electrode with Temperature (Gel -filled) Glass sensing and reference solution calibration One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event Conductivity Combination pH Electrode with Temperature (Gel -filled) Glass sensing and reference solution calibration One groundwater rinsate sample per sampling event One groundwater Field Blank oer sampling event One duplicate per sampling event. Rotate duplicate sampling location per sampling event All groundwater samples must be collected and analyzed according to the summary of analytical methods, holding times, sample containers, preservatives, and reporting limits included on WQCC Tables, or equivalent, upon approval by the Supervisor. Unless otherwise noted, standards are from Table 1 of Colorado Department of Public Health and Environment, WQCC Regulation No. 41 * Table 2 - WQCC Regulation No. 41 ** Table 3 - WQCC Regulation No. 41 *** Table 4- WQCC Regulation No. 41 LEGEND Puma -TED NEIGHBOR WELLS 'MONITORING WELLS AND GROUNDWATER rffil LEVEL GROUNDWATER CONTOURS (DASHEJD WHERE INE ER-PED C F.STIMMO CONTOURS (DASHED WHERE INFE PRE I]) WETLAND PROPERTY BOUNDARY SAMPLING LOCATION • MW -03 • MW -05 • MW -07 • MW -08 • MW -09 . '. 7 titelnyt Col & Fro y FIGURE 1 SAMPLING LOCATIONS DUNN PIT, LOVELAND READY -MIX P.O. BOX 299, LOVELAND, CO 80539 PREPARED BY: TELESTQ SOLUTIONS* I NCORPORA T E [3 PREPARED FOR: LOt M) READY MIE CONCRETE Attachment 1 Standard Operating Procedures Loveland Ready -Mix Concrete, Inc. Telesto Solutions, Inc. app d_202200318 updated_lrm_dunn_gw sap_rev2_final September• 2021 STANDARD OPERATING PROCEDURE #1 EQUIPMENT DECONTAMINATION Prepared by: Telesto Solutions, Inc. 2950 E. Harmony Road, Suite 200 Fort Collins, CO 80528 September, 2009 TELESTO S O L u t I o FMS . t N C O R P cD Q A T E D Equipment. Decontamination Standard Operating Procedure No. 1 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE 1 2.0 RELATED STANDARD OPERATING PROCEDURES 1 3.0 EQUIPMENT NECESSARY FOR DECONTAMINATION 1 4.0 DECONTAMINATION PROCEDURES 2 4.1 General Decontamination Procedures for All Equipment 2 4.2 Decontaminating Sampling Equipment 3 4.3 Decontaminating Submersible Pumps 3 4.4 Decontaminating Water Level Probes 4 4.5 Decontaminating Delicate Equipment 4 4.6 Decontaminating Drilling and Heavy Equipment 5 4.7 Disposing of Decontamination Solution 5 5.0 DOCUMENTATION 5 6.0 QUALITY ASSURANCE REQUIREMENTS 6 7.0 REFERENCES 7 Telesto Solutions, Inc. September, 2009 1 Equipment. Decontamination Standard Operating Procedure No. 1 1.0 PURPOSE AND SCOPE The purpose of this document is to define the standard procedure for decontamination. The American Society for Testing and Materials (ASTM) Standard Practice for Decontamination of Field Equipment Used at Nonradioactive Waste Sites (D 5088-90) was used as a guide in preparing this Standard Operating Procedure (SOP). The overall objective of multimedia sampling programs is to obtain samples that accurately depict the chemical, physical, and/or biological conditions at the sampling site. Extraneous contaminants can be brought onto the sampling location and/or be introduced into the medium of interest during the sampling program (e.g., by bailing or pumping ground water with equipment that was previously contaminated at another site). Trace quantities of these contaminants can thus infect a sample and lead to false positive analytical results and, ultimately, to an incorrect assessment of the contaminant conditions at the site. Decontamination of sampling equipment (e.g., bailers, pumps, tubing, and soil and sediment sampling equipment) and field support equipment (e.g., drill rigs and vehicles) is therefore required to ensure that sampling cross - contamination is prevented and that on -site contaminants are not carried off -site. 2.0 RELATED STANDARD OPERATING PROCEDURES This procedure is intended to be used with the following SOP: SOP # Title 7 Sample Documentation, Handling, Packaging, and Chain of Custody 3.0 EQUIPMENT NECESSARY FOR DECONTAMINATION The following equipment may be needed to perform decontamination: Telesto Solutions, Inc. September, 2009 1 Equipment. Decontamination Standard Operating Procedure No. 1 • • • • • • • • • • • • Brushes Wash tubs (plastic) Buckets (plastic) Scrapers Steam cleaner or hot water washer Paper towels Liquinox detergent (or equivalent) Potable water Deionized water Garden type water sprayers Laboratory wash bottles Clean plastic sheeting and/or trash bags. 4.0 DECONTAMINATION PROCEDURES 4.1 General Decontamination Procedures for All Equipment Decontaminate all equipment that will contact a sampled media. General procedures that apply to most specific decontamination procedures are listed below. • Dress in suitable safety equipment to reduce personal exposure. • Wear clean or new rubber or latex gloves during decontamination activities and when handling decontaminated equipment. • Do not decontaminate new equipment, such as disposable filters and silicon tubing, that is certified clean by the manufacturer. Telesto Solutions, Inc. September, 2009 2 Equipment. Decontamination Standard Operating Procedure No. 1 • Decontaminate all wash/rinse tubs before intial use and between boreholes. • Replace rinse and detergent waters, unless in garden sprayers, with new solutions between borings or sample locations. In some cases, new solutions may be needed between samples in the same location. • Following decontamination, place equipment in a clean area or on clean plastic sheeting to prevent contact with contaminated soil. If the equipment will not be used immediately, cover the equipment or wrap it in plastic sheeting or heavy duty trash bags to minimize potential airborne contamination. 4.2 Decontaminating Sampling Equipment Decontaminate sampling equipment as follows: 1 Scrape off gross contamination from equipment at the sampling or construction site. 2. For equipment that water will not damage, place the equipment in a wash tub containing Liquinox and potable water or spray the equipment with a Liquinox/potable water solution contained within a garden type sprayer, and scrub the equipment with a bristle brush or similar utensil (if possible). 3 In a second wash tub or using a second garden sprayer, triple rinse equipment with potable water to remove the Liquinox solution. 4 Triple rinse the equipment with deionized water from a garden sprayer or laboratory wash bottles, and let the equipment air dry (if possible). 4.3 Decontaminating Submersible Pumps Decontaminate the insides of an electric submersible pump and discharge hose (e.g., a Redi-Flo 2 pump) as follows: 1 Before performing internal decontamination, remove the Redi-Flo2 internal pump fluid and replace it with deionized water (see the Red-Flo2 owners manual). 2 Pump Liquinox/potable water solution through the pump and hose. Be sure that the volume of solution used is not less than one volume of fluid contained in the Telesto Solutions, Inc. September, 2009 3 Equipment. Decontamination Standard Operating Procedure No. 1 pump and hose. (Note that a Redi-Flo2 pump with 250 feet of 0.5 -inch inner - diameter hose contains 2.55 gallons of fluid.) 3 Pump potable rinse water through the pump and hose. Be sure that the volume of solution used is not less than three times the volume of fluid contained in the pump and hose. 4 Pump deionized rinse water through the pump and hose. Be sure that the volume of solution used is not less than three times the volume of fluid contained in the pump and hose. Decontaminate the outside of the pump and discharge hose as follows: 1 When removing the pump and hose from the well, place the hose reel 10 to 20 feet away from the well to allow the hose to be decontaminated before placing it on the reel. Do not let decontamination fluids enter the well. 2. While removing the pump from the well, wash the outside of the pump and hose with Liquinox/potable water solution and triple rinse it with potable water. 3 Triple rinse the hose with deionized water before placing the hose on the reel and/or triple rinse the hose with deionized water while lowering the pump into the next well. If the pump and hose are exposed to airborn contaminants (e.g., dust and mud), rinse the pump and hose while lowering the pump down the next well. 4.4 Decontaminating Water Level Probes Decontaminate water level probes by using the general decontamination procedures for sampling equipment (Section 4.2) or by wiping them successively with paper towels wetted with Liquinox solution, potable water, and deionized water. Rinse the water level probe with deionized water before use. Store the water level probe in a plastic bag after decontamination. 4.5 Decontaminating Delicate Equipment Telesto Solutions, Inc. September, 2009 4 Equipment. Decontamination Standard Operating Procedure No. 1 Carefully wipe clean equipment that water will damage successively with paper towels wetted with Liquinox solution, potable water, and deionized water. Be sure to avoid damaging the equipment. 4.6 Decontaminating Drilling and Heavy Equipment Decontaminate drilling and heavy equipment as follows: • Dress in suitable safety equipment to reduce personal exposure. • With a flat -bladed scraper, scrape gross contamination or drill cuttings off equipment at the sampling or construction site. • Spray equipment, such as drill rigs, augers, drill bits, and shovels, with a Liquinox/potable water solution using a hot water washer. Be sure to adequately clean the insides of the hollow -stem augers and backhoe buckets. • Rinse the equipment with potable water. • Place drilling equipment on the clean drill rig and move it to a clean area. If the equipment will not be re -used immediately, store it in a designated clean area. 4.7 Disposing of Decontamination Solution Dispose of used wash and rinse solutions at a location that will not bias subsequent samples. 5.0 DOCUMENTATION Be sure to document the decontamination of sampling and drilling equipment. Record the documentation with black waterproof ink in the sampler's field notebook with consecutively numbered pages. This documentation should include the following: Telesto Solutions, Inc. September, 2009 5 Equipment. Decontamination Standard Operating Procedure No. 1 • The personnel who performed the decontamination • Date • Decontamination procedures and observations • Rinsate sample collection procedure (if collected). 6.0 QUALITY ASSURANCE REQUIREMENTS To verify the effectiveness of the decontamination procedures, collect equipment rinsate samples from the decontaminated sampling equipment as follows: • Run deionized water through or over a representative decontaminated sampling tool (such as a split spoon sampler or bailer) and collect the rinsate water in sample bottles. • Filter, preserve, handle, and analyze rinsate samples for the same parameters as primary samples collected at the site. Refer to SOP #7 for sample documentation, handling, packaging, and chain -of -custody procedures. • Record the rinsate procedure, including the sample number, in the field notebook. • Send the bottles to the laboratory for analysis. Collect equipment rinsate samples at the following frequencies: • If more than 20 field samples were collected, collect one rinsate sample per 20 field samples collected. • If less than 20 field samples were collected in the sampling event, collect at least one rinsate sample per sampling method used. • When using more than one sampling method or type of equipment, collect at least one rinsate sample from each type of device that was used to obtain samples (e.g., if both a bailer and a electric submersible pump were used to collect ground water samples, collect a rinsate sample from both devices at a minimum frequency of 1 each per 20 samples). Telesto Solutions, Inc. September, 2009 6 Equipment. Decontamination Standard Operating Procedure No. 1 7.0 REFERENCES ASTM D-5088 - 84, Standard Practice for Decontamination of Field Equipment Used at Nonradioactive Waste Sites, 1995 Annual. Book of ASTM Standards, Vol. 04.08. Telesto Solutions, Inc. September, 2009 7 STANDARD OPERATING PROCEDURE #2 MONITORING WELL WATER LEVEL MEASUREMENT Prepared by: Telesto Solutions, Inc. 1601 Prospect Parkway, Suite C Fort Collins, CO 80525 January, 2005 TELESTO S C L u t I O N S+ s N C O R P u Q A T E° Monitoring Well Water Level Measurement Standard Operating Procedure # 2 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE 1 2.0 RELATED STANDARD OPERATING PROCEDURES 1 3.0 NECESSARY EQUIPMENT 1 4.0 WATER LEVEL MEASUREMENT PROCEDURES 2 5.0 DECONTAMINATION 4 6.0 DOCUMENTATION 5 7.0 CALIBRATION 5 Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixdlappendix a_sop02 wl measure.doc 1 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 1.0 PURPOSE AND SCOPE The purpose of this document is to define the standard procedure for measuring water levels in wells, piezometers, and boreholes. This Standard Operating Procedure (SOP) describes equipment and field procedures necessary to collect water level measurements. 2.0 RELATED STANDARD OPERATING PROCEDURES This procedure is intended to be used with the following SOP: SOP # Title 1 Equipment Decontamination 3.0 NECESSARY EQUIPMENT The equipment necessary to measure water levels includes: • Electric water level probe capable of producing measurements to the nearest 0.01 foot • Replacement batteries for water level probe • Field logbook, field data sheets, and black pen • Engineers tape (marked in increments of lOths and 100ths of a foot) • Additional stainless steel weight • Paper cups and/or turkey baster • Paper towels • Liquinox soap • Potable water • Sprayer filled with deionized water Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 1 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 • Appropriate health and safety equipment, including at least safety glasses and latex gloves. 4.0 WATER LEVEL MEASUREMENT PROCEDURES This section gives the sequence of events to follow when measuring water levels. • Before mobilization to the site, obtain the following: previous water level data and survey data if available (data should include description of measurement point location and survey point description) well completion data, including total depth, well casing stickup, and protective casing stickup if wells are locked, obtain the appropriate key. • Wear appropriate health and safety equipment, as described in the Health and Safety Plan when opening and measuring wells and performing decontamination. At a minimum, wear safety glasses and latex gloves. (Latex gloves are required to prevent cross contamination.) • To minimize potential cross contamination, measure the wells in order of cleanest to most contaminated. • Before taking measurements, decontaminate the water level probe according to SOP #1 and Section 5 of this SOP. • • Unlock and open the well. If the water level is above the top of the well and cap, evacuate the water with a paper cup or a turkey baster. Follow all health and safety procedures and if necessary, let the well vent any gasses that may be present in the well casing. If you observe either a negative or positive pressure when opening the well, let the well stabilize before measuring the water level. Stabilization could take several minutes, hours, or days, depending on well characteristics. Test the water level probe to verify that it is working properly. Push the circuit test button to verify that the light/buzzer is working. This button tests only the light/buzzer and does not test the other parts of the water level probe. Dip the tip of the water level probe into water to verify that the water level probe is working properly. Note that deionized water, due to its low conductivity, will not trigger a response. Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 2 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 • After opening the well cover, locate the measuring point for water level measurements. The measuring point for the water level is usually the top of the well casing, not the protective casing, but it can vary between wells and programs. Some programs will specify on which side of the well casing (i.e., the north side) to locate the measuring point or will specify the highest point of the casing if it is not cut evenly. If not already marked and described, the measuring point should be marked and described for easy identification. If possible, the measuring point should be the same as the survey point. • To measure the static water level, lower the water level probe into the well until the buzzer/light indicates that the probe tip has contacted water. By raising and lowering the water level probe and adjusting the sensitivity to indicate when the probe is contacting the water, the depth to water should be measured to the nearest 0.01 foot. Record the water level depth below the measuring point in the field book or data sheet. Then recheck the measurement before removing the water level probe from the well. Compare the most recent measurement with past measurements and verify that the new measurement is reasonable before leaving the well. If the measurement does not seem reasonable, measure the water level again. • If the well is dry, record the maximum depth measured (e.g., dry to 44.34 feet). • Measuring the total well depth will help identify the well, indicate if there is well damage or accumulated sediment in the well, and provide data to calculate saturated borehole volume prior to purging the well. If water contacts cuts or nicks in the line and causes a "short" in the line, you may need to repair and/or clean and dry the line before reuse. (Note: Because measuring total depth in deep wells with high water levels can force water around seals in tips and may cause shorting, the tip may need to be disassembled and dried.) The total well depth should be measured unless a recent total depth measurement has been fully documented. If the measuring point on the well probe is not at the tip of the probe, adjust the total depth measurement to account for the distance between the water measurement point and the tip of the probe. • When raising or lowering the water level probe from the well, exercise great care to avoid pulling the probe wire over the well casing or the protective casing. Even PVC pipe can damage the water level probe if it is not handled properly. • Especially on deep wells, you may need an additional weight to lower the water level probe to the water level. A non -contaminating, long, narrow weight (e.g., a stainless steel rod) should be used. Tape the weight to the water level probe line with plastic electrical tape only when not measuring organics, and remove the weight prior to decontamination. Excessive weight could damage the water level probe by stretching or even breaking the line. Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 3 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 • Measure the distance that the protective casing sticks up above ground level and the distance from the measuring point on the top of the well casing to the top of the protective casing. • Wells with submersible pumps or other installed equipment probably should not be measured unless a tube specifically designed for water level measurements is present. The risk of losing the water level probe and/or damaging equipment installed in the well is considerable. Before attempting to measure a water level in a well with any installed equipment, obtain the project manager's approval. 5.0 DECONTAMINATION Decontaminate the water level indicator before measuring the water level in the first well and after measuring the levels in all wells. Decontaminate the probe according to SOP #1. Decontamination requirements will vary depending on the contaminants present and their concentrations, and some sites may require decontamination of the probe between measurements at each well. At mining sites where low-level inorganic background parameters are being monitored, the decontamination procedure may consist of the following: (1) wiping the well probe line, as it is removed from the well, successively with paper towels that have been wetted with Liquinox solution, potable water, and deionized water and (2) rinsing the entire reel with deionized water before use. Although this method is efficient, it may not be acceptable at all sites. Other acceptable decontamination procedures are specified in SOP #1. The decontamination procedure used should be approved by the project manager before use. Once decontaminated, the water level probe should be either placed in a clean plastic bag or used immediately. If the water level probe has contacted especially corrosive fluids (e.g., water with high or low pH values, high chlorides concentrations, or high TDS concentrations), at a minimum, thoroughly rinse the water level probe immediately after use to protect the water level probe from damage. Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 4 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 6.0 DOCUMENTATION This section describes the documentation necessary for water level monitoring. Record at least the following information in the field book or on the ground water data sheets for each well: • • • • • • • • • • • • • Personnel who performed the measurement Date Time Well number Depth to water from measurement point Depth to well bottom from measurement point Distance from the well probe's water level measurement point to the well probe tip to correct total depth measurements Distance from top of protective casing to ground surface Distance from measuring point on top of the well casing to the top of protective casing Description of the measurement point location Description of the decontamination procedure Well probe's identification number All calculations performed. The field notebook used during water level measurement activities will include any other observations made while measuring water levels. 7.0 CALIBRATION The water level measurement probe cord should be calibrated at least annually or more often as needed to ensure the desired accuracy. The calibration check consists of laying out 100 feet of steel Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 5 January 20 Monitoring Well Water Level Measurement Standard Operating Procedure # 2 tape next to 100 feet of the probe cord. At 2 -foot intervals, note any measurement discrepancies between the two. The probe cord shall be rechecked if it may have been stretched or damaged during water level measurements. Document the procedures followed while calibrating and verifying equipment in the field notebook, along with any calculations. If a correction is required, tag the probe to indicate the correction. Telesto Solutions, Inc. r: Iweldcountyldunnpit. lrmlproductslbaselinestudieslgroundwaterlappendixdlappendix a_sop02 wl measure.doc 6 January 20 STANDARD OPERATING PROCEDURE #5 GROUND WATER SAMPLE COLLECTION Prepared by: Telesto Solutions, Inc. 1601 Prospect Parkway, Suite C Fort Collins, CO 80525 January, 2005 TE LESTO S O L U t I O NN S e t COR i A T f Ground Water• Sample Collection Standard Operating Procedure #5 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE 1 2.0 RELATED STANDARD OPERATING PROCEDURES 1 3.0 NECESSARY EQUIPMENT 1 3.1 General Equipment Requirements 1 3.2 Field Parameter Measurements 4 4.0 WATER SAMPLING PROCEDURES 6 4.1 Well Purging Strategy 6 4.2 Calculating Saturated Borehole Volume 6 4.3 Stability of Field Parameters 8 4.4 Purge Rates and Pump Placement 9 4.5 Purging Low -Yielding Wells 9 5.0 SAMPLING PROCEDURES 10 5.1 Evacuating Well 10 5.2 Obtaining Water Samples 11 5.3 Field Quality Assurance/Quality Control Procedures and Samples 12 5.4 Sample Documentation, Preservation, Handling, Packaging, and Chain of Custody 16 6.0 DOCUMENTATION 16 6.1 Ground Water Data Sheet 16 6.2 Field Notes 17 7.0 REFERENCES 17 LIST OF FIGURES Figure 1 Figure 2 Saturated Borehole Volume Calculation Saturated Borehole Volume Calculation (Form and Example) LIST OF APPENDICES Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 1 Ground Water• Sample Collection Standard Operating Procedure #5 Appendix A Ground Water Sampling Data Sheet Telesto Solutions, Inc. r: I weldcountyl dunnpit lrm\products\baselinestudies\groundwaterl appendixdlappendix a_sop05 gw sampling.doc Ground Water• Sample Collection Standard Operating Procedure #5 1.0 PURPOSE AND SCOPE The purpose of this document is to define the standard procedure for collecting ground water samples from wells. This Standard Operating Procedure (SOP) gives descriptions of equipment, field procedures and quality assurance/quality control (QA/QC) procedures necessary to collect ground water samples from wells. 2.0 RELATED STANDARD OPERATING PROCEDURES This procedure is intended to be used with the following SOPs: s : SOP # Title 1 Equipment Decontamination 2 Monitoring Well Water Level Measurement 7 Sample Documentation, Handling, Packaging, and Chain of Custody 8 Quality Assurance/Quality Control Sample Collection 9 Field Parameter Instrument Calibration and Measurement 3.0 NECESSARY EQUIPMENT 3.1 General Equipment Requirements Equipment that may be used for measuring water levels includes: • Electric water level probe capable of producing measurements to a precision of 0.01 foot • Replacement batteries for water level probe • Field logbook, field data sheets, and black pen • Well keys • Engineers tape (lOths, 100ths feet) Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 1 Ground Water• Sample Collection Standard Operating Procedure #5 • Additional stainless steel weight • Paper cups and/or turkey baster • Paper towels • Liquinox soap • Potable water • Sprayer filled with deionized water • Appropriate health and safety equipment, including at least safety glasses and latex gloves. Use the following equipment for sample collection, sample labeling, filtering, packing, documentation, and performing chain -of -custody procedures: • Sample bottles. Obtain sample bottles and preservatives from the selected analytical laboratory, including several extra sample bottles in case breakage or other problems occur. Sample bottles can be either pre -preserved or preservatives can be added in the field. • Sample labels • Appropriate preservatives • Field book and data forms • Chain of Custody Form • Black permanent markers and pens • Clear plastic tape • Fiber tape • Custody seals • Large (30 gallon) trash bag • Gallon ziplock freezer bags • Ice Telesto Solutions, Inc. r: I weldcountyl dunnpit lrm\products\baselinestudies\groundwaterl appendixdlappendix a_sop05 gw sampling.doc 2 Ground Water• Sample Collection Standard Operating Procedure #5 • Shipping documentation • Disposable 0.45 -micron filters • Silicon or Tygon® tubing • Peristaltic pump. The following equipment may be used during well evacuation and sampling: • Assorted tools (knife, screwdriver, etc.) • PVC, teflon, or stainless steel bailer (bottom filling) • PVC hand pump • PVC pump discharge hose • Braided nylon rope • Bailer tripod • Gas -powered electric generator • Stainless steel submersible pump • Plastic sheeting (for placing around well) • pH meter (with automatic temperature compensation) • Specific conductivity meter • Plastic squeeze bottle filled with deionized water • Polyethylene or glass container (for field parameter measurements) • Chemical -free paper towels or Kimwipes • Calculator • Field notebook • Black waterproof pen • Appropriate health and safety equipment. Telesto Solutions, Inc. r: I weldcountyl dunnpit lrm\products\baselinestudies\groundwaterl appendixdlappendix a_sop05 gw sampling.doc 3 Ground Water• Sample Collection Standard Operating Procedure #5 Use the following equipment for performing decontamination: • • • • • • • • Alconox or Liquinox soap (or equivalent) Potable water Deionized water Decontamination buckets/pails Paper towels Plastic brushes Sprayers Plastic sheeting. 3.2 Field Parameter Measurements Use the following apparatus and supplies for measuring pH in the field: • Portable Hach One pH Meter Model 43800-00 with Hach One Combination pH Electrode Model 48600 or the EC 10 Portable pH/mV/Temperature Meter Model 50050 with the Combination pH Electrode with Temperature (Gel -filled) Model 50200 • • • • • • • Spare electrolyte cartridge, if required Hach pH Electrode Storage Solution, Catalog No. 50301-49 Extra batteries Beakers Buffer solutions of pH 4, 7, and 10 Deionized or distilled water and wash bottle Kimwipes or equivalent. Use the following apparatus and supplies for measuring conductivity in the field: Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 4 Ground Water• Sample Collection Standard Operating Procedure #5 • Hach CO150 Conductivity Meter Model 50150 or Hach Conductivity/TDS Meter Model 44600 • Extra battery • Calibration solutions which bracket expected range of measurements • Deionized water • Wash bottle • Kimwipes • Beakers. Use the following apparatus and supplies for measuring turbidity in the field: • Hach Portable Turbidimeter Model 2100P • Extra battery • Calibration solutions which bracket expected range of measurements • Silicone oil • Deionized water • Wash bottle • Liquinox nox solution • Kimwipes • Beakers. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 5 Ground Water• Sample Collection Standard Operating Procedure #5 4.0 WATER SAMPLING PROCEDURES 4.1 Well Purging Strategy The objective of purging before sample collection is to thoroughly flush the static ground water from the well and filter pack (i.e., saturated borehole volume) and provide representative formation water for sample collection. The amount of water that that needs to be purged and how to determine that the resulting sample will be representative of the formation is a frequently debated issue. The two most common methods are purging a set number of saturated borehole volumes and/or casing volumes, usually between 3 and 10, and demonstrating the stability of field parameters (e.g., pH, conductivity, temperature, and turbidity) over a specified volume. Although this SOP discusses a minimum purge volume and stability of field parameters, the best procedure to help collect a representative sample requires on -site evaluation of all field conditions, which includes purge volume, stabilization of field parameters, well construction, hydrologic properties of the formation, and parameters of interest. Due to the variability of site conditions, no one procedure can ensure that a representative sample will be collected without the possibility of over- or under -purging some wells . 4.2 Calculating Saturated Borehole Volume Monitoring wells should be purged before sampling so that representative ground water is sampled, not the potentially biased water stored in the well casing and filterpack. Because the representativeness of stored water is questionable, stored water should be purged from the monitoring well before collecting samples. Removing all stored water in most cases is not feasible or practical. Therefore, before collecting ground water samples, purge an undetermined amount of water from the monitoring well until representative formation water can be sampled. The amount of water to purge will vary from well to well based on specific well characteristics. No one method of calculating the required purge volume will always work. The usual method to estimate purge volumes is to calculate a number of casing volumes or saturated borehole volumes. Casing volumes account for only the water in the well casing and does not account for the water in Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 6 Ground Water• Sample Collection Standard Operating Procedure #5 the annular borehole space, which is independent of the casing size. Calculating the saturated borehole volume accounts for all the water within the borehole and casing. If purging procedures were completely efficient, the saturated borehole volume would be the minimum volume of water to purge to remove the potentially biased water from the borehole. Because mixing does occur, the minimum purge volume must be greater than one saturated borehole volume. The degree of mixing within the borehole during purging is difficult to estimate and, therefore, the range of recommended purge volumes varies from 3 to 10 saturated borehole volumes. Three saturated borehole volumes has been selected as the best way to estimate purge volumes. Some wells will require purging more than three saturated borehole volumes and some less. The saturated borehole volume calculation formula is presented in Figure 1. Figure 2 presents a sample saturated borehole volume calculation and a blank form to calculate specific saturated borehole volume. The basic formula is volume equals pi times the radius squared times depth (V=mr2d). To calculate saturated borehole volume, the casing and borehole radii and the height of water in the casing and the filter pack must be known. Measure the water level in the field, and obtain the borehole and casing radii from the well completion data. Figure 2 presents a sample saturated borehole volume calculation, as described below: • Equation (a) shows how to calculate the casing radius in feet by dividing the nominal casing diameter in inches by 2 (to convert the diameter to a radius) and dividing the result by 12 (to convert inches to feet). • Equation (b) shows how to calculate the borehole radius in feet by dividing the nominal borehole diameter in inches by 2 (to convert the diameter to a radius) and dividing the result by 12 (to convert inches to feet). • Equation (c) shows how to calculate the casing volume, given the casing radius and height of water in the casing. • Equation (d) shows how to calculate the annular volume, given the annular radius and the height of water in the filter pack. • Equation (e) shows how to calculate the saturated annulus volume by subtracting the casing volume from the borehole volume and multiplying the result by the assumed effective porosity of the annulus. • Equation (0 shows how to calculate the saturated borehole volume by adding the casing volume to the saturated annulus volume and converting cubic feet to gallons. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 7 Ground Water• Sample Collection Standard Operating Procedure #5 In confined wells and unconfined wells that are screened and filter packed below the water table, the height of water in the casing will exceed the height of water in the filter pack (i.e., hi>h2). In these cases, calculate the height of water in the filter pack based on the top of the filter pack interval, and not the top of the screen interval. To calculate the saturated borehole volume in these cases, substitute the appropriate height of water in feet into Equations C and D. Note that wells have variable amounts of filter pack below the bottom of the screen. The volume of water below the bottom of the screen may be a significant portion of the total saturated borehole volume if there is only a few feet of measurable water in the screen and several feet of filter pack below the bottom of the screen. The saturated borehole volume calculation presented in Figures 1 and 2 does not account for the volume of water in the borehole below the screen. For wells with only minimal amounts of water in the screen, evaluate the amount of water within the borehole below the screen and consider it when purging the well. 4.3 Stability of Field Parameters To demonstrate that you have collected a representative ground water sample, measure field parameters during purging and purge the well until these parameters stabilize. The field parameters measured may include pH, conductivity, temperature, turbidity, Eh, and dissolved oxygen. However, these parameters tend to stabilize at different rates, and field parameters generally stabilize before the chemical parameters that are being sampled. Therefore, the purge volume required for field parameters to stabilize should be considered a minimum purge volume, and laboratory parameters may stabilize only with continued purging. In order to demonstrate that parameters have stabilized, establish the acceptable range of field parameter values and the volume of water between field parameter measurements. The acceptable range for most field parameter measurements is generally 10 percent of the value for conductivity, temperature, turbidity, Eh, and dissolved oxygen, and 0.1 units for pH. Demonstrate stabilization over a minimum volume of one saturated borehole volume. Document that the measurements do Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 8 Ground Water• Sample Collection Standard Operating Procedure #5 not fluctuate more than 10 percent or 0.1 pH units between the end points. Collect as many field parameter readings as practical between the end points (i.e., one reading at every 1/4 to 1/2 saturated borehole volume). Calibrate the pH and conductivity meters before use every day. Record calibration times and appropriate readings in the field notebook. Refer to SOP #9 for specific instructions on calibrating the pH and conductivity meters. 4.4 Purge Rates and Pump Placement Do not let the purge rate exceed the development rate. If possible, purge wells at or below their recovery rates in order to minimize turbidity and drawdowns. The purge rate should not result in excessive drawdown. Excessive drawdowns can cause water to cascade into the well, resulting in a significant sample bias, excessive turbidity, and entrapment of air in the filter pack, which will cause long-term sample bias. When purging wells in shallow water tables, locate the pump intake near the top of the water table. Water will enter throughout the screen interval and move toward the pump, flushing all stagnant water from the borehole. If bailers are used, remove the water from the top of the water level. 4.5 Purging Low -Yielding Wells Monitoring wells incapable of yielding three saturated borehole volumes within 24 hours are considered low -yielding wells. Low -yielding wells may be pumped at or below their recovery rates or purged to practical dryness. Purging the well to practical dryness will evacuate the stagnant water in the borehole, but cascading water and exposing the filter pack to air may bias subsequent samples. Preferably, purge low -yielding wells at or below the recovery rate so that the saturated filter pack is not exposed to air. Purging at or below the recovery rate can take a considerable amount of time and may not be practical in some cases. Purge volume requirements and stabilization of field Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 9 Ground Water• Sample Collection Standard Operating Procedure #5 parameters criteria cannot always be applied to low -yielding wells. However, you should still perform saturated borehole volume calculations and field parameter measurement. Purging low - yielding wells can be time-consuming. Identify low -yielding wells during well development so that careful planning and scheduling may be performed to increase efficiency in the field. Based on site - specific conditions and project objectives, evaluate whether to purge a well over an extended period of time or to purge it to dryness and collect a sample when there is sufficient recovery. Purging over time is preferred over dryness if at all practical. Development should provide enough site - specific information to allow the best method to purge a well to be assessed and to acquire representative samples before mobilizing to the field. 5.0 SAMPLING PROCEDURES This section gives the step-by-step procedures for collecting samples in the field. Record observations made during sample collection in the field notebook and field data sheet, as specified in Section 6 of this SOP. 5.1 Evacuating Well As stated previously, the purpose of well purging is to (1) remove stagnant water from the well and (2) obtain representative water samples from the geologic formation while minimizing disturbance to the collected samples. In most cases, purge the well three saturated borehole volumes and until field parameters stabilize. If the well has been pumped or bailed dry twice, it has been completely purged. Before purging a well, perform the following procedures: • Before evacuating or sampling, decontaminate all well probes, bailers, and other sampling devices as specified in SOP #1. Do not decontaminate dedicated downhole pumps. • Place clean plastic sheeting around the well. • Open the well and measure static water level following SOP #2. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 10 January, 2( Ground Water• Sample Collection Standard Operating Procedure #5 • Calculate the saturated borehole volume as specified in Section 4.2. • Calibrate field parameter measurement equipment as specified in SOP #9. • Obtain an initial sample from the bailer or purge pump for field measurements (e.g., temperature, conductivity, and pH measurements) and observation of water quality. • Begin purging three saturated borehole volumes of water with a bailer or pump. Take temperature, specific conductance, and pH measurements after evacuating each 1/4 to 1/2 (if practical) saturated borehole volume. Generally, pH values within ±0.1 pH unit and conductivity within ±10 percent throughout one saturated borehole volume indicate good stability of the water chemistry. If the chemistry is not stable, continue purging. • When evacuating a well using a pump, place the pump intake as follows: for low recovery wells (wells that pump dry at low rates), place the pump intake at the bottom of the screened interval for high recovery wells (wells that experience little drawdown with pumping), place the pump near the top of the water level to ensure the removal of stagnant water from the well bore. Purge the well at a rate that will not significantly draw down the well. • Bail or pump dry low -yielding wells during evacuation. If possible, let low - yielding wells recover before purging them dry again. If recovery is very slow, obtain samples as soon as sufficient water is available, but samples must be collected within 24 hours. 5.2 Obtaining Water Samples Ground water sample documentation, preservation, handling, packaging, and chain -of -custody procedures are specified in SOP #7. Collect ground water samples as follows: 1 Obtain samples for chemical analysis within two hours after purging is completed, if possible. For slow recovering wells, collect the sample immediately after a sufficient volume of water is available. Collect the water quality samples from within the well screen interval. 2. Assemble decontaminated sampling equipment. If bailers are used, use new nylon rope for each well for each sampling episode. Assemble the filtering apparatus. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 11 January, 2( Ground Water• Sample Collection Standard Operating Procedure #5 3 Make sure that sample labels have been filled out for each sample bottle as specified in SOP #7. 4. Place labels on bottle and tape over. 5 Lower the bailer slowly and gently into contact with the water in the well. Lower the bailer to the same depth in the well each time, within the screened interval. If submersible or bladder pumps are used to collect samples, reduce the discharge rate to about 100 milliliters per minute or as low as possible (Note: Some pumps may overheat at 100 milliliters per minute). Before collecting samples, pump the well at the reduced rate until the volume of water in the discharge hose has been purged. 6. Retrieve the bailer smoothly and empty the water in a slow, steady stream into the sample containers or direct the pump discharge into the sample containers. 7 Retrieve additional samples and slowly fill the sample bottles for all other analyses and QA/QC samples. Cap the sample bottles quickly. 8. Filter samples that require filtration with a disposable filter apparatus and peristaltic pump or electric submersible pump, as specified in SOP #7. 9. Slowly pour an unfiltered portion into the sample container for field parameter (e.g., pH, specific conductance, and temperature) analyses, perform the in -field analyses, and record the results. 1 Preserve samples as specified in SOP #7. 2. Place samples in baggies. 3 Place samples on ice in a cooler. 4. Record time of sampling. 5 Replace and lock well cap. 6. Complete field documentation and chain of custody record. 5.3 Field Quality Assurance/Quality Control Procedures and Samples Collect QA/QC samples during ground water sampling, as specified in the project planning documents. All QA/QC samples should be analyzed at the same time and in the same batches as the primary samples. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 12 Ground Water• Sample Collection Standard Operating Procedure #5 QA/QC samples help identify potential sources of sample contamination and help evaluate potential error introduced by sample collection and handling. Label all field QA/QC samples with QA/QC identification numbers (i.e., "02" for duplicate samples, "03" for field blanks, "04" for rinsate samples, and "MS" for matrix spike samples) and send them to the laboratory with the other samples for analyses. Duplicate Samples To check for the natural sample variance and the consistency of field techniques and laboratory analysis, collect duplicate samples side -by -side with primary samples. For ground water sampling, collect a duplicate sample while collecting the primary sample. Fill the primary sample bottle(s) first and the duplicate sample bottle(s) for the same analysis second until all necessary sample bottles for both the primary and duplicate samples have been filled. Use different filter and tubing for the primary and duplicate samples. Handle the duplicate ground water sample in the same manner as the primary sample. Assign the duplicate sample the QA/QC identification number "02"; follow SOP #7 for documentation, preservation, handling, packaging, and chain -of -custody procedures; store the sample in an iced cooler; and ship it promptly to the laboratory so that analyses can be performed within required holding times. Collect one duplicate sample for every 20 primary samples collected so that a rate of at least 5 percent of primary samples collected is achieved. For example, if you collect from 1 to 20 primary samples during a sampling event, collect one duplicate sample, and if you collect from 21 to 40 primary samples during a sampling event, collect two duplicate QA/QC samples. Collect duplicate QA/QC samples so that they represent the time of collection, different sampling teams, field conditions, and sampling equipment variability. For example, if ambient conditions are altered that could impact sample quality, the QA/QC sampling frequency may be increased. Collect duplicate samples throughout the sampling event, not just at the end. Field Blanks Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 13 Ground Water• Sample Collection Standard Operating Procedure #5 Collect field blanks by filling sample containers in the field with deionized water from the same source that is used for decontamination. Assign the sample the QA/QC identification number "03"; follow SOP #7 for documentation, preservation, handling, packaging, and chain -of -custody procedures; store the sample in an iced cooler; and ship it promptly to the laboratory so that analyses can be performed within required holding times. Collect one field blank sample for every 20 samples primary collected, so that a rate of at least 5 percent of primary samples collected is achieved. For example, if you collect from 1 to 20 primary samples during a sampling event, collect one field blank sample; and if you collect from 21 to 40 primary samples during a sampling event, collect two field blank samples. Rinsate Samples An equipment rinsate sample of sampling equipment is intended to be used to check if decontamination procedures have been effective. For the well sampling operation, collect a rinsate sample from the decontaminated sampling equipment (bailer or pump) and filter equipment before using it to obtain the sample. To collect a rinsate sample from a bailer, rinse deionized water over the decontaminated bailer and transfer it to the sample bottles. To collect a rinsate sample from an electric submersible pump, transfer the final deionized water rinse that is pumped through the discharge hose to sample bottles. The same parameters that will be analyzed in the ground water samples will be analyzed in the rinsate samples. Assign the rinsate sample the QA/QC sample identification number "04"; follow SOP #7 for documentation, preservation, handling, packaging, and chain -of -custody procedures; store the sample in an iced cooler; and ship it promptly to the laboratory so that analyses can be performed within required holding times. Collect one rinsate sample for every 20 primary water samples collected so that a rate for rinsate samples of at least 5 percent of primary samples collected is achieved. For example, if you collect from 1 to 20 primary samples during a sampling event, collect one rinsate blank sample, and if you collect from 21 to 40 samples during a sampling event, collect two rinsate blank samples. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 14 January, 2( Ground Water• Sample Collection Standard Operating Procedure #5 Collect rinsate blank samples so that they represent the time of collection, different sampling teams, field conditions, and sampling equipment variability. For example, if ambient conditions are altered that could impact sample quality, the QA/QC sampling frequency may be increased. Collect rinsate blank samples throughout the sampling event, not just at the end. Collect one rinsate blank sample for each type of sampling equipment used if less than 20 samples are collected (e.g., if 10 samples are collected by a bailer and 10 samples are collected by a submersible pump, you would collect two rinsate samples one from the bailer and one from the pump). Matrix Spike Samples Matrix spike (MS) samples are required to evaluate potential matrix effects on sample analyses for all inorganic parameters. The laboratory will spike matrix spike samples for the inorganic parameters. Depending on the specific laboratory and sample volume collected, the matrix spike samples may be split from an existing sample or may require a separate sample. To samples that you collect specifically for matrix spike analysis, assign the QA/QC identification "MS"; follow SOP #7 for documentation, preservation, handling, packaging, and chain -of -custody procedures; store the sample in an iced cooler; and ship it promptly to the laboratory so that analyses can be performed within required holding times. The samplers will identify all samples selected for matrix spike split analysis on the Chain of Custody Form. Specify one matrix spike sample for each sample shipment group of 20 samples or less. Laboratory Replicate Depending on the laboratory conducting the analysis, laboratory replicate samples may be required. Laboratory replicate samples are split from the primary sample in the laboratory and analyzed as part of the laboratory's QA/QC program. The laboratory replicate does not require a separate sample volume. The sample that the laboratory splits must be identified by the samplers on the Chain of Custody Form. One laboratory replicate sample will be specified for each sample shipment group of 20 samples or less. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 15 Ground Water• Sample Collection Standard Operating Procedure #5 5.4 Sample Documentation, Preservation, Handling, Packaging, and Chain of Custody The project work plan specifies sample containers and preservatives. Label and handle samples as described in SOP #7. 6.0 DOCUMENTATION 6.1 Ground Water Data Sheet Complete a ground water data sheet for ground water samples (Appendix A) at each sampling location. Be sure to completely fill in the data sheet. If items on the sheet do not apply to a specific location, label the item as not applicable (NA). The information on the data sheet includes the following: • Well number • Date and time of sampling • Person performing sampling • Depth to water before sampling • Volume of water purged before sampling • Conductivity, temperature, pH, and turbidity during evacuation (note number of well volumes) • Time samples are obtained • Sample identification number(s) • QA/QC samples taken (if any) • How the samples were collected (i.e., bailer and pump) Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 16 Ground Water• Sample Collection Standard Operating Procedure #5 6.2 Field Notes Keep field notes in a bound field book. Record the following information using waterproof ink: • • • • • • • • • • • Names of personnel Weather conditions Date and time of sampling Location and well number Condition of the well Decontamination information Initial static water level and total well depth Calculations (e.g., calculation of evacuated volume) Calibration information, sample methods used, or reference to the appropriate SOP Final sample parameters Sample control number. 7.0 REFERENCES ASTM D-4448 - 85a, Standard Guide for Sampling Groundwater Monitoring Wells, 1995 Annual Book of ASTM Standards, Vol. 04.08. Telesto Solutions, Inc. r: Iweldcountyldunnpit lrm\products\baselinestudies\groundwaterlappendixd\appendix a_sop05 gw sampling.doc 17 APPENDIX A GROUND WATER SAMPLING DATA SHEET GROUND WATER SAMPLING DATA SHEET IDENTIFICATION Project Number: Sample Location Date Start Time Stop time Page of Sample Control Number Samplers WEATHER CONDITIONS Ambient Air Temperature: °C❑ °F❑ Not Measured 0 Wind: Heavy 0 Moderate❑ Light❑ Precipitation: None ❑ Rain❑ Snow ❑ Heavy ❑ Moderate ❑ Light ❑ Sunny ❑ Partly Cloudy ❑ INITIAL WELL MEASUREMENTS (Measurements in feet made from top of well casino) Static Water Level Total Depth Top of Screen Filter Pack Interval Borehole Diameter(inches) 2 -inch = 0.1632 gal/ft 4 -inch = 0.6528 gal/ft 6 -inch = 1.4688 gal/ft Casing Volume: gallons Well Casing ID Well Casing OD Protective Casing Stickup Well Casing Stickup Feet of Water Well purged with: FINAL WELL MEASUREMENTS Static Water Level Total Depth Total Volume Purged Saturated Borehole Volume (gal) INSTRUMENT CALIBRATION pH Meter: Meter Number Buffer Measured Value Temp. °C Standard mS/cm Measured Value mS/cm Temp. °C Buffer Measured Value Temp. °C Standard mS/cm Measured Value mS/cm Temp. °C Turbidity Meter: Standard NTU Measured Value NTU Standard NTU Measured Value NTU FIELD PARAMETER MEASUREMENTS DURING PURGING Max Pumping Rate Conductivity Meter: Meter Number Time Volume (gallons) pH Cond. (µ S/cm) Temp. Turbidity Comments _ Visual Est. ❑ °C ❑ °F❑ Measured ❑ FINAL SAMPLE PARAMETERS Sample Date Sample Time i Discharge pH Cond. (µ,S/cm) Temp. (°C) Turbidity Visual cfs ❑ gpm❑ Est. ❑ Measu red ❑ Duplicate Sample -02 (sample control number/time ) Field Blank -03 (sample control number/time ) Rinsate Sample -04 (sample control number/time ) Matrix Spike -MS (sample control number/time ) (sample control number/time ) Notes: Sampler's Signature STANDARD OPERATING PROCEDURE #7 SAMPLE DOCUMENTATION, PRESERVATION, HANDLING, PACKAGING, AND CHAIN OF CUSTODY Prepared by: Telesto Solutions, Inc. 1601 Prospect Parkway, Suite C Fort Collins, CO 80525 January, 2005 TE LEST S O L U T I O N S* I pa C O k P 0 k A T E D Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE 1 2.0 RELATED STANDARD OPERATING PROCEDURES 1 3.0 NECESSARY EQUIPMENT 1 4.0 PROCEDURES FOR SAMPLE DOCUMENTATION 2 4.1 Sample Identification 2 4.2 Sample Labeling 3 4.3 Sample Containers, Preservatives, Filtration, and Holding Times 4 4.3.1 Sample Containers 4 4.3.2 Sample Preservation 4 4.3.3 Sample Filtration 4 4.3.4 Sample Holding Times and Analyses 5 4.4 Sample Packaging for Shipping 6 4.5 Sample Handling 7 5.0 SAMPLE DOCUMENTATION AND CHAIN OF CUSTODY 8 5.1 Field Notes 9 5.2 Chain Of Custody Procedures 10 6.0 REFERENCES 12 Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater l appendixdl appendix a_sop07 samp handling. doc 1 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 1.0 PURPOSE AND SCOPE This document defines the standard operating procedure (SOP) for sample documentation, handling, packaging, and chain of custody procedures. The American Society for Testing and Materials (ASTM) Standard Practice for Sampling Chain of Custody Procedures (D 4840-88) was used to prepare this SOP. 2.0 RELATED STANDARD OPERATING PROCEDURES This SOP supplements and is referenced by other SOPs; s; however, it does not reference any other SOP. 3.0 NECESSARY EQUIPMENT The following equipment may be used for sample labeling, filtering, packing, documentation, and chain -of -custody procedures: • • • • • • • • • Sample bottles Sample labels Appropriate preservatives Field book and data forms Chain of custody document Black permanent markers, black pens, pencils Clear plastic tape Fiber tape Custody seals Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 1 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 • • • • • • • • • • • Large (30 gallon) trash bags Gallon ziplock freezer bags Ice Sample shipment coolers Shipping labels Federal Express or UPS airbills Disposable 0.45 -micron filters Silicon or Tygon° tubing Peristaltic pump Watch Mobile phone or radio. 4.0 PROCEDURES FOR SAMPLE DOCUMENTATION 4.1 Sample Identification Assign unique sample identification numbers to collected samples in order to identify the sampling location and sampling sequence for each sample and sample date. These numbers are required for tracking the handling, analysis, and verification or validation status of all samples collected during monitoring. In addition, input the sample identification numbers into the project database to identify analytical results received from the laboratory. Divide sample identification numbers that are assigned into three fields, as shown in the following examples: Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 2 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 • Telestol-01-01-011705 (primary sample at Telesto-01) • CCS-03-02-950318 (duplicate sample at Cottonwood Creek Station 03) • 1\4W-01-3.5-4.0-01-960216 (primary sample at MW -01 from 3.5 to 4.0 feet). The first field (e.g., Telesto-01, CCS-03, or MW -0l-3.5-4.0) uniquely identifies the specific sample and is usually tied to the location, matrix sampled, and/or specific sample depths. If required, any additional site -specific identification can be encoded within the sample location field. The second field identifies whether the sample is a primary (01), a field duplicate (02), field blank (03), equipment rinsate (04), or matrix spike (MS) sample. The third and final field contains the date in a day month year format to allow data in the analytical database to be sorted easily. For example, the first sample identified above was collected on January 17, 2005 4.2 Sample Labeling Label each sample that is collected in the field for future identification. Before collecting the sample, a member of the sampling team will fill out sample labels as completely as possible with black waterproof ink. In most cases, sample labels need to be obtained from the analytical company. Each label will contain at least the following information: • Sampler's company affiliation • Unique identification number • Date and time of sample collection • Analyses required • Method of preservation used • Sampler's signature. After the label is completed and attached to the sample container, place clear tape over the label to protect and secure it to the bottle. Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 3 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 4.3 Sample Containers, Preservatives, Filtration, and Holding Times 4.3.1 Sample Containers Observe proper sample preparation practices (Section 4.5) to minimize sample contamination and potential repeat analyses due to anomalous analytical results. Before sampling, obtain commercially -cleaned sample containers from the analytical laboratory. Keep all documentation regarding sample bottle decontamination. Label the bottles as described in the Section 4.2. If sample bottles have not been pre -preserved from the laboratory, add preservatives in the field after sample collection. 4.3.2 Sample Preservation Samples are preserved to prevent or minimize chemical changes that could occur during transit and storage. Preservation methods include placing samples on ice and adding certain chemicals. If sample bottles are not pre -preserved, preserve samples immediately after collecting them to ensure that laboratory results are not compromised by improper coordination of preservation requirements and holding times. If sample bottles are pre -preserved, allow the sample to free fall into the container and do not allow it to overflow. Store samples on ice in coolers before and during shipping. Specific sample preservation requirements will be specified in the project work plan or sample plan and should be discussed with the laboratory before performing the sampling episode. Verify the proper pH of the sample after preservation. Use disposable pH test strips to quickly and conveniently verify proper preservation. Do not immerse the pH test strips directly into the sample bottle; instead, wet the strips with a small aliquot of the sample. 4.3.3 Sample Filtration Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 4 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 Filter samples that will be tested for dissolved cations and metals through a 0.45 -micron filter. Two common filtration methods use either disposable filter cartridges or disposable filters in a reusable filter holder. If possible, use disposable filter cartridges, because these will eliminate both decontamination and the possibility of cross -contamination. Attach the disposable filter cartridge to disposable silicon or Tygon° tubing and connect the combination to a peristaltic pump or directly to the electric submersible pump discharge. If reusable filter holders are used, be sure to decontaminate the filtration apparatus to avoid cross - contamination. Decontaminate filter holders as specified in SOP #1. Follow manufacturer's operating directions when operating filter holders and/or peristaltic pumps. Regardless of the filtration method used, flush the filter and tubing with at least 100 milliliters of sample water before collecting samples. An intermediate container may be required to hold the unfiltered sample. For the intermediate container, use a new, unused sample bottle or a container that has been decontaminated before use as specified in SOP #1. Filter samples that require chemical preservation before preserving them. 4.3.4 Sample Holding Times and Analyses Sample holding times are established to minimize chemical changes in a sample before analysis and/or extraction. A holding time is defined as the maximum allowable time between sample collection and analysis and/or extraction, based on the nature of the analyte of interest and chemical stability factors. Holding times will be specified in the project work plan or sample plan and should be discussed with the laboratory before performing the sampling episode. To minimize the possibility of exceeding holding times, send samples to the laboratory as soon as possible after collection by hand delivery or an overnight courier service. The chemical constituents, preservation, and holding times for samples will be summarized in the project work plan or sample plan. Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 5 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 4.4 Sample Packaging for Shipping To maintain the required storage temperature, ship the samples by the quickest route. Do not allow travel time to exceed 24 hours. Inform the analyzing laboratory of the shipment and of the carrier handling the shipment. Ship the samples in a sealed, ice -filled cooler of good quality. Place the appropriate completed chain -of -custody (COC) forms in each cooler. The field sampling team shall pack non -hazardous samples for shipment as follows: 1 Obtain an appropriately sized cooler of good quality to pack the samples. 2. Line the cooler with a large plastic trash bag. 3 Place each sample bottle in a appropriately sized freezer zip -lock plastic bag, and place the bottle upright in the large plastic trash bag lining the cooler. 4. Double -bag ice in 1 -gallon freezer zip -lock plastic bags. Use enough ice to keep the samples cool until they are received by the laboratory. Use more ice in the summer time. 5 If required, use vermiculite or a similar absorbent material to fill voids in the cooler. 6. Verify that all samples in the cooler have been documented on the COC form. Record the number of the Federal Express Air Bill or other shipping record document on the COC form. Sign and date the COC form and retain a copy of it. Place the COC form in a 1 -gallon zip -lock plastic bag and tape the COC form to the inside lid of the shipping cooler. 7 Seal the plastic trash bag liner with a signed custody seal. This will maintain the chain -of -custody if the cooler is inadvertently opened during shipment. 8. Seal the cooler and drainhole with plastic or fiber tape. 9. Attach signed custody seals across two sides of the cooler top. 10. Attach an address label with the laboratory address and phone number and with a return address and phone number. Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 6 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 11. Attach a Federal Express Air Bill or another shipping document. Retain a copy of shipping documents with the COC form. 12. Notify the laboratory of the sample shipment. 13. Verify that the laboratory receives the samples and that the samples were received in good condition and were sufficiently cool. Transfer the samples in a timely fashion. Holding times and instructions for preservation for the parameters to be analyzed will be specified in the work plan. The laboratory must receive the samples as soon as possible to ensure that analysis and, if the need arises, re -analysis can be performed within the required holding time. Carefully evaluate samples collected at hazardous waste sites to determine if they should be classified as dangerous goods. If they are hazardous, contact the shipping company to determine the proper shipping procedure. In some cases, state department of transportation laws may apply and should be considered. 4.5 Sample Handling General sample handling procedures will include the following: • Always make field measurements on a separate sub -sample, not on the sample that is sent to the laboratory for analysis, and discard it after the measurements have been made. • Sample bottles shall be properly decontaminated if they are not certified clean by the manufacturer or have not been pre -preserved by the laboratory. • Do not use bottles that have been used in the laboratory to store concentrated reagents as sample bottles. • Do not allow the inner portion of sample containers and caps to come into contact with bare hands, gloves, or other objects. Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 7 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 • If contact with air would change the concentration or characteristics of a constituent to be determined, secure the sample without contacting it with air and completely fill the container. • Keep sample containers in a clean environment away from dust, dirt, fumes, and grime. Keep vehicles clean to help eliminate contamination problems. • Field personnel shall wear disposable latex or nitril gloves when collecting samples. • Do not let foreign and metal objects contact acids and water samples. • Do not measure electrical conductivity on a sample that was first used to measure pH. Potassium chloride that diffuses from the pH probe can alter the conductivity of the sample. • Do not let samples stand in the sun. Store them in a cool place, preferably in ice chests with ice. • Ship samples to the laboratory without delay. 5.0 SAMPLE DOCUMENTATION AND CHAIN OF CUSTODY Documentation of the conditions and procedures used to collect, calibrate, treat, and handle samples and field data is one of the most important aspects of any monitoring program. Proper documentation provides sources to determine the integrity and applicability of the data. Carefully document all field activities in a logbook or on data sheets. Logbooks shall be bound with numbered pages and shall be written in with permanent black ink only. Record field activities in sufficient detail so that field activities can later be reconstructed from the notes. Any changes to the notes in the field book shall be made by drawing a single line through the incorrect material and initialing the markout. The following sections provide procedures and formats for documenting the field data and conditions at the time of sample collection, shipment to the laboratory, and laboratory analysis. While forms are provided to document specific tasks, the field sampling team shall maintain a field book for recording all other events, conditions, and observations during sampling. Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 8 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 5.1 Field Notes Documentation of observations and data acquired in the field provide information on sample acquisition, field conditions at the time of sampling, and a permanent record of field activities. Record field observations and data collected during routine monitoring activities with waterproof ink in a permanently bound weatherproof field log book with consecutively numbered pages or on field data sheets. Field notebook and data sheet entries will include at least the following information. Consult relevant sampling and decontamination SOPs to supplement this list. • Project name • Location of sample • Sampler's printed name and signature • Data and time of sample collection • Sample identification numbers • Description of sample (matrix sampled) • Sample depth (if applicable) • Number and volume of samples • Sample methods, or reference to the appropriate SOP • Sample handling including filtration and preservation, as appropriate for separate sample aliquots • Field observations • Results of any field measurements, such as depth to water, pH, temperature, specific conductance • Personnel present Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 9 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 • Decontamination procedures. Strike out changes or deletions in the field book or on the data sheets with a single strike mark and be sure that the original information remains legible. Record enough information to allow the sampling event to be reconstructed from the notes alone. Completely fill out field data sheets and do not leave blank lines. Write "Not Applicable" or "NA" on blank lines. All field books will be signed daily by the person who made the entries. 5.2 Chain Of Custody Procedures The custody of all samples shall be documented on COC forms provided by the laboratory. The COC forms will document possession of the sample from collection through laboratory analysis. Follow appropriate sample custody and documentation procedures precisely to preserve sample integrity and to ensure the validity of field and laboratory data. As a result, all sample data will be traceable from the time and location of sample collection through chemical analyses and to the time when data are used. As described above, record initial information concerning sample collection in the field log book or on data sheets. Information on the custody, transfer, handling, and shipping of samples will be recorded on a Chain -of -Custody (COC) Form. The objective of the custody identification and control system for the samples is to ensure, to the extent practicable, that the following occur: • All samples scheduled for collection are uniquely identified. • The correct samples are analyzed and are traceable to their records. • Important sample characteristics are preserved. Telesto Solutions, Inc. r: Iweldcountyl d.rnnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 10 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 • • • • Samples are protected from loss or damage. Any alteration of samples (e.g., filtration, preservation, and dilution) is documented. A forensic record of sample integrity is established. Legally traceable custody and possession records are maintained. For this project, a sample is defined as being in an individual's custody if the following conditions occur: • The sample is in that individual's actual physical possession. • The sample is in that individual's view after being in their physical possession. • The sample is in that individual's physical possession and then locked or otherwise sealed so that tampering will be evident. • The sample is maintained in a secure area that is restricted to authorized personnel only. General field custody procedures include the following: • As few people as possible should handle samples. • The field sampler is personally responsible for the care and custody of the samples collected until they are properly transferred. • When transferring the samples, the individuals relinquishing and receiving the samples will document the transfer by signing, dating, and writing the time of the transfer on the COC form. • The person responsible for delivering the samples to the laboratory or to the shipping carrier will sign the COC form, retain the third copy of the form, document the method of shipment, and send the original and the second copy of the form with the samples. Upon arrival at the laboratory, the person receiving the samples will sign the COC form and return the second copy to the Project Manager. • Custody seals must be attached so that it is necessary to break the seal to open the shipping container. The person affixing the custody seal will sign and date the seal. Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 11 January, 2005 Sample Documentation, Preservation, Handling, Packaging, and Chain ofCustody Procedures Standard Operating Procedure #7 Observe general documentation rules, including the use of black ink. Make any changes to the COC form by drawing a single line through the incorrect material and initialing the markout. Put a line through and initial blank lines on the COC form. Upon receiving the samples, the laboratory's representative shall do the following: • Sign and keep copies of the air bill. • Sign the COC form. • Measure and document the temperature of the samples. • Document the condition of the sample. • Notify the project manager if any breakage or improper preservation has occurred or if there is a discrepancy between the COC form, sample labels, and requested analyses. • Provide copies of the above documentation to the project manager with the final laboratory data package. 6.0 REFERENCES ASTM D-4840 - 88, Standard Practice for Sampling Chain of Custody Procedures, 1995 Annual. Book of ASTM Standards, Vol. 04.08. Telesto Solutions, Inc. r: Iweldcountyl dunnpit lrmlproducts\baselinestudieslgroundwater•l appendixdl appendix a_sop07 samp handling. doc 12 January, 2005 STANDARD OPERATING PROCEDURE #9 FIELD PARAMETER INSTRUMENT CALIBRATION AND MEASUREMENT Prepared by: Telesto Solutions, Inc. 1601 Prospect Parkway, Suite C Fort Collins, CO 80525 January, 2005 TELESTO SCtUtI ONS+ I NJ C: O R P O k A T E D Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE 1 2.0 RELATED STANDARD OPERATING PROCEDURES 1 3.0 pH METER CALIBRATION AND MEASUREMENT 1 3.1 Required pH Measurement Equipment 1 3.2 pH Meter Calibration Procedures 2 3.3 pH Measurement 4 4.0 CONDUCTIVITY METER CALIBRATION AND MEASUREMENT 4 4.1 Conductivity Measurement Equipment 5 4.2 Conductivity Meter Calibration 5 4.3 Conductivity Measurement 6 5.0 TURBIDITY METER CALIBRATION AND MEASUREMENT 7 5.1 Turbidity Measurement Equipment 7 5.2 Turbidity Meter Calibration and Measurements 8 LIST OF APPENDICES Appendix A pH Meter and Electrode Operator's Manuals Appendix B Conductivity Meter Operator's Manuals Appendix C Turbidimeter Operator's Manual Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. docl January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 1.0 PURPOSE AND SCOPE This document defines the standard operating procedure (SOP) for field parameter instrument calibration and measurement. This SOP describes the equipment and field procedures necessary to measure field parameters. Whenever water samples are collected, measure field parameters on a separate aliquot of the sample immediately after collecting the sample. This SOP describes how to properly calibrate instruments and measure pH, temperature, conductivity, and turbidity in the field. Many types of meters and methods are used to measure field parameters. The following sections: (1) list specific equipment requirements, (2) clarify the objectives of measuring field parameters to help the samplers obtain the proper equipment, and (3) describe the required apparatus for performing the measurements. 2.0 RELATED STANDARD OPERATING PROCEDURES This procedure is intended to be used with the following SOPs: SOP # Title 1 Equipment Decontamination 3.0 pH METER CALIBRATION AND MEASUREMENT 3.1 Required pH Measurement Equipment Use the following apparatus and supplies for measuring pH in the field: • Portable Hach One pH Meter Model 43800-00 with Hach One Combination pH Electrode Model 48600 or the EC 10 Portable pH/mV/Temperature Meter Model 50050 with the Combination pH Electrode with Temperature (Gel -filled) Model 50200 • Spare electrolyte cartridge, if required Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc 1 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 • Hach pH Electrode Storage Solution, Catalog No. 50301-49 • Extra batteries • Beakers • Buffer solutions of pH 4, 7, and 10 • Deionized or distilled water and wash bottle • Kimwipes or equivalent. Many chemical reactions are pH -dependent; therefore, pH is an important indicator of the state of the water. If possible, determine the pH in situ; if this is not possible, determine the pH from a water sample as soon as possible. Determine the pH by the electrometric method using standard buffer solutions. The electrometric method is the preferred method because of its greater accuracy and ease of measurement. A combination electrode, which combines the glass membrane electrode and the reference electrode, may also be used. Many portable battery -powered pH meters are available with a variety of features and abilities. The meter selected for field use should be rugged and it should be carried and stored in a foam -lined, water-resistant carrying case. The carrying case should have sufficient room to store extra pH buffers, electrode filling solution, spare electrodes, cables, and batteries. Meters recommended should automatically compensate for temperature and be capable of calibration with a two -point (two buffers) slope adjustment method. The meter should have a precision of ±0.05 units. 3.2 pH Meter Calibration Procedures Before collecting samples, calibrate the pH meter in accordance with the manufacturer's instructions using calibration solutions. The field sampling team shall record all pH measurement data, including calibration dates, readings, SMI meter number, and temperatures, on a data sheet or in a Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc2 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 field notebook. The field sampling team shall be familiar with the meter and shall follow the manufacturer's instructions for calibrating and using the meter. Appendix A presents the manufacturer's manual for the Portable Hach One pH Meter Model 43 800-00, Hach One Combination pH Electrode Model 48600, the EC 10 Portable pH/mV/Temperature Meter Model 50050, and the Combination pH Electrode with Temperature (Gel -filled) Model 50200. Calibrate the pH meter at the start of each sampling day and, as needed, when measuring waters with different pH values. Thoroughly document all calibrations, including the buffer readings and temperatures in the field book or data sheets. The field sampling team shall do the following when calibrating the meter according to the manufacturer' s procedures: • Condition new pH electrodes by soaking them for one hour in Hach pH Electrode Storage Solution. Do not condition pH electrodes that have been properly stored in Hach pH Electrode Storage Solution. • One of the buffer solutions used for the slope adjustment should bracket the anticipated pH of the sample, and the other buffer should always have a pH of 7. Ensure that the buffer solutions are at the same temperature and are as close as practical to the temperature of the water to be measured. Use buffer solutions once and then discarded them. • Before immersing the probe into the buffer or sample, rinse the probe with deionized or distilled water and blot it dry with a clean wipe. Protect the glass tip of the probe from abrasion and scratching. • Adjust the slope of the meter with two buffer solutions (2 -point slope adjustment) at least daily, and preferably twice per day to account for changes in conditions of the probe and meter and, as needed, when measuring waters with different pH values. • If the slope deviates significantly from its theoretical value, search for a potentially defective electrode or contaminated buffer solution. Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc3 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 3.3 pH Measurement The sampler shall measure pH in the field as follows: 1. Thoroughly check the pH meter, including the battery, and then calibrate the meter in the laboratory before taking it to the field. The buffers used for calibration should bracket the anticipated pH values to be measured. 2. Recalibrate the meter in the field before use. 3 If the pH is measured in a container, rinse the sample container with deionized water and then rinse it three times with the sample water prior to measurement. Rinse the pH probe with deionized water and, if possible, blot the probe dry with a clean wipe. Be sure to protect the fragile glass bulb at the end of the probe from damage. 4. Immerse the electrode into the water, allow the pH reading to stabilize, and monitor the drift of the instrument. Do not immerse the electrode above the top of the pH probe. When the pH reading stabilizes, record the temperature and the pH reading to the nearest 0.01 unit. 5 Between measurements, store the electrode in pH Electrode Storage Solution. 6. Measure samples within a short period of time after sampling and on a separate aliquot of the sample. 7 For the Hach One Combination pH Electrode Model 48600, dispense electrolyte if the reading becomes unstable, erratic, or if stabilization takes too long. An unstable reading may also indicate an air bubble in the reference line. Depress the dispenser button repeatedly until the bubble is expelled (5 to 10 clicks should be sufficient). Note that it is not necessary to refresh the electrolyte gel at the reference outlet between readings unless the reading is not stable. 8. Short-term electrode storage (between measurements/up to one week) will be in the Hach pH Electrode Storage Solution or cotton soaked in the Hach pH Electrode Storage Solution. Do not store in deionized water, as this will shorten the electrode life. 4.0 CONDUCTIVITY METER CALIBRATION AND MEASUREMENT Electrical conductivity, or specific conductance, is the ability of water to conduct an electric current and depends on the concentration of ions in solution. The relationship between conductivity and the concentration of dissolved solids is approximately linear for most natural waters. Changes in this Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc4 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 relationship indicate changes in the proportions of different salts and, therefore, changes in the sources of dissolved substances that enter the water body. Conductivity is usually measured in the field with a hand-held meter that is equipped with a conductivity cell and temperature probe. The meter measures the ability of water to conduct electricity across a specified distance and cross-sectional area. Numerous types of conductivity meters are available with various features and accessories. For measuring conductivity in the field, use a meter that can also measure temperature, has either a manual or automatic temperature compensator, and that displays conductivity directly in units of microsiemens per centimeter (µS/cm), corrected to a temperature of 25 degrees Centigrade (°C). Carry and store the meter in a foam -lined, water-resistant carrying case. The carrying case should have sufficient room to store extra calibration solution, spare probes, and batteries. 4.1 Conductivity Measurement Equipment Use the following apparatus and supplies for measuring conductivity in the field: • Hach CO150 Conductivity Meter Model 50150, Hach Conductivity/TDS Meter Model 44600, or Oakton® WD -35607-10 Hand -Held Conductivity Meter • Extra battery • Calibration solutions which bracket expected range of measurements • Deionized water • Wash bottle • Kimwipes • Beakers. 4.2 Conductivity Meter Calibration Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductslbaselinestudieslgr•oundwaterlappendixdlappendix a_sop09 inst calib and measur•ement.doc5 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 Before collecting samples, calibrate the conductivity meter using calibration solutions in accordance with the manufacturer's instructions (Appendix B). The sampler shall record all conductivity measurement data, including calibration dates, readings, SMI meter number, and temperatures, on a data sheet or in a field notebook. Reagent -grade potassium chloride (KCl) or other equivalent solutions are universally used as reference solutions to calibrate conductivity (specific conductance) equipment. The reference solutions are also used to check the accuracy of the meter, usually on a daily basis or, as necessary, at more frequent intervals. The conductivity of the reference solutions that are used to calibrate the meter should bracket the expected range of the conductivity of the water samples. Commercially prepared calibration standards are available from laboratory suppliers at many standard concentrations. The sampler shall calibrate the meter as follows: 1. Calibrate the meter according to the manufacturer's instructions. 2. Prepare or obtain standard reference solutions of a known value at a known temperature. Adjust the meter or the calibration solution to the correct temperature. 3. Adjust the meter to read the reference conductivity. Rinse the probe with deionized water and blot the probe dry. Re -immerse the probe in the reference solution and read the measured value to validate the corrected conductivity. 4.3 Conductivity Measurement Whenever possible, measure conductivity in situ or immediately after a sample is collected. If conductivity is measured within 24 hours, do not filter the conductivity sample beforehand. Record conductivity readings to the nearest 0.1µS/cm, corrected to 25°C . The sampler shall measure conductivity as follows: Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc6 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 1 Check the meter, including the battery, and calibrate the meter before taking it to the field. Buffer solutions used for calibration should bracket the expected conductivity values to be measured. 2. Recalibrate the meter in the field before use. 3 Rinse the probe with deionized water and blot the probe dry with a clean wipe, without wiping the plating on the cell. 4. Insert the probe into the sample solution. Immerse the tip to or beyond the vent holes and agitate the probe vertically. Make sure that air bubbles are not trapped near the temperature sensor. Allow the reading to stabilize before recording measurements. Measure and record the temperature of the sample. 5 During normal use, rinse the probe thoroughly with deionized water between measurements to minimize the buildup of interfering substances on the probe element. 6. Because the Model 44600 Conductivity Meter does not automatically turn itself off, verify that the unit is off before storing it. 5.0 TURBIDITY METER CALIBRATION AND MEASUREMENT One of the most sensitive and, therefore, the most representative field parameter measured during ground water sample collection is turbidity. Measure turbidity in the field with the Hach Portable Turbidimeter Model 2100P. The Hach Portable Turbidimeter Model 2100P manual is presented in Appendix C. 5.1 Turbidity Measurement Equipment Use the following apparatus and supplies for measuring turbidity in the field: • Hach Portable Turbidimeter Model 2100P • Extra battery • Calibration solutions which bracket expected range of measurements • Silicone oil • Deionized water Shepherd Miller, Inc. r:\weldcotenty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc7 January 2005 Field Parameter Instillment Calibration andMeasurement. Standard Operating Procedure #9 • Wash bottle • Liquinox nox solution • Kimwipes • Beakers. 5.2 Turbidity Meter Calibration and Measurements Calibrate the turbidimeter before mobilizing to the field. Once in the field, check the calibration by measuring standards of known turbidity as specified in the calibration and measurement procedures presented in Appendix C. The field sampling team shall record calibration checks, dates, and the SMI meter number on a field data sheet or in the field book. Note the following operational considerations: • Avoid prolonged exposure to ultraviolet light and sunlight. • Do not hold the instrument during measurements; place the instrument on a flat, steady surface. • Measure samples immediately to prevent temperature changes and settling. Avoid sample dilution when possible. Particles suspended in the original sample may dissolve or otherwise change characteristics when the sample temperature changes or when the sample is diluted, resulting in a non -representative sample measurement. • Handle measurement cells only by the top to minimize dirt, scratches, and fingerprints in the light path. • Always cap the sample cell to prevent spillage of sample into the instrument. • Always close the sample compartment lid during measurement and storage. • When oiling the sample cells, use only a thin coat of oil. Do not use excessive amounts of oil. The sampler shall measure turbidity as follows: Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductslbaselinestudieslgr•oundwaterlappendixdlappendix a_sop09 inst calib and measur•ement.doc8 January 2005 Field ParameterInsti71ment Calibration and Measurement. Standard Operating Procedure #9 Thoroughly check the meter, including the battery, and then calibrate the meter in the laboratory before taking it to the field. 2. Measure the turbidity of the standard and compare it to its certified value. 3 Clean the sample cell. 4. Fill the sample cell with sample. 5 Clean and oil the sample cell. 6. Place the cell in the meter. 7 Select the range. 8. Signal average the sample (if necessary). 9 Read and record the turbidity to 0.01, 0.1, or 1.0 NTU, depending on the range of the sample. 1 Empty and clean the sample cell. Shepherd Miller, Inc. r:\weldcounty\dunnpit lrmlproductsl baselinestudieslgr•oundwaterl appendixdl appendix a_sop09 inst calib and measurement. doc9 January 2005 APPENDIX A pH METER AND ELECTRODE OPERATOR'S MANUALS APPENDIX A pH METER AND ELECTRODE OPERATOR'S MANUALS TABLE OF CONTENTS pH Meters Portable Hach One pH Meter, Model 43800-00, Operator's Manual Hach EC 10 Portable pH/mV/Temperature Meter, Model 50050, Operator's Manual Electrodes Hach One Combination pH Electrode, Model 48600, Operator's Manual Combination pH Electrode with Temperature (Gel -filled), Models 50200 and 50205, Operator's Manual APPENDIX B CONDUCTIVITY METER OPERATOR'S MANUALS APPENDIX B CONDUCTIVITY METER OPERATORS MANUALS TABLE OF CONTENTS Hach Conductivity /TDS Meter, Model 44600, Operator's Manual Hach CO150 Conductivity Meter, Model 50150, Operator's Manual Oakton WD -35607-10, -20, -30 Hand -Held Conductivity Meters Operator's Manual APPENDIX C TURBIDIMETER OPERATOR'S MANUAL APPENDIX C TURBIDIMETER OPERATOR'S MANUAL TABLE OF CONTENTS Hach Portable Turbidimeter, Model 210013, Operator's Manual Attachment 11 ID HEC-RAS Figures 20220314 DRMS Adequacy_Review Response MASTER. docx TELEST® SOLUTION..'„ CG..O.. I [[ 0 co CD 4-J 4-J C C 7 0 2 cc 0 N E C) U 0 S. - a_ cc J r- 0 PREPARED FOR: PROJECT 360100 TASK 006-01D PREPARED BY: TELESIS Ram L IGL►OVCO_1 OO yr_891?cfs_20220314 3/1412022 Railr :ad Bridge 1 Legend E,= PE 1 3 F'F 1 _ Grit PF 1 Ground Ineff E► a n k: S=ta RAILROAD CROSSING OF BIG THOMPSON RIVER RIVER STAGE AT FLOW RATE OF 8,917 CFS LOVELAND READYMIX CONCRETE S a i l f I O N S+ y I-cJ R A 1 ( p 0 L co 7 O -I--' 2 cc 1O 4-1 Ui E U 0 IZ cc +,I O -J 0 Cross Section File Options Help River: BigThori mpsorn Reach: BT: Lower MDF ltd. I _ River Sta.: 43561. BR U Reload Data 4750 4E.- 4740- u 473E - --' lir ii BTP 1A, Lower Pun: BIGLOVCO 100isrr 8917cfs 2O.22O314 3/14/2022 Elate HI.,lI,j, .L, J � 1 L t ' -- I + lit 1 r' 1 .0E .t jr-__ice', 1&00 Station i;ft I 7000 1200 Legend EG PF 1 Ito:.PF1 C: rit PF 1 Ground Ineff Bank Sta PROJECT: 360100 TASK 006-01D PREPARED BY: TELESTQ HIGHWAY 257 CROSSING OF BIG THOMPSON RIVER RIVER STAGE AT FLOW RATE OF 8,917 CFS PREPARED FOR: LOVELAND READYMIX CONCRETE cc Sail I I 0 NS+ y I'cJR Al SG March 23, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Third Adequacy Review — Exhibits F, G and Appendix D Review Memo Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS/Office) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application Exhibit F, G and Appendix D adequacy response dated March 21, 2022 for the Dunn Pit, File No. M-2021-059. A copy of the third hydrology review memo from Patrick Lennberg dated March 23, 2022 is attached for review. The Division is required to issue an approval or denial decision no later than March 31, 2022, therefore a response to the following adequacy review concerns should be submitted to the Division as soon as possible. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Peter S. Hays Environmental Protection Specialist Enclosure — Third Hydrology Review Memo Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://mining.state.co.us Jared Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director ISe) DNR COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Date: March 23, 2022 To: Peter Hays, DRMS From: Patrick Lennberg, DRMS RE: Dunn Pit New Permit Application, Exhibits F, G and Appendix D Review Memo, File No. M2021-059 On September 25, 2021, I was requested to review Exhibits F, G and the Groundwater Baseline Study (Appendix D) of the Dunn Pit new permit application M2021-059, below are follow-up questions that should be addressed after reviewing the Applicant's second adequacy responses. Appendix D 16. Please provide copies of the completed groundwater data sheet(s) for each well sampled. In the future the Division will require submittal of these sheets along with other sample data. Why are there no field parameters recorded during well purging on the field sheets? If parameters were recorded please update the field sheets. Second Adequacy Response: Field parameters are not measured while purging because over three - borehole volumes are removed from the monitoring well during the sampling events. Field parameters are taken at the time of sampling and recorded on the field sheets. DRMS Follow-up: In SOP #5 Groundwater Sampling, the Division could not find where it is stated that a well may be purged for volume only. Specifically in Section 4.2 it states "To demonstrate that you have collected a representative ground water sample, measure field parameters during purging and purge the well until these parameters stabilize.". Please commit to collecting field parameters during purging per the Groundwater Sampling SOP and recording those measurements on the field sheet. The completed field sheets are to be submitted with the other sampling data. 20. In Appendix D, page 15-16, the Applicant states groundwater level and quality samples will be collected from all monitoring wells on quarterly basis. After one year the Applicant may approach the Division seeking to modify the plan along with justification for the modification. In the Groundwater Sampling and Analysis Plan Section 5.0, page 2, the plan states groundwater quality samples will only be collected from select wells and those wells are listed in Table 1. Table 1 only lists five wells to be sampled. Please explain the discrepancy and update accordingly. The Division is expecting all monitoring wells to be sampled on quarterly basis. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov/ Jared Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director 0037[;. Peter Hays Dunn Pit (M2021-059) Page 2 of 2 Second Adequacy Response: We revised Appendix D to reflect that we will collect water levels from all monitoring wells monthly, and water quality samples from the five wells listed in Table 1, quarterly. We cleaned up language in Appendix D in hopes of clearly showing the purpose of each monitoring well. Attachment 10 provides this revision. DRMS Follow-up: Please provide an explanation as to why the Applicant is not going to sample all monitoring wells at the site and only a sub -set? The Division is expecting all monitoring wells at the site to be sampled on a quarterly basis. If you need additional information or have any questions, please let me know. Sincerely, 44 -90 -- Patrick Lennberg Environmental Protection Specialist cc: Jared Ebert, DRMS Q March 24, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Third Adequacy Review - Inlet Protection Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application inlet protection adequacy response dated March 21, 2022 for the Dunn Pit, File No. M-2021-059. A copy of the inlet protection third review memo from Rob Zuber dated March 24, 2022 is attached for review. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Sincerely, Peter S. Hays Environmental Protection Specialist Enclosure — Third Inlet Protection Review Memo Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 ht t ps: / / m i ni ng. st at e. co. us Jared Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Date: From: To: leliONR 7M COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources March 24, 2022 Rob Zuber RDZ Peter Hays Interoffice Memorandum Subject: Dunn Pit (Permit No. M-2021-059), Third adequacy review addressing responses from Telesto Solutions, Inc., 21 March 2022 After reviewing the responses from Telesto (dated March 21, 2022), I have concluded that no additional information is needed related to my adequacy items. I had a concern related to Comment 6, related to the inlet weir for Cell 3, but email correspondence from Telesto clarified the situation and satisfied my concern. Jon Cullor of Telesto stated that, "... the NE corner of Cell 3 was originally graded to daylight at the elevation of the existing ground surface (no weir; left 'A of the figure). The re -graded Cell 3, as submitted in Feb 2022, included a uniformly graded inlet/outlet weir (right 'A of the figure). The inlet/outlet weir served to remove the low lying undulations in the existing ground surface. Before the addition of the weir, these existing ground undulations allowed water to enter Cell 3 in small amounts at relatively low flow rates." The figure that Jon refers to is included below. 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director O C D C) C C J w Z M oCad\DRMS\20220323 Ce cn C O U 713 0 C C O Q J v Date: 3/23/2022 6:40:02 P SCALE IN FEET PROJECT: 360100 TASK: 006-01 D DATE: 3/23/2022 DRWN BY: JC PREPARED BY: TELESTO 5 0 L U T i O j 5• I$ CORPORA 1 E D 4739.33 X 4739.04 4738.70 4738.29 4738.98 4739.01 4739.49 �� 739 7/ 4738.85 � " GJ SEPTEMBER 2021 SUBMITTAL 4740.46 4740.21 FEBRUARY 2022 SUBMITTAL 4739.96 NORTHEAST CORNER OF CELL C3 - ORIGINAL VS. UPDATED GRADING 4739.79 4739.56 PREPARED FOR: LOVELAND READY -MIX CONCRETE TELESTO SOLUTIONS• INCORPORATED March 24, 2022 Via Electronic Mail Mr. Peter Hays Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Subject: Dunn Pit, File No. 3rd Adequacy Review Dunn Pit New Permit Application, Exhibits F, G and Appendix D Review Memo, File No. M2021-059 Dear Mr. Hays: We appreciate the Division's third adequacy review of Loveland Ready -Mix Concrete, Inc.'s (LRM's) hydrology section of the 112c Permit Application for the Dunn Pit. This letter summarizes our response, and commitment regarding the Division's comments. We list the Division's comment in italics, followed by our response. Appendix D Comment 16 DBMS Follow-up: In SOP #5 Groundwater Sampling, the Division could not find where it is stated that a well may be purged for volume only. Specifically in Section 4.2 it states "To demonstrate that you have collected a representative ground water sample, measure field parameters during purging and purge the well until these parameters stabilize. ". Please commit to collecting field parameters during purging per the Groundwater Sampling SOP and recording those measurements on the field sheet. The completed field sheets are to be submitted with the other sampling data. Response 16 We appreciate the Division's comments and helped us realize that over time, the SOP has morphed into too much of a discussion/tutorial and does not make the steps clear as could otherwise be. Based on experience, and the construction of these wells, three well purge volumes is more than enough for the wells to stabilize. However, it is good practice to verify this. Thus, on LRM's behalf, Telesto commits to monitoring field parameters during well purging. We will compare the purged samples to one another as described in the SOP for consistency, and report that information on the completed field sampling sheets, which we will submit with the laboratory results. To: Mr. Peter Hays Date: March 24, 2022 Page 2 Comment 20 DRMS Follow-up: Please provide an explanation as to why the Applicant is not going to sample all monitoring wells at the site and only a sub -set? The Division is expecting all monitoring wells at the site to be sampled on a quarterly basis. Response 20 The monitoring plan is based upon the general flow directions monitored across the site and the initial monitoring results. Our goal with the monitoring plan is to 1) monitor groundwater flow directions, and 2) monitor groundwater quality up and down gradient from our planned mining activities. To meet our first goal, we infer groundwater flow directions from the water level measurements as shown in Figure 1. To meet our second, goal we identify up and down gradient wells from Figure 1 and choose representative wells to sample. Our upgradient wells measuring up gradient groundwater are: MW -01, MW -02, MW -03, MW -06 and MW -09, and our downgradient wells are: MW -05 (groundwater discharges to the river nearby), MW -07 and MW -08. MW -04 is internal to the site and will be mined out during mining of Cell 1. MW -10 is side gradient and is predicted to remain so during mining and after reclamation. Because the major ion and trace metal chemistry of the groundwater in the upgradient wells are similar, we chose one well north of the river and one well south of the river to represent upgradient conditions. Thus, we have good representation of groundwater chemistry both up and down gradient of the planned mining area (two wells north and three wells south of the river). Because we monitor every well for groundwater levels, we will detect any drastic changes in flow directions, and can alter the sampling locations if necessary. However, based on experience, model predictions, and the mining plan, we do not anticipate a drastic change in which wells represent up and down gradient groundwater conditions. 20220323_DRMS 3rdHydrology Adequacy_Review_Response .docx TELESTO To: Mr. Peter Hays Date: March 24, 2022 Page 3 We commit to the full five quarters of water quality sampling from these five wells. Based on initial sampling from all the wells, groundwater flow directions, lack of new activity surrounding the site, and monitoring wells representing groundwater quality on both sides of the river, there is no reason to believe that groundwater quality will change significantly, and water quality sampling from MW -01, MW -02, MW -04 and MW -10 will not add significant information to the dataset. We hope that we have addressed the issues to your and your staff's satisfaction. Please feel free to reach out to me directly if you have any questions. Sincerely, Telesto Solutions, Inc. . alter L. Niccoli, PE Principal/Senior Engineer WLN:tjg Enclosure cc: Weld County Clerk and Recorder 20220323 DRMS 3rdHydrology Adequacy Review Response .docx TELEST© %otf..! $., n •:p. ..* I . C FIGURE 1 GROUNDWATER FLOW DIRECTIONS AND WQ SAMPLING LOCATIONS DUNN PIT, LOVELAND READY MIX P.O. BOX 299, LOVELAND, CO, 80539 S O L U T 14 N S. oveI1rid Co1-yit; (4.) 7 U 484 771)4 Receipt from Weld County Clerk and Recorder For: Knox Pit, DR/I'S Permit Application Ale: M -2O21 -O59 Responses to 112c Permit Application 3r° Adequacy Review on Hydrology Dated 3f24/2022 Received: Received Y(5iqnatcire) 40 April 15, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road P.O. Box 299 Loveland, CO 80539 Re: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Third Adequacy Review Mr. Fancher, The Division of Reclamation, Mining and Safety (Division/DRMS) reviewed the contents of the Loveland Ready -Mix Concrete, Inc. (LRM) 112c permit application adequacy response received on March 23, 2022 for the Dunn Pit, File No. M-2021-059 and submits the following comments. The Division is required to issue an approval or denial decision no later than April 30, 2022, therefore a response to the following adequacy review concerns should be submitted to the Division as soon as possible. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 1. Please provide an affidavit or receipt indicating the date on which the revised application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). Geotechnical Stability Exhibit 2. The Applicant provided the requested Slide -2D modeling data files in electronic format, however the Division was unable to convert the data to Clover Technology's Galena slope stability software. The Division reviewed and accepted the updated geotechnical stability analysis dated February 9, 2022. 3. The Applicant states updates in Section 6.1.2 and 6.2 of Exhibit D specify that LRM mine at slopes and with appurtenances indicated by the slope stability analyses presented in Appendix B1 in the adequacy response. Section 6.1.2 was revised to include "an excavator stationed on a moveable platform..." in the previous submittal. The Applicant responded, Attachment 6 contains the updated Exhibit D with the platform language added to Section 6.2. The Division did not receive the updated version of Exhibit D. Physical: 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 Mailing: DRMS Room 215, 1001 E 62nd Ave, Denver, CO 80216 https://drms.colorado.gov Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director Ol CI:]:�f. tip' `. • �.. Dunn Pit Third Adequacy Review Page 2 of 2 April 15, 2022 Please provide an updated copy of Exhibit D indicating the geotechnical report requires the excavator to utilize a working platform roughly 16'X20' to distribute the excavator load. 4. Please revise Exhibit D to indicate the mined slope of 2H:1V as required by the geotechnical report. Please be advised the Dunn Pit application may be deemed inadequate, and the application may be denied on April 30, 2022, unless the above mentioned adequacy review items are addressed to the satisfaction of the Division. If more time is needed to complete the reply, the Division can grant an extension to the decision date. This will be done upon receipt of a written waiver of the Applicant's right to a decision by April 30, 2022 and request for additional time. This must be received no later than the decision date. If you have any questions, please contact me at peter.hays@state.co.us or (303) 866-3567 Ext. 8124. Peter S. Hays Environmental Protection Specialist Ec: Jared Ebert; Division of Reclamation, Mining & Safety Stephanie Fancher-English; Loveland Ready -Mix Concrete, Inc. Walt Niccoli; Telesto Solutions, Inc. TELESTO 5 O L U T l O N 5• I N C O K P O K A 1' E L7 April 15, 2022 Via Electronic Mail Mr. Peter Hays Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 Subject: Loveland Ready -Mix Concrete, Inc., Dunn Pit, File No. M-2021-059, 112c Permit Application Third Adequacy Review Response Dear Mr. Hays: We appreciate the Division's third adequacy review of Loveland Ready -Mix Concrete, Inc.'s (LRM's) section of the 112c Permit Application for the Dunn Pit, and acceptance of the geotechnical evaluation dated February 9, 2022. As we understand, the remaining issue is ensuring that Exhibit D (mining plan) is consistent with the geotechnical evaluation results and the slopes shown in Exhibits C and F. Please find attached an updated version of Exhibit D. Also attached to this letter is a receipt from the Weld County Clerk and Recorder's office acknowledging receipt of this updated Exhibit D. We hope that we have addressed the issue to your and your staff's satisfaction. Please feel free to reach out to me directly if you have any questions. Sincerely, Telesto Solutions, Inc. / w !°/ x.e.#€ 4 1 Walter L. Niccoli, PE Principal/Senior Engineer WLN:tjg Enclosure cc: Weld County Clerk and Recorder 6.0 EXHIBIT D — MINING PLAN (UPDATED 4/15/22) This exhibit provides the information required by Section 6.4.4 of the Rules and Regulations. 6.1 Mining Methods and Surface Disturbance Section 6.1 provides the information required in Sub -section 6.4.4(a) Rules and Regulations. The entire site consists of approximately 114.25 acres. There are approximately 76 acres that LRM will utilize for mining. Approximately 38 acres of the site will consist of boundary offsets, perimeter buffering the main access road, the Big Thompson River corridor, and stormwater management areas. 6.1.1 Site Preparation The site will first be cleared of unneeded existing structures (old fencing and cattle chutes). The topsoil, if present, material will be stripped as each Cell is mined. Stripping will occur in phases or "strips" approximately 1/8th to 1/4th of the size of the Cell to expose the active mining area. The stripped material will be stockpiled adjacent to the active mining area. Scrapers, front-end loaders, excavators, and bulldozers may be used for stripping. Topsoil stockpiles, ditches and grading may be used to direct stormwater into the mining cells. Exhibit C shows the quantities of topsoil for each phase. A typical topsoil stockpile berm size will be 36 feet in width, 10 foot high, or 6.6 sq-yd per ft. The topsoil stockpiles will be stabilized, and erosion control devices will be installed. If the topsoil stockpiles will be in place for 180 days LRM will seed to produce a vegetated cover. An access bridge across the Big Thompson River will require a 404 Permit to construct. As part of the 404 Permit the bridge will be installed and analyzed to certify that it does not create a rise in the floodway. Haul roads will be established and stabilized during site preparation. Loveland Ready -Mix, Concrete, Inc. 6 updated exhibits d 220415.docx September 2021 TELESTO 6.1.2 Mining The sand and gravel deposit will be mined to bedrock. An excavator stationed on a moveable platform will be used to mine the material wet. The mining excavations will not be dewatered. The mining will be done in three Cells ranging in size from 11 to 36 acres, with excavation conducted to bedrock. A previous geotechnical report (CE. Maguire Subsoil Exploration Report, 1978) and the recently installed groundwater monitoring wells have established the bedrock surface at approximately 28 to 30 feet below ground surface. Wet mining will be completed from a long -reach excavator stationed on a movable 16'x20' (minimum) platform. Because the material is mined "wet", mined slopes will be no steeper than 2H:1 V, consistent with slope stability calculations provided in Appendix B 1. The operator will develop and comply with a Stormwater Management Plan (SWMP). Berms and sloping of ditches will divert flow from all disturbed areas back into the mined cells. The operator will notify the Division of Mine Safety and Reclamation (DRMS) in the event of a reportable spill. Mined material will be stockpiled adjacent to the mining cells. The material will remain adjacent to the mining cell and drainage water will flow back to the mined cell. The material then will be loaded into haul trucks and transported offsite. 6.1.3 Imported Material Currently there are no plans to import material from other sites. Loveland Ready -Mix Concrete, Inc. (LRM) is aware that in accordance with Rule 3.1.5(9) of the Construction Materials Rules and Regulations, if any offsite material is used as backfill, a notarized letter will be submitted to the DRMS indicating the materials are inert. 6.2 Earthmoving Section 6.2 provides the information required by Sub -section 6.4.4(b) of the Rules and Regulations. Loveland Ready -Mix, Concrete, Inc. 7 updated exhibits d 220415.docx September 2021 TELESTO Topsoil will be excavated with front-end loaders, scrapers, or other similar equipment. The topsoil will be placed in berms at the edge of the active mine phase and stabilized as required. The construction material will be mined with an excavator stationed on a movable, 16'x20' (minimum) platform. The construction material will be transported offsite in 15 -ton tandem dump trucks. 6.3 All Water Diversions and Impoundments Sub -section 6.4.4(c) requirements of the Rules and Regulations are described in this section. The operator plans to mine the material wet; no dewatering activities are proposed. Stormwater that flows on to the site will be captured and contained in the cell(s) or allowed to flow through the site using historical channels in undisturbed portions of the site. Likewise, stormwater generated on site in disturbed areas will flow to the mining cells. Stormwater from the access road will be diverted back to the cell(s). The operator will develop and comply with a Stormwater Management Plan (SWMP). 6.4 Working Area Sub -section 6.4.4(d) of the Rules and Regulations requires a description of the size/areas of the mine to be worked at any one time. The proposed permit site will be divided into three cells and mined in phases. Cell 1 (C2) contains 36.7 acres, Cell 2 (C2) contains 10.9 acres, and Ce113 (C3) contains 28.3 acres. Exhibit C shows the progression of the mining phases through each cell. Table 1 shows cell sizes, aggregate, topsoil, and quantities for each cell. Table 1 Cell Area (AC) Total Volume (YD3) Topsoil Volume (YD3) Gravel Volume (YD3) Gravel Weight (Tons) Cl 36.7 1,404,361 50,520 1,353,840 2,166,145 C2 10.9 414,877 1,399 413,478 661,565 C3 28.3 1,101,661 28,137 1,073,524 1,717,639 (C1,C2,C3) 75.9 2,920,898 80,056 2,840,843 4,545,348 Estimated Mining Quantities Loveland Ready -Mix, Concrete, Inc. updated exhibits d 220415.docx 8 September 2021 TELESTO 6.5 Timing of Mining and Reclamation As required by Sub -section 6.4.4(e) of the Rules and Regulations, an approximate timetable to describe the mining operation is needed. The timetable establishes the relationship between mining and reclamation during the different phases of a mining operation. Mining operations are anticipated to begin soon after all permits are in place. The extraction rates are expected to be approximately 200,000 tons of construction material per year. Production rates will vary depending on market demands. LRM plans to conduct concurrent reclamation as mining progresses. Mining and reclamation are planned in five - acre increments. This will allow for safe and efficient operations with detail to slope stability and concurrent reclamation Exhibit C. Cell 1/C1 Mining will begin with Cell Cl for the first 10 to 12 years of operation. Approximately 37 acres will be mined in 7 phases during this time with a total of 2,166,145 tons of gravel. Cell 3/C3 Mining will continue into C3 and will last about 8 years. Cell C3 is approximately 28 acres, will be mined in 5 phases to the mining access road; mining will then begin at Cell 2. As Cell 2 is nearing completion, mining will recommence on Cell 3 along the west side of the access road working from north to south. Cell 3 will generate 1,717,639 tons of gravel. Cell 2/C2 Once mining reaches the access road from Cell 3, mining will be focused on Cell 2. Cell 2 will be conducted in 3 phases. Cell C2 is approximately 11 acres, will be mined in 4 phases and take a little over 3 years for a total of 661,565 tons of gravel. The operator will Loveland Ready -Mix, Concrete, Inc. 9 updated exhibits d 220415.docx September 2021 TELESTO comply with the performance standards of Section 3.1 and this operation is not intended to be an intermittent operation as defined in Section 34-32.5-103(11)(b), C.R.S. Reclamation and mining will be conducted concurrently when practicable to minimize disturbance and material handling. See the Mining Plan Map in Exhibit C for Cells and phases to be mined. 6.6 Deposit As described in Sub -section 6.4.4(f) of the Rules and Regulations, narrative and figures are provided in this section to describe the deposit. Figurel provides a generalized cross-section of the deposit. The deposit to be mined is the Big Thompson River alluvium, which consist of unconsolidated silt, sand, and gravels. The deposit ranges from approximately 25 to 28 feet thick and is overlain by approximately 1 to 2 feet of sandy to clay loam topsoil. A conceptual cross-section though the site is shown in Figure 1. The stratum below the target deposit consists of a weathered shale bedrock. 6.7 Commodities Sub -section 6.4.4(g) of the Rules and Regulations requires that the applicant identify the primary and secondary commodities to be mined/extracted and describe the intended use. The primary commodities to be mined are gravel, sand, and fill. The material will be used as aggregate in concrete and construction materials. 6.8 Incidental Products LRM does not plan to produce any incidental products, and thus, there is no information to report under Sub -section 6.4.4(h) of the Rules and Regulations. Loveland Ready -Mix, Concrete, Inc. 10 updated exhibits d 220415.docx September 2021 TELESTO 6.9 Explosives The Rules and Regulations require a description of the use of explosives [Sub -Section 6.4.4(i)]. No explosives will be used in conjunction with the mining (or reclamation) on this site Loveland Ready -Mix, Concrete, Inc. 11 updated exhibits d 220415.docx September 2021 TELESTO Receipt From Weld County Clerk and Recorder For: Knox Pit, DR/VIS Permit Application No: M-2027-059 Responses to 772c Permit Application 3rd Adequacy Review Dated 4/75/2022 APP 15 2022 Received: (Date) Received by: (Signature) SG April 28, 2022 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Brad Fancher Loveland Ready -Mix Concrete, Inc. 644 N. Namaqua Road PO Box 299 Loveland, CO 80539 Re: Dunn Pit — File No. M-2021-059, Loveland Ready -Mix Concrete, Inc., 112c Construction Materials Reclamation Application Dear Brad Fancher: On April 28, 2022 the Division of Reclamation, Mining and Safety concluded its review of the Construction Materials Reclamation Permit Application submitted to the Division on September 13, 2021. The decision reached by the Division is: Approve. The amount of financial warranty set by the Division for this operation is $398,000.00. You must submit a financial warranty in this amount and a performance warranty in order for us to issue a permit. In the event you have requested a financial warranty form, we will provide you with the applicable form. If you have not, please select a type of financial warranty from Rule 4.3, and then contact us so that we can provide you with the appropriate warranty form. We have enclosed a performance warranty form with this letter for your use. PLEASE NOTE THAT MINING OPERATIONS MAY NOT COMMENCE UNTIL A PERMIT HAS BEEN ISSUED BY THE DIVISION AFTER RECEIPT OF YOUR FINANCIAL AND PERFORMANCE WARRANTIES. A PERMIT CANNOT BE ISSUED UNTIL WE HAVE VERIFIED THE ADEQUACY OF YOUR FINANCIAL AND PERFORMANCE WARRANTIES. M-2021-059: Approved Surety and Acreage Reclamation Liability (Required Surety): $398,000.00 Approved Permit Acreage: 114.25 Approved Affected Acreage: 114.25 If you have any questions, please contact me by telephone at (303) 866-3567 x 8124, or by email at Peter.hays@state.co.us Sincerely, /7).(-7/ Peter S. Hays Environmental Protection Specialist Ec: Jared Ebert, DRMS Physical Address: 1313 Sherman Street, Room 215, Denver. CO &0243 P 303.866.3567 F 333.832.8136 mailing Address: DRYS Room 215, 1001 E 52nd Ave, Denver. CO 80215 nttps;+?drn .cc.orado„ov Jared S. Polls, Gov_gm_oLd Dan Gibbs, Executive Directcr I Virginia Brannon, Director SG COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources PERFORMANCE WARRANTY Permittee/Operator: Loveland Ready -Mix Concrete, Inc. Operation known as: Dunn Pit Permit Number: M-2021-059 This form is approved by the Colorado Mined Land Reclamation Board ("Board") pursuant to C.R.S. 34-32-117 of the Colorado Mined Land Reclamation Act and C.R.S. 34-32.5-117 of the Colorado Land Reclamation Act for the Extraction of Construction Materials. All parties are on Notice from this Document that: The above listed Operator provides this warranty to the Board in conjunction with a reclamation Permit to conduct the above described mining operation on certain lands in Colorado. The "Affected Lands" are described in the above listed reclamation Permit, and include any Permit Amendment(s) approved by the Division of Reclamation Mining and Safety ("Division"). The Colorado Mined Land Reclamation Act, C.R.S. 34-32-101 et seq. ("Hard Rock Act"), and the Colorado Land Reclamation Act for the Extraction of Construction Materials, C.R.S. 34-32.5-101 et seq. ("Construction Materials Act"), both require a permit issued by the Board to include a written promise by the Operator to comply with all requirements of the Hard Rock and Construction Materials Acts (referred to herein together as "Acts"). Through the terms and conditions of this performance warranty and Permit, the Operator agrees to be bound by all requirements of the Acts and all Mineral Rules and Regulations of the Board for Hard Rock, Metal, and Designated Mining Operations (2 C.C.R. 407-1) and all Mineral Rules and Regulations of the Board for the Extraction of Construction Materials (2 C.C.R. 407-4) (referred to herein together as "Rules"). The Operator hereby provides the Board warranties of performance pursuant to C.R.S. 34-32-117(2), (3), and (4)/C.R.S. 34-32.5-117(2), (3), and (4), and promises the Board it will comply with all applicable requirements of the Acts and Rules. The Operator hereby promises the Board it will comply with all of the terms of the reclamation Permit, including any Permit Amendment(s) approved by the Division. This performance warranty obligation of the Operator shall continue until the Operator's liability is released by the Board. The Operator promises to be responsible for reclamation costs up to the amount established by the Board and incorporates its financial warranty to this performance warranty. The Operator agrees to maintain a financial warranty (or warranties) in good standing for the reclamation costs for the entire life of the Permit. The amount of the financial warranty shall be sufficient to assure the completion of reclamation of affected lands if the Division has to complete such reclamation due to forfeiture. If the Board determines the Operator is in default under this performance warranty and the Operator fails to cure such default, the Operator's financial warranty shall be subject to forfeiture pursuant to C.R.S. 34-32-118/34-32.5-118. This performance warranty by the Operator is perpetual and shall remain in full force and effect until all obligations have been met and all associated financial warranty is released by the Board. Any release of liability in a succession of Operators shall comply with C.R.S. 34-32-119/34-32.5-119. The provisions hereof shall bind and inure to the benefit of the parties hereto and their successors and assigns. SIGNED, SEALED AND DATED this day of (date) Operator: Loveland Ready -Mix Concrete, Inc. Signature: Name: Title: STATE OF COUNTY OF (month) (year) NOTARIZATION OF OPERATOR'S ACKNOWLEDGEMENT The foregoing instrument was acknowledged before me this day of by: as (name) Notary Public: My Commission Expires (date) ss. (month) (year) of Loveland Ready -Mix Concrete, Inc. (title) (Operator) APPROVED: State of Colorado Mined Land Reclamation Board Division of Reclamation, Mining and Safety By: Virginia Brannon Division Director Date Executed: Hello