The URL can be used to link to this page

Browse Search

Home My WebLink About20241725.tiffJ&T Consulting, Inc. June 20, 2024 Mr. Rob Zuber Environmental Protection Specialist State of Colorado Division of Reclamation, Mining, and Safety Physical Address: 1313 Sherman Street, Room 215 Denver, CO 80203 Mailing Address: Division of Reclamation, Mining and Safety, Room 215 1001 East 62nd Avenue Denver, CO 80216 RECEIVED JUN 2 4 2024 WELD COUNTY COMMISSIONERS 1 PAGE OF DOCUMENT INCLUDED IN PAPER FILE. REMAINDER RETAINED ELECTRONICALLY IN TYLER. RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025, 112c Permit Application, Fourth Adequacy Review and Cost Estimate Dear Mr. Zuber, WW Clyde & Co. (WW Clyde) has received the Division's Fourth Adequacy Review letter dated June 20, 2024. Below are the comments and the corresponding responses that we have provided to address the comments. Comments 1. Please update the Wildlife Exhibit (Exhibit H). In the last paragraph of this exhibit, you commit to an additional raptor survey. However, you should add additional language stating that, based on the results of this survey, you will coordinate with the Division and Colorado Parks and Wildlife and update the Mining Plan, as appropriate, to limit wildlife impacts. Response: Exhibit H has been updated and is attached. See grey highlighted text. Previous adequacy review updates are in yellow and cyan highlighted text. 2. The second item is related to the Division's Reclamation Cost Estimate (RCE). Please add the cost of constructing the riprap rundown to Exhibit L. Also include a discussion of how this cost item was developed, including the volume of rock and source. Response: Exhibit L has been updated to include the cost of constructing the riprap rundown. The cost we have provided is based on bid costs for the Perry Pit Spillway repair that was bid in October 2023 and constructed in February/March 2024. The source of riprap was from Asphalt Paving's Quarry near Golden. The bedding was supplied from another gravel pit north of Fort Lupton. I have also attached part of the bid schedule from Kelly Trucking's bid for these costs for reference. The quantities that we have for the Bernhardt Pit are larger than this project so using the cost from this project is conservative as there would likely be a price reduction because of the larger quantity of riprap and bedding. As far as the slurry wall cost's we were at $5.50 per face foot which equates to $198 per lineal foot. This cost we believe is accurate because the average depth of the slurry wall is 36 feet and can be constructed with a PC 490 Tub' i jRtv ;ju) 1(317)4 ec.: ?L(6tlMLPfr1prLLkK Ito (CI -H GCf DPI N41 s S) li12i+1z4 zoZL-1- !'1 Z5 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Fourth Adequacy Review and Cost Estimate June 20, 2024 -2- excavator or equivalent (we just finished a similar wall with a PC 490 that was 30 feet in depth but we didn't bid that project so I don't have their cost information). We also have bid numbers on a slurry wall that was averaging 72 feet deep and was $6.65 per square foot for the individual item and it is about $7.50 per sf when you add in the other items for a total cost and this one requires a PC 1250 excavator or equivalent which is much larger and more costly. I have provided the bid from Odin Construction Solutions for the Derr Pit North Slurry Wall bid for reference. WW Clyde appreciates your consideration of this adequacy review response. Please feel free to contact me with any questions or comments. Sincerely, 7-07 e, J.C. York, P. J&T Consulting, Inc. Attachments: 1. Updated Exhibit H 2. Updated Exhibit L with cost references gm VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 EXHIBIT H Wildlife Information The project area was surveyed for general wildlife habitat by Ecological Resource Consultants (ERC). The Screening Report for Federal and State Listed Threatened and Endangered Species from ERC is attached which describes the wildlife habitat present on the site and the common species that may be found in the habitat area. ERC conducted this screening for federal and state threatened, endangered and species of concern for the approximately 134 -acre survey area. The following provides key items identified as part of the report: 1. Two primary land use class/vegetation cover type exists within the survey area. Habitat within the survey area is characterized as the Great Plains Ruderal Grassland and Shrubland (98%) and disturbed (2%). Historic land use for agricultural practices has led to degradation of the native vegetation community. 2. Generally, there are features on the survey area and the surrounding area that provide general habitat for local songbirds, raptors, and small to mid -size mammals. However, habitat within the survey area is somewhat degraded and of lower ecological value from a wildlife perspective due to historic and current land use for agriculture, which has restricted overall growth and establishment of vegetation. The South Platte River and adjacent eastern cottonwood floodplain and woodland, provides suitable habitat for wildlife species and MBTA species. The South Platte River and associated vegetative community will not be impacted by the proposed project. 3. Non -raptor birds No non -raptor migratory bird nests were observed within the survey area. However, prior to vegetation removal a nest survey should be completed to ensure that no nests have become established within the survey area and active nests, if any, are not disturbed. Non -eagle Raptors No non -eagle raptor nests were observed and no CPW mapped non -eagle raptor nest protection zones are located within the survey area (CPW 2023a). However, nest activity status can vary seasonally and from year-to-year. Future land use changes may require additional nest surveys (generally between February 1 and September 15 (CPW 2020)) to determine activity status within % to ' mile of the survey area to ensure compliance with CPW recommendations. Eagles CPW SAM data identifies a bald eagle nest listed as "destroyed" being directly northeast of the survey area. Per CPW monitoring logs, the eagle nest has been inactive from 2019-2021, and destroyed in 2022. A field visit by ERC on January 25, 2023 confirmed the identified nest no longer exists and the nest area is no longer being utilized with no efforts by eagles to rebuild the nest. Therefore, the nest site and the survey area is not subject to any restriction per CPW protective buffer zone recommendations or USFWS Bald Eagle Protection Act. 4. No federally listed threatened and endangered species and/or habitat protected under the ESA were identified within the survey area. The survey area is not within designated critical habitat of any federally listed species. The vegetation community and features rJ&T Consulting, Inc. WW Clyde Bernhardt Sand and Gravel Pit DRMS 112 Permit Application within the survey area were investigated as potential habitat for federally listed species. Any future land use changes will result in No Take on any federal listed species, their habitats, or proposed or designated critical habitat. 5. No State listed threatened or endangered species and/or habitat protected by CPW under Colorado Statute Title 33 were identified within the survey area. The vegetation communities within the survey area were investigated as potential habitat for state listed species. Any future land use changes will have no effect on any state listed species, their habitats, or proposed or designated critical habitat. ERC 2023 provided a detailed evaluation of potential critical wildlife habitat and use within the Permit Area. The Permit Area was determined to be comprised of 100% ruderal grassland and disturbed lands which is generally considered low -value wildlife habitat. No federal or state listed threatened and endangered species/habitat were identified. Following the preparation of ERC 2023, CPW issued ("-March 2023) new wildlife Species Activity Mapping (polygons) that depict the Permit Area within Mule Deer High Priority Habitat (HPH). This CPW polygon encompasses more than 955 square miles (-611,000 acres) acres along the South Platte and Big Thompson Rivers (refer to Figure 1 in ERC's Adequacy Review Responses to CPW below). The Permit Area represents less than 0.02 `)/0 of this entire HPH polygon. In order to minimize potential disturbances to the HPH, the project will implement CPW recommendations addressed in Item 10 of their comment e-mail to DRMS also attached below. No other critical habitat or seasonal wildlife use has been identified within the Permit Area. It is not anticipated that operations (increased traffic, noise, light) will have a significant effect on wildlife in the area. Refer to ERC 2023 for further explanation. Attached are ERC's Adequacy Review Responses to CPW's comments and the Screening Report for Federal and State Listed Threatened and Endangered Species. W.W. Clyde & Co. commits to conducting a raptor survey prior to mobilization of earth -moving equipment or excavation at the site. The survey will be conducted and results submitted to the DRMS as a technical revision 30 days prior to mobilization of earth -moving equipment or excavation. Based on the results of the raptor survey W.W. Clyde & Co. will coordinate with CPW and update the Mining Plan as appropriate to comply with recommendations to limit wildlife impacts. rJ&T Consulting, Inc. WW Clyde Bernhardt Sand and Gravel Pit DRMS 112 Permit Application JET Consulting, Inc. Reclamation Bond Quantities and Costs © 2024 AT Consulting, Inc. W.W. Clyde & Co. Bernhardt Sand and Gravel Pit 6/20/2024 Summary of Unit Costs Direct costs Re -applying topsoil 6" thick Revegetating disturbed area Dewatering full pit Slurry Wall Cost (36 foot average depth @ $5.50/ft) Perimeter Drain Scarifying Ground Grading and Backfill of Reclamation Slopes Spillway Riprap Slope Protection Spillway Slope Protection Bedding Mobilization Overhead and Profit Costs Liability insurance Performance bond Profit Total Overhead Cost Project Management Engineering and bidding Management and administration Total Additional Cost Phase 1 $1,800.00 $1,000.00 $200.00 $198 $20 $200 $2.00 $110 $80 $2,500 / acre / acre / million gallons / linear foot / linear foot / acre / cy / cy / cy lump sum 1.55% of direct cost 1.05% of direct cost 10.00% of direct cost 12.60% of direct cost 4.25% of direct cost 5.00% of direct cost 9.25% of direct cost Reclamation Operation Quantity Unit Unit Cost Cost Active Mining Area Scarifying Disturbed Area Topsoil Placement Disturbed Area Revegetate Disturbed Area Reclaimed Slope Grading and Backfill Slurry Wall Perimeter Drain Spillway Riprap Slope Protection with bedding Spillway Slope Protection Bedding Dewatering of Phase 1 Area Mobilization 15.07 15.07 15.07 351,950 7,723 3,890 2,965 1,485 684.2 1.00 ac ac ac cy If If cy cy Mil. Gal. Is $200 $1,800 $1,000 $2.00 $198 $20 $110 $80 $200 $2,500 $3,014 $27,126 $15,070 $703,900 $1,529,154 $77,800 $326,150 $118,800 $136,840 $2,500 Total Direct Cost Overhead and Profit Cost (12.60%) $2,895,144 $364,788 Contract Cost Project Management (9.25%) $3,259,932 $301,544 Cummulative Financial Warranty Required For Phase 1 $3,561,476 J&T Consulting, Inc. Bid Schedule © 2023 J&T Consulting, Inc. The Consolidated Mutual Water Company Perry Pit Reservoir Repairs 10/9/2023 Item Number Description Quantity Unit Unit Price Total Price General Items 1 Project Mobilization/Demobilization I 1 LS $93,000.00 $93,000.00 2 Erosion Control 1 LS $11,500.00 $11,500.00 3 Traffic Control 1 LS $12,000.00 $12,000.00 4 I Construction Staking 1 LS $25,000.00 $25,000.00 5 Clearing, Grubbing, Striping/Stockpiling/Replacing Topsoil 1 LS $40,000.00 $40,000.00 - 6 Site Restoration of all mulching) Disturbed Areas (misc grading, seeding, 1 LS $15,000.00 $15,000.00 General Items Subtotal $196,500.00 Reservoir Repair items 7 West Berm Grading Area - FILL, Complete in Place I- 280 CY $26.50 $7,240.00 8 West Grading Area - FILL, Complete in Place 1,550 CY $17.60 $27,280.00 9 North Grading Area - FILL, Complete in Place I 1,120 CY $7.50 $8,400.00 ' 10 North Grading Area - CUT, Complete in Place 1,980 CY $5.15 $10,197.00 11 ' North Flow Through Spillway Slope Riprap, Complete in Place 660 4 CY $105.00 $69,300.00 12 North Flow Place Through Spillway Slope Riprap Bedding, Complete in 330 CY $73.50 $24,255.00 13 North Flow Through Spillway Soil Riprap, Complete in Place 590 CY $90.00 $53,100.00 14 Remove Class Access IV Existing 2x18 in RCP Culvert with Road, Complete in DIP Culverts and install 36 in 2 Flared End Sections at Oil/Gas Place 30 I LF $630.00 $18,900.00 15 Remove and Replace Chain Barbed Wire Fence, Complete Link Fence Along CR 6 with 4 -Wire in Place 1,120 LF $22.00 4 $24,640.00 16 Removal of Temporary Spillway Berm - CUT, Complete in Place 795 CY $5.50 $4,372.50 17 Side Place Channel Spillway Repair Area Grading - FILL, Complete in 2,250 CY $4.95 $11,137.50 18 Side Channel Place Spillway Repair Area Grading - CUT, Complete in 1,120 CY $4.50 $5,040.00 cY1 \ lmpervious, Cla,\ - .r l+ a ,,-C cr_ p,I to ire-Pla�te`_�,_\_ -_. ; --, vc _ _ 80 CY $70.00 $5,600.00 20 I Side Channel Spillway Slope Riprap, Complete in Place 380 CY $110.00 $41,800.00 > 21 Side Channel Spillway Slope Riprap Bedding, Complete in Place 190 CY $80.00 $15,200.00 _ Side Channel SpillWa9 Soil Riprap, Complete in Pike-- - 2,060" CY $80.00 $164,800.00 1of2 The Consolidated Mutual Water Company J&TConsulting,Inc. Ihi' Perry Pit Reservoir Repairs 10/9/2023 Bid Schedule © 2023 AT Consulltinc4 Inc. Item Number Description Quantity Unit Unit Price Total Price 23 Intake Structure Flowfill Backfill, Complete in Place 15 CY $585.00 $8,775.00 24 Install Sump Pump Discharge Piping From Meter Vault to Intake Structure, Complete in Place 1 LS $1,250.00 $1,250.00 25 Reset Leaning Intake Structure to Level, Complete in Place 1 LS $2,750.00 $2,750.00 26 Video Inspection of Intake Structure Piping, Complete in Place 1 LS $2,700.00 $2,700.00 27 Removal of Settled Concrete Cutoff Wall Reinforced Concrete to Raise Cutoff Walls, and Installation Complete of in Place 1 LS $85,000.00 $85,000.00 Reservoir Repair Items Subtotal $591,917.00 Project Total $788,417.00 I Total Price in Words Seven Hundred Eighty Eight Thousand Four Hundred Seventeen Dollars and Zero Cents This bid schedule is understood to be all inclusive of the work shown on the contract documents. Items that are not specifically indicated by an individual bid item are understood to be incidental and included in the lump sum cost of a related bid item. Company Kelley Trucking Inc. **See attached for Bid Clarifications.** KtKeIIeyTrucking. Earthmoving Contractors 6201 McIntyre Street • Golden, Colorado 80403 (303) 279-4150 Fax (303) 279-4799 PERRY PIT RESERVIOR REPAIRS CR 6 AND GRACE AVE WATTENBERG, co 11/16/2023 Bid Clarifications 1. Proposal assumes dewatering permit will not be required and any dewatering operations shall discharge into Perry Pit Reservoir. 2. Proposal assumes reservoir shall be drained, by others, to acceptable levels to allow contract completion. 3. Proposal assumes work in South Platte River shall be allowed, as needed, and as necessary. 4. Proposal assumes project shall be complete by 3/15/24. 5. Proposal assumes Rip Rap shall be available from aggregate quarry at time of construction. 6. KTI shall take care to prevent damage to intake structure during leveling but shall not be liable for any damage to intake structure. 7. Proposal assumes Sump Pump Discharge piping is 2" SCH. 40 PVC. 8. Final payment quantities will be based upon pre and post survey. 9. All grading shall be one time only to +/- 0.20 foot. 10. Importing of soils is contingent upon materials being available and accepted by Owner and Geotechnical Engineer for all required geo-technical and environmental considerations. 11. The work is based on current fuel rates. Fuel price increases may result in a price adjustment. The work is based on non -restricted market availability of fuel and DEF. If supply of fuel or DEF becomes restricted and 1 or released on an allocated basis, schedule impacts and repricing may become necessary. 12. This proposal is contingent upon Kelley Trucking Inc's. equipment availability at the time of the work 13. Proposal is based upon obtaining adequate supply of construction water from hydrants located on the project site. 14. Proposal assumes heavy equipment will be allowed to cross over and under existing utility lines. 15. The items within the proposal are tied, if the Owner desires to breakout any items contact us for review and potential price adjustments. 16.. KTI will insure, indemnify and defend Ownership and/or Indemnities only to the degree or percentage of negligence or fault attributable to KTI that caused the claim, damage or loss consistent with C.R.S. 13-21-111.5. 17. If Payment and Performance bonds are required please add 1.0% to total proposal price. 18. Proposal is contingent upon a mutually agreeable Contract. 19. This proposal shall be valid for a period of 30 days. 20. The following work items are excluded from the proposal: Survey control, permits, flaggers, pedestrian control, engineering, barricades, lights, testing, environmental testing, patching, soil gradation or classification, hazardous materials, special waste, crushing or screening, utilities, removal or protection or support of utilities, utility relocation, utility adjustments, utility spoils, underground facilities, potholing, shoring, bracing, winter protection, snow or frost removal or protection, landscaping, muck excavation, subgrade stabilization, soil treatment, rock excavation, blasting, retaining wall construction, topsoil import, export, subgrade prep prior to paving or flatwork, fine grading, grading for curb and gutter and sidewalk, grading more than one time, Textura fees, and bonds. ODIN Derr Pit North Slurry Wall I Section 2 I Bid Form MilM JsT Consulting, Inc.W.W. Consulting, Inc. Clyde Derr Pit North & Co. Slurry Wall 1/18/2024 Bid Schedule ,© 2024 AT BASE BID Item Number Description Quantity Unit Unit Price Total Price 1 Project Mobilization/Demobilization 1 I $300,000.00 LS $300,000.00 2 Payment and Performance Bonds 1 LS • $42,000.00 S42,000.00 3 Slurry Wall Mix Design 1 LS $50,000.00 $50,000.00 4 Slurry Source Water Treatment LS $50,000.00 $50,000.00 5 Slurry Wall - Soil/Bentonite Slurry Wall Installation, Including 1% Dry Bentonite Addition, Complete in Place 493,910 SF $6.65 $3,284,501.50 BASE BID TOTAL $3.726.501.50 J&T Consulting, Inc. May 21, 2024 Mr. Rob Zuber Environmental Protection Specialist State of Colorado Division of Reclamation, Mining, and Safety Physical Address: 1313 Sherman Street, Room 215 Denver, CO 80203 Mailing Address: Division of Reclamation, Mining and Safety, Room 215 1001 East 62nd Avenue Denver, CO 80216 RECEIVED JUN 2 4 2014 WELD COUNTY COMMISSIONERS 1 PAGE OF DOCUMENT INCLUDED IN PAPER FILE. REMAINDER RETAINED RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025, ELECTRONICALLY IN TYLER. 112c Permit Application. Second Adequacy Review Dear Mr. Zuber, VVW Clyde & Co. (VVW Clyde) has received the Division's Second Adequacy Review letter dated April 17, 2024. Below are the comments and the corresponding responses that we have provided to address the comments. Comments 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land 3) The South Platte River must be shown and labeled on maps C-1 and C-2, per Rule 6.4.3(b). No additional response required, but it is suggested that the symbology and legend on the maps in Exhibit C be improved. The same symbol is used for the dewatering trench and the edge of the river this is confusing. Also, the term "Edge of River" is not clear; should it be "West Bank" instead? The 400 -foot setback is not included in the legend. Response: Acknowledged. See updated maps. 6.4.4 Exhibit D - Mining Plan 4) Please discuss if processing will entail washing of the product and if a pond or ponds will be included in the process area. If so, add a discussion to the text of Exhibit D and to Map C-2. The Direction of Mining arrows on Map C-2 imply that mining will occur in the area where the Sediment Pond and Clearwater Pond will be constructed. Please explain in Exhibit D if these ponds will be constructed after this area is mined and how that impacts the process of washing material. Will the ponds need to be constructed twice during the life of the mine? Response: The ponds will be constructed once and the area will be mined at the LAS l i cRemi1131214 kw CC;, PL(£2l w4(E*1DA( NK� PiCt.RIc±c1N2ID415?) 1s1241Z`{ 2024-1725 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21, 2024 -2- end of the mining when no washing will be occurring once the final mining is completed with the final reclamation. 6) Exhibit D needs to include a discussion of stabilization of topsoil stockpiles (Rule 3.1.9(3)). It does not appear that this text was added to Exhibit D. (It does appear that the text for Item #5 was added twice.) Please revise Exhibit D to discuss stabilization of topsoil stockpiles. Response: See updated Exhibit D with the following text: "For topsoil stockpiles, the stabilization includes roughening to help with wind erosion as well as re - vegetating with appropriate seed mixes to minimize erosion and establish more rapidly to stabilize the stockpiles. If a stockpile remains more than one growing season, it will be seeded with the seed mix as recommended by the DRMS and in the reclamation plan in Exhibit E" with cyan highlighting. 7) Exhibit D should include a discussion of the structures that will be constructed for the mining operation, including buildings and roads. The discussion must include dimensions and general construction methods. (For example, will foundations include rebar reinforcement?) The text needs to include dimensions for the concrete pads that will serve as foundations for the scale and scale house. Response: See updated Exhibit D with the following text: "The scale house will be founded on typical trailer type jacks and tiedowns on top of concrete pads that are typically 2 feet x 2 feet x 1.5 feet deep with minimal rebar to provide reinforcement. The scale will also be founded on concrete pads with reinforcement where load cells are located for the scale, these are typically 12' long by 3 feet wide and 3 feet deep. These foundations would be removed once the pit is fully mined" with cyan highlighting. 6.4.7 Exhibit G - Water Information 16) The McGrane report and associated conclusions will be reviewed by a groundwater hydrologist with the Division, and an additional adequacy letter will be sent in October or November 2023. Please see the enclosure with a review by a Division Groundwater Hydrologist, Patrick Lennberg. Response: Acknowledged. See below responses for Groundwater Review Memo. 17) To ensure that the Bernhardt Pit does not impact the hydrologic balance of the river, the application needs to include a water quality monitoring plan, specifically for the alluvium. The groundwater monitoring plan should be developed in accordance with Rule 3.1.7(7)(b) and should include a Quality Assurance Project Plan (QAPP) for the collection of groundwater samples. The plan should provide mitigation steps if there is an exceedance at a groundwater or surface water monitoring location. Potential impacts to quality and/or quantity of nearby domestic wells should also be addressed. A copy of the Division's enclosure to this letter for your reference. Please see the enclosure with a review by a Division Groundwater Hydrologist, Patrick Lennberg. II m VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21, 2024 -3- Response: Acknowledged. See below responses for Groundwater Review Memo. 6.4.8 Exhibit H - Wildlife Information 19) The applicant must address the comments of the Colorado Parks and Wildlife Division (CPW), which are enclosed with this review letter. Each of the comments must be directly addressed in your response letter, and, as applicable, comments must also be addressed by revising Exhibit H. Where necessary, add commitments for future studies or other actions. Note that CPW recommends a setback from the river of 500 feet. While this would be preferable in the context of wildlife protection, the Division believes that the 400 -foot setback described in Exhibit G, above, is sufficient. Please consider the 400 -foot option to protect wildlife as well as protect the riverbanks from erosion. The Division has consulted with Colorado Parks and Wildlife, and we are requiring that another raptor survey be conducted prior to mobilization of earth -moving equipment or excavation at the site. In Exhibit H, please commit to conduction this survey and providing the results to the Division. These results need be submitted to the Division as a Technical Revision and submitted at least 30 days prior to mobilization of earth -moving equipment or excavation. Response: WW Clyde commit to conducting a raptor survey prior to mobilization of earth -moving equipment or excavation at the site. The survey will be conducted and results submitted to the DRMS as a technical revision 30 days prior to mobilization of earth -moving equipment or excavation. (See highlighted text in updated Exhibit H with cyan highlighting) 6.5 Geotechnical Stability Exhibit DRMS is reviewing the geotechnical analysis and our comments will be sent in October or November 2023. DRMS is reviewing the geotechnical analysis and responses. Our comments will be sent under separate cover. Response: Acknowledged. Also, the Division will be working on the reclamation cost estimate in the near future and will be in touch with questions. Response: Acknowledged. Groundwater Review Memo No. 2 1. The Applicant proposes to only collect groundwater samples from two locations, one downgradient and one upgradient. The Applicant will need to expand groundwater sampling to include all four monitoring well locations to demonstrate that existing and reasonably potential future uses of groundwater are protected (Rule 3.1.7(8)) and no unauthorized release of pollutants to groundwater shall occur from any materials mined, handled, or disposed of within the permit area (Rule 3.1.5(11)). Response: The sampling plan has been updated to include all the monitor wells. 2. Pursuant to Rule 3.1.7(7)(b)(ii) and (iv), please provide the method of well sampling and a description of the quality control and quality assurance methods (e.g., duplicate samples, rinsate samples) to be used during groundwater sampling. II m VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21, 2024 -4- Response: The sampling plan has been updated to include the methods as well as the quality control and quality assurance methods to be used during groundwater sampling. See the updated text in Exhibit G with cyan highlighting. 3. Please commit to providing the quarterly groundwater monitoring results along with the monthly groundwater level measurements by the following deadlines: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report should, at a minimum, include a site map with well locations, tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified, and graphs and tables of measured groundwater levels for all locations. The Applicant should be prepared to submit field sheets that demonstrate monitoring wells were purged and sampled according to the approved plan. At the end of five quarters, the Applicant may submit a Technical Revision to reduce the analyte list and frequency of monitoring with sufficient justification. Response: WW Clyde commits to providing the quarterly reporting as stated. 4. Please commit to establishing a point(s) of compliance following five (5) quarters of baseline monitoring in accordance with Rule 3.1.7(6). Response: WW Clyde commits to establishing points of compliance following five quarters of baseline monitoring. Monitor Well 3 located on the west side of the permit boundary will be used as a background water quality sampling location and the remaining three monitoring wells as points of compliance (POC), the POCs will be Monitor Wells 1, 2, and 4. See the updated Exhibit G and updated text with cyan highlighting. 5. Exhibit G needs to be updated with a discussion of mitigation measures regarding groundwater mounding approaching the surface. Include in the discussion triggers for the initiation of mitigation measures. Response: The first mitigation measure will be the construction of a groundwater drain as detailed in the McGrane response attached. The design and construction of the groundwater drain will be at the same time the slurry wall design and construction are completed so there will be minimal affect on the groundwater elevations. The drain will be constructed to a depth deep enough to control groundwater mounding from surfacing. Stop logs will be used to control groundwater elevations such that the drain does not drop the elevation to much or raise the elevation where mounding could occur. The trigger points would be levels of plus or minus 2 feet of difference from the baseline seasonal groundwater levels in MW -1 through MW -4 where stop log elevations could be adjusted to either lower or raise groundwater levels to their historic seasonal elevations. See the updated Exhibit G and updated text with II m VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 RE: Bernhardt Sand and Gravel Pit, File No. M-2023-025 112c Permit Application, Second Adequacy Review May 21, 2024 -5- cyan highlighting. 6. Please clarify whether or not the results presented in the SGS table are total or dissolved. Response: The results are dissolved for the metals. Groundwater Model Review 7. The Division was not able to review Attachment 11 - McGrane Groundwater Model Update and Responses, as it appears it was not included with the adequacy review responses. Please submit the missing attachment. Response: The McGrane response is attached. WW Clyde appreciates your consideration of this adequacy review response. Please feel free to contact me with any questions or comments. Sincerely, J.C. York, P. J&T Consulting, Inc. Attachments: 1. Updated Exhibit C-1, C-2, F-1 and F-2 Maps 2. Updated Exhibit D 3. Updated Exhibit G 4. Updated Groundwater Monitor Well Readings 5. Updated Groundwater Quality Testing Readings 6. McGrane Groundwater Model Update and Responses 7. Updated Exhibit H gm VI 305 Denver Avenue — Suite D • Fort Lupton CO 80621 • Ph: 303-857-6222 EXHIBIT D Mining Plan Mining Limits WW Clyde proposes to mine in the land located in the parcel of land situated in the northeast 1/4 of Section 24, Township 4 North, Range 67 West of the 6th Principal Meridian, in Weld County, Colorado. The proposed mining site is located within the Town of Milliken. CR 46 is north of the property and an access road from the property connects to CR 46 near the intersection of CR 46 and CR 25. The South Platte River is adjacent to the property and approximately 880 feet south of the site on the south side of the permit boundary and 140 feet from the east side of the permit boundary. The dominant land use surrounding the property is agricultural use and industrial use. An aggregate processing plant will be located in Phase 1. These areas will contain stockpiles, portable equipment, storage bins, and silos as necessary to support the plant operations. Mining will start from the northeast corner of the mining limit then moving south approximately to one third of the property then west, then moving south to another third of the property back to the east, then moving south to the final third of the property to the west to complete mining and reclamation. All local, State, and Federal rules and regulations will be followed for the storage and handling of any petroleum products. The permit boundary will encompass approximately 111.01 acres which will all be affected acreage, and approximately 98.24 acres being mined. The remaining area will consist of access roads and disturbed land. The following table depicts the different affected acreage: Affected Acreage Mining Plan Area (acres) Mined Area 98.24 Access Roads 2.36 Disturbed Land 10.41 TOTAL 111.01 Various setbacks from adjacent roads, adjacent structures, and oil and gas infrastructure will be maintained as mining occurs. The final executed agreements are expected to be obtained in the near future and will be forwarded to the Division when they are available. A minimum 200 -foot setback from any existing oil/gas facility will be maintained until that time. See Exhibit C, Mining Plan Map, and the Slope Stability Report for the mining limit configuration and information on setbacks and their locations. The abandoned wells would be cutoff after mining has reached the bedrock surface or the reclaimed slope surface where a new cap and any additional concrete for the existing plug would be needed. Petroleum Development Corporation (PDC) is the leaseholder and operator of the existing abandoned wells. Discussions with PDC have indicated they would cut down the existing casings as mining occurs. We have also worked with McCarty Engineering, LLC to provide this service at other mining permit locations for other operators. If PDC does not want to perform this work then McCarty Engineering, LLC would be contacted to do it. They are licensed and bonded to obtain approvals from the COGCC to do these types of re -plug services on abandoned oil and gas wells. Products Sand and gravel will be the primary product produced from the Bernhardt Sand and Gravel Pit. The principal intended use for the sand and gravel is for road base and construction aggregates. Subsurface drilling and testing have verified that the Bernhardt Sand and Gravel Pit property contains a significant commercial deposit of sand and gravel. The depth of clay, interbedded sandy clays and clayey to silty sands at the surface range from 1 to 8 feet. The thickness of the aggregate material ranges from 4 to 37 feet where bedrock contact occurs. Mining Methods The deposit will be dry mined and a slurry wall will be constructed around the perimeter of the mining area for Phase 1. Mining will not expose groundwater prior to the slurry wall being constructed around the perimeter of Phase 1. Design specifications for the slurry wall and quality control procedures used during construction will ensure that the reclaimed reservoir meets State Engineer's Office (SEO) performance standards. Dewatering trenches will be excavated around the perimeter of each mining area prior to mining operations commencing. The depth of the ditches will vary as the mining progresses deeper into the alluvium in order to maintain the groundwater level below the active mining bottom surface, and therefore minimize the exposed groundwater surface area. The dewatering ditches will flow to a collection pond, from which the water will be pumped and discharged into recharge areas where overflow will reach a ditch that flows to the South Platte River. The equipment and facilities may include, but are not limited to the following: Scaling Equipment A scale house and scale will be used to weigh trucks and product leaving the pit. The dimensions of the scale house are 40' x 12' and the scale will be 70' by 10'. The scale house will be founded on typical trailer type jacks and tiedowns on top of concrete pads that are typically 2 feet x 2 feet x 1.5 feet deep with minimal rebar to provide reinforcement. The scale will also be founded on concrete pads with reinforcement where load cells are located for the scale, these are typically 12' long by 3 feet wide and 3 feet deep. These foundations would be removed once the pit is fully mined. Processing Equipment Screens, wash plant, crusher, conveyors, stackers, and other miscellaneous processing equipment. All processing equipment will be mobile and temporary without fixed foundations. Washing will occur at the wash plant and excess water from the washing will be recycled to the wash water ponds within the processing area, there will be a sedimentation pond that will receive the excess water first and then and overflow from the sedimentation pond to the clear water pond for re -using the water and pumping back to the wash plant. Earth Moving Equipment Dozers, loaders, scrapers, excavators, and compactors will be used for mining and earth moving operations. Haul Roads and Access Roads Haul roads will be graded and constructed using the existing pit run where needed outside the processing area in order to move material from the mine using haul trucks, loaders, or scrapers. These roads will be mined and removed as the mining is completed. Access roads to the processing plant will be constructed with aggregates made at the site where the entrance to the permit boundary is located to the scale house and through the scaling area until the access reaches the stockpile locations. The roads around the stockpiles will be constructed from the existing pit run similar to the haul roads. Miscellaneous Equipment Dewatering pumps, electrical trailer, generator trailer, small portable generators and watering trucks will be used as needed. As mining progresses, topsoil and overburden will be stripped to expose the aggregate product below. Topsoil will be stripped and salvaged from areas where overburden material will be stockpiled. All soil and overburden material will be used on -site for reclamation; so long-term stockpiling of these materials is not anticipated. Overburden stockpiles will be located within the proposed mining area. The stockpiles will be placed parallel to the floodplain to mitigate impacts to the floodplain. Mining of the aggregate will progress down to the underlying bedrock. Since reclamation will occur concurrently with mining, it is not anticipated that overburden material will be stockpiled long-term prior to use in the slope reclamation and also the production of road base. During mining the mining face for Phase 1 will have a 2H:1V slope to bedrock or the bottom of the future reclaimed reservoir and the reclamation slope will be constructed using the excess overburden to a 4.5H:1V slope. The processed aggregate material will be temporarily stockpiled near the portable processing plant. Recommendations for monitoring of slope stability, including, conducting a visual inspection of the excavated slopes on a weekly basis for the duration of mining, conducting a visual inspection after a major precipitation event that has saturated the ground using the same procedures, contacting qualified personnel to evaluate and recommend remediation work to stabilize the area in the event a visual inspection detects signs of potential slope failure, and if no visible signs of slope failures are detected during mining, reducing visual inspections to once every six months after mining completion, or after every major precipitation event. All local, State, and Federal rules and regulations will be followed for the storage and handling of any fuel for the facilities. Topsoil Handling Plan As stated previously the topsoil will be stripped to expose the aggregate product underlying the topsoil. The topsoil will be stripped using scrapers and stockpiled in the topsoil stockpile as depicted in Exhibit C. For topsoil stockpiles, the stabilization includes roughening to help with wind erosion as well as re -vegetating with appropriate seed mixes to minimize erosion and establish more rapidly to stabilize the stockpiles. If a stockpile remains more than one growing season, it will be seeded with the seed mix as recommended by the DRMS and in the reclamation plan in Exhibit E. The volume of topsoil for all the mining phases is approximately 13,000 cubic yards. The depth of the topsoil is approximately six inches over the majority of the mining area. The topsoil will be stripped and stockpiled during each phase of mining where topsoil will only be removed for Phase 1 as Phase 1 is mined. Mining will start from the northeast corner then moving south approximately to one third of the property then west, then moving south to another third of the property back to the east, then moving south to the final third of the property to the west to complete mining and reclamation. The height of the topsoil stockpile will be approximately 15 feet to 20 feet. Mine Phasing WW Clyde anticipates mining and reclaiming the Bernhardt Sand and Gravel Pit in 1 phase, progressing through this phase as shown on the Mining Plan Map. The overall time required to complete the mining and reclamation is estimated to be 11 years based on an average rate of 650,000 tons per year. The initial production is expected to be 300,00 tons per year with the maximum production expected to be 1,000,000 tons per year. However, it is possible that due to demand fluctuations, mining could progress slower than anticipated and additional time may be required for mining and reclamation of the site. Phase 1 is 98.24 acres and the estimated time for mining Phase 1 is approximately 11 years. The mining will progress beginning at the outer edge of the phase where material will be moved toward the interior of the phase such that the mining slope can be established. The mining slope will be established for the entire perimeter of the phase in 3 to 6 feet intervals. Dewateri ng Dewatering trenches will be placed along the perimeter of Phase 1. The dewatering trench around the perimeter of the phase being mined will be placed at the toe of the mining slope. As the phase is mined deeper the dewatering trench will be lowered and moved laterally along the mining slope toward the center of that phase. A slurry wall is anticipated to be installed around the perimeter of Phase 1 prior to exposing groundwater and mining will continue to commence and it is expected minimal dewatering will be required after the slurry wall is installed due to the slurry wall cutting off groundwater infiltration into the pit. WW Clyde will have an approved substitute water supply plan and well permit prior to exposing groundwater. The substitute supply plan will be updated annually to account for water that is consumed due to exposing groundwater by the mining operation. Explosives Explosives will not be used during mining. EXHIBIT G Water Information Introduction WW Clyde proposes to mine in the land located in the parcel of land situated in the northeast 1/4 of Section 24, Township 4 North, Range 67 West of the 6th Principal Meridian, in Weld County, Colorado. The proposed mining site is located within the Town of Milliken town limits. CR 46 is north of the property and an access road from the property connects to CR 46 near the intersection of CR 46 and CR 25. The South Platte River is adjacent to the property and approximately 880 feet south of the site on the south side of the permit boundary and 180 feet from the east side of the permit boundary. The operation will consist of sand and gravel production and will impact the South Platte River in the form of depletions due to evaporation and operational losses associated with mining. Mining of the Bernhardt Sand and Gravel Pit mining site will last for approximately 11 years. Once reclamation is complete a reservoir will be created with a total surface area being 92.35 acres. The depth to groundwater ranges from 3 to 7 feet seasonally within the permit boundary (measured in MW -1 through MW -4, See the attached piezometer measurements table). The site will be mined down to a depth of 37 feet at the deepest depth thus exposing groundwater to the atmosphere. This exposed groundwater, along with the operational losses associated with the extraction of sand and gravel deposits, will impact the South Platte alluvial aquifer. These impacts will cause river depletions that must be augmented. Groundwater will be exposed during the mining once the mining depths reach an elevation of approximately 4713.8. To enable dry mining at the Bernhardt Sand and Gravel Pit mining site, there will be dewatering trenches around the perimeter of Phase 1. These dewatering trenches will change in length throughout mining. The maximum length will occur when Phase 1 is completely mined. The maximum size of dewatering trench will be 5,430 feet long and 5 feet wide, or 0.62 acres of exposed surface area. water will be pumped into dewatering ditch, which traverses the site, and ultimately into the South Platte River. As mining progresses, the dewatering trenches will shift as mining slopes are reclaimed. The gravel pit will have a slurry wall liner being constructed as mining commences in Phase 1. Water Requirements Water use at the Bernhardt Sand and Gravel Pit mining site will include evaporation from exposed groundwater, dust control of haul roads and stockpiles, water for the wash plant (i.e. wash screen for concrete rock and sand) and water retained in material removed from the site. Evaporative Loss Evaporative losses are dependent on the exposed water surface area, which may shift throughout the mining operation, but will not exceed the maximum. Exposed surface area at the Bernhardt Sand and Gravel mining site will include groundwater exposed in the dewatering trenches. The maximum exposed surface area at the site during mining is estimated at 1.80 acres. WW Clyde plans to keep the site dewatered throughout the life of the mine. Evaporation data was taken from NOAA Technical Report NWS 33, Evaporation Atlas for the 48 Contiguous United States. The annual gross evaporation was determined to be 45 inches for this location. Monthly evaporation percentages are established by guidelines set by the State Engineer's Office. To determine precipitation, data from the National Weather Service for Greeley, CO (UNC) (1967-2022) was used. The long-term average precipitation at the Bernhardt Sand and Gravel Pit mining site is estimated at 14.26 inches. Effective precipitation is calculated as 70% of the total precipitation. The net evaporation is the difference between gross annual evaporation and effective precipitation. The resulting net evaporation is 2.56 feet. The maximum evaporative loss from the 1.80 acres is 4.61 ac -ft. Operational Loss The average annual production from the Bernhardt Sand and Gravel Pit mining site is estimated at 650,000 tons. Using 4% moisture content (2% for moisture in the product and 2% for water used to wash), the total associated consumptive use for water retained in the material mined and water used for washing is 19.13 ac -ft. Dust control and water use is 10,000 gal/day, 6 days/week, 4 weeks/month for 10 months of the year. This equates to 7.4 ac -ft. Maximum annual operational loss is estimated to be 26.53 ac -ft for Phase 1. Consumptive Use The maximum annual consumptive use (operational loss + evaporation loss) at this site during the mining operation is estimated to be 31.14 ac -ft for Phase 1. Replacement Water The replacement of consumptive uses at the site is will be accounted for in a substitute water supply plan (SWSP) approved by the State Engineer. The SWSP will be obtained prior to any mining activities occurring that expose groundwater. Surrounding Water Rights The attached Figure A-1 Well Permits in the Bernhardt Sand and Gravel Pit — Groundwater Evaluation by McGrane Engineering, LLC shows the permitted wells within 600 feet of the mining limits and permitted wells within the boundaries of the groundwater model/evaluation. The well information and locations were obtained from the Division of Water Resources online mapping well permit locator. This well and water rights information was cross checked with the State's CDSS. Between the sources, all permitted and decreed wells are included. Table G-1 below is a corresponding list of wells as numbered in the Bernhardt Sand and Gravel Pit — Groundwater Evaluation by McGrane Engineering, LLC that is attached that are within 600 feet of the mining limits. G-1 - Permitted and Decreed Wells Within 600 Feet of Mining Limits Table No. Permit No WDID Well Name Owner Address City State Zip Code 1 14477 (Replaced Expired 014477F Shows Website) DWR -F -R on 0208226 Stroh (Irrigation) Well Stroh, Cheryl Carlene S. Kasten, Currier Karen L. M. Sholdt 511 North Drive Platteville CO 80651 2 42519-F 0205536 (Irrigation) Bernhardt Well (Purchased WW Property 2022) Clyde in 10303 Creek Suite E. Road, 300 Dry Englewood CO 80112 3 85 -R -R 0205392 (Irrigation) Bernhardt Well #5 (Purchased WW Property 2022) Clyde in 10303 Creek Suite E. Road, 300 Dry Englewood CO 80112 4 5-WCB No WDID CWCB Well Montgomery Violet Provided No Address Street Permit on Eagle CO Provided No Permit Zip Code on 5 (Red in 13701-F Showing Do Photos Divert dated 2019) Not Tag 0205393 (Irrigation) Bernhardt Well #6 Herbert Bernhardt B. 500 Street Broad Milliken CO 80543 At the time of SWSP application/approval, a new gravel pit well permit will be applied for/obtained to include the evaporative and operational losses from the property. If the proposed use of groundwater at the Bernhardt Sand and Gravel Pit mining site results in material injury to surrounding wells, WW Clyde will ensure that all necessary measures are taken to address the issues. Water Quality An NPDES permit will be obtained from the Water Quality Control Division at the Colorado Department of Public Health & Environment for the Bernhardt Sand and Gravel Pit mining site prior to discharging any groundwater that is dewatered from the site. This permit will be kept current and amended as necessary to ensure that any water discharged from the site will meet the permitted water quality standards. Impacts to Groundwater/Hydrologic Balance WW Clyde will monitor the groundwater levels surrounding the site and provide groundwater recharge via a groundwater drain as shown on the reclamation plan. The groundwater drain size will be provided with the groundwater drain plan and profiles prior to installation of the slurry wall at the same time that the slurry wall design/construction drawings are provided to the DRMS prior to installation of the slurry wall. WW Clyde will discharge dewatering flows into existing adjacent irrigation laterals where possible to limit the disturbance to the surrounding land or obtain an agreement with one of the adjacent land owners to discharge the dewatering flows directly to the South Platte River. A slurry wall liner is proposed around the individual phase and will be installed prior to mining starting. The first mitigation measure will be the construction of a groundwater drain as detailed in the McGrane response attached. The design and construction of the groundwater drain will be at the same time the slurry wall design and construction are completed so there will be minimal affect on the groundwater elevations. The drain will be constructed to a depth deep enough to control groundwater mounding from surfacing. Stop logs will be used to control groundwater elevations such that the drain does not drop the elevation to much or raise the elevation where mounding could occur. The trigger points would be levels of plus or minus 2 feet of difference from the baseline seasonal groundwater levels in MW -1 through MW -4 where stop log elevations could be adjusted to either lower or raise groundwater levels to their historic seasonal elevations. To summarize the mitigation process, as each phase of mining/dewatering occurs, WW Clyde will monitor the groundwater levels adjacent to mine as each phase progresses. If groundwater levels drop to a level that prevents an adjacent well from performing acceptably, according to that well's owner, WW Clyde will either implement a groundwater recharge ditch/pond near the well in order to raise the groundwater level in the vicinity of the well and hence return it's operation to acceptable standards, or will negotiate an agreement with that well owner to replace the well or provide replacement water via other means until the mining and reclamation activities are concluded but it is not anticipated that any groundwater levels will drop since the slurry wall and be installed prior to exposing groundwater. groundwater drain will Groundwater wells that are not owned by WW Clyde (Table G-1) are potentially located within 600 feet of the mining limits. The exact physical location of these wells will be determined during the SWSP and well permit application processes. If wells are found to be within 600 feet of the mining limits, WW Clyde will either obtain a well waiver from the owner of the well, or provide an agreement with the well owner that WW Clyde will mitigate any material damage to the well that is directly attributable to the mining and reclamation of the site. All other wells within 600 feet of the mining limits are either owned by WW Clyde, or are monitoring wells therefore groundwater impacts to these wells do not need to be addressed. See the attached Piezometer Location Map, and Piezometer Data Summary, which show the locations of monitoring wells around the perimeter of the site that WW Clyde has either installed or has access to, and the groundwater level data that has been collected for each well. The groundwater monitoring data will be provided for what has been done to date with this permit application/adequacy review and then submitted at the following frequency to the DRMS: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report will include a site map with well locations, tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified, and graphs and tables of measured groundwater levels for all locations. The field sheets will be included in an appendix that demonstrates monitoring wells were purged and sampled according to the approved plan. Groundwater Quality Monitoring Plan The majority of the mining operations at this site will be within the slurry wall lined area. The areas outside of the slurry wall will be limited to the scale house and haul roads for trucks coming into and out of the pit, which are not likely to affect groundwater quality. To establish pre -mining groundwater quality at the site WW Clyde will have four monitor wells sampled quarterly. The samples will be taken by a qualified consultant and then tested by SGS Laboratories for the analytes listed in Tables 1-4 of the "Basic Standards for Groundwater." The quarterly sampling will continue until 5 quarters of data has been established. Once the baseline has been established, we would recommend annual sampling to monitor the groundwater quality and a technical revision will be submitted to request the change. WW Clyde commits to establishing points of compliance following five quarters of baseline monitoring. Monitor Well 3 located on the west side of the permit boundary will be used as a background water quality sampling location and the remaining three monitoring wells as points of compliance (P00), the POCs will be Monitor Wells 1, 2, and 4. When obtaining a monitor well sample typically at least 3 well volumes will be taken from the well to make sure a true groundwater sample is obtained. During the purging time, measuring pH, temperature, EC will occur at different times until stabilization occurs. Then the sample will be collected and placed in the lab provided bottle(s) for unfiltered samples. The sample will then be filtered prior to placement into the lab bottle(s) for SGS to run the testing on for the dissolved metals from Table 41. Sampling and collection of the groundwater from the monitor wells will reference the USGS National Field Manual for Collecting Water Quality Data Chapter A.4 Collection of Water Quality Samples and EPA Region 9 Groundwater Sampling Guide. The groundwater quality sampling data will be provided for what has been done to date with this permit application/adequacy review and then submitted in the quarterly report for the pit to the DRMS after approval of the permit application. WW Clyde will notify the DRMS within 7 days of receiving a lab report that indicates any of the standards set forth in Tables 1-4 have been exceeded. If a lab report shows an exceedance, a new sample will be taken to verify exceedance or discount potential lab contamination. The groundwater quality testing data will be provided for what has been done to date with this permit application/adequacy review and then submitted at the following frequency to the DRMS: First quarter report due by May 1st of every year. Second quarter report due by August 1st of every year. Third quarter report due by November 1st of every year. Fourth quarter report due by February 1st of the following year. The report will include a site map with well locations, tabulated data for all parameters, graphs/plots of selected parameters, a narrative analysis of the data with any trends and/or anomalies identified, and graphs and tables of measured groundwater levels for all locations. The field sheets will be included in an appendix that demonstrates monitoring wells were purged and sampled according to the approved plan. Bernhardt Pit - Monitor Well Readings Well Designation JT MW -1 JT MW -2 JT MW -3 JT MW -4 Description North Side East Side West Side South Side Top of Well Elevation (ft) 4722.96 4723.15 4727.70 4726.65 Ground Elevation (ft) 4719.92 4720 09 4724.78 4723.56 Date Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Average Elevation of Groundwater for Month (ft) (average readings for each month for different years i.e. March 2023 and 2024 divided by 2) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Average Elevation of Groundwater for Monti (ft) (average readings for each month for different years i.e. March 2023 and 2024 divided by 2) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Average Elevation of Groundwater for Month (ft) (average readings for each month for different years i.e. March 2023 and 2024 divided by 2) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Average Elevation of Groundwater for Mont (ft) (average readings for each month for different years i.e. March 2023 and 2024 divided by 2) March 29, 2023 7.46 4.42 4715.50 4715.50 9.27 6.21 4713.88 4713.88 10.92 8.00 4716.78 4716.78 10.38 7.29 4716.28 4716.28 April 21, 2023 7.60 4.56 4715.36 4715.36 8.10 5.04 4715.05 4715.05 10.02 7.10 4717.68 4717.68 9.02 5.93 4717.63 4717.63 May 18, 2023 6.29 3.25 4716.67 4716.67 6.04 2.98 4717.11 4717.11 8.54 5.62 4719.16 4719.16 6.58 3.49 4720.07 4720.07 June 12, 2023 5.67 2.63 4717.29 4717.29 6.00 2.94 4717.15 4717.15 7.50 4.58 4720.20 4720.20 6.33 3.24 4720.32 4720.32 July 14, 2023 5.00 1.96 4717.96 4717.96 5.92 2.86 4717.23 4717.23 6.58 3.66 4721.12 4721.12 6.21 3.12 4720.44 4720.44 August 14, 2023 5.75 2.71 4717.21 4717.21 6.92 3.86 4716.23 4716.23 7.33 4.41 4720.37 4720.37 8.58 5.49 4718.07 4718.07 September 13, 2023 7.67 4.63 4715.29 4715.29 8.17 5.11 4714.98 4714.98 9.92 7.00 4717.78 4717.78 9.00 5.91 4717.65 4717.65 October 16, 2023 7.83 4.79 4715.13 4715.13 8.33 5.27 4714.82 4714.82 10.17 7.25 4717.53 4717.53 9.17 6.08 4717.48 4717.48 November 17, 2023 7.50 4.46 4715.46 4715.46 7.83 4.77 4715.32 4715.32 10.00 7.08 4717.70 4717.70 8.58 5.49 4718.07 4718.07 December 22, 2023 7.50 4.46 4715.46 4715.46 8.00 4.94 4715.15 4715.15 9.83 6.91 4717.87 4717.87 8.00 4.91 4718.65 4718.65 January 20, 2024 7.83 4.79 4715.13 4715.13 8.38 5.32 4714.78 4714.78 10.17 7.25 4717.53 4717.53 9.08 5.99 4717.57 4717.57 February 25, 2024 7.67 4.63 4715.29 4715.29 8.13 5.07 4715.03 4715.03 10.02 7.10 4717.68 4717.68 8.92 5.83 4717.73 4717.73 March 30, 2024 6.58 3.54 4716.38 4715.94 7.29 4.23 4715.86 4714.87 9.63 6.70 4718.08 4717.43 8.13 5.04 4718.53 4717.40 April 30, 2024 7.21 4.17 4715.75 4715.55 6.88 3.82 4716.28 4715.66 9.58 6.66 4718.12 4717.90 7.96 4.87 4718.69 4718.16 May 31, 2024 June 30, 2024 _ July 31, 2024 August 31, 2024 September 30, 2024 October 31, 2024 November 30, 2024 _ December 31, 2024 Minimum 5.00 1.96 4715.13 5.92 2.86 4713.88 6.58 3.66 4716.78 6.21 3.12 4716.28 Maximum 7.83 4.79 4717.96 9.27 6.21 4717.23 10.92 8.00 4721.12 10.38 7.29 4720.44 Average 6.97 3.93 4715.99 7.52 4.46 4715.63 9.30 6.38 4718.40 8.28 5.19 4718.37 Monitor Well Locations in decimal degrees MW -1 - LAT N40.303936, LONG W104.834394 MW -2 - LAT N40.301374, LONG W104.830132 MW - 3 - LAT N40.301151, LONG W104.838891 MW - 4- LAT N40.297684, LONG W104.834826 Bernhardt Pit Monitor Wells Elevation of Groundwater 4,722 4,721 4,720 4,719 4,718 z O W 4,717 4,716 4,715 4,714 4,713 M N I A M N Q M N M N i J&T Consulting, Inc. id M N m N Q M N Qi Cr M N O JT MW -1 Cr) N 0 z M N ci 0 DATE =�JT MW -2 N C) L N L N L a N JT MW -3 JT MW -4 N 1 N U N O z N ci 0 Bernhardt Pit Monitor Wells Depth to Groundwater Measured From Top of Well 12 11 10 H rn N ru N Q rri N CD J&T Consulting, Inc. en N m m N N +aA v Q V) N 0 JT MW -1 m m N N N N O a) CD w z a — U_ DATE Rcr N 5 -JT MW -2 JT MW -3 Ct N JT MW -4 N N N N N 4-1 0i D CI Q in 0 z a Bernhardt Pit Monitor Wells Depth to Groundwater Measured From Ground Surface 9 8 7 6 5 4 3 2 1 M N Vt N Vt N m N 2 M N Q M N CD 2 J ■ J&T Consulting, Inc. M (NJ ci V) m (NI +-) O JT MW -1 m N 0 z m N a a N CO DATE N a) 71- 2 ,JT MW -2 JT MW -3 Vt N Q Vt N CD 2 JT MW -4 d- tiup Q Vt N O Vt N 0 z Vt N a a SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID: DA62542-3 Matrix: AQ - Ground Water Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a General Chemistry Analyte 9056A Fluoride Chloride Nitrogen, Nitrite Nitrogen, Nitrate Sulfate Result 0.80 135 0.11 5.7 320 9056A NO2 + NO3O Nitrogen, Nitrate + Nitrite a 5.8 Solids, Total Dissolved 888 RL Units DF Analyzed By Method 0.20 5.0 0.040 0.25 13 mg/1 mg/1 mg/1 mg/1 mg/1 2 03/01/24 21:45 MB 10 03/01/24 22:28 MB 10 03/01/24 22:28 MB 25 03/02/24 17:00 MB 25 03/02/24 17:00 MB 0.29 mg/1 1 SW846 9056A SW846 9056A SW846 9056A SW846 9056A SW846 9056A 03/02/24 17:00 MB SW846 9056A 10 mg/1 1 03/04/24 07:00 JW (a) Calculated as: (Nitrogen, Nitrate) + (Nitrogen, Nitrite) SM 2540C-2011 RL = Reporting Limit SGS 17 of 61 DA62542 SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID: DA62542-3F Matrix: AQ - Groundwater Filtered Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a Dissolved Metals Analysis Analyte Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Mercury Molybdenum Nickel Selenium Silver Thallium Uranium Vanadium Zinc Result 0.0193 B 0.0068 U 0.0046 U 0.0557 0.0013 U 0.206 0.0013 U 0.0013 U 0.0024 B 0.0013 U 0.012 U 0.0063 U RL 0.10 0.030 0.025 0.010 0.010 0.050 0.010 0.010 0.0050 0.010 0.070 0.050 0.322 0.0050 MDL Units DF Prep 0.015 0.0068 0.0046 0.0013 0.0013 0.0063 0.0013 0.0013 0.00063 0.0013 0.012 0.0063 0.00063 mg/1 mg/1 m g/1 mg/1 m g/1 mg/1 mg/1 mg/1 mg/1 mg/1 m g/1 m g/1 mg/1 0.000050 U 0.00010 0.000050mg/1 0.0031 B 0.0040 B 0.022 U 0.0038 U 0.0043 U 0.0319 B 0.0013 U 0.0038 U 0.010 0.030 0.050 0.030 0.010 0.050 0.010 0.030 (1) Instrument QC Batch: MA 17745 (2) Instrument QC Batch: MA17751 (3) Instrument QC Batch: MA 17763 (4) Prep QC Batch: MP39056 (5) Prep QC Batch: MP39057 0.0028 0.0038 0.022 0.0038 0.0043 0.0085 0.0013 0.0038 mg/1 mg/1 m g/1 mg/1 mg/1 m g/1 mg/1 m g/1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/13/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 Analyzed By Method 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/19/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/13/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 3 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 7470A 1 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 Prep Method SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 7470A 5 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 SW8463010A4 SW846 3010A 4 SW846 3010A 4 SW846 3010A 4 RL = Reporting Limit MDL = Method Detection Limit U = Indicates a result < MDL B = Indicates a result > = MDL but < RL Co C SG 18of61 DA62542 SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -2) Lab Sample ID: DA62542-3FC Matrix: AQ - Groundwater Filtered Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Prep Lithium a 0.0189 0.010 0.0043 mg/1 1 (1) Instrument QC Batch: L:MA27325 (2) Prep QC Batch: L:MP27849 MP27849 (a) Analysis performed at SGS Scott, LA. Analyzed By Method Prep Method 03/07/24 03/08/24 ALA SW846 6010C 1 SW846 3010A 2 RL = Reporting Limit MDL = Method Detection Limit U = Indicates a result < MDL B = Indicates a result > = MDL but < RL C SG 19of61 DA62542 SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID: DA62542-4 Matrix: AQ - Ground Water Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a General Chemistry Analyte 9056A Fluoride Chloride Nitrogen, Nitrite a Nitrogen, Nitrate Sulfate Result 0.77 77.6 < 0.040 0.54 237 9056A NO2 + NO3O Nitrogen, Nitrate + Nitrite b 0.54 Solids, Total Dissolved 655 RL Units DF Analyzed By Method 0.20 5.0 0.040 0.020 5. mg/1 mg/1 mg/1 mg/1 mg/1 2 03/01/24 22:42 MB 10 03/01/24 22:56 MB 10 03/01/24 22:56 MB 2 03/01/24 22:42 MB 10 03/01/24 22:56 MB 0.060 mg/1 1 10 mg/1 1 (a) Elevated detection limit due to matrix interference. (b) Calculated as: (Nitrogen, Nitrate) + (Nitrogen, Nitrite) SW846 SW846 SW846 SW846 SW846 9056A 9056A 9056A 9056A 9056A 03/01/24 22:56 MB SW846 9056A 03/04/24 07:00 JW SM 2540C-2011 RL = Reporting Limit w a C SG 20of61 DA62542 SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID: DA62542-4F Matrix: AQ - Groundwater Filtered Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a Dissolved Metals Analysis Analyte Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Chromium Cobalt Copper Iron Lead Manganese Mercury Molybdenum Nickel Selenium Silver Thallium a Uranium Vanadium Zinc Result 0.0177 B 0.0068 U 0.0046 U 0.0329 0.0013 U 0.202 0.0013 U 0.0013 U 0.0045 B 0.0013 U 0.012 U 0.0063 U RL 0.10 0.030 0.025 0.010 0.010 0.050 0.010 0.010 0.0050 0.010 0.070 0.050 0.582 0.0050 MDL Units DF Prep 0.015 0.0068 0.0046 0.0013 0.0013 0.0063 0.0013 0.0013 0.00063 0.0013 0.012 0.0063 0.00063 mg/1 mg/1 m g/1 mg/1 m g/1 mg/1 mg/1 mg/1 mg/1 mg/1 m g/1 m g/1 mg/1 0.000050 U 0.00010 0.000050mg/1 0.0087 B 0.0038 U 0.022 U 0.0038 U 0.0043 U 0.0190 B 0.0013 U 0.0192 B 0.010 0.030 0.050 0.030 0.015 0.050 0.010 0.030 (1) Instrument QC Batch: MA 17745 (2) Instrument QC Batch: MA17751 (3) Instrument QC Batch: MA 17763 (4) Prep QC Batch: MP39056 (5) Prep QC Batch: MP39057 0.0028 0.0038 0.022 0.0038 0.0043 0.0085 0.0013 0.0038 mg/1 mg/1 m g/1 mg/1 mg/1 m g/1 mg/1 m g/1 (a) Elevated reporting limit due to matrix interference. 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/13/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 03/12/24 Analyzed By Method 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/19/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/13/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 03/14/24 CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL CDL SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 3 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 7470A 1 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 SW846 6010C 2 Prep Method SW846 3010A 4 4 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 SW846 3010A 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 7470A 5 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 3010A 4 RL = Reporting Limit MDL = Method Detection Limit U = Indicates a result < MDL B = Indicates a result > = MDL but < RL SG 21of61 DA62542 SGS North America Inc. Report of Analysis Page 1of1 Client Sample ID: BARNHARDT SAND AND GRAVEL PIT (MW -3) Lab Sample ID: DA62542-4FC Matrix: AQ - Groundwater Filtered Project: Material Sites WQ Testing Date Sampled: 03/01/24 Date Received: 03/01/24 Percent Solids: n/a Dissolved Metals Analysis Analyte Result RL MDL Units DF Lithium a 0.0105 0.010 0.0043 mg/1 1 (1) Instrument QC Batch: L:MA27325 (2) Prep QC Batch: L:MP27849 MP27849 (a) Analysis performed at SGS Scott, LA. Prep Analyzed By Method Prep Method 03/07/24 03/08/24 ALA SW846 6010C 1 SW846 3010A 2 RL = Reporting Limit MDL = Method Detection Limit U = Indicates a result < MDL B = Indicates a result > = MDL but < RL SG 22 of 61 DA62542 Wheat Ridge, Co Section 5 Metals Analysis QC Data Summaries Includes the following where applicable: • Method Blank Summaries • Matrix Spike and Duplicate Summaries • Blank Spike and Lab Control Sample Summaries • Serial Dilution Summaries Uri SG 32 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 MB Metal RL IDL MDL raw final Aluminum 100 Antimony 30 14 6.8 -9.9 Arsenic 25 22 4.6 3.1 Barium 10 .3 1.3 -0.10 Beryllium 10 1 1.3 0.0 Boron 50 3.3 6.3 -3.9 Cadmium 10 1.9 1.3 -0.10 Calcium 400 6.6 50 Chromium 10 1.1 1.3 0.10 Cobalt 5.0 2.7 .63 0.30 Copper 10 4.6 1.3 -1.4 Iron 70 8.9 12 0.30 Lead 50 13 6.3 4.2 Lithium 5.0 .6 1.3 Magnesium 200 50 25 Manganese 5.0 .5 .63 0.50 Molybdenum 10 8.5 2.8 -0.10 Nickel 30 6.2 3.8 0.40 Phosphorus 100 91 16 Potassium 1000 84 130 Selenium 50 30 22 20.5 Silicon 200 41 150 Silver 30 .6 3.8 -0.10 Sodium 400 13 50 Strontium 5.0 .1 .63 Thallium 10 17 4.3 2.1 Tin 60 41 51 Titanium 10 .5 1.3 Uranium 50 3.9 8.5 -5.4 Vanadium 10 .9 1.3 -0.10 Zinc 30 9 3.8 9.9 46 15 1.4 <100 <30 <25 <10 <10 <50 <10 <10 <5.0 <10 <70 <50 <5.0 <10 <30 <50 <30 <10 <50 <10 <30 Associated samples MP39056: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits Page 1 SG 33of61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 MB Metal RL IDL MDL raw final (anr) Analyte not requested Page 2 SG 34 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F Spikelot QC Original MS ICPALL5 % Rec Limits Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead Lithium Magnesium Manganese Molybdenum Nickel Phosphorus Potassium 0.00 1010 1000 0.0 98.1 100 0.0 211 200 0.0 414 400 0.0 105 100 0.0 409 400 0.0 102 100 0.0 105 100 0.0 104 100 0.0 105 100 15.6 1040 1000 0.0 201 200 0.80 210 200 0.0 102 100 0.0 101 100 Selenium 0.0 215 200 Silicon Silver 0.0 41.6 40 Sodium am Strontium Thallium 0.0 199 200 Tin Titanium Uranium 0.0 209 200 Vanadium 0.0 104 100 Zinc 15.8 125 100 101.0 98.1 105.5 103.5 105.0 102.5 102.0 105.0 104.0 105.0 102.4 100.5 104.5 102.0 101.0 107.5 104.0 99.5 104.5 104.0 109.2 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 75-125 Associated samples MP39056: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits Page 1 SG 35 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F Spikelot QC Original MS ICPALL5 % Rec Limits (N) Matrix Spike Rec. outside of QC limit (anr) Analyte not requested s Page 2 SG 36 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F Spikelot MSD QC Original MSD ICPALL5 % Rec RPD Limit Aluminum 0.00 1020 1000 Antimony 0.0 106 100 Arsenic 0.0 218 200 Barium 0.0 415 400 Beryllium 0.0 106 100 Boron 0.0 413 400 Cadmium 0.0 104 100 Calcium Chromium 0.0 107 100 107.0 Cobalt 0.0 106 100 106.0 Copper 0.0 107 100 107.0 Iron 15.6 1060 1000 104.4 Lead 0.0 206 200 103.0 Lithium Magnesium Manganese 0.80 211 200 105.0 Molybdenum 0.0 107 100 107.0 Nickel 0.0 101 100 101.0 Phosphorus Potassium Selenium 0.0 218 200 109.0 Silicon Silver 0.0 41.8 40 104.5 Sodium am Strontium Thallium 0.0 195 200 97.5 Tin Titanium Uranium 0.0 218 200 109.0 Vanadium 0.0 106 100 106.0 Zinc 15.8 111 100 95.2 102.0 106.0 109.0 103.8 106.0 103.5 104.0 1.0 7.7 3.3 0.2 0.9 1.0 1.9 1.9 1.9 1.9 1.9 2.5 0.5 4.8 0.0 1.4 0.5 2.0 4.2 1.9 11.9 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 Associated samples MP39056: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits Page 3 SGS 37 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F Spikelot MSD QC Original MSD ICPALL5 % Rec RPD Limit (N) Matrix Spike Rec. outside of QC limits (anr) Analyte not requested Page 4 SG 38of61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal BSP Spikelot QC Result ICPALL5 % Rec Limits Aluminum Antimony Arsenic 220 Barium 415 Beryllium 106 Boron 407 Cadmium 104 Calcium Chromium 105 100 Cobalt 106 100 Copper 106 100 Iron 1040 1000 Lead 209 200 Lithium Magnesium Manganese 213 200 Molybdenum 104 100 Nickel 101 100 Phosphorus Potassium Selenium 219 200 Silicon Silver 41.5 40 Sodium am Strontium Thallium 203 200 Tin Titanium Uranium 209 200 Vanadium 106 100 Zinc 109 100 995 102 1000 100 200 400 100 400 100 99.5 102.0 110.0 103.8 106.0 102.0 104.0 105.0 106.0 106.0 104.0 104.5 106.5 104.0 101.0 109.5 103.8 101.5 104.5 106.0 109.0 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 80-120 Associated samples MP39056: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits O1 Page 1 SG 39of61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal BSP Spikelot QC Result ICPALL5 % Rec Limits (anr) Analyte not requested Page 2 SG 40of61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F QC Original SDL 1:5 %DIF Limits Aluminum 0.00 0.00 0-10 Antimony 0.00 0.00 NC 0-10 Arsenic 0.00 0.00 NC 0-10 Barium 0.00 0.00 NC 0-10 Beryllium 0.00 0.00 NC 0-10 Boron 0.00 0.00 NC 0-10 Cadmium 0.00 0.00 NC 0-10 Calcium Chromium 0.00 0.00 NC 0-10 Cobalt 0.00 0.00 NC 0-10 Copper 0.00 0.00 NC 0-10 Iron 15.6 0.00 23.7 (a) 0-10 Lead 0.00 0.00 NC 0-10 Lithium Magnesium Manganese 0.800 0.00 100.0(a) 0-10 Molybdenum 0.00 0.00 NC 0-10 Nickel 0.00 0.00 NC 0-10 Phosphorus Potassium Selenium 0.00 0.00 NC 0-10 Silicon Silver 0.00 0.00 NC 0-10 Sodium am Strontium Thallium 0.00 0.00 NC 0-10 Tin Titanium Uranium 0.00 0.00 NC 0-10 Vanadium 0.00 0.00 NC 0-10 Zinc 15.8 0.00 10.1 (a) 0-10 NC Associated samples MP39056: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits Page 1 SG 41of61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39056 Matrix Type: AQUEOUS Prep Date: 03/12/24 Methods: SW846 6010C Units: ug/1 Metal DA61679-1F QC Original SDL 1:5 %DIF Limits (anr) Analyte not requested (a) Percent difference acceptable due to low initial sample concentration (< 50 times IDL). UI Page 2 SG 42 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39057 Matrix Type: AQUEOUS Prep Date: 03/13/24 Methods: SW846 7470A Units: ug/1 Metal RL IDL MDL MB raw final Mercury 0.10 .015 .05 0.0087 <0.10 Associated samples MP39057: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested P1 UI Page 1 SG 43of61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39057 Matrix Type: AQUEOUS Prep Date: 03/13/24 Methods: SW846 7470A Units: ug/1 Metal DA62542-4F Spikelot QC Original MS HGWSR1 % Rec Limits Mercury 0.0 1.1 1 110.0 75-125 Associated samples MP39057: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits (anr) Analyte not requested PI N N UI Page 1 SG 44 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39057 Matrix Type: AQUEOUS Prep Date: 03/13/24 Methods: SW846 7470A Units: ug/1 Metal DA62542-4F Spikelot MSD QC Original MSD HGWSR1 % Rec RPD Limit Mercury 0.0 1.1 1 110.0 0.0 20 Associated samples MP39057: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits (anr) Analyte not requested PI N N UI Page 2 SG 45 of 61 DA62542 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing QC Batch ID: MP39057 Matrix Type: AQUEOUS Prep Date: 03/13/24 Methods: SW846 7470A Units: ug/1 Metal BSP Spikelot QC Result HGWSR1 % Rec Limits Mercury 1.0 1 100.0 80-120 Associated samples MP39057: DA62542-1F, DA62542-2F, DA62542-3F, DA62542-4F, DA62542-5F, DA62542-6F Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested PI N • W UI Page 1 SGS 46 of 61 DA62542 Wheat Ridge, CO Section 6 General Chemistry QC Data Summaries Includes the following where applicable: • Method Blank and Blank Spike Summaries • Duplicate Summaries • Matrix Spike Summaries CA SGS 47 of 61 DA62542 METHOD BLANK AND SPIKE RESULTS SUMMARY GENERAL CHEMISTRY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing Analyte Batch ID RL MB Result Units Spike Amount BSP Result BSP %Recov QC Limits Bromide Chloride Fluoride Nitrogen, Nitrate Nitrogen, Nitrate Nitrogen, Nitrite Nitrogen, Nitrite Solids, Total Dissolved Sulfate Associated Samples: Batch GN62770: DA62542-1, Batch GP36124: DA62542-1, Batch GP36126: DA62542-1, (*) Outside of QC limits GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36126/GN62780 GP36124/GN62778 GP36126/GN62780 GN62770 GP36124/GN62778 0.050 0.50 0.10 0.010 0.010 0.0040 0.0040 10 0.50 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 DA62542-2, DA62542-3 0.5 5 1 0.1 0.1 0.05 0.05 250 5 0.474 4.71 0.951 0.0923 0.0985 0.0508 0.0525 241 4.75 94.8 94.2 95.1 92.3 98.5 101.6 105.0 96.4 95.0 90-110% 90-110% 90-110% 90-110% 90-110% 90-110% 90-110% 90-110% 90-110% Page 1 9) SGS 48of61 DA62542 DUPLICATE RESULTS SUMMARY GENERAL CHEMISTRY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing Analyte Batch ID QC Sample Units Original DUP Result Result RPD QC Limits Solids, Total Dissolved GN62770 DA62542-6 mg/1 723 Associated Samples: Batch GN62770: DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 (*) Outside of QC limits 748 3.4 0-5.44% Page 1 9, 0) SG 49of61 DA62542 MATRIX SPIKE RESULTS SUMMARY GENERAL CHEMISTRY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing Analyte Batch ID QC Sample Units Original Spike MS Result Amount Result %Rec QC Limits Bromide Chloride Fluoride Nitrogen, Nitrogen, Nitrogen, Nitrogen, Sulfate Nitrate Nitrate Nitrite Nitrite GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36126/GN62780 GP36124/GN62778 GP36126/GN62780 GP36124/GN62778 DA62422-1 DA62422-1 DA62422-1 DA62422-1 DA62560-6 DA62422-1 DA62560-6 DA62422-1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 0.0 302 0.0 1.7 2.4 0.0 0.25 287 Associated Samples: Batch GP36124: DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36126: DA62542-1, DA62542-2, DA62542-3 (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits 12.5 125 25 2.5 2.5 1.25 1.25 125 12.0 416 24.5 3.9 4.8 1.0 1.4 405 96.0 91.2 98.0 88.0 96.0 80.0 92.0 94.4 80-120% 80-120% 80-120% 80-120% 80-120% 80-120% 80-120% 80-120% Page 1 SG 50of61 DA62542 MATRIX SPIKE DUPLICATE RESULTS SUMMARY GENERAL CHEMISTRY Login Number: DA62542 Account: JTCOCOW - J&T Consulting Project: Material Sites WQ Testing Analyte Batch ID QC Sample Units Original Spike MSD Result Amount Result RPD QC Limit Bromide Chloride Fluoride Nitrogen, Nitrogen, Nitrogen, Nitrogen, Sulfate Nitrate Nitrate Nitrite Nitrite GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36124/GN62778 GP36126/GN62780 GP36124/GN62778 GP36126/GN62780 GP36124/GN62778 DA62422-1 DA62422-1 DA62422-1 DA62422-1 DA62560-6 DA62422-1 DA62560-6 DA62422-1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 0.0 302 0.0 1.7 2.4 0.0 0.25 287 Associated Samples: Batch GP36124: DA62542-1, DA62542-2, DA62542-3, DA62542-4, DA62542-5, DA62542-6 Batch GP36126: DA62542-1, DA62542-2, DA62542-3 (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits 12.5 125 25 2.5 2.5 1.25 1.25 125 12.1 418 24.8 4.0 4.7 1.0 1.4 407 0.8 0.5 1.2 2.5 2.1 0.0 0.0 0.5 20% 20% 20% 20% 20% 20% 20% 20% Page 1 9, a cr) SG 51of61 DA62542 Wheat Ridge, Co Section 7 Misc. Forms Custody Documents and Other Forms (SGS Scott, LA) Includes the following where applicable: • Chain of Custody tA SG S 52 of 61 DA62542 CHAIN OF CUSTODY Page 1 of 1 a tia ,6,,........ 1\ V/ 1.01 nni l,', '" III V n I i I I V M\ I U M u V 4036 Youngfield Street, Wheat Ridge, CO 80033 FED -EX Tracking # Bottle OIdet Comm' # SGS mote # SGS ooh # DA62542 TEL: 303-425-6021 FAX: 303-425-6854 www.sgs.com/ehsusa Client / Reporting Information Project Information Requested Analysis ( see TEST CODE sheet) Matrix Codes Company Name SGS North America Inc. Project Name Material Sites WQ Testing FILTERMET LI OW - Dunking Waver GW - Ground Water WW - Water SW - Surface Water SO - Soil SL- Sludge SED-Sediment OI - Oil LIQ - Other Liquid AIR - Air SOL - Other Solid WP - Wipe FB-Field Blank EB-Equipment Blank RB- Rinse Blank TB -Trip Blank Street Address Street 4036 Youngfield Street Billing Information ( if different from Report to) City State Zip Wheat Ridge, CO 8003. City State Company Name Project Contact E-mail Kelly BlanchardC'sqs.colTt,j Project # Street Address Phone # Fax # 303-425-6021 Client Purchase Order # City State Zip Sampler(s) Narne(s) Phone TT Project Manager Attention Collecb'm Number of preserved Bottles SGS Sample Field ID / Point of Collection MEoHIDI viyl# Dare Time Sampled by Matrix #pi bottles T a y O i EI = 7 9 m a' o 0 m w 8 i LAB USE ONLY 1FC OGILVY RIVER FARM PIT (MW -1) 3/1/24 10.13:00 AM TT AQ X I X t 2FC OGILVY RIVER FARM PIT (MW -4) 3/1/24 10:35:00 AM TT AG X 3FC BARNHARDT SAND AND GRAVEL PI" 3/1/24 12.40:00 PM TT AQ X ' 4FC BARNHARDT SAND AND GRAVEL PI- 3/1/24 12:30:00 PM TT AQ SFC SWEET VALLEY PIT (MW -1) 3/1/24 12.55:00 PM TT AQ X I X k 6FC SWEET VALLEY PIT (MW -3) 3/1/24 1:10:00 PM TT AQ Turnaround Time ( Business days) Data Deliverable Information Comments / Special Instructions D I 0 o \`/,vj C)) )- htto.//www sos.corn/en/terms-and-conditions Approved By (SGS PM): / Data: I Commercial "A" (Level 1) State Forms Standard 10 Day (business) II Commercial "B" ( Level 2) Q EDD Format 5 Business Days RUSH Q REDT1 ( Level 3) II Other 3 Business Days RUSH FULT1 ( Level 4) a MI 2 Business Days RUSH Commercial "C" X Gt. MI 1 Business Day EMERGENCY Commercial "A" = Results Only X other Due 3/8/2024 Commercial IS" : Results + QC Summary Emergency & Rush T/A data available via Lablink Approval needed for RUSH/Emergency TAT Commercial "C" = Results + CC Summary + Partial Raw data Sample Custody must be documented below each time samples change possession, including courier delivery. Relinquished by Sampler: i�1 1 . ('� Date Time: rv'� '' .r Reo y ci By: ,` Relinquished B 1 2 CA( pate time: `r (�f(;fC IS.` Received By:. �> j 1 Relinquished by Sampler: 3 Date Time: Received By: 3 Relinquished By: 4 Date Time: Received By: 4 Relinquished by: 5 Date Time: Received By: 5 Custody Seal # O Intact Preserved where applicable On ❑ hiol intact ❑ Theirn ID In I Cooler Temp. r DA62542: Chain of Custody Page 1 of 3 SGS Scott, LA w•si 1 SGS 53of61 DA62542 03b,gE58,z3SeS Ziff ?CM Co Q VO Ooc j WWW O-03 F- p CD .. (Qo N 0 (a 1 In (W o CE o zoo on ZUMW-r U(A sw no-4CW WC CCWZ Z W Z O m ) 0 W.C)--- 2 O¢(�nv an 0 CC LL Q V 2 _ cc y a � Q uct V tiu el 03 aci-a W Ly CO CL ICC ac c Co C O is U- W OO iq ••a MIMEO MIMEO i a gal rrr An t U7. t SIIEZOEEL(' NC fa- y= M a T CC CC ta M CZ O1n- 1 CC CC ravoift Q) glitt eta Co ccI a CU arlikamdidiassassaismsoss lialSeseeemasseS 3/b0 dX3 Mffi ..8ti t99 # 1.16d' • t .; • DA62542: Chain of Custody Page 2 of 3 • rrrrrrra SGS 54 of 61 DA62542 SGS Sample Receipt Summary Job Number: da62542 Client: SGS NORTH AMERICA Date / Time Received: 3/5/2024 9:15:00 AM Delivery Method: Cooler Temps (Raw Measured) °C: Cooler 1: (3.6); Cooler Temps (Corrected) °C: Cooler 1: (3.6); Cooler Security 1. Custody Seals Present: 2. Custody Seals Intact: Cooler Temperature 1. Temp criteria achieved: 2. Cooler temp verification: 3. Cooler media: 4. No. Coolers: Y or N v V 3. COC Present: 4. Smpl Dates/Time OK Y or N v Ice (direct contact) 1 Quality Control Preservatio 1. Trip Blank present / cooler: 2. Trip Blank listed on COC: 3. Samples preserved properly: 4. VOCs headspace free: Y or N N/A v v v v Project: MATERIALS SITE WQ TESTING FEDEX Airbill #'s: 646648977174 Y or N v v Sample Integrity - Documentation 1. Sample labels present on bottles: 2. Container labeling complete: 3. Sample container label / COC agree: Sample Integrity - Condition 1. Sample recvd within HT: 2. All containers accounted for: 3. Condition of sample: Sample Integrity - Instructions 1. Analysis requested is clear: 2. Bottles received for unspecified tests 3. Sufficient volume recvd for analysis: 4. Com positing instructions clear: 5. Filtering instructions clear: Y or N v v v Y or N v v Intact Y or N N/A v v se v v Test Strip Lot #s: pH 1-12: pH 12+: Other: (Specify) Comments NP metals (6-250m1 bottles) expired upon receipt. Samples taken 3/1/2024 between 10:13-13:10 SM089-03 Rev. Date 12/7/17 DA62542: Chain of Custody Page 3 of 3 ftt4 SG S 55 of 61 DA62542 Wheat Ridge, Co Section 8 Metals Analysis QC Data Summaries (SGS Scott, LA) Includes the following where applicable: • Method Blank Summaries • Matrix Spike and Duplicate Summaries • Blank Spike and Lab Control Sample Summaries • Serial Dilution Summaries CO SG 56 of 61 DA62542 BLANK RESULTS SUMMARY Part 2 - Method Blanks Login Number: DA62542 Account: ALMS - SGS Wheat Ridge, CO Project: JTCOCOW: Material Sites WQ Testing QC Batch ID: MP27849 Matrix Type: AQUEOUS Prep Date: 03/07/24 Methods: SW846 6010C Units: ug/1 MB Metal RL IDL MDL raw final Aluminum 100 13 25 Antimony 6.0 2 3.6 Arsenic 10 2.4 8.6 Barium 10 .36 1.7 Beryllium 4.0 .06 .9 Boron 100 .72 42 Cadmium 5.0 .14 .9 Calcium 100 3.8 32 Chromium 10 .39 1.2 Cobalt 10 .26 1.1 Copper 10 .77 2.8 Iron 100 2.9 18 Lead 10 1.4 3.7 Lithium 10 2.4 4.3 1.5 Magnesium 100 22 40 Manganese 10 .11 .9 Molybdenum 10 .16 1.7 Nickel 10 .29 1.5 Potassium 500 50 120 Selenium 10 1.5 4.3 Silver 10 .57 3.7 Sodium 500 20 120 Strontium 10 .1 3 Thallium 10 1.5 4.6 Tin 10 .74 1.7 Titanium 10 .41 .8 Vanadium 10 .39 1.5 Zinc 20 .18 12 <10 Associated samples MP27849: DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested ®0 Page 1 SGS 57 of 61 DA62542 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: ALMS - SGS Wheat Ridge, CO Project: JTCOCOW: Material Sites WQ Testing QC Batch ID: MP27849 Matrix Type: AQUEOUS Prep Date: 03/07/24 Methods: SW846 6010C Units: ug/1 Metal LA98821-13 Spikelot QC Original MS ICPSPIKE1% Rec Limits Aluminum Antimony anr Arsenic anr Barium anr Beryllium Boron Cadmium anr Calcium Chromium anr Cobalt anr Copper anr Iron anr Lead anr Lithium 0.0 1740 2000 75-125 Magnesium Manganese anr Molybdenum Nickel anr Potassium Selenium anr Silver anr Sodium Strontium Thallium Tin anr Titanium Vanadium Zinc anr Associated samples MP27849: DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits (anr) Analyte not requested Page 1 SG 58of61 DA62542 87.0 MATRIX SPIKE AND DUPLICATE RESULTS SUMMARY Login Number: DA62542 Account: ALMS - SGS Wheat Ridge, CO Project: JTCOCOW: Material Sites WQ Testing QC Batch ID: MP27849 Matrix Type: AQUEOUS Prep Date: 03/07/24 Methods: SW846 6010C Units: ug/1 Metal LA98821-13 Spikelot MSD QC Original MSD ICPSPIKE1% Rec RPD Limit Aluminum Antimony anr Arsenic anr Barium anr Beryllium Boron Cadmium anr Calcium Chromium anr Cobalt anr Copper anr Iron anr Lead anr Lithium 0.0 1740 2000 87.0 20 Magnesium Manganese anr Molybdenum Nickel anr Potassium Selenium anr Silver anr Sodium Strontium Thallium Tin anr Titanium Vanadium Zinc anr Associated samples MP27849: DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (N) Matrix Spike Rec. outside of QC limits (anr) Analyte not requested Page 2 SG 59of61 DA62542 0.0 SPIKE BLANK AND LAB CONTROL SAMPLE SUMMARY Login Number: DA62542 Account: ALMS - SGS Wheat Ridge, CO Project: JTCOCOW: Material Sites WQ Testing QC Batch ID: MP27849 Matrix Type: AQUEOUS Prep Date: 03/07/24 Methods: SW846 6010C Units: ug/1 Metal BSP Spikelot QC Result ICPSPIKE1% Rec Limits Aluminum Antimony anr Arsenic anr Barium anr Beryllium Boron Cadmium anr Calcium Chromium anr Cobalt anr Copper anr Iron anr Lead anr Lithium 915 1000 91.5 80-120 Magnesium Manganese anr Molybdenum Nickel anr Potassium Selenium anr Silver anr Sodium Strontium Thallium Tin anr Titanium Vanadium Zinc anr Associated samples MP27849: DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested ®O W Page 1 SG 60of61 DA62542 SERIAL DILUTION RESULTS SUMMARY Login Number: DA62542 Account: ALMS - SGS Wheat Ridge, CO Project: JTCOCOW: Material Sites WQ Testing QC Batch ID: MP27849 Matrix Type: AQUEOUS Prep Date: 03/07/24 Methods: SW846 6010C Units: ug/1 Metal LA98821-13 QC Original SDL 1:5 %DIF Limits Aluminum Antimony anr Arsenic anr Barium anr Beryllium Boron Cadmium anr Calcium Chromium anr Cobalt anr Copper anr Iron anr Lead anr Lithium 0.00 13.2 0-10 Magnesium Manganese anr Molybdenum Nickel anr Potassium Selenium anr Silver anr Sodium Strontium Thallium Tin anr Titanium Vanadium Zinc anr Associated samples MP27849: DA62542-1FC, DA62542-2FC, DA62542-3FC, DA62542-4FC, DA62542-5FC, DA62542-6FC NC Results < IDL are shown as zero for calculation purposes (*) Outside of QC limits (anr) Analyte not requested oo S Page 1 SG 61of61 DA62542 McGrane Water Engineering MEMORANDUM To: JC York — J&T Consulting, LLC From: Dennis McGrane, P.E., C.P.G. — McGrane Water Engineering, LLC Date: February 23, 2024 Project: Bernhardt Pit Groundwater Model Subject: Response to Questions by DRMS (10/20/23) BACKGROUND McGrane Water Engineering, LLC (MWE) prepared a report dated May 31, 2023 titled, "Bernhardt Pit — Groundwater Evaluation" to support a mine application permit for the Bernhardt Pit prepared by the applicant by J&T Consulting, Inc (J&T). The Colorado Division of Reclamation, Mining and Safety (DRMS) reviewed the report in an internal memorandum dated October 20, 2023, titled, "Bernhardt Sand and Gravel Pit, New Permit Application, Groundwater Review, File No. M2023-025. JC York (J&T Consulting) requested MWE address DRMS's questions no 6 and 7. DRMS QUESTION No. 6 "In review of Figure 10A along with the predicted mounding of �2.5 feet on the upstream side of the proposed permit boundary, it appears the predicted mounding combined with high groundwater levels seen in July 2023 will bring groundwater elevations to within 0.5 feet of ground surface at MW -3. Additionally, extrapolating the potential mounding groundwater elevations during high groundwater levels away from the permit boundary in the southwestern area, it appears that the mounding will result in groundwater being exposed at the surface. Please update the groundwater model using the highest groundwater elevations to evaluate the potential of groundwater being exposed at the surface along the boundary of the permit. It should be noted that groundwater elevations approaching the surface can cause offsite land user issues due to saturated ground conditions. When updating the groundwater model figures, please label the individual well location I.D. 's. " Response: We can do this calculation without creating a transient groundwater model due to the principal of superposition (Reilly and Others, 1987), which means that the solution to a problem involving multiple inputs (or stresses) is equal to the sum of the solutions to a set of simpler individual problems. This is accomplished by first measuring water levels at monitoring wells surrounding McGrane Water Engineering, LLC Page l of 5 1669 Apple Valley Rd. • Lyons, CO 80540 • Phone: (303) 917-1247 E -Mail: dennisnmcgranewater.coin Web: http://www.mcgranewaterengineering.coin the proposed pit to record and evaluate the factual variability. Second, we determine how the predicted modeled change in water levels affects the seasonal depth measurements. Third, we used the model to determine how effective various drain depth designs mitigate upgradient mounding; and lastly we add the changes from the various model runs to the observed seasonal water level values using the concept of superposition. By using the superposition approach, we do not need to spend additional time creating and calibrating a transient groundwater model. Such a model would require estimating or measuring other variables such as precipitation, river stage and evapotranspiration and estimating seasonal recharge which have their own range of measurement error and variability. Then, the process of calibration, which is to match observed to modeled heads in a transient condition would be a waste of time. Since groundwater flow is primarily a function of aquifer properties and gradient, we can use the steady state model and the principal of superposition to achieve an accurate result. Water levels were initially measured in March 2023 and used as model water level targets in the pre -pit model simulation (Report Figure A4). Coincidentally, the levels happen to be when seasonal water levels were deepest. The March 2023 depth to water ranged from 4.42 ft at MW - 1 to 8.0 ft at MW -3. By July however, water levels had risen to within 1.96 ft at MW -1 and 3.66 ft at MW -3. The maximum seasonal water table fluctuation (ie. change) between March and July (highlighted) ranges from 2.46 (MW -1) to 4.33 ft (MW -3). The observed depths to water at various monitoring wells are shown in the Table 1 below. Table 1— Bernhardt Pit Monitoring Well Water Level Depths and Elevations. Well Designation JT MW -1 JT MW -2 JT MW -3 JT MW -4 Location: North Side East Side West Side South Side Top of Well Elevation (ft) 4722.96 4723.15 4727.70 4726.65 Ground Elevation (ft) 4719.92 4720.09 4724.78 4723.56 Date Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) Depth to Groundwater from Top of Well (ft) Depth to Groundwater from Ground (ft) Elevation of Groundwater (ft) March 29, 2023 7.46 4.42 4715.50 9.27 6.21 4713.88 10.92 8.00 4716.78 10.38 7.29 4716.28 April 21, 2023 7.60 4.56 4715.36 8.10 5.04 4715.05 10.02 7.10 4717.68 9.02 5.93 4717.63 May 18, 2023 6.29 3.25 4716.67 6.04 2.98 4717.11 8.54 5.62 4719.16 6.58 3.49 4720.07 June 12, 2023 5.67 2.63 4717.29 6.00 2.94 4717.15 7.50 4.58 4720.20 6.33 3.24 4720.32 July 14, 2023 5.00 1.96 4717.96 5.92 2.86 4717.23 6.58 3.66 4721.12 6.21 3.12 4720.44 August 14, 2023 5.75 2.71 4717.21 6.92 3.86 4716.23 i 7.33 4.41 4720.37 8.58 5.49 4718.07 September 13, 2023 7.67 4.63 4715.29 8.17 5.11 4714.98 9.92 7.00 4717.78 9.00 5.91 4717.65 October 16, 2023 7.83 4.79 4715.13 8.33 5.27 4714.82 10.17 7.25 4717.53 9.17 6.08 4717.48 Max Fluctuations (ft) = 2.46 3.35 4.33 4.17 As requested in this question, we will evaluate the depth to water relative to the ground surface in our response to question No. 7 below and reference the monitoring well locations on the accompanying figures. QUESTION No. 7 "Please provide a groundwater model analysis to demonstrate how effective installing the proposed underdrain will be to mitigate the predicted groundwater mounding on the upstream side of the proposed slurry -wall" McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons, CO 80540 • Phone: (303) 917-1247 E -Mail: dennis@mcgranewater.coin Web: http://w-vvw.mcgranewaterengineering.coin Page 2 of 5 Response: We used the model to evaluate pit liner impacts as discussed in our modeling report. For drain runs, we used the MODFLOW "Drain" package which simulates a drain using a cross sectional area, assumed permeability around the drain and a specified setting depth. The deeper the pipe, the more it lowers the water table and therefore flows (removes water from the model). Water level flow into a drain is controlled by the conductance term (COND) which is a function of the drain area, permeability of the gravel fill around the drain and depth below the water surface. We assume a 1 -ft cross-sectional drain surrounded by gravel with a hydraulic conductivity (K) of 400 ft/day. For a 200 -ft long model cell, COND = 80,000 ft" 2day (400 ft/day x 1 ft x 200 ft). COND is calculated internally by the model using the digitized length of drain across each model cell. After running the model with a MODFLOW drain, we iteratively reinject the cumulative drain volume (divided by the number of cells) using the MODFLOW "Well" package which allows us to "inject" groundwater in adjacent cells similarly to how a horizontal drain would release water into the aquifer along the drain. Note: drain flow from a horizontal exfiltration drain would occur more in response to gravity and be a function of aquifer levels, whereas injecting through wells causes a more equal distribution. Regardless, positive water level changes reflect mounding on the upgradient side of the proposed pit and negative (-) reflect shadowing on the downgradient side of the pit. Table 2 shows the measured depth to water in July (Column "a") which is when the depth to water is shallowest. Modeled "Mounding (+) and Shadowing (-) "changes" were determined by calculating the differences in water table elevation for model cells where monitoring wells are present. MW -3 is where shallow groundwater is most vulnerable to reach the surface which is why those levels are highlighted in red. Table 2 — Modeled Changes Due to Pit Lining and Drain Installation Well Measured Depth to (ft) July Water Modeled Mounding (+)/Drawdown (-) Forecast July Depth to Water (ft) With Pit (Elev. With Drain 4718 ft) (Elev. With Drain 4717 ft) (Elev. With Drain 4718 ft) With Drain (Elev. 4717 ft) (a) (b) (c) (d) (a+c) (e ) (a+d) (f) Run: <Bern_SS7> <Bern_SS9_d4> <Bern_SS9_d5> Upgradient (MW -3) _ -1.96 2.52 0.33 -0.67 -1.63 -2.63 Upgradient (MW -4) = -2.86 0.86 0.52 0.2 -2.34 -2.66 Downgradient (MW -1) = -3.66 r -2.61 -2.54 -2.61 -6.2 -6.27 Downgradient (MW -2) = -3.12 -0.68 ! -0.44 -0.72 -3.56 -3.84 Drain flow (gpm) = 260 -400 Column "b" is the calculated modeled change caused by the pit liner (Run Bern_SS7), which causes mounding at upgradient wells MW -3 (2.52 ft) and MW -4 (0.86 ft), and downgradient shadowing at wells MW -1 (-2.61 ft) and MW -2 (-0.68 ft) as shown in report Figure A-10 and Figure 1 below. McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons, CO 80540 • Phone: (303) 917-1247 E -Mail: dennisnmcgranewater.coin Web: http://w-vvw.mcgranewaterengineering.coin Page 3of5 Figure 1 Change Associated with the Pit Liner (Report Figure A10 with Labels) 13 MW -1 ;MW -3 Nva14477-F . e. 5=WCB 7:785-R 0'S 42519:F' solICek- ;S: 85 -R -R 155687L5 155687-A 14523 -R -R 18 -44\14524-R 841-WCB 1370,-F 19924-X 13703-R I I 279 4411 u�U1Ml 275938 232159 19 C19 185466-A 19924 -V -R As discussed in the modeling report, the contours show upgradient mounding and downgradient shadowing in the range of +/- 2.5 feet. Drain Runs In drain run <Bern_SS9_d4>, we establish an upgradient drain at elevation 4718 ft (yellow cells). The resulting mounding (Figure 2) compared to the pre -pit run at MW -3 (+0.33) and MW -4 (+0.52 ft) are insignificant, but the downgradient shadowing in MW -2 (-0.44 ft) and MW -1 (-2.54 ft) provides only a minor improvement over the non -drain pit impact run (Figure 1). We suspect that most of the exfiltrating groundwater recharges the SPR instead of filling up the shadow zone further to the west. We believe this is not a big problem since there are no downgradient wells within the shadow zone. The modeled drain flow is approximately 260 gpm. Figure 2 — Drain Run (Drain Elev. 4818 ft.) If we add the maximum "change" caused by the drain to the observed shallowest level measurement in July, then the predicted depth to water in upgradient wells (MW -3 to MW -4) McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons, CO 80540 • Phone: (303) 917-1247 E -Mail: dennisnmcgranewater.coin Web: http://www.mcgranewaterengineering.coin Page 4 of 5 ranges from -1.63 to -2.34 ft as shown in Table 2 (column e) above. The predicted July depth to water at MW -3 will likely therefore be shallower than observed in 2023. On the downgradient side, the expected depths to water at both MW -1 and MW -2 will likely be deeper than recently measured because the exfiltrating groundwater will likely flow to the SPR instead of filling the shadow zone. Again, we believe this is not a problem since there are no downgradient wells within the shadow zone (>0.5 ft). To be conservative, we recommend installing a deeper drain (at the 4,717 ft elevation) to reduce seasonal upgradient water level depths. Not surprising, by lowering the drain 1 -ft, the predicted water level drop at MW -3 is the same amount. Overall, the predicted water level at MW -3 will be drop -0.67 ft compared to pre -pit conditions. MW -4 still rises 0.2 ft because there is no drain in that model cell. Downgradient shadowing at MW -2 (-0.72 ft) and MW -1 (-2.61 ft) increases due to the increased drain flow (400 gpm). We did not include the modeled drawdown because it looks very similar to Figure 2. If we add the modeled "change" to the original depth to water, we predict the upgradient depth at wells MW -3 (-2.63ft) to be a foot deeper than observed and MW - 4 (-2.66 ft) to be about the same as measured (-2.86). On the downgradient side, the expected depths to water at both MW -1 and MW -2 will likely be deeper than recently measured. Again, we do not expect this to be an issue since no wells are within the shadow zone in excess of >0.5 ft as shown on Figures 1 and 2. Conclusion We conclude: 1 Using the concept of superposition, we can use the steady state groundwater model to estimate seasonal groundwater conditions. A drain can be installed that stabilizes the seasonal fluctuations such that groundwater will not reach the ground surface and upset the hydrologic balance. 2. A drain installed at a depth of 4,817 ft (across model cells shown in Figure 2) could reduce seasonally high water levels at upgradient well MW -3. Most exfiltrating groundwater will return directly to the SPR thereby leaving downgradient shadowing unmitigated. However, this should not be a problem since there are no downgradient wells within the shadow zone. 3 Based on a simulated drain elevation of 4717 ft bgl, we predict drain flow to be approximately 400 gpm. To account for uncertainty, we recommend that it be designed to flow approximately 800 gpm. Sources Reilly, T.E., O.L. Franke, and G.D. Bennett, 1987. The Principal of Superposition and its implication in Ground -water Hydraulics. U.S. Geological Survey Techniques and Methods 3-B6. Reston, Virginia. McGrane Water Engineering, LLC 1669 Apple Valley Rd. • Lyons, CO 80540 • Phone: (303) 917-1247 E -Mail: dennisnmcgranewater.coin Web: http://w-vvw.mcgranewaterengineering.coin Page 5of5 EXHIBIT H Wildlife Information The project area was surveyed for general wildlife habitat by Ecological Resource Consultants (ERC). The Screening Report for Federal and State Listed Threatened and Endangered Species from ERC is attached which describes the wildlife habitat present on the site and the common species that may be found in the habitat area. ERC conducted this screening for federal and state threatened, endangered and species of concern for the approximately 134 -acre survey area. The following provides key items identified as part of the report: 1. Two primary land use class/vegetation cover type exists within the survey area. Habitat within the survey area is characterized as the Great Plains Ruderal Grassland and Shrubland (98%) and disturbed (2%). Historic land use for agricultural practices has led to degradation of the native vegetation community. 2. Generally, there are features on the survey area and the surrounding area that provide general habitat for local songbirds, raptors, and small to mid -size mammals. However, habitat within the survey area is somewhat degraded and of lower ecological value from a wildlife perspective due to historic and current land use for agriculture, which has restricted overall growth and establishment of vegetation. The South Platte River and adjacent eastern cottonwood floodplain and woodland, provides suitable habitat for wildlife species and MBTA species. The South Platte River and associated vegetative community will not be impacted by the proposed project. 3. Non -raptor birds No non -raptor migratory bird nests were observed within the survey area. However, prior to vegetation removal a nest survey should be completed to ensure that no nests have become established within the survey area and active nests, if any, are not disturbed. Non -eagle Raptors No non -eagle raptor nests were observed and no CPW mapped non -eagle raptor nest protection zones are located within the survey area (CPW 2023a). However, nest activity status can vary seasonally and from year-to-year. Future land use changes may require additional nest surveys (generally between February 1 and September 15 (CPW 2020)) to determine activity status within % to ' mile of the survey area to ensure compliance with CPW recommendations. Eagles CPW SAM data identifies a bald eagle nest listed as "destroyed" being directly northeast of the survey area. Per CPW monitoring logs, the eagle nest has been inactive from 2019-2021, and destroyed in 2022. A field visit by ERC on January 25, 2023 confirmed the identified nest no longer exists and the nest area is no longer being utilized with no efforts by eagles to rebuild the nest. Therefore, the nest site and the survey area is not subject to any restriction per CPW protective buffer zone recommendations or USFWS Bald Eagle Protection Act. 4. No federally listed threatened and endangered species and/or habitat protected under the ESA were identified within the survey area. The survey area is not within designated critical habitat of any federally listed species. The vegetation community and features within the survey area were investigated as potential habitat for federally listed species. Any future land use changes will result in No Take on any federal listed species, their habitats, or proposed or designated critical habitat. 5. No State listed threatened or endangered species and/or habitat protected by CPW under Colorado Statute Title 33 were identified within the survey area. The vegetation communities within the survey area were investigated as potential habitat for state listed species. Any future land use changes will have no effect on any state listed species, their habitats, or proposed or designated critical habitat. ERC 2023 provided a detailed evaluation of potential critical wildlife habitat and use within the Permit Area. The Permit Area was determined to be comprised of 100% ruderal grassland and disturbed lands which is generally considered low -value wildlife habitat. No federal or state listed threatened and endangered species/habitat were identified. Following the preparation of ERC 2023, CPW issued ("-March 2023) new wildlife Species Activity Mapping (polygons) that depict the Permit Area within Mule Deer High Priority Habitat (HPH). This CPW polygon encompasses more than 955 square miles (-611,000 acres) acres along the South Platte and Big Thompson Rivers (refer to Figure 1 in ERC's Adequacy Review Responses to CPW below). The Permit Area represents less than 0.02 `)/0 of this entire HPH polygon. In order to minimize potential disturbances to the HPH, the project will implement CPW recommendations addressed in Item 10 of their comment e-mail to DRMS also attached below. No other critical habitat or seasonal wildlife use has been identified within the Permit Area. It is not anticipated that operations (increased traffic, noise, light) will have a significant effect on wildlife in the area. Refer to ERC 2023 for further explanation. Attached are ERC's Adequacy Review Responses to CPW's comments and the Screening Report for Federal and State Listed Threatened and Endangered Species. W.W. Clyde & Co. commits to conducting a raptor survey prior to mobilization of earth -moving equipment or excavation at the site. The survey will be conducted and results submitted to the DRMS as a technical revision 30 days prior to mobilization of earth -moving equipment or excavation. Hello