The URL can be used to link to this page

Browse Search

Home My WebLink About20252921.tiffHATE I IALS uc October 24, 2025 Patrick Lennberg Environmental Protection Specialist Colorado Division of Reclamation Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 T'ci trz3_;of Document Included in Raper File Remainder Retained Electronically RECEIVED .7 95 WELD COUNTY COMMISSIONERS Re: Technical Revision 5, Kurtz Resource Recovery & Land Development, File No. M-1999-006 Dear Patrick: This Technical Revision is in response to the Inspection Report for this permit dated June 2, 2025 addressing the Inspection Topic: Gen. Compliance With Mine Plan. We believe based on the permit history from the original application and approval, through the previous Technical Revisions, and from discussions on this and prior inspections, that the updates presented to the proposed remaining mining and reclamation do not have a significant effect upon the approved Mining or Reclamation Plan. What we are clarifying in this Technical Revision is the intention to create lined water storage reservoirs in three of the four extraction areas that were always proposed to be water storage, however while progressive reclamation documented over the years has included lining the pit walls to create an impervious liner, the permit has not explicitly addressed this. Indeed, in response to a 2018 inspection this was discussed as the logical approach to release the water held if these basins with exposed ground water. At issue in that earlier inspection and being addressed more completely in response to the current inspection report seeking clarification on the plans are the plans for mining of remnant peninsulas housing oil and gas infrastructure, backfilling of certain areas of the pits, and post -mining land use. Mining of Remnant Areas Small remnant areas remain along the southern property boundary of Tract A resulting from existing oil and gas wells and infrastructure. Raptor has revised the extraction areas to fully recover two peninsulas and a small wedge of material where oil and gas infrastructure is currently located. It is Raptors' understanding that the wells and infrastructure are to be removed in the near future which would allow more complete extraction and recovery of the resource in this area. Raptor have stated clearly that while any of this infrastructure remains in place, the necessary setbacks will be maintained. TkbUC?eviw) CCU. rt_L-DfstRiat DAI AM) lam- I Pim)) 101Z9Z5 L_614-(chjaPst1/41- 2025-2921 Backfilling The extraction areas proposed are the maximum extents. As stated in prior Technical Revision: The flexibility of the material for both production and reclamation requires some mutual flexibility in the representation of the final site configuration within a known area. By this measure, the basin limits (Map 1) are determined as the maximum extent of the basins based upon approved setbacks, and may be smaller, but will not be larger, as a result of the final placement of structural fill from wash plant recycling activities. The extraction limits shown in the updated Exhibit C -2a and C -2b maps are generally consistent with those in previous filings. There may be areas where existing operational activities are on fill material. The fmal decision on whether all that material will be removed toward the final completion of operations will depend on the market for the material involved. In some cases, this is silty material accumulating and periodically cleaned out from ponds in the water recycling for the wet plant. This material can and has been successfully used as a soil substitute both within the permit or as a saleable product. In other cases, the material may be used for lining or regrading fmal walls. In the event there is an excess of material that cannot be used either within the existing or nearby Raptor permits or sold as a commercial product, it may either be left in place resulting in some changes to the final extents of the reservoirs or be regraded to create a more natural variability in the shoreline, basin slopes and basin floor. The final configuration cannot be known with absolute certainty until the operations have run their course, and no further material is required to complete reclamation or has a ready market and will be addressed in a Technical Revision as needed. Post -Mining Land Use While the permit application document only allows one "Primary" present (pre -mining) and future (post -mining) land use, this site effectively contained two significant pre - mining land uses with General Agriculture more prevalent in the uplands and Rangeland more typical in the lower terrace closer to the creek. The post -mining land use as reflected in the original permit application and subsequent technical revisions will consist of multiple uses including Rangeland in the generally undisturbed areas, Developed Water Resource in select extraction areas, and General Agriculture in upland areas either backfilled or otherwise used and reclaimed. It is more likely than not that reclamation would favor Rangeland over General Agriculture to take advantage of the reservoirs. Nonetheless, a clear designation of what would be Rangeland versus General Agriculture has not been made and would be dependent on the final configuration as discussed previously on the subject of Backfill and the preferences of the landowner at that future point in time. Raptor does not propose to change the primary post -mining land use from General Agriculture, but this understanding of the site holistically is an important foundation for the reclamation plan. The lining of the basins in the period since original approval of the permit has attracted more extensive consideration of the impacts to the hydrologic balance due to shadowing and mounding phenomena created by the lining. Raptor (then Varra) in 2019 completed If you have any questions, please contact me. Regards, Robert Haun Vice President of Operations an evaluation in preparation for a Technical Revision which fell by the wayside due to circumstances within the business, and an extended sale process (due to Covid) of the business to become Raptor Materials. A more current report has been prepared by American Water Engineering Services, LLC (AWES) to evaluate the potential impacts of lining the pits. This report is provided as an addendum to the existing Exhibit G. The 2019 evaluation and recent review by AWES showed minimal impacts as a result of lining the pits supporting Raptor's belief that the changes to the permit do not have a significant impact. Attached are the following: Exhibit D — Mining Plan Exhibit E — Reclamation Plan Exhibit L - Reclamation Costs Exhibit C -2a — Mining Plan Map - Part 1 Exhibit F — Reclamation Plan Map Addenda Exhibit D - Raptor Materials: List of Aggregate Products Exhibit E - Backfill Notice - Raptor Materials Universal Stormwater Management Plan (2023) Exhibit G - Kurtz Lined Pit Analysis (AWES, 2025) - CDPS General Permit COG500000 Discharge Certification Exhibit L Kurtz Reclamation Cost Estimate Update — Quantities Summary (July 2025) Kurtz 2025 Financial Warranty Update Tables Kurtz Financial Warranty Increase Letter (July 8, 2025) Kurtz Financial Warranty Increase Acceptance Letter (July 29, 2025) Dewatering Estimates Memo for Raptor Pit P125 (AWES, 2024) Kurtz 2024-2025 Annual Report Financial Warranty Map Seed Mix Calculator Quote: Overland Conveyor Dismantle — Heintzelman Pit (Divide Constructors, 2025) PAGE 1 EXHIBIT D EXHIBIT D -MINING PLAN The mining plan shall supply the following information, correlated with the affected lands, map(s) and timetables: SECTION [A] (a) Description of the method(s) of mining to be employed in each stage of the operation as related to any surface disturbance on affected lands; Via Technical Revisions in 2009 and 2011, the mining areas designated in the original application were simplified to four tracts, A, B, C, and D as have been shown in Annual Report maps to the present day and are set out in Exhibit C -2a: Mining Plan Map. Extraction is largely complete in Tract A with small remnant areas remaining. The dry plant is also located in Tract A. Mining is also complete in Tracts C and D with Tract D largely backfilled and Tract C reclamation pending. Tract B contains most of the remaining material to be extracted and has intermittent extraction ongoing. The wash plant and associated product stockpiles are located within Tract B and it is intended these areas will remain until extraction on other adjacent Raptor property is completed. This updated Mining Plan will outline the current status and proposed plan to complete the extraction of the remaining areas with corresponding updates to Exhibit E: Reclamation Plan. Various references to ponds and basins in previous application and revision documents that were used interchangeably in reference to long term water storage facilities (lined or unlined) are now referred to as basins or lined water storage reservoirs. Reference to ponds will be reserved for more temporary facilities for process water or general water management. Entry to the mine for heavy equipment and haul traffic occurs from the northern boundary of the operations from Colorado Highway 66, as shown on Exhibit C -2a: Mining Plan Map. The initial mining and reclamation plan was intended to facilitate the safety of Weld County Road 17 in its present location. Upon the termination of all resource recovery, exhaustion of stockpiled resource and reclamation of the property, as part of that reclamation, the intent is to relocate Weld County Road 17 to the approximate location shown on Exhibit F: Reclamation Plan Map. Soils are described more thoroughly under Exhibit I: Soils, and the attending Exhibit I/J: Soils and Vegetation Map. Topsoil is considered to be the material to a depth of 4.0± to 10.0± inches (6.0± inches average) with salvage not exceeding the upper foot to minimize removal of soils where salts may have accumulated in the lower horizons due to past irrigation practices. Generally, total overburden depth over the property was approximately four [4.0±] feet, with a gravel depth to shale varying 15.0± to 40.0± feet over the entire property. Site geology is typified by mixed alluvial and aeolian development, that is predominantly alluvial in nature, with groundwater varying from one foot below the surface in the wetland portions of the lower terrace (mostly Section 29), to 7.0± to 10± feet along portions of the upper terrace (mostly Section 28). The site is fully developed with significant extraction and reclamation having taken place. Site features include settling ponds for management of water to be discharged at approved discharge points, silt ponds for the process water, wet and dry process plants, and stockpile areas. Various other infrastructure includes a security building, truck scale, and minor ancillary buildings for storing parts and supplies and conducting minor maintenance. A conveyor delivers material from the nearby Raptor Parcel 122 operation (M2015-003) to the processing plant areas. These features are all evident on Exhibit C -2a: Mining Plan Map. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 2 EXHIBIT D Resource recovery would normally commence by first removing the upper four to ten inches of soil [six (6.0±) inches typical], combined with existing grass or crop stubble however at the advanced stage of this operation, all soil has been removed. Soil stockpiles are currently maintained in the nearby Parcel 122 operation (M2015-003). Removing the overburden to expose the sand and gravel would follow however this too has been largely completed in all areas where sand and gravel remains to be extracted. The extent of areas disturbed is shown on Exhibit C -2a. Any overburden encountered in mining the remnant areas will be used as fill either in areas to be backfilled, or in regrading the basin slopes. Extraction of remaining sand and gravel employs a dry mining method where perimeter drains at the base of the sand and gravel horizon intercept ground water and divert it to in -pit sumps. From the sumps the water is pumped into settling ponds for discharge back to the environment at approved discharge locations. Extraction involves loading of off -road articulated dump trucks by excavators or wheel loaders for transportation to the processing facilities. Plant equipment includes but is not limited to the set-up of a crusher, screens, and conveyors, scale house and attending equipment. Plant equipment will also include the establishment of asphalt and concrete batch plant operations. Resulting stockpiles of pit run and processed products are located in Tract B and the northern areas of Tract A. Plant activities also include a wash plant and wash and silt ponds to recycle wash water and receive discharge silts and other reject fines from the washed product. Plant and wash/silt pond areas are identified on Exhibit C — 2a: Mining Plan Map. All water requirements and sources for the operation are identified under Exhibit G: Water Information and will be in conformance with all requirements of the Colorado Division of Water Resources - Office of the State Engineer. Ultimately, the closed system wash and silt ponds will fill with silt and be revegetated in a manner consistent with Exhibit E: Reclamation Plan. Interim clean out of the wash and silt ponds will occur, returning the inert materials to the bottom of exhausted pits, or utilizing it in part or in whole as product, or for purposes as substitute soil, soil additive, or as subsoil for reclamation. Silt or other reject fines from the wash pond that are used for reclamation will be soil tested for suitability prior to use, and all tests will be included in the Annual Report to the DRMS. Plant and material processing activity will divide materials into diverse and dynamic product stockpiles [refer to Section G, below], that will come and go with unpredictable variations in sale and production. To the extent possible, product material will surround plant activities to lessen visual and noise impacts to surrounding properties. Relative to noise, traffic along Colorado Highway 66 is approximately 70.0± decibels within 100 feet from the centerline of the Highway. Noise at ground zero, as measured by a handheld meter, is at 80.0± decibels, dropping to 70.0± decibels at 100.0± feet from the center. The level drops an additional 5.0± decibels for every 100.0± feet from the center of the crusher and surrounding plant noise. Plant placement will ensure that plant noise is well below that of the nearby traffic on Colorado Highway 66. Backup sirens and heavy equipment averaged 60.0± to 75± decibels, with similar decreases in decibel readings from the source measured in a manner similar to that indicated for the crusher and plant equipment sources. The location of the scale house and internal traffic at the plant site location will vary depending upon production levels and areas needed for product stockpiling. Regardless, the scale house will be located along internal paths for haul trucks, where finished material will be weighed and disembarked to help build the urban matrix of roads, highways, foundations, etc. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 3 EXHIBIT D SECTION [B) (b) Earthmoving; Following soil salvage (which has been completed for all existing and planned extraction areas), the balance of materials will be extracted to the depth of unconsolidated or weathered shale, and either placed directly into stockpiles as pit run, or manipulated at the plant site by screening, crushing, washing, and other methods to size and properly dimension the earth product into merchantable materials for sale. Except for minor and temporary anomalies, slopes resulting from extraction activities will be established by concurrent grading to 3H: 1V, although initial extraction may result in temporary slopes up to 1H: 1V until backfilled with shale, overburden, and soil. Most resulting slopes will drain internally into the future basin and are not anticipated to result in any off -site impacts due to erosion or stormwater runoff. The gentle to flat topography of the native site tends to aid in overall stability above the planned areas of extraction. While some erosion of mined slopes will be evident after extraction, over the shoulder soil placement and revegetation (delineated under Exhibit E: Reclamation Plan) will provide cover for both near and long-term stability of affected lands remaining above water level of the finished basins. The extraction limit is identified by a line set back uniformly at 25± feet from the edge of property lines; and, the centerline of field located underground gas lines or other underground facilities, irrigation ditches and seep ditch, wells, and other structures. Oil and gas wells and infrastructure in the southern area of Tract A are pending removal and are shown within extraction limits. Extraction will not occur within 25 feet of the wells or other infrastructure before they are removed. Minor variations may occur in the field over time from those represented on exhibit maps. The plans detailed in this application are based upon future events for which minor or temporary departures at any point in time may be evident. To the extent any significant departure in the field occurs in a time and manner not otherwise anticipated in these exhibits, the operator may cure by self -inspection, by observation from DRMS inspection in a timely manner, or by operator -initiated Revision to the Permit or otherwise via clarification in attending required DRMS Annual Reports. In the original application, Exhibit C-1: Pre -Mining Map has certification for protection of structures located within 200 feet from the proposed extraction limits at extraction slopes no steeper than 1 H: 1V. Final slopes and grades will be concurrently established at 3H:1 V, or flatter, from 5± feet above to 10± below the expected water level of each location of extraction. Actual locations of flatter slopes and escalloped shorelines [refer to Exhibit H: Wildlife Information] will be field fitted by grading or other cut/fill activity to optimize final shoreline irregularity. Final disposition of each reclaimed shoreline will be measured and resulting maps included in the annual report pertinent to that year's activities. Slopes may approach 2H:1V at depths of 10± feet below the expected water level to the basin bottom. Reclamation will follow guidelines established under Exhibit E: Reclamation Plan. Note: shoreline irregularities and fill to establish and enhance the aesthetic and end -use functions of the resulting basins is not shown on Exhibit F: Reclamation Plan Map, as this effect will be field fitted, and representations are too general to be accurately portrayed. Exhibit F simply identifies the near maximum extent [typical] of the resulting basins. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 4 EXHIBIT D SECTION [C] (c) All water diversions and impoundments; and Dewatering of the property to maintain suitable conditions for extraction and resource recovery occurs primarily through approved discharge points 001-A, 002-A, and 003-A to the ditch on the south and east boundaries of the permit. All discharge of waters will be conducted under an approved CDPHE discharge permit, with the current permit provided as an updated addendum to Exhibit G. The static water surface elevation was determined by subtracting the estimated depth to groundwater of 5 - 10 feet provided in the Kurtz well Permit (DNR #87180-F) from the approximate existing ground surface elevation of 4,800 feet. Static groundwater is therefore estimated at 4,793 feet in Tracts A and B, and 4,785 feet in Tract C. The extraction perimeter significantly influences the inflow of water into the excavation and that perimeter will not change significantly from the current extraction areas through the end of mining. Cut slopes will cause direct precipitation to drain internally into the resulting basins and are not anticipated to result in any off -site impacts due to erosion or stormwater runoff. The gentle to near flat topography of the area landscape tends to aid in overall stability above the planned areas of extraction. While some erosion of resulting basin perimeter slopes will be evident subsequent to extraction, the advance of reclamation activity over affected lands will provide cover for both near and long-term stability of those lands remaining above water level of the finished basins. All completed slopes above the anticipated static groundwater elevation will be soiled, seeded and stabilized as provided for under Exhibit E: Reclamation Plan. Of the total 201 acres of potential extraction in Tracts A, B, and C, the resulting basins will function as lined water storage reservoirs with a slightly fluctuating maximum combined water surface area covering 193.8 acres. The remainder of the proposed disturbed area will be stabilized with vegetation. This includes regraded slopes of basins or extraction areas that will be backfilled to at least two feet above ground water level, as well as other surface areas disturbed to support operations. SECTION [Dl (d) The size of area(s) to be worked at any one time. The 296.3 -acre parcel boundary forms the permit boundaries, as reflected on exhibit maps. This area represents a de minimis adjustment from previously stated 295.4 acres due to property boundary adjustments in the west parcel along St Vrain Creek. No disturbance of these areas has taken place or is proposed. All lands within the 296.3 -acre permit boundary, are affected lands under C.R.S. 34-32.5-103(1), respective of this permit application. Any changes required in the nature of planned extraction or reclamation having more than a minor effect on the financial warranty calculation will be made through the DRMS, by an appropriate revision. If lands are needed beyond the designated permit boundary, those lands will be secured for the active DRMS permit by Amendment. Within the permit boundary, there are four (4) identifiable areas designated for primary extraction. The primary areas of Extraction are as follows: Tract A: 132.6 ac Tract B: 55.5 ac Tract C: 12.9 ac Tract D: 8.8 ac Total primary extraction: 209.8 ac RAPTOR MATERIALSILc Raptor Materials, LLC Kurtz Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 5 EXHIBIT D Of the outlying 86.5 acres, Weld County Road accounts for approximately 3.6 ac, and the remainder is largely u ndisturbed rangeland. SECTION [El (e) An approximate timetable to describe the mining operation. The timetable is for the purpose of establishing the relationship between mining and reclamation during the different phases of a mining o peration. An Operator/Applicant shall not be required to meet specific dates for initiation, or completion of mining in a phase as may be identified in the timetable. This does not exempt an Operator/Applicant from complying with the performance standards of Rule 3.1. If the operation is intended to be an intermittent o peration as defined in Section 34-32.5-103(11)(b), C.R.S., the Applicant should include in this exhibit a statement that conforms to the provisions of Section 34-32.5-103(11)(b), C.R.S. Such timetable should include: SUBSECTIONS I THROUGH III i. An estimate of the periods of time which will be required for the various stages or phases of the operation; The remaining progression of operation for this Kurtz permit is dependent on the complimentary activity on nearby Raptor permits supplying raw sand and gravel to the processing plants on Kurtz. The following are estimates based on assumed rates of extraction which may vary according to market demand and the impacts of geologic variability on the actual volume of sand and gravel. Contemporary extraction is ongoing in the Kurtz permit (M1999-006) in Tracts A and B and is expected to continue ensuring continued production of marketable materials until the conclusion of extraction in Parcel 122 operation (M2015-003) and commencement of operations in the Cogburn permit (M2025-016) once permitted. This is currently expected to be in the late winter to early spring of 2026. It is expected however that regardless of the availability of Cogburn, any remnant areas in Tract A other than under the processing plant and ponds in the southwest corner will be completed to enable reclamation of most of this excavation. Extraction operations providing material to the Kurtz processing plants will then focus on the Cogburn permit. The initial area under application on the Cogburn permit is projected to support approximately five years of operation. Additional areas exist that if successfully permitted could extend the Cogburn operation by a further three to five years. Upon completion of the Cogburn operation, the final extraction of remaining material in Kurtz Tracts A and B will ensue with some relocation of plant equipment and potentially the use of smaller mobile processing plant. Depending on processing capability, extraction of the final material in Tracts A and B could take two to five years. The duration of mining (including activity on the Plant 122 and Cogburn permits) and processing operations then is estimated to range from ten to fifteen years depending on geology, permitting of addition areas at Cogburn, and market demand. In calendar terms, this would be in the 2036-2041 window, with reclamation to be completed within five years of completion of mining and processing operations (2041-2046). ii. A description of the size and location of each area to be worked during each phase; and Three small remnant areas remain in Tract A along the southern boundary. These are peninsulas currently occupied by oil and gas wells and infrastructure that Raptor have been advised will be removed soon. There are two small peninsulas with wells with a total area of 6.4 acres, and a wedge RAPTOR MATERIALSILc Raptor Materials, LLC Kurtz Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 6 EXHIBIT D area with infrastructure with an area of 2.2 acres. These will only be mined when the oil and gas infrastructure has been removed. iii. Outlining the sequence in which each stage or phase of the operation will be carried out. (Timetables need not be separate and distinct from the mining plan, but may be incorporated therein.) Discussed in item i. above. SECTION (F) (f) A map (in Exhibit C - Pre -Mining and Mining Plan Maps(s) of Affected Lands, Rule 6.43) may be used along with a narrative to present the following information: i. Nature, depth and thickness of the deposit to be mined and the thickness and type of overburden to be removed (may be marked "CONFIDENTIAL," pursuant to Rule 1.3(3)); and ii. Nature of the stratum immediately beneath the material to be mined in sedimentary deposits The upland terrace is nearly level and supports a variety of crops. U.S.G.S. Geologic Maps describe most of the site as Piney Creek Alluvium to an approximate depth of 20 feet. Field cores suggest depths can vary to approximately 40± feet to shale. The thickness of the overburden was generally 4± feet with the thickness of the sand and gravel in extraction areas ranging from 15± to 40± feet. The lower terrace is used for pasture and supports a mature stand of Cottonwoods along the creek banks. The lack of regeneration suggests that the area has not incurred much flooding, since scouring by flooding is necessary for natural regeneration of Cottonwood trees. U.S.G.S. Geologic Maps describe most of the flood plain and lower areas immediately adjacent to St. Vrain Creek as Post Piney Creek Alluvium with depths averaging 15± feet to shale. SECTIONS (0) AND [Hl (g) Identify the primary and secondary commodities to be mined/extracted and describe the intended use; and (h) Name and describe the intended use of all expected incidental products to be mined/extracted by the proposed operation. The primary commodities to be extracted are sand and gravel in a range of marketable sizes. For a diverse list of products to be extracted and/or processed, and sold, they may include but are not limited to the more common products identified in Table D1 - Raptor Materials Product List (included as an addendum), or other inert or commonly useful products used for diverse construction purposes, including, but not limited to: structural fill, concrete products, road construction products; and other products to aid the residential, commercial, industrial customer; and for any other infrastructure use. Incidental products depending on availability from and suitability of the material extracted, and market available, could include but are not limited to topsoil, overburden and silt/clay. These product uses are diverse but could reasonably be expected to include landscaping, reclamation or use as bulk fill. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE7 EXHIBIT D SECTION [I] (I) Specify if explosives will be used in conjunction with the mining (or reclamation). In consultation with the Office, the Applicant must demonstrate pursuant to Rule 6.5(4), Geotechnical Stability Exhibit, that off -site areas will not be adversely affected by blasting. Explosives will not be used. SECTION U] 0) Specify the dimensions of any existing or proposed roads that will be used for the mining operation. Describe any improvements necessary on existing roads and the specifications to be used in the construction of new roads. New or improved roads must be included as part of the affected lands and permitted acreage. Affected land shall not include off -site roads which existed prior to the date on which notice was given or permit application was made to the office and which were constructed for purposes unrelated to the proposed mining operation and which will not be substantially upgraded to support the mining operation. Describe any associated drainage and runoff conveyance structures to include sufficient information to evaluate structure sizing. Entry to the mine for heavy equipment and haul traffic occurs from the northern boundary of the operations from Colorado Highway 66. Access points are shown on Exhibit C -2a: Mining Plan Map. Any changes to access points will be addressed in an appropriate revision. The extent and dimensions of existing roads are represented in the aerial images or graphic representation on the exhibit maps relative to the access locations detailed below. Existing roads are generally 10-16 feet wide in extraction areas, with wider roads up to 35 feet common around the processing plants. Modifications to existing roads including minor widening, minor realignment, or application of additional gravel to improve the running surface may occur as needed and will be reported in DRMS Annual Reports. Due to the mature state of the operation, no significant changes to the current road network are anticipated. As sand and gravel mining is not precision engineered excavation and extraction is field -fit according to the conditions and geology encountered, combined with the very flat nature of the pre-existing irrigated fields, detailed design of possible drainage structures is impractical and generally not warranted. While largely confined by small existing earthen berms around the perimeter of the extraction areas, where apparent or evident that water will accumulate on sides of roads away from the excavations, small ditches will be constructed as needed, with culverts where required to drain to the pits. As with any existing roads, used in their existing state or improved, the perimeter roads will be retained according to the desires of the landowner. No other defined roads within the Extraction Limits will occur except for the temporary paths created by extraction equipment or otherwise determined by subsequent Revision to the permit. All existing agricultural roads outside of the designated extraction limits will be retained according to the desires of the landowner. The same shall form part of the final end use of the reclaimed lands, unless otherwise indicated in this submittal or by subsequent permit revision. Known structures and landowners, including above and below ground utility owners, located on and within 200± ft. of the permit boundary, are shown on Exhibit C-1: Existing Conditions Map including creeks, roads, buildings, oil and gas facilities [such as tanks, batteries, wells and lines], and power and communication lines and support structures, easements and rights -of -way. RAPTOR MATERIALSILc Raptor Materials, LLC Kurtz Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 1 EXHIBIT E EXHIBIT E -RECLAMATION PLAN SECTION 1 (1) In preparing the Reclamation Plan, the Operator/Applicant should be specific in terms of addressing such items as final grading (including drainage), seeding, fertilizing, revegetation (trees, shrubs, etc.), and topsoiling. i ng. Operators/Applicants are encouraged to allow flexibility in their plans by committing themselves to ranges of numbers (e.g., 6"-1 2" of topsoil) rather than specific figures. Acknowledged. SECTION 2 (2) The Reclamation Plan shall include provisions for, or satisfactory explanation of, all general requirements for the type of reclamation proposed to be implemented by the Operator/Applicant. Reclamation shall be required on all the affected land. The Reclamation Plans shall include: SECTION 2.A (a) A description of the type(s) of reclamation the Operator/Applicant proposes to achieve in the reclamation of the affected land, why each was chosen, the amount of acreage accorded to each, and a general discussion of methods of reclamation as related to the mechanics of earthmoving; As discussed in the revised Exhibit D: Mining Plan various references to ponds and basins in previous application and revision documents that were used interchangeably in reference to long term water storage facilities (lined or unlined) are now referred to as basins or lined water storage reservoirs. Reference to ponds will be reserved for more temporary facilities for process water or general water management. While the permit application document only allows one "Primary" present (pre -mining) and future (post - mining) land use, this site effectively contained two significant pre -mining land uses with General Agriculture in the uplands and Rangeland in the lower terrace closer to the creek. The post -mining land use as reflected in the original permit application and subsequent technical revisions will consist of multiple uses including Rangeland in the generally undisturbed areas, Developed Water Resource in select extraction areas, and General Agriculture in upland areas either backfilled or otherwise used and reclaimed. Raptor does not propose to change the primary post -mining land use from General Agriculture, but this understanding of the site holistically is an important foundation for the reclamation plan. Reclamation at this location is geared to lay a foundation that will capture both short and long-term multiple - e nd use benefits that will complement the dynamic mix of surrounding land uses over time. The primary end u se will remain general agriculture supplemented in select areas by developed water resources with other areas remaining in a more or less native state or returned to rangeland. The plans as evidenced in previous technical revisions have changed modestly over time and the current plan as reflected on Exhibit F; Reclamation Plan Map shows the various areas with different post mining land u ses. In general, the reclamation can be summarized as follows: RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E Tract A excavation with minor areas remaining to be mined as previously permitted will be reclaimed as lined water storage reservoir. Much (�70 percent) of the existing Tract A excavation perimeter has been regraded and lined with this post mining land use in mind. Tract B currently contains the wet processing plant with the dry processing plant currently situated in the northwest corner of Tract A. Minor excavation is ongoing in Tract B and these excavations are proposed to be converted to a lined water storage reservoir once extraction is completed. Lining and regrading will be undertaken where possible in areas where extraction is completed subject to operational requirements for the remaining area. Tract C excavation is largely complete except for a small area awaiting removal of oil and gas wells and associated infrastructure. Pending approval of the adjacent Cogburn permit (M2025-016), establishment of a liner and regrading slopes may import material from the Cogburn operation, otherwise backfill material will be hauled from Tract A. Tract D has minor excavations remaining to be backfilled to no longer expose groundwater. This area is currently in active use as part of the construction of a water pipeline by the City of Thornton. Similar to the Tract C area, pending approval of the adjacent Cogburn permit (M2025-016), backfill may be imported material from this operation, otherwise backfill material will be hauled from Tract A. Table 1 Post Mining Land Use Areas Area Rangeland & General Agriculture1 Developed Water Resource2 Other3 West 68.3 East 23.4 Total 91.7 12.9 2.1 188.1 1.5 201.0 3.6 1: Certain areas within these general post -mining land use classifications will retain roads per the stated preference of the landowner. 2. These areas include the basin slopes and perimeter areas where these are inadequate or irregular in nature resulting in limited alternative uses. These areas will be revegetated as described in this Exhibit. 3. Primarily County Road 17 SECTION 2.B (b) A comparison of the proposed post -mining land use to other land uses in the vicinity and to adopted state and local land use plans and programs. In those instances where the post -mining land use is for industrial, residential, or commercial purposes and such use is not reasonably assured, a plan for revegetation shall be submitted. Appropriate evidence supporting such reasonable assurance shall be submitted; Uses: The Permit location and surrounding lands are predominantly irrigated croplands, however, diverse residential, commercial and industrial uses are increasing along lands surrounding the location. For example, a commercial log mill is located immediately North of the location. The Town of Mead has annexed land and built a subdivision approximately 1.5± miles due West of the location. Other residences are approximately one quarter mile away in any direction. Highway 66 is becoming a major route between the towns of Longmont, Platteville, and surrounding communities, and links the increasingly congested transportation corridors of U.S. Highway 85 and Interstate 25. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E Table E-1: Revegetation Seed Mixture, combines a thoughtful mingling of native grasses of diverse height, form, color and function, to assure that the reclaimed site can provide for a multiple -use benefit. Should post resource recovery land development be deferred, or even negated, all affected land remaining above the anticipated final water level of the resulting basins will be stabilized with a diverse and durable cover of predominantly native grasses. This is compatible with, and an improvement over, adjacent pasture lands located in the St. Vrain Creek flood plain, and area monocultures of bluegrass and cropped land. Combined with the creation of waterfowl habitat, the baseline reclamation plan provided for under this submittal will provide less fragmenting of the area ecology than what may otherwise transpire. As such, the operation will result in immediate and prolonged positive impacts to the area. SECTION 2.C (c) A description of how the Reclamation Plan will be implemented to meet each applicable requirement of Rule 3.1; Rule 3.1.1 Establishing Post -Mining Use The operator, as landowner, has chosen to reclaim the land in a manner that will facilitate future both elements of former use supplemented with developed water resources. While the permit application document only allows one "Primary" present (pre -mining) and future (post - mining) land use, this site effectively contained two significant pre -mining land uses with General Agriculture in the uplands and Rangeland in the lower terrace closer to the creek. The post -mining land use as reflected in the original permit application and subsequent technical revisions will consist of multiple uses including Rangeland in the generally undisturbed areas, Developed Water Resource in select extraction areas, and General Agriculture in upland areas either backfilled or otherwise used and reclaimed. Raptor does not propose to change the primary post -mining land use from General Agriculture, but this understanding of the site holistically is an important foundation for the reclamation plan. Reclamation at this location is geared to lay a foundation that will capture both short and long-term multiple - end use benefits that will complement the dynamic mix of surrounding land uses over time. The primary end use will remain general agriculture supplemented in select areas by developed water resources with other areas remaining in a more or less native state or returned to rangeland. Rule 3.1.2 Reclaiming Substituted Land Acknowledged. Rule 3.1.3 Time Limit and Phased Reclamation Acknowledged. Rule 3.1.4 Public Use Acknowledged. Rule 3.1.5 Reclamation Measures - Materials Handling Lining of basins involves the placement of low permeability compactible fill, from on -site or other suitably sourced geologic materials, into the keyway (dewatering trench); the same keyway used to facilitate discharge to keep the basins dry and free of groundwaters at the time of extraction. The balance of the basin floors (where needed) and slopes are also covered and compacted with the same materials until they meet RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E the standards established under the August 1999 State Engineer Guidelines for Lining Criteria. Typical to obtaining approval for the constructed liner, the lined basin must pass a 90 -day leak test. Correspondence from the OSE approving the construction of the lined basin will be submitted to the DRMS on receipt; or as part of any request for release of the permit, in part or whole. Raptor has extensive experience successfully constructing lined storage reservoirs with several prior projects completed, tested and approved by the OSE. The deposit contains extensive materials suitable for use in constructing the liner including shale, claystone, clay, sandstone-claystone-siltstone and sandstone- siltstone bedrock, clay lenses in the sand and gravel deposit, and overburden often comprised of low plasticity sandy silty clay to silty sand. Excess topsoil has also been successfully used as a liner construction material and could be used if excess material is available. Other materials suitable for liner construction encountered within the sand and gravel deposit during excavation are either placed where needed to construct a liner or stored in temporary piles on the excavation floor. Parameters such as plasticity, percentage of fines etc. have not been determined for the deposit materials at this time but extensive experience in constructing several approved lined storage reservoirs with similar materials along the St. Vrain Creek and other rivers and streams provides high confidence in the availability of suitable materials within the extraction area. The liner has been progressively constructed as the pit is developed to allow regrading and any problems with the efficacy of the liner can usually be detected prior to leak testing through evidence of seeps in the constructed liner which can have remedial action taken. Similarly, although not common, seeps are sometimes observed in the bedrock floor. While these have generally in Raptor's extensive experience proved to be self -healing, where needed remedial action and spot lining and compaction would be undertaken. Liner construction involves building a compacted low permeability core by placing and compacting suitable material in 6"± lifts. A Caterpillar 815 or 825 (or equivalent) compactor generally makes 2-4 passes to achieve suitable compaction of the core and which experience has shown provides integrity of the core both laterally and vertically. This process starts in the keyway and continues until the core reaches ground level. As the core is built the internal slopes are also brought up to achieve a 2H:1 V or shallower slope up to 10± feet below the anticipated final water level of the basins, and a 3H:1 V or shallower slope from 10± feet below the anticipated final water level to surface elevation. The exact mix of material used to construct the core is determined at the time of construction based on the materials available. Moisture adjustments required have generally been minimal in prior experience and judgements on additional water are made during construction to achieve a moisture content typically in an optimum range of 2-4 percent. The internal slopes do not necessarily have to be clay materials, but can consist of pit run, overburden, shale or a mixture of these materials. The general approach to construction of the core and regrade of a typical wall at the extraction limit is shown in Figure 1 below. Backfill material placed over liners to regrade the lined reservoirs to 3:1 will be placed in relatively shallow lifts typically 5 to 6 -feet high as the liner is built up. No specific compaction is proposed or has been found necessary in previous construction as with the relatively shallow lifts, adequate compaction is achieved through the repeated traversing over the material by haul trucks and dozers. Backfill where required is proposed to be end dumped at surface level extending fill faces from the edges of the pit. Some initial settling would be expected and if more than modest swales or other features generally acceptable and desirable on general agricultural land, additional fill would be placed to establish a more level surface. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E Typical Liner and Regrade for Extraction Limit Wall— Final Reclamation 1_ rou_inctkn' ter Lev&1 1: I—:1 V Ei.Cirre IJ n ex cad ated Perimeter Wall Original Ground Surface Static Water Level es) Backfilw. at 3H_1'wr slope eqUence In cycles Estc blish liner in keyiAray Install liner in 5" lifts Backfillto,311:1V Replace topsoil ELI cv,ewater le'iel ... .... •••s••.S.ti...•%••..••••••••d. • • • • ••.• :i•..ti••.O.• . • • • • ••..•••'L• .. • • a.O.•%••..•....•a.••.•••.••.•..•y•i . ▪ is.•.......•.....o.:.o........•.........o.o.:.▪ e•▪ •'.•'.•........•..•.....▪ ...•a.• . . . . . . . ..... ■ ......... •.....: •j.j.i •: is .... 1s •:•: •:.. ■...e.i .. is is is is .. ■.•.r.i •� . is .: is ...� •...j•� •.•....,...1.r•1.1.e •� ........ ••a••••••%•••••.•••••••%•••••••.•••••••••••••••••••••••a•%•%•.•••••••••••••••.•••••..'•.%••••••••••••••n•••••••aa•i,•..••••%•ti.aa.an•••••••a.•%••••••••••••• ▪ s; _: :; :: ,. a::.•:: ;: it iv •,.. , 00.•%•%•%•%•%18%.::••••%•%ti:ti:.:ti.ti:ti:.. ,:ti••:•%•%• .:::..,%•%•%,%•L••ti •••:ti:....:..i� •%•%•:••%:tiiatiiti�•:'n:itiiti6Lo%•%•%.::.• r' •• ••• ••U �•U • �•p •o �•• �• �• •• �•• •�' j f � •e•.-•.-•..•.....•.••••••••..•..•......i.r.f.i•� •� •f.r. f.f.f..••U •• •r.r.e.�••r•r.r•. •. •i•f•i•.�...•i...•.•••••e•. •. •......r•..• -••c •i •. Bedrock•••••....%.%.••.%u%.%�%.•••.••1•••••••.•••. .%.a.�a•••..%% ....%.%.,....%.....%.%;.....%....•••.•.% •..•..%.%.%•...•.�•..•.�•..ti.%••••••• • • ▪ • •l.jad•i•• its .f••••••• •• .f••••..i •. ••••••••••• •f•�••••.• •J•.•. ..•••••.••• ..-•:•........•. •...•.••••••••.-.. •• ..ra• . •.•.y •.••.••.r.. . •••▪ ••••••••••••••••••••••••••• ..••.•..•..• e.......... 0..• U, ...�I,,•U •. ............,• ,,•U • U..............e...........i.%..•...d..u...••....•...,.O..t..•..•..••..•.•..•%.i._.......•.e........•..•..••.•.....••.•......••.•..•..a....•...•.....c.........•..•.... 00 ..•.•... i ▪ •n a • e ▪ . e•n a • n• ▪ a ▪ n•a•. n▪ •a n•• . .. s•a n •. •• i .:•• •n• a e•n a • n a a n a i •:.:.• • n a n a . n. , a n • . s a e •. •a • n a •. •n n •: Figure 1. Typical Completed Reclamation Liner and Regraded Slope for Extraction Limit Wall Estimated volumes of material used in liner construction, overburden available from the extraction areas, and backfill on lined slopes is summarized in Table 2. Table 2 Key Reclamation Quantities Tract A B C D Total Liner volume (CY) 59,384 42,502 19,321 NA 121,208 Lined Slope Fill (CY) 314,933 Backfill Volume2 (CV) NA 225,400 NA 102467 NA NA 12,485 642,800 12,485 Depth Min (ft) 15 Depth Max (ft) 40 15 40 15 40 Backfilled Backfilled 1. Estimated total volume based on the extraction limits and does not include the work already completed 2. Tract D backfill is largely complete. The volume shown is the estimate to complete backfill of one small area. A Backfill Notice is included with this application as an Addendum at the back of Exhibit E: Reclamation Plan. Currently it is anticipated that some overburden excess to the reclamation requirements and currently in stockpiles on the nearby Raptor Parcel 122 operation (M2015-003) may be used as fill. The excavation of sand and gravel does not entail or engage any processes, products, or methods that are expected to result in the release of pollutants or otherwise contaminate surface or groundwater. An appropriate Stormwater Management Plan is in place and attached as an addendum to this Exhibit. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E Rule 3.1.6 Water — General Requirements 1. Hydrology and Water Quality: Disturbances to the prevailing hydrologic balance of the affected land and of the surrounding area and to the quantity or quality of the affected land and of the surrounding area and to the quantity of quality of water in surface and groundwater systems both during and after the mining operation and during reclamation shall be minimized by measures, including, but not limited to: a. compliance with applicable Colorado water laws and regulations governing injury to existing water rights; The site operates under a substitute water supply plan [a.k.a., augmentation plan] from the Colorado Division of Water Resources - Office of the State Engineer has been approved. Additional information is available upon request. b. compliance with applicable federal and Colorado water quality laws and regulations, including statewide water quality standards and site -specific classifications and standards adopted by the Water Quality Control Commission; The operation has obtained from the CDPHE a Stormwater and Processing Permit, and has a Storm Water Management Plan in place. Additional information is available upon request. c. compliance with applicable federal and Colorado dredge and fill requirements; and The operation has been subject to review by the U.S. Dept. of Army - Corps of Engineers and wetlands areas delineated as shown on Exhibit C -2a: Mining Plan Map as incorporated in Technical Revision 3. There are no plans to affect wetlands, waters of the United States, or the banks or bed of St. Vrain Creek under this proposal. An evaluation of these concerns is included in the report by Savage and Savage, Inc. in Exhibit G - Water Information. d. removing temporary or large siltation structures from drainage ways after disturbed areas are revegetated and stabilized, if required by the Reclamation Plan. This concern is not anticipated under this submittal. 2. Earth dams, if necessary to impound water, may be constructed if the formation of such impoundments will not damage adjoining property or conflict with water pollution laws, rules or regulations of the federal government, the state of Colorado or with any local government pollution ordinances. Earth dams are not anticipated under this proposal. 3. All surface areas of the affected land, including spoil piles, shall be stabilized and protected so as to effectively control erosion. Please refer to the soil stabilization and management plan under Exhibit I — Soils Information. Rule 3.1.7 Groundwater - Specific Requirements The quality of groundwater will not be adversely impacted by this operation. Issues concerning depletion have been addressed in a substitute water supply plan with the Colorado Office of the State Engineer, Division of Water Resources. Rule 3.1.8 Wildlife Wildlife safety and protection is discussed in Exhibit H - Wildlife Information. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 7 EXHIBIT E 3.1.9 Topsoiling Topsoiling is discussed below in Section 2.f. 3.1.10 Revegetation Revegetation is addressed in Sections 2.B, 2.D, and 2.F of this Exhibit. 3.1.11 Building and Structures Preexisting structures that have not been removed and are shown on Exhibit C -2a: Mining Plan Map will remain as a preference of the landowner. There are no historic structures within the permit boundary. 3.1.12 Signs and Markers Acknowledged. 3.1.13 Spill Reporting Acknowledged. SECTION 2.D (d) Where applicable, plans for topsoil segregation, preservation, and replacement; for stabilization, compaction, and grading of spoil; and for revegetation. The revegetation plan shall contain a list of the preferred species of grass, legumes, forbs, shrubs or trees to be planted, the method and rates of seeding and planting, the estimated availability of viable seeds in sufficient quantities of the species proposed to be used, and the proposed time of seeding and planting; Soil salvage, preservation and replacement are detailed under Exhibit D - Mining Plan and Exhibit - Soils Information. Revegetation will utilize the grass mixture specified in Table L - Preferred/Primary Seed Mixture attached as an addendum to Exhibit L - Reclamation Costs: Forbs, shrubs, and trees are not included as the primary goal is to stabilize the site for general agriculture. The seed mixture will serve to complement the existing ecosystems and future basins, without conflicting with the goals of later development that may introduce a different mix of forbs, shrubs, and trees than a wildland planting would require. SECTION 2.E (e) A plan or schedule indicating how and when reclamation will be implemented. Such plan or schedule shall not be tied to any specific date but shall be tied to implementation or completion of different stages of the mining operation as described in Rule 6.4.4(e). The plan or schedule shall include: i. An estimate of the periods of time which will be required for the various stages or phases of reclamation; The timing of reclamation will generally follow the mining of each tract in stages as described below: Tract A is anticipated to be largely mined out in 2026 dependent on possible removal of existing oil and gas wells and infrastructure in the southern extents of the area and other than under the processing plant and ponds in the southwest corner. Lining and regrading of the existing pit walls is estimated to be 70 percent complete and contemporaneous reclamation as remnant areas are extracted will be completed as practical subject to ongoing operational requirements. Once all areas have been extracted, lining and regrading of the remaining wall, with topsoil replacement and revegetation above the water line would be completed within five years. Tract B as described in Exhibit D: Mining Plan has some minor extraction areas currently active but most of the remaining material in this area will not be recovered until the extraction of Raptor Parcel RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E 122 operation (M2015-003) and proposed extraction of Cogburn permit currently with application under review (M2025-016). Tract B currently contains the wet processing plant with the dry processing plant currently situated in the northwest corner of Tract A and these plants together with the truck scale facility and approved access to Colorado Highway 66 will continue in use processing material from Parcel 122 and Cogburn once approved. Tract B is proposed to be converted to a lined water storage reservoir once extraction is completed. Where possible depending on operational requirements for the extracted areas, contemporaneous reclamation including lining and regrading will be undertaken in areas where extraction is completed prior to relocation of the processing plant and final extraction of the area. Final lining and regrading will be completed within 5 years of completion of extraction activities. Tract C excavation is largely complete except for a small area awaiting removal of oil and gas wells and associated infrastructure. Pending approval of the adjacent Cogburn permit (M2025-016), establishment of a liner and regrading slopes may import material from this operation, otherwise backfill material will be hauled from Tract A. Tract D backfill is largely complete, however the area is currently occupied by the construction crew for the City of Thornton water pipeline project. Once this work is completed, it is anticipated that any remaining fill, replacement of topsoil and revegetation would be completed within five years. ii. A description of the size and location of each area to be reclaimed during each phase; and The size and location of work to complete reclamation is broken down by tract below. Tract A is anticipated to have a total final perimeter wall length of 9448 feet. Currently approximately 7,000 feet have been lined and regraded. Basin walls above water line and additional surface areas within Tract A to have topsoil replaced and be revegetated amount to 3.4 acres. Tract B is anticipated to have a total final perimeter wall length of 6762 feet. Currently none of the Tract B perimeter has been lined and regraded. Basin walls above water line and additional surface areas within Tract B to have topsoil replaced and be revegetated amount to 2.3 acres. Tract C is anticipated to have a total final perimeter wall length of 3074 feet. Currently none of the Tract C perimeter has been lined and regraded. Basin walls above water line and additional surface areas within Tract C to have topsoil replaced and be revegetated amount to 1.5 acres. Tract D area requiring topsoil replacement and revegetation amounts to 7.2 acres. Note that this area reflects the entire tract currently re -disturbed temporarily by batch plant operations conducted by a third party supporting construction on 1-25. iii. An outline of the sequence in which each stage or phase of reclamation will be carried out. (The schedule need not be separate and distinct from the Reclamation Plan, but may be incorporated therein.) As described in section (i) above. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT E SECTION 2.F (f) A description of each of the following: i. Final grading - specify maximum anticipated slope gradient or expected ranges thereof; Lands situated above the anticipated final water level of the completed basins, and within 10± feet below the anticipated final water level of the basins, will be graded to 3H:1 V, or flatter. Lands below 10± feet from the anticipated final water level of the basins will be graded 2H:1 V, or flatter. ii. Seeding - specify types, mixtures, quantities, and expected time(s) of seeding and planting; The balance of unoccupied affected lands above the anticipated static water level will be stabilized where necessary utilizing the seed mixture as shown as an addendum to Exhibit L — Reclamation Costs: Table L — Preferred/Primary Seed Mixture. The Primary Seed Mixture combines a thoughtful mingling of predominantly native grasses of diverse height, form, color and function, to assure that the reclaimed site can provide for a multiple - use benefit. Generally, warm and cool seed mixtures can be treated in a myriad of ways. In Table L this distinction is indicated in the column labelled "C/W". Cool season mixtures are often planted in the fall and warm in the spring, however, exceptions may apply. Some argue warm season grasses are better broadcast, while others like them drilled with the cool season grasses. Resoiled areas will be allowed sufficient time to settle prior to seeding, which will commonly follow in the fall or spring. Resoiling will occur when soil moisture is adequate to prevent blowing, yet dry enough to prevent compaction. Part of the soil rebuilding process on the reconstituted soils will be in establishing structure to the soils to facilitate plant -soil -water relationships. Overly compacted soils will tend to limit soil structure development and create a poor seedbed for later establishment, so revegetation may be deferred if soils to be reclaimed are manipulated while wet, instead of moist. iii. Fertilization - if applicable, specify types, mixtures, quantities and time of application; Actual fertilizer rates will be based upon soil tests taken at the time of reapplication of salvaged soil to affected lands remaining above water level. Refer to Exhibit I- Soils Information. Regardless, a theoretical rate is included under Exhibit L- Reclamation Cost Estimate, for that purpose. iv. Revegetation - specify types of trees, shrubs, etc., quantities, size and location; and Forbs, shrubs, and trees are not included as the primary goal is to stabilize the site for general agriculture. The seed mixture will serve to complement the existing ecosystems and future basins, without conflicting with the goals of later development that may introduce a different mix of forbs, shrubs, and trees than a wildland planting would require. v Topsoiling - specify anticipated minimum depth or range of depths for those areas where topsoil will be replaced. Please refer to Exhibit D - Mining Plan and Exhibit I- Soils Information. Mean resoiling minimum depth is six inches. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT L EXHIBIT L - RECLAMATION COSTS SECTIONS 1 AND 2 All information necessary to calculate the costs of reclamation must be submitted and broken down into the various major phases of reclamation. The information provided by the Operator/Applicant must be sufficient to calculate the cost of reclamation that would be incurred by the state. The Office may request the Operator/Applicant to provide additional, reasonable data to substantiate said Operator/Applicant's estimate of the cost of reclamation for all Affected Lands. SUMMARY OF RECLAMATION COSTS, PARAMETERS, AND APPROACH This reclamation cost estimate has been completed for the worst -case scenario for reclamation in the event of the default of current ongoing operations. This Exhibit L reflects the July 2025 site conditions, which were used as the basis for the Financial Warranty update that was approved by the DRMS on July 8, 2025; site conditions have not materially changed since the approval of the updated Financial Warranty. The supporting material and approval letter from the DRMS for the updated Financial Warranty from $431,000 to $2,571,871 are included as attachments. A summary of project costs is presented below. Costs are separated into operational tasks (direct costs - Table 1) and insurance, bonding, project management, engineering, legal, and administration (indirect costs — Table 2). Indirect costs are calculated as a percentage of either the direct costs or the number of hours to complete tasks. Table 1. Reclamation Direct Cost Summary Task DIRECT COSTS Cost Tract A: Dewater pond - initial pumping $426,422 Tract A: Dewater pond - continual pumping 512,367 Tract A: Grade slope under liner $54,070 Tract A: Rip source material for liner S10,369 Tract A: Haul liner and backfill material from Tract A source $131,906 Tract A: Mix material for liner 533,881 Tract A: Compact liner $16362 Tract B: Push sand stockpile into pit S211,774 Tract B: Haul backfill material from Tract A source to pit and pond $1 62,485 Tract C: Haul backfill material from Tract A source to pond $584,644 Tract D: Haul backfill material from Tract A source $17,674 Haul topsoil to all disturbed areas 111r190 RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE2 EXHIBIT L Seed all disturbed areas Demo and remove concrete and conveyor Mobilization and Demobilization 313,006 324,612 11,154 SUBTOTAL DIRECT COSTS: $1,983,797 Table 2. Reclamation Indirect Cost Summary Item Percentage of Cost/Hours INDIRECT COSTS OVERHEAD AND PROFIT Liability Insurance 2.02% DC Performance Bond 1.05% DC Job Superintendent 50% Total Job Hours * Profit 10% DC Cost 40,073 20,830 56,103 198,380 NDIRECT COSTS LEGAL, ENGINEERING/ PROJECT MANAGEMENT Financial (legal) Warranty Processing N/A S500 Engineering/contract/bid 4.25% DC + O&P 597,715 Reclamation Mgmt/Admin 4.5% DC + O&P $114,959 Contingency 3% DC $59,514 SUBTOTAL INDIRECT COSTS: $588,074 *Job hours for this project are estimated at 1415 hrs, with a superintendent hourly rate of $79.27, based on the September 2024 DRMS Cost Estimate for the P124 Two Rivers (M2022-013) project A rider for the Revised Grand Total Financial Warranty Amount - $2,571,871 - was accepted by the DRMS in a letter dated July 29, 2025, which is attached to this Exhibit. For future reference, the ultimate project dimensions that will be used at the end of the current projected Life of Mine are summarized in Table 3. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT L Table 3. Total Proposed Affected Lands and Reclaimed Features Measurements Entity Extraction - finished basin (Acres) Static Water Area - surface (Acres) Static Water Area — elevation (ft.) Basin Lands Above Static Water Level (Acres) Basin Area Volume (cu.yds.) Static Water Level Volume (Gallons) Static Water Level Volume (Acre Feet) Tract Ar 132.9 93.6 4793 39.3 5,018,171 1,013,540,070 3,110.4 Tract B N/A N/A N/A N/A Tract C N/A Tract D N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Combined 132.9 N/A 39.3 N/A 5,018,171 N/A 1,013,540,070 N/A 3,1104 NOTE: All lands within the 213.5± acre permit area are considered as affected lands under C.R.S. 34-32.5- 103(1) respective of this permit application and any subsequent permit revisions or amendments to the permit as originally approved. Previously affected ground prior to the onset of Operations under this permit will not be reclaimed under the terms of this permit unless otherwise re -affected beyond their original state. Public Lands and other easements and rights -of -way are offset from operations and while they may fall within the 213.5± acre parcel — are excepted from the permit conditions to the extent of their approved setbacks. The following estimates use assumptions based upon the current condition of the site as of July 2025 for purposes of determining estimated costs of reclamation and correlated financial warranty. Where appropriate, information is generalized and approximated from similar estimates determined by the Division of Reclamation, Mining and Safety (DRMS), as indicated. Based upon the Extraction and Reclamation Plans of this application, the status and trend of activities and affected land, and related calculations to estimate reclamation liability, are determined as follows. Please Note: Due to the difficulty of calculating heavy equipment costs similar to the Division's software program, unit costs from previous and reasonably current Division estimates of like or similar kind have been used to create a reasonably close estimate. The per unit basis from Division records are shown in the calculation tables throughout this Exhibit. The Kurtz (P115) permit, #M-1999-006, is currently serving primarily as a central processing facility for sand and gravel extracted primarily from the adjacent Raptor Materials, Parcel 122 — Bearson Resource Development Project (DRMS Permit #M-2015-033) and intended in the future to process material from an adjacent property currently being permitted (Cogburn Sand, Gravel, and Reservoir Project, (DRMS Permit #M-2025-016). In addition, some material remains to be extracted and processed from the Kurtz permit area. The permit has 4 separate areas identified as Tracts A, B, C, and D labelled on map Exhibit C-2. Please note: The graphic representation of Tracts in Exhibit C-2, which was updated in October 2025, may vary slightly from the July 2025 conditions used for calculation of the Financial Warranty. However, as RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE4 EXHIBIT L extraction activities are currently minimal and reclamation has continued since the time of the Financial Warranty calculation, the bond required to reclaim the site is expected to be equal to or less than the amount presented here within. Annual Reports will report on the nature and extent of affected lands and more properly reflect actual conditions on the ground in a given year of operations. Tract A is an extraction area where a minor amount of material remains to be extracted. Tract A excavation will be reclaimed as a lined water storage reservoir. Much N70%) of the Tract A excavation has been regraded and lined with this post mining land use in mind. Tract B currently contains the dry processing plant with the wet processing plant currently situated in the northwest corner of Tract A. Material from the south adjacent Bearson permit (M-2015-033) is delivered to this area via a conveyor belt. Product stockpiles, including a large sand pile (approximately 200,000 cubic yards) exist in various locations within Tract B. Minor excavation is ongoing in Tract B and these excavations are proposed to be backfilled to no longer expose ground water as part of final reclamation. Tract C contains an excavation currently being backfilled to no longer expose groundwater; backfilling is proposed to continue until groundwater is no longer exposed. Tract D has minor excavations remaining to be backfilled to no longer expose groundwater. This area is currently in active use as part of the construction of a water pipeline by the City of Thornton. A general approach to reclamation of the operation left in its current state assumes: 1. Tract A excavation will fill with water and require dewatering to complete grading and liner construction. A significant amount of fill material has been stored in the Tract A excavation and this will be used in backfilling excavations in Tracts B, C, and D to ensure groundwater is no longer exposed. Existing ponds in Tract A will be backfilled unless they can be shown to satisfy the State Engineer requirements for lined storage. 2. The large sand pile in Tract B will be pushed using tracked dozers into adjacent existing excavations. Additional fill material to ensure groundwater is no longer exposed will be sourced from Tract A. 3. The exposed groundwater in Tracts C and D will be eliminated through backfilling of those areas. 4. Topsoil is currently being stored on the adjacent Bearson property (DRMS Permit M-2015-033) and will be conveyed using the existing conveyor to Tract B from where it will be distributed to all areas of the Kurtz permit to a depth of six inches. 5. The conveyor will be removed and while likely to have salvage value greater than the cost of recovery, a cost has been included in the estimate for removal. 6. The processing plant is all portable equipment and is conservatively assumed to be salvaged with no residual value. 7. Other items including truck scales, concrete pads and small structures will be removed. Estimates of the work required to complete the above reclamation of the Kurtz operation include material properties, material quantities, and material transport distances. Equipment productivity and fleet requirements are generally based on Cat Handbook and in some cases supported by previous DRMS methodology. The physical quantities and equipment requirements support cost estimates using rates either from recent DRMS reclamation cost estimates prepared in CIRCES, or other sources as noted. Raptor will update this Exhibit L, the reclamation cost estimate, and any other exhibits as required for purposes of determining financial warranty prior to final reclamation if the reclamation plan deviates materially from that described herein. RAPTOR MATERIALSILc Raptor Materials, LLC Kurtz Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT L In the following breakdown of components for estimating reclamation cost, various approaches to obtain the necessary quantities exist, but Raptor believes the approaches and quantities are reasonable and alternate approaches would be no more certain as to the accuracy obtained. This is simply due to the variable nature of the deposit and the need to field -fit the excavation to ensure safety in the conditions encountered. DEWATERING At the time of reclamation, areas with exposed groundwater in Tracts B, Cr and D will be backfilled and therefore will not require dewatering. Tract A will recharge to the static water level and will require dewatering to complete grading and liner construction. The reservoir volume for Tract A for the current condition was calculated using a 3D computer -aided design (CAD) program using the stage -storage curves for the static water surface elevation (WSEL) listed in Table 3. Determination of the static WSEL is detailed in Exhibit D - Extraction Plan. Table 4. Initial Dewatering Cost Estimate Pit Reservoir Vol (WSEL = 4,793 gal Tract A 1,013,540,070 Unit Discharge Cost $ Total Job Cost $ 0.000421 $426,422 Following initial dewatering, a 25 -day dewatering need was assumed for completion of lining and regrading. A 25 -day continuous dewatering volume was calculated based on the individual pit inflow estimate provided in the AWES Dewatering Estimate memo dated October 28, 2024 (attached as an addendum) for the P125B pit at the adjacent Cogburn (DRMS Permit M-2025-016) site. Inflow to the Cogburn P125B pit was calculated per linear foot; this same inflow rate per linear foot was applied to the Kurtz Tract A pit. As Tract A is currently partially reclaimed (N70%), inflow was reduced proportionally to the length of pit wall that is currently exposed, representing the worst -case scenario for inflow. Table 5.30 -Day Continuous Dewatering Cost Estimate Pit Inflow MCD Pit wall length ft Pit wall length exposed ft % of Tot Inflow Inflow over 25 days gal Tract A 3.89 10,680 2,535 23.74 Unit Cost Total Job Cost: 23,062,846 0.000536 12,367 The total dewatering cost (initial plus continuous) is estimated at $438,790. During dewatering, the basins will be lined or otherwise segregated from the area groundwater, to liberate the water otherwise retained to supplement loss from evaporation in the unlined state. LINER At the time of reclamation, liner will have been keyed into at least 70% of the base of the Tract A side walls and installed up to the ground surface, as detailed in Exhibit E - Reclamation Plan. Any areas below static water surface elevation in Tracts B, C, and D will be backfilled. Liner installation was separated into five stages for RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT L the purposes of cost estimation: grading the slope under the liner, ripping the liner source material, hauling liner material to the pit area, mixing material for the liner, and compacting the liner. The surface required to be regraded was assumed to be from either the base of the pit where no liner exists, or above the existing base liner where installed, to the top of the pit wall, at a thickness of 1 foot. Additional liner material not already accounted for either in stockpiled material or as an existing liner in Tract A will be ripped from the base of Tract A. Liner material was assumed to be installed at a thickness of 4 feet on the slope with a 4 -foot -by -4 -foot keyway where applicable to the height of the existing ground surface. Half of the liner material was estimated to require mixing; all the liner material was assumed to require compaction. Surface areas for wall to be regraded and liner installation were measured based on the above -described mining plan, further detailed in Exhibit D — Mining Plan, for the current condition surface in a 3D CAD program. Keyway was estimated to be required for all wall lengths requiring lining; these sections are indicated on the attached Kurtz Project 2024-2025 Annual Report map. As material is expected to expand during grading and mixing, a swell factor was applied to these volumes. Likewise, a shrinkage factor was applied to the material volume for compaction. Calculation of the regrade and liner material volumes required for reclamation is presented in Table 6 below. Table 6. Regrade and Liner Volume Calculations Activity Wall Area sq.ft Wall Depth ft Keyway Length ft XS Keyway Area sq.ft Material Vol cu.ft Material Vol cu.yd Regrade Liner 407,667 1 N/A N/A 2,983,500 110,500 252,824 4 2,535 16 1,011,296 37,455 Haul distance was calculated as a weighted average of the of the distances from the liner source to the liner installation and backfill areas for Tract A. The source deposits contain extensive materials suitable for use in constructing the liner including shale, claystone, clay, sandstone-claystone-siltstone and sandstone-siltstone bedrock, clay lenses in the sand and gravel deposit, and overburden often comprised of low plasticity sandy silty clay to silty sand. Excess topsoil has also been successfully used as a liner construction material and could be used if excess material is available. Typical liner installation as described in Exhibit E - Reclamation Plan is shown on Figure 1 below, which indicates dimensions used in the calculation of regrade area and liner and backfill volumes for this cost estimate. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 7 EXHIBIT L Typical Liner and Regrade for Extraction Limit Wall — Final Reclamation Topsoil Regrade at 3H:1V slope Original Ground Surface Static Water Level (varies) Existing 5H:1V slope - Excavate this portion Sequence 1. In cycles • Excavate wall to 3H:1V • Establish line in keyway Install liner in G" lifts , Replace topsoil • j. j•••• j•e• j• j••••,••.1•••12•0•0•••••••••••••••••••••••••••••••••••••P•0••••• •. j. j. • • • • • ••• ••••••••••• • • • • •• •• • • • • • • • • • •• j j j j . . . . . . . . . . . . . . . . . . . . . . •••••••••••••••••••••••••....%0.0 .••••'. . ••+••+++•++••+' ,•.,d+++++'++++++.+'++'++°++ .• .• .• . . .• ,• •••••%0y••'•..+••+,•..•..+..+..+,+..+..,..,:.•..+..+..+..+..•..+..+,+..+..+..•..+..+..+.+.+.;..,..+,.+..+..+..+..+..+..+..+..+..,..•...;.+..+..+..+..+..,:.+..+..+..•..+..+,.+..+..+..+..+,.•..•.+.+.•. . :.tit•j.j•: ' . i.•..' Bedrock •. . �f F i I 5 1 = Figure 1. Typical Fully Reclaimed Liner and Backfill Construction Calculations for the individual lining component costs are provided in Table 7 below. Unit costs were derived from the total cost, which was based on fleet production and rates for the calculated volumes, which were taken from the recent DRMS-provided P124 Two Rivers (M2022-013) cost estimate. Table 7. TractA Reclamation Liner Installation and Pond Backfill Cost Estimate Activity Initial cum Vol d yd Swell/ Compaction Factor p Compacted Loose/ R cu.yd Vol Unit Cost Unit Total Job Cost Grade 110,500 1.12 123,760 $0,437 cu.yd $54,070 Rip 78,992 N/A N/A $556.28 acre $10,639 Haul 126,621 1.00 126,621 $1.042 cu.yd $131,906 Mix 63,311 1.163 73,599 $0.460 cu.yd $33,881 Compact 126,621 0.91 115,225 $0.145 cu.yd $16,762 Total Liner Cost: $247,258 In the current condition groundwater is exposed in Tracts B and D in active areas of fill and excavation. Additionally, unlined groundwater ponds in inactive area are present in Tracts A and C. All of these areas will be backfilled as part of the reclamation plan. The standing groundwater within the active extraction area of Tract A is within the area currently being lined and is planned for reclaimed use as a lined reservoir. Backfill was assumed to be hauled from the source area and progressively placed in the areas of exposed groundwater, with compaction achieved through the tracking of heavy equipment over the backfill and through weight of the backfill itself. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGES EXHIBIT L Surfaces were created for the existing and reclaimed conditions in a 3D CAD program for all tracts; backfill volume required for reclamation was determined to be the difference between these two surface volumes. Backfill for all tracts will be achieved using the source material area within Tract A, with the exception of Tract B, which will achieve the majority of its backfill through pushing the existing sand pile into the adjacent pit. Haul distances are illustrated in the attached quantities supplement. Material hauled for backfill has already been excavated and therefore has not been assigned a swell factor for cost estimating purposes. The backfill concepts for lined walls in Tract A is portrayed in Figure 1 in the preceding subsection: Liner; backfill for the Tract A ponds was also accounted for in the previous section. The cost estimate for backfilling Tracts A, B, and C, summarized in Table 6 below, is, similar to the liner cost estimate, based on fleet production and rates for the calculated volumes, which were used to derive unit costs from the total backfill cost. Table 8. Reclamation Backfill Cost Estimate Activity Tract Initial Vol cu.yd unit Cost $/cu.yd Total Job Cost Haul Backfill Push Sand B C D B 135,844 317,211 12,485 202,613 1.196 1.843 1.416 1.045 162,485 584, 644 }17,674 211,774 Total Backfill Cost: 976,577 TOPSOIL Topsoil will be applied to the cut basin slopes remaining above the static water level for pits reclaimed as reservoirs (Tract A) and to the entirety of the currently disturbed surface and areas of proposed backfill for Tracts B, C, and D. Topsoil will be placed at a depth of approximately 6 inches over both even ground and cut slopes and seeded with a cover of stabilizing vegetation, as detailed in Exhibit E - Reclamation Plan. Current disturbed surfaces in all tracts were measured from aerial imagery from a June 2025 drone flight. The cut slope surface area above the static WSEL was calculated from the Tract A reclaimed surface in a 3D CAD program. Topsoil is currently being stored on the adjacent Bearson property (DRMS Permit M-2015-033) and will be conveyed using the existing conveyor to Tract B from where it will be distributed to all areas of the Kurtz permit to a depth of six inches. Topsoil application was assumed to be covered under a hauling task, which is based on the haul distances from the topsoil stockpile location to the average application area for each tract. Topsoil is expected to swell during conveyor transport to its stockpile location, where it is proposed to be hauled soon thereafter for placement; therefore, no additional swell factor was applied for cost estimating purposes. Similar to backfill costs, topsoil hauling costs were based on fleet production and rates taken from the recent DRMS-provided P124 Two Rivers (M2022-013) cost estimate for the calculated volumes, which were used to derive unit costs from the total haul cost. The average haul route distances from the conveyor deposit area to each of the Tracts is documented in the attached quantities supplement. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE EXHIBIT L Table 9. Topsoil Application Cost Estimate Activity A sf Tract B sf Tract C sf Tract D sf Topsoil To .soil Depth p ft Initial Vol cu.yd Total Unit $/cu. Cost Y d Total Cost Job Haul 1711,908 2,269,476 527,076 466,092 0.5 92,121 1.207 $111,190 REVEGETATION Revegetation will occur following placement of topsoil on disturbed areas remaining at the time of reclamation. As described in the above subsection, Topsoil, all disturbed areas remaining at the time of reclamation, including currently disturbed ground surface, current areas of groundwater to be backfilled, and reservoir slopes above the static groundwater level in the Tract A lined water storage, will be revegetated. Seeding will therefore occur over the same exposed area as described in more detail in Exhibit E — Reclamation Plan, and according to seed mixes and application methods presented in Table L, attached as an addendum to this Exhibit. The cost estimate for revegetation, which assumes a 25% initial failure rate that will require re -seeding, is based on labor and machinery unit costs taken from the recent DRMS-provided P1 24 Two Rivers (M2022- 013) cost estimate, and materials unit costs provided by Great Basin Seed, and is presented in Table 10 below. This unit cost includes the cost of seed and fertilizer, their application, tilling, mulching, and nursery stock planting. Please note that seed costs are known to fluctuate seasonally and may vary noticeably from the unit cost used here. Table 10. Revegetation Cost Estimate Tract Total Disturbed Area ac Estimated Rate Failure Initial + Reseeding Area ac Seed Cost/Acre Total Job Cost All 114.2 25% 142.8 $2,740.86 $313,006 CONVEYOR DECOMMISSIONING An elevated conveyor currently transports raw material from the south adjacent Bearson property (DRMS Permit #M-2015-033) to be processed at the wet plant located on the Kurtz site's Tract B. This conveyor will be used during reclamation to transport topsoil stockpiled on the Bearson site to the Kurtz property. The conveyor, installed in modular 40 -foot sections, is portable and will be decommissioned and transported offsite for use elsewhere following site reclamation. The span of conveyor to be removed starts at the south end at the bridge that spans County Road 28 and includes all conveyor segments on the Kurtz property, for an estimated total of 4,620 linear feet. Decommissioning will involve conveyor sections and belting, and demolition and on -site disposal of its supporting concrete blocks. A cost estimate of $269,000 for conveyor decommissioning was provided by Divide Construction in June 2025 and is attached to this Exhibit. 1 https://greatbasinseeds.cam/ RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC PAGE 10 EXHIBIT L MOBILIZATION AND DEMOBILIZATION Mobilization and demobilization costs are based upon the Division's estimates, which are pending - but estimated in the summary at the beginning of this Exhibit L at $11,154. DEMOLITION OF STRUCTURES Table 11 lists on -site structures that are proposed to be removed to return the site to a reclaimed condition. The weigh station at the north site entrance contains truck scales with concrete pads and wingwalls, as well as a scale house with a concrete foundation. A materials storage area in the western portion of Tract A contains a Quonset hut and 10,000 -gallon fuel tank, both with concrete pads. Concrete culverts have been temporarily stored in the southern portion of the Tract C pond and would be removed as part of reclamation. Cost estimates for all structures were taken from the CDOT 2025 Cost Data Book, with the exception of the 10,000 -gallon tank removal, which used as a basis the 2024 Eagle -Gypsum Mine (DRMS Permit #M-1984- 041) financial warranty cost estimate. Table 11. Structure Demolition or Removal Cost Estimate Tract Structure Dimensions Quantity Unit Unit Cost Total Cost B wingwalls A, B Concrete Pads A C A Quonset Hut Culverts Fuel tank 5x 25' at Truck Scales Quonset Hut: 267 SY Fuel Tank: 21 SY Truck Scale 1:101 SY Truck Scale 2: 72 SY Scale House: 16 SY 60'x40' 125.00 LF 376.00 SY 1.00 EA 8'L x 2.5'-5'D RCP 300.00 LE 10,000 gallons 1.00 EA 148.74 124.15 $11466.74 S57.25 S1,000.00 18,592 46,680 11,467 17,176 1,000 Total Demolition Cost: $94,915 Please Note: Since there is no possibility of the applicant in fully reproducing the Division's methods, using similarities from past DRMS calculations is the most viable and accurate means available for the applicant to derive reasonable estimates of per unit costs and should result in estimates very reliable with that of the Division. RAPTOR MATERIALSILc Raptor Materials, LLC Kurt Resource Recovery and Land Development Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC I APPRO% PARCEL remY rd •.; .<A^.•-;'.i. AA 3�- . • . 1447 333293- 33292— •33329ar 1. .4••• -ell Set 3296r • HRIISM:IT'66--�__-_.-- i i / EXCAVATION BOUNDARY TRACT C 12.9 AC. HAMA .s:j#G r. 'a ACCESS POINT W2 A . • ` /` •r I� \ V It PACEi.cERWT SOUND -Mg. OUTFALL Dn a Nor Mw -1 7023 00 ACCESS P01419 [O/4AI4•Pre S.— Rvtt• re *MA NC. MS W VOW ras a. MOWS earn ti..wr IMP) W-Wr IMPOINIO GROUND/ ATM TO IMERACKFILLID TRACT D 8.8 AC. PRODUCT STOCKPILE AREA Acct E3'. POINT •: SILT POND RECYCLE WATER FOR WET PLANT SILT POND RECYCLE WATER FOR WET PLANT HAD F 40:11*3 `PANCIIMIRMIT ROUNDARv i 1 - "- - Hlr:llWA1' dd ACTIVE AREA OF EXTRACTION 11 h. Ya•ic-.y 1 TRACT 8 563 AC. ' H4C it) rw_ +114) EXCAVATOR BOUNDARY I t. 1 trfif • PARCRIPERWT BOWOARY SCALE 1 =;to CONTOUR INTERVAL 10 FEET SUMMARY O- AREAS 296 3 AC PERMIT AREA; AFFECTED LAND AREA 209 8 AC TOTAL TRACT AREA 132 6 AC TRACT A 55 5 AC. TRACT B 12.9 AC. TRACT C 8.8 AC. TRACT D LE.5END `J PERMIT BOUNDAR r / AFFECTED LANDS " AREA LW EXCAVATION / 411NIhG TRACT AREA PERMIT BOUNDARY - 200 FOOT SETBACK APPROXIMATE ADJACENT PARCEL LINE SECTION BCUNDARY EXISTING MAJOR CONTOURS EXISTING STRUCTURES EXISTING OPT RCA') EXISTING EDGE OF WATERBODY O EXISTING GAS Wel_ (CW) O EXISTING WATER WELL EXISTING OVERHEAD UTILITY I.-3 • EXISTING UNDERGROUND GAS I INE rt S EXISTING CONCRETE DITCH EXISTING EARTHEN DITCH EXISTING CONVEYOR DEFINED DISCHARGE OU FALL "ant Kurtz Project — OMLR Permit M1999-006 DSSt Exhibit C - 2a- Mining Plan Mao -- Part 1 Nat ALT 3021 WPM ! OONITIW WFONATION Iran Propel* sibilf• DipM/Mtt can) Peter Christensen. NM-SME O94 wed Or PS (ninon RYIAMI Oat M11044 133129pm w1t 1 Inca - 200 lest BAU. 25 Seotsmber 2001 Cfldk 23 October 2025 PAW. —1— °`...ileemp, PRIMARY ENTRANCE 1PPROX PARCEL IOUNDARY APPROX PARCEL 7 BOUNDARY '4.• .:PL.:",!A PARCEL/PERNIT SOUNDARI Sri/ 333293- 333292- 333294 - HIGHWAY of. at 1 •' • e t'\ EXTRACTION AREA ID EXTRACTION AREA. AC BACKFILL AREA, AC. RESERVOIR AREA. AC (WATER SURFACE) SLOPE G4ADIENT TRACT A 130.2 N/A 129.2 3H:1 V TRACT B 55 5 N/A 53 2 3H: 1V TRACT C 17.9 N/A 11.4 3M:1 V TRACT D N/A 8.8 N/A N/A RAPTOR LIATIVIALS, 4C. Pi AM SHIMt MSS e0.a..JO SM „Med, Iwo MI- Mel EXCAVA T WAN BOUNDARY TRACT C 12_9 AC. r PARCEL,PERmIl BOUNDARY ./ .d :33152- -- 1 Mw -1 7023 ACCESS POINT t! tmJT A N. ti17r 6Mr • Av i CHANCE DITCH { ACCESS PUNJT Pt EXCAVATION BOUNDARY PARCEUPERMII BCUNGARr /UGH ICS 1.1515 TRACTS 55.5 AC. TRACT A 132.6 AC. WIT S At,. 207S AERIAL It CONICXJR re OSHA* TION Yom P.ant a rob iv t. (rep tame, aids& prpMY corn) OUTFALL 001•A EXCAVATE)N BOUNDARY OUTFALL 0034 EXCAVATION BOUNDARY A� 87t OUTFALL az-A. EXCAVATION BU UNOAR Y PARC EUPER MTV BO UNLIAR V LEGEND Peter Christensen, Digital, signed by Peter Christensen, RM-SME RM-SM E Date: 2025.10.241704:33 0 • 0 100 tin SCALE 1' = 200 CONTOUR INTERVAL 10 FEET EXISTING MAJOR CONTOUR EXISTING MINOR CONTOUR PERMIT AND AFFECTED LANDS BOUNDARY 200 FOOT BOUNDARY OFFSET - APPROXIMATE FENCE EASEMENT UNE DISCHARGE PIPE RIGHT 0E-NMY LINE STREET • EXISTING FLOODPLNN EXTRACTION LIMITS WATER -FILLED AREA BACKFILLED RANGELAND PIT WATER LEVEL RIVERBANK PRODUCING WELL HEAD APPROXIMATE PLUGGED a ABANDONED WELL HEAD t.00ATION GATE POST WATER WFLt. OIL OR GAS VVELt. ABANDONED OIL OR GAS WELL %CAW 1 inch 200 feet COT 2S September REVISOR: PACL 23 October 2025 1 orb_, �AIO� Product # RAPTOR MATERIALSLLc 8120 Gage Street • Frederick, CO 80516 Bus: (303) 666-6657 • Fax: (303) 666-6743 AGGREGATE PRODUCTS 201 1 1/2" Washed Rock 203 3/4" Washed Rock 204 3/8 Pea Gravel 301 1 1/2" Road Base 308 Class 5 Road Base 303 3/4" Road Base 309 Class 6 Road Base 304 Class 1 Structural Fill 401 Concrete Sand 403 Squeegee 825 Restocking Fee PAGE 1 BACKFILL NOTICE EXHIBIT E - BACKFILL NOTICE Inertfill may be imported, or utilized from existing on -site sources, to meet or exceed planned post extraction land use development potentials over the project area during the life of the operation. The extent and location of fill will be field determined. All inert materials used for backfilling will be consistent with DRMS Rules and Regulations, and those of the Colorado Department of Health and Environment. All backfill material will be placed with sufficient fines to minimize voids and settling of backfilled areas and slopes. There are no known or expected acid forming or toxic producing materials or refuse at this location, nor will materials known to possess such qualities be knowingly utilized for fill. Any other refuse or reject materials that do not meet the definition of inert and requiring removal and disposal will be placed in closed containers and taken to an appropriate landfill for disposal, unless it is otherwise 'inert,' per Rule 3.1.5(9), of the DRMS Rules and Regulations. All materials, whether extracted on -site or imported, will be handled in such a manner so as to prevent any unauthorized release of pollutants to surface or ground water resources. All fill will be integrated to meet or exceed the reclamation plan and correlated end uses authorized under the approved Colorado Division of Reclamation, Mining and Safety permit. All fill above the anticipated static water level of the resulting basins will be soiled and stabilized according to the approved reclamation plan, or as otherwise allowed according to this application or locally approved land uses. The location and extent of fill utilized over extracted lands will be designated in required DRMS Annual Reports, permit revision, or as part of any request for release of the permitted area, in part or whole. These representations are authorized as is or otherwise modified under the signed original approved DRMS permit, until or unless subsequently modified by an approved DRMS Technical Revision. RAPTOR MATERIALSILc Raptor Materials, LLC Kurtz Sand, Gravel, and Reservoir Project October 2025 A REGULAR IMPACT (112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING AND SAFETY, OFFICE OF MINED LAND RECLAMATION RESPEC Universal Stormwater Management Plan Raptor Materials LLC May 4, 2023 Revision: 00 Universal Stormwater Management Plan May 4, 2023 Table of Contents 1.0 Introduction 1 1.1 SWNP Administration 2 1.2 SWMP Availability 2 1.3 Updating the SWMP 2 1.4 Facility Maps 3 2.0 Facility Inventory And Assessment Of Pollutant Sources 1 2.1 Inventory of Facility Activities and Equipment 1 2.2 Inventory of Materials 1 2.2.1 Potential Sources Of Pollutants From Past Activities 1 2.3 Assessment of Potential Pollutant Sources 1 3.0 Control Measures 1 3.1 Minimize Exposure 1 3.2 Good Housekeeping 1 3.2.1 Concrete Batch Plant Good Housekeeping Requirements 1 3.3 Maintenance of Control Measures 2 3.4 Spill Prevention and Response Procedures 2 3.4.1 Spill Prevention Procedures 2 3.4.2 Spill Response Procedures 2 3.4.3 Notification Procedures 3 3.5 Erosion and Sediment Controls 4 3.6 Waste, Garbage, and Float able Debris 4 3.7 Dust Generation and Vehicle Tracking of Industrial Materials 5 3.8 Management of Runoff 5 3.9 Salt Storage Piles or Piles Containing Salt 5 3.10 Process Waste Water (Extractive Facilities Only) 5 3.11 Employee Training 5 3.12 Non-Stormwater Discharges 5 3.12.1 Unauthorized Non-Stormwater Discharges 5 4.0 Inspection Procedures and Documentation 1 4.1 Quarterly Visual Inspect ions 1 4.1.1 Inspection Scope 1 4.1.2 Inspection Documentation 1 4.1.3 Non -Compliance Discoveries 2 5.0 General Monitoring Requirements 1 ii Universal Stormwater Management Plan May 4, 2023 5.1 Visual Monitoring/Assessment 1 5.1.1 Quarterly Visual Assessment Documentation 2 5.1.2 Quarterly Visual Assessment Corrective Actions 2 5.2 Monitoring Periods 2 5.3 Benchmark Monitoring (Concrete Batch Plants Only) 2 6.0 Corrective Actions 1 6.1 Conditions that Must Be Eliminated 1 6.2 Condit ions t hat Require Review and Modification 1 6.3 Correction Action Reports and Deadlines 1 6.4 Control Measure Modification 2 7.0 Reporting and Recordkeeping 1 7.1 Discharge Monitoring Reports 1 7.2 Annual Report 1 7.3 SWMP Records 1 8.0 Certifications and Signatures 1 Appendices Appendix A Facility Detail Summaries and Maps Appendix B Appendix C Appendix D Appendix E Appendix F Spill Log and Five Day Report Form Employee Training Log Inspection Forms Annual Report Forms Corrective Action Summary Sheet iii Universal Stormwater Management Plan May 4, 2023 1.0 Introduction This Stormwater Management Plan (SWMP) has been developed as a Universal SWMP for the Raptor Materials, LLC (Raptor) facilities identified below that have coverage under the Colorado General Permit No. COG500000 for Discharges from Sand and Gravel Mining and Processing (and other Nonmetallic Minerals Except Fuel) and Colorado General Permit No. COR900000 for Stormwater Discharges Associated with Non -Extractive Industrial Activity (General Permits) administered by the Colorado Department of Public Health and Environment (CDPHE). The purpose of the SWMP and the stormwater program is to minimize the potential pollution of surface waters. Specifically, this SWMP outlines and describes the actions required for management of stormwater and pollution prevention at the facilities. Facility specific information for each location is provided in Attachment A. Facility/Operations Name Land Parcel Address Certification Number Greeley North Ready Mix Plant P1 N 3600 Greeley, O Street CO 80632 Pending Greeley Aggregate Ready Central Mix Sand Ready Recycling Plant & Mix Gravel and Plant and Greeley Plant, inactive P1C/P120 1431 Greeley, E 16th Steet CO 80632 COG501526 Ft. Lupton Ready Mix Plant P2 15457 Fort Lupton, HWY 52, CO 80621 COR901453 North Aggregate Metro Recycling Ready Mix Plant and P4 1688 WCR Erie, CO 11 80516 COR900353 Aggregate Supply Reservoirs Recycling and Water P109, and P110 P112 12910 Longmont, County CO Rd. 80504 13 COG501828 Platteville Water Reservoir Sand & Gravel Plant and P115 8490 Platteville, Highway 66 CO 80651 COG500346 Greeley Aggregate Ready Mix Sand Recycling Plant & Gravel and Plant, Inactive P117 1431 Greeley, E. 16TH CO Ave. 80631 COG500100 Greeley Aggregate Ready Mix Sand Recycling Plant & Gravel and Plant, Inactive P121 Northeast Ave. Greeley, and Corner E 16th CO 80631 St., of Fern COG501583 Platteville Water Reservoir Sand & Gravel Plant and P122 Intersection County and WCR Road 28 of (WCR) Weld 17 COG501584 1 Universal Stormwater Management Plan May 4, 2023 1 .1 SWNP Administration The following individuals or position are responsible for SWMP development, implementation, maintenance and modification. Permittee Contact Name Robert Haun Title Vice President of Operations Phone 720-698-2455 Email rhaun@raptormaterialslIc.com Site Contact and SWMP Administrator Name Ben Wilson Title Environmental Manager Phone 832-335-0230 Email bwilson@raportmaterialsllc.com Discharge Monitoring Report (DMR) Official Name Ben Wilson Title Environmental Manager Phone 832-335-0230 Email bwilson@raportmaterialsllc.com 1.2 SWMP Availability A copy of the SWMP is maintained at the main Raptor office at 8120 Gage Street in Frederick, Colorado. The SWMP is available for the CDPHE to review at the time of an on -site inspection. 1.3 Updating the SWMP There are two required SWMP modification categories: 1. Water Quality Control Division (Division) initiated: a. Raptor will modify the SWMP when notified by the Division that it does not meet one or more of the requirements of the General Permits. Unless otherwise provided by the Division, Raptor will have 30 days after notification to make the necessary changes to the SWMP and implement them. b. The Division may require Raptor to submit the modified SWMP to the Division. c. If the Division determines that Raptor's stormwater discharges do not, or may not, achieve the effluent limits required by the General Permits, the Division may require Raptor, within a specified time period, to develop and implement a supplemental control measure action plan, which describes additional SWMP modifications to adequately address the identified water quality concerns. 2. Permittee initiated: a. Raptor will modify the SWMP whenever necessary to address any of the triggering conditions for corrective action to ensure that they do not reoccur. b. Raptor will modify the SWMP whenever there is a change in design, construction, operation, or maintenance at the facility that significantly changes the nature of pollutants discharged in stormwater from the facility, significantly increases the quantity of pollutants discharged, or that requires Raptor to implement new or modified control measures. 2 Universal Stormwater Management Plan May 4, 2023 c. The SWMP modifications may include a schedule for control measure design and implementation, provided that interim control measures needed to comply with the permit are documented in the SWMP and implemented during the design period. Raptor will make all SWMP modifications in accordance with the corrective action deadlines identified in the General Permits (Corrective Actions, Section 6.0 of this SWMP) . 1.4 Facility Maps Maps for each facility are included in Attachment A. Maps include at a minimum the following if applicable: • The boundary of the mining and processing operation • The location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility (including the name of the surface water; if the name is not known, indicate that on the map); a separate vicinity map may be necessary to comply with this requirement • Significant impervious surfaces within the facility property boundaries, including paved areas and buildings • The locations of all facility stormwater conveyances including ditches, pipes, and swales • The locations of stormwater inlets and outfalls, with a unique identification code for each outfall and an approximate outline of the areas draining to each outfall • Direction of stormwater flow indicated by arrows • The areas where mining and processing activities are currently or have previously been conducted, where such activities are exposed to precipitation. This includes all areas of soil disturbance and reclamation/revegetation • Locations of all actual or potential pollutant sources associated with mining and processing activities including but not limited to: o Vehicle fueling areas o Fertilizer or chemical storage areas o Areas used for storage or disposal of overburden, materials, soils or wastes o Areas used for mineral milling and processing o All access and haul roads o All asphalt or concrete batch plants, or areas used for recycling of asphalt or concrete • For concrete batch plants — include (as applicable): dust control devices, recycle/sedimentation ponds, clarifiers, or other devices used for the treatment of process wastewater; and the areas that drain to the treatment device. • The location of any and all process water discharge outfalls, including specified locations of mine dewatering operations • Location of all structural and non-structural control measures used to meet the effluent limits of permit • The locations where significant spills or leaks meeting the definition of significant spills and leaks have occurred • Stormwater monitoring points (visual, benchmark, numeric effluent, and water quality -based) 3 Universal Stormwater Management Plan May 4, 2023 • Location and description of authorized non-stormwater er discharges • Locations and sources of potentially polluted run-on to the facility from adjacent property • The date that the facility site map was prepared/amended • Maps for concrete batch plans will also include the location of the following if present: o Dust control device o Recycle/sedimentation pond o Clarifier o Other devices used for the treatment of process water o Areas that drain to the treatment device 4 Universal Stormwater Management Plan May 4, 2023 2.0 Facility Inventory And Assessment Of Pollutant Sources Various activities that could be sources of pollution to stormwater are described in this section and shown on the facility figures in Attachment A. For each activity, equipment area, or material storage area, Raptor has assessed the potential pollutant sources and has included a description of the potential of a pollutant to be present in stormwater discharges. Raptor updates this description when data becomes available that identifies the presence or absence of these pollutants. 2.1 Inventory of Facility Activities and Equipment The following is an inventory of the Facility activities and equipment associated with industrial activities that have been, or may potentially be, sources of pollutants, that contribute, or have the potential to contribute, any pollutants to stormwater. • Loading and unloading of materials, including solids and liquids • Outdoor storage of materials or products, including solids and liquids • Outdoor manufacturing and processing • On -site dust or particulate generating processes, including dust collection devices and vents • Vehicle and equipment fueling, maintenance, and/or cleaning • Roofs or other surfaces exposed to air emissions from a manufacturing building or a process area 2.2 Inventory of Materials Raptor has developed the following Inventory of Materials that contribute or have the potential to contribute pollutants to stormwater. • Aggregate, ash, cement and other concrete components • Diesel and gasoline • Oils and other maintenance fluids • Concrete additives including calcium chloride, Sika NCA, and Sikament-475 2.2.1 Potential Sources Of Pollutants From Past Activities Raptor has identified no past activities that could contribute pollutants to stormwater discharges. Any significant spills and leaks of oil or toxic or hazardous pollutants that occurred at exposed areas, or that drained to a stormwater conveyance are documented on the Spill and Leak Log in Appendix B. 2.3 Assessment of Potential Pollutant Sources The following is a description of the potential pollutants that may be present in stormwater discharges for each facility activity, equipment and material identified above. Note that the activities listed below do not occur at every facility. Facility Activity Potential Pollutants Loading and unloading operations Total chemical suspended additivities solid (TSS), fuel and oils, concrete Outdoor storage of chemicals or equipment TSS, fuel and oils, concrete chemical additivities 1 Universal Stormwater Management Plan May 4, 2023 Facility Activity Potential Pollutants Crushing generating facilities activities or significant dust and particulate TSS On site waste disposal practices TSS Stockpiles products, products of byproducts, overburden, finished raw material, products intermediate or waste TSS Asphalt recycling or of concrete asphalt batch or concrete plants or areas used for Not present Routine pesticides, maintenance detergents, activities fuels, solvents, involving oils, fertilizers etc TSS, fuel and oils Haul roads TSS Disturbed and revegetated areas TSS Roofs materials and that associated may be surfaces mobilized composed by stormwater of galvanized Not present 2 Universal Stormwater Management Plan May 4, 2023 3.0 Control Measures This Section describes structural and non-structural Best Management Practices (BMPs) or control measures implemented at the facilities to achieve the effluent limitations. Raptor also complies with the additional sector specific requirements that apply to the concrete batch plant facilities (P1C and P1N). Those requirements/BMPs are incorporated below. 3.1 Minimize Exposure In addition to BMPs implemented at the Facility that are designed to minimize exposure by conducting operations and storage activities within on -site structures, the Facility is equipped with structural controls designed to minimize the exposure of industrial activities to rain, snow, snowmelt, and runoff. All stormwater at the facilities is directed via drainage systems, such as catch basins, into the facility wide -storm systems. The aboveground storage tanks (ASTs) at the facilities are equipped with spill controls and secondary containment which are designed to minimize exposure. Repairs on heavy equipment are made at the Raptor Diesel Shop. All materials are hauled to the processing facilities internally and are not anticipated to breach the internal drainage of each facility. Stockpiled material at the plants/processing locations is deterred from exiting the facilities by their large size higher surrounding topography and other features such as perimeter access roads. 3.2 Good Housekeeping Good housekeeping measures/BMPs at the facilities are designed to keep clean all exposed areas and minimize potential sources of pollutants. The following good housekeeping BMPs are implemented at the facilities: • Exposed areas of the facilities are maintained in a clean, orderly manner; • Petroleum product storage areas, containers/tanks (interior and exterior), and fueling pumps are inspected on a monthly basis; • Any oil -stained areas (pavement or soil) are required to be cleaned immediately; • Dumpsters are emptied regularly and as needed; • Materials are kept orderly and labeled; • Materials are stored in appropriate containers; • Drums, tanks, and containers are routinely (at least quarterly) inspected for leaks and their condition; • Dumpsters are kept closed or covered with a tarp when not in use; and • The potential for waste, garbage, and floatable able debris to be discharged is minimized by keeping exposed areas free of such materials, or by intercepting them before they are discharged. 3.2.1 Concrete Batch Plant Good Housekeeping Requirements Additional good housekeeping measures are in place per the sector specific requirements to prevent or minimize the discharge of spilled cement, aggregate (including sand or gravel), settled dust, or other significant material in stormwater from paved portions of the facilities that are exposed to stormwater. 1 Universal Stormwater Management Plan May 4, 2023 • Raptor sweeps regularly (at least once a month) or uses other equivalent measures to minimize the presence of these materials. • Raptor prevents the exposure of fine granular solids (e.g., cement, etc.) to stormwater, where practicable, by storing these materials in enclosed silos, hoppers, or buildings, or under other covering. 3.3 Maintenance of Control Measures A preventative maintenance program is currently in place for the facilities, with daily, weekly, monthly, annual, and/or as -needed inspections of control measures (dependent upon the manufacturer specifications). Preventative maintenance includes preventative and routine maintenance, modification, repair, replacement, or installation of new control measures. Corrective actions associated with maintaining control measures are conducted with due diligence, as soon as possible after the need is discovered, to achieve the effluent limits required. Raptor will implement interim control measures to achieve the effluent limits required by the General Permits while performing maintenance of the primary control measure. Raptor will document corrective actions associated with maintaining control measures, in accordance with Section 6.0, and will revise the SWMP to reflect replacement or installation of new control measures in accordance with Section 1.3. 3.4 Spill Prevention and Response Procedures The facilities will minimize the potential for leaks, spills and other releases that may be exposed to stormwater and has developed a plan for the effective response to such spills. 3.4.1 Spill Prevention Procedures At a minimum Raptor has implemented the following: • Procedures for regularly inspecting, testing, maintaining, and repairing all industrial equipment and systems to avoid situations that may result in leaks, spills, and other releases of pollutants in stormwater discharged to receiving waters. • Procedures for plainly labeling containers (e.g., "Used Oil," "Spent Solvents," "Fertilizers and Pesticides," etc.) that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur. • Preventative measures such as barriers between material storage and traffic areas, secondary containment provisions, and procedures for material storage and handling. o Control measures (secondary containment or equivalent protection) for any chemical (e.g., petroleum products, pesticides, magnesium chloride, treatment chemicals, etc.) located at the facilities to contain all spills and prevent any spilled material from entering state waters. The containment system must have sufficient capacity to contain 10% of the volume of containers, or the volume of the largest container plus 10%, whichever is greater. • Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases. • Procedures for notification of appropriate personnel, emergency response agencies, and regulatory agencies. 3.4.2 Spill Response Procedures Raptor employs the following procedure for spill response for surface spills or sheens: 2 Universal Stormwater Management Plan May 4, 2023 1. Quickly identify the source and substance and assess the situation. 2. Contain the spill, if safe to do so, preventing it from reaching the stormwater system by using available spill response equipment. All spills or leaks are cleaned using good housekeeping methods. 3. Immediately contact the SWMP Administrator and, if necessary, call 911. If the SWMP Administrator is not available, then contact other trained personnel and they will assume the responsibility for implementing the remaining procedures below, provided that they have been trained to protect health and safety during a spill response and to implement these procedures. 4. The SWMP Administrator will make the determination on if the spill has exceeded reportable quantities and make the assignment to an outside emergency response contractor to implement control and clean up if needed. 5. The SWMP Administrator will document and report reportable spills. The SWMP Administrator will also document the spill response and corrective action as well as conduct follow-up reporting or written correspondence as required. All spill material and debris will be managed in a manner that fully complies with applicable local, State and Federal laws regarding recycling or disposal of wastes. The preferred method is to recycle or reclaim materials from spills in an effort to minimize waste generation. Where this is not feasible or allowed, then disposal in accordance with applicable local, State or Federal rules will be performed. 3.4.3 Notification Procedures 1. External notification will be made to the appropriate governmental authorities as follows: a. 911 when there is a threat to life or property. b. State: i. Report an emergency related to an environmental spill, health facility, or community public health concern to the CDPHE at 1-877-518-5608; 24 -hour emergency line c. Federal: i. Releases into the environment of hazardous substances in excess of reportable quantities' or discharge of oil that (a) violates applicable water quality standards, (b) causes a film, sheen, or discoloration of surface of the water or adjoining shorelines, or (c) cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines, shall be reported immediately to the National Response Center (NRC) at (800) 424-8802. a. The NRC will ask forthe following information: 1. Name, location, organization, and telephone number; 2. Name and address of the party responsible forthe incident; 3. Date and time of the incident; 4. Location of the incident; 5. Source and cause of the release or spill; 6. Types of material(s) released or spilled; 7. Quantity of materials released or spilled; 8. Danger or threat posed by the release or spill; 9. Number and types of injuries or fatalities (if any); ' Section 103(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires that the person in charge of an onshore facility immediately notify the National Response Center whenever a reportable quantity (RQ) or more of a CERCLA hazardous substance is released in any 24 -hour period, unless the release is federally permitted. The list of hazardous substances and their reportable quantities are codified in 40 CFR part 302, Table 302.4. The RQ for any product used onsite can also be obtained from the Safety Data Sheet, 3 Universal Stormwater Management Plan May 4, 2023 10. Weather conditions at the incident location; and 11. Any other information that may help emergency personnel respond to the incident. ii. Releases of (a) more than 1,000 U.S. gallons of oil in a single discharge to navigable waters or adjoining shorelines or (b) more than 42 U.S. gallons of oil in each of two discharges to navigable waters or adjoining shorelines occurring within any twelve- month period shall be reported immediately to the Regional Administrator of the US EPA at 312-353-2000 or the Region 5 Spill Reporting Number at 800-621-8431. a. The notification must include the following information: 1. The name of the facility; 2. The name of the owner or operator of the facility; 3. The facility location; 4. The maximum oil storage or handling capacity of the facility along with the normal daily use of oil; 5. A description of the facility, including topographic maps, facility plot plans, and flow diagrams; 6. A description of the cause of the spill, including a failure analysis; 7. A description of the corrective actions and countermeasures taken by the facility, including a description of any repairs to equipment; 8 A discussion of any additional preventive measures taken or contemplated to reduce the possibility of a recurrence; and 9. Any additional information that the Regional Administrator may require 3.5 Erosion and Sediment Controls Sediment is controlled by perimeter ditches and roads that prevent escape of materials due to stormwater. Vegetation acts to buffer adjacent lands due to established setbacks. Where barren outslopes exist, they are stabilized with vegetation, mulch, or other traditional soil conservation methods or structures including hay bales or other appropriate methods. If necessary, the upper portion of outslopes will be burned or cut to divert upland overland flow away from the out slope, limiting the influences of direct precipitation. The primary erosion concern is gully and rail erosion on outslope areas, and the transportation or detachment of material from exposed ground originating on internal portions of the facilities. Where road services are compacted treatment of those areas will not be necessary due to the low level of detachment over these locations. Sediment laden waters flowing over roads will be directed back to internal portions of the facilities or onto vegetated buffers or waterways. The roads are relatively flat and do not support a significant water shed. Final stability of each facility is secured subsequent to extraction operations as part of reclamation. The majority of the excavation causes stormwater to drain internally. Reclaimed grades are established at appropriate slopes and will be revegetated to predominantly native vegetation. 3.6 Waste, Garbage, and Floatable Debris Raptor minimizes the discharge of waste, garbage, and floatable able debris by keeping the areas around dumpsters and the loading/unloading areas free of such materials. 4 Universal Stormwater Management Plan May 4, 2023 3.7 Dust Generation and Vehicle Tracking of Industrial Materials Generation of dust and off -site tracking of raw, final, or waste materials is minimized via the stormwater control measures discussed above and through effective implementation of facility air control permits. 3.8 Management of Runoff Raptor diverts, infiltrates, reuses, contains, or otherwise reduces stormwater runoff, to minimize pollutants in discharges. 3.9 Salt Storage Piles or Piles Containing Salt Designated salt storage areas are not present at the facilities. If these activities are planned in the future, further evaluation of the areas and procedures will be evaluated in accordance with this SWMP. 3.10 Process Waste Water (Extractive Facilities Only) Process waste water from washing trucks, mixers, etc., are discharged in accordance with CDPHE requirements or are recycled. 3.11 Employee Training Employee training is conducted at least annually and addresses the following: • Site -specific control measures used to achieve the effluent limits, • Components and goals of the SWMP, • Monitoring and inspection procedures, and • Other applicable requirements of the General Permits. At a minimum, the following individuals are trained: • Employees overseeing implementation of, revising, and amending the SWMP. • Employees performing installation, inspection, maintenance, and repair of control measures. • Employees who work in areas of industrial activity subject to the General Permits. • Employee(s) who conduct stormwater discharge monitoring. An Employee Training Log (Appendix C) will be completed to document employee training topics and attendees. Completed forms are stored with the SWMP. 3.12 Non-Stormwater Discharges 3A2.1 Unauthorized Non-Stormwater Discharges Raptor has eliminated non-stormwater discharges not authorized by the General Permits. Raptor has completed documentation of the stormwater conveyance system evaluation for the presence of non- stormwater discharges not authorized by the General Permits. This documentation includes: • The date of any evaluation; • A description of the evaluation criteria used; • A list of the outfalls or onsite drainage points that were directly observed during the evaluation; • The different types of non-stormwater discharge(s) and source locations; and • The action(s) taken, such as a list of control measures used to eliminate unauthorized discharge(s), if any were identified. 5 Universal Stormwater Management Plan May 4, 2023 For facilities producing ready -mix concrete, concrete block, brick, or similar products, the documentation/certification includes a description of measures that ensure that process waste waters resulting from washing trucks, mixers, transport buckets, forms, or other equipment are discharged in accordance with CDPHE requirements or are recycled. This documentation is maintained onsite with the SWMP. 6 Universal Stormwater Management Plan May 4, 2023 4.0 Inspection Procedures and Documentation 4.1 Quarterly Visual Inspections Raptor conducts and documents visual inspections of the facilities at least quarterly (i.e., once each calendar quarter), at least 20 days apart. A minimum of one inspection per calendar year is conducted during a runoff event, which for a rain event means during, or within 24 hours after the end of, a measurable storm event; and for a snowmelt event, means at a time when a measurable discharge occurs The inspections are conducted by qualified personnel. 4.1.1 Inspection Scope Each inspection includes: • Observations made at stormwater sampling locations and areas where stormwater associated with industrial activity is discharged off site; or discharged to waters of the state, or to a storm sewer system that drains to waters of the state. • Observations for the presence of: o floating materials, o visible oil sheen, o discoloration, o turbidity, o odor, o etc. in the stormwater discharge(s). • Observations of the condition of and around stormwater outfalls, including flow dissipation measures to prevent scouring. • Observations for the presence of illicit discharges or other non -permitted discharges such as domestic wastewater, noncontact cooling water, or process wastewater (including leachate). • A verification that the descriptions of potential pollutant sources required under this permit are accurate. • A verification that the site map in the SWMP reflects current conditions. • An assessment of all control measures used to comply with the effluent limits contained in this permit, noting all of the following: o Effectiveness of control measures inspected. o Locations of control measures that need maintenance or repair. o Reason maintenance or repair is needed and a schedule for maintenance or repair. o Locations where additional or different control measures are needed and the rationale for t he additional or different control measures. 4.1.2 Inspection Documentation Raptor documents the findings for each inspection on a Visual Inspection Checklist located in Appendix D. Completed records are also kept onsite with the SWMP. Each inspection report documents the observations, verifications, and assessments required above, and additionally includes: • The inspection date and time; • Locations inspected; 1 Universal Stormwater Management Plan May 4, 2023 • Weather information and a description of any discharges occurring at the time of the inspection; • A statement that, in the judgment of 1) the person conducting the site inspection, and 2) the responsible corporate officer or duly authorized representative, the site is either in compliance or o ut of compliance with the terms and conditions of the General Permits; • A summary report and a schedule of implementation of the corrective actions that Raptor has taken or plans to take if the site inspection indicates that the site is out of compliance; • Name, title, and signature of the person conducting site inspection; and the following statement: o "I certify that this report is true, accurate, and complete, to the best of my knowledge and belief 77, • Certification and signature of the responsible corporate officer or duly authorized representative, o r a duly authorized representative of Raptor. 4.1.3 Non -Compliance Discoveries Any corrective action required as a result of a facility inspection is performed consistent with the Corrective Actions of the Permit (see Section 6.0) and retained with the SWMP. 2 Universal Stormwater Management Plan May 4, 2023 5.0 General Monitoring Requirements The General Permits includes five types of required stormwater monitoring, one or more of which may apply to the discharge authorized by the General Permits, as identified in the General Permits certification for Raptor. The types of monitoring include: • Visual Monitoring o Requirements identified in Section 5.1. • Benchmark Monitoring o The General Permit identifies concrete batch plants (P1C, P1N, P2, and P4) having benchmarks that apply to discharges associated with their industrial activity. o No other benchmark parameters are listed forthe remaining facilities. • Effluent Limitations Guidelines (ELG) Monitoring o No parameters listed for the facilities, ELG Monitoring is not applicable for Raptor. • Water Quality Standards Monitoring o The Division did not identify water quality standards in the Permit certification issued to Raptor. o Raptor does not discharge to impaired waters, to waters designated as critical habitat for threatened and endangered species, or discharge as necessary to determine if compliance with the other terms and conditions of the General Permits meet water quality standards. • Additional Monitoring Required by the Division (e.g., Whole Effluent Toxicity [WET] testing) o No additional monitoring requirements were provided from the Division. 5.1 Visual Monitoring/Assessment For the entire General Permit term, once each quarter, Raptor collects a stormwater sample from each facility outfall and conducts a visual assessment of the sample. The sample is collected in such a manner that the sample is representative of the stormwater discharge. Raptor conducts all required monitoring from storm events that results in an actual discharge from the facility ("measurable storm event"), and that follows the preceding measurable storm event by at least 72 hours (3 days). Raptor must conduct snowmelt monitoring at a time when a measurable discharge occurs from the facility. The visual assessment sample is collected in a clean, clear glass, or plastic container, and examined in a well -lit area. Raptor takes a minimum of one grab sample from a discharge resulting from a measurable storm event. Grab samples are collected within the first 30 minutes of a measurable storm event, and if it is not possible to collect the sample within the first 30 minutes of a measurable storm event, the sample is collected as soon as practicable after the first 30 minutes, and documentation is kept with the SWMP explaining why it was not possible to take samples within the first 30 minutes. In the case of snowmelt, samples are taken during a period with a measurable discharge. All discharge samples at the Raptor facilities are taken during the same storm event, if feasible. Raptor visually inspects the sample forthe presence of the following water quality characteristics: • Color; • Odor; • Clarity; • Floating solids; • Settled solids; 1 Universal Stormwater Management Plan May 4, 2023 • Suspended solids; • Foam; • Oil sheen; and • Other obvious indicators of stormwater pollution. Quarterly Visual Assessment Documentation Raptor documents the visual assessment results on the Quarterly Visual Monitoring Form in Appendix D and maintains this documentation onsite with the SWMP. Raptor is not required to submit visual assessment findings to the Division, unless specifically requested to do so. At a minimum, visual assessment documentation includes: • Sample location(s); • Sample collection date and time, and visual assessment date and time for each sample; • Personnel collecting the sample and performing visual assessment, and their signatures; • Nature of the discharge (i.e., runoff or snowmelt); • Results of observations of the stormwater discharge; • Probable sources of any observed stormwater contamination; and • If applicable, why it was not possible to take samples within the first 30 minutes. Storm event documentation includes: • For each monitored rain event. o The date, time of the start of the discharge, time of sampling, duration (in hours) of the rainfall event, and magnitude (in inches) of the storm event sampled; o The duration between the storm event sampled and the end of the most recent storm event that produced a discharge. • For each monitored snowmelt event. o The date of the sampling event. 5.1.2 Quarterly Visual Assessment Corrective Actions If the visual assessment indicates the control measures for a facility are inadequate or are not being properly operated and maintained, Raptor will conduct corrective actions consistent with Section 6.0. 5.2 Monitoring Periods Quarterly monitoring will be conducted at least once in each of the following 3 -month intervals: • January 1 -March 31; • April 1 -June 30; • July 1 -September 30; and • October 1 -December 31. 5.3 Benchmark Monitoring (Concrete Batch Plants Only) The General Permit (No. COG500000) provides pollutant benchmark concentrations that are applicable for concrete batch plants to the discharge authorized by the General Permit. The benchmark concentrations are not effluent limitations; a benchmark exceedance, therefore, is not a General Permit violation. When the discharge exceeds an applicable benchmark concentration, Raptor will conduct 2 Universal Stormwater Management Plan May4, 2023 corrective actions consistent with Section 6.0. Failure to respond to benchmark value exceedances is a violation of the permit. Benchmark samples are be conducted quarterly, for the first 4 full quarters of General Permit coverage. Samples are collected per the Section 5.1 above. For ready -mixed concrete (SIC 3273) facilities, the following benchmarks apply: Parameter Benchmark Monitoring Concentration TSS 100 mg/L Total Iron 1.0 mg/L After collecting 4 benchmark samples, if the average of the monitoring values for any parameter, at a specific outfall, does not exceed the benchmark, Raptor may reduce benchmark monitoring frequency for that parameter to once -per -year, rotating through the quarterly monitoring periods. DMR reporting requirements are provided in Section 7.1. If the averaged monitoring values for any parameter, at a specific outfall, exceeds the benchmark, as described below, Raptor will conduct corrective action in accordance with Section 6.0. • The average of the initial 4 quarterly sample monitoring values for any parameter exceeds the benchmark. • If less than 4 benchmark samples have been taken, but the sum of the quarterly sample results to date is more than 4 times the benchmark level (i.e., an exceedance of the 4 -quarter average is mathematically certain ), this is considered a benchmark exceedance. • If any of the annual samples taken after the first 4 quarterly samples (i.e., samples 5 through 8), when averaged with the proceeding samples, causes an average monitoring value that exceeds the benchmark for any parameter, this is considered a benchmark exceedance. Following control measure(s) modification, Raptor will continue quarterly monitoring for 4 additional quarters. For this monitoring: • If the average of the monitoring values for any parameter does not exceed the benchmark, Raptor will monitor once -per -year. • If the average of the monitoring values for any parameter still exceeds the benchmark (or if an exceedance of the benchmark by the 4 -quarter average is mathematically certain prior to conducting the full 4 additional quarters of monitoring), Raptor will again conduct corrective actions consistent with Section 6.0 unless the Division waives the requirement for additional monitoring and corrective action. 3 Universal Stormwater Management Plan May 4, 2023 6.0 Corrective Actions 6.1 Conditions that Must Be Eliminated If any of the following conditions occur at a facility, Raptor will review and revise the selection, design, installation, and implementation of the facility control measures to ensure that the condition is eliminated and will not be repeated in the future: • An unauthorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not authorized by the General Permits occurs; • A discharge violates a numeric effluent limit; • Facility control measures are not stringent enough for the discharge to meet applicable water quality standards; • Modifications to the facility control measures are necessary to meet the practice -based effluent limits in the General Permits; or • Raptor finds in a facility inspection, that facility control measures are not properly selected, designed, installed, operated, or maintained. 6.2 Conditions that Require Review and Modification If any of the following conditions occur, Raptor will review the selection, design, installation, and implementation of facility control measures to determine the appropriate modifications necessary to attain the effluent limits in the General Permits: • Construction or a change in design, operation, or maintenance at a facility significantly changes the nature of pollutants discharged in stormwater from the facility, or significantly increases the quantity of pollutants discharged; or • If a facility is required to complete numerical monitoring (benchmark monitoring), the average of quarterly sampling results exceeds an applicable benchmark. 6.3 Correction Action Reports and Deadlines Raptor will document the discovery of any condition listed above, within 24 hours and 5 days as described below, and will submit the documentation in the Annual Report as required in Section 7.0 and will retain a copy onsite with the SWMP. • 24 -hour documentation requirement: o Within 24 hours of discovery of any condition listed above, the Raptor will document the following information: ■ Identification of the condition triggering the need for corrective action review; ■ Description of the problem identified; and ■ Date the problem was identified. • Five-day documentation requirement: o Within five days of discovery of any condition listed above, Raptor will document the following information: ■ Summary of corrective action taken or to be taken (or, for triggering events where Raptor determines that corrective action is not necessary, the basis for this determination); ■ Notice of whether SWMP modifications are required as a result of this discovery or corrective action; 1 Universal Stormwater Management Plan May 4, 2023 ■ Date corrective action initiated; and ■ Date corrective action completed or expected to be completed. A Corrective Action Summary Sheet is provided in Appendix F. Completed sheets are maintained in with the SWMP. 6.4 Control Measure Modification Modification of any control measure as part of the corrective action must be performed consistent with General Permits identified Control Measures. 2 Universal Stormwater Management Plan May 4, 2023 7.0 Reporting and Recordkeeping 7.1 Discharge Monitoring Reports Raptor will electronically report DMRs by using the EPA's Net-DMR service unless a waiver is granted in compliance with 40 CFR 127. The data must be received no later than the 28th day of the following month (for example, the DMR for the first calendar quarter must be received by the Division by April 28th). If no discharge occurs during the reporting period, "No Discharge" shall be reported. The DMR electronic forms are filled out accurately and completely in accordance with requirements of the General Permit and the DMR instructions on the forms, and they are signed by an authorized person. 7.2 Annual Report Raptor will complete and submit an Annual Report to the Division for the reporting period January 1 through December 31 for each facility. Raptor will submit the Annual Reports in order for it to be received by the Division by: • March 31 of the following year for General Permit No. COR900000. • February 28 of the following year for General Permit No. COR500000. The Annual Reports will include: • Name of permittee, address, phone number • Permit certification number • Facility name and physical address • Contact person name, title, and phone number • Summary of inspection dates • Summary of visual monitoring (for General Permit No. COR900000 only) • Corrective action documentation, and status of any outstanding corrective action(s). Raptor will submit signed copies of the Annual Reports to the Division at the address below, and a copy will be maintained with the SWMP. Attn: Annual Report Colorado Department of Public Health and Environment Water Quality Control Division WQCD- P- B2 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 7.3 SWMP Records Raptor will retain copies of the SWMP, including any modifications made during the term of the General Permits, documentation related to corrective actions taken, all reports and certifications required by the General Permits, monitoring data, and records of all data used to complete the application to be covered by the General Permits, for a period of at least three years from the date that coverage under the General Permits expires or is terminated. 1 Universal Stormwater Management Plan May 4, 2023 8.0 Certifications and Signatures The General Permits require that this SWMP to be signed by a responsible corporate office or their duly authorized representative. This signature requirement also applies to any reports, certifications, or other information prepared as required by the Division. All SWMPs and documents prepared for the Raptor facilities will be signed and certified by a responsible corporate officer or duly authorized representative. Hereby, this SWMP is signed and certified: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." Signature: Printed Name: Title: Date: 1 Appendix A Facility Detail Summaries and Maps Universal SWMP Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Greeley Plant Sand & Gravel Plant, Aggregate Recycling and inactive Ready Mix Land Parcel: P1C/P120 Address: 1200 Greeley, Ash Avenue/ CO 80631 1431 E 16th Steet Certification Number: COG501526 (Acres) The Total Size Of The Facility 104 Outfalls 1 Facility Drainage Stormwater Poudre River, collects adjacent in drainage to the north ditches of the that Facility. discharge to the Cache La Description Activities: Of Industrial The aggregate overburden converted of for asphalt tires, An and a cement followed exterior heated then truck also provided hot containment ASTs connected conveyor the active sale identified water northern added be (500 and where pond via added to for and poly concrete by from -gallon into scrap tank. and crushing system a to materials is customers. fly non diesel and it and AST finishes to provide a the an an as ash, the used metal. -hazardous the Two P1C. and meet and southwestern engineered area -fueled northern and batch that stored resulting water exterior fuel oil from Raw in 1,000 used mixing. customer This leads burner recycling, totes plant supply to in horizontal -gallon) other materials water pits by area the water to two in concrete 500 a is Colorants, inside portions are extraction contractor located a -based an specification. pond -gallon hot also and mixing vertical in supply exterior in (sand hot water secondary the includes a mixture north the diesel boneyard on hopper admixtures, water silos, which building of pond and heater. process areas. for the storage of P120 the filling southern aggregate) are tank is are Water ASTs in stockpiles inside containment The discharged for were approximately of added plant, Two of container. stored in scrap north southwestern supersacks which for secondary heat. being the exterior formerly production, is portion are to of in of equipment, building. are into pumped backfilled mixing the totes, concrete loaded are Hot stored used building, the mined 2015. with of water, pit P120 Dry hopper, may into onto in mixer oil sand used with East and for was the an is Facility Measures Specific Control • Washplant discharges flow to the onsite de -silt pond. Fl Facility Location Map r� Ciship g �_.ton idSr I- S tart . I CyD mitrr ALLA tf. IPS 6. a S Si FACILITY LOCATION F2_Facility Map (Attached) I -4 r-_ Cluverki Wahl law rity r- iut-.nap & _ Tr� flarport CirnMarr tild?rvtarh Aopen a�a z 4 a b re A C T 417 St. I w INN ACTIVE FILL AREA FORMER IRRIGATION WELL ENGINEERED POND WATER SUPPLY (FORMER OFF -SITE BEAT PLANT CLARIFIER DISCHARGE) RECYCLING AREA Q Ofre J atin ACTIVE FILL AREA k•-• STOCKPILES OF CONCRETE, SAND, AND GRAVEL CONCRETE BATCH PLANT .••••/ • I acc, DE -SILTATION POND DEWATERING DITCH MATERIAL STOCKPILES CRUSHING TIRES AND SCRAP EQUIPMENT P117 O 350 700 1,050' NOTES AERIAL IMAGE FROM OOOGLE EARTH PRO 2019. NO ACTIVE OIL AND GAS ON THE SUBJECT PROPERTY_ LEGEND MW® Q SUBJECT PROPERTY BOUNDARY MONITORING WELL HISTORICAL OIL AND GAS SPILL STORMWATER OUTFALL STORMWATER FLOW STORMWATER DISCHARGE PUMPS GREELEY SAND & GRAVEL PLANT, AGGREGATE RECYCLING AND INACTIVE READY MIX PLANT P120/P1C 1200 ASH AVENUE/ 1431 E 16TH STEET GREELEY, CO 80631 Report STORMWATER MANAGEMENT PLAN SITE PLAN Date May 31, 2023 File Name P120P1C Scale AS SHOWN Project No. 108.00664.00023 Figure No. 2 SLR" Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Greeley North Ready Mix Plant Land Parcel: PIN Address: 3600 Greeley, O Street CO 80632 Certification Number Pending Outfalls 1 Facility Drainage Stormwater discharge River. offsite from around through the a pipe plant and is collected ultimately in two to the culverts Cache which La Poudre The Facility Total (Acres) Size Of The 9 Description activities: of industrial is into located The central occupied surrounding for storing crusher. Concrete materials mixing vertical admixtures, building. northwest mixture Colorants, customer facility Two western that the fluid occupied truck facility the building 2,000 provides and portion hopper by southeast stockpiles silos, is hot facility by parking, (sand Heated motor specification. truck -gallon is mixing of discharged which the the which water consists developed by inside are the heat of oil, batch building, and from boundary the a water storing operations added are building are tank. diesel of drums two of to facility. aggregate) the the of off plant. concrete stored into stored the with -bay via -site routine the building. to ASTs building. of aggregate Water in a is building the various a The maintenance With majority mixing propane water secondary 5,000 at in then in for onto oil for totes for northeastern the the mixer totes, Dry truck Truck and supply and lubricants, square and periodic a hopper, added production exception of cement in -fueled facility conveyor truck fluid the sand a may fueling containment. fuel maintenance reservoirs, -foot shop, metal and facility changes. two-thirds recycling followed horizontal where also for for consist and and of the building concrete concrete system container is are the with is fly totes be transported resulting it located unpaved ash, also, hot conducted Totes added using of by finishes A the that hot of located of stored propane water loading water and coolants the paved mixing, outside of remainder leads water a along and concrete to pumped hydraulic building -based mixing. to tank in areas mobile in inside used to two tank meet tank the and raw the the the and is a washer fluid were observed inside the building. Used oil is transferred to totes, which are temporarily stored outside the building before being pumped out and transferred via portable service trucks equipped with 80 -gallon tanks to other Raptor Materials facilities in the area for use in used oil burners. Returned concrete is stockpiled on -site to be crushed and recycled. Facility Measures Specific Control • Trucks water are washed is recaptured. in a designated truck washout area were Fl Facility Location Map re U Jr e\\ Mete:nap th iriako tit (t he C- 4 J7 =Lied = it •'A�1 art- s� yr • ail froth 1 - ,. • See lei: y LAI" I" '. •r „teed: F2_Facility Map (attached) toca'ell - Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Ft. Lupton Ready Mix Plant Land Parcel: P2 Address: 15457 Fort Lupton, HWY 52, CO 80621 Certification Number COR901453 The Facility Total (Acres) Size Of The 2.5 Outfalls 1 Facility Drainage Stormwater northwest surface ditches corner flows of and as the ultimately sheet facility. flow to to The the a stormwater detention South Platte detention area River. discharges area in to the Description activities: of industrial located is trucks The concrete facility sand Concrete materials mixing vertical non building horizontal resulting finishes customer by water One walled site. building production. at with facilities truck used the -hazardous facility for 4,000 Two 80 tank. Subject in is hopper silos, for diesel for -gallon and concrete and concrete mixing. from for the paved unpaved (sand specification. water is mixing hot -gallon vehicle to additional pails No burning developed are AST transport central inside water off Property. used and admixtures, tanks significant areas added Colorants, -site operations inside double fueling used and mixing. mixture aggregate) the tank oil in portion connected surrounding water water used for tanks the used to the with building. north Water -walled on As the is stored fueling truck for at which building. supply storage needed, used oil a of discharged site. are the truck mixing for heaters. 3,200 onto of the to maintenance in diesel In used oil the Dry are the the facility production facility. pails, reservoirs addition, city off parking a Heated during portable square building, conveyor cement hopper, stored building hot for -site AST into water changing consist may water -foot With in in periods to and followed water the a service is is and secondary are operations the and two also 500 other the system then transported heater storing of mixer located batch fly pumped via be -gallon majority totes of oil loading Raptor exception trucks ash, added, added increased in by a truck is that diesel the plant aggregate containment present are stored water outside into double inside of raw leads to equipped on Materail and where to conducted building -fueled the -site of -based the the meet the in the the - on to and two it site hot a Facility Measures Specific Control • A clean water truck is used for dust suppression as needed. Fl Facility Location Map F2 Facility Map (Attached) NOTES 41 CONCRETE TRUCK WASH -OUT MATERIAL STORMWATER DETENTION AREA CONCRETE BATCH PLANT 1 -ea AGRICULTURAL -41 OIL AND GAS CONTRACTOR COUNTY ROAD 12 1/2 4 _ -DIESEL AST f i SAND AND GRAVEL BINS OIL AND GAS CONTRACTOR ,' a r 27 S N 0 100 200 300' AERIAL IMAGE FROM 000GLE EARTH PRO 2018. LEGEND OUTi ALL SUBJECT PROPERTY BOUNDARY STORWMATER OUTFALL STORMWATER FLOW FT. LUPTON READY MIX PLANT - p2 15457 HWY 52 FORT LUPTON, COLORADO Report STORMWATER MANAGEMENT PLAN SITE PLAN Date November 30, 2021 File Name P2 Scale AS SHOWN Project No. 108.00664.00023 Figure No. 2 SLR" Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: North Metro Ready Mix Plant and Aggregate Recycling Land Parcel: P4 Address: 1688 WCR Erie, CO 11 80 516 Certification Number: COR900353 The Facility Total (Acres) Size Of The 69 Outfalls None, discharge to onsite ponds. Facility Drainage Stormwater southeastern ponds. generally portion flows of the to property. two retention There are ponds no in outfalls the central from the and Description Activities: Of Industrial the two is totes, truck The the remainder concrete Subject aggregate asphalt Concrete materials mixing followed aboveground via mixer production supply Three a hot maintenance fluid drums were gallon 1,000 then a facility central building water vertical diesel fueling changes. observed truck double and hopper added may reservoirs -gallon of ASTs Property paved (sand by various occupied and mixing -fueled tank is portion is concrete where also is in silos water -walled are developed storage transported conducted occupied inside and diesel to Two secondary areas sand and be located inside is operations and and lubricants, -based the it provide of horizontal added 350 by unpaved for aggregate) finishes for the diesel AST the surrounding one tanks resulting pumped the the -gallon concrete by inside with periodic building. admixtures, to northwest in containment property. horizontal to fuel building. a ASTs batch at (ASTs) secondary and three and hot mixing. meet the a into for the ASTs 9,500 onto concrete the totes used mixing, recycling water site (4,000, -bay plant. the facility Dry customer heating Used The inside the building silo, Colorants, of of a by square building, for conveyor cement which the of northwestern maintenance With and are the tank truck hot 2,000, containment hydraulic coolants oil outside truck mixture facility process consist is using are southwest water consists -foot the storing added specification. transferred and building. from the the which parking, stored and exception a system is tank. fluid building. building of fly water. and mobile to discharged off building. majority is stockpiles loading 1,000 of two-thirds shop, and ash, mixing in Heated are -site adjacent washer of routine storing that to poly the stored Truck located crusher. stored gallon) In motor with of of raw leads Water water addition, two hopper, building fluid the of water into oil the in to 1,000 of in oil, for for the and in to the a - F2 Facility Map(Attached) Returned crushed with open concrete and tops recycled. containing as well A boneyard as asphalt small amounts is area stockpiled of empty of residual drums, on site used to totes oil), be (some empty poly tanks, tires, and scrap equipment was observed to the north of the building. Facility Specific Control • Cement trucks are cleaned out in a designated area in the Measures central portion of the facility which consists of three concrete wash bays containing water that is recirculated and periodically changed out. Fl Facility Location Map It+ 91am5Ex , 'h ti 4 1=1.O (4) -r, e- tre CE� � I i i) 1 . BROOM} I KID Saint s+ rads AP • N:\Portland\Piojects\Eagle Materials\Project Milestone (Varra Companies)IFigures\Report #51Varra Companies Report #5.dwg r a 0) C s a Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Aggregate Recycling and Water Supply Reservoirs Land Parcel: P10 9, P110, and P112 Address: 12910 Longmont, County CO Rd. 80504 13 Certification Number: COG501828 Outfalls The not onsite have outfalls. ponds are designed to retain water for process use and do Facility Drainage All onsite drainage is directed to the onsite water reservoirs. The Facility Total (Acres) Size Of The 230 Description Activities: Of Industrial located P109 constructed provided (described transported by P110 developed aggregate provided connected utilized by The and currently of scale P112 constructed reservoir Creek, water LLC. Raptor Raptor pipe asphalt - - majority - and for The The The located to for sections is via via being office off facility below). Materials, southeastern as pits. the to process Materials, parcel via for provided in piping a in -site water a of a water north recycling former to water Replenishment water the conducted. trailer. former of is the is The concrete developed connected LLC. supply diversion of water LLC. remainder various developed trucks via north replenishment aggregate reservoir P110. aggregate a and using for size, water to reservoirs Other of batch northwestern The off from water ditch of a as P112. as is off -site a diversion northwestern P110 mobile a pit. a -site uses concrete plants pit. utilized water water an connected The that for source. concrete Replenishment is Water adjacent of concrete crusher. reservoir operated the used supply P110 ditch supply for pod were truck to southeastern The for process ions include the constructed to reservoir batch connected reservoir reservoir reservoir batch reservoirs stockpiling No washout is St. by of utilized reservoir active waterforthe this Vrain plants Raptor water exterior plants is on reservoir area, that that parcel Creek, not on operated recycling to for in concrete Materials, is P110 operated former currently P110 was St. process was storage and Vrain are is are is a Facility Measures Specific Control None Fl Facility Location Map TIY - 1..r c... r a -1 _ U f — hi Lrt ! '1 e 1, A- f I -• L I°»'mil t. Lie i* :I of •!. MR zr 1f V �•• n I' •. T Irt J e+-- r.- Ili 1i' i4- rw} It - • I iNN IAINGIMtN-I j 1 4144114 ale 1 w AIM Ala =abbr. r SUBJECT PROPERTY LOCATION -at 1 st -l. . .a. rwrn irk --s woos- uto P. M f...,..._ 1_ •1,_..... ft y is r7, "'�.,. 13 3 t I a art s?71' � 1 it ;at. mil • 41. 7.4 11� am. 10' i r ;- ,+.• • ANIL _ca I ,. • i ;gam nsns - _I ir I .. Si... s F2 Facility Map (Attached) —+il I" duo _ rt— ii • D. f •, 'a— sf 10 4104 L 4 .L� Drawing path: N:\Portland\Projects\Eagle Materials\Project Milestone (Varra Companies)\Figures\Report #2\Varra Companies Report #2.dwg Drawing path: N:\Portland\Projects\Eagle Materials\Project Milestone (Varra Companies)\Figures\Report #2\Varra Companies Report #2.dwg Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Platteville Sand & Gravel Plant and Water Reservoir Land Parcel: P115 Address: 8490 Platteville, Highway 66 CO 80651 Certification Number: COG500346 Outfalls 2 Facility Drainage Stormwater desiltating discharging Creek. Stormwater series of ditches pond to for an from the in off the to the St. eastern southeastern -site drainage western Vrain portion Creek. portion ditch of portion P115 and of P115 is of then routed this flows to parcel, St.Vrain through to a before a The (Acres) Total Size Of The Facility 299 Description Activities: Of Industrial The northeast portion currently structure supplies. Creek, extraction area. with been extraction The aggregate transported portion routed aggregate which through are after discharged parcel groundwater eastern The mostly is settling of located of through supplied Irrigation the -southwest on P115 leased areas southern areas this of is extraction this via screens backfilled portion various divided truck parcel. to out, predominately portion west are on a from to crusher two water and extraction the easement a located to sizes, to and of and a into of rainwater. Materials settling local is Subject a freshwater filter is with P115 a the wash and then which eastern pole provided processing. dairy to out overburden a for consists grazing the area Property. predominately plant ponds, to barn are series The are fines. an for south located pond a and by was placed used eastern placed recirculation access of of where cattle a area. Excavated The diversion left screens south western agricultural for and materials a in washwater road. storage open extraction on on fines grazing. Former east consists stockpiles. of the a to the portions from of and materials northwestern conveyor are The separate pond land of the from plant, aggregate excavated The irrigation has of and western St. area grazing that active Water, is where Vrain filled other by only fines has are and out run a is additional settling occurs before pumping the water back to the freshwater pond for reuse. Trucks and equipment are fueled onsite via a 4,000 -gallon diesel aboveground storage tank (AST) and a 500 -gallon gasoline AST located southwest of the freshwater pond. The tanks are stored in concrete secondary containment. No significant truck maintenance operations are conducted at the parcel. As needed, portable service trucks are used when changing the oil in trucks and excavating equipment, and to transport used oil off -site to affiliated facilities where it is burned for heat. In addition to the wash plant, structures on the eastern portion of P115 and southwest of the freshwater pond, include an active dry crushing plant, which is similar in operation to the wash plant without the use of water, an inactive dry crushing plant in the process of being dismantled, three residences currently occupied by tenants, and multiple sheds/barns that were formerly associated with agricultural use that are currently used for miscellaneous storage of tires, scrap materials, electrical cable, piping, multiple empty drums, and several partially full drums of grease. An additional occupied residence and scale house are located on the northeastern corner of the eastern portion of P115. A boneyard of used tires, scrap metal, piping, and scrap equipment is located west of the freshwater pond. Facility Specific Control Measures None Fl Facility Location Map Ian it !VW'S Luke fiuuiu• _ 1 • Shah + a.'I tiiiw 11171 r� r'- a; 441'; aaaa 1 _ • -4 CV WHO %— r tale G _i •/ ` ...- . r.! rod F2 Facility Map (Attached) a �I r 21 /r $($4 f' or ,r G�«�m11llal _� J P _.4 r!t ate;._ •r ei f, �/ .• fa - .00 ,sfir • vim , w a 1 _ • ▪ ' a _.aa r f ® • sa• a =w: S S 1 reit et.. - 1. L S Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Greeley Plant Sand & Gravel Plant, Aggregate Recycling and Inactive Ready Mix Land Parcel: P117 Address: 1431 Greeley, E. 16TH CO Ave. 80631 Certification Number: COG500100 The Facility Total (Acres) Size Of The 230 Outfalls 1 Facility Drainage Stormwater Poudre River, collects adjacent in to drainage the ditches north of the that property. discharge to the Cache La Description Industrial Activities: Of to the In include inside tank transferred the Active portion of At a sizes, freshwater fines. of from P120 scale equipment and and equipment containment this crusher the addition a the wash wash fluid drums scale The this (adjacent house, (AST) which plant, the aggregate parcel wash of a changes. this plant and pond plant maintenance house washwater to building. pond maintenance and outside to are plant, are where both located and a the parcel, is totes ASTs fueled and series parcel). without placed south consist extraction a pumped wash located New dry materials fines Used the a at dry and of east with of in the shop/idled building the on screening of The plant oil various of screening screens stockpiles. fines are conducted oil site the to southeast the use is concrete office of operations are excavated dry is an and stored via the plant, stored excavated are lubricants that placed adjacent screening of two to dry and scale plant water. concrete discharged plant separate is in is of inside in batch Water, screening dispatch diesel run a periodically house. are in on after the 500 a located 200 materials the through pond plants and conducted a wash the plant conveyor which batch -gallon ASTs out settling -gallon central to shop coolants activities. on plants, on on aggregate a are plant. in is the the plant pumped transported the de similar consists AST P120. secondary portion supplied out. aboveground and -siltation on screens eastern structures Truck building inside were western Trucks the Overflow routed in Operations of out of and of also eastern various from to portion operation the pond via this routine and and and portion through filter on heavy observed truck building storage parcel. a water west P117 a of at out to oil Facility Control Specific Measures None Fl_Facility Location Map 1�. (ME • • FACILITY LOCATION I -Urn Oran tenneWY F2_Facility Map (Attached) I r II Weld in_u1lyne `-111 unapeI Am pan Ori&fF/- WeldiCounty _ .tftt°u is Wit. J . _ _ G rE.EY • • r r 4.. DE -SILTATION POND • f r r METAL SALVAGE YARD DRY SCREENING T *M i t' r` .i • . r e r `iva drr I, S. . . r r . j r F C' • WASH PLANT FRESH WATER POND "SWF 1- 41 • r I. USED OIL AST SHOP AND IDLED CONCRETE BATCH PLANT (VARIOUS OIL AST AND DRUMS) SF SCALE HOUSE DRY SCREENING AND CRUSHING FORMER EXTRACTION SCRAP EQUIPMENT FUELING AREA AND DIESEL FUEL ASTs ACTIVE EXTRACTION ACTIVE AND G EXTRA 0 350 700 1,050' NOTES AERIAL IMAGE FROM NO ACTIVE OIL AND G00GLE GAS ON EARTH PRO 2019. THE SUBJECT PROPERTY LEGEND MW® SUBJECT PROPERTY BOUNDARY MONITORING WELL RAPTOR MATERIALS - P117 1431 EAST 16TH AVENUE GREELY, COLORADO Report SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN FACILITY SITE PLAN Date May 30, 2023 File Name Varra Companies Report #3 Scale AS SHOWN Project No. 118.00664.00025 Figure No. 2 SLR" Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Greeley Ready Mix Sand Plant & Gravel Plant, Aggregate Recycling and Inactive Land Parcel: P121 Address: Northeast Greeley, Corner of CO 80631 Fern Ave. and E 16th St., Certification COG50158 3 Outfalls 1 Facility Drainage that Due approximately conducted to leads shallow to using the groundwater 10 feet), pumps Cache dewatering that La Poudre beneath discharge River. of the the to parcel extraction an adjacent (depth area ditch of is The (Acres) Total Size Of The Facility 10 0 Description Activities: Of Industrial transported The active portion central aggregate of P121 and via is southern extraction. truck currently to P117 portions an Excavated for inactive processing. of P121 materials extraction are The currently northern are pit. used for Facility Specific Control Measures None Fl Facility Location Map MAa • tn? 'I IJ FACILITY LOCATION lu • -I fr r F2 Facility Map (Attached) S -a • emr "IV CI tit .' INC it ,ISO -spa ui I�,_ 4 N:Portland IProjects\Eagle Materials\Raptor\Audit Corrective ActionlUniversal SWMP1Figures\P120P1C.dwg CFI Y SCREENING D CRUSHING keep,' FORMER EXTRACTION ACTIVE EXTRACTION INACTIVE EXTRACTION PIT ACTIVE SAND AND GRAVEL EXTRACTION ' f • P121 l OUTFALL M Ws DEWATERING DITCH M Wa i I I I I I - fit rairwrittrit: • y� w C-4 = I • lel' true ,t 4.17 It 0 400 800 1,200' NOTES 1 AERIAL IMAGE FROM GOOOLE EARTH PRO 2019. LEGEND S M We • OUTFALL SUBJECT PROPERTY BOUNDARY MONITORING WELL HISTORICAL OIL AND GAS SPILL STORMWATER OUTFALL RAPTOR MATERIALS - P121 1431 EAST 16TH AVENUE GREELY, COLORADO Report STORMWATER MANAGEMENT PLAN SITE PLAN Date May 31, 2023 File Name P120P1C Scale AS SHOWN Project No. 118.00664.00025 Figure No. 2 SLR" Universal SWMP — Facility Detail Raptor Materials LLC has been developed a Universal Stormwater Management Plan (SWMP). This attached provides additional facility specific details for the facility identified below. The attached Figure 1 shows the location of the facility in relation to surface waters that receive industrial stormwater discharges from the facility. Figure 2 provides the facility boundary, process, storage, and stormwater details. Facility/Operations Name: Platteville Sand & Gravel Plant and Water Reservoir Land Parcel: P122 Address: Intersection of Weld County Road (WCR) 17 and WCR 28 Certification Number: COG501584 The Facility Total (Acres) Size Of The 150 Outfalls 2 Facility Drainage the The portion. structures Creek pit facility area The is is ditch traveling fairly sloped flat transects from inward slightly the the towards south sloped western and to ditches, ditch continuing portion and the of creek remaining facility N -NW in western in vicinity to St portion Vrain of of Description Activities: of Industrial the The extraction. approximately using of of for P122. P122. the corn south western pumps ponds. The crops. side Due portion that ponds 10 The of to Irrigation feet), the shallow discharge eastern of are crop P122 dewatering periodically water fields, groundwater portion to is is currently two provided which of of ponds the pumped P122 also beneath used extraction on is by the leased receives into a for diversion the northwestern active a area drainage to parcel stormwater a aggregate is local ditch (depth conducted ditch farmer portion along from of west Facility Measures Specific Control • Dewatering settling pond. ditches throughout pit area are pumped to a Fl Facility Location Map • • a� • 1 I rA•rIgl• t *attar za ,►-"-� •1 • Last L*.IU'1 JI nit id11. H - f rs'( ar ' �Ir 1 ableirAIFI 1/4 i I urN se •^ e • r'V_ A jtrattnalkii Y~� era % u' M FACILTY LOCATION aa• 1 I �1 Il rrr 4 _.. ...sr_ tfrir _ ..“- _,.... et- Ilit- ____....,. taT _ 1 T 41 eltl.siH(Y`IN ltyoU l 11111111 r' I- 1 ! r 11 a • '1 5 I Crinitldp WWI f rarni- I 1 Nall* F2 Facility Map (Attached) a_ fi ill rrtr, kit Lirfirsi.... ti r`11 \V +► n� - V '1 AIlls if i Q Y a 1 t`1 •a1 Appendix B Spill Log and Five Day Report Form Spill and Leak Log Record below all spills and leaks that have occurred at the Facility: Date Spill (S/ Leak P) or Location Description Response Procedure Preventative Measures Taken Type of Material Amount Recovered (gallons) Material of Exposed Stormwater (YIN) to Appendix C Employee Training Log Employee Training Log Date of Training: Training Topics: Attendees: Appendix D Inspection Forms Industrial Stormwater Permit Quarterly Visual Monitoring Form Visual Monitoring (One Sample per Form) Year: Quarter (circle one): 1 2 3 4 Date: Visual monitoring outfall (or must be conducted once each quarter for the entire permit term. The permittee must collect a storm water sample from each a substantially identical outfall) and conduct a visual assessment of each sample. Required Documentation: Personnel and assessment: performing collecting the visual sample Print Title: Provide Name: Signature: Sample location: Sample collection date and time: Visual time: assessment date and Nature runoff of or the snowmelt): discharge (i.e., Results stormwater of observations discharge: of the Probable observed contamination: sources stormwater of any If possible the applicable, first to 30 take minutes: why it was samples not within The visual assessment must be made of a sample in a clean, clear glass, or plastic container, and examined in a well -lit area. The permittee must visually inspect the sample for the presence of the following water quality characteristics, and document the visual assessment results: * Color * Odor * Clarity * Floating Solids * Settled Solids * Suspended Solids * Foam * Oil sheen * Other stormwater obvious indicators pollution of Required Documentation Regarding Corrective Action: If permittee ****Use that the has visual or the must monitoring Corrective conduct indicates corrective Action the Summary control actions. Sheet measures to are provide inadequate a summary or are and schedule not being of implementation properly operated of and any maintained, corrective action(s) the will be taken based on this visual monitoring. Industrial Stormwater Permit Visual Inspection Checklist Visual Inspections (One Inspection per Form) Year: Quarter (circle one): 1 2 3 4 Date: Visual inspections must be conducted quarterly and 20 days apart. One inspection per year must be conducted during a runoff event. Statement of Certification: 1 Name certify of that this report Person conducting is true, accurate, site inspection and (Print): complete, to the best of my knowledge and belief Title: Signature: Name of Permittee or Authorized Representative (Print): Title: Signature: Required Documentation: Inspection date and time: Weather information: Locations inspected: inspection: Description occurring at of the any discharges time of the Inspection Scope: Observations sampling stormwater activity of that the drains state, is locations discharged associated or to made to waters and a storm at off of stormwater areas with -site; the sewer where industrial to state. waters system Observations materials, turbidity, discharge(s). visible odor, for etc. the oil sheen, in presence the discoloration, stormwater of floating Observations around flow scouring. dissipation stormwater of the condition outfalls, measures including to of prevent and Inspection Scope (continued): Observations discharges discharges noncontact wastewater or such cooling (including for other the as domestic non water, presence leachate). -permitted wastewater, or of process illicit Are pollutant permit the descriptions are sources accurate? required of potential under this Yes No . If no, explain: Does current the site conditions? map in the SWMP reflect Yes No . If no, explain: An used contained following: assessment to comply in this of with all permit, control the effluent noting measures all limits of the Effectiveness inspected. of control measures Locations need of maintenance control measures or repair. that Reason needed maintenance maintenance and a schedule or repair. or repair for is Locations different needed additional measures and where control or the different additional measures rationale control for or are the Required Documentation Regarding Corrective Action: Is Inspection compliance of the this site permit, in Scope? compliance with with the respect terms or and out to the of conditions In Compliance:__ Out of Compliance: . If out of compliance, explain: ****Use that has the or will Corrective Action Summary Sheet to provide a summary and schedule of implementation of any corrective action(s) be taken based on this visual monitoring. Appendix E Annual Report Forms COLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado COG500000 Annual Report Form Sand and Gravel Mining and Processing Applicable to Stormwater-only discharges FOR INTERNAL USE ONLY Reviewer: Further Review: Yes No Part A: General Facility Permit Permit Certification Identification Number: Number COG500000 COG50 Part (Check B: one. Reporting Report due Period by Jan February 1 through 28 of the Dec following 31 year.) 2021 2022 2023 2024 Part C: Organization: Mailing Permittee Address: Information City: State: Zip: Part Facility Facility Facility D: Facility Name: Address: Contact Information City: Name: Title: Address: No: Telephone Email Part Check E: the Permittee-conducted box for which inspection Inspections frequency applies to the permitted facility, Part I.J.: Active Site - 4 inspections annually (Quarterly) Inactive Site w/ inspections annually No Exposure - (Spring/Fall) 2 Inactive Site w/ Exposure - 6 inspections annually (Every 2 months) Provide the date(s) the inspections were conducted, as required by Part I.J of the permit: If an inspection(s) was not conducted in accordance with the required frequency, attach an explanation of why. 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Part F: Required Monitoring (Indicate if the following monitoring is required at the YES NO permitted required monitoring.) facility. Refer to the facility's permit certification for information on - Visual observed, Monitoring attach (Part a summary) 1.1.1) (If any of the characteristics in Part 1.1.1.b are - Benchmark Monitoring (Part 1.1.2) - Water Quality Standards Monitoring (Part 1.1.3) - Additional Monitoring Required by Division (Part 1.1.4) Part G: Corrective Actions (Indicate whether any of the following conditions YES NO occurred at the permitted facility.) - An non-stormwater unauthorized release not authorized or discharge under observed (e.g., COG 500000 or spilt, another leak, discharge permit); of - Facility applicable control water measures quality are standards; not stringent enough for the discharge to meet - Modifications to the facility control measures are necessary to meet the practice - based effluent limits in this permit; - The not permittee properly selected, finds in a facility designed, inspection, installed, that operated facility or control maintained. measures are - Construction significantly facility, or significantly or changes a change the in nature increases design, of the operation, pollutants quantity discharged or of maintenance pollutants in stormwater discharged; at the facility from the - The average of quarterly sampling results as described in Part I.I.2.e of this permit exceeds an applicable benchmark. If criterion the answer /criteria to any of and describe the above the is "YES," corrective provide action a description (s) taken (attach of the conditions additional pages that met as needed): the Part "I in submitted. for complete. fine certify accordance gathering and H: Required under imprisonment I Based am the with penalty information, aware on Certification a system my that for of inquiry law knowing there that designed the Signature this of the information are violations." to significant document person assure or [Reg submitted that penalties 61.4(1)(h)] and qualified persons all attachments who is for to personnel manage the submitting best the were of properly system, my false prepared knowledge information, gather or those under and and persons including my direction evaluate belief, directly true, the the or supervision information responsible accurate possibility and of Name: Title: Signature: Date signed: TEMPORARY COVID19 SUBMISSION, digitally signed documents may be emaited to: cdphe.wqrecordscenter@state.co.us 11/2021 COLORADO Department of Public Health & Environment COR9O0000 Annual Report Form Stormwater Discharges Associated with Non -Extractive Industrial Activity FOR INTERNAL USE ONLY Reviewer: Further Review: Yes No Part A: Permit Identification General Permit Number: COR900000 Facility Certification Number COR90 Part B: Reporting Period Jan 1 through Dec 31 (Check one. Report is due by March 31 of the following year.) 2019 Part C: Permittee Information Organization: Mailing Address: 2020 2021 2022 City: State: Zip: Part D: Facility Information Facility Name: Facility Address: City: Facility Contact Name: Title: Telephone No: Email Address: Part E: Permittee-conducted Inspection Dates (Provide the date the inspection was conducted for each quarter, as required by Part I.G of the permit). Jan - Mar: July - Sept: Apr - June: Oct - Dec: Note: If an inspection was not conducted during any quarter(s) please attach an explaination of why. Page 1 of 2 4300 Cherry Creek Drive S, Denver, CO 80246-1530 P 303-692-3500 www.colorado.gov/cdphe Jared Polis, Governor Jill Hunsaker Ryan, MPH, Executive Director Part permitted required F: Required facility. monitoring.) Monitoring Refer to the (Indicate facility's if the permit following certification monitoring for information is required at on the YES NO - Visual Monitoring (Part 1.1.1) - Benchmark Monitoring (Part 1.1.2) - Effluent Limitations Guidelines (ELG) Monitoring (Part 1.1.3) - Water Quality Standards Monitoring (Part 1.1.4) Part occurred G: Corrective at the permitted Actions (Indicate facility.) whether any of the following conditions YES NO - An non-stormwater unauthorized release not authorized or discharge under observed COR900000 (e.g., or spill, another leak, permit); discharge of - A discharge violates a numeric effluent limit; - Facility applicable control water measures quality are standards; not stringent enough for the discharge to meet - Modifications based effluent to limits the facility in this control permit; measures are necessary to meet the practice - - The not permittee properly selected, finds in a facility designed, inspection, installed, operated that facility or control maintained. measures are - Construction significantly facility, or significantly changes or a change the increases in nature design, of the operation, pollutants quantity or discharged of maintenance pollutants in stormwater discharged; at the facility from the - The permit average exceeds of quarterly an applicable sampling benchmark. results as described in Part I.I.2.e of this If criterion/criteria the answer to any and of describe the above the is "YES," corrective provide action(s) a description taken (attach of the conditions additional pages that as met needed): the Part "I in submitted. for complete. fine certify accordance gathering and H: Required under imprisonment Based I am the with penalty aware information, on Certification a system my that for of inquiry law knowing there designed that the of are information Signature this the violations." significant document to person assure or [Reg submitted that penalties and persons 61.4(1)(h)] qualified all attachments who is for to personnel manage submitting the best the were of properly system, my false prepared knowledge information, gather or those under and and my persons including direction evaluate belief, directly true, the the or information responsible accurate possibility supervision and of Name: Title: Signature: Date signed: Revised 10/2019 Page 2 of 2 Appendix F Corrective Action Summary Sheet Corrective Action Summary Sheet Within 24 hours of a corrective action discovery Raptor will document the following information: Condition action triggering review: the need for corrective Description of the problem identified: Date the problem was identified: Within five (5) days of a corrective action discovery, Raptor will document the following information: Summary (or, for for this triggering determination) of corrective events action where taken McLane or to determines be taken: that corrective action is not necessary, the basis Notice action: of whether SWMP modifications are required as a result of this discovery or corrective Date corrective action initiated: Date to corrective be completed: action completed or expected COLO R A D o Water Quality Control Division Department of Public Health Er Environment Five day reporting form Incident / spill I sanitary sewer overflow release Use this form to report incidents impacting waters of the state The Water Quality Control Division distinguishes between reporting requirements for incidents that occur at entities operating under a Colorado Discharge Permit System (CDPS) permit and those resulting from non -permitted activities. Permitted activities - Reporting and management of non-compliance incidents and spills that occur as a result of permitted activities should be performed in accordance with the specific requirements in the notifications section of your permit. You may use this form to submit the information requested in the permit. Non -permitted activities - In the case of an activity where a permit does not address reporting of, or response to, a given spill please submit a written summary of the event, your response, and clean up efforts to the division within five working days of the date of the event. This form is provided for your convenience. If you have any questions please contact the division's field services staff person assigned to your spill case. Prior to the five working day deadline you may request an extension to submit the report if needed for sampling analysis or other reasons. To request an extension please send an email to the division's field services staff person assigned to your spill case or to the spill administrator. The field services contact list is available at: www.colorado.gov/ cdphe/ wq-inspect ion-services-cont act -us. Please send the completed form or report with signature to the division's field services spill administrator: Michelle Thiebaud 222 S. Sixth Street, 232 Grand Junction, Co 81501 Telephone: 970-248-7150 Fax: 970-248-7198 Email: michelle.thiebaud@state.co.us a©state. co. us 1. Incident background information Incident/ (division spill provided) number Date event of County Type of incident / spi l l / SSO (check one) Sanitary sewer overflow Potable water/ reuse water/ Biosolids reclaimed water Wastewater treatment plant bypass or Petroleum product Oil or gas field production spill upset (authorized outfall point) Wastewater treatment plant spi l l or Chemical Other overflow (other than outfall) Estimated volume released Size and depth of area affected Contact information Potentially responsible party contact name Potentially responsible party company/ agency name CDPHE Permit number and facility name (if applicable) Email address Phone as Incident information: Please provide the following information. A. Describe incident including source, cause, and location (e.g. address, latitude/ longitude). B. Material Data Sheets released, for any e.g. and untreated all chemicals wastewater, or products specific in spill chemical or release. or product, biosolids. Please attach the OSHA Material Safety C. Actual and time or estimated the release duration is expected of the to event be stopped. and time spill was fully controlled/ stopped. If release is still occurring, the date D. Describe measures taken or planned to contain, reduce, and clean up spill or release. E. Describe steps taken or planned to prevent reoccurrence. 3. Incident Examples intermittent impact of state or to ephemeral state waters include: waters gulches, (As stormwater ditches, defined in ponds, § 25-8-103(19), conveyances lakes, (when C.R.S.). discharge irrigation to canals, surface wetlands water), and perennial groundwater. streams, they reservoirs, A. Did What flow quantity or materials of material reach surface reached the water surface of the state? waters and If so, what identify was the the water resulting body impact? or bodies and describe the path of flow. B. Did If yes, flow what or materials quantity reach of material groundwater reached of the the state? ground or If so, identify groundwater the and water what body was the or bodies resulting and impact? describe the path of flow. C. Did the incident include any of the following? If so, please include additional details below. Chemical release Fish kill Sheen on water D. Were relationship any water to the quality incident, samples i.e. or up/down other samples stream taken? and attach If so, results. please describe sampling process, sampling location(s) in 4. Incident impact to areas or water users A. Describe and swim the beaches potential or impact public water of the incident/spill/SSO system sources and irrigation to public diversions. use areas or downstream water users. This includes parks B. Were posted, the impacted via phone. area users and downstream water users notified and describe the method of notification, e.g. signs C. List any downstream users who were notified. I hereby certify that the information above is accurate and complete. presented Signature Name and title Company, organization Date Revised November 2017 PAI 1 BACKFILL NOTICE Exhibit-eBackfill Notice Inert fill may be imported, or utilized from existing on -site sources, to meet or exceed planned post extraction land use development potentials over the project area during the life of the operation. The extent and location of fill will be field determined. All i nert materials used for backfilling will be consistent with DRMS Rules and Regulations, and those of the Colorado Department of Health and Environment. All backfill material will be placed with sufficient fines to minimize voids and settling of backfilled areas and slopes. There are no known or expected acid forming or toxic producing materials or refuse at this location, nor will materials known to possess such qualities be knowingly utilized for fill. Any other refuse or reject materials that do not meet the definition of inert and requiring removal and disposal will be placed in closed containers and taken to an appropriate landfill for disposal, unle ss it is otherwise 'inert,' per Rule 3.1.5(9),of the DRMS Rules and Regulations. All materials, whether extracted on -site or imported, will be handled in such a manner so as to prevent any unauthorized release of pollutants to surface or ground water resources. All fill will be integrated to meet or exceed the reclamation plan and correlated end us es authorized under the approved Colorado Division of Reclamation, Mining and Safety permit. All fill above the anticipated static water level of the resulting basins will be soiled and stabilized according to the approved reclamation plan, or as otherwise allowed according to this application or locally approved land uses. The location and extent of fill utilized over extracted lands will be designated in required DRMS Annual Reports, permit revision, or as part of any request for release of the permitted area, in part or whole. These representations are authorized as is or otherwise modified under the signed original approved DRMS permit, until or unless subsequently modified by an approved DRMS Technical Revision. Raptor Materials, LLC Kurtz Sand, Gravel, and Reservoir Project October 2025 A Regular Impact (112) Construction Permit -A ores .StoiDivision of Reclamation Mining and Safety,Office of Mined Land 6c:2t #e i o; °: Ca .AWES, LLC Fort Collins, Colorado, USA October 15, 2025 Mr. Garrett Varra Raptor Materials, LLC 8120 Gage Street Frederick, Colorado 80516 RE: Kurtz Lined Pit Analysis Weld County, Colorado AWES No. 2025-RM-P115 Dear Garrett: You have inquired as to the influence that lining the Kurtz pit may have on the local groundwater hydrology. As you are aware I performed a shadow/mounding analysis in May 2019, for the Kurtz pit as a lined reservoir. My comments on this issue are provided below. I used a numerical model to predict changes in the groundwater hydrology that might occur by lining the Kurtz pit. The issue of shadow and mounding has been raised by DRMS for most lined reservoirs. Lining the reservoir will result in groundwater mounding on the upgradient side of the pit and a depression (shadow) on the downgradient of the pit. I have attached two model simulations, one being a calibration model with no mining influences and the second simulation with the Kurtz mine with lined pits. The simulations depict groundwater being diverted around the lined reservoir. Mass balance graphs indicate less than a one percent reduction in river leakage and an overall mass balance of much less than one percent. A slight decrease in the upstream hydraulic gradient is also observed. In the immediate vicinity of the mine face mounding of approximately 4 feet is predicted, however, at a distance of 1500 feet upstream of the mine face no or very little mounding is predicted. If you have any questions regarding this letter or attachment, please contact me at 970-590-3807. Sincerely, AWES, LLC Joby L. Adams, P.G. Principal Hydrogeologist S 4SC9 Four Star Court, Fort Collins, CC SC524 - 91C-5)C-3SC7 VMOD MODEL OUTPUTS - - O - N - - 71 = _ co O • Nr -- - co _ O - _ �_ N = - - __O _ -- _ 0 \D : AIMS �- O Nr O 4. ‘o - - el I -- NW. O _ • 71- N- -3 - O• . " N - -� 0 2000 4000 6000 8000 10000 11986 Kurtz River Only Calibration Graph Project: Modeller: Raptor Pit115 J Adams AWES, LLC 970-590-3807 O CO -cr Go o an mW-2 ri w 1 - co co O Mu _ = -,1 4 -_ o�Q= cvzt, M -_ 7Y��Q x _ f O - 0 (N - - - ._ I 1 I 0 2000 4000 6000 8000 10000 11986 Kurtz GW River Contours only Project: Modeller: Raptor Pit115 J Adams AWES, LLC 970_590_3807 Time = 1000 1077 4- W E O O) 0 w 0 , , SS IN TOTAL = IN 6.05006E9 RIVER OUT LEAKAGE = 5.883079E9 OUT TOTAL OUT = 6.050187E9 HEAD IN DEP BOUNDS = 5.877445E9 V ... STORAGE CONSTANT HEAD RIVER LEAKAGE HEAD DEP BOUNDS TOTAL IN OUT Flow Summary Kurts River Only Site ._ ton epret:txa .t€ t_ r. P115 al o Aver O y C od�-e-� e -r. earns Raptor P115 Calculated vs. Observed Head : Steady state ct a) 0 a) C6 N U c0 Umcf MW -3 Observed = 4798.54 Calculated = 4798.54 MW -4 Observed = 4788.80 Calculated = 4788.80 MW -1 Observed = 4783.78 Calculated = 4783.78 MW -2 Observed = 4777.66 Calculated = 4777.66 4787.24 Observed Head (ft) Max. Residual: 0.004 (ft) at MW-1/MW-1 Min. Residual: -0.001 (ft) at MW-2/MW-2 Residual Mean : 0 (ft) Abs. Residual Mean : 0.003 (ft) 4797.24 Layer #1 95% confidence interval 95% interval Num. of Data Points : 4 Standard Error of the Estimate : 0.002 (ft) Root Mean Squared : 0.003 (ft) Normalized RMS : 0.014 ( °/0 ) Correlation Coefficient : 1 Kurtz River Only Cal Graph AWES, LLC 970-590-3807 Project: Raptor Pit 115 Modeller: J Adams O - - 1- - 0) 0 • - 1 CO _ - - _ _� -tn - -_ = - - _ _ - - N - N 0 _ • \0 S a y r we O -- • — - - a O • \0 - M _ - = alas MW -3 I , O n — -- -- 1- - N - o • :t N - _=z _ _ _ _ __t a• - - - _ 0 2000 4000 6000 8000 10000 11986 Kurtz Lined Pits Boundary Conditions Project: Modeller: Raptor Pit115 J Adams AWES, LLC 970_590_3807 "' 0 - , ` - -1 -_- - - - moo} CO . _ 4 = co - _- N s 4780. O -_ - - - N - ( - r -- - .- , ■ o CL 1 - �`1W-2 - = _ O W V L - NI M -fig - MW MW -3 - N ,_ - — o- - „--_ o _ ti 0 2000 4000 6000 8000 10000 11986 Kurtz Lake Sim Project: Modeller: Raptor Pit 125 J Adams AWES, LLC 970-590-3807 Time = 1000 1077 4- W E O w cp cd a) w O w 0 N , , TOTAL OUT = 6.070446E9 OUT HEAD IN=5.822147E9 DEP BOUNDS OUT RIVER LEAKAGE = 5.862871E9 IN TOTAL = 6.069328E9 IN aprar STORAGE CONSTANT HEAD RIVER LEAKAGE HEAD DEP BOUNDS LAKE SEEPAGE TOTAL IN OUT Flow Summary Kurts Reservoir Simulation t ��pct��'tor_ 'dhil D Dewater fo4r1jjtIo4erll eer.�s Raptor P123 Calculated vs. Observed Head : Steady state rn o- 1- t -a v -a cD U co 0) co 0 c i i MW -3 Observed = 4798.54 Calculated = 4802.54 7 7 7 MW -4 Observed = 4788.80 Calculated = 4789.03 , , MW -1 Observed = 4783.78 Calculated = 4783.90 MW -2 Observed = 4777.66 Calculated = 4777.45 Max. Residual: 4 (ft) at MW-3/MW-3 Min. Residual: 0.117 (ft) at MW-1/MW-1 Residual Mean : 1.033 (ft) Abs. Residual Mean : 1.14 (ft) 4786.94 Observed Head (ft) 4796.94 • Layer #1 95% confidence interval 95% interval Num. of Data Points : 4 Standard Error of the Estimate : 0.993 (ft) Root Mean Squared : 2.007 (ft) Normalized RMS : 9.611 ( % ) Correlation Coefficient : 0.997 Kurtz Lake Sim Calibration Graph AWES, LLC 970-590-3807 Project: Raptor Pit 115 Modeller: J Adams COLORADO c,. *;:,:,,c/ ** Department of Public fn6 Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado CERTIFICATION DISCHARGE UNDER TO CDPS GENERAL PERMIT COG500000 DISCHARGES ASSOCIATED WITH SAND Et GRAVEL MINING AND PROCESSING (and other Nonmetallic Minerals except fuel) Certification Number: COG500346 This Certification to Discharge specifically authorizes: to Raptor Materials LLC to discharge from the facility identified as Platteville Sand and Gravel Plant and Water Reservoir P115 to an Unnamed Tributary to the Saint Vrain Creek and St Vrain Creek Faci lit y Located at: 8490 Hwy 66, Platteville, Weld County, CO 80601 Center Point Latitude 40.1214, Longitude -104.5557 Outfall Defined (s) { ) Water Discharge to Surface Outfall( Lat, Long Lon s) Discharge Outfall ( ) (s) Description Receiving Stream MGD Outfall 001-A Number -104.897767 40.19359, Process water stormwater and commingled discharge g Tributary Saint Unnamed Vrain to Creek the 2.75 Outfall Number 40.196775, Process water and commingled g Tributary Unnamed to the 2.75 002-A -104.895179 stormwater discharge Saint Vrain Creek Outfall Number 40.200396, Process water and commingled Tributary . Unnamed to the 2.75 003-A -104.895141 stormwater discharge Saint Vrain Creek Outfall 004-A Number -104.905991 40.203095, Process water and commingled stormwater discharge Saint Vrain Creek 2.75 Outfall Number 40.198888, Process water and commingled 005-A -104.905991 stormwater discharge water storage from surface pond Saint Vrain Creek 2.75 All discharges must comply with the lawful requirements of federal agencies, municipalities, counties, drainage districts and other local agencies regarding any discharges to storm drain systems, conveyances, or other water courses under their jurisdiction. Permit Limitations and Monitoring Requirements apply to outfall(s) 001A, 002A, 003A, 004A, 005A as outlined in the Permit in Parts I.C.1, I. D, and I.E. Crushed Stone and Construction Sand and Gravel Facilities (SIC Codes 1442) Permitted Feature ID: 001A, 002A, 003A, 004A, and 005A Permitted Feature External Outfall Type: Limit Set: 2 Discharge Limitations Maximum Concentrations Monitoring Sample Parameter Units Frequency q y 30 -Day Average 7 -Day Average Dail y Max. 2 Year Average Type Flow, 50050 MGD 2.75 NA Report p NA Continuous1 Recorder1 pH, (Minimum - Maximum) s.u. NA NA 6.5-9.0 NA 2x/month Grab 00400 4300 Cherry Creek Drive S., Denver, CO 80246-1530 Page 1 of P 2 303-692-2000 www.colorado.gov/cdphe/wqcd 4,1/4 CDP'HE co y Total Suspended Solids, 00530 mg/1 30 45 NA NA 2x/month Grab Oil 84066 and Grease Visual NA NA NA NA 2x/month Visual2 Oil and 03582 Grease, m /l g NA NA 10 NA Contingent2 g Grab Site Specific Limitations Total 515001 Outfalls and 003A Flow3, 001A, Only 002A, MG Qrtr Report Total NA NA NA Continuous) Calculated Electrical Conductivity 00094 (EC), dS/m Report NA NA NA Quarterly Grab Manganese, Dissolved, Outfalls and 003A 01056 001A, Only 002A, ug/l l g Report p NA Report p NA 2x/ month Grab 1: Flow - The chronic flow limit is equal to the flow rate provided in the permit application, and will be stated on the certification. If power is not available, flow may be measured on an instantaneous basis. 2: Oil and Grease: - A visual observation of the discharge for each permitted outfall must be made 2 times per month. In the event an oil sheen or floating oil is observed, a grab sample shall be collected, analyzed, and reported on the DMR. In addition, corrective action shall be taken immediately to mitigate the discharge of oil. 3: Total Flow - Total flow is the cumulative flow of the discharge for the quarter in million gallons. If continuous flow monitoring is not conducted, the permittee must calculate the total flow for the month or quarter using the 30 -day average flow (measured) and the number of days the facility discharged within the month or quarter. Modified, Reissued, Effective 8/22/2022 Modification 2 transfers permit from Varra Companies Inc to Raptor Materials LLC and update the name of the facility to Platteville Sand and Gravel Plant and Water Reservoir P115 Modified, Reissued, Effective 3/20/2018 Modification 1 changes facility name to Varra Resource Development Project 115 Originally issued: 12/19/2016 Effective: 1/1/2017 The general permit COG500000 expired 12/31/2021 and is administratively continued. This certification is also administratively continued. It will remain in effect until the general permit is renewed or other actions are taken. This certification under the permit requires that specific actions be performed at designated times. The certification holder is legally obligated to comply with all terms and conditions of the permit. Certification approved by Kathleen Rosow Permits Unit 3 Work Group Lead Water Quality Control Division Page 2 of 2 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe/wqcd 4 July 8, 2025 COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Garrett C. Varra Raptor Materials, LLC. 8120 Gage Street Frederick, CO 80516 RE: Financial Warranty Increase, Revision No. SI-4, Kurtz Resource Recovery Land Development Project, Permit No. M-1999-006 Dear Mr. Varra, On July 8, 2025, the Division of Reclamation, Mining and Safety (Division/DRMS) increased the current Financial Warranty for the Kurtz Resource Recovery Land Development Project (M-1999-006) to $2,571,871.00, in accordance with Rule 4.2.1 of the Mineral Rules and Regulations for the Extraction of Construction Materials. This is an increase of $2,140,871.00 from the currently held amount of $431,000.00. The surety increase is based on your financial warranty cost estimate provided to the Division on July 2, 2025. The bond amount will be reevaluated during the upcoming amendment process and may be increased or reduced once the amendment is approved. The Division ordered amendment of the current Financial Warranty, or submittal of a new Financial Warranty reflecting the increase, is due within sixty (60) days from the date of this letter, September 6, 2025. Failure to post the additional required Financial Warranty within sixty (60) days may result in the Division pursuing enforcement actions. Please make arrangements with Sara Stevenson-Benn at the Division's Denver office for submittal of the financial warranty. Any other questions regarding completion, execution and/or submittal of financial warranty forms should also be directed to Sara at sara.stevenson-benn@state.co.us. If you need additional information or have any questions, please contact me by email at patrick.lennberg@state.co.us. Sincerely, 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 https://drms.colorado.gov/ Jared Polls, Governor I Dan Gibbs, Executive Director I Michael A. Cunningham, Director SI-4 M-1999-006 Page 2 of 2 Patrick Lennberg Environmental Protection Specialist Enclosures: Operator's Financial Warranty Cost Estimate CERTIFIED MAIL NO. 9589 0710 5270 0298 0368 94 Return Receipt Requested cc: Jared Ebert, DRMS Sara Stevenson-Benn, DRMS ec: Garrett Varra, Raptor Materials, LLC, gvarra@raptormaterialsllc.com COST SUMMARY WORK Task description Site: 2025 Financial Warranty Update M1999-006 - Kurtz Sand, Gravel and Reservoir Project (P115) Permit Action: 2025 Financial Warranty Update Task Description Form Used Fleet Size Task Hours Cost 2 691 $426,422 Ola Tract A: Dewater Pond - initial pumping PUMPING Olb Tract A: Dewater Pond - continual pumping PUMPING 1 126 $12,367 Ol Tract A: Grade slope under liner DOZER 2 79 $54,070 Old Tract A: Rip source material for liner DOZER 2 15 $10,639 Ole Tract A: Haul liner and backfill material from Tract A source TRUCK 3 258 $131,906 Ali Tract A: Mix material for liner DOZER 2 50 $33,881 pig Tract A: Compact liner COMPACT 1 66 $16,762 2 274 $211,774 02a Tract B: Push sand stockpile into pit DOZER 02b Tract B: Haul backfill materials from Tract A source to pit and pond TRUCK 4 260 $162,485 03a Tract C: Haul backfill material from Tract A source to Pond TRUCK 6 679 $584,644 04a Tract D: Haul backfill material from Tract A source TRUCK 5 24 $17,674 05a Haul topsoil to all disturbed areas TRUCK 3 176 $111,190 05b Seed all disturbed areas REVEGE - - $313, 006 06a Demo and remove concrete and conveyor DEMOLISH - - $324,612 1 2 $11,154 07a Mobilization and Demob. MOBILIZE SUBTOTALS: 1415 $1,983,797.43 INDIRECT COSTS OVERHEAD AND PROFIT: Liability insurance: 2.02 Performance bond: 1.05 I Job superintendent: 7 07.7 5 Profit: 10.00 i _ Total = $40;073 Total = $20,830 $79.27 Total = Total = TOTALO&P= CONTRACT AMOUNT (direct + O & P)= $56,103 $198,380 $315,386 $2,299,183 LEGAL - ENGINEERING - PROJECT MANAGEMENT: Financial warranty Engineering work Reclamation CONTINGENCY: 500.00 4.25 5.00 3.00 Total = Total = Total = TOTAL INDIRECT COST = TOTAL, BOND AMOUNT (direct + indirect) = Yellow cells are where data is input Green cells is the data output with the completed formula $500 $97715 $114,959 $59,514 $588,074 $2,571,871 7:7 III - AWES, LLC e• Fort Collins, Colorado, USA October 28, 2024 Mr. Garrett Varra Raptor Materials, LLC Frederick, Colorado RE: Dewatering Estimates Raptor Pit 125 Weld County, Colorado Dear Garrett: As requested I have generated estimated dewatering pumping rates for cells A, B and C at the proposed Pit 125. As you are aware the numerical model Visual ModFlow was used to estimate the effects of dewatering. I used this model to estimate groundwater pumping rates as well. I ran model simulations without any other dewatering influences (no influence simulations) for each cell and then ran simulations with the surrounding mines (Kurtz and two southern mines) being dewatered. Without any other dewatering influences the flow rates for cells A, B and C were 2.5 million gallons per day (mgd), 2.17 mgd and 2.89 mgd, respectively. Simulations with surrounding mine dewatering predicted pumping rates of 0.17 mgd, 0.56 mgd and 2.17 mgd for cells A, B and C, respectively. I assumed in the no influence model runs that dewatering was not occurring in adjacent cells. The simulations without any other dewatering influences represent the maximum predicted extraction volumes. A second method of estimating flow rates is to use the one dimensional unconfined flow equation as presented by McWhorter and Sunada 1977, as presented below. Where: Q=K/2L(H02-HL2) Q= pumping rate (1-0/day/ft) 1< = hydraulic conductivity (ft/day) L = distance to no influence (ft) HL= head at seepage face Ho= head at no influence. I estimated the average K values of the sand and gravel deposits at 200 feet per day. The distance to no influence is a function of time and was estimated by solutions presented by Bear 1979, as presented below. AM' iS 4SC9 Four Star Court, Fort Collins, CO 8524 — g7C-5gC-387 Dewatering Estimates Pit 125 Weld County, Colorado Page 2 R(t) = 1.9(Tt/ne)1/2 Where: R(t) = Radius of influence as a function of time (ft.) T = transmissivity (5000 ft2/day) t = time (100 days) ne = effective porosity 0.27 (dimensionless) Using the above values a distance to no influence of 2586 feet was calculated. Using analytical methods the predicted pumping rates were 1.76 mgd, 2.66 mgd and 1.93 mgd for cells A, B and C respectively. Obviously the analytical method used does not account for adjacent water features, which accounts for the discrepancies in model predicted values and analytical predicted values. The no dewatering influence simulations in VMOD represent the maximum predicted withdraw rates. Adding the other dewatering influences dramatically reduces the predicted pumping rates in cells A and B. If you have any questions regarding this letter, please contact me at 970-590-3807. Sincerely, AWES, LLC Joby L. Adams, P.G., REM Principal Hydrogeologist it_AAWES 4SC) Four Star Court' Fort Collins' CC SC524 — 47C-59C-3SC7 COST SUMMARY WORK Task description Site: 2025 Financial Warranty Update M1999-006 - Kurtz Sand, Gravel and Reservoir Project (P115) Permit Action: 2025 Financial Warranty Update Task Description Form Used Fleet Size Task Hours Cost PUMPING 2 691 $426,422 Ola Tract A: Dewater Pond - initial pumping 01b Tract A: Dewater Pond - continual pumping PUMPING 1 126 $12,367 inc Tract A: Grade slope under liner DOZER 2 79 $54,070 Old Tract A: Rip source material for liner DOZER 2 15 $10,639 Ole Tract A: Haul liner and backfill material from Tract A source TRUCK 3 258 $131,906 Olf Tract A: Mix material for liner DOZER 2 50 $33,881 Tract A: Compact liner COMPACT 1 66 $16,762 DOZER 2 274 $211,774 02a Tract B: Push sand stockpile into pit 02b Tract B: Haul backfill materials from Tract A source to pit and pond TRUCK 4 260 $162,485 03a Tract C: Haul backfill material from Tract A source to Pond TRUCK 6 679 $584,644 TRUCK 5 24 $17,674 04a Tract D: Haul backfill material from Tract A source 05a Haul topsoil to all disturbed areas TRUCK 3 176 $111,190 05b Seed all disturbed areas REVEGE - - $313,006 06a Demo and remove concrete and conveyor DEMOLISH - - $324,612 07a Mobilization and Demob. MOBILIZE 1 2 $11,154 SUBTOTALS: 1415 $1,983,797.43 INDIRECT COSTS OVERHEAD AND PROFIT: Liability insurance: 2.02 Performance bond: 1.05 Job superintendent: 707.75 Profit: 10.00 $79.27 Total = $40,073 Total = $20,830 Total = $56,103 Total = $198,380 TOTALO&P= $315,386 CONTRACT AMOUNT (direct + O & P)= 2,299,183 LEGAL - ENGINEERING - PROJECT MANAGEMENT: Financial warranty Engineering work Reclamation CONTINGENCY: 500.00 4.25 5.00 3.00 Total = Total = Total = TOTAL INDIRECT COST = TOTAL BOND AMOUNT (direct + indirect) = Yellow cells are where data is input Green cells is the data output with the completed formula Cells in red indicate cells that were not necessary for completion of the cost estimate $500 $97715 $114,959 $59,514 $588,074 $2,571,871 Return to Summary Task description: Site: Dewater Tract A pit - initial pumping Kurtz Sand, Gravel and Permit Action: Reservoir Project PROJECT IDENTIFICATION Task #: 01A Date: 6/23/2025 User: JEL Agency or organization name: DRMS HOURLY EQUIPMENT COST State: County: 2025 Financial Warranty Update Colorado Weld Description Quantity Make and Model: Submersible pump - 460v, 8 in. 8 Attachment 1: Suction hose - 6 in. diam., 25 ft. 8 Attachment 2: Discharge hose - 6 in. D., 25 ft. 8 Labor Unit 1: Pump operator 2 Horsepower: Shift Basis: Weight: Cost Breakdown: 95 1 per day 0.70 (US Tons) Utilization % Ownership Cost/Hour: $49.45 NA Operating Cost/Hour: $20.60 100 Operator Cost/Hour: $28.23 NA Total Unit Cost/Hour: $70.05 per pump Total Fleet Cost/Hour: $616.86 plus two operators PUMPING QUANTITIES Initial Pond Volume: Final Pond Volume: Total Pond Inflow Surface Area: Total Pond Inflow Volume per Hour: 1,013,540,070 1,013,540,070 gallons 0 Sq.ft. 0.00 gallons Permit/Job#: M1999006 Tract A Pond at Static GW Elevation (4793') [yd3]: Tract A Pond at Static GW Elevation (4793') [gal]: Conversion factor: 1.0000 Unit inflow rate in gph/sq. ft.: Source of estimated volume: Volume extraction from June 2024 Propeller Surface 0.0000 5,018,171 1,013,540,070 PUMPING TIME Maximum Pump Capacity: 170,000 gph/pump Estimated Suction Head: 0 feet Estimated Discharge Head: 15 feet Total Head: 15 feet CPB Pump Capacity: 168,000 gph/pump Site Altitude: 4,800 feet Adjusted Pumping Capacity: 1,344,000 gph Initial Unadjusted Pumping 754.12 hours Inflow during Initial Pumping: 0 gallons Net Unadjusted Pumping Time: 754.12 Hours Altitude Adjustment Factor: 1.0000 (3% rule) Pump Efficiency Factor: 0.9167 (55 min./hr.) Total Adjusted Pumping Time: 691.28 hours JOB TIME AND COST Unit cost: $0.000421 /Gallon Total job time: Total job cost: 691.28 $426,422 Hours Return to Summary Task description: Site: Dewater Tract A pit - continual pumping Kurtz Sand, Gravel and Permit Action: Reservoir Project PROJECT IDENTIFICATION Task #: O1B Date: 6/23/2025 User: JEL Agency or organization name: DRMS HOURLY EQUIPMENT COST State: County: 2025 Financial Warranty Update Colorado Weld Description Quantity Make and Model: Submersible pump - 460v, 8 in. 1 Attachment 1: Suction hose - 6 in. diam., 25 ft. 1 Attachment 2: Discharge hose - 6 in. D., 25 ft. 1 Labor Unit 1: Pump operator 1 Horsepower: Shift Basis: Weight: Cost Breakdown: 95 1 per day 0.70 (US Tons) Utilization % Ownership Cost/Hour: $49.45 NA Operating Cost/Hour: $20.60 100 Operator Cost/Hour: $28.23 NA Total Unit Cost/Hour: $70.05 per pump Total Fleet Cost/Hour: $98.28 plus one operator PUMPING QUANTITIES Initial Pond Volume: Final Pond Volume: Total Pond Inflow Surface Area: Total Pond Inflow Volume per Hour: Source of estimated volume: 23,062,846 23,062,846 gallons Permit/Job#: M1999006 Location P125 Pit B P115 Tract A Inflow (mgd)* 2.17 3.89 Pond/Pit perimeter 5,963 10,680 Avg pond perimeter Pctg of Tot Inflow exposed (ft) (gal) 5,290 2,535 88.71 23.74 Inflow over 25 days 48,127,201 23, 062, 846 Inflow (gal/hr) 80,212 38,438 *Inflow rate calculated proportionately based on dewatering estimate at adjacent cell P125 Pit B, estimated in the AWES P125 Dewatering Memo (10/28/2024) . Conversion factor: 1.0000 0 Sq. ft. Unit inflow rate in 0.0000 gph/sq. ft.: 0.00 gallons AWES Dewatering Memo inflow rate. P115 Pond A inflow rate proportional to average length of exposed pond perimeter. Assumes no dewatering in adjacent cells. PUMPING TIME Maximum Pump Capacity: 170,000 gph/pump Estimated Suction Head: 0 feet Estimated Discharge Head: 15 feet Total Head: 15 feet CPB Pump Capacity: 168,000 gph/pump Site Altitude: 4,800 feet Adjusted Pumping Capacity: 168,000 gph Initial Unadjusted Pumping 137.28 hours Inflow during Initial Pumping: 0 gallons Net Unadjusted Pumping Time: 137.28 Hours Altitude Adjustment Factor: 1.0000 (3% rule) Pump Efficiency Factor: 0.9167 (55 min./hr.) Total Adjusted Pumping Time: 125.84 hours JOB TIME AND COST Unit cost: $0.000536 /Gallon Total job time: Total job cost: 12.5.84 $12,367 Hours Total Dewatering Cost: 438,789.55 Return to Summary BULLDOZER WORK Task description: Grade slope under liner Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 01C Agency or organization name: DRMS M S HOURLY EQUIPMENT COST Basic Machine: Cat D8T - 8SU Horsepower: 310 Blade Type: Semi -Universal Attachment: 1 -shank ripper Shift Basis: 1 per day Data Source: (CRG) Cost Breakdown: Utilization % Ownership Cost/Hour: $173.32 NA Operating Cost/Hour: $109.71 100 Ripper Cost/Hour: own. $14.53 NA Ripper op. Cost/Hour: $3.98 50 Operator Cost/Hour: $40.04 NA Total unit Cost/Hour: $341.58 Total Fleet Cost/Hour: $683.16 MATERIAL QUANTITIES Initial Volume: 110,500 Swell factor: 1.120 Loose volume: 123,760 Source of estimated volume: Propeller Assume walls flight 3:1. 6/11/25. will be regraded to Exterior perimter length Interior perimeter length Linear Feet Length Depth Source of estimated swell factor: Wisconsin DOT CY LCY LF ft ft State: Date: User County: Colorado 6/24/2025 JEL Weld Permit Action: 2025 Financial Warranty Update East wall length (ft): East wall height (ft): West wall length (ft): West wall height (ft): Approx EX Wall Slopes (H:V): East wall vol. to regrade (CY): West wall vol. to regrade (CY): Total vol. to regrade (CY): https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf 1820 40 715 10 5:1 107852 2648 110500 Permit/Job#: M1999006 HOURLY PRODUCTION Average push distance: 50 feet Unadjusted production: hourly 1,400.00 description: Materials consistency Partly consolidated wall slope Average push gradient: 20% Average site altitude: 4,800 Material weight: 2900 lbs/LCY Weight description: Dry sand and gravel Job Condition Correction F actor LCY/hr Source Operator Skill: 0.750 (AVG.) Material consistency: 0.800 (CAT HB) Dozing method: 1.000 (GEN.) Visibility: 1.000 (AVG.) Job efficiency: 0.830 (1 SHIFT/DAY) Spoil pile: 0.900 (SSD-FC) Push gradient: 1.400 (CAT HB) Altitude: 1.000 (CAT HB) Material Weight: 0.890 (CAT HB) Blade type: 1.000 (PAT) Net correction: 0.5585 Adjusted unit production: Adjusted fleet production: 781.84 1563.68 JOB TIME AND COST Fleet size: Unit cost: Total job time: Total job cost: 2 IIla $0.437 79.15 $54,070 LCY/hr LCY/hr Dozer(s) /LCY Hours estimated from CAT HB (June 2022) p. 16-10: Bulldozers - Estimating Production Off -the -Job Return to Summary BULLDOZER RIPPING WORK Task description: Rip liner and backfill material source area in Tract A Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 0lD D State: Date: 7/01/2025 County: User: JEL Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat D8T - 8SU Ripper Attachment: 3 -Shank Ripper Cost Breakdown: Utilization % Ownership Cost/Hour: $173.32 NA Operating Cost/Hour: $109.71 100 Ripper Ownership Cost/Hour: $14.53 NA Ripper Operating Cost/Hour: $7.95 100 Operator Cost/Hour: $40.04 NA Total Unit Cost/Hour: $345.55 Total Fleet Cost/Hour: $691.10 MATERIAL QUANTITIES Alternate Methods: Seismic: Area: NA 19.13 acres Colorado Weld Horsepower: Shift Basis: Data Source: Permit Action: 2025 Financial Warranty Update Permit/Job#: 310 1 per day (CRG) Selected estimating method: Area Bank Volume: NA Rip Depth (ft): 2.56 Exhibit C-2 Source of estimated quantity: See Individual Tract TRUCKcLOADER sheets BCY Volume: NA 78,992 CY M1999006 Total backfill/liner material needed Tract A Tract B Tract C Tract D TOTAL: Available Fill Tract A - existing fill stocks Tract A - liner regrade TOTAL: Fill Required Swell factor: Excavation Fill Required 126,621 LCY 135,844 LCY 317,211 LCY 12,485 LCY 592,161 LCY (excludes sand pile) 395,000 LCY 110,500 LCY 505,500 LCY 86,661 LCY 1 77,376 CY HOURLY PRODUCTION Seismic: Seismic Velocity: NA feet/second Area: Average Ripping Depth: 2.56 feet/pass Average Ripping Width: 7.08 feet/pass Average Ripping Length: 150.00 feet/pass Average Dozer Speed: 88.00 feet/minute Average Maneuver Time: 0.25 minutes/pass Production per unit area: 0.748 acres/hour 3,0911 CY/hr Job Condition Correction Factors Unadjusted Hourly Unit 0.748 CY/hr Production: Site Altitude: 4,680 feet Altitude Adj: 1.00 (CAT HB) Job Efficiency: 0.83 (1 shift/day) Net Correction: 0.83 multiplier Adjusted Hourly Unit 0.621 acres/hour Production: Adjusted Hourly Production: Fleet 1.24 acres/hr JOB TIME AND COST Fleet size: Unit cost: 2 $556.28 Dozers Per acre No of lifts: Total job time: Total job cost: 1 15.39 $10,639 Hours Return to Summary TRUCK/LOADER TEAM WORK Task description: Haul shale/clay to Tract A unlined walls to construct liner Site: Kurtz Sand, Gravel and Reservoir Project Permit Action: PROJECT IDENTIFICATION Task #: 01E E Date: 6/24/2025 User: JEL Agency or organization name: DRMS M S HOURLY EQUIPMENT COST Equipment Description Truck Loader Team -Truck: Generic 12-18 cy, 6x4 -Loader: CAT 966H high lift Support Equipment -Dump -Load Area: Area: NA NA Road Maintenance —Motor Grader: -Water Truck: NA Water Tanker, 3,500 Gal. Cost Breakdown: Truck/Loader Team State: County: Shift basis: 1 per day Support Equipment 2025 Financial Warranty Update Permit/Job#: Colorado Weld Maintenance Equipment M1999006 Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 75 NA NA 25 25 Ownership cost/hour: $27.14 $57.78 NA NA $52.82 $11.65 Operating cost/hour: $62.81 $34.69 NA NA $10.94 $5.61 %Utilization -riper: NA $0.00 NA NA NA NA Ripper own. cost/hour: NA $0.00 NA NA $0.00 $0.00 Ripper op. cost/hour: NA $0.00 NA NA $0.00 $0.00 Operator cost/hour: $24.82 $56.64 NA NA $56.70 $0.00 Unit Subtotals: $114.77 $149.11 NA NA NA $17.26 Number of Units: 3 1 0 0 0 1 Group Subtotals: Work: $493.42 Support: $0.00 Maint: $17.26 Total work team cost/hour: $510.68 MATERIAL QUANTITIES Initial volume: Loose volume: 126,621 126,621 ligla CCY LCY Swell factor: 1.000 Tract A East Wall to be lined (length, ft): Tract A East Wall height (ft): Tract A East Wall slope length (ft): Tract A West Wall to be lined (length, ft): Tract A West Wall height (ft): Tract A West Wall slope length (ft): Total Slope Area to be lined (sq.ft): Liner Depth (ft): Liner Vol (CY): 4'x 4' Keyway Vol (CY): Total Liner Material Vol (CY): Tract A Pond 1 Backfill Vol (CY): Tract A Pond 2 Backfill Vol (CY): Total Ponds Backfill Vol (CY): 1820 40 126 715 10 32 252824 4 37455 1502 38958 75700 11963.4 87664 Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: Propeller flight 6/11/25. Assume walls will be regraded to 3:1. No liner was discussed in the orginal permit documents. A liner depth of 4 ft with a 4'x4' keyway from the P125 site (in process of permitting) was used. Wisconsin DOT - avg of clay (1.3) and shale https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf (1.025) HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: Description: Rated Payload: Payload Capacity: Truck Bed (volume) Basis: 2,450 Clay and Shale 50,300 20.53 7 Pounds/LCY Pounds LCY Struck Volume: Heaped Volume: Average Volume: Adjusted Volume: 12.00 LCY 18.00 LCY 15.00 LCY 18.00 Loading Tool Capacity Final Truck Volume Based on Number of Loader Passes: LCY 15.75 LCY Bucket Size Class NA Rated Capacity: 5.000 LCY (heaped) Bucket Fill Factor: 1.050 Other - moist loam (100-110%) 1.050 Adjusted Capacity: 5.250 LCY I Job Condition Corrections: Site Altitude (ft.): 4,800 Truck Loader Source Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: Selected Value within this Basic Rating: Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA NA Maneuver: Number of LoadingTool Passes Required to Fill Truck: 3 passes Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): Dump: 0.500 0.100 Cycle Time Factors Factor (min.) Source Material: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Stockpile: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Truck Ownership: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Operation: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Dump Target: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: 0.000 minutes Adjusted Loader Cycle Time: 0.500 minutes Net Load Time per Truck: 1.100 minutes Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 1.100 Minutes Truck Maneuver and Dump Time: 0.90 Minutes 1240 Haul Route: minutes Material Destir Haul Dist (ft) Haul Dist weighted by Hauled Vol (ft) Liner Pond 1 Pond 2 1240 382 836 500 2672 252 Total weighted haul dist (ft): 1134 Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 1.100 Minutes Adjusted for site altitude: 0.900 Minutes Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (min) Time 1 1238.00 0.00 3.00 3.00 1460 0.848 Haul Time: 0.848 minutes Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (mm) 1 1238.00 0.00 3.00 3.00 1604 0.772 Return Time: 0.772 Total Truck Cycle Time: 4.120 minutes minutes Loading Tool unit Production 590.63 LCY/Hour Truck Unit Production 229.39 LCY/Hour Optimal No. of Trucks: 2.6 Truck(s) JOB TIME AND COST Fleet size: Unit cost: 1 $1.042 Adjusted hourly truck team production: Adjusted single truck/loader team production: Adjusted multiple truck/loader team production Team(s) /LCY Adjusted for job efficiency: 490.22 LCY/Hour Adjusted for job efficiency: 190.39 LCY/Hour Selected Number of Trucks: 3.0 Truck(s) 490.22 490.22 490.22 Total job time: Total job cost: LCY/Hour LCY/Hour LCY/Hour 258.30 $131,906 Hours Return to Summary BULLDOZER WORK Task description: Mix material for liner Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 01F State: Colorado Date: 6/24/2025 User JEL Agency or organization name: DRMS M S HOURLY EQUIPMENT COST Basic Machine: Cat D8T - 8SU Horsepower: 310 Blade Type: Semi -Universal Attachment: 3 -shank ripper Shift Basis: 1 per day Data Source: (CRG) Cost Breakdown: Utilization % Ownership Cost/Hour: $173.32 NA Operating Cost/Hour: $109.71 100 Ripper Cost/Hour: own. $14.53 NA Ripper op. Cost/Hour: $0.00 0 Operator Cost/Hour: $40.04 NA Total unit Cost/Hour: $337.60 Total Fleet Cost/Hour: $675.20 MATERIAL QUANTITIES Initial Volume: 63,311 Swell factor: 1.163 Loose volume: 73,.599 Source of estimated volume: Assumed liner material half volume (Task of 02B) Area Depth Source of estimated swell factor: Wisconsin clay (1.3) (1.025) DOT - shale avg of and CY LCY ac ft Permit Action: 2025 Financial Warranty Update Permit/Job#: M1999006 County Weld https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf HOURLY PRODUCTION Average push distance: 50 Unadjusted production: hourly 1,400.00 Materials description: consistency Clay and Shale Average push gradient: 0% Average site altitude: 4,800 Material weight: 2,450 lbs/LCY Weight description: Avg of clay and shale Job Condition Correction F actor LCY/hr Source Operator Skill: 0.750 Material consistency: 1.100 (AVG.) Dozing method: 1.000 (CAT 1-1B) Visibility: 1.000 (GEN.) Job efficiency: 0.830 (AVG.) Spoil pile: 0.900 (1 SHIFT/DAY) Push gradient: 1.000 (SSD-FC) Altitude: 1.000 (CAT HB) Material Weight: 0.850 (CAT HB) Blade type: 1.000 (CAT HB) Net correction: 0.5238 (PAT) Adjusted unit production: Adjusted fleet production: 733.37 1466.73 JOB TIME AND COST Fleet size: Unit cost: Total job time: Total job cost: 2 $0.460 50.18 $33,881 LCY/hr LCY/hr Dozers /LCY Hours Return to Summary COMPACTION WORK Task description: Compact liner Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 01G Date: 6/24/2025 User: JEL Agency or organization name: State: County: DRMS HOURLY EQUIPMENT COST Basic Machine: CAT 815F Compactor Type: Cost Breakdown: Soil - tamping foot Colorado Weld Horsepower: Shift Basis: Data Source: Utilization % Ownership Cost/Hour: $107.16 NA Operating Cost/Hour: $117.19 100 Operator Cost/Hour: $31.50 NA Total Unit Cost/Hour: $255.85 Total Fleet Cost/Hour: $255.85 MATERIAL QUANTITIES Loose volume: Compacted volume: Source of estimated volume: Source of estimated shrinkage factor: 126,621 115,225 HOURLY PRODUCTION LCY CCY Same as hauled quantity (Task 01B) Cat Handbook Compacted width per pass (W): 6.50 feet Average Compactor Speed (S): 8.00 mph Compacted thickness of each lift (L): 10.00 inches Conversion Constant (C): 16.3 (5,280ft./12in./ 27cu.ft.) Required number of machine passes (P): 4 passes Unadjusted Hourly Unit Production: 2,119.00 CCY/hour Site Altitude: 240 1 per day (CRG) Shrinkage factor: 4,800 ft Permit Action: 2025 Financial Warranty Update 0.910 Permit/Job#: M1999006 Job Condition Correction Factors Source Altitude Adj: 1.00 (CAT HB) Job Efficiency: 0.83 (1 shift/day) Net Correction: 0.8300 multiplier Adjusted Hourly Unit Production: 1,758.77 CCY/Hour Adjusted Hourly Fleet Production: 1,758.77 CCY/Hour JOB TIME AND COST Fleet size: Unit cost: 1 $ 0.145 Total job time: Total job cost: Compactor(s) per CCY 65.51 $16,762 Return to Summary BULLDOZER WORK Task description: Tract B: Push sand pile into adjacent pit Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 02A State: Colorado Date: 6/24/2025 User JEL Agency or organization name: DRMS HOURLY EQUIPMENT COST Basic Machine: Cat MOT OT Horsepower: 310 Blade Type: Semi -Universal Attachment: 2 -shank ripper Shift Basis: 1 per day Data Source: (CRG) Cost Breakdown: Utilization % Ownership Cost/Hour: $174.79 NA Operating Cost/Hour: $136.68 100 Ripper Cost/Hour: own. $22'93 NA Ripper op. Cost/Hour: $12.04 5 Operator Cost/Hour: $40.04 NA Total unit Cost/Hour: $386.48 Total Fleet Cost/Hour: $772.97 MATERIAL QUANTITIES Initial Volume: 202,613 Swell factor: 1.000 Loose volume: 202,613 Source of estimated volume: Propeller measurement (6/11/25 volume flight) Source of estimated swell factor: Wisconsin DOT CY CY Permit Action: 2025 Financial Warranty Update Permit/Job#: M1999006 County Weld https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf Sand Pile Vol (LCY): Receiving Pit Capacity (CY): 202,613 332,224 HOURLY PRODUCTION Average push distance: 500 Unadjusted production: hourly 400 Materials description: consistency Sand stockpile Average push gradient: 12% Average site altitude: 4,800 Material weight: 2,600 lbs/LCY Weight description: Sand Job Condition Correction F actor LCY/hr Source Operator Skill: 0.750 (AVG.) Material consistency: 1.200 (CAT HB) Dozing method: 1.100 (GEN.) Visibility: 1.000 (AVG.) Job efficiency: 0.830 (1 SHIFT/DAY) Spoil pile: 0.900 (SSD-FC) Push gradient: 1.250 (CAT HB) Altitude: 1.000 (CAT HB) Material Weight: 1.000 (CAT HB) Blade type: 1.000 (PAT) Net correction: 0.9244 Adjusted unit production: Adjusted fleet production: 369.77 739.53 JOB TIME AND COST Fleet size: Unit cost: Total job time: Total job cost: 2 $1.045 273.98 $211,774 LCY/hr LCY/hr Dozer(s) /LCY Hours Ref Cat HB-49, 19-55 Return to Summary TRUCK/LOADER TEAM WORK Task description: Haul backfill material to Tract B pit and pond Site: Kurtz Sand, Gravel and Reservoir Project Permit Action: PROJECT IDENTIFICATION Task #: 02B Date: 7/02/2025 User: JEL Agency or organization name: DRMS M S State: County: HOURLY EQUIPMENT COST Shift basis: 1 per day Equipment Description Truck Loader Team -Truck: Generic 12-18 cy, 6x4 -Loader: CAT 966H high lift Support Equipment -Load NA -Dump Area: Area: NA Road Maintenance —Motor NA Grader: -Water Truck: Water Tanker, 3,500 Gal. Cost Breakdown: Truck/Loader Team Support Equipment 2025 Financial Warranty Update Permit/Job#: M1999006 Colorado Weld Maintenance Equipment Tract B Pond to be Backfilled [CY]: Tract B Remaining Pit to be Backfilled [CY]: 6,233 129,611 Vol to fill Tract B pit not filled by sand pile and pond [yd3]: 135,844 Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 75 NA NA NA 25 Ownership cost/hour: $27.14 $57.78 NA NA $52.82 $11.65 Operating cost/hour: $62.81 $34.69 NA NA $10.94 $5.61 %Utilization -riper: NA $0.00 NA NA NA NA Ripper own. cost/hour: NA $0.00 NA NA $0.00 $0.00 Ripper op. cost/hour: NA $0.00 NA NA $0.00 $0.00 Operator cost/hour: $24.82 $56.64 NA NA $56.70 $0.00 Unit Subtotals: $114.77 $149.11 NA NA NA $17.26 Number of Units: 4 1 0 0 0 1 Group Subtotals: Work: $608.19 Support: $0.00 Maint: $17.26 Total work team cost/hour: $625.45 MATERIAL QUANTITIES Initial volume: Loose volume: Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: 135,844 135,844 Propeller volume measurement (6/11/25 flight) Wisconsin DOT 80.00 S0.0() HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: Description: Rated Payload: Payload Capacity: Truck Bed (volume) Basis: 2,900 Dry sand and gravel 50,300 17.34 CY LCY Pounds/LCY Pounds LCY Swell factor: 1.000 https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf Struck Volume: 12.00 LCY Heaped Volume: 18.00 LCY Average Volume: 15.00 LCY Adjusted Volume: 18.00 LCY Loading Tool Capacity Final Truck Volume Based on Number of 15.75 LCY Bucket Size Class NA Rated Capacity: 5.000 LCY (heaped) I Bucket Fill Factor: 1.050 Other - moist loam (100-110%) 1.050 Adjusted Capacity: 5.250 LCY I Job Condition Corrections: Site Altitude (ft.): 4680 Loader Source Truck Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Number of Loading Tool Passes Required to Fill Truck: 3 passes Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: Selected Value within this Basic Rating: Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA NA Maneuver: Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): Dump: 0.500 Cycle Time Factors Factor (min.) Source Material: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Stockpile: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Truck Ownership: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Operation: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Dump Target: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: 0.000 minutes Adjusted Loader Cycle Time: 0.500 minutes Net Load Time per Truck: 1.500 minutes Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 1.500 Minutes Truck Maneuver and Dump Time: 0.90 Minutes Haul Route: minutes Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 1.100 Minutes Adjusted for site altitude: 0.900 Minutes Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (min) Time 1 1956.00 0.00 3.00 3.00 1398 1.400 Haul Time: 1.400 minutes Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (min) Time 1 1956.00 0.00 3.00 3.00 1499 1.305 Return Time: 1.305 minutes Total Truck Cycle Time: 5.605 minutes Loading Tool unit Production 630.00 LCY/Hour Truck Unit Production 168.61 LCY/Hour Optimal No. of Trucks: 3.7 Truck(s) Adjusted for job efficiency: 522.90 LCY/Hour Adjusted for job efficiency: 139.95 LCY/Hour Selected Number of Trucks: 4 Truck(s) JOB TIME AND COST Fleet size: Unit cost: 1 $1.196 Adjusted hourly truck team production: Adjusted single truck/loader team production: Adjusted multiple truck/loader team production Team(s) /LCY 522.90 522.90 522.90 Total job time: Total job cost: LCY/Hour LCY/Hour LCY/Hour 259.79 $162,485 Hours Return to Summary TRUCK/LOADER TEAM WORK Task description: Haul backfill material to Tract C Pond Site: Kurtz Sand, Gravel and Reservoir Project Permit Action: PROJECT IDENTIFICATION Task #: 03A Date: 6/23/2025 User: JEL Agency or organization name: DRMS M S State: County: HOURLY EQUIPMENT COST Shift basis: 1 per day Equipment Description Truck Loader Team -Truck: Generic 12-18 cy, 6x4 -Loader: CAT 966H high lift Support Equipment -Load NA -Dump Area: Area: NA Road Maintenance —Motor CAT 120M Grader: -Water Truck: Water Tanker, 3,500 Gal. Cost Breakdown: Truck/Loader Team Support Equipment 2025 Financial Warranty Update Permit/Job#: M1999006 Colorado Weld Maintenance Equipment Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 75 NA NA 25 25 Ownership cost/hour: $27.14 $57.78 NA NA $52.82 $11.65 Operating cost/hour: $62.81 $34.69 NA NA $10.94 $5.61 %Utilization -riper: NA $0.00 NA NA NA NA Ripper own. cost/hour: NA $0.00 NA NA $0.00 $0.00 Ripper op. cost/hour: NA $0.00 NA NA $0.00 $0.00 Operator cost/hour: $24.82 $56.64 NA NA $56.70 $0.00 Unit Subtotals: $114.77 $149.11 NA NA $120.46 $17.26 Number of Units: 5 1 0 0 1 1 Group Subtotals: Work: $722.96 Support: $0.00 Maint: $137.72 Total work team cost/hour: $860.68 Vol to fill Tract C Pond to 2' above WSEL [yd3]: 317,211 MATERIAL QUANTITIES Initial volume: Loose volume: Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: 317,211 317,211 ill See POND BACKFILL CALCS_v1 from Brian Ewert Cat Handbook S0.00 S0.0() HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: 1,600 Description: Top Soil Rated Payload: Payload Capacity: Truck Bed (volume) Basis: Struck Volume: Heaped Volume: Average Volume: Adjusted Volume: Loading Tool Capacity 50,300 31.44 CY LCY Pounds/LCY Pounds LCY 12.00 LCY 18.00 LCY 15.00 LCY 18.00 LCY Final Truck Volume Based on Number of 15.75 LCY Bucket Size Class NA i Rated Capacity: 5.000 LCY (heaped) I Bucket Fill Factor: 1.050 Other - moist loam (100-110%) 1.050 Adjusted Capacity: 5.250 LCY I Job Condition Corrections: Site Altitude (ft.): 4680 Loader Source Truck Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Swell factor: 1.000 Number of Loading Tool Passes Required to Fill Truck: 3 passes Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: Selected Value within this Basic Rating: Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA NA Maneuver: Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): Dump: 0.500 minutes Cycle Time Factors Factor (min.) Source Material: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Stockpile: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Truck Ownership: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Operation: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Dump Target: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: 0.000 minutes Adjusted Loader Cycle Time: 0.500 minutes Net Load Time per Truck: 1.500 minutes Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 1.500 Minutes Truck Maneuver and Dump Time: 0.90 Minutes Haul Route: Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 1.100 Minutes Adjusted for site altitude: 0.900 Minutes Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (min) Time 1 4906.00 0.00 3.00 3.00 1754 2.796 Haul Time: 2.796 minutes Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (min) Time 1 4906.00 0.00 3.00 3.00 1816 2.702 Return Time: 2.702 minutes Total Truck Cycle Time: 8.398 minutes Loading Tool unit Production 630.00 LCY/Hour Truck Unit Production 112.53 LCY/Hour Optimal No. of Trucks: 5.6 Truck(s) JOB TIME AND COST Fleet size: Unit cost: 1 $1.843 Adjusted hourly truck team production: Adjusted single truck/loader team production: Adjusted multiple truck/loader team production Team(s) /LCY Adjusted for job efficiency: 522.90 LCY/Hour Adjusted for job efficiency: 93.40 LCY/Hour Selected Number of Trucks: 5 Truck(s) 466.98 466.98 466.98 Total job time: Total job cost: LCY/Hour LCY/Hour LCY/Hour 679.28 $584,644 Hours Return to Summary TRUCK/LOADER TEAM WORK Task description: Haul backfill material to Tract D exposed groundwater Site: Kurtz Sand, Gravel and Reservoir Project Permit Action: PROJECT IDENTIFICATION Task #: 04A Date: 6/25/2025 User: JEL Agency or organization name: DRMS M S State: County: HOURLY EQUIPMENT COST Shift basis: 1 per day Equipment Description Truck Loader Team -Truck: Generic 12-18 cy, 6x4 -Loader: CAT 966H high lift Support Equipment -Load NA -Dump Area: Area: NA Road Maintenance —Motor NA Grader: -Water Truck: Water Tanker, 3,500 Gal. Cost Breakdown: Truck/Loader Team Support Equipment 2025 Financial Warranty Update Permit/Job#: M1999006 Colorado Weld Maintenance Equipment Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 75 NA NA NA 25 Ownership cost/hour: $27.14 $57.78 NA NA $52.82 $11.65 Operating cost/hour: $62.81 $34.69 NA NA $10.94 $5.61 %Utilization -riper: NA $0.00 NA NA NA NA Ripper own. cost/hour: NA $0.00 NA NA $0.00 $0.00 Ripper op. cost/hour: NA $0.00 NA NA $0.00 $0.00 Operator cost/hour: $24.82 $56.64 NA NA $56.70 $0.00 Unit Subtotals: $114.77 $149.11 NA NA NA $17.26 Number of Units: 5 1 0 0 0 1 Group Subtotals: Work: $722.96 Support: $0.00 Maint: $17.26 Total work team cost/hour: $740.22 Vol to fill Tract D exposed GW area [yd3]: 12,485 MATERIAL QUANTITIES Initial volume: Loose volume: Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: 12,485 12,485 ' Propeller volume measurement (6/11/25 flight) Wisconsin DOT 80.00 S0.0() HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: Description: Rated Payload: Payload Capacity: Truck Bed (volume) Basis: 2,900 Dry sand and gravel 50,300 17.34 CY LCY Pounds/LCY Pounds LCY Swell factor: 1.000 https://wisconsindot.gov/documents2/research/0092-22-05-final-report.pdf Struck Volume: 12.00 LCY Heaped Volume: 18.00 LCY Average Volume: 15.00 LCY Adjusted Volume: 18.00 LCY Loading Tool Capacity Final Truck Volume Based on Number of 15.75 LCY Bucket Size Class NA i Rated Capacity: 5.000 LCY (heaped) Bucket Fill Factor: 1.050 Other - moist loam (100-110%) 1.050 Adjusted Capacity: 5.250 LCY Job Condition Corrections: Site Altitude (ft.): 4680 Loader Source Truck Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: Selected Value within this Basic Rating: Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA NA Maneuver: Number of Loading Toot Passes Required to Fill Truck: 3 passes Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): Dump: 0.500 minutes Cycle Time Factors Factor (min.) Source Material: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Stockpile: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Truck Ownership: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Operation: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Dump Target: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: 0.000 minutes Adjusted Loader Cycle Time: 0.500 minutes Net Load Time per Truck: 1.500 minutes Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 1.500 Minutes Truck Maneuver and Dump Time: 0.90 Minutes Haul Route: Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 1.100 Minutes Adjusted for site altitude: 0.900 Minutes Seg # Haul Distance Ft ( ) (o ) Grade /o Roll. (o ) Res /o Total Res /o (o ) Velocity (fpm) Travel (min) Time 1 3240.00 0.00 3.00 3.00 1614 2.008 Haul Time: Return Route: 2.008 minutes Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel Time (min) 1 3240.00 0.00 3.00 3.00 1694 1.913 Return Time: 1.913 Total Truck Cycle Time: 6.820 minutes minutes Loading Tool unit Production 630.00 LCY/Hour Truck Unit Production 138.55 LCY/Hour Optimal No. of Trucks: 4.5 Truck(s) JOB TIME AND COST Fleet size: Unit cost: 1 $1.416 Adjusted hourly truck team production: Adjusted single truck/loader team production: Adjusted multiple truck/loader team production Team(s) /LCY Adjusted for job efficiency: 522.90 LCY/Hour Adjusted for job efficiency: 115.00 LCY/Hour Selected Number of Trucks: 5 Truck(s) 522.90 522.90 522.90 Total job time: Total job cost: LCY/Hour LCY/Hour LCY/Hour 23.88 $17,674 Hours Return to Summary TRUCK/LOADER TEAM WORK Task description: Haul topsoil to Tracts A, B, C, D Site: Kurtz Sand, Gravel and Reservoir Project Permit Action: PROJECT IDENTIFICATION Task #: 05A Date: 6/25/2025 User: JEL Agency or organization name: DRMS M S State: County: HOURLY EQUIPMENT COST Shift basis: 1 per day Equipment Description Truck Loader Team -Truck: Generic 12-18 cy, 6x4 -Loader: CAT 966H high lift Support Equipment -Load NA -Dump Area: Area: NA Road Maintenance —Motor CAT 120M Grader: -Water Truck: Water Tanker, 2,500 Gal. Cost Breakdown: Truck/Loader Team Support Equipment 2025 Financial Warranty Update Permit/Job#: M1999006 Colorado Weld Maintenance Equipment Truck Loader Load Area Dump Area Motor Grader Water Truck %Utilization -machine: 100 75 NA NA 25 25 Ownership cost/hour: $27.14 $57.78 NA NA $ 52.82 $11.65 Operating cost/hour: $62.81 $34.69 NA NA $ 10.94 $5.61 %Utilization -riper: NA 0 NA NA NA NA Ripper own. cost/hour: NA $0.00 NA NA $ - $0.00 Ripper op. cost/hour: NA $0.00 NA NA $ - $0.00 Operator cost/hour: $24.82 $56.64 NA NA $ 56.70 $0.00 Unit Subtotals: $114.77 $149.11 NA NA 120.46 $17.26 Number of Units: 3 1 0 0 1 1 Group Subtotals: Work: $493.42 Support: $0.00 Maint: $137.72 Total work team cost/hour: $631.14 MATERIAL QUANTITIES Initial volume: Loose volume: Source of estimated volume: Source of estimated swell factor: Material Purchase Cost: Total Cost: 92,121 92,121 1. Apply 6" topsoil to disturbed surfaces on all Tracts. Areas estimated from Propeller flight P115 on 6/11/2025, except for Tract C Pond disturbed area provided in POND BACKFILL CALCS by Brian Ewert. Cat Handbook HOURLY PRODUCTION Truck Capacity: Truck Payload (weight) Basis: Material weight: Description: Top Soil Rated Payload: Payload Capacity: 1,600 Truck Bed (volume) Basis: 50,300 31.44 Struck Volume: Heaped Volume: Average Volume: Adjusted Volume: 12.00 18.00 15.00 18.00 Final Truck Volume Based on Number of Loading Tool Capacity CCY LCY Pounds/LCY Pounds LCY LCY LCY LCY LCY 15.75 LCY Bucket Size Class NA 1 Rated Capacity: 5.000 LCY (heaped) I Bucket Fill Factor: 1.050 Other - moist loam (100-110%) 1.050 Adjusted Capacity: 5.250 LCY Swell factor: 1.000 Topsoil depth (ft): Topsoil Area - Tract A [sf]: Topsoil Area - Tract B [sf]: Topsoil Area - Tract C [sf]: Topsoil Area - Tract D [sf]: Total Topsoil Vol [cu.yd]: 0.5 1,711,908 2,269,476 527,076 466,092 92,127. Job Condition Corrections: Site Altitude (ft.): 4,800 Loader Source Truck Altitude Adj: 1.000 1.000 (CAT HB) Job Efficiency: 0.830 0.830 (CAT HB) Net Correction: 0.830 0.830 Loading Tool Cycle Time: Excavators and Front Shovels: Machine Cycle Time vs. Job Condition Rating: Selected Value within this Basic Rating: Track Loaders — Material Description: Cycle Time Elements (min.): Load: NA NA Maneuver: Number of LoadingTool Passes Required to Fill Truck: 3 passes Wheel and Track Loaders - Unadjusted Basic Loader Cycle Time (load, dump, maneuver): Dump: 0.500 minutes Cycle Time Factors Factor (min.) Source Material: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Stockpile: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Truck Ownership: No adjustment - factor not applicable 0.00 0.000 (Cat FIB) Operation: No adjustment - factor not applicable 0.00 0.000 (Cat FIB) Dump Target: No adjustment - factor not applicable 0.00 0.000 (Cat HB) Net Cycle Time Adjustment: 0.000 minutes Adjusted Loader Cycle Time: 0.500 minutes Net Load Time per Truck: 1.500 minutes Truck Cycle Time: Truck Exchange Time: 0.50 Minutes Truck Load Time: 1.500 Minutes Truck Maneuver and Dump Time: 0.90 Minutes Haul Route: Tract A Tract B Tract C Tract D Haul Distance (ft) Haul Distance weighted by Topsoil Vol (ft) 397 434 1768 664 137 198 187 62 Total Weighted Haul Distance (ft): 584 Adjusted for site altitude: 0.500 Minutes Adjusted for site altitude: 1.500 Minutes Adjusted for site altitude: 0.900 Minutes Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (mm) Time 1 584.16 0.00 3.00 3.00 807 0.724 Haul Time: 0.724 minutes Return Route: Seg # Haul Distance (Ft) Grade (%) Roll. Res (%) Total Res (%) Velocity (fpm) Travel (mm) Time 1 584.16 0.00 3.00 3.00 902 0.647 Return Time: 0.647 minutes Total Truck Cycle Time: 4.271 minutes Loading Tool unit Production 630.00 LCY/Hour Truck Unit Production 221.25 LCY/Hour Optimal No. of Trucks: 2.8 Truck(s) JOB TIME AND COST Fleet size: Unit cost: $1.073 Adjusted hourly truck team production: Adjusted single truck/loader team production: Adjusted multiple truck/loader team production Team(s) /LCY Adjusted for job efficiency: 522.90 LCY/Hour Adjusted for job efficiency: 183.64 LCY/Hour Selected Number of Trucks: 3 Truck(s) 522.90 522.90 522.90 Total job time: Total job cost: LCY/Hour LCY/Hour LCY/Hour 176.17 $111,190 Hours Return to Summary REVEGETATION WORK Task description: Seed banks of pond Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 05B Date: 6/23/2025 FERTILIZING Materials State: Colorado County: Weld Permit Action: 2025 Financial Warranty Update Permit/Job#: M1999006 User: JEL Agency or organization name: DRMS Description Units /Acre Unit Cost / Unit Cost /Acre 10-34-0, 18-46-0, 5-10-5 200.00 pound $0.51 $102.00 $102.00 Total Fertilizer Materials Cost/Acre Application Description Cost /Acre Tractor towed spreader (MEANS 32 01 90.13 0120) $43.12 Fertilizer Application Cost/Acre $43.12 Total TILLING Description Cost /Acre Chisel plowing €DMG} $102.41 Weed control spraying (MEANS 31 31 16.13 3100) $338.80 Total Tilling Cost/Acre $441.21 SEEDING* Seed Mix Rate — PLS ee Seeds FT per Cost /Acre LBS Acre / Western Wheatgrass (Arriba, Barton, Rosana) 2.50 NA $11.50 Blue Grama (Hachital, Lovington) 1.50 NA $29.00 Sideoats Grama (Vaughn, Butte, Niner, El Reno, Haskell) 2.25 NA $29.00 Smooth Brome (Lincoln, Manchar) 2.00 NA $4.05 Sand Dropseed 0.25 NA $22.00 Perennial Ryegrass (Calibra or Garibalsi tetraploid) 0.75 NA $3.85 Slender Wheatgrass (Pryor, Revenue or San Luis) 2.50 NA $4.25 Alkaligrass (Fults II, Salt on Sea) 1.25 NA $62.00 Switchgrass (Nebraska 28, Blackwell) 1.00 NA $13.74 Totals Seed Mix 14.00 0.00 179.39 *Seed mix follows General Seed Mixes for Weld County documentfound at http://www.weld.gov/Government/Departments/Public-Works/Weed-Management/Controlling-Weeds/Reseeding. Seed costs found at greatbasinseeds.com Application Description Cost /Acre Drill Seeding (DRMS Survey Cost) $236.64 $236.64 Total Seed Application Cost/Acre MULCHING and MISCELLANEOUS Materials Description Units /Acre Unit Cost / Unit Cost /Acre Herbicide - Curtail @ 4.0 pt/ac 1.00 ACRE $36.14 $36.14 Straw, delivered {MEANS 31 25 14.16 1200} 2.00 TON $492.78 $985.56 $1021.70 Total Mulch Materials Cost/Acre Application Description Cost /Acre Crimping, with tractor {DMG survey data} $85.37 Weed spray, truck, non -aquatic area, nox. [DMG] $83.26 $168.63 Total Mulch Application Cost/Acre NURSERY STOCK PLANTING Common Name No / Acre Planting Fertilizer Cost /Acre Type and Size Cost Pellet Cost $0.00 Totals Nursery Stock Cost / Acre JOB TIME AND COST No. of Acres: Estimated Failure Rate: *Selected Replanting Work Items: Initial Job Cost: Reseeding Job Cost: Total Job Cost: Job Hours: 114.20 25% $250,405.20 $62,601.30 $313,006 ■ Cost /Acre: Cost /Acre*: SEEDING $2,192.69 $548.17 P115 Tract A exposed S.A. above WSEL [ac]: P115 Tract B all [ac]: P115 Tract C backfill area [ac]: P115 Tract D all [ac]: 39.3 52.1 12.10 10.70 Return to Summary DEMOLITION WORK Task description: Demo and remove concrete and conveyor Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 06A State: Colorado Date: 6/25/2025 County: Weld User: JEL Agency or organization name: DRMS UNIT COSTS Permit Action: 2025 Financial Warranty Update Permit/Job#: M1999006 Location adjustment: 89.20 Structure or Item Description Dimensions Demolition Menu Selection Quantity Unit Unit Cost Cost Total Wingwalls 5 x 25' at Truck Scales Demo and on -site disposal in existing pit 125.00 LF $148.74 $18,592.08 Concrete 2 x truck pads - quonset hut, scales, scale fuel tank, house Quonset Fuel Truck Truck Scale Hut: Tank: Scale Scale House: 267 SY 21 SY 1: 101 SY 2: 72 SY 16 SY Demo and on to -site disposal equal structure of concrete footprints pads, 376.00 SY $124.15 $46,680.40 assumed Quonset Hut 60' x 40' Remove structure 1.00 EA $11466.74 $11,466.74 Culverts 8'L x 2.5'-5'D RCP Remove and dispose of C RCP culverts Pond from Tract 300.00 LF $57.25 $17,175.60 Conveyor 3' x 6', 4620' long Disassemble conveyor, and store on -site. and trusses, tower, and Remove concrete foundations dispose off -site. bridge 1.00 EA 269,000.00 $269,000.00 Fuel tanks 10,000 gallons Haul tank to dump - 10,000 gal. tank 1.00 EA $1,000.00 $1,000.00 Job Hours: Subtotal (unadjusted): $363,914.83 Total Cost (adjusted for location): $324,612.03 oA Source CDOT Cost Data Book CDOT Cost Data Book CDOT Cost Data Book CDOT Cost Data Book Divide Constructors Estimate (June 2025) American Gypsum Estimate (January 2025) Return to Summary EQUIPMENT MOBILIZATION/DEMOBILIZATION Task description: Mobilization and Demob. Site: Kurtz Sand, Gravel and Reservoir Project PROJECT IDENTIFICATION Task #: 07A State: Colorado Date: 6/25/2025 County: Weld User: JEL Agency or organization name: DRMS Permit Action: 2025 Financial Warranty Update Permit/Job#: M1999006 EQUIPMENT TRANSPORT RIG COST Shift basis: 1 per day Cost Data Source: CRG Data Truck Tractor Description: GENERIC ON -HIGHWAY TRUCK TRACTOR, 6X4, DIESEL POWERED, 400 HP (2ND HALF, 2006) Truck Trailer Description: GENERIC FOLDING GOOSENECK, DROP DECK EQUIPMENT TRAILER (25T, 50T, AND 100T) Cost Breakdown: Available Rig Capacities 0-25 Tons 26-50 Tons 51+ Tons Ownership Cost/Hour: $10.44 $22.18 $23.94 Operating Cost/Hour: $26.48 $54.55 $55.65 Operator Cost/Hour: $22.52 $22.52 $22.52 Helper Cost/Hour: $0.00 $23.53 $23.53 Total Unit Cost/Hour: $59.44 $122.78 $125.64 NON ROADABLE EQUIPMENT: Machine Description Weight/ Unit Owner ship Haul Rig Cost/hr/unit Fleet Size Haul Trip Cost/hr/fleet Return TripDOT Cost/hr/ fleet Permit Cost/ fleet Cost/hr/ unit (TONS) Cat D8T - 8SU 52.21 $187.01 $125.64 2 $625.30 $251.28 $250.00 CAT 966H lift high 25.80 $57.78 $59.44 2 $234.44 $118.88 $250.00 CAT 815F 22.88 $107.16 $59.44 1 $166.60 $59.44 $250.00 Drill/Broadcast with Tractor Seeder 25.00 $41.02 $59.44 1 $100.46 $59.44 $250.00 Grove 81.60 MT RT890E, 142', 54.55 $222.11 $125.64 1 $347.75 $125.64 $250.00 Cat D10T 72.90 $174.79 $178.00 2 $70.5.57 $355.99 $250.00 Subtotals: $2,180.12 $970.67 $1,500.00 ROADABLE EQUIPMENT: Machine Description Total Cost/hr/ Fleet Size Haul Trip Cost/hr/ fleet Return Trip Cost/hr/ unit fleet Generic 12-18 cy, 6x4 $114.77 4 $459.08 $4.59.08 Water Tanker, 3,500 Gal. $34.10 1 $34.10 $34.10 Subtotals: $493.18 $493.18 EQUIPMENT HAUL DISTANCE and Time Nearest Major City or Town within project area region: GREELEY Total one-way travel distance: Average Travel Speed: Total Non-Roadable Mob/Demob Cost * `* two round trips with haul rig: Total Roadable Mob/Demob Cost ** ** one round trip, no haul rig: Transportation Cycle Time: Non-Roadable Equipment Roadable Equipment Haul Time (Hours): 0.60 0.60 Return Time (Hours): 0.60 0.60 Loading Time (Hours): 0.00 NA Unloading Time (Hours): 0.00 NA Subtotals: 1.20 1.20 JOB TIME AND COST Total job time: Total job cost: 2.40 $11,154 Hours 24.00 40.00 $10,561.91 591.82 miles mph Kurtz Resource Recovery & Land Development Raptor Materials 112C Permit M 1999-006 Reclamation Cost Estimate Update July 02, 2025 This submission is in response to a corrective action from a permit inspection conducted May 09, 2025. The specific action concerns the inadequacy of the current Financial Warranty. A formal update to Exhibit L has not been completed but will be pending determination the enclosed information is satisfactory to bring the Financial Warranty to be more current with the current status of the permit. Raptor Materials (Raptor) believes all information necessary to calculate the costs of reclamation is included in this submission. Overview The Kurtz (P115) permit, #M-1999-006, is currently serving primarily as a central processing facility for sand and gravel extracted primarily from the adjacent Raptor Materials, Parcel 122 — Bearson Resource Development Project (DRMS Permit #M-2015-033) and intended in the future to process material from an adjacent property currently being permitted (Cogburn Sand, Gravel, and Reservoir Project, (DRMS Permit #M-2025-016). In addition, some material remains to be extracted and processed from the Kurtz permit area. The permit has 4 separate areas identified as Tracts A, B, C, and D labelled on the enclosed map updated for this submission from the most recent Annual. Report filing. Tract A is an extraction area where a minor amount of material remains to be extracted. An amendment will be submitted prior to August 31, 2025 also satisfying a corrective action in the most recent inspection report. This amendment will propose permitting the Tract A excavation as a lined water storage reservoir. Much ("-'70%) of the Tract A excavation has been regraded and lined with this post mining land use in mind. Tract B currently contains the dry processing plant with the wet processing plant currently situated in the northwest corner of Tract A. Material from the Bearson permit is delivered to this area via a conveyor belt. Product stockpiles, including a large sand pile (approximately 200,000 cubic yards (CY) as of the last survey on June 11, 2025 exist in various locations within Tract B. Minor excavation is ongoing in Tract B and these excavations are proposed to be backfilled to no longer expose ground water as part of final reclamation. Tract C contains an excavation currently being backfilled to no longer expose groundwater and this activity is proposed to continue. Tract D has minor excavations remaining to be backfilled to no longer expose groundwater. This area is currently in active use as part of the construction of a water pipeline by the City of Thorton. As extraction activities are currently minimal and reclamation activities are ongoing in Tracts C and D, Raptor proposes the worst case scenario for reclamation in the event of default is the current state of the operation. A general approach to reclamation of the operation left in its current state assumes: 1. Tract A excavation will fill with water and require dewatering to complete grading and liner construction. A significant amount of fill material has been stored in the Tract A excavation and this will be used in backfilling excavations in Tracts B, C, and D to ensure groundwater is no longer exposed. Existing ponds in Tract A will be backfilled unless they can be shown to satisfy the State Engineer requirements for lined storage. 2. The large sand pile in Tract B will be pushed using tracked dozers into adjacent existing excavations. Additional fill material to ensure groundwater is no longer exposed will be sourced from Tract A. 3. The exposed groundwater in Tracts C and D will be eliminated through backfilling of those areas. 4. Topsoil is currently being stored on the adjacent Bearson property (DRMS Permit #M- 2015-033) and will be conveyed using the existing conveyor to Tract B from where it will be distributed to all areas of the Kurtz permit to a depth of six inches. 5. The conveyor will be removed and while likely to have salvage value greater than the cost of recovery, a cost has been included in the estimate for removal. 6. The processing plant is all portable equipment and is conservatively assumed to be salvaged with no residual value. 7. Other items including truck scales, concrete pads and small structures will be removed. Estimates of the work required to complete the above reclamation of the Kurtz operation include material properties, material quantities, material transport distances. Equipment productivity and fleet requirements are generally based on Cat Handbook and in some cases supported by previous DRMS methodology. The physical quantities and equipment requirements support cost estimates using rates either from recent DRMS reclamation cost estimates prepared in CIRCES, or other sources as noted. The enclosed map provides a site wide overview of key elements. The following sections provide more detail on specific elements of the estimate which are then documented in the attached costing sheets patterned on CIRCES output. •mot. _ ::. Tract A Tract A: re -grade and re -line — west wall Polygon Grde 3D path 3D polygon Measure the distance between multiple points on the ground Length: Show Elevation Profile Mouse Navigation 850.60 NOTE: Actual distance measured on CAD drawing as 715 feet Polygon Circle 3D palh 3.. polygon Tract A: slope - west wall existing slope Tract A: Stored fill material Updated topographic survey of this area of the pit has been ordered. The area stored fill material is approximately 714,000 sq. feet, with the west side estimated to be 30 feet deep grading down to zero feet on the pit floor on the east side. A conservative volume estimate from this geometry is 395,000 LCY of material. Tract A: Liner and fillsource material Line Path Polygon Circle .3) path 3) polygon Measure the distance or area of a geometric shape on the ground Perimeter: 5,932,46 Feet Area: 40,30 Acres ti' Mouse Navigabon 2u25 Airbus Notepad - - Imagery Date: -5f244/ t?3$ Shale, claystone and clay material are found as bedrock below the extracted sand and gravel. This material has proven to be suitable in several previously constructed reservoirs by Raptor and predecessor Varra. More than adequate material. exists that can be ripped and transported for constructing compacted liner surfaces, or as borrow material to fill other excavations. Tract A: Liner Material Haul Distance Ruler Line Path Polygon Circle 3D path 3D polygon Measure the distance between multiple points on the ground Length: 1,237.54 Feet Show Elevation Profile J Mouse Navigation Save Tract A: Ponds Backfill Haul Distances Line I Path I Polygon Circle 31) path 3D polygon Measure the distance between multiple points on the ground Length; 835,42 Feet Show Elevation Profile Mouse Navigation Clear Line Path Polygon Circle 3D path 3D polygon Measure the distance between multiple points on the around Lin etype ByLayer Li n etype scale 1,0000 Plot style ByColor Line weight ByLayer Transparency ByLayer Hyperlink Thickness 0,0000 3D Visualization Naterial Geometry Current Vertex Vertex X Vertex Y Start segmentwidth End segment width Globalwidth Elevation Area Length M ise Closed Linetype generation ByLayer 1 3166531,8513 1314545.6269 0,000? 0.0000 0,0000 0,0001 271884.0551 2003.3519 Ye= Disabled 1;7 u F O `I I., Eh A 01. Pond depth is approximately 5'. Assume 3:1 slopes. Backfill to 2' Above WSEL. B1 = 34676.7SY; B2 = (271884 SF / 9) = 30209.3 SY; H = (5+2) = 7' = 2.33 yd Backfill Vol [CY] ='/z x [B1(34676.7 SY)+B2(30209.3 SY)]*H(2.33yd) _ 75, 700.3 CY • Offset Pond surface at 3:1 slope: Start P115-27 Jun 202.4 -Tract A Pond 2.dxt x PROPERTIES Palyline eta General Color Layer Linetype Linetype scale Plot style Lineweight Transparency, Hyperlink Thickness 3D Visualization Material ByLayer TRACT -A -POND -2 ByLayer 1.,0000 ByColor ByLayer ByLayer 0.0000 ByLayer Geometry Current 'V`e'rtex I Vertex X 3166258,0398 Vertex Y 1314199.6639 Start segment w i d th 0.0000 End segment width 0.0000 Global width 0.0000 Elevation 0.0000 Area 22016.9343 Length 684.7399 Misc V Closed Linetype generation Yes Disabled e 17 u c 17 u 4-1 v 0 C`- H a A • [—] ropl(2D Wirefrarn e] s Pond depth is approximately 8'. Assume 3:1 slopes. Backfill to 2' Above WSEL. B1 = 4738.9SY; B2 = (22016 SF / 9) = 2446.3 SY; H = (8+2) = 10' = 3.33 yd _ 1 x [B1(4738.9 SY)+B2(2446.3 SY)]*H(3.33yd) Backfill Vol [CY] Tract B Tract B: Sand Pile Volume omit PROPERTIES ,e STY I r ,; Surface Comparison From Surface O Current Surface (P115 Stockpile! To Surface Smart Volume Surface 3D CUT/FILL 2D CUT/FILL CONTOURS cr�t NCI FILL 202,613.4 yd3 -201579.5 yd3 33.9 yd3 TOTAL j 20Z647.3 yd3 r. `s.r![ minim a This volume was the current volume of sand stored above grade as of a topographic survey of the stockpile areas on June 11, 2025. This material would be pushed into the adjacent excavation immediately to the north. Tract B: Receiving Pit Capacity for Sand Pile Pit for Sand Pile ,s Surface Comparison From Surface Current Surface (P115 Stockpile! Smart Volume Surface 3D CUT/FILL 2D CUT/FILL CONTOURS CUT NET ■ FILL TOTAL 1,835.5 yd3 330,388.3 yd3 332,223.8 ycP 334,059.2 yd3 The required backfill volume for the Tract B excavation will be partially filled by pushed material from the sand stockpile. The sand will partially fill the excavation and an additional 129,611 LCY of fill material will be hauled from available fill or borrowed fill in Tract A. Average push distance from approximate centroid of stockpiled sand to excavation. Average push gradient from approximate centroid of stockpiled sand to excavation measured at -1V:8.3H or -12%. Tract B: Pond to Backfill Offset Pond surface at 3:1 slope: Polylin General Color Layer 0 L i n etype ByLayer Linetype scale Plot style 1.0000 E_,Colc::r L inewei•ght ByLayer Transparency ByLayer Hyperlink Thickness 0,0000 3D Visualization Material ByLayer Geometry V Current Vertex Vertex X Vertex V Start segment width End segment width Global width Elevation Area Length 1 3167426,8610 1316589.6555 0;0000 0.0000 0.10000 0:0000 L08,2330 604.4405 Misc Closed Linetype generation No Disabled u 71. r_1 Lv ra V 44 V J 0 0 L C a A •-3 • Pond depth is approximately 14'. Assume 3:1 slopes. Backfill to 2' Above WSEL. B1 = 6232.6SY; B2 = (21208 SF / 9) = 2356.5 SY; H = (14-2) = 16' = 5.33 yd ='/z;; [B1(6323.6 SY)+B2(2356.5 SY)]*H(5.33yd) Backfill Vol [CY] 23,132.5 CY I� 1s1.• ft (US) Line Path Polygon tide 3D path 3D po4pgon measure the idislitncebetween multiple points on the ground Tract D Tract D: Being Backfi fled • Tract D - being backfilled - a Surface Comparison From Surface Smart Volume Surface 3D CUT/FILL 2D CUT/FILL COINTDURS TOTAL 6yd3 12,478.8 y& 12,484.9 yd3 12,490.9 yd3 Tract D: Backfill Haul Distance 166.3 ft (US) 106.6ft(US) 545.1 ft (US) '341.8 ft (US) Lift (US) 18g, n(Ub) '_i Horizontal Distance 3,240 ft (US) rNA Surface Distance ,hr Point to Point Distance 3,245.2 ft (US) ± ADD/EDIT ITEMS Topsoil Haul Distance Tract A - Topsoil Haul Distance Ruler Line Path Polygon Circle 3D path 3D polygon pleasure the distance between two points on the ground Map Length: Ground Length: Heading: J Mouse Navigation 396.59 Feet 396.59 144.26 degrees Save I I Clear Tract B - Topsoil Haul Distance Ruler Line Path Polygon Circle 3D path 3D polygon Measure the distance between two points on the ground Map Length: 433.92}Feet Feet • Ground Length: 433,92 Heading: 121.21 degrees V Mouse Navigation Save Clear Tract C -Topsoil Haul Distance Ruler Polygon Circle 3D path 3D polygon Measure the distance between multiple points on the ground Length; 1,768,22 Feet I_I Show Elevation Profile J Mouse Navigation Image c_, ? x,225 Airbus Tract D - Topsoil Haul Distance Ruler Line Path Polygon Cirde 3D path 3D polygon Measure the distance between two point on the ground Map Length: Ground Length: Heading: 664.02 Feet 664,02 JL„-9 degrees Mouse Na'v'igation Save Q ®25 Airbus Clear 111 TABEL L- PREFERRED/PRIMARY SEED MIXTURE 2025 Seed Mix Calculator - - - ----------- PROJECT: Kurtz Resource Recovery Tract: ALL Application: Initial STEP 1 PRIMARY/PREFERRED SEED MIXTURE I Critical AREA Planting I STEP 2 M x % of Mixture = STEP 3 # Species - Scientific Name Species - Common Name Variety C/W Seeds/# pls , 43560 Seeds/sq.ft. (ri 40 Seeds/sq.ft. I % Mix # pls/acre ** I $./# I S/Acre I NOTES: 1 Pascopvruna .Smith// Western wheatgrass Arriba, Barton, Rosana 2.50 $ 11.50 $ 28.75 2 Bouteloua gracil/.S Blue grama Hachital, Lovington 1.50 $ 29.00 $ 43.50 3 Bouteloua curtipendula Sideoats grama Vaughn, Butte, Niner, El Reno, Haskell 2.25 $ 29.00 $ 65.25 4 Bronius inermis Smooth brome Lincoln, Manchar 2.00 5 4.05 $ 8.10 5 Sporobolus crvptandrus Sand dropseed 0.25 $ 22.00 $ 5.50 6 Lolium perenne Perennial ryegras Calibra, Garibaldi tetraploic 0.75 $ 3.85 $ 2.89 7 Elymus trachycaulus Slender wheatgrass Pryor, Revenue, San Luis 2.50 5 4.25 $ 10.63 8 Sporobolus airoides Alkaligrass Fults II, Salt on Sea 1.25 $ 62.00 $ 77.50 9 Panicum v/rgatum Switchgrass Trailblazer 1.00 $ 13.74 $ 13.74 10 11 12 13 TOTALS = $ 255.85 RAPTOR MATERIALS LLC KURTZ RESOURCE RECOVERY AND LAND DEVELOPMENT PROJECT OCTOBER 2025 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION- COLORADO DIVISION OF RECLAMATION MINING SAFETY OFFICE OF MINED LAND RECLAMATION COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources July 29, 2025 Raptor Materials LLC sent via email: gvarra@raptormaterialsllc.com Re: Permit No. M-1999-006, Kurtz Resource Financial Warranty Increase Acceptance, SI-4 Dear Garrett Varra: This Division has accepted your Liberty Mutual increase rider in the revised amount of $2,571,871.00. You are now considered fully bonded for this site. Sincerely, Sara Stevenson-Benn Financial Warranty Specialist cc: Patrick Lennberg, DRMS Physical Address: 1313 Sherman Street Room 215, Denver, CO 80203 P 303.866.3567 7 F 303.832.8106 Mailing Address: DRMS Room 215, 1001 E 62nd Aver Denver, CO 80216 https: / /drms.colcra do. gav Jared S. Pelts, Governor I Dan Gibbs, Executive Director I Michael A. Cunningham, Director Divide Constructors Engineering I Fabrication I Steel Erection June 25, 2025 Respec, Inc. 720 S. Colorado Blvd, Ste 410 S Denver, CO 80246 Attn: Jenna Lohmann, PE PO Box 438 Berthoud, CO 80513 Telephone: (970) 532-3761 Fax: (970) 532-0567 Quote: Overland Conveyor Dismantle - Heintzelman Pit Description: Dismantle and relocate the overland conveying system at the Heintzelman Pit — Raptor Materials. Scope of Work: 1. Dismantle approx. 2,620ft of overland conveyor running parallel with Cty Rd 17. o Includes: ■ Belt winding — Belt rolls to be approx. 1000ft in length. ■ Disassemble and relocate approx. qty. 62 40ft trusses and support legs. ■ Disassemble and relocate the drive section and tail section. ■ Relocate precast concrete blocks used along the line. 2. Dismantle approx. 2,000ft of overland conveyor running into the plant site. o Includes: ■ Belt winding — Belt rolls to be approx. 1000ft in length. ■ Disassemble and relocate approx. qty. 49 — 40ft trusses and support legs. ■ Disassemble and relocate the drive section and tail section. ■ Relocate precast concrete blocks used along the line. 3. Dismantle the conveyor bridge over Cty Rd 28. o Includes: ■ Disassemble and relocate the bridge system including the trusses and towers. Total Bid Price for Items 1 — 3: $232,000.00 Additional Work: 4. Removal of concrete foundations at Line 1, Line 2 and at the Cty Rd 28 bridge. Total Bid Price for Item 4: $ 37,000.00 Qualifications and Exclusions: - Bid pricing includes: All labor, forklifts, trucks, cranes, consumables and fuel. - All of the overland conveyor equipment is to be staged at the plant/pit site. - The above pricing does not include electrical wiring decommissioning or removal. Hello