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Home My WebLink About20230651.tiffRaptor Materials, LLC. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 Thursday 9 March 2023 To: Weld County Clerk to the Board 1150 O Street Greeley, Colorado 80632 From: Bradford Janes, Professional Forester Liaison, Interdisciplinary Affairs Subject Raptor Materials, LLC. (formerly Varra Companies, Inc.) Two Rivers Sand, Gravel and Reservoir Project, File No. M-2022-013, 112c Permit Application 4th Adequacy Review. • Correspondence of 8 March 2023 from Raptor Materials, LLC., to the Colorado Office of Mined Land Reclamation, and attending Exhibits and Maps — Adequacy #4 Response. Attachments: • Current 112 Form (for reference, unchanged from previous) • Updated Exhibit C1 Maps — Existing Conditions • Updated Exhibit L — Reclamation Costs • Updated Exhibit G Map — Water Information • Revised Groundwater Monitoring Plan (Exhibit G, Addendum 15) • Revised Water Well Detail (Exhibit G, Addendum 16) Your signature and/or official stamp, below acknowledges receipt of the above referenced materials included with this correspondence. The material should be added to the identified Application, as originally submitted to the Weld County Clerk to the Board, and made accessible for public review. RECEIVED 2023 Received On , MAR 0 9 2023 By: WELD COUNTY COMMISSIONEHS Office of the Weld County Clerk to the Board of County Commissioners Greeley, Colorado P�bt; C Rev ;e(,.,) 0LI/°3/23 cc: FL (TP/MN/DA/Ko/DA) Pw (cH/ER/cK/DD/DN) .3/25023 2023 - 0651 STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 APPLICABILITY: CONSTRUCTION MATERIAL REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION PACKAGE COLORADO DIVISION OF RECLAMATION MINING SAFETY This application package is for a construction materials operation which affects 10 acres or more. If you plan to conduct a construction materials extraction operation which meets these criteria, please follow the instructions provided in this package, in the Rules and Regulations, and in the Colorado Land Reclamation Act for the Extraction of Construction Materials, as required. RECOMMENDATIONS PRIOR TO FILING: The Construction Material Rules and Regulations (the Colorado Land Reclamation Act for the Extraction of Construction Materials, Section 34-32.5-101, et seq., C.R.S., and 2 CCR 407-1) and the Colorado Mined Land Reclamation Board (the "Board") regulate the permitting, operational and reclamation requirements for all construction material extraction operations in Colorado. It is your obligation to comply with the Act and Regulations. You are encouraged to obtain and review a copy of the Rules, available for $8.00 from the Division of Reclamation, Mining, and Safety (the "Office"). In order to submit your application properly, it is recommended that you review the Act and: Rule 1.1 Rule 1.4.1 Rule 1.4.5 Rule 1.6 Rule 3.1 Rule 3.3.1 Rule 4 Rule 6 Rule 6.2 Rule 6.4 Rule 6.5 Definitions; Application Review and Consideration Process; Specific Requirements for Regular 112 Operations; Public Notice Procedures; Reclamation Performance Standards; Operating without a Permit - Penalty; Performance Warranties and Financial Warranties; Permit Application Exhibit Requirements; General Requirements of Exhibits; Specific Permit Application Exhibit Requirements; and Geotechnical Stability Exhibit. It is recommended that you contact the agencies listed in the application section titled "Com submitting the application to the Office . 2liance With Other Laws" prior to Office of Mined Land Reclamation Office of Denver • Grand Junction • Durango Active and Inactive Mines FILING REQUIREMENTS: In order to apply for a Reclamation Permit for a Regular 112 Operation, please provide: o One (1) signed and notarized completed ORIGINAL and one (1) copy of the completed original Regular 112 Operation Application Form. ORIGINAL SIGNATURES MUST BE DONE IN BLUE INK. o Two (2) copies of Exhibits A -S (required sections described in Rule 6). o Two (2) copies of Addendum 1 -Notice requirements (described in Rule 1.6.2(1)(b)). A sample of this notice is attached for your use. o The Geotechnical Stability Exhibit when required by the Division. o The application fee. The ninety (90) day period for review of the application and exhibits will NOT begin until all required information and fee are submitted. The Office will then review the submitted information for adequacy. NOTICE REQUIREMENTS: 1. You MUST send a notice, on a form approved by the Board, to the local board of county commissioners. A copy of this "Notice of Filing Application" form is attached for your use. 2. If the mining operation is within the boundaries of a conservation district, send a notice to the board of supervisors of the conservation district, PRIOR to filing the application. A copy of this "Notice of Filing Application" form is attached for your use. 3. You MUST include proof of notice #1 and #2 above with the application at the time the application is submitted to the Office for filing (Rule 1.6.2(1)(g)). 4. PRIOR to filing the application, place for public review a copy of the application, less confidential items, with the clerk or recorder of the county or counties in which the affected land is located. 5. You MUST include an affidavit or receipt demonstrating that the application was filed with the county clerk or recorder at the time the application is submitted to the Office for filing. 6. Any changes or additions made to an application submittal MUST be filed with the county clerk or recorder. You MUST also provide the Office with an affidavit or receipt demonstrating that the change was filed with the county clerk or recorder no later than the close of business on the day the change was filed with the Office (Rule 1.8.1(2)). 7. Within ten (10) days after your application is considered filed, you must publish four times in a newspaper of general circulation, in the locality of the proposed mining operation, the notice described in Rule 1.6.2(1)(d). 8. In addition, after the first publication you must mail or personally serve a copy of the notice described in Rule 1.6.2(1)(d) to all owners of record of surface rights to the affected land and all owners of record of lands that are within 200 feet of the boundary of the affected land (Rule 1.6.2(1)(e)). A copy of a form which includes all required information for the notice is attached for your use. 9. Prior to the Office making a decision (consideration ofthe application), you MUST submit a copy of the proof of publication from the newspaper and proof of all required notices. Proof of the notices may be by submitting copies of return receipts of a certified mailing or by proof of personal service (Rules 1.4.1(4), 1.4.2(4)(c), 1.6.2(1)(a)(ii), and 1.6.2(1)(g)). The copy of the application and any changes or additons placed at the office of the county clerk or recorder shall NOT be recorded, but shall be retained there for at least sixty (60) days after a decision on the application by the Office and be available for inspection during this period. At the end of this period, the application may be reclaimed by the applicant or destroyed (Rule 1.6.2(2)). APPLICATION REVIEW PROCEDURES: The Office shall approve or deny the application within ninety (90) days of filing unless the date for consideration by the Office is extended pursuant to Rule 1.8. The time for consideration shall not be extended beyond ninety (90) days after the last such change submitted. For complex applications, the review period may be extended an additional sixty (60) days. Please see Rule 1.1(10) for the definition of what constitutes a complex application. APPLICATION APPROVAL/DENIAL: If the requirements of the Act and Mineral Rules have been satisfied, the Office will approve the application. The Act also provides for automatic approval if no action is taken by the Office by the end of the review period. If the Act and Regulation requirements have not been satisfied, the Office will deny the application. If the Office denies the application, you may appeal to the Board for a final determination by submitting a written request for administrative appeal to the Board within 60 days of the decision date (Rule 1.4.7). PERFORMANCE AND FINANCIAL WARRANTIES: A performance warranty, and a financial warranty dollar amount determined during the application review process, must be submitted and approved by the Office PRIOR to permit issuance. A financial warranty should NOT be submitted until a decision on the application has been made. If the applicant is a unit of state or county government, then ONLY a performance warranty is required. Several different types of financial warranties are allowed by the law. Please review Rule 4.0 to determine which type of financial warranty you desire to use. You may obtain the appropriate warranty forms from the Office during the application review period. Please note that an application approval DOES NOT convey a right to begin operations. You MUST submit, and have approval of your performance and financial warranties, and receive your copy of the signed permit document PRIOR to beginning on -site mining activity. AUTOMATIC PERMIT APPROVAL: An automatic approval will occur where the Office fails to notify the applicant/operator that the application has been denied. This decision must be made ninety (90) calendar days from the date the application was determined to have been filed. However, the performance and financial warranties must be submitted and approved by the Office before the permit will be issued even if you receive an automatic approval. NO MINING OPERATIONS SHALL BEGIN UNTIL A PERMIT IS ISSUED (Section 34-32.5-109(1), C.R.S.). -iv - COMPLIANCE WITH OTHER LAWS: Compliance with the Act and Rules and Regulations of the Mined Land Reclamation Board DOES NOT relieve you of your responsibility to comply with all other applicable state and federal laws. We recommend that you contact the following agencies to determine whether you need to comply with their legal requirements: o The Colorado State Historical Preservation Office regarding properties of historical significance including the need for an archeological survey, procedures for requesting a file search, and inventory forms to identify structures. o Colorado Division of Water Resources with regard to water rights; Colorado Department of Health, Water Quality Control Division, with regard to the discharge of pollutants into the State waters; o Colorado Department of Health, Air Pollution Control Division, with regard to the need for a fugitive dust permit; o U.S. Bureau of Land Management or the U.S. Forest Service if the proposed operation will occur on federal lands; o U. S. Army Corps of Engineers regarding a dredge and fill (404) permit; and The County Planning Department for the county or counties in which your proposed operation is located. Section 34-32.5-109(3), C.R.S, requires a mining operator to be responsible for assuring that the mining operation and the post -mining land use comply with local land use regulations and any master plan for extraction adopted pursuant to Section 34-1-304, C.R.S. COMPLETION OF MINING: Upon completion of any phase of reclamation, you should consult Rule 3.1 for reclamation standards and 4.16 for details on how to request a reclamation responsibility release from the Board. STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 CONSTRUCTION MATERIALS REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION FORM CHECK ONE: ✓ There is a File Number Already Assigned to this Operation COLORADO DIVISION OF RECLAMATION MINING SAFETY Permit # MZ,g22 - 013 (Please reference the file number currently assigned to this operation) New Application (Rule 1.4.5) Conversion Application (Rule 1.11) Amendment Application (Rule 1.10) Permit # M - (provide for Amendments and Conversions of existing permits) The application for a Construction Materials Regular 112 Operation Reclamation Permit contains three major parts: (1) the application form; (2) Exhibits A -S, Addendum 1, any sections of Exhibit 6.5 (Geotechnical Stability Exhibit; and (3) the application fee. When you submit your application, be sure to include one (1) complete signed and notarized ORIGINAL and one (1) copy of the completed application form, two (2) copies of Exhibits A -S, Addendum 1, appropriate sections of 6.5 (Geotechnical Stability Exhibit, and a check for the application fee described under Section (4) below. Exhibits should NOT be bound or in a 3 -ring binder; maps should be folded to 8 1/2" X 11" or 8 1/2" X 14" size. To expedite processing, please provide the information in the format and order described in this form. GENERAL OPERATION INFORMATION Type or print clearly, in the space provided, ALL information requested below. 1. Applicant/operator or company name (name to be used on permit): Raptor Materials, LLC. 1.1 Type of organization (corporation, partnership, etc.): Limited Liability Company 2. Operation name (pit, mine or site name): Two Rivers Sand, Gravel & Reservoir Project 3 Permitted acreage (new or existing site) : 3.1 Change in acreage (+) 3.2 Total acreage in Permit area 4. Fees: 4.1 4.2 4.4 4.5 New Application New Quarry Application Amendment Fee Conversion to 112 operation (set by statute) 5 Primary commoditie(s) to be mined: sand 5.1 Incidental commoditie(s) to be mined: 1. 3. / lbs/Tons/yr 4. gravel earth products lbs/Tons/yr 2. 409.234 permitted acres acres acres $2,696.00 $3,342.00 $2,229.00 $2,696.00 application fee quarry application amendment fee conversion fee lbs/Tons/yr / lbs/Tons/yr 5. / lbs/Tons/yr 5.2 Anticipated end use of primary commoditie(s) to be mined: commercial urban & rurual infrastructure needs N/A 5.3 Anticipated end use of incidental commoditie(s) to be mined: 6. Name of owner of subsurface rights of affected land: Raptor Materials, LLC. If 2 or more owners, "refer to Exhibit O". 7 Name of owner of surface of affected land: Raptor Materials, LLC. 8. Type �e of mining operation: eration: Surface 1' Underground 9 Location Information: The center of the area where the majority of mining will occur: COUNTY: Weld PRINCIPAL MERIDIAN (check one): SECTION (write number): TOWNSHIP (write number and check direction) : RANGE (write number and check direction) : QUARTER SECTION (check one) : QUARTER/QUARTER SECTION (check one) : 6th (Colorado) 10th (New Mexico) s3 T4 R 66 i North East _ South West NE I " NW In SE r SW NE NW SE ' SW Ute GENERAL DESCRIPTION: (the number of miles and direction from the nearest town and the approximate elevation): 10. Primary Mine Entrance Location (report in either Latitude/Longitude OR UTM): Latitude/Longitude: Example: (N) 39° 44' 12.98" (W) 104° 59' 3.87" Latitude (N): deg min sec (2 decimal places) Longitude (W): deg nun sec (2 decimal places) OR Example: (N) 39.73691° (W) -104.98449° Latitude 40 .348174 (5 decimal places) P ) Longitude(W) -104 .776631 (5 decimal places) OR Universal Tranverse Mercator (UTM) Example: 201336.3 E NAD27 Zone 13 4398351.2 N s eci NAD27, NAD83 or WGS 84) N ad 83 Zone 13 UTM Datum (specify Easting Northing 11. Correspondence Information: APPLICANT/OPERATOR Contact's Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: PERMITTING CONTACT Contact's Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: INSPECTION CONTACT Contact's Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: (name, address, and phone of name to be used on permit) Kevin Jeakins Raptor Materials, LLC. Title: Vice -President 8120 Gage Street P.O. Box: Frederick Colorado (303 ) _ 666-6657 (303 ) _ 666-6743 (if different from applicant/operator above) Garrett C. Varra Raptor Materials, LLC. Zip Code: 80516 Title: General Manager 8120 Gage Street P.O. Box: Frederick Colorado (303 ) _ 666-6657 c 303 ) _ 666-6743 Garrett C. Varra Raptor Materials, LLC. Zip Code: 80516 Title: General Manager 8120 Gage Street P.O. Box: Frederick Colorado (303 ) _ 666-6657 (303 ) _ 666-6743 CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Zip Code: 80516 Zip Code: Telephone Number: ( ) - CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Telephone Number: Zip Code: ( ) 4 12. Prima future (Post -mining) land use (check one): Cropland(CR) Pastureland(PL) FI Rangeland(RL) Forestry(FR) Residential(RS) Recreation(RC) Developed Water Resources(WR) 13. Primary present land use (check one : Cropland(CR) Pastureland(PL) Rangeland(RL) Forestry(FR) Residential(RS) Recreation(RC) Developed Water Resources(WR) General Agriculture(GA) Wildlife Habitat(WL) Industrial/Commercial(IC) Solid Waste Disposal(WD) General Agriculture(GA) Wildlife Habitat(WL) Industrial/Commercial(IC) 14. Method of Mining: Briefly explain mining method (e.g. truck/shovel): Surface extraction, processing, and transport of aggregate resources until bedrock establishment of final basins is complete. 15. On Site Processing: _Ft Crushing/Screening 13.1 Briefly explain mining method (e.g. truck/shovel): In place extraction of unconsolidated soil and aggregate by excavators, dozers, scrapers, or backhoes followed by transportation by conveyor or haul truck to a processing locations where material is crushed, screened, and prepared and stockpiled for commercial sale and removal from property. All extracted materials may be utilized for either commercial purposes or on -site reclamation and development. List any designated chemicals or acid -producing materials to be used or stored within permit area: None 16. Description of Amendment or Conversion: If you are amending or converting an existing operation, provide a brief narrative describing the proposed change(s). N/A 5 Maps and Exhibits: Two (2) complete, unbound application packages must be submitted. One complete application package consists of a signed application form and the set of maps and exhibits referenced below as Exhibits A -S, Addendum 1, and the Geotechnical Stability Exhibit. Each exhibit within the application must be presented as a separate section. Begin each exhibit on a new page. Pages should be numbered consecutively for ease of reference. If separate documents are used as appendices, please reference these by name in the exhibit. With each of the two (2) signed application forms, you must submit a corresponding set of the maps and exhibits as described in the following references to Rule 6.4, 6.5, and 1.6.2(1)(b): EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D EXHIBIT E EXHIBIT F EXHIBIT G EXHIBIT H EXHIBIT I EXHIBIT J EXHIBIT K EXHIBIT L EXHIBIT M EXHIBIT N EXHIBIT O EXHIBIT P EXHIBIT Q EXHIBIT R EXHIBIT S Rule 1.6.2(1)(b) Rule 6.5 Legal Description Index Map Pre -Mining and Mining Plan Map(s) of Affected Lands Mining Plan Reclamation Plan Reclamation Plan Map Water Information Wildlife Information Soils Information Vegetation Information Climate Information Reclamation Costs Other Permits and Licenses Source of Legal Right -To -Enter Owners of Record of Affected Land (Surface Area) and Owners of Substance to be Mined Municipalities Within Two Miles Proof of Mailing of Notices to County Commissioners and Conservation District Proof of Filing with County Clerk or Recorder Permanent Man -Made Structures ADDENDUM 1 - Notice Requirements (sample enclosed) Geotechnical Stability Exhibit (any required sections) The instructions for preparing Exhibits A -S, Addendum 1, and Geotechnical Stability Exhibit are specified under Rule 6.4 and 6.5 and Rule 1.6.2(1)(b) of the Rules and Regulations. If you have any questions on preparing the Exhibits or content of the information required, or would like to schedule a pre -application meeting you may contact the Office at 303-866-3567. Responsibilities as a Permittee: Upon application approval and permit issuance, this application becomes a legally binding document. Therefore, there are a number of important requirements which you, as a permittee, should fully understand. These requirements are listed below. Please read and initial each requirement, in the space provided, to acknowledge that you understand your obligations. If you do not understand these obligations then please contact this Office for a full explanation. A4' 1. Your obligation to reclaim the site is not limited to the amount of the financial warranty. You assume legal liability for all reasonable expenses which the Board or the Office may incur to reclaim the affected lands associated with your mining operation in the event your permit is revoked and financial warranty is forfeited; �S `4-b xs.t 2. The Board may suspend or revoke this permit, or assess a civil penalty, upon a finding that the permittee violated the terms or conditions of this permit, the Act, the Mineral Rules and Regulations, or that information contained in the application or your permit misrepresent important material facts; 3. If your mining and reclamation operations affect areas beyond the boundaries of an approved permit boundary, substantial civil penalties, to you as permittee can result; 4. Any modification to the approved mining and reclamation plan from those described in your approved application requires you to submit a permit modification and obtain approval from the Board or Office; 5. It is your responsibility to notify the Office of any changes in your address or phone number; 6. Upon permit issuance and prior to beginning on -site mining activity, you must post a sign at the entrance of the mine site, which shall be clearly visible from the access road, with the following information (Rule 3.1.12): a. the name of the operator; b. a statement that a reclamation permit for the operation has been issued by the Colorado Mined Land Reclamation Board; and, c. the permit number. 7. The boundaries of the permit boundary area must be marked by monuments or other markers that are clearly visible and adequate to delineate such boundaries prior to site disturbance. 8. It is a provision of this permit that the operations will be conducted in accordance with the terms and conditions listed in your application, as well as with the provisions of the Act and the Construction Material Rules and Regulations in effect at the time the permit is issued. 9. Annually, on the anniversary date of permit issuance, you must submit an annual fee as specified by Statute, and an annual report which includes a map describing the acreage affected and the acreage reclaimed to date (if there are changes from the previous year), any monitoring required by the Reclamation Plan to be submitted annually on the anniversary date of the permit approval. Annual fees are for the previous year a permit is held. For example, a permit with the anniversary date of July 1, 1995, the annual fee is for the period of July 1, 1994 through June 30, 1995. Failure to submit your annual fee and report by the permit anniversary date may result in a civil penalty, revocation of your permit, and forfeiture of your financial warranty. It is your responsibility, as the permittee, to continue to pay your annual fee to the Office until the Board releases you from your total reclamation responsibility. 10. For joint venture/partnership operators: the signing representative is authorized to sign this document and a power of attorney (provided by the partner(s)) authorizing the signature of the representative is attached to this application. 7 NOTE TO COMMENTORS/OBJECTORS: It is likely there will be additions, changes, and deletions to this document prior to final decision by the Office. Therefore, if you have any comments or concerns you must contact the applicant or the Office prior to the decision date so that you will know what changes may have been made to the application document. The Office is not allowed to consider comments, unless they are written, and received prior to the end of the public comment period. You should contact the applicant for the final date of the public comment period. If you have questions about the Mined Land Reclamation Board and Office's review and decision or appeals process, you may contact the Office at (303) 866-3567. Certification: As an authorized representative of the applicant, I hereby certify that the operation described has met the minimum requirements of the following terms and conditions: 1. To the best of my knowledge, all significant, valuable and permanent man-made structure(s) in existence at the time this application is filed, and located within 200 feet of the proposed affected area have been identified in this application (Section 34-32.5-115(4)(e), C.R.S.). 2. No mining operation will be located on lands where such operations are prohibited by law (Section 34-32.5-115(4)(fl, C.R.S.; 3. As the applicant/operator, I do not have any extraction/exploration operations in the State of Colorado currently in violation of the provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials (Section 34-32.5-120, C.R.S.) as determined through a Board finding. 4. I understand that statements in the application are being made under penalty of perjury and that false statements made herein are punishable as a Class 1 misdemeanor pursuant to Section 18-8-503, C.R.S. This form has been approved by the Mined Land Reclamation Board pursuant to section 34-32.5-112,CR.S., of the Colorado Land Reclamation Act for the Extraction of Construction Materials. Any alteration or modification of this form shall result in voiding any permit issued on the altered or modified form and subject the operator to cease and desist orders and civil penalties for operating without a permit pursuant to section 34-32.5-123, C.R.S. Signed and dated this S‘itvday of Ak 01 S �" . Sc\ar rAAiaisAp1/4% uL Applicant/Operator or Company Name Signed: Title: Kevin Jeakins, Vice -President State of CO ►r 4. d � County of imAd )ss. If Corporation Attest (Seal) NO SEAL/NO CORPORATE SECRETARY - This is a Limited Liability Company Signed: Corporate Secretary or Equivalent Town/City/County Clerk The foregoing instrument was acknowledged before me this 1 % day of 1On, by JKtvkdt4K"5 as v P JESSICA HOOVER NOTARY PUBLIC STATE OF COLORADO NOTARY ID 20044035571 MY COMMISSION EXPIRES OCTOBER 4, 202 iatWitttE of R&g*orM44€r4At l,L My Commission expires: I V I 2 SIGNATURES MUST BE IN BLUE INK You must post sufficient Notices at the location of the proposed mine site to clearly identify the site as the location of a RAPTOR MATERIALSusc 8120 Gage Street • Frederick, CO 80516 Bus: (303) 666-6657 • Fax: (303) 666-6743 Wednesday 08 March 2023 To: Robert D. Zuber, P.E. Environmental Protection Specialist Colorado Division of Reclamation Mining and Safety Office of Mined Land Reclamation (OMLR) 1313 Sherman Street, Room 215 Denver, Colorado 80203 From: Garrett C. Varra, General Manager Raptor Materials, LLC 8120 Gage Street Frederick, Colorado 80516 Subject: Two Rivers Sand, Gravel and Reservoir Project, File No. M-2022-013, 112c Permit Application Adequacy Review #4 REPSPONSE Dear Rob, The Division of Reclamation, Mining and Safety (Division/ORMS), Office of Mined Land Reclamation (OMLR); reviewed the contents of the Original 112c permit application for the Two Rivers Sand, Gravel and Reservoir Project (TRP), File No. M-2022-013 and submitted comments via Adequacy Letters of 24 June and 5 August 2023 which were responded to by Raptor Materials on 6 September 2022. Raptor Materials received a Second Adequacy Review dated 17 October 2022 which were responded to by Raptor Materials on 4 January 2023. In addition to the Second Adequacy Review dated 17 October 2022, DRMS on November 17, 2022 provided an additional comment on the berm failure analysis included in the application. Raptor submitted a supplemental response to the Second Adequacy on 2 February 2023 addressing excavation setbacks from the South Platte and Big Thompson rivers. Raptor Materials received Third Adequacy Reviews dated 09 February, 10 February and 14 February 2023, which were responded to on 24 February, 2023. A Fourth Adequacy Review was received. Raptor's Fourth Adequacy response is confined to the outstanding items. Raptor Materials received Fourth Adequacy Reviews dated 6 March 2023. The items requiring a response in our fourth adequacy response are addressed by exception. Raptor's responses below follow the comments from the adequacy review and are highlighted in blue font for clarity. 6.4.7 Exhibit G - Water Information Item 46) To ensure that the Two Rivers project does not impact the hydrologic balance of the rivers, the application needs to include a water quality monitoring plan, specifically for the alluvium. The groundwater monitoring plan should be developed in accordance with Rule 3.1.7(7)(b) and should include a Quality Assurance Project Plan (QAPP) for the collection of groundwater samples. The plan should provide mitigation steps if there is an exceedance at a groundwater or surface water monitoring location. Potential impacts to quality and/or quantity the nearby domestic wells should also be addressed. A copy of the Division's Groundwater Monitoring and Protection Technical Bulletin has been included as an enclosure to this letter for your reference. • RM needs to address a discrepancy between a statement and the Water Information Map in Exhibit G. In the February 23rd letter responding to adequacy items, RM stated that the Dos Rios well is north of the Big Thompson River. However, the map indicates that it is south of the river, and the coordinates listed on the map for this well also suggest that it is on the south side. Also, please check the scale on this map and revise as appropriate. Raptor has confirmed the Dos Rios well is north of the Big Thompson River. There are minor although not insignificant in the context of a groundwater evaluation discrepancies between the Colorado DWR Well Permit GIS database maps and actual locations. This appears to be DWR maps are based on locations set out in original permit applications. Raptor was aware of this conflict and had opted to keep maps in the application consistent with those on the DWR GIS system. Raptor maps have now been updated to reflect GPS coordinates of the well locations where available. Exhibits C1, Existing Conditions Map, and G, Water Information Map have been updated, along with Addendum 16 to Exhibit G providing revised Water Well Detail. The scale on Exhibit G, Water Information Map has also been corrected. • The Contingency Plan in the current submittal is not sufficient. RM needs to add a Groundwater Assessment and Mitigation Plan to Exhibit G addressing potential impacts to nearby wells, including the Shable and Lafarge wells (and possibly the Dos Rios well depending on location). o The plan must state that if RM receives a complaint from a well owner, the following steps shall be taken. 1) RM will notify the Division within seven days of the complaint. 2) After the Division is notified, RM will review the data and available information and submit a report to the Division within 30 days. The report will include documentation of discussions with the water user who made the complaint and a review of baseline data from the affected well and vicinity to evaluate whether changes were due to seasonal variations, climate, mining, or other factors. The report will identify the extent of potential or actual impacts associated with the factors. 3) If mining or reclamation activities by RM are determined to be a significant contributing factor to the groundwater impacts, the impacts will be mitigated by RM to the satisfaction of the Division. o The mitigation actions discussed in the plan should include one or more of the following: the use of a recharge pond (or ponds), improvements to the wells, and the supply of alternative sources of water. Raptor consultant AWES have updated the Groundwater Monitoring Plan, Raptor Two Rivers Mine, Section 2.5, Contingency Plan and Abatement, to address this comment. The revised Groundwater Monitoring Plan is provided as Addendum 15 to Exhibit G. • The Division recommends that RM obtain agreements with well owners who may be impacted by the TRP. These include the owners of the Shable and Lafarge wells, and possibly the Dos Rios well owner. The agreement shall state that RM will mitigate any negative impacts to these wells. Raptor consultant AWES have addressed this comment in the updated the Groundwater Monitoring Plan, Raptor Two Rivers Mine, Section 2.5, Contingency Plan and Abatement. The revised Groundwater Monitoring Plan is provided as Addendum 15 to Exhibit G. 6.4.12 Exhibit L - Reclamation Costs Item 51) This exhibit should be updated, as necessary, to match any revisions to Exhibits D and E, per the adequacy items for those sections. This includes details on structures. • An apparent error in the text should be addressed. Regarding the dewatering calculations on page 5, the total cost has likely not been updated. The Division calculates that the value should be $12,427.45 rather than $12,352.35. Please revise this or explain the apparent error. Raptor have corrected the error and updated Exhibit L. Please find attached the following documents as our response: - Current 112 Form (for reference, unchanged from previous) - Updated Exhibit Cl Map- Existing Conditions - Updated Exhibit L - Reclamation Costs - Updated Exhibit G Map - Water Information Revised Groundwater Monitoring Plan (Exhibit G, Addendum 15) - Revised Water Well Detail (Exhibit G, Addendum 16) The current decision date is 31 March 2023. Regards Ampv-Arr.- Garrett Varra General Manager Page Ii 6.4.12 EXHIBIT L - Reclamation Costs (1) 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. (2) 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: $ 12,427.45± Site Discharge $ 130,002.96± Total Grading per Extraction Front. $ 321,033.08± Total Liner Construction Expense $ 20,359.20± Total Re -soiling (inc. Processing area) $ 5,449.27± Total Re -vegetation Expense (inc. Processing area) $ 74,552.68± Total Processing/Conveyor Removal Expense $ 563,824.65± $ 10,000.00± $ 573,924.65± $ 139,640.23± Sub -Total Possible Mobilization and Demobilization Costs (pending OMLR estimate) Sub -Total Direct Costs Possible Indirect Costs Pending DRMS Indirect Costs © 24.335 % $ 713,464.87± of Total Reclamation Costs Grand Total — Financial Warranty Amount — Pending OMLR Review and estimates including estimated expenses for State of Colorado Mobilization and Demobilization and other `Indirect' cost determinations by the Office. SUMMARY OVERVIEW: Table 1 - Primary Data on Area of Total Proposed Affected Lands and Reclaimed Features: Entity Central Field North-West Field Combined Extraction — finished basin (Acres) 162.57 41.04 203.61 Static Water Area — surface (Acres) 151.38 36.28 187.66 Static Water Area — elevation (ft.) 4,673 4,675 Basin Level (Acres) Lands Above Static Water 11 . 19 4 . 7 6 15.95 Basin Area Volume (cu.yds.) 7,278,366 1,649,937 8,928,303 Static Water Level Volume (Gallons) 1, 470, 040, 694 333, 244, 376 1, 803, 285, 070 Static Water Level Volume (Acre Feet) 4,511.4 1,022.7 5,534.1 Plant Processing Area (Acres) 15.76 Wash Pond Area (Acres) 5.60 Total Level Lands Above Static (Acres) Water 37.31 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 12 6.4.12 EXHIBIT L - Reclamation Costs NOTE Well: All lands within the 409.234± 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 on -set 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 Right -of -Ways are offset from operations and while they may fall within the 409.234± acre parcel — are excepted from the permit conditions to the extent of their approved setbacks. The following estimates utilize assumptions based upon the pre -disturbed state of the application 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 Colorado Office of Mined Land Reclamation (OMLR), as indicated. RECLAMATION EXPOSURE: 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 utilized to create a reasonably close estimate. The per unit basis from Division records are shown along with other sources used or referenced to determine unit costs, at the back of this exhibit. METHOD OF EXTRACTION: Before concurrent grading, resoiling, and revegetation for reclamation can commence, a perimeter keyway (dewatering trenchl) must first circumnavigate the area where the perimeter slopes form along the extraction limits. For Two Rivers, this includes four sequential areas of extraction: • 121.86± Acres - Central Field — Center Section • 15.58± Acres - Central Field — North-East Section • 25.09± Acres - Central Field - West Section • 41.04± Acres - North-West Field 1 Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 13 6.4.12 EXHIBIT L - Reclamation Costs Exhibit L: Financial Warranty Map, shows Initial Extraction will begin in the yellow hatch area shown on the Exhibit L Map, comprising 16± acres. The direction of extraction will follow the perimeter of the extraction limits in order to establish the perimeter keyway for the 121.86± acre Center Section of Central Field. The perimeter extraction comprises approximately 70.21± acres and will leave an approximately 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The initial extraction area is bordered to the South adjacent to a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). Extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed under Exhibit D: Extraction Plan. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary settling basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H:1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.OOH:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and excise the bed dimensions where the resulting channel is sufficient to convey the groundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape and size presented. 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. UNITS OF DISTURBANCE: The life of the operation is based upon a base rate of extraction approximating 8.0± acres of disturbance in a given year. This time will pulse with the market and may average 8.0+ acres, but could be faster or slower. Starting out, initial warranty necessary to cover the costs of reclamation for the extent of disturbance in a given year will also vary in time and circumstance, as the initial disturbance is generally less at the onset. So, a rate of disturbance can be estimated and the warranty adjusted incrementally with time and circumstance. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 14 6.4.12 EXHIBIT L - Reclamation Costs Starting out in the initial projected 5 years of Operations, and incrementally thereafter, necessary warranty can be estimated and adjusted in incremental Units based upon the projected Life of the Operation. Essentially, a 28-33± year Life of Operations assumes a rate of extraction of approximately 8.0± acres per year. Considering the Mining -Regrading Schedule included as Table E-1 in Exhibit E, and the general development concept shown on Exhibit L: Financial Warranty Map, Raptor estimates for the initial 5 -year period, development of an initial 40 -acre excavation and development of a "Core" area in the Center Section of Central Field will result in creation of approximately 6,200 -foot of external perimeter pit wall. No reclamation or lining is anticipated in the initial 5 -year period. Raptor estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H:1 V and a 2,180 -foot wall at 1.25:1V slopes. It is important to note that the financial warranty estimates the closure cost of the operation at the end of the expected first 5 -year period. It is assumed in this initial estimate that no reclamation activities (regrading, lining, topsoiling) will take place. The cost estimate then reflects reclaiming the projected excavation at that point in time. The actual extents and shape of the excavation may change, and actual progress will be addressed in the annual reports. Raptor will update this Exhibit L, the reclamation cost estimate, and any other exhibits as required for purposes of determining financial warranty prior to disturbance reaching the limits projected in the initial 5 years of Operations as described in this Exhibit and shown conceptually on Exhibit map C-2 and L. In the following breakdown of components for estimating reclamation cost, factoring of the 5 -year projected disturbance against the final pits is used where appropriate to obtain a reasonable estimate of work required. 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: Raptor assumes that the pit would be in an unlined state and if operations had ceased, would recharge to static water level requiring dewatering of the pit to allow reclamation operations to be completed. 100 hp. 4,500 gal./min. pump x (up to) 3 pumps @ 24 hours/day VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page IS 6.4.12 EXHIBIT L - Reclamation Costs Volumes: Total Central Field Volume at Static Water Level Area of Central Field at Static Water Level = Central Field average storage = For the initial 5 -year excavation: 1,470,040,694± gallons 151.38 surface water acres 9,710,931 gal./acre 9,710,931 gal./acre x 40.0± acres 388,437,229± gallons Total Cost for initial 40.0± acres of Discharge = 388,437,229E ± gallons x $ 0.000026/gal. discharge (refer to Kurtz est. utilizing similar pump and rates.) $ 10,099.37 -Initial Discharge Cost for 40± acres It is assumed that ongoing dewatering will be required during reclamation of the pit and Raptor has allowed for 30 days once the pit has been dewatered. The estimated inflow rate to the fully excavated pits has been estimated at 15,190,000 gallons/day. The estimate is based on modeling of the groundwater by AWES in support of Exhibit G: Water Information. A memo summarizing the basis of the estimate is attached as a new addendum. The initial 40 -acre excavation area represents approximately 19.6% of total extraction area (203.acres). Total discharge to maintain dry conditions for reclamation then is: 15,190,000 gallons/day x 19.6% x 30 days = 89,541681± gallons Cost for 30 working days of Discharge = 89,541,681± gallons x $ 0.000026/gal. discharge (refer to Kurtz est. utilizing similar pump and rates.) $ 2,328.08 30 days Dewatering Cost for 40± acres $ 12,427.45 Total Dewatering Cost for 40± acres Please Note: 2The basins will be lined or otherwise segregated from the area groundwater, in order to liberate the water otherwise retained to supplement loss from evaporation in the unlined state. 2 Adequacy Item 28 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.12 EXHIBIT L - Reclamation Costs GRADING: As stated above, Raptor conservatively estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H: 1V and a 2,180 -foot wall at 1.25:1V slopes along the extraction limits flanking WCR 396; and 2H:1V along the South Platte River levee, as shown on Exhibit D: Extraction Plan, and Exhibit L: Financial Warranty Map. Actual volume of fill required to grade at 3H:1V for a respective cut slope is determined in the graphics, below. Square Foot volume of backfill x linear feet of slope divided by 27 will yield the required cubic yards needed for each section of highwall. A rate per Loose Cubic Yard of fill taken from the previously approved values determined by the OMLR, is used to better ensure the integrity of the resulting values. G se::: A 1 .9 0 3-: 1 V FINISHED GRADE )17;',/ F1Lt TO GRADE = 800 SOIFL VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 17 6.4.12 EXHIBIT L - Reclamation Costs DIAGRAM 2: 40.0'± C p pth O"C e 04 u/ FlU TO CR 1V FINISHED GRADE. ASE - 1,400SQ.FT Hauls are expected to be very short excavating material from the core area where material is readily available to establish final grade on those walls at 3H:1V and placed on the exterior walls to establish the required grades. It is estimated that there would be approximately 4,610 -foot of core and side slopes in addition to the 6,200 -foot extraction limit wall. Due to the very short hauls it may only require a wheel loader operating in load/carry/dump mode with a supporting Tracked Dozer. At most, the method of fill will utilize one (1) Excavator/Loader, two (2) Haul Trucks, together with a supporting Tracked Dozer and one (1) Sheep's Foot Compactor. The concept for establishing the regraded slopes for financial warranty purposes is shown in the following figure. NW FIELD = 41.04± ACRES 0 CENTRAL FIELD WEST SECTION -• INITIAL AREA OF EXTRACTION Extraction limit wall.k• Material backfilled to reduce slope to 3H:1V Material excavated from interior wall used as backfill on extraction limit wall Interior wall. Material excavated to reduce slope to 3H:1V �a 2 9 O,t n CENTRAL FIELD = 162.56± ACRES GENERAL MINING PROGRESSION Interior wall. Material excavated to reduce slope to 3H:1V T Material excavated from interior wall used as backfill j on extraction limit wall. _ ;....::::::..: •::.':: • NOTE WELL THE CORE AREA OF EXTRACTION MAY VARY IN SIZE, SHAPE AND EXTENT FROM THAT PORTRAYED DEPENDING UPON FIELD CONDITIONS NECESSARY TO CIRCUMNAVIGATE THE KEYWAY(S) WITHIN A DESIGNATED SECTION OR FIELD. artersort) rote O '\ 'ten, r� .. �O o CZ IExtraction limit wall. �� ;Material backfilled to r;''"'/` 'reduce slope to 3H:1V it: I lei! - ••_••_ D For estimate of financial warranty reclamation cost. material from interior walls is excavated reducing the slope to 3H:1V and that material is placed on the exterior extraction limit walls as backfill to establish 3H:1V slopes. CENTRAL FIELD CENTRAL SECTION GENERAL MINING PROGRESSION Interior wall. Material excavated to reduce slope to 3H:1V Material excavated from interior wall used as backfill on extraction limit wall. a^ iri .• r rim.`_ 1--� NOF 2H.1V CUT SLOPE �o .I:lrsrivniin/zi�'` Extraction limit wall. Material backfilled to reduce slope to 3H:1V 2H 7V CUT SLOPE avizrowarien Approach to regrading interior and extraction limit slopes for financial warranty purposes. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 18 6.4.12 EXHIBIT L - Reclamation Costs Assuming a mean depth of advancing cut of 1.25H:1V at the extraction limits of 40.0+ feet depth: 2,180± lin.ft. (extraction limit) x 1,400.00± sq.ft. (required fill — Diagram 1, above) 113,037± LCY 113,037± LCY x $ 0.56± per LCY. $ 63,300.74± fill along an 2,180 -foot extraction limit cut at 1.25H:1V. Assuming a mean depth of advancing cut of 2:1V at the extraction limits of 40.0± feet depth: 4,020± lin.ft. (extraction limit) x 800.00± sq.ft. (required fill — Diagram 1, above) _ 119,111± LCY 119,111± LCY x $ 0.56± per LCY. $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction limit cut at 2H:1V $ 63,300.74 Sub Total -Grading to 3H:1V along an 2,180 -foot extraction limit cut at 1.25H:1V. + $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction limit cut at 2H:1V. $130,002.96 Total — Initial Grading. Liner Installation: Raptor has made allowance for liner installation on the regraded slope. Assumptions are that a 4 -foot -thick liner will be keyed into bedrock at the base of the regraded slope and up the slope to approximately 5 -foot below the original surface elevation. The keyway dimensions in bedrock are assumed to be 4x4 -foot. For the exterior walls at extraction limits, the regrade and liner installation is as described in Exhibit E. For interior walls around the core, for the purposes of financial warranty estimate, regrading is performed as described above, and then the liner will be installed. Typical liner installation as described previously in Exhibit E is shown in the following figure. The volume of liner material required will vary according to the slope of the wall the liner is installed on. The volume of liner material is conservatively estimated based on the perimeter length at the top of the liner. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 9 6.4.12 EXHIBIT L - Reclamation Costs Typical Liner and Regrade for Extraction Limit Wall — Final Reclamation Original ground surface Topsoil Static Water Level Sequence 1. In cycles • Install liner in 6" lifts • Backfillto3H:1V 2. Replace topsoil Regraded slope at 3H:1V Backfill material Unexcavated Perimeter Wall (slope 1.25H:1V) Typical Liner and Regrade for Extraction Limit Wall Raptor conservatively estimates for Financial Warranty purposes an approximately 4,020 - foot wall excavated at 2H:1V, a 2,180 -foot wall at 1.25:1V slopes, and a 4,610 -foot wall at 3H:1V. Perimeter liner at 2H:1V, 4,020 lin.ft. x 78 sq.ft./ft x 4 ft. / 27 = 46,610 CY of liner placed at an estimated cost of $2.20/CY = $ 102,541.11. Perimeter liner at 1.25H:1V, 2,180 lin.ft. x 56 sq.ft./ft x 4 ft. / 27 = 18,095 CY of liner placed at an estimated cost of $2.20/CY = $ 39,808.46. Perimeter liner at 3H:1V, 4,610 lin.ft. x 111 sq.ft./ft x 4 ft. / 27 = 75,590 CY of liner placed at an estimated cost of $2.20/CY = $ 166,298.33. Keyway at the base of the 3:1 slope is estimated at 9,500 lin.ft. x 16 sq.ft. / 27 = 5,630 CY of liner placed an estimated cost of $2.20/CY = $12,385.19. $ 321,033.08 Total Liner Installation Cost NOTE: This is a conservative approach to the estimation of reclamation cost for financial warrant at the projected 5 -year disturbance. The distance of 2H:1V wall is maximized which has a higher lining cost than wall at 1.25H:1V. Also, if sufficient backfill material were available or accessible on site from either topsoil or overburden material in temporary stockpiles, or readily accessible from bedrock exposed, backfilling all the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I10 6.4.12 EXHIBIT L - Reclamation Costs slopes with available material and installing the liner in typical fashion as described in Exhibit E would be significantly less expensive. Soil Demand AND Re -soiling of Affected Lands (refer to Exhibit D): Soil demand is limited to the cut basin slopes remaining above the static water level. For Central Field, the total area above the anticipated static water level of the basins is 11.19 ± acres. To estimate the area involved in resoiling the Center Section of Central Field — we'll use a percentage of the total perimeter length of the extraction limits involved: 14,311 Total perimeter length Central Field 6,200 External perimeter length Center —Central Field —extraction limits 4,610 Internal perimeter length on core area 10,810 Combined perimeter length 10,810 : 14,311 = 76% 11.19 acres x 76% = 8.5± acres requiring resoiling and revegetation (see Establishment of Vegetation over Affected Lands, below. At a depth of 0.5± feet, total volume = 8.5± acres x 0.5± feet of soil replacement, is: 8.5± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 6,857± cu.yds. @ 0.5' depth. The majority of soil placement can occur using the average placement distance of 600 ft., or less along embankments, (utilizing the same assumptions utilized at either Kurtz or Heintzelman Projects). 6,857± cu.yds of soil demand x $ 0.843 per LCY. $ 5,780.17to replace 0.5± feet of soil over the existing affected lands remaining above the anticipated final water level at the Center of Central Field along the perimeter cut slopes at the extraction limits. 3Although Raptor does not anticipate the areas of soil replacement to be extensively compacted, an allowance for disking or scarifying 25% of the area at a cost of $28.5/acre. 8.5± acres x 25% x $28.50/acre = $60.60 3 Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page Ill 6.4.12 EXHIBIT L - Reclamation Costs The processing area will also require soil replacement over the entire 21.35 acre area. 21.35± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 17,222± cu.yds. @ 0.5' depth. 17,222± cu.yds of soil demand x $ 0.843 per LCY. $ 14,518.43 to replace 0.5± feet of soil over the existing affected lands in the processing area. 4Raptor assumes disking or scarifying this entire area at a cost of $28.5/acre. 21.35± acres x 100% x $28.50/acre = $608.48 $ 20,359.20 Total Soil Replacement Cost NOTE: Total Soil Demand for the entire Central Field and the North-West Field: 11.19± Acres Central Field 4.76± Acres North-West Field 15.95± Acres Total — Combined Soil Replacement Demand 15.95± Acres x 43,560 sq.ft./acre : 27 cu.ft./cu.yd. = 25,732.67± cu.yds. @ 1' depth.25,732.67± cu.yds. @ 1' depth soil : 2 = 12,866.33± total cu.yds soil required at 6 inches in depth at Central and North-West Fields for all basin slopes remaining above the anticipated static water level and below the extraction limits. Establishment of Vegetation over Affected Lands: The demand establishment of vegetation over the affected lands will also diminish proportionately with the planned extraction of the Tracts. For now, the total exposure is estimated as indicated above to be 8.5± acres for the Center Section of Central Field (see Soil Demand): NOTE: The cost for seed is estimated on Exhibit L - Table L-1: Primary/Preferred Re - vegetation Seed Mixture; however, the costs are known to fluctuate seasonally — and are estimates based on prior seasons. The seed mixture includes a substitute for mulch in the inclusion of a wheatgrass hybrid. The Division has historically agreed with and approved the inclusion of this hybrid as a substitute for mulch. The Optional Seed Mix will be used if the Primary Mixture fails, but costs less, so that cost is accounted for. These costs are as follows: 4 Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I12 6.4.12 EXHIBIT L - Reclamation Costs $ 58.72± Preferred Seed Mix x 8.5± acres $ 499.12± Sub -Total Seed The cost for applying seed is based upon information derived in proximity to the Northern Colorado economy. Costs for tilling, fertilizing and seeding are based upon estimates from Longs Peak Equipment Co. These costs, including labor, are reflected as follows: $ 25.00± per acre Tilling $ 20.00± per acre Fertilizing $ 20.00± per acre Seeding $ 65.00± per acre Total Application Cost per Acre. x 8.5± acres $ 552.5± Sub -Total — Application Costs $ 1,051.62± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or: $ 525.81± Sub -Total Re -seeding costs $ 1,577.43± Excavation Area Re -vegetation Expense Re -vegetation of the 21.35 acre processing area is also estimated. $ 58.72± Preferred Seed Mix x 21.35± acres $ 1,253.67± Sub -Total Seed $ 65.00± per acre Total Application Cost per Acre. x 21.35± acres $ 1,387.75± Sub -Total — Application Costs $ 2,641.42± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or: $ 1,320.71± Sub -Total Re -seeding costs $ 3,962.13± Processing Area Re -vegetation Expense $ 5,449.27 Total Re -vegetation Cost VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 03 6.4.12 EXHIBIT L - Reclamation Costs Processing Area and Decommissioning: Raptor has estimated decommissioning costs for the Processing Area and Conveyor that will deliver mined material to that area. All plant and equipment in the processing area is portable and would have more value that the cost of loading and removing it. Decommissioning will involve the removal of concrete pads for processing equipment, concrete supports for truck scales and temporary buildings, and the conveyor infrastructure and belting. Three 12 -inch -thick concrete pads are assumed in the processing area with dimensions 15- x 30 -feet, 15- x 60 -feet, and 15- x 25 -feet. Demolition and removal costs are estimated at $1.70/sq.ft. for 12" concrete pads. The truck scale will have concrete supports with an estimated volume of 10 CY. Additionally temporary buildings for the scale house/site entrance area and processing area will have concrete support blocks with estimated at 8 CY of concrete. Estimated costs for the concrete supports is $65.00/CY. Concrete pads: 1,725 sq.ft. x $1.70/sq.ft. _ $ 2,932.50 Concrete supports: 18 CY x $65.00/CY = $ 1,170.00 The decommissioning cost estimate for the conveyor structure is based on previous estimates provided by Divide Construction for other Raptor (previously Varra) operations and presented in Financial Warranty estimates. The costs have been updated to current using US Army Corps of Engineers Civil Works Construction Cost Index System (CWCCIS) indices. The regular conveyor structure in 40 -foot sections supported on concrete blocks is estimated to be 1,787± lin.ft. with an additional three extended span elevated truss sections 125 -foot in length for crossing WCR296 and the Big Thompson River. Decommissioning costs for the regular conveyor structure is estimated at $ 8.75/lin.ft. and the extended spans at $ 18,270.00 each. Conveyor decommissioning: 1,787± lin.ft. x $ 8.75/lin.ft. _ $ 15,640.18 Conveyor extended spans: 3 x $ 18,270.00 each = $ 54,810.00 $ 74,552.68 Total Processing and Conveyor Decommissioning Cost VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page O4 6.4.12 EXHIBIT L - Reclamation Costs OTHER MISCELLANEOUS COSTS: 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 $10,000. Demolition of Structures: None. Building Permits for structures will be obtain where required from the Weld County Building Department. Please Note: Since there is no possibility of the applicant in fully reproducing the Division's methods, utilizing similarities from past OMLR LR 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. Extraction of the Core following completion of the Perimeter Extraction Keyway VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Two Rivers Sand Gravel Reservoir Project Exhibit G Addendum 16 (supercedes Addendum 11) Water Well Detail Permit Number Latitude Longitude Owner Permit Status Construction Date Permit Category Use(s) 13950 -R -R 40.352074 -104.769322 DOS RIOS ESTATES WTR CO Well Constructed 10/11/1989 General Purpose Irrigation 270-R 40.34165 -104.788031 SHABLE, ALVA L Well Constructed 6/20/1955 General Purpose Irrigation 8303 -R -R 40.342074 -104.783461 Well Constructed 11/14/1989 General Purpose Irrigation VARRA COMPANIES INC (VARRA, GARRETT) 8304-R 40.343489 -104.779183 Well Constructed 6/30/1952 General Purpose Irrigation VARRA COMPANIES INC (VARRA, GARRETT) 320422- 40.339043 -104.78599 LAFARGEHOLCIM / AGGREGATE INDUSTRIES Well Constructed 1/22/2021 Monitoring/Observation Monitoring/Sampling 79087--A 40.339404 -104.776829 SORIN NATURAL RESOURCES PARTNERS LLC Well Constructed 5/12/1975 Residential Domestic 1282 -R -R 40.340933 -104.762048 DIXIE WATER, LLC (WHITE, MICHAEL B.) Well Constructed 4/23/1976 General Purpose Irrigation 78568-F 40.349274 -104.761489 SORIN NATURAL RESOURCE PARTNERS LLC Well Constructed 9/24/2014 General Purpose Industrial NOTE: Where available, GPS coordinates from the CO DWR Well Permit GIS database are used, otherwise coordinates are from Permit Application AMERICAN WATER ENGINEERING SERVICES, LLC GROUNDWATER MONITORING PLAN RAPTOR TWO RIVERS MINE 14822 396 HWY EVANS, COLORADO AWES PROJECT # 2022-RM-P124 March 2023 Prepared for: Raptor Materials, LLC. 8120 Gage Street Frederick, CO 80516 Inr t v Datetb/19/20111 lat 10.31/131" len. -1001. 112hh8"" - eW1692 ft eye alt 142,11) pit Prepared by: AWES, LLC 4809 Four Star Ct. Fort Collins, CO 80524 �swts 48C1 Four Star Court, Fort Collins, CO 8524 AWES, LLC Table of Contents 1.0 INTRODUCTION 1 1.1 Objectives 1 1.2 Background Information 1 2.0 GROUNDWATER MONITORING 1 2.1 Monitoring Well Installation 1 2.2 Groundwater Level Measurements 2 2.3 Chemical Analyses 2 2.4 Drawdown/Mounding Modeling 3 2.5 Contingency Plan and Abatement 3 3.0 ORGANIZATION AND STAFF ASSIGNMENTS 3 3.1 Project Personnel 3 3.2 Subcontractors 3 4.0 OVERVIEW - QUALITY ASSURANCE/QUALITY CONTROL 4 5.0 REMARKS 4 FIGURES Figure 1 - Site Location Map Figure 2 — Monitoring Well Location Map TABLE Table 1 Analytical Parameters APPENDIX Appendix A — Boring Logs Appendix B — Methods and Procedures AWES, LLC GROUNDWATER MONITORING WORK PLAN RAPTOR TWO RIVERS MINE PROJECT WELD COUNTY, COLORADO 1.0 INTRODUCTION This Groundwater Monitoring Plan (Plan) has been prepared by AWES, LLC on behalf of Raptor Materials, LLC (Raptor) for the proposed Two Rivers mine project located in Weld County, Colorado (Figure 1). The current mining plan includes dry mine gravel extraction from two pits that will encompass approximately 270 acres. This plan will be submitted to the Division of Reclamation, Mining and Safety (Division) as part of Raptor's mine permit application. 1.1 Objectives The objectives of this Plan are to identify potential liabilities with the extraction of aggregate under semi - saturated conditions. Specific objectives for the Raptor project are described below. • To determine the aerial extent of drawdown associated with mine dewatering; • To determine the effects of dry mine aggregate extraction on local hydrology and water quality; • To generate predictive models on possible adverse drawdown in adjacent domestic wells; and • To determine the effects of lined pit reclamation on the local groundwater flow regime. 1.2 Background Information The proposed gravel quarry is located in sections 3 and 4 of Township 4 North, Range 66 West and sections 33 and 34, Township 5 North, Range 66 West of the 6t" Principal Meridian. The surrounding land use consists of agricultural, rural residential and oil and gas gathering. The proposed mine area occupies an estimated 380 acres with an extraction area of 270 acres. The anticipated extraction depth will vary between 12 and 44 feet below grade. Information provided by geotechnical investigations, monitoring well water level data and water resource evaluation reports document the local and regional hydrogeology. In January 2015, 12 soil borings were drilled from ground surface to bedrock to determine the potential aggregate mass within the proposed mine boundary. These borings were completed as one -inch groundwater monitoring wells and the well locations are depicted on Figure 2. The depth to bedrock within the proposed mine pit boundaries varied between 12 and 44 feet below ground surface. In general soil conditions consist of less than one to six feet of top soil and sandy clay underlain by sand and gravel with occasional clay and poorly graded sand lenses. The coarse alluvial deposits are underlain by bedrock which consists of siltstone, sandstone and claystone. 2.0 GROUNDWATER_ MONITORING 2.1 Monitoring Well Installation As mentioned in January 2015, WesTest, LLC drilled 12 soil borings from ground surface to bedrock using hollow stem auger techniques and completed the borings as one -inch groundwater monitoring wells. The 1 AWES, LLC construction details of the monitoring wells were not reported in WesTest's summary report but are identified as one -inch monitoring wells by the operator. Boring logs are presented in Appendix A. 2.2 Groundwater Level Measurements All monitoring wells were surveyed to the nearest 0.01 foot for vertical elevation and to the nearest 0.5 foot for horizontal location. Groundwater level measurements in all wells have been measured by an electric water level indicator on a monthly basis since September 2015. Raptor will continue to measure water levels on a monthly basis during dewatering operations. After reclamation groundwater levels will be measured on a quarterly basis until the mine permit has been withdrawn. 2.3 Chemical Analyses Table 1 presents field parameters and laboratory analyses for samples obtained from one well selected as a compliance monitoring well. Water levels will be measured from all wells on a monthly basis. Five samples will be obtained from the compliance well on a quarterly basis will be analyzed for the parameters below to establish a baseline. The compliance well will be sampled annually thereafter. Table 1 —Analytical Parameters Parameter Analytical Method Units Water Standard Quality Frequency I Field Parameters pH Measurement Direct s.u. 6.5-9 Annual Specific Conductance Measurement Direct uS/cm N/A Annual Temperature Measurement Direct °F N/A Annual Water Level Measurement Direct Ft. N/A Monthly Laboratory Parameters Arsenic EPA 200.8 ug/L 10 5 quarters/annual Cadmium EPA 200.8 ug/L 5 5 quarters/annual Chromium EPA 200.8 ug/L 10 5 quarters/annual Copper EPA 200.8 ug/L 200 5 quarters/annual Lead EPA 200.8 ug/L 50 5 quarters/annual Manganese EPA 200.8 ug/L 50 5 quarters/annual Mercury EPA 200.8 ug/L 2 5 quarters/annual Nickel EPA 200.8 ug/L 100 5 quarters/annual Selenium EPA 200.8 ug/L 50 5 quarters/annual Uranium EPA 200.8 ug/L 30 5 quarters/annual Zinc EPA 200.8 ug/L 2000 5 quarters/annual Nitrate EPA 300 mg/L 10 5 quarters/annual Sulfate EPA 300 mg/L 250 5 quarters/annual Gross Alpha Particle EPA 900 pCi/L 15 5 quarters/annual Total Dissolved Solids EPA 160.1 mg/L Varied 5 quarters/annual AWES, LLC 2.4 Drawdown/Mounding Modeling Water level data will be used for drawdown and mounding analyses. The average of monthly water level data over a one year period will be input into the geostatistical software package Surfer®. Variations in pre - mining water levels will be presented on a two dimensional contour map and will be compared to numerical predictions and will be provided to the Division in an annual report which will be delivered during the first quarter after each sample year. All data and methods will be presented in the report. 2.5 Contingency Plan and Abatement As mine dewatering will create a groundwater sink it is highly unlikely that changes in groundwater quality will occur due to mining activities. As water levels will be measured on a monthly basis unanticipated groundwater drawdown can be predicted and evaluated for possible injury to off -site well owners. The extent of any abatement will be determined by negotiations with affected parties. Abatement actions if required may include one or more of the following: the use of a recharge pond (or ponds), improvements to the wells, and the supply of alternative sources of water. Raptor as described in Exhibit M, "Other Permits and Licenses" to the permit application will obtain a Well Permit from the Colorado Division of Water Resources as the excavation will expose groundwater. As part of the well permitting process, Raptor will seek to obtain agreements with well owners who may be impacted by the operation and reclamation of the mine. If Raptor receives a complaint from a well owner, the following steps shall be taken. 1) Raptor will notify the Division within seven days of the complaint. 2) After the Division is notified, or if the complaint is received by the Division and Raptor is notified, Raptor will review the data and available information and submit a report to the Division within 30 days. The report will include documentation of discussions with the well owner who made the complaint and a review of available baseline data from the affected well and vicinity to evaluate whether changes were due to seasonal variations, climate, mining, or other factors. The report will identify the extent of potential or actual impacts associated with the factors. 3) If mining or reclamation activities by Raptor are determined to be a significant contributing factor to the groundwater impacts, the impacts agreed to be attributable to Raptor will be mitigated by Raptor to the satisfaction of the Division. 3.0 ORGANIZATION AND STAFF ASSIGNMENTS 3.1 Project Personnel Ms. Tana Kersting of Raptor will serve as field coordinator and will be responsible for obtaining water levels and will perform or supervise water quality sampling. Mr. Garrett Varra of Raptor will provide senior review of field and analytical data and will serve as project coordinator. 3.2 Subcontractors Subcontracted services for this project will include Technology Laboratories, Inc., of Fort Collins, Colorado who will perform analytical services. 3 AWES, LLC 4.0 OVERVIEW - QUALITY ASSURANCE/QUALITY CONTROL Quality assurance (QA) is a management system for ensuring that all information, data, and decisions resulting from the project are technically sound and properly documented. Quality Control (QC) is the functional mechanism through which quality assurance achieves its goals. Quality control programs, for example, define the frequency and methods of checks, audits, and reviews necessary to identify problems and dictate corrective action to resolve these problems, thus ensuring data of high quality. Thus, a QA/QC program pertains to all data collection, evaluation, and review activities that are part of the project. The use of qualified personnel for conducting various portions of the project is of paramount importance to an effective QA/QC program. This pertains not only to qualified QA/QC specialists, but also to specialists in other fields, including hydrogeologists, air quality specialists, soil scientists, analytical chemists and other scientific and technical disciplines. The project manager should ensure that qualified specialists, primarily individuals with the proper education, training, and experience, including licensed or certified professionals, are directing and performing the various project activities. The same general principles apply to selection of contractors and/or outside laboratories. Another important aspect of the QA/QC program is the communication between the QA/QC organization and the project manager. Regular appraisal by the project manager of the quality aspects related to the ongoing project data -gathering efforts provides the mechanism whereby the established objectives may be met. QA/QC procedures should provide details relating to the schedule, information to be provided, and the mechanism for reporting to the project manager. Reports to the project manager should include: • Periodic assessment of measurement data accuracy, precision, and completeness; • Results of performance audits; • Results of system audits; • Significant QA/QC problems and recommended solutions; and • Resolutions of previously stated problems. 5.0 REMARKS The scope of work is based upon current available information and our understanding of this project. As the project develops, changes to the project scope of work may be required. If changes in the scope of work are dictated by the needs of the project, these changes will be presented prior to implementation. This Groundwater Monitoring Plan was prepared by AWES, LLC. Date Joby L. Adams, P.G., REM Principal/Hydrogeologist 4 Figure 1- Site Location Map Va= T_a Companies - Conrad Capital Group Property 7{:0 864_ °Ston a • 473, 4700-, U. 0 r5 1 MILE 0 1030 FEET 0 500 1000 METERS r r 1 9 • 4.7e3- - Pi • a 1O - P -P n7?,•7 • -K _ 4723 s _ S • Y 472O Map created with TOPO! ©2002 National Geographic (www_naticnaigeograp _carn./topo) 472.3 14.70'8 - 4728 • r • Well 4714 4727 . 'i:lelf s 4725 4722 C a APPENDIX A SOIL BORING LOGS ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 1 LOGS OF BORINGS PROJECT: Two Rivers Property WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 2 REPORT DATE: February 12, 2015 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 3 0 5 10 15 20 25 30 35 40 45 50 50/4 50/5 W = 16.1 DD= 114.0 0 5 10 15 20 25 30 35 40 45 50 50/4 W = 15.9 DD = 108.8 #200 = 67.3 Qu = 11,090 0 5 10 15 20 25 30 35 40 45 50 0 ..u. 150/5 W=14.1 DD= 118.6 Qu = 18,440 FIGURE 2 ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 4 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 5 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 6 0 5 10 15 20 25 30 35 40 45 50 0 25/12 W = 21.1 DD = 105.2 0 5 10 15 20 25 30 35 40 45 50 #4=57 #10 = 36 #40 = 16 #200 = 5.9 #4 = 84 #10 = 60 #40 = 22 #200 = 1.9 ////////////// ////////////// 50/3 W = 20.1 LL=38 PI = 14 #200 = 88.4 0 5 10 15 20 25 30 35 40 45 50 0 • 4 ........................... ........................... 50/5 W = 15.6 DD = 115.9 Qu = 18,050 1 50/0 FIGURE 3 ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 7 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 8 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 9 0 5 10 15 20 25 30 35 40 45 50 #4 = 60 #10 = 30 #40 = 11 #200 = 3.8 2 0 50/4 0 5 10 15 20 25 30 35 40 45 50 0 Mat MIMMTNIT /%%%%%%%%%%%%i ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// V.......................... .......................... I' 50/3 0 5 10 15 20 25 30 35 40 45 50 #4=86 #10=61 #40 = 18 #200 = 4.1 d 50/6 W = 24.6 DD = 99.3 Qu = 4,120 FIGURE 4 �T25T 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 10 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 11 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 12 0 5 10 15 20 25 30 35 40 45 50 U 150/3 0 5 10 15 20 25 30 35 40 45 50 0 ////////////// rrrrrrrrrrrrrr 11111111111111 rrrrrrrrrrrrr/ ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// "III", //////////////////////////////////////// /1/11/1/////// ////////////// ////////////// ////////////// ////////////// r///////////// ////////////// ////////////// i _ ................... .................... .................... .................... i 50/3 0 5 10 15 20 25 30 35 40 45 50 #4 = 69 #10 = 55 #40 = 22 #200 = 2.7 0 50/4 FIGURE 5 627 Sheridan Boulevard • Lakewood. CO 80214 303.975.9959 • office@westest.net LEGEND AND NOTES TWO RIVERS PROPERTY PROJECT NO.: 440515 i X 0 0 Topsoil Overburden, silty sandy CLAY to silty SAND, TRACE GRAVEL, stiff, slightly moist to moist, light brown to dark brown SAND, occasional GRAVEL, loose to medium dense, slightly moist to wet, tan to brown SAND, with gravel, loose to medium dense, slightly moist to wet, tan to brown SAND, gravelly, medium dense, wet, tan to brown Silty clayey SAND, loose to medium dense, moist to wet, brown CLAY, soft to medium stiff, very moist to wet, brown SANDSTONE-CLAYSTONE-SILTSTONE BEDROCK, interbedded, hard to very hard, moist to very moist, gray to brown CLAYSTONE BEDROCK, very hard, moist to very moist, gray SANDSTONE-SILTSTONE BEDROCK, interbedded, hard to very hard, moist to very moist, brown to gray Indicates bulk sample location Indicates 2" Modified California Barrel Sample location (ASTM D 3550) Water level at number of days indicated Caved at number of days indicated W Indicates % moisture (ASTM D 2216) DD Indicates dry density (pcf) (ASTM D 7263) Qu Indicates unconfined compressive strength (psf) (ASTM D 2166) 50/4 Location of sample; indicates that 50 blows with a 140 pound hammer, falling 30 inches, were required to drive a 2 -inch 1. diameter sampler 4 inches. The borings were drilled on January 27, 2015 through January 30, 2015, with a Longyear 66 Drill Rig and 4 1/4 I.D. Hollow Stem Augers. 2. The stratification lines represent the approximate boundary between soil types and the transition may be gradual. 3 4 The boring logs show subsurface conditions on the date and at the locations indicated. It is not warranted that they are representative of subsurface conditions at other locations and times within the project area. The boring locations were staked in the field by referencing to existing landmarks. The boring locations are adequate for purposes of this report, but should be considered as approximate for any other use. 5. Free water was encountered in the borings as indicated. Fluctuations in the water level should be anticipated. FIGURE 6 APPENDIX B METHODS AND PROCEDURES AWES, LLC METHODS AND PROCEDURES Groundwater Sampling All monitoring wells where groundwater is encountered will be sampled according to the protocols listed below. All pertinent information will be recorded on a sampling information form or field book. Field Protocol Step 1- Measure water level. Step 2 - A dedicated polyethylene bailer will be used to develop each well. Three well volumes will be evacuated from each well prior to sampling. Step 3 - Collect water samples. Water samples will be collected using a polyethylene bailer. Step 4 - Store samples in a cooler on ice for transport to the laboratory. Follow all documentation and chain - of -custody procedures. Step 5 - Clean equipment. Water level measurement equipment will be cleaned with ethanol followed by a deionized water rinse. Upon completion of soil or groundwater sampling, a chain of custody log will be initiated. A copy of the chain of custody will be returned to the project manager. Chemical Analysis All analytical parameters are presented on Table 1. Groundwater Elevation Measurements The following outlines our standard groundwater quality sampling methodology. Before purging any of the soil test borings or monitoring wells, water level measurements must be taken. Measuring Point Establish the measuring point for the well. The measuring point is marked on the north side of the top of the monitoring well riser. The top of the riser is normally a one or two inch casing inside a locked protective casing. The riser will generally be PVC pipe. The measuring point should be described on the groundwater sample collection record or field book. Access After unlocking or opening a monitoring well, the first task will be to obtain a water level measurement. Water level measurements will be made using an electronic water level indicator. Depth to water and total depth of the well will be measured for calculation of purge volume. AWES, LLC Measurement To obtain a water level measurement, lower a decontaminated electronic water level probe into the monitoring well. Care must be taken to assure that the electronic probe hangs freely in the monitoring well and is not adhering to the well casing. The electronic probe will be lowered into the well until the audible sound of the unit is detected and the light on the electronic sounder illuminates. At this time, the precise measurement should be determined by repeatedly raising and lowering the probe to obtain an exact measurement. The water level measurement is then entered on the groundwater sampling collection record sheet or field book to the nearest 0.01 feet. Decontamination The electronic probe shall be decontaminated immediately after use by wiping with isopropyl alcohol -soaked paper towels. If applicable always proceed in order from the suspected cleanest well or soil test boring to the suspected most contaminated one. Purge Volume Computation All monitoring wells will be purged prior to sample collection. Depending upon the rate of recovery, three to five volumes of groundwater present in a well or bore hole shall be withdrawn prior to sample collection. If a well or bore hole bails dry, the well or bore hole should be allowed to recharge and a sample taken as soon as there is sufficient volume for the intended analysis. The volume of water present in each well or bore hole shall be computed using the two measurable variables, length of water column in soil boring or monitoring well and diameter. Purging and Sample Collection Procedures Bailing • Obtain a laboratory decontaminated disposable bailer and a spool of nylon rope or equivalent bailer cord. Tie a bowline knot or equivalent through the bailer loop. Test the knot for adequacy by creating tension between the line and the bailer. Tie again if needed. New rope will be used for every sample or purge. New clean latex gloves will be used when touching the rope or bailer. • Spread a clean plastic sheet near the base of the well. The plastic sheet should be of sufficient size to prevent bailer or bailer rope from contacting the ground surface. • Place the bailer inside the well to verify that an adequate annulus is present between the bailer and the well casing to allow free movement of the bailer. • Lower the bailer carefully into the well casing to remove the sample from the top of the water column, taking care not to agitate the water in the well. • Pour the bailed groundwater into a bucket. Once the bucket is full, transfer the water to a barrel and contain on -site. If no regulated substances are suspected the evacuated water can be poured on the ground if local regulations allow. AWES, LLC • Raise the bailer by grasping a section of cord, using each hand alternately. This bailer lift method will assure that the bailer cord will not come into contact with the ground or other potentially contaminated surfaces. Sampling Instructions for obtaining samples for parameters are reviewed with the laboratory coordinator to insure that proper preservation and filtering requirements are met. • Appropriate sample containers will be obtained from the contract laboratory. After samples are collected, they will be put on ice in coolers (4°C). Care will be taken to prevent breakage during transportation or shipment. • Samples collected by bailing will be poured directly into sample containers from bailers. The sample should be poured slowly to minimize air entrapment into the sample bottle. During collection, bailers will not be allowed to contact the sample containers. • Upon completion of sampling a chain -of -custody log will be initiated. Chain -of -custody records will include the following information: project name and number, shipped by, shipped sampling point, location, field ID number, date, time, sample type, number of containers, analysis required and sampler's signature. The samples and chain -of -custody will be delivered to the laboratory. Upon arrival at the laboratory the samples will be checked in by the appropriate laboratory personnel. Laboratory identification numbers will be noted on the chain -of -custody record. Upon completion of the laboratory analysis, the completed chain -of -custody record will be returned to the project manager. Field Cleaning Procedures For all equipment to be reused in the field, the following cleaning procedures must be followed: • Disassemble the equipment to the extent practical. • Wash the equipment with distilled water and laboratory -grade detergent. • Rinse with distilled water until all detergent is removed. • Rinse the equipment with isopropyl or methanol, making sure all surfaces, inside and out, are rinsed. • Triple rinse the equipment with distilled water. Laboratory Selection The project manager should consider the following factors when selecting a laboratory: • Capabilities (facilities, personnel, instrumentation), including: • Participation in interlaboratory studies (e.g., EPA or other Federal or State agency sponsored analytical programs); • Certifications (e.g., Federal or State); • References (e.g. other clients); Experience. • Turnaround time; and • Technical input (e.g., recommendations on analytical procedures). AWES, LLC The project manager is encouraged to gather pertinent laboratory -selection information prior to extensively defining analytical requirements under the project. A request may be made to a laboratory to provide a qualifications package that should address the points listed above. Once the project manager has reviewed the various laboratory qualifications, further specific discussions with the laboratory or laboratories should take place. In addition, more than one laboratory should be considered. For large-scale investigations, selection of one laboratory as a primary candidate and one or two laboratories as fall -back candidates should be considered. The quality of the laboratory service provided is dependent on various factors. The project manager should be able to control the quality of the information (e.g., samples) provided to the laboratory. It is extremely important that the project manager communicate to the laboratory all the requirements relevant to the project. This includes the number of samples and their matrices, sampling schedule, parameters and constituents of interest, required analytical methodologies, detection limits, holding times, deliverables, level of QA/QC, and required turnaround of analytical results. Field and Laboratory Quality Control General Quality control checks are performed to ensure that the data collected is representative and valid data. Quality control checks are the mechanisms whereby the components of QA objectives ore monitored. Examples of items to be considered are as follows: 1. Field Activities: • Use of standardized checklists and field notebooks; • Verification of checklist information by an independent person; • Strict adherence to chain -of -custody procedures; • Calibration of field devices; • Collection of replicate samples; and • Submission of field blanks, where appropriate. 2. Analytical Activities: • Method blanks; • Laboratory control samples: • Calibration check samples; • replicate samples; • Matrix -spiked samples; • "Blind" quality control samplers; • Control charts; • Surrogate samples; • Zero and span gases; and • Reagent quality control checks. Raptor Materials, LLC. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 Thursday 2 February 2023 To: Weld County Clerk to the Board 1150 O Street Greeley, Colorado 80632 From: Bradford Janes, Professional Forester Liaison, Interdisciplinary Affairs Subject: Raptor Materials, LLC. (formerly Varra Companies, Inc.) Two Rivers Sand, Gravel and Reservoir Project, File No. M-2022-013, 112c Permit Application RECEIVED FEB 2 4 2023 WELD COUNTY COMMISSIONERS (Re-sobM:-,9e ) • Correspondence of 1 February 2023 from Raptor Materials, LLC., to the Colorado Office of Mined Land Reclamation, and attending Exhibits and Maps. Attachments: • Current 112 Form • Updated Exhibit D - Extraction Plan • Updated Exhibit E - Reclamation Plan • Updated Exhibit G - Water Information • Updated Exhibit I/J - Soils Information • Updated Exhibit L - Reclamation Costs • Updated Exhibit CI Map- Existing Conditions • Updated Exhibit C2 Map- Extraction Plan • Updated Exhibit F Map - Reclamation Plan • Updated Exhibit G Map - Water Information • Updated Exhibit 1/J Map - Soils and Vegetation • Updated Exhibit L Map - Financial Warranty) Your signature and/or official stamp, below acknowledges receipt of the above referenced materials included with this correspondence. The material should be added to the identified Application, as originally submitted to the Weld County Clerk to the Board, and made accessible for public review. 1 PAGE OF DOCUMENT INCLUDED IN PAPER FILE. REMAINDER RETAINED ELECTRONICALLY IN TYLER. Received On , 2023 RECEIVED By: FEB 02 2023 (Erro, W:t8 svioAl+,-e.d FIoSI, ()ewe) Office of the Weld CAdi R5oard of County Commissioners Greeley, Colorado Pv b I : c Rev :e,) 03/13/23 ccTL(TP/KW0A/10/0A), PbJ(cH/re/m4/oo) 03 /06/23 2023-0651 Water Wee anal Permit Number Latitude longitude Owner Permit Status Construction Date Permit Category Use(s) 13%O-R•R 40.35129 •104.76911 DOS RIOS ESTATES WTR CO Well Constructed 10/11/1989 General Purpose Irrigation 27OR 40.342653 -104.78573 SHARE, ALVA I. Well Constructed 6/20/1965 General Purpose Irtlgallott !�{ i r 1. r ` A 10.3x2343 IOd.7824$ VARM COMPANIES INC GARRETT) 7 • \ i $303-A• • (YARRA, Well Constructed 31/28/1989 General Purpose Irrigation ! : :` +�� . ` .". . ' 830I 10.342642 -1tN 78099 YARRA COMPANIES INC GARNETTI Well Constructed 6/30/1952 General 1� .,�,� -R WARM. Purpose Irrigations '`� i > 120122- 40.339083 104 - 7+3599 IAFARt3EHOlCIM/ 0.GCIIIEGATE INDUSTRIES Well Constructed 1/2212021 Monitoring/Observation Monttwirg/Sam li >' \'�- k ., i / . , - l� "' -)- OS7••A 40.339404 •104.77683SORIN NATURAL RESOURCES PARTNERS EEC Well Constructed S/12/1975Residential �- S --'' �� Domestic \ , • \� 12d7,R.R 40 341719 10/.76131 OIX1E WATER, LLC Well Constructed 4/23/1976 General Purpose Inigatlon _ f � i' 78568-F 40_349874 -104.76147 SORIN NATURAL RESOURCE PARTNERS 11C Weil Constructed 9/24/2014 General Purpose Industrial —R t ' ` y '.J1 ^-S—�'-' Ara • 1 < , ; - t .—_ I / :.p n.. J 1 _ - t t • kv± l ✓ ► _ • _ r r--.---1—• _ —mam. / — \ t . i Iraki t ( i .... \mot yl tr', \ • 1 -- r 15 t•.,.... if P ti -A1 r ` ` _ .10 4 . • • �_ yr1b- �.y • .- a a 7 �I AMY• . it ��"- ` 1 ��r.'»'_.� G...�. ..--a.-�—. {µ. I n yl ` 1. 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I', jft .. 3--22144 :.: ` • ;. a •••••.• am t•tilt-S .ra .r•9 matte' NI Matt. n-• tame ? a•_ km Gas' Mat _ - �• VP'Wrlll isn't *1'S rtr_w a :11YY•!f. wawa. o .•-•e ill_rw e _ _-__ - �- ._— scat. • n. fl MM_ al M LENSrY .fif !• I mar •- l• twos. r•..e r{I1gr a •i. _• Y w ger 41.9 ._a___• S• a. prep IY seals rwsr earn -MM •_FlPwa nl_1M'am91F a.fra a., -r. pan on. Nil _• 2♦ur fill eann4•110 r.11- and wid a-9 •} 0 .MIM rill airs. Y1 IrlM:JI Wllintr.l v....• Ja M91Mti• •tnlaaalM_r intmina w.Mae ,a r. IPIwM m rw_ •mratr. a IA_ SLIM• StRi_-SIMI Y•►! 1 war .r7 _• a -r a•mip .aI•am-• S•• Yt juaN m _a►s 1yaa.'. •,, :stag, m at. as *SSa e1Atat wttluAls tit Ina east awn isl[O[CI'. Two Rivers Sand, Gravel and Reservoir Project NOTES Ora,,,, by. Mr Thompson Checked by. P. C. Chrlatenoen arse[ 1 Inch 400 feet bAtC: 01 November 2021 mesa Mould Salk °RA*4tk Exhibit C-1: Existing Conditions Map RCMSIaN: 22 Februar 2022 r 4. -a-a PAM. —1— Of —J--_ oM•• . r....... t I ` — lava — - - �. agOUND.Jeoee1 • ..... --. --� - TOP PIPP•M11 51 -.N .. - - ----. ..�.--.'"---..___.--._ - - _ _ -. 1 - - ` ` WASH POND .. �-_ '• ' - • 5.60± ACRES .-'., i MATERIAL PROCESSING I AREA = 15.76± ACRES , SUBJ. TO CH .;GE; f 3 1 l -• ... t' .1 '• .a rw goo ,,-...1.M+•M• ✓'R' ,..: •� MY • 0 -i�-•.'r✓'.�'.+. t�4-.f" %�y.S `f V . .�' � I- p pLP ,p '✓ ..r E .• TyOMA ill ..... L J �" .---' _ -f"� -- �= "� \ \ f �; S.Y -t J 4 SOIL STOCKPILES STOCKPIUNG OF SALVAGED SOIL ABOVE THE EXISTING GROUND ELEVATION WILL NOT OCCUR IN A MANNER UNDERSTOOD TO OBSTRUCT FLOOD WATERS WHERE THEY 1 �. S b t+ — EXTRACTION CONVEYOR MIGHT OCCUR WITHIN THE EXISTING _ `.r LINE s CENTRAL FIELD s FLOODPLAIN. IT IS UNDERSTOOD r'` . F ` -- NORTH-EAST SECTION _ �� .- DIMENSIONSSHOULDPARALLEL ANTICIPATED FLOOD FLAWS UNLESS THE PILE IS INTENDED AS TERM {" p SHORT STORAGE I ........a•••••- =s TEMPORARY SOIL STOCKPILE LOCATION TEMPORARY OUTSIDE OF SEASONALITY WHERE FLOODING MIGHT RE MORE REASONABLY ANTICIPATED, 1 I 1. w .. ' ./ • ` Get �` a ra) t. F- ¢ - •_..- NW FIELD = `► O4 r�, S11 .,�" .•.+..-. ... _ �,,, tt 41.04± ACRES �;..- / dt + i OSSIBLE ARKING & EQUIPMENT O, L ,r oa f ° STORAGE UBJECT TO CHANGE) - •; • f ' '� !„ if, .': -' .A.: CENTRAL FIELD = 162.56± ACRES ,;.)//: r 14 f i i l '4' CE TRAL FIELD 9 • L GENERAL MINING PROGRESSION - , _.•-- CE RAL SECTION ,r �r, �. _- :fl 'V . 1: , •''Y NOTE WELL: THE CORE AREA OF . 2H:CUT SLOPE it EXTRACTION MAY VARY IN SIZE, SHAPE % - o % ryzeriwzdy, ,.. - AND EXTENT FROM THAT PORTRAYED Z / �! ,. — INITIAL DEPENDING UPON FIELD CONDITIONS 'r 'r lo CENTRAL FIELD AREA OF NECESSARY TO CIRCUMNAVIGATE THE pi",: : ' . WEST SECTION EXTRAC ON • "•:::,b`;'44:4•74#SECTI0N KEYWAY(S) WITHIN A DESIGNATED OR FIELD. /- GENERAL MINING PROGRESSION ., I• )4 - Irj is / $ r/ors" ! / ..10.1.4, .. 1' _ _ . •,•! )I'.::4:1,e - '+ •",�1`• ,, fsr 6 �4>1 f1 I f�1 f. ', � .' i -^^ , �✓f�flp JJ1/ J+If ��f•% / r� �,,L�� - ... - ! , �2�! ...JAW i�"i'. ij r% `/� !f ��•' �� ' ifr• 1� y+ sr/ d�`'r r ,;%.. 1V Gil dPE r ,/rim'/i///�i/ F •'�-.- - �• II SL fA� f I :. t rrrr�.r� ;, rYdsrrr� .. \O r..,„ ta. , . - f„ �ock0 _•' -. "'•""' „.--C., �` l -• r� y c>rcol1aw-4NM it /lJ�,'!' ' SETTLING BASIN �.. d' :.»_. SOUTH PLATTE RIVER .�. -- "',fit ms+. ,, .....- �.� — • • __.• _ '-.r i c-••••-1. .__--_-_-. -_ .-__ _— .n.�r�f Mw - /;1-1-7"": L •_.„ NAPTaa Tpa�Al5•LLC PROJECT. Two Rivers Sand, Gravel and Reservoir Project "°�� 203.59± Acres R.O.W & Easements not shown Basins Total + 5.60± Acre Wash Pond from Exhibit C-1: Existing Conditions Map. ore obsolete or vacated. Drawn by. M. Thompson Checked by, P. E. Christensen SCALL I 'nch a 200 feet NA DR �� DATE22 February 2022 nItn•0u (WI On An, DRAWING: { REVISION: 20 Novembor 22 'twos Exhibit C-2: Extraction Plan Map PACE: 1 0F�._ _•:c . •......ter--_ RAPTOR LEATEZAms. R!C N,TIVE UPO I Jo R QROTE p{�IG1Nh1- CONTOUR RANGE -AP ._ r TE pRIG1N�- CONTOUR NATIVE PASTURE APPROXI NIA HOMPsON " DEVELOPED WATER RESOURCES WITH GRASS EMBANKMENTS SOUTH PLATTE RIVER PROScr. Two Rivers Sand, Gravel and Reservoir Project _---- --.4traiLk DEVELOPED WATER RESOURCES WITH GRASS EMBANKMENTS DRA1MNO: Exhibit F: Reclamation Plan Map /-1 I I I 2.03.60±Acres Rosins Total r __At I co co V ti a;,: --7 w -..-.77. ::--:-) 'b. t 1 I I I ONLY THOSE STRUCTURES, EASEMENTS, AND RIGHTS -OF -WAY SHOWN IN THIS EXHIBIT F: RECLAMATION PLAN MAP, ARE ANTICIPATED TO REMAIN FROM THOSE SHOWN IN EXHIBIT C-1: EXISTING CONDITIONS MAP. IF CHANGES TO EXISTING OR POSSIBLE REVISED STRUCTURES, EASEMENTS. OR RIGHTS -OF -WAY ARE IN ANY MANNER RETAINED, OR WHERE THEY MIGHT OCCUR SUBSEQUENT TO OMLR APPROVAL OF THIS APPLICATION. THEN A TECHNICAL REVISION WILL BE SUBMITTED TO UPDATE EXHIBIT F: RECLAMATION PLAN MAP hr. Drown by. M. Thompson Checked `SCALE: 1 inch = 200 Feet by P. E. OATS• 22 February 2022 Christensen, REVISION: 20 November 2022 a_�, _ I PACE: 1 Or 1 flee r Two Rivers Sand, Gravel Reservoir Project RAP1TP MATERIALS, LAC nn mat Intl" tnw- ww .c.: toeJA n:tw].t (n1) w• MS. 71041 PeraHStaar. iCenstsustteni the hej`i 13* * -11-1 d9.3S12n •lptt?WJ11DOS R05ESTATFSWTACO fwentowlttuctrd ltir7l(19st hTKa,Vjn 4034111!-MNiftg..n i>S ALVAI • Wed fmraiurtedt WW1 klithW, 40:S1.'3ads•144J%2Alyvf.RrAC)MPANM;NtLVMcRA.GAME rnett ei►tnnnnxse4' :V141t rr:t.thv, 40.a4'I.537: • 111 s.7SO n VRKROL I twIPANtfs iPC jYA4RI •6ARRETf I! C suteursad 1 6/mt795z G snar.� vyr fr-Ranwn M_3i9g131- .._if* 781921!.iFARGM.C.41]W ilt!,A ,CA3119. $124105 M/!lh Cash utttrl ; - .42212011 6>vAu�rxlst 1 Mesv�u�m Mr.15"1n ampiint 40.1399L+t� •i0tT161.11 RSINfATMLttRE4C.Jlie?3PARTNERStIC iViruton4KMned Sin/tfl/SRoteti�rttc,f Onnastsr ... �171� -:8s.7707114Tt>:1I WATEriLt� �WRnLMtlfltvd 'J?3,t19' ounlPu a>o t»ttutun 40-.teer I. -?n.. Nter!CPI M MAttt#L,, Rtt-t)t Jur. OaP Does f!t` tWn•pco ery;eti (t;:!dr1@,A r0P:,-,18.njnt.p Porsrlt neatvsy Strout Pu:ptne t'waeral Purfsose »_._. ikueral r,Mpwe tp.ly. tIt,,t " Tr" .. T.f.pO .••••t ...._, NM .. v ..._..-y.w- ... «.- .... ».. •... . f PIM • MATERIAL PROCESSING AREA = 15.76± ACRES NW FIELD SURFACE WATER AREA = 34.99± ACRES AT ELEVATION 4675' WASH POND = 5.60± ACRES NW FIELD= 41.04± ACRES be Pima rl CENTRAL FIELD = 162.56± ACRES CENTRAL FIELD SURFACE WATER AREA = 151.38± ACRES AT ELEVATION 4673' id.__.-... • SOUTH PLATTE RIVER Saar GRauNn•4490.Si TOP PIPE =460144 DRAWING: Exhibit G: Water Information Map NOTES: _._.. as _... 203.59±Acres Basins Total :_•.._,. .-. Drawn by. M. Thompson Checked by. P. E. Christensen SCALE-:-Fir-ca-3OO feet DATE: RCVIStON: 20 November 2022 PAGE: 22 February 2022 1 I' SOIL UNIT 61 a 4., • - - . .7..N. 4•'._-i•s•,. -4H"•O a . •sue •• 6 :s. I £ re. 'cane • /4 -•••‘• • K War••• -• '.I•'. at that • /W .7 4.4 ' •.-A•U • 4..11(a —w...•1-1. .at anX.. OR :IF•Rr " in rt.h'; ler ire to itW •-•.r :..:.L.' R a .d. w:-\.ai'•. 1111 •M mare -er1st;•,l'. .. i•- wap •.• RAPTee MATERIALS, (LC SOIL UNIT 3 SOIL UNIT 3 PRO.ECE DRAWING: L OROUNn'ae0O CI TOP PIPEVE1I SI SOIL UNIT 3 SOIL UNIT 52 MATERIAL PROCESSING AREA = 15.76± ACRES �.F 1 elA1.1S GP44-' 0\G f 4.- 0 53 50\\ SO\\-JN\� �1 WASH POND = 5.601 ACRES � I TMOMPSON i Y NW FIELD SURFACE WATER AREA = 34.99± ACRES AT ELEVATION 4675' • NW FIELD = 41.04± ACRES SOIL UNIT 3 4 Ong O ~ I I SOIL UNIT 3 CENTRAL FIELD = 162.56± ACRES CENTRAL FIELD SURFACE WATER AREA = 151.38± ACRES AT ELEVATION 4673' Two Rivers Sand, Grave! Reservoir Project • t�Tevc. SASlti • BIG 1 203.60±Acres Basins Total TNOMp50N RIVER -t SOIL UNIT 10 0 co 4 Drawn by. M. Thompson Checked by P. E. Christensen amass. "a.; 'tom•_ •&-• Y q l W. it R' SCALE: 1 inch - 300 feet DATE: 22 February 2022 REVISION: PAGE: 1 a- 1 R APTE(7 WADDIGALS, IC F.. MATERIAL PROCESSING AREA = 15.76± ACRES PROJECT. DRAWING: EXTRACTION CONVEYOR LINE t NW FIELD = 41.04± ACRES CENTRAL FIELD WEST SECTION INITIAL AREA OF EXTRACTION SETTLING BASIN SOUTH PLATTE RIVER Two Rivers Sand, Gravel and Reservoir Project WASH POND = 5.60± ACRES CENTRAL FIELD NORTH-EAST SECTION TEMPORARY SOIL STOCKPILE LOCATION CENTRAL FIELD = 162.56± ACRES GENERAL MINING PROGRESSION NOTE WELL: THE CORE AREA OF EXTRACTION MAY VARY IN SIZE, SHAPE AND EXTENT FROM THAT PORTRAYED DEPENDING UPON FIELD CONDITIONS NECESSARY TO CIRCUMNAVIGATE THE KEYWAYS) WITHIN A DESIGNATED SECTION OR FIELD. CENTRAL FIELD CENTRAL SECTION • GENERAL MINING PROGRESSION 203.60±Acres Basins Total + 5.60±Acre Wash Pond Drawn by M.Thompson Checked by. P. E. Christensen RENSiON: SCALE: 1 inch = 200 feet 22 rebruory 2022 PAGE: f ()jr 1 Water Well Detail Permit Number Latitude Longitude Owner Permit Status Construction Date Permit Category Use(s) 13950 -R -R 40.35129 -104.76911 DOS RIOS ESTATES WTR CO Well Constructed 10/11/1989 General Purpose Irrigation 270-R / 40.342653 -104.78573 SHABLE, ALVA L Well Constructed 6/20/1955 General Purpose Irrigation /\---r 8303 40.342343 " `"_ -R -R -104.78248 VARRA COMPANIES INC (VARRA, GARRETT) Well Constructed 11/14/1989 General Purpose Irrigation (L: 8304-R 40.342642 -104.78099 VARRA COMPANIES INC (VARRA, GARRETT) Well Constructed 6/30/1952 General Purpose Irrigation t1 i'�.r(� , . ,;; N 320422- 40.339043 `' F' ` f< -104.78599 LAFARGEHOLCIM/AGGREGATE INDUSTRIES Well Constructed 1/22/2021 Monitoring/Observation Monitoring/Sampling :` I a •4 =. ` r t '.4 - \•4 - 79087--A 40.339404 - 104.77683 SORIN NATURAL RESOURCES PARTNERS Lit Well Constructed 5/12/1975 Residential Domestic 11',` r ...v,+'^-•'(" n- 1 ' .. Y. ). y J, "II'Y 1282 -R -R 40.341719 -104.76314 DIXIE WATER, LLC Well Constructed 4/23/1976 General Purpose Irri •ation / \ fto / d' - ^" 'a ':a. \ 78568-F 40.349824 -104,76142 SORIN NATURAL RESOURCE PARTNERS LW Well Constructed 9/24/2014 General Purpose Industrial f .. y�./ v ": — — " e, rt. 1 �" -: j1J1j t \ t •_. � , ;: I i I� - -„ v :�: .. ' t i. t l .rte" ` :h - .. .. .._ ..<: " '.i.T4,]fIRi yS,j ._.. .n. ... Y ._... t :: tPaY.x 1: mr ...• ia.41" .r"/'._ y.�\ �,.•^ L ' >3 wa ' ,r 0 400 800 - ... T: , �•�. :� .. SCALE IN FEET jj✓" ,..,.. .:_._:. .. _ . `. „Y. '. •x..-;: <<:, h:; T' �3?;4:0:: t4 _. ...._,„,_,...,„._,„_,.._d_,........„.„.-.,.:., .. �`_j .,,.,-.. - .,,,. „�:, ----�_.,-.....- - O ' t.1 `,: ,A �- ^_"'__•..w:�� 095933000023 �" -�� --- /I f IVY R 1 f _ �- _!_ __"-- - ` R BIG 1 •..: - �� •.:. -. '. .I WOOS, NO W.Aciaera • �'is '_ -V .E AI 1 po] g10tsYrLY.O ib •n.. ; C... : '.. 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WY OA :whim :CRT IOtDRI CO Man IOD-CV.1Dll 'MI L ALMS Wit C,fO AS IAYIID W[iIV IT EmOQYM AANaM AIM MOOT a WAY OCR. CfA'RIOY, M Ytu.RN Min- Min PROJECT. Two Rivers Sand , Gravel and Reservoir Project NOTES: Drawn by M. Thompson Checked by P. E•DATE: Christensen Pie r. SCALE 1 inch as 400 feet RAPTOR MATERIALS, LLC• 01 R.,., Ara SIr JAPT0P 1 DRAWING: Exhibit C—1: Existing Conditions Map !�-=-x� ca DaA^o °°_�` REVISION: 22 February 20221 —T 'Ii A'=R1_Y,y�,'. 4 PAGE: 1 1 a,awa,,, • �"'.-_ ._ GROUND=4600.61 w- -- .. .. .. TOP PIPET4611. 51 - •' - _• ,•!? I�. WASH POND = 5.60± ACRES w . r • MATERIAL PROCESSING .- ,:° --SCALE HOUSE (LOC. ' AREA = 15.76± ACRES `r` f SUBJ. TO CHANGE) ;1 • •- - ,.�.:...._..-'�" 0 204 400 - -� • ," Yomr,11fiw i'- EVPNs T OMPSO/y 6�6 ,w,:a SOIL STOCKPILES }. �' STOCKPILING OF SALVAGED SOIL ABOVE THE EXISTING GROUND ELEVATION WILL NOT a N OCCUR IN A MANNER UNDERSTOOD TO OBSTRUCT FLOOD WATERS WHERE THEY •,--_.�- 1_ .- MIGHT OCCUR WITHIN THE EXISTING EXTRACTION - FLOODPLAIN IT UNDERSTOOD - CONVEYOR LINE ± , CENTRAL FIELD IS AND a _„•— " AGREED HERE THAT THEIR LONGITUDINAL r',,_. ----- -IN DIMENSIONS '- ed �~l NORTH-EAST SECTION NTICIPATEDFLOUDDLOWSU UNLESS THE ANTICIPATED FLOOD FLOWS UNLESS THE PILE zi ),•' I IS INTENDED AS SHORT TERM STORAGE I 1 • 'lit' " / ' y TEMPORARY SOIL STOCKPILE LOCATIONOUTSIDE OF SEASONALITY WHERE FLOODING MIGHT BE MORE REASONABLY ANTICIPATED. ,, j �_ - I �.-�.. 1 /� ? - - i. ? tee,,...,,. . _ . CC .. • . . . -_— — - t _ J ' .1 •. ,1'G�f_,L ' 1- Q k 1h p N NW FIELD = / .'_e' / / /�?v. ,I O4 o • v ;' = II n 41.04± ACRES �� ;''/oGP�'tDOSSIBLE/o �� ARKING & EQUIPMENT ' is 4.d , o ./., / e := STORAGE ( UBJECT TO CHANGE) ; /;) ., : f�� r'.1 CENTRAL FIELD ' i , �-� . ,� :. • r J' = 162 . 56± ACRES o •/19 ✓' / 't:;;;;;:::::,:•,,./.:).te,• _� / -------:(74::1;11. Q ,Q -1 4t f/ —! x Y "--...-- ..r• ..��'' :.:: - if J CE TRAL FIELD a i --� :1r •: ' GENERAL MINING PROGRESSION f It- '�.r zycr _._- - •:•.•• CENTRAL NT SECTION • : I` NOTE WELL: THE CORE AREA OF EXTRACTION MAY VARY IN SIZE, SHAPE ' u_ 2H: V CUT SLOPE :' o t tt fl/Z!za- r AND EXTENT FROM THAT Z ,'. PORTRAYED y�✓IRNT / • m INITIAL DEPENDING UPON FIELD CONDITIONS y a CENTRAL FIELD AREA OF NECESSARY TO CIRCUMNAVIGATE THE ��. I�tl II EXTRAC ON KEYWAY(S) WITHIN A DESIGNATED - GENERAL MINING PROGRESSION O t i 4/ WEST SECTION SECTION OR FIELDft I _;-,�/,�� ,I `„ ,. L li pS ;r.. LOPE Q •. I ., 1 f Jri, ZN W LT oN A L!.T �/'�1Pid' -• - -ore y, 11 ' B� .. ., - _. • - • 'a • • ' — •+�• '-- - ._ _- O•Pia i'• • fO.i '®66,tp• —1 .. - _._•._--......._.. y ,.,•+ Sr. -"pee .iiN • .. / r f ' 0 . _ `; - ,-„f<.: ®. #4. Of -_y , , : �_ .••.._""�..._,..,.. -^i r _ - ... _':'r ,,------.----•-•-•• V IT' i-J, 90 3 GROUNDS 7 -.4j ®SI - ," .. O" ! TOP PIPE=4694 45 - �If oil l .. -r-PA, �s, ! i`. ` !J •_ ter- SETTLING BASIN i .4e -,d. _: SOUTH PLATTE RIVER r r Y .' •�' J: .- ... ..... .. ._ .• w t�lq vfEfi ut VY a W t j �. 01. Mewl Gcsont, -•.1 - .--•- GOwwsr ,/-�,v7 .. �. \ wrath IOU IN X111/ 0 \ .� St a'u.caar !JCS .. Ate• m rF PROJECT.•• Two Rivers Sand, Grave and Reservoir Project NOTES: 203.59±Acres Basins Total + 5.60±Acre Wash Pond Drawn by. M. Thompson Checked b P. E. Y Christensen SCALE: 1 inch = 200 feet RAPTOR MATERIALS, LLC „20 GAGE , Aa saw ,nEPHONC OW) 9441-1457 C DATE; 22 February 2022 Y DRAWING: Exhibit C-2: Extraction Plan Map R.0.W & Easements not shown from Exhibit C-1: Existing Conditions Map, are obsolete or vacated- REVISION: 20 November 2022 PAGE: 1 OF .„.a.—,..� DEVELOPED WATER RESOURCES WITH GRASS EMBAIIKIIENTS 1 ONLY THOSE STRUCTURES, EASEMENTS, AND RIGHTS -OF -WAY SHOWN IN THIS EXHIBIT F: RECLAMATION PLAN MAP, ARE ANTICIPATED TO REMAIN FROM THOSE SHOWN IN EXHIBIT C-1: EXISTING CONDITIONS MAP. IF CHANGES TO EXISTING OR POSSIBLE REVISED STRUCTURES, EASEMENTS, OR RIGHTS -OF -WAY ARE IN ANY MANNER RETAINED, OR WHERE THEY MIGHT OCCUR SUBSEQUENT TO OMLR APPROVAL OF THIS APPLICATION, THEN A TECHNICAL REVISION WILL BE SUBMITTED TO UPDATE EXHIBIT F: RECLAMATION PLAN MAP. PROJECT. RAPTOR MATERIALS, LLC 0129 GA 577MT rR**Oacx. CaD.A r maoxc (ic3) 6.545-46 :7 Two Rivers Sand, Gravel and Reservoir Project DRAWING: Exhibit F: Reclamation Plan Map "OTES:203.60±Acres Basins Total Drawn by: M. Thompson Checked by. P. E. Christensen SCALE: 1 inch = 200 feet 22 February 2022 DATE: REVISION: 20 November 2022 PAGE: 1 OF 1 Water Well Detail . Permit Number Latitude Longitude Owner Permit Status krinstruction Date 'Permit Category Use{sj 13950.8-R 40.35129 •:04.76911 DOS RIOS ESTATES WEB CO Well Constructed 10/11/1959•6enera; Purpose Irrigation' 270 -ft WellConstructedGeneral Pu. pvse Irrigation .83;33-•°.-R(VARR+a. it GARRETT) WellCanntniaed8304•R413. .:04.78099 VARRA COMPANIES INC (VARRA, GARRETT) Well Constructed 6/30/1952 General PurF+ose trri fiatiau 320422- 40.339043i-104.7$599,,lAFARGEHOLCtti/AGGREGATE INDUSTRIES Well Constructed 1/22/2021 Monitoring/Observation fvlonttoring/Sampling(41 I 79p87••A 40.339404? -144.77683 SORiN NATURAL RESOURCES PARTNERS LC Well Constructed 5/12/1975 Residential Domestic tt- l 1282 -R -R 40.34x719 -1(4.76314 DIXIE. WATER, LLC Purpose Irrigation Well Constructed 4/23/1976 General 78568-F 40.349824 -104.76142 SOWN NATI r .1+l. RESOURCE PARTNERS LLC Weil Constructed 9124/2014 General Purpose industrial o t , ., -,,. .. -� _.- - - .. � MQ I ,.: <.. ,.. �. .... .. -ENO _ 2, 0, \ RIVER BIG g. _- WASH POND = ' ,� .,f.. C YYY.- WS = `4J 5.60± ACRES '° ` ��' MATERIAL PROCESSING AREA =GROU --r— _ — Pa Ldf 15.76± ACRES `r . , I • C J' � r� `' - - CPNpt_ `\ Smo .\1144 0G TH OMP / " s0 x 1 W ... - w : NT„to-�'� =' ws•-a.;a -. a,r y .. -+• _�E !!11�C , ] I Vii - `! 1? r Q Y 1 i NW FIELD= 41.04± l la, ;cr = ACRES o Q W i-I Q' N O a W o _ .- NnT r WWW,. �� " P...1., I ' `'' NW FIELD SURFACE WATER r ' , o iI I!: AREA = 34.99± ACRES AT ELEVATION 4675' r7 • 0 Q - .-:- jam. _ '/i. ✓ � '� CENTRAL FIELD = 162.56± ACRES ----_ r,. �. --_ r ,fir . a i .i .I WATER AREA s ? CENTRAL FIELD SURFACE I� { ]�Y i ' na �'I' ' sti 151.38± ACRES AT ELEVATION 4673' -- 21. 04 . -' .. .., p„ --,d y 4 „ I - I i. ¢._ h l V;" 4 I ) r . GROUND=4690.37 ` - N a / 7 - TOP PIPE4694.44 • .rue vnu Atm u Ira rra .%''''''..,...,,,.... - moo.. rau• Han: r ace w sewn 0 y N .,.'-TTE SOUTH PLATTE RIVER WM! WOW 0y al ---- ---- -. _ _ 4 a. r _ f ..c ; a _t - 6 � • F. IAVIIMMYF. o eM1.Araw learn isr c u ONO / RAPTOR UATERIAJAac PROJECT'. Two Rivers Sand Gravel Reservoir Project NOTES: Drawn y. M. Thompson Checked by P E Christensen SCALE: inch = 300 feet •' r 203.59±Acres Basins Total DATE: 22 February 2022 +n:n sAT STREET rya, COLORADO 10534 TELDN•Y:E: C5C7 666-61157 DRAWING: Exhibit G: Water Information M a P REVISION: 20 November 2022 - - PAGE: 1 OF 1 L..,.o..,.. SOIL UNIT 61 RAPTOR MATERIALS. LC IMO Ca0FT TM -FT FREXItOt, C.0RAD0 et534 Ti[P1I0NE (303) au 0457 SOIL UNIT 3 SOIL UNIT 3 SOIL UNIT 3 GROUND=460B.61 TOP PIPE=4611 51 SOIL UNIT 52 MATERIAL PROCESSING AREA = 15.76± ACRES NW FIELD SURFACE WATER AREA = 34.99± ACRES AT ELEVATION 4675' PROJECT. T,A,O R"/ers Sand Gravel RPRPrvnir Pm lent 7 DRAWING: Exhibit I/J: Soils carpi Vegetation Map WASH POND = 5.601 ACRES NW FIELD = 41.04± ACRES SOIL UNIT 3 SOIL UNIT 3 CENTRAL FIELD = 162.56± ACRES CENTRAL FIELD SURFACE WATER AREA = 151.38± ACRES AT ELEVATION 4673' SOUTH PLATTE RIVER allal herein ,. .m....0. J NOTES: SOIL UNIT 10 203.60±Acres Basins Total RIVER nrnwr h.r M. Thompson rlharLad by. RE. Christensen Ma UMmxn •—•..•••••• SCALE: 1 inch = 300 feet DATE: REVISION: PAGE: 22 February 2022 1 OF 1 RAPTOR MATERIALS. US 5129 GAGE STRUT FRE9CRIGX. Cy ORAjo 82,534 1r1.11111JYL (153) 666 6847 GROUND ---4608 61 TOP PIPE=4611.51 MATERIAL PROCESSING AREA = 15.76± ACRES EXTRACTION CONVEYOR LINE ± NW FIELD = 41.04± ACRES CENTRAL FIELD WEST SECTION INITIAL AREA OF EXTRACTION SOUTH PLATTE RIVER PROJECT. Two Rivers Sand. Grovel and Reservoir Pro iect DRAWING: Exhibit L: Financial Warranty Map WASH POND = 5.60± ACRES �..• T0PPPF new CENTRAL FIELD NORTH-EAST SECTION TEMPORARY SOIL STOCKPILE LOCATION CENTRAL FIELD = 162.56± ACRES GENERAL MINING PROGRESSION I t.?ZYrn NOTE WELL: THE CORE AREA OF EXTRACTION MAY VARY IN SIZE, SHAPE AND EXTENT FROM THAT PORTRAYED DEPENDING UPON FIELD CONDITIONS NECESSARY TO CIRCUMNAVIGATE THE KEYWAY(S) WITHIN A DESIGNATED SECTION OR FIELD. CENTRAL FIELD CENTRAL SECTION GENERAL MINING PROGRESSION 4K4u. row .1 Tv an—war. 203.60±Acres Basins Total + 5.60±Acre Wash Pond Drawn by. M.Thompson Checked by. P. E. Christensen p.. REVISION: DATE: PAGE: 1 inch = 200 feet 22 February 2022 OF 1 Raptor Materials, LLC. 8120 GaRe Street Frederick c_o 80516 Telenh+ ne (303) 666-6657 Fax (303) X666-6743 Wednesday 04 January 2023 To: Robert D. Zuber, P.R. Environmental Protection Specialist Colorado Division of Reclamation Mining and safety office of Mined Land Reclamation (OMLR) 1313 Sherman Street, Room 215 Denver, Colorado 80203 From: Garrett C. Vj arra, General Manager Subject:. Two Rivers Sand, Gravel and Reservoir Project, File No. M-2022-013, 112c Permit Application Adequacy Review #2 - REPLY Dear Rob. The Division of Reclamation, Mining and Safety (Division/DRMS), Office of Mined Land Reclamation (OMLR) reviewed the contents of the Original 112c permit application for the Two Rivers Sand, Gravel and Reservoir Project (TRPX File No. M-2022-013 and submitted comments. Raptor responded to the First Adequacy comments on September 06, 2022 and the Division responded with additional comments in a Second Adequacy Review dated October 17, 2022 and subsequently with additional comments on November 17, 2022. The Division was required to issue an approval or denial decision to the original application no later than July 17, 2022. Several extensions have been requested and granted through the review and response process with the current extension through January 06, 2023. The review consisted of comparing the application contents with the specific requirements of Rules 1, 3, 6.1, 6. 2, 6.4 and ► .5 of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials (effective date July 15, 2019). Any inadequacies were identified under respective exhibit headings, along with suggested actions to correct then. We have reviewed the Division's comments and trust the following reply will serve to fully address them. For greater continuity and ease of reference, we have iterated the comments from the OMLR Adequacy Review (Review) of 24 June 2022 and 05 August Page 1 2022, necessitating a reply according to its respective item numbers from the Review, iterated in a graphical box, with our comments in blue following: Prologue The permit application has been prepared as a holistic document. We believe it would be inconsistent with the intent of the Rules and Regulations or good practice to approach it otherwise. Mining must be designed from the outset and operated through the life of themine vvith closure in mind. To different degrees then, all the elements of the application are interwoven and form a narrative about the development, operation and ultimately closure of the mine. Naturally the Rules and Regulations must be segmented to at least address different elements of this process, but where the context, of a discussion suggests certain discussions be combined, we have done this. There comes a point when the review will so put into fractions for purposes of style as to make the application fundamentally difficult to navigate or perform as a useful tool for compliance by the Operator. To cross reference every subject or element of the application would make the document both unwieldy and likely harder to understand and comprehend, rendering it less likely to be useful to either the operator or regulator. For example, while some information in Exhibits D and E addresses soils and vegetation, there is another exhibit completely devoted to the same. Similarly, there are independent exhibits intended to satisfy parts of Exhibit H - Wildlife Information, which may also add to the understanding of I/J - Soils and Vegetation and other data. Soils and Vegetation are grouped because they are so contextually close and difficult to regard separately, so keen are their influences. This is not new and is also consistent with how we access established information of the same from SCS (NRCS) reports and data, as provided under Exhibit I el: Soils and Vegetation Information, and maps. The vegetation, being typified according to soils, shown on the maps, fully complies with a map -based description of vegetation as it may naturally occur absent man caused modifications like agriculture or natural events like flooding or wildlife impacts, clearly evident in the aerial photographs used to enhance maps. Consequently, there are extensive references to Exhibit In throughout this application, in large part because soils are so integral to every aspect of the project, and it would be ungainly to repeatedly end every paragraph touching on the subject in Exhibits D, E, or others with redundant references. The same logic applies to Exhibit G: Water Information, which may also have other. 1Page Correspondence to the Colorado Office of Mined Und Reclamation - Reply to Rob Zuber, EP - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project a M2022-013. supplemental water information contextually placed in other exhibits. An effort is made to call out these respective exhibits where the information desired in one exhibit is found in another, or as it may be otherwise be identified by a map legend. With regard to map exhibits, please consider the aerial information at scale is intended to speak pictorially and provide substantial detail. Typically maps includes additional information to aid clarity, even though such information is not necessarily called out by the Rules and Regulations. This serves to minimize extensive additional narrative. since a picture (commonly) really is worth a thousand words. It should be considered that the Rules and Regulations call for a considerable amount of information that must appear on the included maps. Some discretion as to what is revealed and how on a given map exhibit is in part determined in the submittal to meet the demands of communicating to a broad audience. Some information that might appear or not appear on a given map are commonly represented on another for the sake of context with the associated narrative under the same or similar .intent. We are aware of the present-day names and full anacronyms of governmental agencies referenced in this submittal. It is a matter of convention versus free expression as a reasonable person might view it. Clearly, the Agency comments suggest it understands the application of the names and letters that we used. In other cases, we are unclear on apparentconflicts with the Rules and Regulations. is ° ILR (it has been suggested we remove this acronym as it does not exist) It's in your Definitions: Rule 1.1 (3 2) (32) "Office" means the Office of Mined Land Reclamation within the Division of Reclamation, Mining and Safety (OR's). It's in your Rules and Regulations: Any reference to the Colorado Office of Mined Land Reclamation is consistent with the following Colorado Revised Statutes, as of year 2020 (Source: Justia US Law ) US Codes and Statutes ' Colorado Revised Statutes > 2020 Colorado Revised Statutes s Title 34 — Mineral Resources > Article 32. Colorado Mined Land Reclamation Act. ) Section 34-32-105. Office of mined land reclamation mined land reclamation board created. 3IPaRe Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zabel-, EPS — Adequacy Letters of 24 June and 5 August 2022; in die matter of the Two Rivers Sand, Gravel and Reservoir Project - M2022-013. Universal Citation: CO Rev Stat § 34-32-105 (2020) (6)There is hereby created, in the division of reclamation, mining, and safety in the department of natural resources, the o ffice of mined land reclamation and, in the department of n atural resources, the mined land reclamation board. The head o f the office of mined land reclamation shall be appointed by the director. The head of the office of mined land reclamation shall have professional and supervisory experience in mined land reclamation, mining, or natural resource planning and management. • Change "NPDES" to "CDPS" to reflect the requirements of the Water Quality Control Commission. Our only reference to NPDES was simply incorporating the following text directly from the rules.. Rule 6.4.7 (5) (51 The o pera►tor/A pplicant shall affrrrnativ{e&y state that the operator/Applicant has acquired (or has applied for) a National Pollutant Discharge Elimination System *FOES) oer iit from the Water Quality Control Damon at the Colorado Department of Health and Environment, if necessary. Also, any effort to update agency names betrays our desire under the First Amendment to maintain a casual reference in place of convention, which is apparently easy enoughto follow, and has been since 1999. For example We use DOW in reference to the Colorado Division of Parks and Wildlife, but left out Parks - because wildlife is involved, but not parks. We are aware of their formal name and alphabet soup. • For the Colorado Division of Water Resources, we may use DWR or o SE- for the Office of the State Engineer, or some, SEO for State Engineer's Office, which resides within the Division. Our abbreviations occur in parenthesis at least once in reference to their full expansion. In future submittals, we will make efforts to bring some of these forward as desired, but for consistency and to avoid possible confusion in the many documents making up this application and in keeping with convention accepted in our submittals since 1999, it is preferred to maintain the current acronyms. October 17, 2022 Second Adequacy Review - General Comments 1) On May 18, 2022, the Division approved a transfer of the Two Rivers Sand, Gravel Wage correspondence to the Colorado Office of Mined Land Reclamation a Reply to Rob Zuber, EP — Adequacy Letters of 24 June and 5 August 2022; in the utter of the Two Rivers Sand, Gravel and Reservoir Project -- N12022-013. and Reservoir Project 112 Application from Varra Companies, Inc. to Raptor Materials, LLC. Please provide a letter from Kevin Jeakins (as part of your response to this adequacy review) stating that Bradford Janes is authorized to act as a permitting representative of Raptor Materials LLC. Raptor Materials First Adequacy Response The work and prior submittals of Bradford Janes, a Professional Forester . and Soil Scientist, having nearly 43 -years of experience in orchestrating the diverse talents and content that comprise Minerals Section permits of the Colorado Division of Reclamation Mining and Safety's (DRMS), Office of Mined Land Reclamation- (OMLR),. is presently employed by Raptor Materials, LLC. RM"vI All submittals through our office of Special Projects represented essential continuity from his work under the same with Varra Companies, Inc. Lis work continues. now under the direct responsibility, oversight and approval of Office, my o ff rce, as signified below; and continuing under Garrett C. Varra, General Manag er and former President of Varga Companies, Inc.; all under the authority of � Raptor Materials, LLC. Please NOTE: Since the Application began under Varra Companies, Inc.,p a Succession of operator to Raptor Materials, LLC has since been approved by the OMLR. Garrett C. Varra is now our new Permittee Contact and Designated Representative, until and unless otherwise notified. , 2022 Kevin Jeak.ins, Vice -President Raptor Materials, LLC. Division Second Adequacy Comment No additional response is required from Rb! 2) Please commit to submitting Financial and Performance Warranties antes with the name Raptor Materials, LLC. avtorateriais First Adequacy Response 51Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project --14 M2022-013. All financial and performance warranties necessary for the issuance of an approved OMLR Permit will be submitted, as underwritten by or for, Raptor Materials, LLC. Division Second Adequacy Comment No additional response is required from RN. 3) The Division received timely state agency comments from History Colorado arid the Division of Water Resources, as well as a late comment letter from Colorado Parks and Wildlife. The letters from these agencies are included as an enclosure with this adequacy review letter. Please review the letters and provide comments accordingly. Raptor Materials First Adequacy Response The comments from Flistory Colorado are acknowledged. RN'I intends to complete a Class HI Intensive Cultural Resource Inventory of the permitted area. Concerning comments from the Division of Water Resources., Kiel has affirmed in Item 54 of this response that all permits including well permits and documents related to water rights, such as a substitute water Supply Plan will be obtained and provided before actions requiring permits commence. A revised application for CDPS General Permit Co 500000 Discharges from sand and Gravel Mining and Processing is submitted with this response. Comments from Colorado Parks and wildlife are addressed in various comments throughout this response and in the response prepared by ERO dated August 26, 2022 attached as an addendum to Exhibit H Division Second Adequacy Comment No additional response is required from Rill Application Form 4) The application form must be updated to indicate that the new permittee is Raptor Materials LLC. Raptor Materials First Adequacy Response An updated and signed, Regular Impact (112) Construction Materials application form under Raptor Materials, LLC., is attached. 6 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir project — M2022-013. Division Second Adequacy Comment No additional response is required from RN! 5) On Page 1, Item #1.1 of the application form, the Applicant indicated the type of organization as a corporation. Please provide the corporation seal on Page 8 of the application form, if the corporation does not have a seal please indicate "no seal". Raptor Materials First Adquacy Response raptor Materials, LLC., is a Limited Liability Company and does not have a Corporate Seal. Consistent. with Item #1, above, a newly completed 112 Construction Materials Application is provided as requested and having the signature of the Vice -President of Operations. Division Second Adequacy Comment Please revise Page 8 of the form and add the text "no seal.,, Ra for Materials Second Adequacy Response The application has been revised as requested. 6.2 General Requirements of Exhibits 6) Rule 6.2.1(2)(b) requires maps be signed by a registered land surveyor, professional engineer, or other qualified person. .Please submit signed copies of the � Exhibit C and Exhibit F maps Raptor Materials First Adequacy Response All maps for Permit M2022-013, were submitted Digitally. All maps show they were `Brawn by: B. L. Janes.There is no reliable way to insert a legitimate signature on the maps. Please allow this reply to serve as testimony and signatory that all maps previously created in cooperation with diverse content providers and technical support, with Autodesk software and utilized by the office of Special Projects, from which the final drawing was created by B.L. Janes. The content includes survey and aerial data for optimum accuracy and portrayal of all features and content to scale; including area roads, vegetation, and other obvious features as apparent or otherwise identified there -in, such as internal irrigation ditch -works all owned by 7JP,age Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Raptor Materials, LLC. This Signature, below, bears witness to this effect that all maps as submitted prior to this date were digital reproductions on .pdf and in this instance were Drawn By: B.L. Janes. ,2022 B.L. Janes PLEASE NOTE: Future Map Submittals beyond those already provided with the Original Application, or under this Adequacy Reply, will come with separate letterhead bearing this OR a similar Affirmation relative to the assigned Cartographer, and Original (not facsimile) signature in Blue Ink as Drawn By; Will apply equally to ALL as Signified, signed and Dated, as provided with that submittal. , 2022 Kevin Jeakins, s, Vice -President Raptor Materials, LLC. Division Second Adequacy Comment It rs cO177172 on practice for operators to provide signed maps. needs to comply; with this request Raptor Materials Second Adequacy Response All maps have been updated and are signed as requested. 6.4 Specific Exhibit Requirements Regular 112 Operations The following items must be addressed by the Applicant to satisfy the Mineral Rul es and Regulations of the Mined Land Reclamation Board: 6.4.1 Exhibit A - Legal Description 7) The Applicant indicated that a portion of the permit area is in Sections 3 and 4 of Township 4 North, Range 65 West. However, it appears (based on the Exhibit Map p in Exhibit B) that the text should indicate Range 66 West instead of 65 West. Please address this apparent error and revise the Exiiibit A text as necessary. Wage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob baba, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Raptor Materials First Adequacy Response Exhibit A has been updated to reflect the correction, as attached. Division Second Adequacy Comment No additional response Is required from RAI 8) It appears that the coordinates for the Central Field SW Entrance are incorrect. Please check them and revise the Exhibit A text as necessary. (The coordinates listed for this entrance appear to be near the Varra Coulson Project.) Raptor Materials First Adequacy Response Three locations were corrected as reflected in the revised Exhibit A, and verified via supporting Snippets of the coordinates captured from Google Maps, which follow, below: SouthWest Entrance: Evans Colorado 40 341869, -104 783755 The Homestead (North) Entrance: The Primary Entrance (#8): Evans Colorado 40 349120, -104.714905 9 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS - Adequacy Letters of 24 Jane and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project M2022-013. T� 1411$7-1400 CON 3% MIKE; CO 60543 4f130 9.> a 7:redee 1 • • Division Second Adequacy Comment No additional response is required from RM. 6.4.3 Exhibit C - Pre -Mining and Mining Plan Maps of Affected Land 9) The irrigation ditches need to be clearly shown and labeled on the Existing Conditions Map ibit C-1). Raptor Materials First_Adequacy Response The Evans Ditch is labelled. The internal irrigation ditches are owned and controlled by RM, are visibly evident in the aerial image. While these company owned ditches are predominantly outside the extraction limits, some are inside the extraction limits and will be lost to extraction. • r_• i :.lt r_ .y 1 ,. 6 5t .tip -IM • .90?! dic Division Second Adequacy Comment No additional response is required from RAI 10) Also, per Rule 6.4.31, the existing vegetation at the site should be shown. Raptor Materials First Adequacy Response 10IPage Correspondence to the Colorado Office of Mined Land Reclamation -- Reply to Rob Zuber, EPS — Adequacy Letters, of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Aerial images are provided to reflect a better understanding as to the nature of the diverse vegetation that either exists or could e s st over the affected lands. Since it is stated that extraction occurs with the cropped lands exclusively, the denuded lands sho\ In in the aerial image reflect the seasonal absence of crops. .sCrops p may vary in composition from year to year, so any manifestations as to what kind of crop, if any; or the state of cover, is somewhat misleading. Still, while we believe the aerial image satisfies the requirement, it should also be understood that this submittal is consistent with those submitted to the OMLR since 1999. We believe your colleague, Peter Hays, can attest to this. Further, there is ample information in Exhibit I/,l ,here the native vegetation that may exist as correlated to area soils is fully manifested in the included Range Site Descriptions, per SC NRC s publications. Further, information is provided that much of the cottonwood corridors that occupy a majority of the riverine areas have vegetation that is atypical, since it is highly overgrazed or otherwise disturbed by natural conditions, sporting a near monoculture of smooth brorne or diverse ann u al Division Second Adequacy Comment No additional response is required from R I 11) The scale on Exhibit C-1 appears to be incorrect. Please check and revise as necessary. Raptor Materials First Adequacy Response It was off, but so little you could just see a minor shift in the image as the Scale was remedied. A corrected version at 1" = 400' of the Original Drawing now in .pdf, is included with this submittal. Please keep in mind that in the translation of highly complicated drawings produced in Autodesk Civil 3D and Raster Design, , some loss may occur as Adobe attempts to translates the .dwg files of Autodesk, into usable .pdf files necessary in communicating the OMLR permit to a diverse else agency and public audience. Then (the scale reflected as indicated at 0.002496): 11 Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project - 20 2-013. V 7:1O1K la 0.002496 - +� Now (the scale reflected as indicated at 1 inch = 400 feet - as set in Model Space). Note: Revised Map with corrected scale included in .pdf \\Pith this digital submittal: Si -Lc I Drain es. ikeita ..• 1 'etch e 4 Qfer Dal b$ ncvlbrr 2011 Ewa* 22 Tansy 2022 re-� Lfc4i. . iCZ. Winn t Inch : 440 feet • El Division Second Adequacy Comment An additional response is required from RM. The scale bar appears to have incorrect numbers. Rather than 400 feet and 800 feet it appears that the numbers should be 200 and 400. Raptor Materials second ,degua,cy Response The scale bar on Exhibit C-1 has been corrected as requested. 12) The legend on Exhibit C-1 includes the 100 -year floodplain, but the floodplain lines are not on the map. These lines should be added to this map as well as the Extraction Plan Map, Exhibit C-2. Raptor Materials First Adequacy Response The 100 -year floodplain intersects the affected lands only to the north of the Big Thompson River and can be seen in both drawings. It's clearly identified in the C-1 Legend there the 100 Year Floodplain appears in True Blue. The line remained as a reference on Exhibit -2, but having been called out on C-1, did not appear in the C -2 Legend. 12IPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zither, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. ! .r Division Second Adequacy Comment '-_ r i Ly r raj i t 1 673+-•PRESCRIF_AWL" APRQXIW7E FLOODPOIN IW1 d GARY (Mr PlOTE 6) — f • 1 5 TN STREET ) �> RUNE Of :. EVrws'rnrf*4. WC. NO:, . . fag (MEPTION 10 * 22) '� r es- CAMENISCFl-J-�• 1 i V 331.15 +' esSfiCtr frit Arra.: Mc NO 2410,746 J 70.1 * f.2©' EASENENT -, - 'R`M, NO, j74a (Ekc"fT'rcN 4s) 'I- t No additional response is required from RM. 13) For the sake of clarity, the Division recommends that the entire permit area be permitted to be affected, and this should be stated in Exhibit C and Exhibit D. (The 'vision recognizes that this statement is made in Exhibit L.) Raptor Materials First Adequacy Response Your language is accurate, for it provides more precisely that all lands within the permit boundary may become `affected lands.' Regardless, this statement is included in the Original Submittal Exhibit D, Pages 5 and 8: 131Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zub,er, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project - M2022-013. 6.4.5 EXHIBIT 0 a Extraction Plan Is 11± feet from the surface, we determined the Static Water Level using the upper limit of 5.0± feet, The Cyan colored contour shown on Exhibit G: Water information Map represents the Static Groundwater Elevation at 4675' at North-West Field, and 4673' at Central Field. Since completed reservoirs will be lined to meet State of Colorado Water Resources specifications and requirements, and since lined basins will ultimately equalize with the surrounding groundwater elevations, the Static Water Levels shown should reasonably reflect those of the both the lined or unlined state; and represent a proper reflection of the optimal surface area of the water over the finished basins. Varra Companies, Inc. has sufficient water to meet the circumstances and obligations of both the lined and unlined states; and as reflected under Exhibit G: Water Resources Information; until and tmless the reservoirs have an approved liner, the operator will dedicate sufficient waters to secure the reclamation of the resulting basins in the unlined state. Planned Field Activities: The 409.23± acre parcel boundary fo Hs the permit boundary, as reflected on exhibit maps. All lands under its direct control within the 409.23± acre permit area, are affected lands under C.R.S. 34-32.5- 103(1), respective of this permit application. As a result, any changes required in the nature of planned axtraction or reclamation will be made only through the Colorado Office of Mined Land Reclamation (OMLR), by Technical Revision only. If lands are needed beyond the designated permit boundary, those lands will be secured for the active OMLR permit by Amendment. AND: 6.4.5 EXHIBIT 0 — Extraction Plan Operations svill predominantly utilize unmodified existing agricultural field access roads (unless other ise indicated), winch will themselves be subsequently extracted in time where they fall within the extraction limits shown on Exhibit C-2: Extraction Plan Map. 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. For purposes of this submittal, all lands within the indicated permit boundary will be considered affected landst but only those locations between the existing access roads, and which otherwise remain above the anticipated static water level of the resulting basins, will he soiled (where soil is absent) and seeded toestablish vegetation consistent with the approved reclamation plan. Division Second Adequacy Comment No additional response is required from RM. 141Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the shatter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. 14) During the pre -operations ground truth inspection on June 14, 2022, the idea of relocating the access point at the northwest corner of the site (to the east) was discussed. Please update Exhibit C-2 to reflect any change in that location. i Raptor Materials First Adecuacy Response No changes to Exhibit C-2 are necessary as no change is proposed to access at this time. Alternate plant site development and access may be considered at a later time if possible and in consultation vvith the city of Evans. Any future changes will be included as part of a Technical Revision to the approved permit at that time. Division Second Adequacy Comment No additional response is required from RA; . 15) Please add the following to the Extraction Plan. Map, Exhibit C-2: roads, parking and equipment storage areas, levees, soil piles, keys, settling basins, and other structures pertinent to the mining operation that are not currently shown on the map. Comments on the map can indicate where these features are subject to change. Ra ' tor Materials First Adequacy Response There are no established parking and equipment storage areas. Parking may occur within planned active extraction, along existing access roads, or within the Homestead location. Levees are also access roads for street legal vehicles and service trucks. These roadways atop the levees are not designated forextraction and are visible to scale on the outer perimeter of planned extraction areas. There are no soil piles at this time, except that identified as stockpiled soil from the adjacent Westervelt Wetland Bank, and as established and set aside over the entire NE Section of Central Field, as stated in the application. Updates to soil stockpile conditions over the NE Section of Central Field, or other locations, may also be updated in required Annual Reports as conditions warrant. As previously stated in the application, keyways are a feature that run at or near the toe of extracted slopes. It is unprecedented to show them in an application but can be updated in required Annual Reports to better reflect their size and extent, as they are field fit concurrent with extraction progress, which may vary in a manner 15IPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. difficult to portray in advance. Here's some additional information taken from the application on the planned keyways: 3 6.4.12 iEXHIBIT L - Reclamation Costs follow the perimeter of the extraction limits over approximately 75.45± acres in order to establish the perimeter keyway for the 127.10± acre Center Section of Central Held. The perimeter extraction will leave a 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The initial extraction area is bordered to the South along a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). Extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed under Exhibit D: Extraction Plan. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary sealing basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line, and may then be extracted itself once discharge is discontinued for Central Field Operations. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H:1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.00H:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and exise the bed dimensions where the resulting channel is sufficient to convey the g roundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape and size presented. 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. Division Second Adequacy Comment • The Division reiterates that structures related to the mining fining operation need to be on Exhibit C-2. Regarding soil piles. RM states in the responses that, "There are no soli' piles at this time." ho tie vet. the purpose of the map is to illustrate the plan far soil piles in the future, and those should be shown on the map. • The Division requests that the term "keyway" be clarified by RAI is this actually a de- watering tren ch ? • The purpose of Annual Reports is described in Rule 1.15. These reports are not to be used to make changes to the mining and reclamation plans. Those changes must be made with technical revisions and amendments. 'Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Raptor Materials Second Adequacy Response • The temporary soil stockpile location in the North-East Section of Central Field is labeled on Exhibit C-2. • RM confirms the term "keyway" as used generally in the Two Rivers application is a de- watering trench. This is clarified in each Exhibit where the term is used when referenced for the first time. • Acknowledged 6.4.4 Exhibit D - Mining Plan 16) in this and other exhibits, an effort should be made to update agency names. For example, the Colorado Division of Wildlife is now Colorado Parks and Wildlife. The abbreviation CDH should be CDP Raptor Materials First Adequacy Response Please refer to the discussion as it applies to the use of agency names and anacronyrns, as discussed in the Prologue, above. Division Second Adequacy Comment No additional response is required from RM 17) The mining plan (aka extraction plan) requires more detail. In particular, the plan should include a schedule that specifies the areas to be worked for given phases, with ranges of time periods. The phases described in Exhibit D should be coordinated with the Extraction Plan Map, Exhibit -. The operator can change the plan later, as needed, with technical. revisions and/or amendments. Additional clarification on the sequence of the mining plan is necessary to calculate the required financial warranty. Raptor Materials First Adequacy Response Fields vs. Phases: As detailed in the Extraction Plan over pages 13 and 14 (copied below), we detail a modified Phasing Plan based upon Field Sections. The NW Field is Separated in the whole by a public road from Central Field, while Central Field is bound together in three contiguous Sections (you may consider them Phases, although not sequential phases as they can be accessed simultaneously in time). So, the Fields and Sections are distinct from conventional mining phases, in that with enough Warranty, any or all can be accessed andextracted independently and simultaneously, instead of sequentially. 17page Correspondence to the Colorado Office ofMined Land Reclamation — Reply to Rob Zuber, EPS a Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. One of the attributes of our Established Extraction Methodology is the use of flexibility to aid a rapid access to the deposit and completion of the basin. If needed, four separate extraction teams could be set up in each Section or Field to speed or adjust the extraction timeline. This has been a feature accepted by the Office over many submittals and many years. Your own Specialist, Peter Hays, can attest to this. The timely application and use of Annual Reports, or Technical Revisions, to anticipate and adjust attending Financial warranty to allow the operations to pulse over time is a humble approach that respects the requirements and objectives of the Rules and Regulations. The idea is designed to reduce the need for untimely delays and expensive permit revisions, as well as needless field operation conflicts that can also jeopardize Compliance with otherwise rigid self-imposed constraints. The greater beneficial effect is to flexibly match extraction and subsequent reclamation as operations adjust more naturally to shifts in marketdemand that determine the functional life of the mine. This is a projected 35 -year life of mine operation that could be shortened or lengthened by economic influences and other factors for levhich we and your office cannot reliably or genuinely foresee. This answer skill play out for Exhibit L as well, as the entire described Onset Area is not essentially planned for disturbance, simply the area where initial disturbance may onset, however, given possible directions NE and SE along an idealized core, could affect 8-16acres over the course of the initial 2 years, unless we hit a depression and it takes 10 years instead. Unlikely as either are, they are projections in time. The actual areas will be monitored using aerial imagery and handheld survey instruments to monitor and report the acreages and make revisions to the Plan and estimated Warranty in response to the current market drivers of the business. We will then reflect this on related maps and as content through the annual report process as determined at the time. Active Resource Recovery: Following soil salvage, the balance of the extractable deposit will be removed to the depth of the unconsolidated or weathered bedrock, transported by conveyor to the plant site pit lea and subsequently manipulated as desired by screening, crushing, washing, and other methods to size and properly dimension the earth product into diverse merchantable materials for sale. Resource recovery commence radially North and East from a point near the existing pond and planned first discharge point shown near the Southern boundary of Central Meld_ There are no fixed sequences or phases scheduled as pan of the extraction plan. Instead, Fields are used instead of Phases to describe the activities, since each BleM, can be accessed concurrently instead of sequentially with the 181Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS -Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. e 14 6.4.5 EXHIBIT D — Extraction Plan other: as reflected or otherwise updated as part of required oMLR Annual Reports_ Under this method, extraction is "pulseci.! As such, the rate of extraction and subsequent reclamation will slow or quicken according to influences of the markets, weather, and inter logistics_ Flexibib.ty in operations encourages better outcomes when adapting tog circumstance or unexpected field conditions, and may involve actively working different fields or different parts of the same field as necessary_ Generally, flexibility aids integrity of operations and encourages optning operational activity and subsequent reclamation of affected lands_ Therefore, any method that accelerates the extractiontimeline will be utilized, ze►d, and should be encouraged to better engage the i predictable dictable elena - is and variables that reasonably affect the capacities of the operator_ Exhibit C-2: Extraction Plan Map, shows the location and planned extraction limits, general direction of extraction, and related features described above; along with features made obvious in the included aerial ire of the permit location and surrounding lands_ Additional information is provided under Exhibit C-1: Egg Conditions Map; which shows all known current and active significant manemade stnictures located on or within 200 feet of the permit boundary detailed under • t eluding creeks, roads, buildings, oil and gas facilities [such as tanks, batteries, wells and lines], and power and communication lines and support mixtures, easements and rights -of -way, located over the permitted lands or within 00 feet of the same. A listing of the adjoining surface owner's names and addresses located. within these areas are listed under Exhibit C Text, correlated with those shown n the afore -mentioned Exhibit C-1: Existing Conditions Map. Division Second Adequacy Comment ATM needs to clarify an apparent contradiction between the response toitem #17 and the approach to minimizing impacts on wildlife, as required by Rule 3.1.8. On page 15, the response states that "Your separate extraction teams" could be used to hasten the extraction schedule. Ho we verb, the ERO memorandum (August 26, 2022; page 2) describes an incremental approach that will protect mule deer habitat by only disturbing a 1' el a 4- i vel y sm a i ! area at one e time. m e. The text in the m el f l o suggests that a iaximurrn size for an active cell is 16 acres. This example illustrates the need to better define the mining and reclarna tion plans. Raptor Materials Second Adequact esponse The First Adequacy response has been incorporated into the revised Exhibit (p16, Footnote 4). Also, in revised Exhibit D, the wildlife concern has been 19jPage Correspondence to the Colorado Office of Mined Land Reclamation -- Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project —1 022.013. addressed and is supported by a letter from Ron Beane, senior Wildlife Biologist with wildlife consultant ERO Resources Corp attached as an addendum to Exhibit (p17, Footnote 6). 18) The discussion on pages 6 and 7 regarding structures and easements should discuss which structures and easements will be relocated or removed from the site (if any). Raptor Materials First Adequacy Re ponce lands within the Extraction Limits, only those structures, easements, and rights -of -way shown in Exhibit C-2. Extraction Plan Mal are anticipated to remain from those shown under Exhibit C-1: Existing Conditions Map. If changes to existing or possible revised structures, easements, or right-of-way are in any manner retained, or where they might occur subsequent to ° MLR approval of this application, then a Technical Revision vA l be submitted to update Exhibit C-2: Extraction Plan Map. All established set -back distances from planned activities will be maintained regardless. Operations are not intended to affect existing structures, Easements or Right -of - Ways within the Planned Extraction Limits or related Processing Areas and Wash Pond, and are designed to avoid and retain any structure, Easement or Right -of - Way on the surface, and subsurface. Future agreements may be reached allowing mining in areas currently identified as being restricted to mining containing certain structures, Easements or Right -of -Ways. Exhibit C-1 shows and identifies all these features understood by us, and the respective surveyed information, and correlated observation and Title Work upon which they are based and represented on the attending Maps. The Maps are not Surveys. They are Maps and as such, they comprise a reasonable representation of all site features, but must not be relied upon by themselves exclusively for location purposes. Maps and features are not a substitute for identification of underground structures and will rely upon location services of the 811 service. Exhibit C-2 shows the remaining Oil Wells and Lines within Planned Operations at the time of the Submittal. Any revisions, additions, or modifications of residual Oil Wells or Lines will be avoided as represented on updated Maps and Revisions to the Permit, and consistent with Setback Distances identified in this submittal. Removal of any Existing Structures such as the oil and Gas structures and or lines, will be updated on required Annual Reports, or by Technical Revision, as warranted, or as otherwise directed consistent with Colorado Statute. 2U1Page Correspondence to the Colorado Office of Mined l -std. Reclamation — Reply to Rob Zuber, EPS — Adequacy Utters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Division Second Adequacy Comment As noted at the beginning of this letter, RM needs to revise actual exhibits (in thh case Exhibit U) to address adequacy items and re -submit them. Also, please address the particular structures (above -ground and underground) and easements shown on Map C-1. Raptor Materials Second Adequacy Response As requested, Exhibits C-1 and 0-2 have been enhanced and an updated table added to Exhibit C-1. Further the matter is addressed in revised Exhibit D (p7, Footnote 1). 19) On page 7,. more detail is needed for the roads onsite. Please explain which roads \kill be built and which will be modified. Explain construction method and dimensions. Raptor Materials First Adequacy Response All lands within the Extraction Limits will be traversed during extraction and are not roads. Areas outside of Active Extraction that have existing agricultural access roads below the existing riverside berms, may be accessed by all manner of vehicles and equipment and may be modified accordingly. In this instance, these are not leased lands but owner operator lands. As such, any improvement of existing access roads, or creation of new access roads, are capital improvements of the land. Therefore, all improvements to access are an asset to the lando m ert and as such, ll not be removed b - a default by the operator, but retained subsequent to extraction where they are not otherwise removed by the same. This is established real property law. As todesign widths and composition, this will be field fit and determined, and updated in required OMLR Annual Reports. Road widths will vary but may typically be 10 to 40 feet wide depending on end use. Road surfaces will be fit for purpose and constructed using site produced materials if necessary to improve or establish the running surface. Division Second Adequacy Comment No additional response is required from RAI 21 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS --- Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. 20) on pages 1 - 13, the discussion on stockpiles should include teat indicating that soil management practices will protect the soil piles from erosion, prevent contamination of the soil from toxic or acid-forming material, and ensure that the soil will remain usable for reclamation. Raptor Materials First Adequacy Response Comments 20, 23 and 32 \Ae believe are best addressed in a comprehensive rather than fragmented manner. Consistent with the backfill permit, it would be highly unusual that an alluvial aggregate operation would find potentially toxic or acid forming materials, nor would they if found be utilized. Sulfur is sometimes used on plains soils where acidification moderates alkalinity or the planting of evergreen trees which prefer a slightly acidic soil. Nonetheless the operator's intent is not to create or import such a problem. .if found on site such materials would be disposed of in an appropriate landfill. The application does attend to the real threat on irrigated lands, which is the accumulation of salts due to evapotranspiration in some p circumstances of the lower soil profile, which profile is significantly absent in U nit 3 Soils, as iterated here: Continued...next page... 22 Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project -- M2022-013. 6.4.5 EXHIBIT D - Extraction Plan Unit 3 soils commonly form within floodplains. As a result, differing states of soil formation may exist within the soil unit designation; such as soils with little horizon development like tipa s and lanagigh. Mglibegi4 with deep well -developed horizons may exist in the minority and the near hinge of planned extraction. Refer to graphic above, and Meow. Enc - • tiso l ti,•,, mow. a. „F - y : . --r Soil Morphology olisoi I nc_ppjjsol 111115*Sdat - a , 1 F - n with over a century of agricultural manipulation of area agricultural fields, prior mixins, or importation of soils for land leveling, or flood plain management in the creation of levees, may have dramatically altered the original native soil profiles and properties,. The native A profile of the upland terrace found within the agricultural Fields at the TRP, is predominantly modified as a plow (Ap) layer of 6.0+ to 8.0± inches. The historic practice of corporati.ng manure into the plow layer should have served to maintain the organic base and quality of the cropped ed soils and accelerated soil horizon formation and development where it was lagging. Since the cropped soils 1i have been irrigated, care should be taken not to salvage soils greater than 12.0± inches in depth to avoid mixing of potential accumulated salts. We use Exhibit i/J to expand upon Soil and Vegetation considerations that are also considered relevant to Exhibit E - the Reclamation Plan and correlated as well in attending supplemental information provided from the U.S. Natural Resources and 23 Page Correspondence to the Colorado Office of Mkted Land Reclamation — Reply to Rob Zuber, E1's — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Conservation Service (formerly the U.S. Soil Conservation Service). The SCS were the principal authors and creators of soil conservation and management throughout the United States, and the first to systemically incorporate plant -soil -water relations in their considerations, ithich are certainly a factor in our own and reflected in the correlated exhibits to reflect their influence and relevance in this submittal. Persons familiar vvith the SCS/NRCS, know these are the authors of soil stabilization, so we commonly locate this information under Exhibit I/J, where the information used for those considerations resides. Subsequently, what follows is a guide through the Application to reveal how the matter was addressed. We hope this clarifies and assures the office in this manner. It should be understood that the application attempts to guide the reader point blank, as follows: LW 6.4.5 EXHIBIT D — Extraction Plan Soils found within the entire project area are described more thoroughly under Exhibit I - Soils Exhibit, and the attending Exhibit I/J - Soils and Vegetation Map, shown not to scale, above. Additional geologic considerations are also included under Exhibit S - Stability Analysis. Area and Site Geology The area geology is typified by mixed alluvial and Soil Stabilization methods are rather extensive in the application, intended to minimize erosion and impacts to waters and adjacent lands. Specifically, soil salvage and stockpile stabilization are called out by topic under Exhibit D, as follows: Continued...next page... 24IPage Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EP - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. SoilSalvage: Resource recovery will commence by first removing the upper [, . profile/plow layer) six to t ► elve inches of soil [six (6.0±) inches typical], combined with e3disting grass or crop stubble. Removal will utilize scrappers or excavators, aided by dozers where necessary, and hauled to the Northeast Section of Central Field_ _ ex -traction and surface related activities detailed in this application will occur under an approved Fugitive Dust Permit issued by the Colorado Department of Public Health and Environment (CD_ Until resoiling activity occurs, where harvested soils have been stockpiled and remain undisturbed for reclamation or sale, they will be seeded with the mixture specified under Exhibit L - Table Lei- Primary/Preferred Revegetation Seed Mixture. A stabilizing cover of native vegetation ,T take up to three years to fullyestablish the desired cover. In the event the native seed mixture fails, an optional mixture of predominantly introduced species be used as a fall back to better assure a stab " cover of vegetation. Still, using the ge $13 6 4.5 EXHIBIT D — Extraction Plan preferred native seed rnitnire offers opportunity to gauge the potential performance of the selected species prior to utilizing it over larger areas requiring reclamation later in the life of the resource recovery operation_ Once vegetation is established over the initial reclamation soil stockpiles, they will likely. remain untouched for the life of the operation until final reclamation of remaining affected lands takes place_ Where concurrent reclamation is possible, operations il]. u • -ze soil • an over the shoulder method when practical In this manner, reclamation is expe sited without increasing soil stock -pile volumes while reduc" . g expenditures related to labor, handling, and tee_ There are no agents preventing the soil from functioning for reclamationother than the inevitable loss of some native soil structure, organic matter, and fertility that can be compensated for by any analytically determined need at the time of resoiling and revegetation, via analysis using of soil samples by the CSU Soils Laboratory. This and other measures are detailed in the application under Exhibit I/.l: Soils and Vegetation Information, as follows: Continued... next page... 25I Page Correspondence to the Colorado Office of Mined Land Reclamation — Remy to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project M2022-013. Once applied to the surface, the new soils will be exposed to the raw forces of erosion until adequate vegetative cover and root mass develops. Erosion requires both detachment and transportationin order to occur. Running water, wind, and raindrop impact are the main forces of erosion acting upon the soil. The use of a sterile hybrid live cover crop will aid in the stabilization of the soil by allowing a quick vegetative cover to become established in advance of the native grasses. The hybrid will also serve as an aid to reduce competition resulting from the establishment and growth of unwanted pioneer species (weeds) on disturbed ground. The attending reclamation seed mixture/ and as approved, has a provision for the use of a sterile hybrid grass in lieu of mulch. Mulch, even when crimped with specialized equipment, is subject to being blown off the property, or reduced to an ineffective stubble. Often, it has been observed to intercept rainfall where it quickly evaporates from the stubble surface, limiting the benefits of light precipitation by preventing infiltration and percolation of moisture to the root zone. The hybrid on the other hand will establish quickly, but since it is sterile, will not continue to compete with the emerging native grasses. After two to three years, the hybrid grass will begin to die out just as the native grasses emerge and improve their dominance over the revegetated areas. Increasing Organic matter, such as the incorporation of manure into fallow soils, will aid in the restructu ri ng of the new soils by increasing the mo istu re and fertility holding capacity of the upper profile seed bed, while simultaneously facilitating healthier plant -soil -water relations and overall root development of the emerging grasses. As the roots of the emerging grasses develop and mature over time, the resulting root mass will serve to build upon the base percent organic matter content of the new soils, thereby increasing the potential for long term survival and spread of the established grasses. Soil testing may occur on the new soils to better gauge the need or success of any applied organic soil amendments respective of the resulting vegetative cover. The addition of fertilizer may also aid in the establishment, growth and survival of the emerging grasses. Fertilizer may be applied to the seeded areas at rates determined from soil tests of the reapplied soils. To this end, soils may be sampled as needed. Sampling will utilize a hand auger and approved NRCS soil sample bags, and utilizing recommended procedures. Any soil testing will be conducted by the CSU Soil Laboratory in Ft. Collins, Colorado, The tests will be used to monitor soil quality and suitability of any amendments. Fertilizer may be withheld until after emergence to deter the encouragement of weed species. The use, composition and rates of 7 6.4.5 EXHIBIT I/J — Soils and Vegetation information fertilization will be determined prior to the time of seeding where appropriate, and may be reported in the OMI R Annual Reports, as appropriate. WEED MANAGEMENT PLAN: Because the Agricultural Fields are the only planned area where the deposit itself will be extracted, it should be understood they are within the floodplain of two rivers. As such, stockpiling and placement of soil is initially designated outside of the flood plain on top of the pre-existing sol stockpile located over the NE Section 26IPage Correspondence to the Colorado Office of Mined Land Reclamation a Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. of Central Field, until such a time as sufficient detention can be created to accommodate above ground stockpiling. The application provided a copy of the Westervelt project detailing that this area of extraction was removed by the City of Evans from the floodplain. There are no floodplain impacts anticipated by continued stockpiling of soil over that location. We can affirm here that stockpiling above the existing ground elevation will not occur in a manner understood to obstruct flood waters where they might occur within the existing floodplain. It is understood and agreed here -in that their longitudinal dimensions if they occur there should extend parallel to anticipated flood flows where they exceed a cone or other shape that might find its existence contrary to intent by volume beyond that which could be understood to be temporary, or transitory; especially outside of seasonality where flooding might be more reasonably anticipated. What follows is information provided in the application (Exhibit bin that was intended to address this concern as to e t sting volume stockpiled at that location; .and a volume which exceeds the necessary volume needed to reclaim the completed project. The thickness of topsoil capping to be placed is stated as "All affected lands between the extraction limits and remaining above the anticipated high-water mark of the basins will be capped vvith a minimum of six (6.0±) inches of soil, as supported by Ei 'bit I J -- Soils and Vegetation Information." In Exhibit E (p5) and "there is sufficient soil to assure a re -soil depth of approximately six inches over the basin banks above the anticipated static water level of the reservoirs" in Exhibit IB (p4). Haul and push distances to re -soil will vary based on the actual progress rate and active sections of the operations. Where possible once the operation matures over the shoulder placement will be employed where possible for efficiency and best outcomes with soil. RM will report this activity in the Annual Report as the circumstances for re -soiling become clearer. 271Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Graveland Reservoir Project - M2022-013. 6.4.5 EXHIBIT I/J — Soils and Vegetation Information A portion of in situ soils may be used in an over the shoulder method to resell the completed banks of basin slopes or other upland areas in time. Commonly, soils will be parked in stockpiles until ready for application in a manner more fully described below. Consistent with existing zoned agricultural practices, soil from an adjacent wetland bank was approved by the City of Evans, and completed In early 2021. The City of Evans approved (refer to the Addendum at the back of this Exhibit) the placement of these soils within the floodplain of the upper North-East portion of Central Field, as shown on Exhibit C-2: Extraction Plan Map. These orphan soils are in place, seeded/ and the area remains under continuing agricultural production, yet are no longer part or the area floodplain. The current extent of this 200,000± cu.yd. stockpile is represented on Exhibit L: Financial Warranty Map. This stockpile location area will also receive a portion of soils removed from planned extraction locations over other areas of Central and North-West Fields. it should be noted that a monoculture of cultivated corn occupies a majority of the planned areas of extraction, and will gradually be turned out of production through extraction. This soil may be utilized to line the resulting basins, for reclamation of affected lands above the static water level, or for market as warranted. Division Second Adequacy Comment No further response required The Extraction Plan does discuss how soil piles will be stabilized. It also discusses how fertilizer can compensate for the loss of organic matter. Finally; the applicant has stated that potentially toxic or acid forming materials would not be utilized in die reclamation activities. 21) on page 14 in the second to last paragraph, the sentence that begins "Specific variations in the location of -••" should be re►-itten. The structure of this sentence does not follow standard rules of grammar, and (more importantly) the meaning � y g is not clear. Please revise this statement accordingly. Raptor Materials First Adequacy Iesporse The paragraph segment was simply a DRAFT oversight. There is a tendency to look at lines drawn on a map in a rather precise manner. The forces of nature have laid don a valuable resource that cannot be defamed with absolute precision and consequently, applications and actual conditions combined with human error and massive equipment sometimes are unable to make that pencil lined vision in ink line up with reality. Slight variations and departures � es in the field may occur from time to time, often to ensure safe conditions, minimize impacts, or to fulfil an obligation to m "mite the recovery of the resource. Here's a better version that now clarifies this spot under Exhibit D: 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 28I Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob ,tuber, ' S — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022 -O13. 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 self -inspection, .3f �' by observation from WES inspection in a timely manner, or by opera tor-in.itia ted Revision to the Permit or otherwise via clarification in attending required °MLR Annual Reports.' Division Second Adequacy Comment RMneeds to revise Exhibit D to address this item and re -submit It-. Raptor Materials Second Adequacy Response The First Adequacy response provided has been added to revised Exhibit D as requested (p17, Footnote 7). 22) on page 14 in the last paragraph, the units are not specified (appears to be 125 feet), and this should be revised. Also, add a discussion on pipelines to this paragraph as appropriate. Raptor Materials First Adequacy Response As seen on the paragraph preceding the oversight, as reproduced by Snippet, below; underground gas lines or other underground facilities are referenced. The missing units are confirmed as `feet,' . Continued...next page... 29IPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Mbar, EP — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. The extraction limits assure through the use of setbacks that other interests are not affected by planned extraction, Extraction is set back uniformly at a minimum 10.0± feet from the edge of property lines; easements and rights -of - way; underground gas lines or other underground facilities, irrigation ditches and seep ditch, wells and other structures. Specific variations in the location of: stockpiles, boundaries of extraction, and related information relative to adjacent structures and easements; from that represented on Exhibit C-2: Extraction Plan Map. Extraction will not occur closer than 12 5± ifrom the face of a residential structure; unless there is a written accommodation with the owner of the residential structure that allows extraction to occur within a closer stated limit. Extraction will occur no closer than 25± feet from well heads and related above ground facilities. Extraction around well heads \v ll be concurrently backfilled to maintain a 100± foot buffer from the balance of extracted lands. At all VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112) CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MI NG & SAFETY OFC ICE OF MINED LAND RECLAMATION 6.4.5 EXHIBIT D a Extraction Plan Division Second Adequacy Comment Page 115 RAJ needs to revise Exhibit D to address this item and re -submit it. Raptor Materials Second Adequacy Response The revised Exhibit Dhas been corrected as requested (p18, Footnote 8). 23) on page 16. regarding the discussion on topsoil and overburden stockpiles, . p � more detail is needed regarding the storage volumes and locations of the piles, including distances from the piles to the areas to be reclaimed. It is recommended that they be shown on Map C-5. It should also be stated that the piles will be configured to prevent obstruction of flood waters, namely elongate the piles to make them parallel to the flow direction. 30IPage Correspondence to the Colorado Office of Mined Land. Reclamation — Reply to Rob Zuber, EPS Adequacy Letten of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project - M2022-013. Ra for Materials First Ade uac Res onse There is no reference we can identify on p16 to stockpiles, at least not explicitly. There is discussion of backlilling cut slopes and topsoiling above water line. Nonetheless items 20, 23 and 32 all broadly relate to topsoil and need to be read together via a consolidated response to comment 20. Division Second Adequacy Comment It appears that the extensive discussion on soils does not include any information regarding the quantities of soil in stockpiles or the location of soil piles. This information is required for a detailed reclamation cost estimate and needs to be added to the Extraction Plan, Exhibit D. Raptor Materials Second Adequacy Response The information requested has been included in revised Exhibit D (p 14, Footnote 2). 24) In the section Plant Site Development Sz Operations, text should be added regarding the details of structures that will be built, including the conveyor. Dimensions and other details should be provided to aid in the estimate of demolition costs for these structures. Raptor Materials First Adequacy Response Equipment to be used atthe plant site is described in the Plant Site Development and operations section on p19 as shown below. Plant site equipment will be semi - mobile in nature and is not expected to require permanent foundations or footers. The conveyor will be set on an elevated structure at varying heights to be situated about the 1 in 100 -year flood level. An average height of 7 feet is expected. The conveyor will be supported by legs at intervals of approximately 20 feet with concrete blocks used as necessary to anchor the legs. Final conveyor specifications are to be determined but a 24-36" belt is anticipated. 31IF'age Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and S August 2022; in the matter of the Two Rivers Sand, Gravel and. Reservoir Project a M2022-013. age I 1 6.4.6 EXHIBIT D — Extraction Plan north-west of the existing Evans Ditch as it courses IN" i ds north of the Big Thompson Rivera Plant activities will require a wash plant and attending wash pond to recycle wash water and receive discharge silts and other reject fines from the washed product want and Wash and areas are identified on Exhibit Cez: Extraction Plan Map. The wash pond will function as recycling wash water and recei basin for reject fines for the intended Plant/Processing activities. Since the basin functions in a closed system, it will not require dewatering. Once the wash pond is established, wet plant operations can be created and join any d y plant activities in progress. Dry Plant operations can be readily established since water is not integral to their operations_ once established, wash pond water will function as a closed system Settled materials from wash Ponds will be utilized as product or for reclamation as desired. Plant equipment will include, but is not limited to, a crusher, screens, and conveyors, scale house and scale, and attending equipment. Resulting stockpiles of pit nin and processed products may be temporarily stockpiled here with processed stockpiles, or combined as needed, til transported to market Division Second Adequacy Comment • More detail is needed regarding the conveyor. Please pro v de the size of the con veyor. Also, provide the dimensions of pads and other foundations that will be used for this structure and provide an estimate of the total volume of concrete that will be used. Related to this, Exhibit L will need to be updated to include the cost of dismantling the conveyor. • Please describe the measures to be taken to prevent material from overtopping the conveyor system and falling into the Big Thompson River.': Ra R for Materials Second Adequacy Response The First Adequacy response provided has been enhanced and added to revised Exhibit D as requested including additional discussion on how material originally placed by the river will be prevented from falling from the conveyor back into the river (p23, Footnote 9). 25) In the section Plant Site Development & Operations, text should be added regarding the control of prairie dogs. Will they be relocated? 321Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand; Gravel and Reservoir Project v M2022-013. • Raptor Materials First Adequacy Response Please see response item "Issue -- Prairie Dogs" prepared by ERO dated August 26, 2022 attached as an addendum to Exhibit H. Division Second Adequacy Comment No additional response is required from R1. 26) The applicant should discuss the following (related to Rule 3.1.8): How vsgrill the operation minimize impacts on mule deer habitat during the winter season (December 1 through April 30). This should include (but not be limited to) a discussion on fencing. Fencing should be limitedas practical, and wildlife -friendly fencing should be used. Raptor Materials First Adequacy Response, Please see response item "Issue - Mule Deer (severe winter range and migration corridors)" and "Issue - Fencing" prepared by ERO dated August 26, 2022 attached as an addendum to Exhibit H f Division Second Adequacy Comment No additional response is required from RM. 27) Include a discussion on how the operation will allow for deer and other animals to "escape" the mining operations. Raptor Materials First AdeQuacy Response Please see response item "Issue - Escape Ramps" prepared by ERO dated August 26, 2022 attached as an addendum to Exhibit IL Division Second Adequacy Comment No additional response is required from R . 6.4.5 Exhibit B - Reclamation Plan 28) The Application form specifies that the post -mining land use of the site will be Developed Water Resource. Additionally, the Applicant has provided a shadowing/mounding analysis for the installation of clay liners. However, the Reclamation Plan notes (page 5) that lining of the reservoirs is an option only. If the 33iPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 Ault 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Applicant wishes to maintain lining of the reservoirs as an option only, then the Application must be revised to reflect that the reservoirs will he reclaimed to open groundwater ponds. If the Applicant chooses to reclaim the reservoirs to open groundwater ponds, then the following options are available to address the liability associated with exposed groundwater: RaptorMaterials_ First adequacy Response Please consider the Application Form to be correct and disregard any ambiguity in the application exhibits, Raptor Materials intends to establish lined reservoirs in final reclamation for the purpose of establishing a Developed Water Resource. a) Provide adequate bond to backfill the pit to two feet above the historic highest groundwater level. Raptor Materials First Adequacy Response The application is clarified to reflect choice of lined reservoirs for final reclamation eliminating the need for backfill calculations. b) obtain a court approved augmentation plan prior to exposing groundwater at the site. Raptor Materials First Adequacy Response As the pits will be open ponds until they are lined and approved by the Office of the State Engineer, a court approved substitute water supply plan will be obtained prior to exposing groundwater at the site. This is stated in Exhibit E, p4, specific Reclamation Elements and Methods, third paragraph. 34 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand{ Gravel and Reservoir Project — M2022 -4H3. Specific Reclamation Elements and Methods: This application provides substantial detail of features utilizing aerial photography that is ortho-rectified to approximately 1.0±- percent of sun -eyed accuracy. This highly accurate and detailed portrayal of planned extraction and reclamation is visible under Exhibit C-1: Existing Conditions, Exhibit C-2: Extraction Plan Map, and Exhibit F - Reclamation Map. How reclamation will occur over affected lands is further detailed under Exhibit L - Reclamation Costs. As extraction progresses over the Fields south of the Big Thompson River, the resulting 1.25H:1V slopes (2H:1\-, where indicated) created during extraction will be concurrently modified when and where practical. Concurrent reclamation is a natural incentive for Operations to speed site recovery while generally sen-ing to lower attending financial warranty burdens. The cut slopes along the extraction limits perimeter will be finished graded by pushing the resulting pit bottom with a dozer until the resulting basin slopes conform with Rule 3.1.a(i). Since the primary end use is Developed 'Water Resources, the basins are intended to hold waters based upon the rights assigned bis) decree, or as stipulated in regulatory compliance with the Colorado Division of Water Resources, Office of the State Engineer (OSE). This may include the need to augment water sufficient to cover the anticipated exposed groundwaters of the basins in the unlined state. The - is or will be sufficiently covered under an approved substitute supply plan. In order to again liberate waters set aside for augmentation, the basins silllAtme point in the life of e activity be lined to segregate the basin from Colorado groundwaters. Alternatively, the Applicant may clarify that the post -mining land use of developed water resource will be achieved through clay lining the reservoirs. If the Applicant chooses to clay line the reservoirs, then the Applicant shall provide enough detail for the Division to calculate the cost to line the reservoirs. Raptor Materials First Adequacy Response The application will be revised to reflect choice of lined reservoirs for final reclamation. Details of reclamation to form lined reservoirs is contained in Exhibit E, pp 4-5, specific Reclamation Elements and Methods. 35 Page Correspondence to the Colorado Office of Mined Land Reclamation —Reply to Rob Zuber, E "'S — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Lining of basins involves the placement of low permeability compactable fill, from on -site or other suitably sourced geologic as aterials, into the keyway; 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 and slopes are also covered and compacted with the same materials until it meets the standards established under the August 1999 StateEngineer Guidelines for Lining VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION -COLORADO DIVISION OF RECLAMATION %MING & SAFETY OFFICE OF MINED LAND RECLAMATION 6.4.5 EXHIBIT E - Reclamation Plan 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 OMLR on receipts or as part of any request for release of the permit, in part or whole. Essentially, the pus s ed parent rock material will form the minimum h:1v slopes of the basin and be compacted to a permeability of 104; forming a lined basin that complies with Colorado Water Law and Guidelines mentioned, above. In this manner, the lined basins will maintain a required separation and accounting of stored water from the underlying ground waters. Evidence of compliance with the rules and regulations of the Colorado Division of Water Resources will be provided to t t e OMLR on completion of the lined basins. Division Second Adequacy Comment RA/ must update Exhibit ,? to remove ambiguity in the plan in general, and in particular in comparison to the application .corm. Raptor Materials Second _ Adequacy Response The application has been revised as requested with wording revised or removed completely in various revised Exhibits to remove ambiguity and provide clarity that the reclamation plan and proposed post mining land use is lined water storage. 29) The reclamation plan requires more detail. In particular, the plan should include 36IFage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. a schedule that specifies the areas to be reclaimed for given phases, with ranges of time periods. The phases described in Exhibit E should be coordinated vyith the Reclamation Plan Map, Exhibit F. Raptor Materials First Adequacy es onse Refer back to Item #17: We avoid the use of 'Phases' to aid simultaneous development of Sections within Fields. The rules provide for clarity in Required Annual Reports and via Revision (Technical Revisions & Amendments). The goal is to provide flexibility in the document, addressing changes via the Annual Report, and minimize revisions. Division Second Adequacy Comment This item was not sufficiently addressed. Rule 6.4.5 requires details in the reclamation plan. In the event that an operator wishes to change the plan at a later date, a technical revision or amendment can be employed. Raptor Materials Second Adequacy Response Raptor has revised Exhibit E to provide additional detail including discussion and Table E-1, Mining -Regrading Schedule (p 9, Footnote 5, plo, Footnote 6). 30) The discussion on pit slopes (pages 4 - 5) should include a discussion on the 1 l . t hod for grading these slopes, including push distances. Also, the discussion should include the method for verifying the final slopes and documenting this information. Raptor Materials First Adequacy Response Hiinal slopes are readily determined using hand-held lasers. Push distances will vary by finished basin depth but are not anticipated to exceed 200 feet but will average significantly less than this. A Caterpillar D6 LGP or equivalent will be used supported by a compactor. Some material may be dumped in by articulated dump trucks working together with the dozer push and compaction. DivisionSecond Adequacy Comment No additional response is required from 1) The reclamation plan needs to state that all compacted areas will be ripped prior to addition of topsoil and seed, 3?dPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Tuber, E'S — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Raptor Materials First Adequacy Response It does: All affected lands between the extraction limits and remaining above the anticipated high-water mark of the basins will be capped with a minimum of six (6.0±) inches of soil, as supported by Exhibit I & J - Soils and Vegetation Information. Timing and use of soil are detailed further under Exhibit I & J - Soils and Vegetation Information and Exhibit L - Reclamation Costs_ Where compacted lands exist, and are to be revegetated, those locations will be ripped prior to re - VARY,: COMPANIES, INC, TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [U12J CONSTRUCTION PERMIT APP'_ICATION - COLORADO DIVISION OF RECLAMATION MANG & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.5 EXHIBIT E - Reclamation Plan soil application. There are no known areas of compaction at the time of this application which would require such activity; and ripping remains a contingency of the application. Division Second Adequacy Comment No additional response is required from '; 32) The reclamation plan needs to include a clear plan for the storage and application of topsoil prior to seeding. The plan should include push distances to the areas and minimum depth. Raptor Materials First Adequacy Response Items addressed under #20 and #23, should satisfy this concern. J Division Second Adequacy Comment ft appears that the extensive discussion on soils does not include any information regarding the quantities of soil in stockpiles or the location of soli piles. This 38 Pa g. e Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPs — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. information is required for a detailed reclamation cost estimate and needs to be added to the Extraction Plan, Exhibit D. Raptor Materials Second Adequacy Response The information requested has been included in. revised Exhibit D (p 14, Footnote 2). 33) on page 6, the discussion on seeding should include timing of seeding (and planting if applicable) . At what time of year will seeding operations be conducted? Raptor Materials First Adequacy Response Generally, warm and cool seed mixtures can be treated in a myriad of ways. In Table L-1 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. Division Second Adequacy Comment _RAI needs to revise Exhibit D to address this item and re -submit 1 t . Raptor Materials Second Adequacy Response Raptor has incorporated the First Adequacy response above into revised Exhibit E (page 6, Footnote 3). 34) The weed control paragraph (page 9) should reference the more detailed plan in Kxhibit I' . Raptor Materials_ First Adequacy R onse We understand your preference. Exhibit In is an integral part of the application, ind the expansion on weeds made self-evident, by virtue of your own acknowledgement that it exists there. There is a significant plan to control weeds evidenced in both exhibits. We respectfully request the matter be settled as is to avoid needless revision. Division Second Adequacy Comment RM needs to revise Exhibit D to address this item and re -submit it. 39113 age Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of th.e Two Rivers Sand, Gravel and Reservoir Project - M2022-013. Raptor Materials Second . deguaey Response Raptor have provided additional information in response to this request to the Weed Management Plan section in revised Exhibit I/J (page 7, Footnote 2). 35) The Backfill Notice must state the maximum quantity of inert fill that will be stockpiled on the site at any given time. This information is necessary to calculate the required financial warranty amount. Will buildings or other structures be constructed on backfill areas? If so, how will the material be placed and stabilized to prevent settling and voids? Raptor Materials First Adequacy Response Revisiting the Backfill Notice located at the back of Exhibit E= Reclamation Plan, i1 is noted that a Backfill Notice is required to address specifics in placement of external materials "generated outside of the approved permit area". The notice in this application however seeks to serve both that purpose and address the use of backfill generated within the MLRB permitted area. The use of on -site fill is from extracted or processed reject materials, field lit at the time, depending upon the state of Operations. This is not predictable, but only inert fill, whether found on -site, or imported, will be utilized. There is no means is forecast fill material produced, but the use and location will be reported in required OMLR Annual Reports and addressed as necessary with adjustment to the financial warranty. This is an established practice with the OMLR from prior operations. As to methodology and avoidance of instability of fill areas, the Notice states: '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 ()MLR Rules and Regulations.' Division Second Adequacy Comment No additional response is required from RM, but the Division would like to make two comments for the record. The purpose of the Backfill Notice is to address imported material, not material that originates within the permit area. Also, if 4O I P a g e Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - ./Cdequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sandi Gravel and Reservoir Project — M2022-013. Imported material contains rubble or similar, RAI should handle this material to avoid any instability of slopes. 36) The applicant should discuss the follovving related to the ponds: • The use of very flat slopes (H:1 V) and irregular shorelines in some locations, to allow for diverse habitat. Raptor Materials First Adequacy Response We submit that is in inappropriate for lined basins. Some natural irregularity of man-made structures, easements, and right -of --Tay. Will suffice for edge effect, as will the likely shallower slopes that may form along the sharper edges of the extraction limits, suggested in Exhibit F: Reclamation Plan Map, if lining is from the basin instead of the perimeter, otherwise, not so much. The purpose of the basin is optimal storage of water, consistent with the stated end use of Developed WaLer Resources. • The use of constructed islands in the ponds for ildlife habitat. Raptor Materials FirstAdequacy Response Please see response item "Issue Water Storage Ponds" prepared by ERG dated August 26, 2022 attached as an addendum to Exhibit I--i. Division Second Adequacy Comment No additional response is required from RM. 6.4.5 Exhibit F - Reclamation Plan Map 37) The permit boundary is not shorn on this map and needs to be added (or the line weight needs to be larger to improve clarity). Raptor Materials First Adequacy Response Exhibit F has been revised. Division Second Adequacy Comment No additional response is required from 38) A legend should be added to the map clearly showing what the hatching and 41 1Aage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. other features represent. A yellow box is shown at the southeast corner of the site; please indicate if this symbol represents a real feature or if it is an error. Raptor Materials First Adequacy Response, It was shoval at a smaller scale to show the effect on the landf orm ecology of the area. A revised 1 inch = 200 scale map with legend is provided. Division Second Adequacy Comment The issue with the yellow box was not addressed Please explain this feature on the map. Also, please remove the scale In the upper left portion of the map since it appears to be inaccurate. Raptor Materials Second Adequacy Response Exhibit F Map has been revised. The purpose of the yellow box was not understood and so has been removed. The scale has been corrected. 39) It appears that the map requires more detail regarding the processing area. Do the topographical lines on Exhibit F accurately show the post mining topography? if not, the map needs to be updated. Raptor Materials First Adequacy Response Some minor leveling of this area is anticipated to take place however it is proposed to regrade with similar direction and slope to approximate original contour as part of reclamation unless the owler requires otherwise. Division Second Adequacy Comment Please add a text box to the map explaining the topographical lines. If they illustrate pre -mining conditions, this should be stated. Raptor Materials Second Adequacy Response Exhibit F Map has been revised with labels indicating the processing area will is aL "Approximate Original Contour". 40) Per Rule 6.4.6, post -mining land uses should be shown on the map. This is especially important for the material processing and wash pond areas. [Raptor Materials First Adequacy Response 42VPage Correspondence to the Colorado Office of Mined Land Reclamation. — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the mattes of the Two Rivers Sand, Gravel and Reservoir Project =- M2022-013. Exhibit F has been revised and the primary post -mining land use of Developed Water Resources is clearly evident on the map. Additionally, post -mining land use \\ill be at the ultimate discretion of the owner,, also the operator, and is described in Exhibits D and E. Exhibit D, page 2 Cott Is ending on the family farm in 1948, the liana family combines nearly. 73± years of operational experience that serves as testimony to a history of sound and thoughtfa executed operations of this Lind. For the Two Rivers Sand Gravel and Reservoir Project, lands not otherwise occupied for Developed Water Resources will be improved to the highest possible end -use. Post Extraction Uses beyond the Primary Use of Developed Water Resources will likely, comprise continuing and diverse general agricultural uses; as well as possible light residential, commercial., or industalal uses; as determined by right, or as otherwise authorized by the governing authority] Exhibit E, p6 6.4.5 EXHIBIT E Reclamation Plan soil application. There are no known areas of compaction at the time of this application which would require such activity; and ripping remains a contingency of the application. The final land configuration will ultimately result in two (2) reservoir basins] totaling 234.06± surface acres, with a static water elevation surface area of 217.44± acres (refer to Exhibit F: Reclamation Map). The balance of unoccupied affected lands above the anticipated static water level will be stabilized where necessary utilizing the seed mixture as shown under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. Lands not otherwise occupied for developed water resources will be later developed to the highest possible end -use, and will likely comprise a mixed use which may include other general agricultural uses as well as light residential, commercial or industrial uses. Division Second Adequacy Comment RM needs to revise Exhibit F and re -submit it. As appropriate, the language included in the response letter from RAI should be added to the map in a text box or in notes in the title block. Bap. Materials Second Adequacy Response 43 MPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; i.n the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022--013. i Exhibit F Map has been revised as requested. Labels have been added indicating the regraded and lined excavations are "Developed Water Resources with Grass Embankments", and an explanatory note added adjacent to the Legend. 41) Several structures and easements are shown on Exhibit C-1, and none are shown on Exhibit P. Please explain if all of these structures will be removed during the mining and reclamation operations. Raptor Materials First Adequacy rResponse Please refer to response to Item 18. Division Second Adequacy Comment Please confirm that Exhibit F is accurate. Are all above -ground and underground structures that will remain after mining is complete shown on the map? Raptor Materials Second Adequacy Response Raptor has confirmed in revised Exhibit F that Exhibit F presents Raptor Material's. current expectation of the remaining above ground and underground structures within Affected Area at the point the reclamation of mining related disturbance is complete (page 8, Footnote 4). This is also explained in a note on the Exhibit -F map. 42) The l ivision recommends adjusting the scale on this map. The current version includes considerable area that is beyond the permit boundary. Raptor Materials First ,Adequacy Response it was shown at a smaller scale to show the effect on the landform ecology of the area. A revised 1 inch = 200 scale map with legend is provided.. Division Second Adequacy Comment No additional response is required from laL 6.4.7 Exhibit G - Water Information 43) on Page 1 of Exhibit G, the text states that the site will drain internally. Please add a statement that the site will be operated to prevent any significant runoff from disturbed areas from flowing offsite. Also state that the site will be operated to 44Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. prevent any negative impacts to the hydrologic balance of the two rivers. Raptor Materials First Adequacy Response We are not required to 'Prevent,' but rather 'Minimize' impacts. We believe the submittal conservation measures and provisions attain this standard. Rule 3.1.6 "Disturbances to the prevailing hydrologic balance of the affected land and of the surrounding area and to the quantity or quality of eater in surface and groundwater systems both during and after the mining operation and during reclamation shall be minimized by measures, a • •" Considerable efforts are made to control storm flows, including the use of grassed waterways. Some tilling will occur on cut slopes, but the sediment is inbound. minor 6 -inch furrow above cut slopes will create a 1 -foot swale that could minimize such tilling, especially valuable on reclaimed slopes above the final estimated water level of the basins. The stormwater management plan referenced in Exhibit I & Jr will address broader water management covering the material processing area and any piles of soil or inert fill constructed external to the excavations. Division Second Adequacy Comment the Division agrees that the word ` dnimize " is appropriate. rather than "prevent." However; RBI needs to revise Exhibit G and re -submit it. Exhibit C should include the statements requested in the original adequacyletter (using the word "minimize" as noted above). Ra for Materials Second Adequacy Response Raptor has revised Exhibit G as requested (page 1, Footnotes 1 and 2). 44) Describe the physical dewatering system and provide a description of the operation of this system.. A copy of the discharge permit application provided to CDH is included with this submittal. it will indicate information about the pump capacity and discharge rates. Exhibit D: Extraction Plan devoted a section to it, and AWES devoted a report to it, as provided with the other attachments in this reply. Here's what the permit application stated, followed by a blow-up of the feature visible near the #10 451 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EN — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project M2022-013. Piezometer, under Exhibit G: Water Information Map: I13 6 4.5 EXHIBIT D - Extraction Plan preferred native seed mixture offers opportunity to gauge the potential performance of the selected species prior to utilizing it over larger areas requiring reclamation later in the life of the resource recovery operation. Once vegetation is established over the initial reclamation soil stockpiles, they will likely remain untouched for the life of the operation until final reclamation of remaining affected lands takes place. Where concurrent reclamation is possible, operations will utilize soil in an over the shoulder method when practical. In this manner, reclamation is expedited without increasing soil stockpile volumes while reducing expenditures related to labor, handling, and time. Deli/catering: As extraction activity progresses into the aggregate profile, groundwater must generally be removed in advance tbarpmgb, the use of pumps and subsequent discharge into area tributaries. A complete dewatering evaluation was performed by AWES in their report of 27 July 2020, as provided at the back of Exhibit G: Water Information. The report concludes that 'the results of analytical and numerical solutions indicate that the proposed mine dewatering activities will not adversely affect the regional groundwater hydrology.' The reader is further assured that all discharge of waters will be conducted under an approved CDII discharge permit. Initial dewatering of the property in preparation for extraction and resource recovery will occur by establishment of a dewatering pump and/or well in the Southern boundary near an existing agricultural pond. The point of discharge is on Exhibit G: Water Information Map. Other discharge locations may occur in time as needed and otherwise approved under the applicable CDH discharge permit requirements. Subsequent CDH approved discharge locations will be field fit and the location updated in the following OMLR Annual Report. 46IPage Correspondence to the Colorado Office of Mined Land Reclamation —. Reply to Rob Zuber, EPS — Adequacy Letters of 24 June am d 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Division Second AdequacyComment Please add to Exhibit C a summary of the system with references to other exhibits and other documents (e.g., the Water- Qua lty Control Division application), as appropria te. Raptor Materials Second Adequacy Response Revised Exhibit G now references clearly the extensive discussion on dewatering in Exhibit D (page 6, Footnote 10). 45) The Water Information exhibit should provide a detailed discussion of floodplain management at the site. This must include a discussion of the conveyor crossing of the Big Thompson River. It should also reference the Floodplain Permit report by Headwaters Corporation, as appropriate. Raptor Materials First Adequacy Response Operational elements of floodplain management are describe. in E 'bit D. Exhibit D, p6 47 Page Correspondence to the Colorado Office of Mined Lord Reclamation — Reply to Rob Zuber, BPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Wetland conditions appear confined within portions of the stream terrace and bank -full stage of the rivers, and along segments internal to the Evans Canal. Extraction will form a depression (basin) within the floodplain as shown in Exhibit C-2: Extraction Plan Map. Temporary above ground fill may occur within the floodplain, and as part of this permitted activity, provided the above ground volume does not exceed the belolt- ground volume created by extraction. All product stockpiles and processing will occur within the cite limits of Evans under this application, and North and outside of the floodplain boundary of the 100 -year floodplain of the Big Tho so pson River. The floodplain extent will be visually marked in the field to better assure the integrity of the floodplain. Material transport of raw materials from extraction locations to the plant site will occur via conveyor (see route on Exhibit C-2: Extraction Plan Map). This will in turn serve to minimize impacts to area transportation corridors. The actual location, extent, and nature of the conveyor systems not otherwise designated in this submittal Eri11. be provided as updates in the required °MLR Annual Reports. As described in this response concerning items 23 and 24, additional detail on the floodplain management and the conveyor was stated as followB: From Item 23 Response We can affirm here that stockpiling above the existing ground elevation will not occur in a manner understood to obstruct flood waters where they might occur within the existing floodplain. It is understood and agreed here -in that their longitudinal dimensions if they occur there should extend parallel to anticipated flood. flows where they exceed a cone or other shape that might find its existence contrary to intent by volume beyond that which could be understood to be temporary, or transitory; especially outside of seasonality where flooding might be more reasonably anticipated. From Item 24 Response The conveyor will be set on an elevated structure at varying heights to be situated about the 1 in 100 -year flood level. An average height of 7 feet is expected. The conveyor will be supported by legs at intervals of approximately 20 feet with concrete blocks used as necessary to anchor the legs. Final conveyor specifications are to be determined but a 24-36" belt is anticipated. A wider span than typical will cross the Big Thomson River at an elevation above 48IPage Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. the 1 in 100 -year flood level. Division Second Adequacy Comment • The text provide in the RM response that explains floodplain management at thr. site must be added to Exhibit G. • As noted above, Annual Reports should not to be used to make changes to the mining and reclamation plans, including the locations of structures. Those changes must be made with technical revisions and amendments. • Please explain the relevance of the Headwaters Corporation report included in the original submittal. Raptor Materials Second Adequacy Response Raptor has revised Exhibit G as follows • Raptor's First adequacy response that explains floodplain management at the site has been added to Exhibit G (page 3, Footnote 6). • Acknowledged. • The relevance of the Headwaters Corporation report included in the original submittal is discussed (page 4, Footnote 7). 46) To ensure that the Tvio Rivers project minimizes impacts to the hydrologic balance of the rivers, the application needs to include a water quality monitoring plan, specifically for the alluvium. (see Section 20 - Exhibit G in- Adequacy Response] The groundwater monitoring plan should be developed in accordance with Rule 3.1.7M) and should include a Quality Assurance Project Plan CQAPP) for the collection of groundwater samples. The plan should provide mitigation steps if there is an exceedance at a groundwater or surface water monitoring location. Potential impacts to quality and/or quantity the nearby domestic wells should also be addressed. A copy of the Division's Groundwater Monitoring and Protection Technical Bulletin has been included as an enclosure to this letter for your reference. Raptor Materials First Adequacy Response This was an oversight. Please refer to AWES Report, #2022-RM-P124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment 49JPag Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Crawl and Reservoir Project — M2022-013. A water quality monitoring plan is required for this permit. Please develop that and include in the revised Exhibit C Raptor Materials Second Adequacy Response A Groundwater Monitoring Plan has been prepared by consultant AWES and is provided as an additional addendum to Exhibit G (page 4" Footnote 8). 47) Change "NPDES" to "CDPS" to reflect the requirements of the Water Quality Control Commission. Raptor Materials First Adequacy Response Acknowledged and noted that our only reference to YPU S was sir -Cpl, incorporating text directly from the rules. Please see Prologue. Division Second Adequacy Comment No additional response is required from R1 Exh H - Wildlife 48) Indicate which recommendations on wildlife protection in "Threatened and Endangered Species Habitat Assessment, Two Rivers Parcels" CERO, 2022) will be implemented at the site. This report was submitted with Exhibit H of your application. Raptor Materials First .de ± acy Response Please see response item "Issue - Wildlife Protection Recommendations" prepared by ERO dated August 26, 2022 attached as an addendum to Exhibit H. Division Second Adequacy Comment No additional response is required from Exhibits In 49) This exhibit should include a discussion on, wetlands in the project area, including the wash pond and material processing areas. Please state that operations vvill be conducted to minimize impacts on wetlands or state that no operations will be conducted in wetland areas. Raptor Materials First Adequacy Response 50IPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Riven Sand, Gravel and Reservoir Projects 2022-013. Under. Exhibit M is an approved U.S. Army Corps of Engineers report designating `No Permit Required.' Most of the wetlands as they occur at the Big Thompson River are predominantly limited to the channel itself. If and when a conveyor is built upon the projected line, the footings are not expected to exceed the requirements for a Nationwide Permit, but if they will, a Nationwide Permit will be applied for and secured prior to affecting such areas. It simply isn't anticipated at this time. If a Nationwide Permit is necessary, the OMLR will be provided with the necessary justification or approval under an O1\41,R Technical Revision to that end. Please refer to Item #45 for additional clarification. Division Second Adequacy Comment RM needs to revise Exhibits J/., and re -submit, with the discussion and statement regarding minimization of impacts. As appropriate, reference other exhibits and reports from other entities (e. g. , the US Army y Corps of Engineers). Raptor Materials Second Adequacy Response Raptor has revised Exhibit I/J as requested (page 3, Footnote 1). 50) In the Weed Management Plan, the paragraph that mentions the State of Colorado noxious weeds list should state that List A species will be eradicated and List B Species will be controlled. The plan should also describe the efforts that will be made to control List C species, including field bindweed, a focus in Weld County. The Division recognizes that mapping and vector identification can be useful tools for weed control, but these practices should not delay treatment of weeds. Ra •tor Materials First Adequacy Response Weed management will be under the supervision of a certified weed management specialist. All applicable requirements currently in force at the time will be adhered to. Division Second Adequacy Comment RM did not address the adequacy item. R 1 needs to revise Exhibits P/, and re- submit, with the statements regarding listed species. Raptor Materials Second Adequacy Response Raptor have provided additional information in response to this request to the Weed 51 !Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project - M2022-013. [Management Plan section in revised Exhibit In (page 7, Footnote 2). 6.4.12 Exhibit L - Reclamation Costs 51) This exhibit should be updated, as necessary, to match any revisions to Exhibits D and E, per the adequacy items for those sections. This includes details on structures. i Raptor Materials First Adequacy Response RNI has reviewed Exhibit L and believes it adequately reflects changes to Exhibits D and E. Division Second Adequacy Comment In the context of this second adequacy letter, Exhibit L must be updated to reflect revisions to Exhibits D and E. Raptor Materials Second Adequacy Response A substantially revised Exhibit L has been prepared as requested. 52) The cost estimate should include a task for ripping areas that will be topsoiled and vegetated. Raptor Materials First Adequacy Response An allowance could be made for ripping a percentage of the area assuming it becomes compacted. Division Second Adequacy Comment RA'fdid not address the adequacy ite. RMneeds to revise Exhibit L to include the ripping task. Raptor Materials Second Adequacy Response Raptor has made appropriate allowances for ripping (disking/scarifying) as requested in revised Exhibit L (page 8, Footnote 3; page 9, Footnote 4). 53) The Applicant has noted under the Reclamation Plan (page 5) that water shares will be dedicated to the Division of Water Resources (DWR) to cover the liability associated with exposing groundwater. Please be aware that the Division no longer 52JPage Correspondence to the Colorado Office of Mined Land Reclamation -- Reply to Rob abet, EPS Adequacy Leiters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. accepts the dedication of water shares to DWR as a bonding mechanism. The Applicant will need to post a financial warranty to allow for bacfilg the areas of exposed groundwater or a financial warranty to cover the cost of installing clay liners in the reservoir. Please see additional comments under Item No. 29. Raptor Materials First Adequacy Response Raptor has confirmed and will amend the application to state that Developed Wate Resources will be the post -mining use for the pit excavations and will provide financial warranty appropriate for cost of constructing lined pits. Division Second Adequacy Comment No additional response is required from RA 6.4.13 Exhibit M— Other Permit and Licenses 54) Please commit to providing copies of all required and approved permits and licenses to the Division when available. This should include well permits and documents related to water rights, such as a Substitute Water Supply Plan. Raptor Materials First Adequacy Response Raptor affirms copies of all. required and approved permits and licenses will ►- obtained and provided before actions requiring permits commence. Division Second Adequacy Comment No additional response is required from RA/1. 6.4.14 Exhibit N s Source of Legal Right to Enter 55) This document must show that Raptor Materials LLC (rather than Varra Companies, Inc.) has the legal right to enter lands under this permit. Raptor Materials First Adequacy Response The exhibit is updated and attached. Division Second Adequacy Comment No additional response is required from RM 6.4.18 Exhibit R — Proof of Filing with County Clerk and Recorder 53 rage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob tuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project a M2022,-013. 56) Please provide an affidavit or receipt indicating the date on which the revised application lication information required toaddress this adequacy letter was placed with the Weld County Clerk. Raptor Materials First Adequacy Response An updated affidavit is provided and attached as Exhibit I?r;a. Division Second Adequacy Comment No additional response is required from RI 6.4.19 Exhibit S! Permanent Man-made Structures 57) The Division requires Raptor Materials LLC to demonstrate that they attempted to obtain notarized structure agreements with all owners of the structures within 200 feet of the affected area of the proposed mine site, pursuant to Rule 6.4.19. This attempt must be made prior to the Division's consideration of a stability analysis. Please also indicate what agreements have been obtained. Raptor Materials First Adequacy Response This information was provided earlier via Susan Bergmaier submittal of Notifications, with the signed versions of an agreement sent to all owners of structures known to us. Division Second Adequacy Comment • RAJ needs to update Exhibit S with all relevant information including: o l list of all structure owners o A list of agreements obtained from these owners. Rapor Materials Second Ade uac. Res onse Exhibit S has been revised as requested (page 2, Footnote a 6.5 Geotechnical Stability Exhibit 58) The Division has reviewed the Slope Stability Analyses (prepared by AWES, LLC), and our comments are provided as an enclosure with this letter. Please review this memorandum and provide responses.. Raptor Materials First Adequacy Response Please refer to AWES Report dated August 10, 2022, now appended to the 54IPaUc Correspondence to the Colorado Office of Mined Land Reclamation —Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022 -013. Application as an addendum to Exhibit S. Division Second Adequacy Comment No additional response is required from RM 55 Page Correspondence to the Colorado Office of Mined Land Rec , P• 'on — Reply to Rob Zuber, EL''S — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. The Division is still reviewing two of the technical reports associated with this application: "Riverside Berra Failure Analysis and Flood Control Mitigation Plan" (Flow Technologies LLC, 2020) and "Dewatering Evaluation, V arra Two Rivers Mine" (AWES LLC, 2020). Division comments and questions related to these reports will be sent under separate cover. August 05, 2022 Additional reviews for preliminary adequacy Flood Control Mitigation 'Ian Raptor received additional comment on this aspect of the application November 17, 2022 and will respond separately on this issue. 1) -lyclrograph Deyelo ment: Paragraph 3.2.3 indicates the 10 -year flow was subtracted from the inflow hydrograph because "it is estimated the earthen berm will control a 10-yr flood event". This does not seem to be a straight forward assumption. If the entire site is to be flooded, it seems the water elevation of the flood above the berm elevation would be the controlling flow parameter, much as a hydrograph routed through a reservoir controls the depth of overflow in a don overtopping failure analysis. Please provide some background on why this assumption is reasonable. Raptor Materials First Adequacy Response f i se refer to Flow Technologies Report dated August 27, 2022, now appended to the Application as an addendum to Exhibit G. 2) Hydrograph proportionment: Paragraph 3.2.3 references FEIVIA, Flood Insurance Study, January 20, 2016 as validation for having two-thirds flow through the south side of the Site (Central Field) and the remaining one third flow through the north side of the site. Please. a) Elaborate on the purpose of splitting the flows, b) Explain if this is used directly in the WmDAM C berm failure analyses or n the hydrograph development for determining water elevation, or somewhere else, c) Explain how it impacts the approach and results (e.g., how sensitive is the analyses to this 2/3 ratio) Raptor Materials First Adequacy Response Please refer to Flow Technologies Report dated August 27., 2022, now appended t o the Application as an addendum to Exhibit G. 3) Hard Armoring: Both paragraphs 3.2 and 4.2 reference Section V, Hard Armoring. 6 Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. Section V is labeled. Mitigating Measures and does not discuss any hard armoring. Please provide some discussion on the anticipated hard armoring for reclamation closure. Raptor Materials First Adequacy Response The Flow Technologies January 2020 report indicated both that the riverside berms under conservative assumptions should withstand breach due to head cutting in a 1 in 100 year flood event, however suggested that "the pit locations most susceptible to head cutting will be armored"(Section 3. 2), or more specifically in Sections 3.6 and 4.2, hard armoring is discussed as a reclamation practice in the areas or locations (most) susceptible to head cutting. It should be understood that the head cutting modelled did not result in breach of 100 -feet berms although berms are assessed as varying in width from 100-150 feet. Additional conservatism included in the modeling included inundation from a storm event which would be worst case with little warning allowing pit dewatering to be temporarily halted and reducing pit fill time, assuming the event occurs when the pits are fully excavated, resulting in maunizing fill time, and that there is no vegetation w increases the rate of erosion. The mitigating measures described in Section. V state that "should a flood occur that results in head cutting/erosion of a riverside berm, Varra Companies, Inc. [now Raptor Materials] will immediately restore the damaged area to pre -flood conditions.". This is in effect, "reclamation" of the berms. This however does not preclude RM implementing measures to reduce the impacts of head cutting or likelihood of berm breach including establishing or maintaining vegetation, and hard armoring (riprap). Such measures, particularly hard armoring would be considered in the areas or locations most susceptible to head cutting, i.e. where berms are narrower. Should such measures be taken as preventative rather than restorative (reclamation), properly installed engineered riprap, (size and thickness calculated) would be assessed at the time. 4) variable Water Surface Elevation: As expected for a river flood and depicted in Figure 8, the water surface elevation varies from the upstream to downstream segments of both rivers. The DRMS' understanding of WinDAM C is that it assumes a uniform flow elevation over the embankment being analyzed. How is the fact that the water elevation is not uniform in this scenario accounted for in the modeling? Raptor Materials First ,deQua.cr Response Please refer to Flow Technologies Report dated August 27, 2022, now appended to 57I Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to Rob Zuber, EPS —Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project M2022-013. the Application as an addendum to E I ibit G. 5) Fill Time Estimates - Central Pit: The fourth column in table on p. 30 suggests a nearly uniform incremental delta for every 10 feet of pit depth. This suggests the pit being analyzed for a depth storage relationship has nearly vertical side walls. Are the pit walls in the berm failure scenarios being analyzed vertical and is this condition reflected in the WinDAM analyses? i Raptor Materials First Adequacy Response Please refer to Flow Technologies Report dated August 27, 2022 now appended to the Application as an addendum to Exhibit G. 6) Central Pit Groin Training Channels Calculations: On p. 41 is a Mannings normal depth flow calculator for a 25 -foot bottom width with 1I:1►I side slopes. It is unclear as to the purpose of this image. Based on the Mannings n = 0.025, it would appear this is likely an earth -lined channel. As such, a 1HaV slope is not likely to be stable for long. Please indicate the purpose of this image and justify the channel geometry depicted in it. Raptor Materials First Ades uacy Response Please refer to Flow Technologies Report dated August 27, 2022, now appended to the Application as a supplement an addendum C. 7) H c -RAs Output: Several of the C-RAS cross section output results indicate additional cross -sections may be warranted: a) the conveyance ratio (upstream conveyance divided by downstream conveyance) is less than 0.7 or greater than 1.4. This may indicate the need for additional cross sections. b) Warning: The energy loss was greater than 1.0 ft (0.3 m). between the current and previous cross section. This may indicate the need for additional cross sections. Please provide rationale for not including additional cross sections. Raptor Materials First Adequacy Response Please refer to Flow Technologies Report dated August 27, 2022, now appended to the Application as an addendum to Exhibit G. Additional Comments on Groundwater (AWES Dewatering Evaluation) 58 Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, E'S — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand.,, Gravel and Reservoir Project - M2022-013. Exhibit CJ General 1) The proposed text of Section 6.4.7, Exhibit G, allows for the post -mining lining of the pits but does not commit to it. It is not appropriate for the Division to approve a contingent reclamation plan; the approved text should describe a single reclamation plan. If the decision is made at a later date to change the plan then an amendment application should be submitted at that time. P lease revise the text of Exhibit G to describe the post -mining plan for the lining or otherwise of the excavated pits. Raptor Materials First Adequacy Response P lease refer to Flow Technologies Report dated August 27, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient - the plan is to line the pits. 2) The text also refers to "o'MLR" in places, which presumably stands for "office of Mined Land Reclamation". This office does not exist in Colorado. Please replace any reference to "OMLR" in the text with "DRMS". Raptor Materials First Adequacy Response Acknowledged. Please see Prologue. Division Second Adequacy Comment The response is sufficient - the applicant has elected to continue to use "OML,l? ". with justifica don, despite the fact that the term is deprecated. 3) Water level data from pie meters P124-1 through P124-12 has been given in the text of Exhibit G but the locations of the piezometers are not shore on Exhibit G: Water Information Map (or Exhibit C-1: Existing Conditions Map). P lease add the piezometer locations to Exhibit G: Water Information Map Raptor Materials First Adequacy Response P lease see revised Exhibit G Map. Please note there is considerable detail presented on the map and it may be necessary to either print at scale or zoom to see the information. 59IPage Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project -- M2022-013. Division Second Adequacy Comment f'iezom eter locations have been sho iv n on the updated version of Exhibit G: Water ter Information Map, however they are labelled using a different naming ng convention (see figure 1). Please label the plezometers on the map as they are referred to in the text of the AWES study. Raptor Materials Second Adequacy Response A revised addendum (10) to Exhibit G is attached with the piezometer names corrected and now aligned with the Exhibit G map. 4) The key of Exhibit G: Water Information Map shows a symbol for wells, but no wells are identifiable on the map. it's not clear whether they were omitted or are not legible. Please identify allregistered wells on Exhibit : Water Information Map. Please also add a table to section 6.4.7 with details of these wells including their per 10 it IDs, owners, date of construction and registered use. Raptor Materials First Adequacy Response Please see revised Exhibit G Map. Please note there is considerable detail presented on the map and it may be necessary to either print at scale or zoom to see the information. Division Second Adequacy Comment Please identify all registered wells on Exhibit G.' Water Info' -matron Map. Please also add a table to section 6.4.7 with details of these icons including their permit IDs, owners, date of construction and registered use. Raptor Materials Second Adequacy Response A table of wells has been compiled and added to revised Exhibit G map and as an addendum to Exhibit G (page 3, Footnote 5). 5) Exhibit G: Water Information Map shows several symbols that are riot included in the map key, and the text in many of the labels on the map is illegible (including what are presumably stream stage elevations). Please revise Exhibit G: Water Information Map to improve its legibility and to provide a complete key for map symbols (it may be helpful to remove the aerial imagery base -map). The revised map should be prepared and signed by a 6O Page Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Riven Sand, Gravel and Reservoir Project — M2022-013. registered land surveyor, professional engineer, or other qualified person, as is required by Rule 6.2.1(2)(b). Raptor Materials First Adecuacy Response Please see revised Exhibit G Map. Please note there is considerable detail presented on the map and it may be necessary to either print at scale or zoom to see the information. We have found either provides legible information. Division Second Adequacy Comment Please revise Exhibit G: Water Information Map to improve its legibility and to provide a complete key for map syn. bols (it may be helpful to remove the aerial imagery base -map). The revised map should be prepared and signed by a registered land surveyor, professional engineer, or other qualified person, as is required by Rule 6.2.1(Z)kb,). (With reference to die updated version of Exhibit G. Water Information Map) 11ihen the pdf of the map is viewed at 300% zoom most of the labels are legible (except where they are obscured by other map elements, however this level of zoom makes the map very difficult to use. Several symbols are used on the map but are not identified in the key or labelled on the map, these include.' • Inverted red triangles (as shown in figure 1) • Bold red lines and squares (as shown in figure 2) • Yellow highlighting on contour fines (as shown in figure 2) • Dashed brown line (as shown in figure 2) • Yello u- polygons (as sho wa in figure 3) • Blue marks (as shown in figure 3) • Fine dashed red lines (as shown in figure 3) • Light red dots (as shown in figure 3) • Black triangles (as shown in figure 3.) The map has not been signed, stamped, or otherwise certified b v a registered land surveyor, professional engineer, or other qualified person. In 6.4.7(1) the statement is made that "Operations will not adversely affect surface and groundwater systems" In support of the statement, the text refers to a July 27, 61 !Page Correspondence to the Colorado Office of Mined. Land Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022;. in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022e013. 2020 study by American Water Engineering Services, LLC of Fort Collins, CO (AWES 20'20). American Water Engineering Services, LLC was formed in 2011 and is currently in good standing with the Colorado Secretary of State's office. The AWES 2020 report presents a h cirogeologic evaluation based on a numerical groundwater flow model built with Visual illociFlow Pro, an industry standard groundwater- floc T modeling code. Background Information is given in the report, followed by assumptions., model parameters, results and conclusions. Figures and plates are appended to the report. T:t.. its nature a numerical groundwater flow model is a simplification on of the real system and is built using a series of assumptions and compromises on the part of the modeler, with the goal of answering pertinent questions about the system. The questions that the A IVES 2020 model seeks to answer are not specifically defined, but are generally stated as "to estimate the effects of dewatering operations on the s urro un ding gro undwa .ter hydrology". . In my re view of the A WE'S 2020 model I have tried to a void "nit-picking" but to look first at the overall validity of the conclusions that can be drawn from it, and then to evaluate whether those conclusions support the statement that "Operations c rill not adversely affect surface and groundwater systems": Questions 6 through •• • below are asked to help the Di nsion better understand the model. Raptor Materials Second Adequacy Response Exhibit G map has been revised as requested vvith the minor drawing artifacts removed for clarity. Exhibit G - AWES De atering Evaluation 6) Key assumptions of the model are that the aquifer is unconfined, homogenous and anisotropic, with a horizontal hydraulic conductivity (h) of 125 ft/day and a vertical hydraulic conductivity (Ky) of 12.5 ft/day. The K values are at the loser end of the expected range of 2000-100 ft/day (Robson, 1989). Please justify the assumption of anisotropy and the chosen K values for the sand and gravel aquifer. Raptor Materials First Adequacy Response Please refer to AWES Report,, #2022-RM-P124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment 62IPage Conespondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zuber, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. see comment on 'tern 7. 7) The piezometers referred to in (3) are described as monitoring wells in AWES 2020. Please describe how these wells were used for pre -mining aquifer characterization (besides the collection of water level data). Raptor Materials First Ades uacy Response Please refer to AWES Report, ##2022-RM-1 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response to 6 and 7 is sufficient - the author has assumed aquifer properties based on his prior experience of similar geologic settings. Although the assumed hydraulic conductivity values seem reasonable with respect to the literature, it is a notable weakness of the AWES study that the opportunity wasn't taken to use the constructed monitoring wells to conduct any field tests of aquifer properties. There are many published equations linking h -dra ulic conductivity and grain size of the form "K is proportional to d_10" since it was first proposed in the .1890s, but they are of doubtful validity; are generally only employed when other methods of estimating hydraulic conductivity are not a vailable, and the value of the proportionality constant is usually empirically derived - nn not aware of any justification for assuming a proportionality constant of 1, and none has been presented, (Hazen, 1892; Eggleston, 2001.: Carrier, 2003). 8) No information is presented about the vertical extent of the model. How many vertical layers are used in the model? What are the layer thicknesses? Raptor Materials First Adequacy Response Please refer to AWES Report, #2022-R --P 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment 631P age Correspondence to the Colorado Office of Mined Land Reclamation -_ Reply to Rob Zuber, EPS Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. The response is sufficient - there are two vertical layers in the model, with the upper layer representing unconsolidated alluvial deposits and the lower layer representing bedrock. 9) No information is presented about recharge from precipitation. Is recharge from precipitation accounted for in the model, or is its impact assumed to be negligible? Raptor Materials First .deguacy Ronse Please refer to AWES Report, #2022-RM-P 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient - a 1.5 inch recharge rate was assumed 10) The Mine Area Map presented as Figure 2 shows a different pit configuration from that presented elsewhere in the permit application packet (PAP) - it shows three pits, whereas Exhibit G: Water Information Map, for example, shows just two. The Model Boundary Conditions presented as Plate 1 reflect the configuration shown in Figure 2. Please discuss the vali u'ty of the model boundary conditions in the light of the final pit configuration (which is assumed to be that shown on maps in the PAP). Raptor Materials First Adequacy Response Please refer to AWES Report, #2022-RM-P124 124 dated August 31,. 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient the model boundary conditions were updated to correspond more closely to the two pit configuration shown elsewhere in the mine plan. 11) According to the literature, water table gradients in the alluvial aquifers of the region are typically in the range 0.002 to 0.007 (rnold, Langer & Paschke, 2003). The water table contour map presented as Plate 3 shows a generally easterly gradient of 0.002 across the center of the proposed permit area. A single data point (MW-i, which is presumably the same as P124-1) exists north of the Big 641Page Correspondence to the Colorado Office of Mined Laud Reclamation - Reply to Rob Zuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022M13. Thompson River, with a significantly higher water level. This distorts the water level contours in the north of the study area, suggesting a far steeper gradient (0.01) and a south-easterly flow direction. Please discuss the characterization of the pre -mining water table. How reliable is the data from -1? How do you account for the steeper gradient? Are there any other data points in the north of the study area to improve the characterization? Rator Materials First Adequacy Response Please refer to AWES Report, #2022 --FPM -P 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient - the author has used the a vailable data to characterize the site as thoroughly as possible. 12) The model was calibrated using model -assigned observation wells outside of the proposed excavations, (presumably the points shown With green and white symbols on Plates 6 and 7). The first two sentences of the final paragraph on Page 3 of the AWES 2020 report suggest that water levels were measured at these locations, but I think that these are simulated wells. Plates 5 and 5A show the calibration results, They appear to show identical data. Water level contours showing initial conditions in the calibrated model are presented as Plate 4. The contours suggest a gradient of 0.06 to the SSE in the north of the study area. Please clarify the initial calibration process. Please discuss the validity of the model in the north of the study area. Ra tor- Materials First Adequacy _Response Please refer to AWES Report, #2022-RM-P124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient - the author thoroughly described the model calibration process. 13) The results of the dewatering simulation are presented as Plate 6. This is presumably a steady state simulation. It simulates dewatering of thecentral and 65dI Correspondence to the Colorado Office of Mined Land Reclamation — Reply to Rob Zither, 1S -- Adequacy Letters of 24 June and. 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project —12022-013, north-west pits only. Please simulate the dewaterin, , of the full extent of the mined area. Please estimate the time to achieve steady state conditions. Raptor Materials First Adequacy Response Please refer to AWES Report, #2022-RM-P124 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The steady state draWdourn scenario is presented on Plate 7. In the Conclusions section of the report the author states: "The predicted dra ivdo72 associated with the mine dewaterin ' represents the worst case scenario and a substantial amount of time will be required before maximum drat/VC/01412S will occur.: Please estimate the amount of time. based on model results. for maximum dra wdowns to occur. Raptor Materials Second Adequacy Response This was an oversight from the First Adequacy response and has been addressed in revised Exhibit G supported by a August 30, 2022 letter report from AWES, LLC now added as an addendum (page 2, Footnote 3). 14) Table 1 presents the predicted \\rater levels at the 4 simulated wells before mining and folloiing the lining of the mined pits. Please add a column to Table 1 showing the predicted water levels under the pit de -watering scenario. The table should show the fullest extent of the potential drawdown caused by the mine operation. Raptor Materials First Adequacy Response Please refer to AWES Report. ##2022 RM -P 1 4 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient Table 1 shows maximum predicted dra wdowns at the 4 simulated wells, as well as the predicted post --pit -lining water elevation. 15) In the conclusions section on Page 4 of the report, the statement is made that "The results of analytical and numerical solutions indicate' �" however no analytical 66 Page Correspondence to t e Colorado Office of Mined Land Reclamation — Reply to Rob Zither, EPS — Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project — M2022-013. solutions are presented. Please update the report to present any relevant analytical solutions that support the conclusion. Ra for Materials First Ade uac Res one Please refer to AWES Report, 412 22--FPM-P 124 dated August 31, 2022, now appended to the Application as an addendum to Exhibit G. Division Second Adequacy Comment The response is sufficient - analytical solutions are used earlier in the report. RAPTOR HATE RIALSLLC Garrett C. Varra, General Manager 671Page Correspondence to the Colorado Office of Mined Land Reclamation - Reply to RobZuber, EPS - Adequacy Letters of 24 June and 5 August 2022; in the matter of the Two Rivers Sand, Gravel and Reservoir Project - M2022-013. STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 APPLICABILITY: CONSTRUCTION MATERIAL REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION PACKAGE COLORADO DIVISION OF RECLAMATION MINING SAFETY This application package is for a construction materials operation which affects 10 acres or more. If you plan to conduct a construction materials extraction operation which meets these criteria, please follow the instructions provided in this package, in the Rules and Regulations, and in the Colorado Land Reclamation Act for the Extraction of Construction Materials, as required. RECOMMENDATIONS PRIOR TO FILING: The Construction Material Rules and Regulations (the Colorado Land Reclamation Act for the Extraction of Construction Materials, Section 34-32.5-101, et seq., C.R.S., and 2 CCR 407-1) and the Colorado Mined Land Reclamation Board (the "Board") regulate the permitting, operational and reclamation requirements for all construction material extraction operations in Colorado. It is your obligation to comply with the Act and Regulations. You are encouraged to obtain and review a copy of the Rules, available for $8.00 from the Division of Reclamation, Mining, and Safety (the "Office"). In order to submit your application properly, it is recommended that you review the Act and: Rule 1.1 Rule 1.4.1 Rule 1.4.5 Rule 1.6 Rule 3.1 Rule 3.3.1 Rule 4 Rule 6 Rule 6.2 Rule 6.4 Rule 6.5 Definitions; Application Review and Consideration Process; Specific Requirements for Regular 112 Operations; Public Notice Procedures; Reclamation Performance Standards; Operating without a Permit - Penalty; Performance Warranties and Financial Warranties; Permit Application Exhibit Requirements; General Requirements of Exhibits; Specific Permit Application Exhibit Requirements; and Geotechnical Stability Exhibit. It is recommended that you contact the agencies listed in the application section titled "Com submitting the application to the Office . 2liance With Other Laws" prior to Office of Mined Land Reclamation Office of Denver • Grand Junction • Durango Active and Inactive Mines FILING REQUIREMENTS: In order to apply for a Reclamation Permit for a Regular 112 Operation, please provide: o One (1) signed and notarized completed ORIGINAL and one (1) copy of the completed original Regular 112 Operation Application Form. ORIGINAL SIGNATURES MUST BE DONE IN BLUE INK. o Two (2) copies of Exhibits A -S (required sections described in Rule 6). o Two (2) copies of Addendum 1 -Notice requirements (described in Rule 1.6.2(1)(b)). A sample of this notice is attached for your use. o The Geotechnical Stability Exhibit when required by the Division. o The application fee. The ninety (90) day period for review of the application and exhibits will NOT begin until all required information and fee are submitted. The Office will then review the submitted information for adequacy. NOTICE REQUIREMENTS: 1. You MUST send a notice, on a form approved by the Board, to the local board of county commissioners. A copy of this "Notice of Filing Application" form is attached for your use. 2. If the mining operation is within the boundaries of a conservation district, send a notice to the board of supervisors of the conservation district, PRIOR to filing the application. A copy of this "Notice of Filing Application" form is attached for your use. 3. You MUST include proof of notice #1 and #2 above with the application at the time the application is submitted to the Office for filing (Rule 1.6.2(1)(g)). 4. PRIOR to filing the application, place for public review a copy of the application, less confidential items, with the clerk or recorder of the county or counties in which the affected land is located. 5. You MUST include an affidavit or receipt demonstrating that the application was filed with the county clerk or recorder at the time the application is submitted to the Office for filing. 6. Any changes or additions made to an application submittal MUST be filed with the county clerk or recorder. You MUST also provide the Office with an affidavit or receipt demonstrating that the change was filed with the county clerk or recorder no later than the close of business on the day the change was filed with the Office (Rule 1.8.1(2)). 7. Within ten (10) days after your application is considered filed, you must publish four times in a newspaper of general circulation, in the locality of the proposed mining operation, the notice described in Rule 1.6.2(1)(d). 8. In addition, after the first publication you must mail or personally serve a copy of the notice described in Rule 1.6.2(1)(d) to all owners of record of surface rights to the affected land and all owners of record of lands that are within 200 feet of the boundary of the affected land (Rule 1.6.2(1)(e)). A copy of a form which includes all required information for the notice is attached for your use. 9. Prior to the Office making a decision (consideration ofthe application), you MUST submit a copy of the proof of publication from the newspaper and proof of all required notices. Proof of the notices may be by submitting copies of return receipts of a certified mailing or by proof of personal service (Rules 1.4.1(4), 1.4.2(4)(c), 1.6.2(1)(a)(ii), and 1.6.2(1)(g)). The copy of the application and any changes or additons placed at the office of the county clerk or recorder shall NOT be recorded, but shall be retained there for at least sixty (60) days after a decision on the application by the Office and be available for inspection during this period. At the end of this period, the application may be reclaimed by the applicant or destroyed (Rule 1.6.2(2)). APPLICATION REVIEW PROCEDURES: The Office shall approve or deny the application within ninety (90) days of filing unless the date for consideration by the Office is extended pursuant to Rule 1.8. The time for consideration shall not be extended beyond ninety (90) days after the last such change submitted. For complex applications, the review period may be extended an additional sixty (60) days. Please see Rule 1.1(10) for the definition of what constitutes a complex application. APPLICATION APPROVAL/DENIAL: If the requirements of the Act and Mineral Rules have been satisfied, the Office will approve the application. The Act also provides for automatic approval if no action is taken by the Office by the end of the review period. If the Act and Regulation requirements have not been satisfied, the Office will deny the application. If the Office denies the application, you may appeal to the Board for a final determination by submitting a written request for administrative appeal to the Board within 60 days of the decision date (Rule 1.4.7). PERFORMANCE AND FINANCIAL WARRANTIES: A performance warranty, and a financial warranty dollar amount determined during the application review process, must be submitted and approved by the Office PRIOR to permit issuance. A financial warranty should NOT be submitted until a decision on the application has been made. If the applicant is a unit of state or county government, then ONLY a performance warranty is required. Several different types of financial warranties are allowed by the law. Please review Rule 4.0 to determine which type of financial warranty you desire to use. You may obtain the appropriate warranty forms from the Office during the application review period. Please note that an application approval DOES NOT convey a right to begin operations. You MUST submit, and have approval of your performance and financial warranties, and receive your copy of the signed permit document PRIOR to beginning on -site mining activity. AUTOMATIC PERMIT APPROVAL: An automatic approval will occur where the Office fails to notify the applicant/operator that the application has been denied. This decision must be made ninety (90) calendar days from the date the application was determined to have been filed. However, the performance and financial warranties must be submitted and approved by the Office before the permit will be issued even if you receive an automatic approval. NO MINING OPERATIONS SHALL BEGIN UNTIL A PERMIT IS ISSUED (Section 34-32.5-109(1), C.R.S.). -iv - COMPLIANCE WITH OTHER LAWS: Compliance with the Act and Rules and Regulations of the Mined Land Reclamation Board DOES NOT relieve you of your responsibility to comply with all other applicable state and federal laws. We recommend that you contact the following agencies to determine whether you need to comply with their legal requirements: o The Colorado State Historical Preservation Office regarding properties of historical significance including the need for an archeological survey, procedures for requesting a file search, and inventory forms to identify structures. o Colorado Division of Water Resources with regard to water rights; Colorado Department of Health, Water Quality Control Division, with regard to the discharge of pollutants into the State waters; o Colorado Department of Health, Air Pollution Control Division, with regard to the need for a fugitive dust permit; o U.S. Bureau of Land Management or the U.S. Forest Service if the proposed operation will occur on federal lands; o U. S. Army Corps of Engineers regarding a dredge and fill (404) permit; and The County Planning Department for the county or counties in which your proposed operation is located. Section 34-32.5-109(3), C.R.S, requires a mining operator to be responsible for assuring that the mining operation and the post -mining land use comply with local land use regulations and any master plan for extraction adopted pursuant to Section 34-1-304, C.R.S. COMPLETION OF MINING: Upon completion of any phase of reclamation, you should consult Rule 3.1 for reclamation standards and 4.16 for details on how to request a reclamation responsibility release from the Board. STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 CONSTRUCTION MATERIALS REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION FORM CHECK ONE: ✓ There is a File Number Already Assigned to this Operation COLORADO DIVISION OF RECLAMATION MINING SAFETY Permit # MZ,g22 - 013 (Please reference the file number currently assigned to this operation) New Application (Rule 1.4.5) Conversion Application (Rule 1.11) Amendment Application (Rule 1.10) Permit # M - (provide for Amendments and Conversions of existing permits) The application for a Construction Materials Regular 112 Operation Reclamation Permit contains three major parts: (1) the application form; (2) Exhibits A -S, Addendum 1, any sections of Exhibit 6.5 (Geotechnical Stability Exhibit; and (3) the application fee. When you submit your application, be sure to include one (1) complete signed and notarized ORIGINAL and one (1) copy of the completed application form, two (2) copies of Exhibits A -S, Addendum 1, appropriate sections of 6.5 (Geotechnical Stability Exhibit, and a check for the application fee described under Section (4) below. Exhibits should NOT be bound or in a 3 -ring binder; maps should be folded to 8 1/2" X 11" or 8 1/2" X 14" size. To expedite processing, please provide the information in the format and order described in this form. GENERAL OPERATION INFORMATION Type or print clearly, in the space provided, ALL information requested below. 1. Applicant/operator or company name (name to be used on permit): Raptor Materials, LLC. 1.1 Type of organization (corporation, partnership, etc.): Limited Liability Company 2. Operation name (pit, mine or site name): Two Rivers Sand, Gravel & Reservoir Project 3 Permitted acreage (new or existing site) : 3.1 Change in acreage (+) 3.2 Total acreage in Permit area 4. Fees: 4.1 4.2 4.4 4.5 New Application New Quarry Application Amendment Fee Conversion to 112 operation (set by statute) 5 Primary commoditie(s) to be mined: sand 5.1 Incidental commoditie(s) to be mined: 1. 3. / lbs/Tons/yr 4. gravel earth products lbs/Tons/yr 2. 409.234 permitted acres acres acres $2,696.00 $3,342.00 $2,229.00 $2,696.00 application fee quarry application amendment fee conversion fee lbs/Tons/yr / lbs/Tons/yr 5. / lbs/Tons/yr 5.2 Anticipated end use of primary commoditie(s) to be mined: commercial urban & rurual infrastructure needs N/A 5.3 Anticipated end use of incidental commoditie(s) to be mined: 6. Name of owner of subsurface rights of affected land: Raptor Materials, LLC. If 2 or more owners, "refer to Exhibit O". 7 Name of owner of surface of affected land: Raptor Materials, LLC. 8. Type �e of mining operation: eration: Surface 1' Underground 9 Location Information: The center of the area where the majority of mining will occur: COUNTY: Weld PRINCIPAL MERIDIAN (check one): SECTION (write number): TOWNSHIP (write number and check direction) : RANGE (write number and check direction) : QUARTER SECTION (check one) : QUARTER/QUARTER SECTION (check one) : 6th (Colorado) 10th (New Mexico) s3 T4 R 66 i North East _ South West NE I " NW In SE r SW NE NW SE ' SW Ute GENERAL DESCRIPTION: (the number of miles and direction from the nearest town and the approximate elevation): 10. Primary Mine Entrance Location (report in either Latitude/Longitude OR UTM): Latitude/Longitude: Example: (N) 39° 44' 12.98" (W) 104° 59' 3.87" Latitude (N): deg min sec (2 decimal places) Longitude (W): deg nun sec (2 decimal places) OR Example: (N) 39.73691° (W) -104.98449° Latitude 40 .348174 (5 decimal places) P ) Longitude(W) -104 .776631 (5 decimal places) OR Universal Tranverse Mercator (UTM) Example: 201336.3 E NAD27 Zone 13 4398351.2 N s eci NAD27, NAD83 or WGS 84) N ad 83 Zone 13 UTM Datum (specify Easting Northing 11. Corresvondence reformation: APPLICANT/OPERATOR (name, address, and phone of name to be used on permit) Contact's Name: Kevin Jeakins Tide: Vice -President Company Name: Raptor Materials, LLC. Street/P.O. Box: 8120 Gage Street P.J. Box: City: Frederick State: Colorado Zip Code: 8°516 Telephone Number: (303 ) _ 666-6657 Fax Number: (303 ) .. 666-6743 PERMITTING CONTACT (if different from applicant/operator above) Garrett G. Varra Title: General Manager Contact's Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: INSPECTION CONTACT Contacts Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: Raptor Materials, , LLC. 8120 Gage Street Frederick P.O. Box: Colorado (303 )- 666-6657 (303 ) - 666-6743 Zip Code: 80°16 Garrett C. Varra Title: General Manager Raptor Materials, LL. 8120 Gage Street P.O. Box: Frederick Colorado (303 ) _ 666-6657 (303 ) s 666-6743 CC: STATE OR FEDERAL LANDOWNER if any) Agency: Street: City: State: Zip Code: 80516 Zip Code: Telephone Number: ( a CC: STATE OR FEDERAL LANDOWNER Of any) Agency: Street: City: State: Zip Code: Telephone Number: C ) r 4 12. Prima future (Post -mining) land use (check one): rcpland(CR) fl Pastureland(PL) El Rangeland(RL) r] Forestry(FR) El Residential(RS) flRection(R) Trif Developed Water Resources(WR) 13. Primary present land use (check one Cropland(R) Rangeland(RL) Residential(RS) Pastureland(PL) Forestry(FR) RecreationCR ) Developed Water Resources(WR) r General Agrictiiture(GA) Wildlife Habitat(WL) IndustrialJCommerci al(IC) n Solid Waste Disposal(WD) General Agricuiture(A) Wildlife Habitat(WL) Industrial/Commercial(1C) 14. Method of Mining: Briefly explain mining method (e.g, truck/shovel): Surface extraction, processing, and transport of aggregate resources until bedrock establishment of final basins is mplete. 15_ On Site Processing : 11717 Crushing/Screening 13.1 Briefly explain mining method (e.g. truck/shovel): In place extraction of unconselidate+d soil and aggregate by excavators, dozers, scrapers, or backhoes followed by transportation by conveyor or haul truck to a processing locations where material ps crushed, screened, end prepared and stockpiled for commercial sale and removal from property. All extracted materials may be utilized for either commercial purposes or on -site reclamation and development. List any designated chemicals or acid -producing materials to be used or stored within permit area: None 16. Description of Amendment or Conversion: If you are amending or converting an existing operation, provide a brief narrative describing the proposed change(s). N/A - Mans and Exhibits: Two (2) complete, unbound application packages must be submitted. One complete application package consists of a signed application form and the set of maps and exhibits referenced below as Exhibits A - S, Addendum 1, and the Cieotechnical Stability Exhibit. Each exhibit within the application must be presented as a separate section. Begin each exhibit on a new page. Pages should be numbered consecutively for ease of reference. If separate documents are used as appendices, please reference these by name in the exhibit. With each of the two (2) signed application forms, you must submit a corresponding set of the maps and exhibits as described in the following references to Rule 6.4, 6.5, and 1.6.2(1)(b): EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D EXHIBIT E EXHIBIT F EXHIBIT G EXHIBIT H EXHIBIT I EXHIBIT J EXHIBIT K EXHIBIT L EXHIBIT M EXHIBIT N EXHIBIT 0 EXHIBIT P EXHIBIT EXHIBIT R EXHIBIT S Rule 1.6.2(1)(b) Rule 6.5 Legal Description Index Map. Pre -Mining and Mining Plan Map(s) of Affected Lands Mining Plan Reclamation Plan Reclamation Plan Map Water Information Wildlife Information Soils Information Vegetation Information Climate Information Reclamation Costs Other Permits and Licenses Source of Legal Right -To -Enter Owners of Record of Affected Land (Surface Area) and Owners of Substance to be Mined Municipalities Within Two Miles Proof of Mailing of Notices to County Commissioners and Conservation District Proof of Filing with County Clerk or Recorder Permanent Man -Made Structures ADDENDUM I - Notice Requirements (sample enclosed) +eotechnical Stability Exhibit (any required sections) The instructions for preparing Exhibits A -S, Addendum I, and Geotechnical Stability Exhibit are specified under Rule 6.4 and 6.5 and Rule 1.6.2(1)(b) ofthe Rules and Regulations. If you have any questions on preparing the Exhibits or content ofthe information required, or would like to schedule a pre -application meeting you may contact the Office at 303-866-3567. Responsibilities as a Permittee: Upon application approval and permit issuance, this application becomes a legally binding document. Therefore, there are a number of important requirements which you, as a permittee, should fully understand. These requirements are listed below. Please read and initial each requirement, in the space provided, to acknowledge that you understand your obligations. If you do not understand these obligations then please contact this Office for a full explanation. I,. Your obligation to reclaim the site is not limited to the amount of the financial warranty. You assume legal liability for all reasonable expenses which the Board or the Office may incur to reclaim the affected lands associated with your mining operation in the event your permit is revoked and financial warranty is forfeited; VS. sts ‘4‘ Y.r 2. The Board may suspend or revoke this permit, or assess a civil penalty, upon a finding that the permittee violated the terms or conditions of this permit, the Act, the Mineral Rules and Regulations, or that information contained in the application or your permit misrepresent important material facts; 3. If your mining and reclamation operations affect areas beyond the boundaries of an approved permit boundary, substantial civil penalties, to you as permittee can result; 4. Any modification to the approved mining and reclamation plan from those described in your approved application requires you to submit a permit modification and obtain approval from the Board or Office; 5. It is your responsibility to notify the office of any changes in your address or phone number; 6. Upon permit issuance and prior to beginning on -site mining activity, you must post a sign at the entrance of the mine site, which shall be clearly visible from the access road, with the following information (Rule 3.1.12): a. the name of the operator; b. a statement that a reclamation permit for the operation has been issued by the Colorado Mined Land Reclamation Board; and, c. the permit number. 7. The boundaries of the permit boundary area must be marked by monuments or other markers that are clearly visible and adequate to delineate such boundaries prior to site disturbance. 8. It is a provision of this permit that the operations will be conducted in accordance with the terms and conditions listed in your application, as well as withthe provisions of the Act and the Construction Material Rules and Regulations in effect at the time the permit is issued. 9. Annually, on the anniversary date of permit issuance, you must submit an annual fee as specified by Statute, and an annual report which includes a map describing the acreage affected and the acreage reclaimed to date (if there are changes from the previous year), any monitoring required by the Reclamation Plan to be submitted annually on the anniversary date of the permit approval. Annual fees are for the previous year a permit is held. For example, a permit with the anniversary date ofJuly 1, 1995, the annual fee is for the period of July 1, 1994 through June 30, 1995. Failure to submit your annual fee and report by the permit anniversary date may result in a civil. penalty, revocation of your permit, and forfeiture of your financial warranty. It is your responsibility, as the pe . ettee, to continue to pay your annual fee to the office until the Board releases you from your total reclamation respo►ns b i l i ty . 10. For joint venture/partnership operators: the signing representative is authorized to sign this document and a power of attorney (provided by the partner(s)) authorizing the signature of the representative is attached to this application. 7 NOTE TO COMMENTORS/OBJECTORS: S/O ECToRS: It is likely there will be additions, changes, and deletions to this document prior to final decision by the Office. Therefore, if you have any comments or concerns you must contact the applicant or the Office prior to the decision date so that you will know what changes may have been made to the application document. The Office is not allowed to consider comments, unless they are written, and received prior to the end of the public comment period. You should contact the applicant for the final date of the public comment period. Ifyou have questions about the Mined Land Reclamation Board and Offices review and decision or appeals process., you may contact the Office at (303) 866-3567. Certification: As an authorized representative of the applicant, I hereby certify that the operation described has met the minimum requirements of the following terms and conditions: 1. To the best of my knowledge, all significant, valuable and permanent nnanemade structure(s) in existence at the time this application is filed, and located within 200 feet ofthe proposed affected area have been identified in this application (Section 34-32.5-115(4)(e), C.R.S.). 2. No mining operation will be located on lands where such operations are prohibited by law (Section 34-32.5-115(4)(i C.R.S., 3. As the applicantioperator, I do not have any extraction/exploration operations in the State ofColorado currently in violation of the provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials (Section 34-32.5-120, C.R.S.) as determined through a Board finding. 4. I understand that statements in the application are being made under penalty of perjury and that false statements made herein are punishable as a Class 1 misdemeanor pursuant to Section 18-8.503, C.R.S. This farm has been approved by the Mined Land Reclamation Board pursuant to section 34-32.5-I '2, R. '., of the Colorado Land Reclamation Actfor the Extraction of Construction Materials. Any alteration or modification °fats form shall result in voiding any permit issued an the altered or modified form and subject the operator to cease and desist orders and civil penalties, for operating without a permit pursuant to section 34-32.5-123, &. Signed and dated this 1 gstriA day of ital S , ev\A Applicant/Operator or Company Name Signed: Title: Kevin Jeakins, Vice -President State of County of tAi )ss If Corporation Attest (Seal) NO SEAL/NO CORPORATE SECRETARY - This is a Limited Liability Company Signed: The foregoing instrument was acknowledged before me this 4 % day of 20!2, by .e Viet dealt' ' A s as vP JESSICA HOOVER NOTARY PUBUC STATE OF COLORADO NOTARY ID 20044035571 MY COMMISSION EXPIRES OCTOBER 4, 2024 abs Corporate Secretary or Equivalent Town/City/County Clerk lake of €&04*or Make rs l,L My Commission expires: I DI 412 SIGNATURES MUST BE IN BLUE INK You must post sufficient Notices at the location of the proposed mine site to clearly identify the site as the location of a 6.4.12 EXHIBIT L - Reclamation Costs (1) 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. (2) 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: $ 12,352.35± Site Discharge $ 130,002.96± Total Grading per Extraction Front. $ 402,338.53± Total Liner Construction Expense $ 20,359.20± Total Re -soiling (inc. Processing area) $ 5,449.27± Total Re -vegetation Expense (inc. Processing area) $ 74,552.68± Total Processing/Conveyor Removal Expense $ 645,054.99± $ 10,000.00+ $ 655,054.99± $ 159,407.63± $ 814,462.63± Sub -Total Possible Mobilization and Demobilization Costs (pending OMLR estimate) Sub -Total Direct Costs Possible Indirect Costs Pending DRMS Indirect Costs @ 24.335 % of Total Reclamation Costs Grand Total - Financial Warranty Amount - Pending OMLR Review and estimates including estimated expenses for State of Colorado Mobilization and Demobilization and other `Indirect' cost determinations by the Office. SUMMARY OVERVIEW: Table 1 - Primary Data on Area of Total Proposed Affected Lands and Reclaimed Features: Entity Central Field North-West Field Combined Extraction — finished basin (Acres) 162.57 41.04 203.61 Static Water Area surface (Acres) 151.38 36.28 187.66 — Static Water Area — elevation (ft.) 4,673 4,675 Basin Level (Acres) Lands Above Static Water 11.19 . 7 15.95 Basin Area Volume (;u.yds.) 7,278,366 1,649,937 8,928,303 Static Water Level Volume (Gallons) 1, 470, 040, 694 333, 244, 376 1, 803, 285, 070 Static Water Level Volume (Acre Feet) 4,511.4 1,022.7 5,534.1 Plant Processing Area (Acres) 15.76 Wash Pond Area (Acres) 5.60 Total Level Lands (Acres) Above Static Water 37.31 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION e 12 6.4.12 EXHIBIT L - Reclamation Costs NOTE Well: All lands within the 409.234± 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 on -set 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 Right -of -Ways are offset from operations and while they may fall within the 409.234± acre parcel — are excepted from the permit conditions to the extent of their approved setbacks. The following estimates utilize assumptions based upon the pre -disturbed state of the application 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 Colorado Office of Mined Land Reclamation (OMLR), as indicated: RECLAMATION EXPOSURE: 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 utilized to create a reasonably close estimate. The per unit basis from Division records are shown along with other sources used or referenced to determine unit costs, at the back of this exhibit. METHOD OF EXTRACTION: Before concurrent grading, resoiling, i ng, and revegetation for reclamation can commence, a perimeter keyway (dewatering trench') must first circumnavigate the area where the perimeter slopes form along the extraction limits. For Two Rivers, this includes four sequential areas of extraction: • 121.86± Acres - Central Field — Center Section • 15.58± Acres - Central Field — North-East Section25.09± Acres - Central Field - West Section • 41.04± Acres - North-West Field l Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 3 6.4.12 EXHIBIT L - Reclamation Costs Exhibit L: Financial Warranty Map, shows Initial Extraction will begin in the yellow hatch area shown on the Exhibit L Map, comprising 16± acres. The direction of extraction will follow the perimeter of the extraction limits over approximately 70.21± acres in order to establish the perimeter keyway for the 121.86± acre Center Section of Central Field. The perimeter extraction will leave a 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The initial extraction area is bordered to the South adjacent to a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). Extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed under Exhibit D: Extraction Plan. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary settling basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H:1V, :1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.00H:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and excise the bed dimensions where the resulting channel is sufficient to convey the groundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape and size presented. 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. UNITS OF DISTURBANCE: The life of the operation is based upon a base rate of extraction approximating 8.0± acres of disturbance in a given year. This time will pulse with the market and may average 8.0+ acres, but could be faster or slower. Starting out, initial warranty necessary to cover the costs of reclamation for the extent of disturbance in a given year will also vary in time and circumstance, as the initial disturbance is generally less at the onset. So, a rate of disturbance can be estimated and the warranty adjusted incrementally with time and circumstance. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 4 6.4.12 EXHIBIT L - Reclamation Costs Starting out in the initial projected 5 years of Operations, and incrementally thereafter, n ecessary warranty can be estimated and adjusted in incremental Units based upon the projected Life of the Operation. Essentially, a 28-33± year Life of Operations assumes a rate of extraction of approximately 8.0± acres per year. Considering the Mining -Regrading Schedule included as Table E-1 in Exhibit E, and the general development concept shown on Exhibit L: Financial Warranty Map, Raptor estimates for the initial 5 -year period, development of an initial 40 -acre excavation and development of a "Core" area in the Center Section of Central Field will result in creation of approximately 6,200 -foot of external perimeter pit wall. No reclamation or lining is anticipated in the initial 5 -year period. It is important to note that the financial warranty estimates the closure cost of the operation at the end of the expected first 5 -year period. It is assumed in this initial estimate that no reclamation activities (regrading, lining, topsoiling) will take place. The cost estimate then reflects reclaiming the projected excavation at that point in time. The actual extents and shape of the excavation may change, and actual progress will be addressed in the annual reports. Raptor estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H:1 V and a 2,180 -foot wall at 1.25:1V slopes. DEWATERING: Raptor assumes that the pit would be in an unlined state and if operations had ceased, would recharge to static water level requiring dewatering of the pit to allow reclamation o perations to be completed. 100 hp. 4,500 gal./min. pump x (up to) 3 pumps @ 24 hours/day Volumes per Tract: Total Gallons — Central Field = 1,470,040,694± gallons , 151.38 surface water acres = 9,710,931 gal./acre x 40.0± acres = 388,437,229± gallons for the initial 5 -year excavation. 1 = Avg. = 77,687,448 gal./8.0 acres x $ 0.000026/gal. discharge (refer to Kurtz est. u tilizing similar pump and rates.) Total Cost for initial 40.0± acres of Discharge = 388,437,229± ± gallons x $ 0.000026/gal. discharge (refer to Kurtz est. utilizing similar pump and rates.) $ 10,099.37 -Initial Discharge Cost for 40± acres VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 5 6.4.12 EXHIBIT L - Reclamation Costs It is assumed that ongoing dewatering will be required during reclamation of the pit and Raptor has allowed for 30 days once the pit has been dewatered. The estimated inflow rate to the fully excavated pits has been estimated at 14,700,000 gallons/day. The initial 40 -acre excavation area represents approximately 19.6% of total pit volume. Total discharge to maintain dry conditions for reclamation then is: 14,700,000 gallons/day x 19.6% x 30 days = 86,653,240± gallons $ 2,252.98 30 days Dewatering Cost for 40± acres $ 12,352.35 Total Dewatering Cost for 40± acres Please Note: 2The basins will be lined or otherwise segregated from the area groundwater, in order to liberate the water otherwise retained to supplement loss from evaporation in the unlined state. GRADING: As stated above, Raptor conservatively estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H:1V and a 2,180 -foot wall at 1.25:1V slopes along the extraction limits flanking WCR 396; and 2H:1V along the South Platte River levee, as shown on Exhibit D: Extraction Plan, and Exhibit L: Financial Warranty Map. Actual volume of fill required to grade at 3H:1V for a respective cut slope is determined in the graphics, below. Square Foot volume of backfill x linear feet of slope divided by 27 will yield the required cubic yards needed for each section of highwall. A rate per Loose Cubic Yard of fill taken from the previously approved values determined by the OMLR, is used to better ensure the integrity of the resulting values. Adequacy Item 28 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 6.4.12 EXHIBIT L - Reclamation Costs D 4OO'_L depth '.,N. . A M 1: ki I _ I: 1V F NI HED R ' b sin 1490 do, ckte. sti/ FILL TO GRADE = 80Q SO1Ff. DIAGRAM 40.O'± ceDth FILL TO GRADE - 1,400 SQ. FT Hauls are expected to be very short excavating material from the core area to establish final grade on those walls and placed on the exterior walls to establish the required grades and it may only require a wheel loader operating in load/carry/dump mode with a supporting tracked dozer. At most, the method of fill will utilize one (1) Excavator/Loader, two (2) Haul Trucks, and one (1) Sheep's Foot Compactor. Assuming a mean depth of advancing cut of 1.25H:1V at the extraction limits of 40.0+ feet depth: VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 7 6.4.12 EXHIBIT L - Reclamation Costs 2,180± lin.ft. (extraction front and side slopes) x 1,400.00± sq.ft. = 113,037± LCY 113,037± LCY x $ 0.56± per LCY. $ 63,300.74± fill along an 2,180 -foot extraction front cut at 1.25H:1V. Assuming a mean depth of advancing cut of 2:1V at the extraction limits of 40.0± feet depth: 4,020± lin.ft. (extraction front and side slopes) x 800.00± sq.ft. (required fill — Diagram 1, above) = 119,111± LCY 119,111± LCY x $ 0.56± per LCY. $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction front cut at 2H:1V $ 63,300.74Sub Total -Grading to 3H:1V along an 2,180 -foot extraction front cut at 1.25H:1V. + $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction front cut at 2H:1V. $130,002.96 Total - Initial Grading. Liner Installation: Raptor has made allowance for liner installation on the regraded slope. Assumptions are that a 4 -foot -thick liner will be keyed into bedrock at the base of the regraded slope and up the slope to approximately 5 -foot below the original surface elevation. It is further assumed that the interior wall of the regraded core area will be of similar length to the external wall. The keyway dimensions in bedrock are assumed to be 4x4 -foot. Perimeter liner at 10,810 lin.ft. x 111 sq.ft./ft x 4 ft. / 27 = 177,252 CY of liner placed at an estimated cost of $2.20/CY = $ 389,953.34. Keyway at the base of the 3:1 slope is estimated at 9,500 lin.ft. x 16 sq.ft./ft / 27 = 5,630 CY of liner placed an estimated cost of $2.20/CY = $12,385.19. $ 402,338.53 Total Liner Installation Cost Soil Demand AND Re -soiling of Affected Lands (refer to Exhibit D): Soil demand is limited to the cut basin slopes remaining above the static water level. For Central Field, the total area above the anticipated static water level of the basins is 11.19 ± acres. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 8 6.4.12 EXHIBIT L - Reclamation Costs To estimate the area involved in resoiling the Center Section of Central Field — we'll use a percentage of the total perimeter length of the extraction limits involved: 14,311 Total perimeter length Central Field 6,200 External perimeter length Center —Central Field —extraction limits 4,610 Internal perimeter length on core area 10,810 Combined perimeter length 10,810 : 14,311 = 76% 11.19 acres x 76% = 8.5± acres requiring resoiling and revegetation (see Establishment of Vegetation over Affected Lands, below. At a depth of 0.5± feet, total volume = 8.5± acres x 0.5± feet of soil replacement, is: 8.5± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 6,857± cu.yds. @ 0.5' depth. The majority of soil placement can occur using the average placement distance of 600 ft., or less along embankments, (utilizing the same assumptions utilized at either Kurtz or Heintzelman Projects). 6,857± cu.yds of soil demand x $ 0.843 per LCY. $ 5,780.17to replace 0.5± feet of soil over the existing affected lands remaining above the anticipated final water level at the Center of Central Field along the perimeter cut slopes at the extraction limits. 3Although Raptor does not anticipate the areas of soil replacement to be extensively compacted, an allowance for disking or scarifying 25% of the area at a cost of $28.5/acre. 8.5± acres x 25% x $28.50/acre = $60.60 The processing area will also require soil replacement over the entire 21.35 acre area. 21.35± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 17,222± cu.yds. @ 0.5' depth. 17,222± cu.yds of soil demand x $ 0.843 per LCY. $ 14,518.43 to replace 0.5± feet of soil over the existing affected lands in the processing area. 3 Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 9 6.4.12 EXHIBIT L - Reclamation Costs 4Raptor assumes disking or scarifying this entire area at a cost of $28.5/acre. 21.35± acres x 100% x $28.50/acre = $608.48 $ 20,359.20 Total Soil Replacement Cost NOTE: Total Soil Demand for the entire Central Field and the North-West Field: 11.19± Acres Central Field 4.76± Acres North-West Field 15.95± Acres Total — Combined Soil Replacement Demand 15.95± Acres x 43,560 sq.ft./acre : 27 cu.ft./cu.yd. = 25,732.67± cu.yds. @ 1' depth.25,732.67± cu.yds. @ 1' depth soil : 2 = 12,866.33± total cu.yds soil required at 6 inches in depth at Central and North-West Fields for all basin slopes remaining above the anticipated static water level and below the extraction limits. Establishment of Vegetation over Affected Lands: The demand establishment of vegetation over the affected lands will also diminish proportionately with the planned extraction of the Tracts. For now, the total exposure is estimated as indicated above to be 8.5± acres for the Center Section of Central Field (see Soil Demand): NOTE: The cost for seed is estimated on Exhibit L - Table L-1: Primary/Preferred Re - vegetation Seed Mixture; however, the costs are known to fluctuate seasonally — and are estimates based on prior seasons. The seed mixture includes a substitute for mulch in the inclusion of a wheatgrass hybrid. The Division has historically agreed with and approved the inclusion of this hybrid as a substitute for mulch. The Optional Seed Mix will be used if the Primary Mixture fails, but costs less, so that cost is accounted for. These costs are as follows: $ 58.72± Preferred Seed Mix x 8.5± acres $ 499.12± Sub -Total Seed The cost for applying seed is based upon information derived in proximity to the Northern Colorado economy. Costs for tilling, fertilizing and seeding are based upon estimates from Longs Peak Equipment Co. These costs, including labor, are reflected as follows: $ 25.00± per acre Tilling $ 20.00± per acre Fertilizing $ 20.00± per acre Seeding Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 10 6.4.12 EXHIBIT L - Reclamation Costs $ 65.00± per acre Total Application Cost per Acre. x 8.5± acres $ 552.5± Sub -Total — Application Costs $ 1,051.62± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or $ 525.81± Sub -Total Re -seeding costs $ 1,577.43± Excavation Area Re -vegetation Expense Re -vegetation of the 21.35 acre processing area is also estimated. $ 58.72± Preferred Seed Mix x 21.35± acres $ 1,253.67± Sub -Total Seed $ 65.00± per acre Total Application Cost per Acre. x 21.35± acres $ 1,387.75± Sub -Total — Application Costs $ 2,641.42± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or $ 1,320.71± Sub -Total Re -seeding costs $ 3,962.13± Processing Area Re -vegetation Expense $ 5,449.27 Total Re -vegetation Cost Processing Area and Decommissioning: Raptor has estimated decommissioning costs for the Processing Area and Conveyor that will deliver mined material to that area. All plant and equipment in the processing area is portable and would have more value that the cost of loading and removing it. Decommissioning will involve the removal of concrete pads for processing equipment, concrete supports for truck scales and temporary buildings, and the conveyor infrastructure and belting. Three 12 -inch -thick concrete pads are assumed in the processing area with dimensions 15- x 30 -feet, 15- x 60 -feet, and 15- x 25 -feet. Demolition and removal costs are estimated at $1.70/sq.ft. for 12" concrete pads. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 11 6.4.12 EXHIBIT L - Reclamation Costs The truck scale will have concrete supports with an estimated volume of 10 CY. Additionally temporary buildings for the scale house/site entrance area and processing area will have concrete support blocks with estimated at 8 CY of concrete. Estimated costs for the concrete supports is $65.00/CY. Concrete pads: 1,725 sq.ft. x $1.70/sq.ft. _ $ 2,932.50 Concrete supports: 18 CY x $65.00/CY = $ 1,170.00 The decommissioning cost estimate for the conveyor structure is based on previous estimates provided by Divide Construction for other Raptor (previously Varra) operations and presented in Financial Warranty estimates. The costs have been updated to current using US Army Corps of Engineers Civil Works Construction Cost Index System (CWCCIS) indices. The regular conveyor structure in 40 -foot sections supported on concrete blocks is estimated to be 1,787± lin.ft. with an additional three extended span elevated truss sections 125 -foot in length for crossing WCR296 and the Big Thompson River. Decommissioning costs for the regular conveyor structure is estimated at $ 8.75/lin.ft. and the extended spans at $ 18,270.00 each. Conveyor decommissioning: 1,787± lin.ft. x $ 8.75/lin.ft. _ $ 15,640.18 Conveyor extended spans: 3 x $ 18,270.00 each = $ 54,810.00 $ 74,552.68 Total Processing and Conveyor Decommissioning Cost OTHER MISCELLANEOUS COSTS: 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 $10,000. Demolition of Structures: None. Building Permits for structures will be obtain where required from the Weld County Building Department. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 6.4.12 EXHIBIT L - Reclamation Costs Please Note: Since there is no possibility of the applicant in fully reproducing the Division's methods, utilizing similarities from past OMLR 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. Extraction of the Core following completion of the Perimeter Extraction Keyway VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page Ii 6.4.5 EXHIBIT I/J - Soils and Vegetation Information 6.4.9 EXHIBIT I - Soils Information (1) In consultation with the Soil Conservation Service or other qualified person, the Operator/Applicant shall indicate on a map (in Exhibit C) or by a statement, the general type, thickness and distribution of soil over the affected land. Such description will address suitability of topsoil (or other material) for establishment and maintenance of plant growth. The above information shall satisfy "completeness" requirements for purposes of determination of date of filing. (2) If necessary, at its discretion, the Board may require additional information on soils or other growth media to be stockpiled and used in revegetation to be submitted subsequent to the filing and notification of "completeness" of the application. 6.4.10 EXHIBIT J - Vegetation Information (1) The Operator/Applicant shall include in this Exhibit a narrative of the following items: (a) descriptions of present vegetation types, which include quantitative estimates of cover and height for the principal species in each life -form represented (i.e., trees, tall shrubs, low shrubs, grasses, forbs); (b) the relationship of present vegetation types to soil types, or alternatively, the information may be presented on a map; and (c) estimates of average annual production for hay meadows and croplands, and carrying capacity for range lands on or in the vicinity of the affected land, if the choice of reclamation is for range or agriculture. (2) The Operator/Applicant shall show the relation of the types of vegetation to existing topography on a map in Exhibit C. In providing such information, the Operator/Applicant may want to contact the local Soil Conservation District. Exhibit I & J — Soils & Vegetation Map, identifies the type and extent of soils over the project site and surrounding lands. Areas designated for resource recovery within the extraction limits will remove all recoverable soils. A portion of the available soils will be utilized for reclamation from a portion of either existing or future soil stockpiles, or suitable in situ soils, as circumstances warrant. The balance of soils not otherwise needed for reclamation of affected lands remaining above the anticipated static water level of the completed basins will be made available to meet the demands of the market. Interpretation of current soil conditions and vegetation suitable for reclamation relies in part on information and correlated available data from the U.S. Soil Conservation Service (SCS) Soil Surveys and updated digital information of the same by the renamed U.S. Natural Resources VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 12 6.4.5 EXHIBIT I/J - Soils and Vegetation Information Conservation Service (NRCS). Range Site Descriptions (uniquely designated for each Soil Unit as shown by number and boundary on Exhibit I/J: Soils and Vegetation Map) and other related soil and ecosystem information taken from these publications. The information extracted from this source is included at the back of this exhibit. SOI L LEGEND of on -site soils (Refer to Exhibit I/J: Soils & Vegetation Map): SOIL UNIT #3. AQUOLLS & AQUENTS, GRAVELLY SUBSTRATUM; CAPABILITY SUBCLASS VIw; SALT MEADOW RANGE SITE DESCRI PTI ON [A Horizon = 0-48" Depth - Atypical - Will vary randomly - poorly formed in alluvial floodplain] SOIL UNIT #4. AQUOLLS & AQUEPTS, flooded bottoms and depressions, 0% SLOPES; NO CAPABILITY SUBCLASS; AQUOLLS in SALT MEADOW & AQUEPTS in WET MEADOW RANGE SITE DESCRI PTI ON [A Horizon = 0-60" Depth - Atypical - Will vary randomly - poorly formed in alluvial floodplain] SOIL UNIT #51. OTERO SANDY LOAM, 1-3% SLOPE; CAPABILITY SUBCLASS I I I e I RRI GATED & VI e NON -I RRI GATED; SANDY PLAINS RANGE SITE DESCRI PTI ON [A Horizon = 0-12" Depth] SOI L UNIT # 52. OTERO SANDY LOAM, 3-5% SLOPE; CAPABILITY SUBCLASS I I I e I RRI GATED & VI e NON -I RRI GATED; SANDY PLAINS RANGE SITE DESCRI PTI ON [A Horizon = 0-12" Depth] SOIL UNIT #53. OTERO SANDY LOAM, 5-9% SLOPE; CAPABILITY SUBCLASS I Ve I RRI GATED & VI e NON -I RRI GATED; SANDY PLAINS RANGE SITE DESCRI PTI ON [A Horizon = 0-12" Depth] I nterpretations of former native conditions of soils and vegetation are offset and updated by present day field investigations, aerial images, and other resources. Ultimately, what is applied relies upon an arena of experience that draws upon an empirical understanding of the web of e nvironmental, technical, economic, industrial and regulatory factors acting in concert with historical land use influences that depart from the SCS/NRCS records reflected in the Soil Legend, above; and as shown on Exhibit I /J: Soils and Vegetation Map. The combined effort eventually finds itself as applied and established over the completed and newly adapted landscape of the future; as projected in the diverse exhibits made part of this application. The attending narrative descriptions in the included Soil Survey addendums and extracts, detail the native soils, vegetations, and associated ecological conditions likely prevalent over unaltered lands of like kind, and as they might present themselves over the identified parcels. The identified vegetation is an indicator of what did, or may, grow on the represented soils under native u ndisturbed soil conditions. This information is utilized to create the seed mixture(s) proposed u nder Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. The species selected for reseeding are selected as offering the best genetic potential for establishment of a diverse and e nduring stabilizing cover in the reclamation and restoration of the affected lands. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 13 6.4.5 EXHIBIT I/J - Soils and Vegetation Information A portion of in situ soils may be used in an over the shoulder method to resoil the completed banks of basin slopes or other upland areas in time. Commonly, soils will be parked in stockpiles u ntil ready for application in a manner more fully described below. Consistent with existing zoned agricultural practices, soil from an adjacent wetland bank was approved by the City of Evans, and completed in early 2021. The City of Evans approved (refer to the Addendum at the back of this Exhibit) the placement of these soils within the floodplain of the u pper North-East portion of Central Field, as shown on Exhibit C-2: Extraction Plan Map. These o rphan soils are in place, seeded, and the area remains under continuing agricultural production, yet are no longer part of the area floodplain. The current extent of this 200,000± cu.yd. stockpile is represented on Exhibit L: Financial Warranty Map. This stockpile location area will also receive a portion of soils removed from planned extraction locations over other areas of Central and North-West Fields. It should be noted that a monoculture of cultivated corn occupies a majority of the planned areas of extraction, and will gradually be turned out of production through extraction. This soil may be utilized to line the resulting basins, for reclamation of affected lands above the static water level, or for market as warranted. 1As described in Exhibit D, wetland conditions appear confined within portions of the stream terrace and bank -full stage of the rivers, and along segments internal to the Evans Canal. Excavation and processing activities will not take place within these areas. Under Exhibit M is an approved U.S. Army Corps of Engineers report designating 'No Permit Required.' If and when a conveyor is built upon the projected line, the footings are not expected to exceed the requirements for a Nationwide Permit, but if they will, a Nationwide Permit will be applied for and secured prior to affecting such areas. If a Nationwide Permit is necessary, the OMLR will be provided with the necessary justification or approval under an OMLR Technical Revision to that e nd. At this time there is little to find in dominant preferred species of cover typifying the cropped fields o r riverine areas. Beyond the row crops, the former pasturelands appear impacted by overgrazing, monocultures of smooth brome, annuals, and other comparatively recent impacts. Reclamation will not return the former Fields to agricultural crop production. Further, present day impacts over the planned Processing and Wash Pond locations do not reflect representative or realistic percent cover of a desirable matrix of native vegetation communities intended for reclamation. Consequently, the reclamation target will be to establish a stabilizing foliar cover of predominantly n ative vegetation (refer to seed mixture) of approximately 20 percent [determined as measured at the stem three inches above the ground surface respective of the foliar diameter of the established grass species, as determined by ocular estimates, or utilizing standard vegetation cover analysis such as line transect, as warranted] . For clarity, topsoil is generally regarded as the plow layer (upper six inches) on agricultural soils, o r the A-1 soil profile horizon otherwise. The solum, or soil, includes the topsoil plus all other material found above the regolith of the parent rock, and generally no deeper than the optimal ' Adequacy Item 49 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 4 6.4.5 EXHIBIT I/J - Soils and Vegetation Information depth of roots of perennial plants and trees, or which otherwise meets the definition of soil. One soil differs from another soil by its unique properties and characteristics (such as horizon profile development, structure, texture, color, percent organic matter, chemical composition, etc.) and is identified as such by soil scientists, and detailed in available SCS (NRCS) Soil Survey documents. The affected soils to be extracted as permitted are designated under the soil survey to fall predominantly under Unit 3: Aquolls and Aquents, gravelly substratum; and may include minor components of Unit 10: Blankard sandy loam (refer to extracts and tables from the 1980 Weld County Soil Survey — Southern Part). Occurring in flood plain locations, as they do at this location, while described as `deep,' would apply more commonly to the Mollisols that appear to form a minor component of the area soils, while the majority of the location is more characteristic of Aquolls, Aquent or Entisol soil formations, which are commonly poorly formed soils in floodplain locations, and lacking a typical profile or horizon development; or, in the case of the Blankard Series, having a shallow A -profile of 0-5 inches in depth overlying sand and gravel. The lack of a deep, well developed soil profile is in part due to alluvial flooding which both scours and lays down sediment of diverse textural classes over time, but which lacks the appearance of an I nceptisol which is also commonly associated with flood plain locations. Deeper profiles may occur, however they are difficult to map under the best of conditions as they may vary every three (3) feet. Fundamentally, previous crop production activities over Unit 3 soils created a plow layer over the majority of Central Field, to an approximate depth of six inches; and likely contains the greater percentage of desirable organic matter and texture amenable to plant establishment and sustainability. These former rangelands turned to croplands have no predictable soil profile of consequence as you progress increasingly below the cropped layer. Other minor areas of impact over the remaining acres found within the parcel, have poorly developed soils whose depths vary from zero to eight inches. While anomalous pockets of deeper soil depths may occur, for purposes of this submittal, we will assume a soil depth to the plow layer of six inches over affected lands, excluding any obvious previously disturbed ground where soil has been removed (trenches, structures, etc.). Regardless, there is sufficient soil to assure a resoil depth of approximately six inches over the basin banks above the anticipated static water level of the reservoirs. The predominantly Otero Series soils underlying planned processing and product stockpile and transportation north of the Evans Canal are shallow soils of a foot or less over eolian deposits and alluvium; or sandstone bedrock, as in the case for the Tassel Series Soils. These soils are best left undisturbed where possible and simply reclaimed in place once processing and related activities are completed. For purposes of this submittal, all lands within the indicated permit boundary will be considered affected lands, but only those locations between the existing access roads, and which otherwise remain above the anticipated static water level of the resulting basins, will be soiled and seeded to establish vegetation consistent with the approved reclamation plan. All other previously disturbed lands outside of this area may be seeded to establish the desired vegetative cover where reaffected by planned activities, but in its previously disturbed state will not receive additional soil resources beyond what already remains, if any. Fortunately, the act of extraction serves to return affected lands to a stable configuration, and in a manner that creates a more enduring and beneficial habitat of indigenous vegetation and abundant water. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 15 6.4.5 EXHIBIT I/J - Soils and Vegetation Information Soil salvage will commence with the removal of the surface layer of soil to a mean depth of 6.0+ inches, depending upon equipment and equipment operator limitations. Additional depths of soil (to the extent it occurs) will be removed in like manner until commercially viable overburden and aggregate are reached, unless already exposed as a result of poor soil development or flood based deposition. Soil salvage will be conducted primarily with excavators, but may include other heavy equipment such as bulldozers as warranted. To minimize the undesirable effects of soil blowing and loss, and to avoid damage to the soil resource via compaction, soil will be stripped wherever possible when soil is moist, and not dry or wet. Any portion of the solum suitable for plant regrowth will be utilized to meet the minimum depth of soil replacement for reclamation, with the excess made commercially available for export from the property. Generally, soil will be retained in sufficient volume to reclaim all lands remaining between the anticipated static water level of the basins and existing access roads which surround them at any given point in time during resource recovery operations. As detailed under Exhibit L - Reclamation Costs, the initial exposure of lands requiring revegetation will be approximately 8.5± acres in the extraction area, and 21.35± acres requiring 24,049± cu.yds of soil. Total replacement ✓ olume required for Central and North-West Fields combined together with the processing area, is 30,089± cu.yds of soil. Once removed from its native location, soil retained for reclamation will be stockpiled over the North-East portion of Central Field, in an area already improved above the prior floodplain; or otherwise windrowed along the perimeter of the basin area of extraction or area to be resoiled and seeded with the reclamation seed mixture specified under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture, or as otherwise determined under an approved revision. Stabilization of inactive soil stockpiles will provide an opportunity to gauge the performance of the seed mixture while attempting to provide a stabilizing cover of vegetation over the stockpiled soil until it is ready for replacement on finished slopes and affected lands remaining above the anticipated static water level of the completed reservoir basins. Direct precipitation from short duration high intensity rainstorm events, and wind, are the common e rosion forces opposed to soil stability over in situ or established perimeter basin slopes at this location. The more uncommon flood event is considered under Exhibit G: Water Information, in the included Flow Technologies, Flood Control Mitigation Plan of 22 January 2020. Never the less, with few exceptions, the natural forces are commonly slight since the location geology and agricultural uses form a nearly flat table beyond the slopes of the extracted basins. Further, extraction will result in basin slopes that cause water from direct precipitation to drain internally, minimizing concentrated flows to existing area drainageways outside of the basin areas; while acting as detention and temporarily lowering any intersecting flood velocity and peak flows during a flood event. Additional conservation measures will be taken for common storm events to assure site stability and protection of off -site areas. An example would be directing overland flows, beyond the influence of the extracted basins, to existing or established grassed water ways. The operator's stormwater management plan may address additional detailed information about maintaining on -site stability consistent with its pending Colorado Department of Health stormwater permit. The measures taken to stabilize soil stockpiles described above, should be adequate for controlling e rosion from wind and direct precipitation at those locations. Wind born effects are reduced by VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 6 6.4.5 EXHIBIT I/J - Soils and Vegetation Information surface roughing during continued development of agricultural row crops, or from the natural consequence of extraction activity, itself. Due to the flat topography of the parcel, the interception of upland overland flows by local irrigation ditches and surrounding roads, there is little upland watershed that would impact these locations as a result of nominal storm related events. The greater threat of erosion will be to resoiled slopes pending establishment of vegetation during reclamation. While some sheet and rill erosion can be anticipated on unprotected areas following seed bed preparation and seeding, planned conservation measures should help to limit erosion potential that would threaten the revegetation efforts. Prior to resoiling, the foundation material that will underlie the soil will be sculpted to establish initial soil stabilization features, and left rough to aid in resoil adherence. Soil will be placed over a 12-18± inch minimum friable, or otherwise unconsolidated, subsoil. A 12-18± inch swale with slopes of 3H:1V or flatter will be placed above finished slopes where necessary to direct any upland surface flows around the finished slopes to an established stable drainage corridor or grass -way. Resoiled areas will be allowed sufficient time to settle prior to seeding. Seeding will commonly follow in the fall or spring as detailed under Exhibit E — Reclamation Plan. 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. Once applied to the surface, the new soils will be exposed to the raw forces of erosion until adequate vegetative cover and root mass develops. Erosion requires both detachment and transportation in order to occur. Running water, wind, and raindrop impact are the main forces of erosion acting upon the soil. The use of a sterile hybrid live cover crop will aid in the stabilization of the soil by allowing a quick vegetative cover to become established in advance of the native grasses. The hybrid will also serve as an aid to reduce competition resulting from the establishment and growth of unwanted pioneer species (weeds) on disturbed ground. The attending reclamation seed mixture, and as approved, has a provision for the use of a sterile hybrid grass in lieu of mulch. Mulch, even when crimped with specialized equipment, is subject to being blown off the property, or reduced to an ineffective stubble. Often, it has been observed to intercept rainfall where it quickly evaporates from the stubble surface, limiting the benefits of light precipitation by preventing infiltration and percolation of moisture to the root zone. The hybrid on the other hand will establish quickly, but since it is sterile, will not continue to compete with the emerging native grasses. After two to three years, the hybrid grass will begin to die out just as the native grasses emerge and improve their dominance over the revegetated areas. I ncreasing Organic matter, such as the incorporation of manure into fallow soils, will aid in the restructuring of the new soils by increasing the moisture and fertility holding capacity of the upper profile seed bed, while simultaneously facilitating healthier plant -soil -water relations and overall root development of the emerging grasses. As the roots of the emerging grasses develop and VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 7 6.4.5 EXHIBIT I/J - Soils and Vegetation Information mature over time, the resulting root mass will serve to build upon the base percent organic matter content of the new soils, thereby increasing the potential for long term survival and spread of the established grasses. Soil testing may occur on the new soils to better gauge the need or success of any applied organic soil amendments respective of the resulting vegetative cover. The addition of fertilizer may also aid in the establishment, growth and survival of the emerging grasses. Fertilizer may be applied to the seeded areas at rates determined from soil tests of the reapplied soils. To this end, soils may be sampled as needed. Sampling will utilize a hand auger and approved NRCS soil sample bags, and utilizing recommended procedures. Any soil testing will be conducted by the CSU Soil Laboratory in Ft. Collins, Colorado. The tests will be used to monitor soil quality and suitability of any amendments. Fertilizer may be withheld until after emergence to deter the encouragement of weed species. The use, composition and rates of fertilization will be determined prior to the time of seeding where appropriate, and may be reported in the OMLR Annual Reports, as appropriate. WEED MANAGEMENT PLAN: Mapping and Identification: Field identification and location of targeted weed species is fundamental to determining the extent and character of weed infestation; and in the subsequent development of a treatment plan. Due to the complex nature of identification, assistance with identification and mapping will be sought from among Weld County Weed and Pest Division; Colorado State University Cooperative Extension Service; U.S. Natural Resources and Conservation Service; as well as on-line and internal resources. Mapping will attempt to identify general areas of infestation within the permit boundary, and vectors of infestation from inside or outside the permit boundary. Vectors are a consideration in prevention of future infestation, which may affect on -site behaviors, including method and means of access within permitted lands. An expectation that vectors from adjacent lands must be treated by adjacent landowners if treatment on permitted lands is to be fruitful is part of continuing treatment considerations. Since the list of noxious weed continues to grow; and considering the development of new treatments; this management plan is intended to retain the flexibility needed to meet future conditions and capabilities in the arena of weed management and control. 2Weed management will be under the supervision of a certified weed management specialist. All applicable requirements currently in force at the time will be adhered to. The primary species to be identified, mapped (if found), and treated will include those species on the State of Colorado noxious weed list, as updated. List A species will be eradicated and List B Species will be controlled. Weed management efforts will also attend to current guidance from the Weld County Department of Public Works. 2 Adequacy Item 34/50 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 18 6.4.5 EXHIBIT I/J - Soils and Vegetation Information It should be noted that many weeds are sourced and vectored from adjacent lands and waterways. Weed management will suffer to diminishing effects that may beyond the capacities of the Operator to ameliorate if responsible weed management fails on those lands. Consideration of due diligence should apply respective of on -site efforts and limitations due to sources and vectors beyond the reach of the Operator. Treatment: Once the nature and extent of weeds have been mapped, and vectors identified; a course of treatment options will be considered in order of priority of economy and effectiveness. The overall o bject of weed management will be to control weeds by establishing a healthy competitive stand of vegetation that wins the competition for plant available water. This effort is linked to on -site soil management; including monitoring of soil fertility and percent organic matter on problem lands; relative to distribution and amount of field available moisture on affected areas. Physical weed control at the site will utilize non -chemical means, unless, due to weed morphology, o r other factors, circumstance require application of other methods or an approved herbicide. If chemical weed control is utilized, it will be conducted in compliance with manufacturer's recommendations and in conformance with applicable federal, state, or local laws. Chemical treatment of weeds will be the last option considered except where all other methods of competitive control fails; including mechanical cutting, tilling, or removal of noxious weeds. Where possible, pre -emergent weed control chemicals will be utilized. An exception to chemical weed control would be operator applied concentrated vinegar based organic weed control that does n ot harm soil or water. This is especially advantageous in application near water bodies. I n general, weeds will be mowed or mechanically removed before a seed head can develop. This will take priority over recently seeded areas expressing emergent grasses. Where mechanical means fail; chemical applications may follow according to recommendations from previously stated sources, and applied accordingly (see above) to prevent damage to grasses, aquatic species and wildlife. An example of Chemical treatment and primary noxious weeds can be found at the Colorado State University Extension Service website: http://www.ext.colostate.edu/. Still, predominant weed control efforts will focus upon prevention, principally through the establishment of a diverse stabilizing cover of grasses, as described earlier. Regardless of control methodology, the intent of mechanical and chemical methods will be to prevent weed species from reproducing vegetatively, or by seed in percentages that threaten the preferred species. I n general, the idea is to aid the grasses in out competing weed species for plant available water and n utrients in the new soils, until such a time that the grasses are fully established over the applied areas, are dominant over the weeds, and capable of self -regeneration. It should be understood that some weeds will remain. Total eradication of weeds is unlikely under the best circumstances, and is not a reasonable expectation or likely outcome. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 1 6.4.7 EXHIBIT G - Water Information (1) If the operation is not expected to directly affect surface or groundwater systems, a statement of that expectation shall be submitted. (2) If the operation is expected to directly affect surface or groundwater systems, the Operator/Applicant shall: (a) Locate on the map (in Exhibit C) tributary water courses, wells, springs, stock water ponds, reservoirs, and ditches on the affected land and on adjacent lands where such structures may be affected by the proposed mining operations; (b) Identify all known aquifers; and (c) Submit a brief statement or plan showing how water from de -watering operations or from runoff from disturbed areas, piled material and operating surfaces will be managed to protect against pollution of either surface or groundwater (and, where applicable, control pollution in a manner that is consistent with water quality discharge permits), both during and after the operation. (3) The Operator/Applicant shall provide an estimate of the project water requirements including flow rates and annual volumes for the development, mining and reclamation phases of the project. (4) The Operator/Applicant shall indicate the projected amount from each of the sources of water to supply the project water requirements for the mining operation and reclamation. (5) The Operator/Applicant shall affirmatively state that the Operator/Applicant has acquired (or has applied for) a National Pollutant Discharge Elimination System (NPDES) permit from the Water Quality Control Division at the Colorado Department of Health, if necessary. (1) Operations will not adversely affect surface and groundwater systems. 1 Measures described in the Two Rivers Application and particularly in this Exhibit G, and also in Exhibits D and E are intended to minimize disturbances to the prevailing hydrologic balance of the affected land and of the surrounding area and to the quantity or quality of water in surface and groundwater systems both during and after the mining operation and during reclamation The manner and method of extraction is detailed under Exhibit D — Extraction Plan. Anticipated effects on surface flows are anticipated to be minor to none. Essentially, the flood plain covers a majority of the property and unless under flood conditions, upland overland flows are generally diverted by levees, surrounding roads, or grassed drainage channels; or otherwise by draining internally into existing or planned basins. l Adequacy Item 43: Minimization of impacts. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 2 6.4.7 EXHIBIT G - Water Information a) 2Considerable efforts are made to control storm flows, including the use of grassed waterways. Some rilling will occur on cut slopes, but the sediment is inbound. A minor 6 -inch furrow above cut slopes will create a 1 -foot swale that could minimize such rilling, especially valuable on reclaimed slopes above the final estimated water level of the basins. The stormwater management plan referenced in Exhibit I & J will address broader water management covering the material processing area and any piles of soil or inert fill constructed external to the excavations. b) Impacts to groundwater and area wells from groundwater discharge during mining was evaluated by AWES, LLC in their 27 July 2020 report, as included in this submittal. The report concludes: The results of analytical and numerical solutions indicate that the proposed mine dewatering activities will not adversely affect the regional groundwater hydrology. Based on the location of registered water wells, the saturated aquifer thickness west of the mine is sufficient to provided adequate well yields. The predicted drawdown associated with the mine dewatering represents the worst -case scenario and a substantial amount of time will be required before maximum drawdowns will occur.' 3Additional groundwater evaluation is documented in an August 30, 2022 letter report addressing initial adequacy items and an August 31,2022 revised Dewatering Evaluation from AWES, LLC, both provided as addenda to Exhibit G. The estimated time to reach steady state drawdown due to the mining activity is summarized as follows: `Assuming a saturated thickness of 35 feet, a transmissivity of 4375 ft2/day, an effective porosity of 0.27 and a radius of influence of 4000 feet the time to reach steady state is calculated to be 273 days. However dewatering will be progressive during mining and an estimated 1000 days will be required to achieve this radius of influence during early dewatering operations.' c) 4POST RECLAMATION IMPACTS have been minimized: i. The AWES report of 27 July 2020 evidences that there will be no measurable impacts of either shadowing or mounding of the resulting lined basin. The operation therefore includes lining of the basin during reclamation of the resulting basin. Satisfaction of Colorado State Standards as to the integrity and functionality of the resulting lined basin Adequacy Item 43: Prevention of significant runoff -i Supplemental Groundwater Adequacy Item 13 Adequacy Item 28: Various edits in this section clarifying post mining land use as lined reservoir VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 3 6.4.7 EXHIBIT G - Water Information will be made in cooperation with the Colorado Division of Water Resources, and any resulting submittals and approvals made available to the OMLR at the time of the Annual Report, or by separate cover. No measurable impacts to the prevailing hydrologic balance are foreseen. ii. The Flow Technologies Report of 22 January 2020, provides a plan of modified basin design to be incorporated into this submittal as a means to minimize erosion of the basin berms while optimizing the integrity of the basin from the South Platte and Big Thompson Rivers during a 100 -year flood event. The DRMS in a supplemental adequacy response dated November 17, 2022 challenged the validity of the engineered design approach taken by Flow Technologies despite having accepted it as valid in the past. Raptor Materials believes the approach is valid and is in the process of performing an analysis by alternate methods incorporated in HEC-RAS. This, however, will take time. Raptor has per DRMS suggestion decided to adopt the 400 -foot setback from the top of the riverbanks to the top of the pit -side slope based on guidance developed using generic and non -site -specific empirical methods as adopted by the Mile High Flood District whose jurisdiction does not include the proposed operation. Raptor Materials intends after permit approval to present the results of the ongoing engineering evaluation as a Technical Revision to obtain relief from what we are confident are extreme setbacks. (2) (a) Please refer to Exhibit C-1: Existing Conditions Map. 5Wells are also shown on Exhibit G: Water Information Map and a table providing well details is included as an addendum to this Exhibit G. (b) The known aquifer under the site is the stream alluvium. (c) Discharge water will be dissipated with hard surface riprap or established grassed waterways. Other waters are retained by internal pit drainage, directed by vegetated berms or established waterways or through the maintenance or establishment of a stabilizing cover of vegetation, or as otherwise established under an approved Colorado Department of Health stormwater permit and/or stormwater discharge permit. 6Stockpiling of soil, overburden, or product above the existing ground elevation will not occur in a manner understood to obstruct flood waters where they might occur within the existing floodplain. It is understood and agreed here -in that their longitudinal dimensions if they occur there should extend parallel to anticipated flood flows where they exceed a cone or other shape that might find its existence contrary to intent by volume beyond that which could be understood to be temporary, or transitory; especially outside of seasonality where flooding might be more reasonably anticipated. Supplemental Groundwater Adequacy Item 4 6 Adequacy Item 45: Floodplain management, including conveyor crossing discussion VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 4 6.4.7 EXHIBIT G - Water Information As stated in Exhibit D, the conveyor will be set on an elevated structure at varying heights to be situated about the 1 in 100 -year flood level. An average height of 7 feet is expected. The conveyor will be supported by legs at intervals of approximately 20 feet with typically 6- x 2- x 2 -foot concrete blocks sitting on ground surface used as necessary to anchor the legs. The conveyor will span the river channel and metal (or other appropriate material) pans will be installed under the conveyor structure to prevent spillage into the river. The design will be similar to other Raptor locations where an extended span has been required to cross a county road. Final conveyor specifications are to be determined however belt width is anticipated in the range 24-36". 7I ncluded as an addendum is the Headwaters Corporation report (July 2019) for what is generally referred to as the Westervelt project which was a stream and floodplain restoration project downstream and adjacent to the Two Rivers project at the confluence of the South Platte and Big Thomson rivers. As described in Exhibit I -J, approximately 200,000± cu.yd. of material excavated in the execution of this project was stockpiled in a 28± acre area comprising most of the North- East section of the Central Field. The Headwaters report discusses the excavation and placement of this material and expected hydrological impacts. 8A groundwater monitoring plan has been prepared for the Two Rivers project and is attached as an addendum to this Exhibit G. (3) The three components of the project water requirements are water removed for dust control, water removed with the product, and evaporation from exposed ground water. Dust will be controlled using truck sprinklers, and the estimated frequency is one to ten loads per day depending upon field conditions. Dust will be controlled using truck sprinklers, and the estimated frequency varies daily according to seasonal influences of rain, snow, freezing, and temperatures (Refer to Seasonal Temperatures and Precipitation. At 3,000 gallons of truck capacity, the annual demand is 10.6 acre-feet. (Refer to following Chart (days of hot, freezing, rainy and snowy days derived from: https://www.bestplaces.net/weather/county/colorado/weld): Adequacy Item 45: Headwaters addendum explanation 8 Adequacy Item 46 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 5 6.4.7 EXHIBIT G - Water Information * including Sundays Holidays not & 3,000 gallons Truck per Dust Suppression Month Active Days* Hot reezing Rainy Snowy # Days # Trucks Total Trucks # gallons total gallons Total Acre Feet Days Days Days Days per day per month per Month per year January 25 0 31 4 39 18 1 18 54,000 0.16 February 23 0 27 4 34 16 1 16 48,000 0.15 March April 28 26 0 0 2L 1, 6 8 36 24 17 16 ...„.„2...„........_.34...„102,000._______________________.0:31 3 48 144,000 0.44 May 25 1 10 0 9 14 5 70 210,000 0.64 June 26 7 0 9 0 2 24 10 240 720,000 2.21 July 25 16 0 7 0 -9 25 10 250 750,000 2.3 August 27 12 0 8 0 -4 27 10 270 810,000 2.48 September 25 4 7 0 4 21 5 105 315,000 0.97 October November 25 23 0 0 5 5 19 34 19 15 3 2 57 30 171,000 90,000 0.52 0.28 December 25 0 4 38 18 1 18 54,000 0.16 303 40 77 226 230 1156 Annually 3,468,000 10.6 Acre Feet 1040 Trucks .Apr.- Oct = 3,120,000 90% or 9.6 Acre Feet After the water table is encountered, the water removed with the estimated 1,200,000 tons of product is 35.32 acre-feet per year. The estimated net evaporation is 2.64 feet per year. At the maximum potentially exposed ground water of 217.44± acres, the annual evaporation is 574.25± acre-feet. The monthly distribution of these estimates is shown in the following table. The reclamation plan provides that the pits will9 be lined after being mined. The lined pits will not require replacement water and will be used for storage. There may be incidental demand for water to establish vegetation on the site after lining is completed. However, the ultimate demand for water will be zero. Continued... next page... 9 Adequacy Item 28 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 6 6.4.7 EXHIBIT G - Water Information MONTH GAL. PRODUCT WATER (9.59 TON /TON) DUST CONTROL I i NET EVAPOATION of of t ac X %ev of Tons Trucks November 60,000 1.77 30 f 0.28 187.66 0.10 4 19.52 December 54,000 0.16 0 187.66 0.00 1.59 18 0.00 0 January 54,000 1.59 18 0.16 187.66 0.00 0 0.00 February 93,000 2.73 16 0.15 t " 187.66 0.11 3 21.21 March - 127,500 138,000 3.75 4.06 34 48 0.31 0.44 ' I- ' 187.66 187.66 0.13 8 - -- - - 25.90 - - April 0.22 1 41.47 May 139,500 4.11 70 0.64 I ' 187.66 0.28 8 54.05 June 135,000 3.97 240 2.21' 187.66 0.41 3 77.50 July 127,500 3.75 250 2.30 ' 187.66 0.45 3 85.01 August 118,500 3.49 270 2.48 ; 187.66 0.41 8 78.44 Septembe r 93,000 2.73 105 0.97 ' 187.66 0.29 4 55.17 October 60,000 1.77 57 0.52 ' 187.66 0.19 9 37.34 Apr -Oct 811,500 23.8 8 9.56 } 428.9 9 1040 TOTAL1156 1,200,00 0 35.3 2 10.62 i 495.6 1 (4) Water available for supply are from Six sources: Beeline, Big Thompson, South Platte Ditch, Hayseed Ditch as decreed in Case No. 90CW174, four shares of the Rural Ditch Company as decreed in Case No. 03CW306, five shares of Last Chance Ditch Company, 25.0 shares of Godding Ditch Company, and water decreed in Case No. 01CW274. From April through October, water use at the site will be replaced to the stream system using the historical consumptive use credits from any of the sources and/or from storage. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 7 6.4.7 EXHIBIT G - Water Information Because storage is available to regulate the supplies, only the annual historical consumptive use for the sources is shown in the following table. Source Annual Consumptive Use, a -f Beeline 87 Big Thompson & South Platte 274 123 Hayseed Rural 434 Last Chance 1,191 Godding 384 2,493 Total = The storage sites are lined pits described in Case No. 01CW274 decree. Water available under these storage decrees will also be stored and used for VCI operations. The storage facilities are listed in the following table. Those currently lined and approved by the state are 112, Von Ohlen, and Dakolios. VCI STORAGE FACILITIES (All Values in Acre -Feet) Reservoir Active Capacity, a -f Dead Storage, a -f 112 1,552 0 Dakolios 1,104 0 Von Ohlen 1,300 0 Kurtz 4,000 0 YEAR NOT 7,500 3,000 EXCEED A -F refill PER of a -f 0 TO plus Total (5) 10A Colorado Wastewater Discharge Permit System Permit has been applied for with the Colorado Department of Health, and an approved permit issued September 27, 2022. The application and permit are provided as an addendum to this Exhibit. Dewatering activities are discussed in Exhibit D. 1 ° Adequacy Item 44 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 8 6.4.7 EXHIBIT G - Water Information (6) The application provides for the lining of the extracted basins (please refer to the AWES Dewatering Evaluation Report of 27 July 2020. Lining will involve the utilization of suitably derived on -site materials to meet final 3H:11/ slopes. Subsequently, the same materials may be compacted to satisfy standards for lined basins as established and governed by the Colorado Department of Water Resources Office of the State Engineer. Once operations near completion of any lined basin, the OSE will be contacted and the lined basins will be approved by the OSE prior to use. The OSE approval letter will be provided to the OMLR as a condition of the permit as evidence that the lined basin has met the specifications necessary to pass a liner test as part of the OSE approval process. Consistent with conclusion in the AWES Report, lining of the completed basins will have 'will have a de -m inim is effect on groundwater hydrology.' The report continues, adding that, `Predicted post lining head levels immediately up and downgradient of the barrier walls are within the range of normal seasonal water table elevation changes.' NOTE: Information showing baseline piezometer well readings and respective locations immediately follow this page. 11 The table has been updated from the original application with data extended through June 2022, and the well names conformed to those on Exhibit C-1: Existing Conditions Map and Exhibit G: Water Information Map. 1' Adequacy — Dewatering Review Item 3 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page Ii 6.4.5 EXHIBIT E - Reclamation Plan (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. Operators/Applicants are encouraged to allow flexibility in their plans by committing themselves to ranges of numbers (e.g., 6"-12" of topsoil) rather than specific figures. (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: (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 e ar thmoving; (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; (c) A description of how the Reclamation Plan will be implemented to meet each applicable requirement of Rule 3.1; (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; (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(1)(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; VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 2 6.4.5 EXHIBIT E - Reclamation Plan (ii) A description of the size and location of each area to be reclaimed during each phase; and (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.) (f) A description of each of the following: (i) Final grading - specify maximum anticipated slope gradient or expected ranges thereof; (ii) Seeding - specify types, mixtures, quantities, and expected time(s) of seeding and planting; (iii) Fertilization - if applicable, specify types, mixtures, quantities and time of application; (iv) Revegetation - specify types of trees, shrubs, etc., quantities, size and location; and (v) Topsoiling - specify anticipated minimum depth or range of depths for those areas where topsoil will be replaced. Acknowledged. Rule 6.4.5(1) is an advisory statement, the particulars of which are provided for, below. MISSION STATEMENT: Utilizing Resource Recovery of Sand and Gravel as a Method of Conservation to Establish DEVELOPED WATER RESOURCES; and to function as a Foundation for the implementation of other beneficial Multiple End -Uses over the Property. Reclamation and Development of the Property over Time. The majority of sand, gravel and other earth product demand, like water, is the consequence of market forces resulting from urbanization. The commercial, industrial, transportation, and other land use matrixes arise to support and sustain a growing residential population. Governments count the roof tops for they rely upon public and commercial revenue to sustain the roads, schools, water supply and infrastructure needed to secure it. With continued growth of human habitat and development in Colorado, the products that make possible the construction and maintenance of it all, comes from the ground. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 13 6.4.5 EXHIBIT E - Reclamation Plan Unconsolidated aggregate deposits simply must be taken where they are formed. The aggregate resource must be recovered from undeveloped locations first, before those locations are overtaken by ever expanding urban development; or it is lost. Now is the time and this is the geologically determined and economically feasible location from which the proposed extraction activity must occur. Hence, the Two Rivers Sand Gravel and Reservoir Project. Underlying earth resources are too often squandered when human development occurs in advance of resource extraction and recovery. Extraction and resource recovery are required by Colorado law to occur in advance of development where sand and gravel deposits are present. The resource is 'recovered' to benefit inevitable and unrelenting human habitat and infrastructure expansion, while providing a more enduring indigenous buffer to the very impacts it serves. The extraction of aggregate resource is in fact resource conservation. Beyond that, it is an essential social asset. Without earth products, transportation maintenance costs increase as infrastructure begins to fall apart. Industries begin to shrink, along with correlated revenues for state and local governments. Impacts would likely spread downstream from there, degrading schools and everything else dependent upon government revenue, as taxes increase to make up the difference. Affected populations would likely begins to flee an ever-increasing tax burden, further depreciating home values while accelerating loss of revenues from ever diminished home valuations, loss of businesses, jobs, and ultimately the very infrastructure itself. Without earth products, the economic engine and quality of life for everyone, begins to unravel. The secondary and enduring benefit of mineral extraction is in the reclamation and restoration of extracted lands. Extraction of aggregate resources is comparatively temporary and transitional by its very nature. 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. While residential, commercial, and industrial development will eventually be inspired by economic forces over portions of the Two Rivers property; the primary end use will be the creation of essential Developed Water Resources. An understanding of the vital importance of aggregate resources to the people of Colorado is not new, but well established; and protected. It remains the stated duty of any governing body in Colorado to aid in the lawful recovery of these vital mineral resources under Title 34. Section 22-5-80 of Weld County's Code of Regulations is consistent with Colorado law, both of which require that this resource must be recovered prior to other development which would otherwise impede access to it. Municipalities are obligated for the sake of their citizens to assert the same. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 4 6.4.5 EXHIBIT E - Reclamation Plan The subsequent development of a diverse multiple land use potential at this location, when complemented with sound environmental parameters, as advanced under this application and the attending OMLR permit exhibits, is in keeping with the spirit and intent of the policies and goals of the State of Colorado, Weld County, and the Towns of Evans and Milliken. Approval of the application will allow the resource to be accessed and utilized in a responsible and orderly manner as required under both Colorado law, and consistent with local County and Municipal Regulations. Specific Reclamation Elements and Methods: This application provides substantial detail of features utilizing aerial photography that is ortho-rectified to approximately 1.0± percent of surveyed accuracy. This highly accurate and detailed portrayal of planned extraction and reclamation is visible under Exhibit C-1: Existing Conditions, Exhibit C-2: Extraction Plan Map, and Exhibit F - Reclamation Map. How reclamation will occur over affected lands is further detailed under Exhibit L - Reclamation Costs. As extraction progresses over the Fields south of the Big Thompson River, the resulting 1.25H:1V slopes (2H:1V, where indicated) created during extraction will be concurrently modified when and where practical. Concurrent reclamation is a natural incentive for Operations to speed site recovery while generally serving to lower attending financial warranty burdens. The cut slopes along the extraction limits perimeter will be finished graded by pushing the resulting pit bottom with a dozer until the resulting basin slopes conform with Rule 3.1.5(7). Since the primary end use is Developed Water Resources, the basins are intended to hold waters based upon the rights assigned by decree, or as stipulated in regulatory compliance with the Colorado Division of Water Resources, Office of the State Engineer (OSE). This may include the need to augment water sufficient to cover the anticipated exposed groundwaters of the basins in the unlined state. The entire unlined basin is or will be sufficiently covered under an approved substitute supply plan. In order to again liberate waters set aside for augmentation, the basins will at some point in the life of the activity be lined to segregate the basin from Colorado groundwaters. Lining of basins involves the placement of low permeability compactable 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 it meets the standards established under the August 1999 State 1 Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 15 6.4.5 EXHIBIT E - Reclamation Plan 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 OMLR on receipt; or as part of any request for release of the permit, in part or whole. Essentially, the pushed parent rock material will form the minimum 3h:ly slopes of the basin and be compacted to a permeability of 10-6; forming a lined basin that complies with Colorado Water Law and Guidelines mentioned, above. In this manner, the lined basins will maintain a required separation and accounting of stored water from the underlying ground waters. Evidence of compliance with the rules and regulations of the Colorado Division of Water Resources will be provided to the OMLR on completion of the lined basins. 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 claystone, 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. The liner will be progressively constructed once the pit is developed sufficiently 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. 2A Backfill Notice is included with this application as an Addendum at the back of Exhibit E - Reclamation Plan, to facilitate the fill of portions of the extracted lands for final end -use potentials beyond water storage, which may include residential, commercial or industrial structures or uses otherwise approved, now or in the future, by Weld County, Colorado; or a Colorado municipality, as applicable. The extent and nature of the water storage basin represents the maximum build -out respective of optimal extraction of commercial product and resulting final slopes. As part of reclamation, lands situated above the anticipated final water level of the completed basins, and within 10.0± feet below the anticipated final water level of the basins, will be graded to 3H:1V, or flatter. Lands below 10.0± feet from the anticipated final water level of the basins will also be graded to 3H:1V, or flatter, unless 2H:1V slopes are otherwise approved by subsequent permit revision. Naturally occurring or previously established slopes may exceed 2H:1V where not otherwise affected by extraction activities and may not be altered as 2 Adequacy Item 28: Paragraph removed as proposed post mining land use is lined water storage. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.5 EXHIBIT E - Reclamation Plan part of reclamation unless necessary to facilitate the reclamation of affected lands. All affected lands between the extraction limits and remaining above the anticipated high-water mark of the basins will be capped with a minimum of six (6.0±) inches of soil, as supported by Exhibit I & J - Soils and Vegetation Information. Timing and use of soil are detailed further under Exhibit I & J - Soils and Vegetation Information and Exhibit L - Reclamation Costs. Where compacted lands exist, and are to be revegetated, those locations will be ripped prior to re - soil application. There are no known areas of compaction at the time of this application which would require such activity; and ripping remains a contingency of the application. The final land configuration will ultimately result in two (2) reservoir basins totaling 203.61± surface acres, with a static water elevation surface area of 187.66± acres (refer to Exhibit F: Reclamation Map). The balance of unoccupied affected lands above the anticipated static water level will be stabilized where necessary utilizing the seed mixture as shown under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. Lands not otherwise occupied for developed water resources will be later developed to the highest possible end -use, and will likely comprise a mixed use which may include other general agricultural uses as well as light residential, commercial or industrial uses. The Primary Revegetation 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. Should post resource recovery land development be deferred, or even negated, all affected land remaining above the anticipated final water level of the resulting ponds will be stabilized with a diverse and durable cover of predominantly native grasses. This is compatible with, and an improvement over the diminished lands located in the floodplain of the two rivers, and area monocultures of residential bluegrass lawns and surrounding cropped land. Generally, warm and cool seed mixtures can be treated in a myriad of ways. In Table L-1 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. Combined with the creation of waterfowl habitat, the baseline reclamation plan provided for under this submittal will provide less fragmentation of the 3 Adequacy Item 33 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 7 6.4.5 EXHIBIT E - Reclamation Plan area ecology than what may otherwise exist or transpire. As such, the operation will result in immediate and enduring positive impacts to area habitat as a long-term beneficial buffer against continued developmental impacts to the river ecosystem. Consistent with previous discussions with conservationists from the Division of Wildlife; operations will result in a desirable establishment of irregularities for the finished reservoirs. For example: The basin irregularities will be provided for, both by direct concurrent grading, post mine landform grading and establishment, and use of fill from excess or residual materials and reject fines from the operations. Shallower locations due to variations in site geology may allow for the creation of other shoreline features through the placement of fill. Due to the unpredictable nature of the anticipated geology [actual depth of material and type will vary - extraction and pond depths are approximated typical maximum extent] and other factors, it is a near misrepresentation to forecast the final appearance of the ponds, as it creates an unrealistic expectation in a regulated environment on the minds of various regulating agents, the general public, and on Operations. Simultaneously, setting false expectations about the final appearance of the ponds, beyond that already portrayed, will drain flexibility from Operations essential to the creation of more desirable effects, while simultaneously exerting pressure for needless and on- going revisions to the permit. It should be remembered that the Annual Report to the OMLR will provide a graphic record of this effort. Since the pace occurs over many years, there is ample time for reflection and analysis of the effort. Time and timing will also come into play respective of materials to be used as fill. The utilization of fill is dependent upon the space available for deposition over completed areas of extraction in relation to the rate of creation of reject fines and or other deposit materials. Other influences will be the attending space for stockpiling, uses, or market conditions for fill material. Some locations will be more advantageous to fill at a given point in time than others, and the attending circumstances cannot be reasonably anticipated. The random nature of this limitation will actually aid in furthering the establishment of preferred non -geometric patterns of the finished ponds. Exhibit F - Reclamation Plan Map, represents the regulated base for which reclamation must be judged as adequate for release. At the very least, the basins delineated under Exhibit F - Reclamation Plan Map, provide desirable shoreline irregularity and slopes in conformance with existing statutory requirements. Anything more is a bonus, for everyone, and every opportunity will be made to take advantage of it, as stated above. Since the creation of aesthetic effects, edge effect, and other natural landforms, VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 18 6.4.5 EXHIBIT E - Reclamation Plan remain subjective and empirical, the stated intentions and any resulting efforts to achieve such effects, beyond those identified in the approved seed mixture and as portrayed in Exhibit F - Reclamation Plan Map, is commendable, and to be encouraged. Placement of soil and initial stabilization of affected lands with a stabilizing cover of grasses will better assure a foundation for later vertical development and establishment of cover; whether resulting from natural invasion or direct planning of trees, shrubs, and forbs. By themselves, the grasses will provide a stable foundation for later enhancements, while visibly improving wildlife habitat by interrupting area monocultures. While end use development beyond that already described cannot be fully determined or detailed at this time, the trend toward continued residential, commercial and industrial development is self- evident on surrounding lands. Although the establishment of native grasses is a primal requirement under this permit, the incorporation of forbs, shrubs and trees remains at the discretion of the landowner. Markets and the inherent values of the landowner to enhance the multiple end use worth of the property will serve to encourage the vertical development and diversity of the area vegetation with the contribution of forbs, shrubs, and trees. The purpose is to add cover, food source for wildlife and pollinators, and stratified creatures that will come to inhabit and depend upon the natural configuration, character and extent of the finished landform and diverse stabilizing cover. It should also be kept in mind that extraction is occurring within an area formerly occupied by monocultural crops, The cottonwoods along the lower terrace of the two rivers will be preserved in the majority. A light culling of a few cottonwoods may occur to assure the integrity of the intended conveyor line and wash basin; or as needed to assure the protection of personnel. The riverine areas will otherwise remain untouched, further complementing the utility of the reclaimed and restored expanse. Whatever long-term development occurs at the location, and on surrounding lands, resource recovery and correlated reclamation at this location will tend to direct human densities away from the two rivers. The reduced densities will produce direct and indirect long-term wildlife benefits and diverse multiple end -use potentials involving inherent wetland development, water resources development, water fowl improvement, and other desirable effects. The long-term worth of this effect will serve to increase the other long-term values for everyone in the area communities formed by the towns of Evans and Milliken; and greater Weld County. The final acreage of land remaining for development relative to surface acres of resulting ponds is illustrated on the following Exhibit F - Reclamation Plan Map. The map details the post resource recovery land form establishment. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 19 6.4.5 EXHIBIT E - Reclamation Plan The size of the resulting basins is a function of area geology and available resource relative to man-made obstructions that serve to prohibit a greater linkage. 'Exhibit F presents Raptor Material's current expectation of the remaining above -ground and underground structures within the Affected Area at the point the reclamation of mining related disturbance is complete. Any revisions, additions, or modifications to this forecast of what may be the outcome of mining and reclamation operations some 30-35± years from now will be updated on required Annual Reports, or by Technical Revision, as warranted, or as otherwise directed consistent with Colorado Statute. The estimated timetable for extraction, commencing approximately spring to winter 2023; is estimated to take 23-28± years combined, or longer, followed by an additional five years to complete reclamation; or a total estimated life of the mine of 28-33± years; ending approximately winter 2051 to 2056. This is a life of the mine operation and all timetables are estimates and may prove shorter or longer than stated. The final determination will occur five years after the deposit is exhausted and all marketable product has been removed and necessary infill completed at the location to the point of final reclamation as approved or modified under the terms of the permit is completed. Table E-1 provides a projection of mine development and regrading/reclamation. The plan as described in Exhibit D and above in this Exhibit E, is a forecast and may vary according to market conditions with mining and subsequent regrading occurring faster or slower, sometimes significantly so. The geology may also dictate changes in the rate of extraction. If efficiency demands in a higher production demand scenario, separate areas could be developed in the manner described in Exhibit D simultaneously. Such changes may happen quickly and would be addressed in the Annual Report. Miscellaneous considerations: Fertilizer may be utilized as part of revegetation efforts. The need for fertilization and any subsequent fertilizer rates will be determined based upon soil tests taken at the time of reapplication of salvaged soil to affected lands remaining above water level. Status of fertilization and soil test results can be included in OMLR Annual Reports, as warranted. Refer to Exhibit I - Soils Information. Weed Control may involve a mix of mechanical or benign vinegar -based sprays as control methods. A detailed plan to control weeds is described 4 Adequacy Item 41 5 Adequacy Item 29 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 10 6.4.5 EXHIBIT E - Reclamation Plan in Exhibit I/J. Treatment and control of noxious or nuisance weeds will be reported in OMLR Annual Reports as warranted. A Backfill Notice follows this page. The flexible use of inert fill will facilitate the timely reclamation of affected lands. Continued...next page... VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 11 6.4.5 EXHIBIT E - Reclamation Plan 'Table E-1 - Two Rivers Mining -Regrading Schedule Mining -Regrading Schedule Years Schedule Central Field Center Section North-East Section West Section 1-5 6-10 Area (ac) Area Mined (ac ±) North West Field 121.9 15.6 25.1 41.0 11-15 16-20 21-25 40.0 40.0 30.0 11.9 10.0 5.6 Total 203.6 20.0 2.5 26-30 31-35 5.1 34.9 3.6 40.0 40.0 40.0 Central Field North West Field Total Length (ft) 14,311 6,672 20,983 Pit wall Created (ft ±) 6,200 2,800 6,200 2,800 Central Field North West Field Total Length (ft) 14,311 6,672 20,983 40.0 40.0 2,800 2,800 2,511 1,000 3,511 5,672 5,672 Pit wall Regraded (ft ±) 3,200 3,200 0 3,200 3,600 3.6 0.0 0 0 4,311 489 5,400 3,200 3,600 4,800 Central Field North West Field Length (ft) 14,311 6,672 Pit wall Remaining (ft ±) 6,200 5,800 5,400 0 0 4,311 0 0 1,000 6,183 5,400 783 783 0 783 0 0 Total 20,983 6,200 5,800 5,400 5,311 6,183 783 0 6 Adequacy Item 29 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 112 6.4.5 EXHIBIT E - Reclamation Plan BACKFILL 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 inert materials used for backfilling will be consistent with OMLR 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 OMLR 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 Office of Mined Land Reclamation 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 allowed under this application or locally approved land uses. The location and extent of fill utilized over extracted lands will be designated in required OMLR Annual Reports, permit revision, or as part of any request for release of the permitted area, in part or whole. I, Garrett C. Varra, hereby attest that the material to be utilized as inert fill in the area described as the Two Rivers Sand, Gravel and Reservoir Project; is clean and inert as defined in Rule 1.1(20), of the OMLR Rules and Regulations. Garrett C. Varra, General Manager Raptor Materials LLC VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I1 6.4.4 EXHIBIT D — Extraction Plan The mining plan shall supply the following information, correlated with the affected lands, map(s) and timetables: (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; (b)earthmoving; (c)all water diversions and impoundments; and (d)the size of area(s) to be worked at any one time. (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 operation. 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 operation 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: (i)an estimate of the periods of time which will be required for the various stages or phases of the operation; (ii)a description of the size and location of each area to be worked during each phase; and (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.) (f)A map (in Exhibit C - Pre -Mining and Mining Plan Maps(s) of Affected Lands, Rule 6.4.3) 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. (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. (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. (j) 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 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 2 6.4.4 EXHIBIT D — Extraction Plan 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. Prologue: Extraction of natural resources for rock products is essential to the well-being of a community. The urban infrastructure served by development of construction materials is a local and transitional benefit. The more remote these resources are from the need, the greater the cost to the private and public community. Unlike fixed urban impacts to the landform and area ecosystems, reclamation and restoration of extracted lands allow for preservation of natural buffers, and complementary alteration of both natural and human systems. Commencing on the family farm in 1948, the Varra family combines nearly 73± years of operational experience that serves as testimony to a history of sound and thoughtfully executed operations of this kind. For the Two Rivers Sand Gravel and Reservoir Project, lands not otherwise occupied for Developed Water Resources will be improved to the highest possible end -use. Post Extraction Uses beyond the Primary Use of Developed Water Resources will likely comprise continuing and diverse general agricultural uses; as well as possible light residential, commercial, or industrial uses; as determined by right, or as otherwise authorized by the governing authority. The restoration of above ground lands to native grasses and attending large water bodies are a baseline asset to area wildlife terrestrials and avifauna. Beyond good will, there are continuing landowner philosophical and economic enticements to further benefit area wildlife populations and diversity to further the value and enjoyment of the modified and surrounding lands. These efforts laid down over time involve the considerable experience of the landowner, staff, and other resources, including periodic consultation with the Colorado Division of Wildlife, the U.S. Natural Resources and Conservation Service, Colorado State University Natural Resource Departments and Extension Service, and a multitude of other natural resource professionals; including those highly qualified organizations and professionals who have already contributed to the Exhibits included under this application. Setting: The project area lies along and within the flood plain of the South Platte and Big Thompson Rivers. The predominant location of extraction is proximal to the geological delta found near the existing confluence of the two rivers (hence, the Two Rivers Sand Gravel and Reservoir Project (Two Rivers VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 3 6.4.4 EXHIBIT D - Extraction Plan Project; or TRP); and overlies bedrock that varies in depths as shallow as 20+ feet in some locations, and more commonly 30-45+ feet in depth from the surface. The permit area is flanked on its immediate western boundary by agricultural operations. To the north, residential uses expand, as remnant agriculture clings to the rising ground. Unfettered agricultural and rangeland uses still thrive as they extend beyond the permit boundary east, west, and south of the permit boundary along the alluvial influences of the two rivers. To the immediate east of the TRP, riverine lands are under active transformation into a created wetland bank. It should be understood that agricultural practices will remain active over the project area until converted by resource recovery and reclamation. America's first Transcontinental Railroad was being discussed in the 1840's, and surveyed in the 1850's. The railroads began the transformation of the American West on 10 May 1869 at Promontory Point, Utah. Railroad routes were being planned for this location and surrounding lands likely soon after the end of America's Civil War. The lines planned over the Two Rivers parcels were never built. Other lines were built nearby, like the Union Pacific's Dent line, that runs parallel to this day along the south bank of the South Platte River; and below the TRP. With area railroads came increased settlement, and with population the nature of the landscape became modified to complement growing market economies of agriculture and commerce since the early 1870's. We estimate the lands hugging the two rivers were farmed and the topography gradually manipulated for agriculture following the early establishment of Greeley and LaSalle, Colorado; in 1869-70. Area crops are commonly in corn, but this has not always been the case. We postulate that near the onset of the Twentieth Century sugar beet farming began to feed the demand of area sugar beet mills, further evidenced by speculative railroad routes over and near the parcel, itself. So, the appearance of the land that we see today, is commonly different than what it appeared at the time of settlement. In order to improve the area and extent of tillable lands, even early agricultural practices included landform modification to aid the plow. Prior floodplain modification is evidenced today by the historical placement of utilitarian levees flanking the existing agricultural fields along the outer cottonwood tree lined escarpments of each river. The levees are maintained to this day, and form perimeter access to the rivers and tillable fields. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 14 6.4.4 EXHIBIT D - Extraction Plan The later creation of farm to market County Road 396 eased access to the areas' agricultural fields, yet consequentially separates the fields at the TRP with its graveled surface, and subsequent rights -of -way and easements. The levees, public roads, cottonwood corridors and area tributaries are visible in the different map exhibit aerial images, and will not be impacted by planned extraction. All planned operations have conforming setbacks, and levee access will remain limited to wheeled vehicles during operations. Today, the upper terrace where extraction operations are planned, supports agricultural crops above the lower stream terrace formed further below and beyond the perimeter levees and cottonwood corridors that frame the adjacent active stream channels. The Fields designated for resource recovery (Central Field and North-West Field; as shown on Exhibit C - 2: Extraction Plan Map) lie over a nearly level upper terrace of the two rivers. The South Platte River borders the southern and eastern extent of planned extraction, and the Big Thompson River intersects the permit area north of the Fields. The stream terrace itself is a riparian area that supports on its flanking escarpment an uneven aged stand of Cottonwood trees. The uneven aged trees suggest this segment of the river has experienced some scouring in the past from periodic, yet commonly limited, flooding; which encourages natural regeneration of Cottonwoods. To determine the influence of past activities on groundwater, twelve (12) Piezometer Wells were located along and within the entire TRP boundary. Groundwater level information here, is based on 5.75 years of continuous monthly measurements at twelve (12) piezometer locations identified on the included Exhibit G: Water Information Map. Recorded groundwater depths vary in elevation below the surface, with a general (weighted) mean depth of 8.40± feet. Groundwater elevations are influenced by crop irrigation practices that run generally from April through September, and may occasionally lag into the middle of October. During this time groundwater depths may be skewed higher in elevation to the extreme North-eastern extents of Central Field, yet with few exceptions, groundwater elevations over the entire site remain significantly deeper than 5.11+ feet from the surface, year over year, over the entire TRP area. Using the approximate surface elevation at the extreme eastern boundaries of North-West Field and Central Field, and noting that groundwater fluctuations will commonly meet at 8.40± feet below the surface, yet rarely rise more than 5.11± feet from the surface, we determined the Static Water Level using the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page IS 6.4.4 EXHIBIT D - Extraction Plan upper limit of 5.0± feet. The Cyan colored contour shown on Exhibit G: Water Information Map represents the Static Groundwater Elevation at 4675' at North-West Field, and 4673' at Central Field. Since completed reservoirs will be lined to meet State of Colorado Water Resources specifications and requirements, and since lined basins will ultimately equalize with the surrounding groundwater elevations, the Static Water Levels shown should reasonably reflect those of the both the lined or unlined state; and represent a proper reflection of the optimal surface area of the water over the finished basins. Raptor Materials, LLC has sufficient water to meet the circumstances and obligations of both the lined and unlined states; and as reflected under Exhibit G: Water Resources Information; until and unless the reservoirs have an approved liner, the Operator will dedicate sufficient waters to secure the reclamation of the resulting basins in the unlined state. Planned Field Activities: The 409.23± acre parcel boundary forms the permit boundary, as reflected on exhibit maps. All lands under its direct control within the 409.23± acre permit area, are affected lands under C.R.S. 34-32.5- 103(1), respective of this permit application. As a result, any changes required in the nature of planned extraction or reclamation will be made only through the Colorado Office of Mined Land Reclamation (OMLR), by Technical Revision only. If lands are needed beyond the designated permit boundary, those lands will be secured for the active OMLR permit by Amendment. Within the permit boundary, there are two* (2) identifiable areas designated for primary extraction, the description of which will help to explain the nature of planned extraction and reclamation. The Primary Areas of Extraction are as follows: 162.57± Acres 41.04± Acres 203.61± Acres 205.62± Acres 409.23± TOTAL Primary Extraction (***) Central Field: 15-25± years (2023- '48) ** Primary Extraction North-West Field: 4-8± years (2045- '53) ** Total Primary Extraction * Affected Lands beyond planned extraction limits (*) NOTE: The third area of secondary extraction is limited to approx. 5.60± Acres for a Plant Processing/Stockpile Area Pond, as further indicated, below; and is not included in this total. (**) NOTE: Final reclamation will add up to five (5.0±) years to the anticipated Life of the Mine, subsequent to completion of extraction and removal of all marketable materials. Life of Extraction is an approximation, and could lengthen or shorten the overall life of the mine depending upon market conditions. (***) NOTE: Of the 162.57± Acres of Primary Extraction, 4.09± Acres comprise an existing Farm Yard & Structures with residence. These facilities may be leased or VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.4 EXHIBIT D — Extraction Plan otherwise utilized as an Office and Support/Storage facilities for Operations, potable water and sanitation. Lands identified within a designated Extraction Limit may not be extracted, including the Farm Yard area, as circumstances warrant according to the discretion of the Operator. Of the outlying 205.62± Acres: 15.76± Acres = Plant Processing/Stockpile Area 5.60± Acres = Secondary Extraction - Plant Processing/Stockpile Area Wash Pond 21.35± TOTAL The remaining 184.2 7± acres of lands within the permitted limits may comprise planned or existing permanent access roads, levees, previously affected areas, and areas of minor to no disturbance (including public transportation corridors, right-of-way's, easements, permanent structures, river and stream terrace and cottonwood corridor buffer areas), or other farm land features or structures; or as otherwise determined from included maps and aerials. These lands may also include essential support operations, including: parked vehicles, equipment, plant site equipment and processing stockpiles, etc., not otherwise explicitly indicated or shown, but reasonably associated with operations of like kind, and may be varied in location and extent over time; or otherwise, field fit within the permit boundary as warranted. Wetland conditions appear confined within portions of the stream terrace and bank -full stage of the rivers, and along segments internal to the Evans Canal. Extraction will form a depression (basin) within the floodplain as shown in Exhibit C-2: Extraction Plan Map. Temporary above ground fill may occur within the floodplain, and as part of this permitted activity, provided the above ground volume does not exceed the below ground volume created by extraction. All product stockpiles and processing will occur within the city limits of Evans under this application, and North and outside of the floodplain boundary of the 100 -year floodplain of the Big Thompson River. The floodplain extent will be visually marked in the field to better assure the integrity of the floodplain. Material transport of raw materials from extraction locations to the plant site will occur via conveyor (see route on Exhibit C-2: Extraction Plan Map). This will in turn serve to minimize impacts to area transportation corridors. The actual location, extent, and nature of the conveyor systems not otherwise designated in this submittal will be provided as updates in the required OMLR Annual Reports. 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. Exhibit S: Stability Analysis - provides VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 17 6.4.4 EXHIBIT D - Extraction Plan certification from a registered professional engineer that these structures will not be harmed by planned extraction profiles and extents. 'For lands within the Extraction Limits, only those structures, easements, and rights -of -way shown in Exhibit C-2: Extraction Plan Map, are anticipated to remain from those shown in Exhibit C-1: Existing Conditions Map. If changes to existing or possible revised structures, easements, or right-of-way are in any manner retained, or where they might occur subsequent to OMLR approval of this application, then a Technical Revision will be submitted to update Exhibit C-2: Extraction Plan Map. All established setback distances from planned activities to any remaining features will be maintained regardless. Operations or related Processing Areas and Wash Pond are not intended to affect existing structures, Easements, or Right -of -Ways within the Planned Extraction Limits identified as remaining and are designed to avoid and retain any remaining structure, Easement or Right -of -Way on the surface, and subsurface. Future agreements may be reached allowing mining in areas currently identified as being restricted to mining containing certain structures, Easements or Right -of -Ways. Exhibit C-1 shows and identifies all these features understood by us, and the respective Surveyed information, and correlated Observation and Title Work upon which they are based and represented on the attending Maps. The Maps are not Surveys. They are Maps and as such, they comprise a reasonable representation of all site features, but must not be relied upon by themselves exclusively for location purposes. Maps and features are not a substitute for field identification of underground structures and will rely upon location services of the 811 service. Setbacks where required will be based on the actual field locations of site features. Exhibit C-2 shows the remaining Oil Wells and Lines within Planned Operations at the time of the Submittal. Any revisions, additions, or modifications of residual Oil Wells or Lines will be avoided as represented on updated Maps and Revisions to the Permit, and consistent with Setback Distances identified in this submittal. Removal of any Existing Structures such as the Oil and Gas structures and or lines, will be updated on required Annual Reports, or by Technical Revision, as warranted, or as otherwise directed consistent with Colorado Statute. Access to the Theater of Operations: Entry into the permitted areas is dependent upon the needs and necessary management of continued agricultural activities during operations, as well as essential management and 1 Adequacy Item 18 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 8 6.4.4 EXHIBIT D - Extraction Plan mobility within the active areas of extraction, processing; and correlated need for transportation of human resources, equipment, and product. Human resources for operations, heavy equipment, and haul traffic will occur based upon the desired and dynamic activities necessitated by time and circumstance within the designated Fields. Access points for continued agricultural, extraction, and plant site operations are shown :; on Exhibit C-2: Extraction Plan Map, as follows (NOTE: Access purpose and usage may change in time from that indicated here -in. Also, General Existing Dimensions and length of existing access roads are represented in the aerial images on the Exhibit Maps relative to the Access locations detailed, below. Modifications may occur as needed and will be reported in OMLR Annual Reports.): * Entrance 1: Farmstead entrance. Limited Access. Note: Visitors will first access operations by checking in at an established plant scale -house, not here. Entrance 2: Primary Access to the lower boundary of Central Field. Entrance 3: Primary Western Access to the North-West Field. Entrance 4: Primary Eastern Access to the Wash Pond and designated Plant Site. Entrance 5: Adjacent Parcel Existing Access. Entrance 6: Oil & Gas Access into the Western Section of Central Field. Entrance 7: Primary Eastern Access to the North-West Field. Entrance 8: Primary Northern Access to Central Field. Entrance 9: Primary Northern Access into the designated Plant Site location. Entrance 10: Internal Access from Adjacent Lands. Entrance X — Agricultural/Mechanical Entrance WV — Agricultural/Mechanical — Westervelt R -O -W Access to adjacent Wetland Bank Existing roads outside of the permit boundary are shown on Exhibit C-1: Existing Conditions Map. Existing on -site internal access roads are also visible to scale in the aerial information provided under Exhibit C-2: Extraction Plan Map and other map exhibits included with this submittal. In general, Operations will predominantly utilize unmodified existing agricultural field access roads (unless otherwise indicated), which will themselves be subsequently extracted in time where they fall within the extraction limits shown on Exhibit C-2: Extraction Plan Map. 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. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I9 6.4.4 EXHIBIT D - Extraction Plan 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. For purposes of this submittal, all lands within the indicated permit boundary will be considered affected lands, but only those locations between the existing access roads, and which otherwise remain above the anticipated static water level of the resulting basins, will be soiled (where soil is absent) and seeded to establish vegetation consistent with the approved reclamation plan. Area and Site Soils: Soil formation surrounding and within the project area varies according to diverse geologic, natural, and man -caused influences. The United States Soil Conservation Service, Soil Surveys, are the foundation source for understanding area soils as identified on Soil Survey Maps by their Soil Unit Number. Unit 3 Soil formations for Weld County are not easily typified or quantified as other soil units, for a reason; natural and man-made alteration and use of the land over time. Planned extraction limits will affect predominantly Unit 3 Soils. Extract from Exhibit I/J. Unit 3 soils commonly form within floodplains. As a result, differing states of soil formation may exist within the soil unit designation; such as soils with little horizon development like Entisols and Inseptisols. Mollisols with deep well -developed horizons may exist in the minority and the near fringe of planned extraction. Refer to graphic above, and below. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 10 6.4.4 EXHIBIT D - Extraction Plan Enceptisol I nceptisol Soil Morphology Molisol „a , r°r .,� ctt .1'i, i .i; t tdri E I .'r;,:.��t 7. c With over a century of agricultural manipulation of area agricultural fields, prior mixing or importation of soils for land leveling, or flood plain management in the creation of levees, may have dramatically altered the original native soil profiles and properties. The native A profile of the upland terrace found within the agricultural Fields at the TRP, is predominantly modified as a plow (Ap) layer of 6.0± to 8.0± inches. The historic practice of incorporating manure into the plow layer should have served to maintain the organic base and quality of the cropped soils and accelerated soil horizon formation and development where it was lagging. Since the cropped soils have been irrigated, care should be taken not to salvage soils greater than 12.0± inches in depth to avoid mixing of potential accumulated salts. Generally, total soil depth (including all soil horizons) over the property may vary from approximately zero inches to four [4.0±] feet, yet predominantly having a shallow Ap plow layer of six to eight [6-8±] inches, lacking a B profile and having the potential for a mixture of silt, clay, or gravel outcrops over random areas. Gravel depth may occur from the surface to the underlying Fox Hills Sandstone varying at approximately 30.0± to 45.0± feet over the entire property. Suitable soil in excess of that needed for reclamation will be made commercially available to meet area infrastructure and residential demand. Soils found within the entire project area are described more thoroughly under Exhibit I - Soils Exhibit, and the attending Exhibit I/J - Soils and VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 11 6.4.4 EXHIBIT D - Extraction Plan Vegetation Map, shown not to scale, above. Additional geologic considerations are also included under Exhibit S - Stability Analysis. Area and Site Geology: The area geology is typified by mixed alluvial and aeolian development, that is commonly alluvial in nature at lower elevations. As viewed in the Geologic Timeline and shown in Figure 1, below, the aggregate deposit is found between the Laramie and Fox Hills Sandstone formations, both formed during the Upper Cretaceous Period nearly 65 million years ago. The alluvium of the river valleys and aeolian sands that cap the hills formed of the Laramie formation north of the permit area are more geologically recent, developing during the Quaternary Period. ERA PERIOD kat ' C Quigattirnary Tint ia I CI Cretaceous J ur-ras s i 'sic EP CH ti -n1 'F M II. MILLIONS iP YEARS A15. NOW s: i r 1 . Pliorpno Mk"( irai arilliguitene !Eocene lieCititfule are Led el' Id le Early Late arly .ate p rfAiiekile Ems; Lair Fair er taitit Early Middllit Ear _ 0.1 a . a l 5,3 112 A f 2S3 33, :c 544 610 159 I BO 206 J,42' 248 Geologic Time - Livescience.com VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 12 6.4.4 EXHIBIT D - Extraction Plan Figure 1: Area Geology Map The areas of extraction are in the alluvium whose general morphology, area and extent are better understood in Figure 1 above, and 2 and 3, below (Colorado Geological Survey). Figure 2: Area Geology 3D Oblique View VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 13 6.4.4 EXHIBIT D - Extraction Plan CORRELATION OF MAP UNITS -R I:.'EA. DEPOSITS HUMAN -MADE DEPOSITS L7.70:1:41-.1. DEPOSITS GRAVEL ECLI-124 DEPOSITS DEPOSITS of .: •• _.... •• . f. . - . - _ . - . . . . . cra2 GS: . • f . • 1 • • . �- II X4 C. 17t731.7,...r -4411 if.:4- f ___,,i1 1 . • 1 . i anconformity un. conformity Holo to e Pist+eene Figure 3: Surficial Deposits relative to areas shown in Figure 2, above. The aggregate deposits of Qal and Qa2 (Figure 3, above) form the bulk of the deposit planned for extraction. Depths vary by field from approx. 30 to 45 feet. Depths are shallower as the adjacent hillside rises to the north; while the deposit dips deeper toward the South -East of each designated Field. Soil Salvage: Resource recovery will commence by first removing the upper [A profile/plow layer] six to twelve inches of soil [six (6.0±) inches typical], combined with existing grass or crop stubble. Removal will utilize scrapers or excavators, aided by dozers where necessary, and hauled to the Northeast Section of Central Field. All extraction and surface related activities detailed in this application will occur under an approved Fugitive Dust Permit issued by the Colorado Department of Public Health and Environment (CDPHE). Until resoiling activity occurs, where harvested soils have been stockpiled and remain undisturbed for reclamation or sale, they will be seeded with the mixture specified under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. A stabilizing cover of native vegetation may take up to three years to fully establish the desired cover. In the event the native seed mixture fails, an optional mixture of predominantly introduced species will be used as a fall back to better assure a stabilizing cover of vegetation. Still, using the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 14 6.4.4 EXHIBIT D - Extraction Plan preferred native seed mixture offers opportunity to gauge the potential performance of the selected species prior to utilizing it over larger areas requiring reclamation later in the life of the resource recovery operation. Once vegetation is established over the initial reclamation soil stockpiles, they will likely remain untouched for the life of the operation until final reclamation of remaining affected lands takes place. Where concurrent reclamation is possible, operations will utilize soil in an over the shoulder method when practical. In this manner, reclamation is expedited without increasing soil stockpile volumes while reducing expenditures related to labor, handling, and time. 'Soil salvaged as stated above will range six to twelve inches in thickness. Resulting volumes of salvaged soil will range from 131,100± - 262,300± cubic yards for Central field, and from 33,100± - 66,300± cubic yards for the North West field. Salvaged soil will generally be stockpiled on top of the Westervelt soil storage area in the North-East section of Central field. Smaller short-term stockpiles may be created along the pit edges where regrading is imminent or in progress and resoiling will follow. Resoiling volumes required above the waterline of the lined water storage will require much less soil. The resoiling areas are estimated at 11.19 ± acres for Central field and 4.76 ± acres for the North West field with volumes at a nominal six inches of soil cover at 9,027 ± and 3,840± cubic yards respectively. Excess soil not needed on site may be sold. Dewatering: As extraction activity progresses into the aggregate profile, groundwater must generally be removed in advance through the use of pumps and subsequent discharge into area tributaries. A complete dewatering evaluation was performed by AWES in their report of 27 July 2020, as provided at the back of Exhibit G: Water Information. The report concludes that 'the results of analytical and numerical solutions indicate that the proposed mine dewatering activities will not adversely affect the regional groundwater hydrology.' The reader is further assured that all discharge of waters will be conducted under an approved CDPHE discharge permit. Initial dewatering of the property in preparation for extraction and resource recovery will occur by establishment of a dewatering pump and/or well in the Southern boundary near an existing agricultural pond. The point of discharge is on Exhibit G: Water Information Map. Other discharge locations may occur in time as needed and otherwise approved under the applicable 2 Adequacy Item 23/32 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 15 6.4.4 EXHIBIT D - Extraction Plan CDPHE discharge permit requirements. Subsequent CDPHE approved discharge locations will be field fit and the location updated in the following OMLR Annual Report. Active Resource Recovery: Following soil salvage, the balance of the extractable deposit will be removed to the depth of the unconsolidated or weathered bedrock, transported by conveyor to the plant site pit run, and subsequently manipulated as desired by screening, crushing, washing, and other methods to size and properly dimension the earth product into diverse merchantable materials for sale. Resource recovery will commence radially North and East from a point near the existing pond and planned first discharge point shown near the Southern boundary of Central Field. There are no fixed sequences or phases scheduled as part of the extraction plan. Instead, Fields are used instead of Phases to describe the activities, since each Field can be accessed concurrently instead of sequentially with the other; as reflected or otherwise updated as part of required OMLR Annual Reports. Under this method, extraction is 'pulsed.' As such, the rate of extraction and subsequent reclamation will slow or quicken according to influences of the markets, weather, and internal logistics. Flexibility in Operations encourages better outcomes when adapting to changing circumstance or unexpected field conditions, and may involve actively working different fields or different parts of the same field as necessary. 3For Two Rivers, there are four Fields, intended as sequential areas of extraction unless market demands warrant concurrent development: • 121.86± Acres - Central Field — Center Section • 15.58± Acres - Central Field — North-East Section • 25.09± Acres - Central Field - West Section • 41.04+ Acres - North-West Field Generally, flexibility aids integrity of operations and encourages optimizing operational activity and subsequent reclamation of affected lands. Therefore, any method that accelerates the extraction timeline will be utilized, and should be encouraged to better engage the unpredictable elements and variables that reasonably affect the capacities of the Operator. Exhibit C-2: Extraction Plan Map, shows the location and planned extraction limits, general direction of extraction, and related features described above; along with features made obvious in the included aerial image of the permit location and surrounding lands. 3 Adequacy Item 17: Aspects of detail required. Other aspects addressed elsewhere. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 16 6.4.4 EXHIBIT D - Extraction Plan Exhibit L: Financial Warranty Map, shows Initial Extraction proposed to begin in the yellow hatch area shown on the Exhibit L Map, comprising 16± acre. The direction of extraction will follow the perimeter of the extraction limits over approximately 70.21± acres in order to establish the perimeter keyway (dewatering trench') for the 121.86± acre Center Section of Central Field. The perimeter extraction will leave a 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The Initial Extraction area is practical as it has no encumbrances and is adjacent to the existing pond. The initial extraction area is bordered to the South along a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). If or while this infrastructure is still in place, extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed below. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary settling basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line and may then be extracted itself once discharge is discontinued for Central Field Operations. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H:1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.00H:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and excise the bed dimensions where the resulting channel is sufficient to convey the groundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape, size, and location presented. 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. 'Adequacy Item 17: Modified from first adequacy response to better define the mining and reclamation plan and reference a schedule in Exhibit E. 'Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 117 6.4.4 EXHIBIT D - Extraction Plan At anticipated production levels and production only from the Center Section of Central Field, extraction of the remaining perimeter excavation could take 6-7+ years. Extraction of the core could then commence and take 6-8± years, overlapping with initial development of the next field. With sequential development, extraction of the North-East Section of Central Field could take 3- 5± years, the West Section of Central Field 4-6± years, and the North-West Field, 6-8± years. Please Note: The time periods will depend on the actual rate of production required to meet market demand, and the average annual advance may also vary with thickness of the sand and gravel and ground conditions. Some flexibility may also be exercised to optimize operations around or through existing infrastructure if scheduled for removal. Table E-1 provides a projection of mine development and regrading/reclamation. The plan as described in this Exhibit D and also in Exhibit E, is a forecast and may vary according to market conditions with mining and subsequent regrading occurring faster or slower, sometimes significantly so. The geology may also dictate changes in the rate of extraction. If efficiency demands in a higher production demand scenario, up to four separate areas could be developed in the manner described simultaneously. Such changes may happen quickly and would be addressed in the Annual Report. 'In discussing this flexing of production and scaling operations up or down with OMLR staff, a concern was raised as to impacts on mule deer habitat if there were separate production areas with a larger area under active production. This has been addressed as having minimal impact in a letter from Ron Beane, Senior Wildlife Biologist with wildlife consultant ERO Resources Corp attached as an addendum to this Exhibit D. As discussed above and considered in the letter from ERO Resources Corp, Raptor envisions up to four active mining areas (area of active extraction operations) of up to 16 acres could be in production simultaneously for an anticipated maximum active mining area of 64 acres. As noted in the ERO Resources letter, this area is only a small percentage of the riparian corridor within and adjacent to the extraction area and while Raptor would not anticipate exceeding 64 acres of active mining area, small and temporary variances may occur in response to market demands, coordinating operations around existing infrastructure, water management, or to ensure safe operations. The maximum disturbed area will continue to grow over the life of the operation as the post mining land use is lined water storage and as noted by the DRMS, until the basin is fully extracted and lined, and a leak test is performed and approved by the State Engineer. Progressive regrading and lining however will be performed and is discussed in Exhibit L. 6 Adequacy Item 17: Wildlife concern VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 118 6.4.4 EXHIBIT D - Extraction Plan Additional information is provided under Exhibit C-1: Existing Conditions Map; which shows all known current and active significant man-made structures located on or within 200 feet of the permit boundary detailed under 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; located over the permitted lands or within 200 feet of the same. A listing of the adjoining surface owner's names and addresses located within these areas are listed under Exhibit C Text, correlated with those shown in the afore -mentioned Exhibit C-1: Existing Conditions Map. The extraction limits assure through the use of setbacks that other interests are not affected by planned extraction. Extraction is set back uniformly at a minimum 10.0± feet from the edge of property lines; easements and rights -of - way; underground gas lines or other underground facilities, irrigation ditches and seep ditch, wells and other structures. 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 OMLR inspection in a timely manner, or by operator -initiated Revision to the Permit or otherwise via clarification in attending required OMLR Annual Reports. Extraction will not occur closer than 125± feet8 from the face of a residential structure; unless there is a written accommodation with the owner of the residential structure that allows extraction to occur within a closer stated limit. Extraction will occur no closer than 25± feet from well heads and related above ground facilities. Extraction around well heads will be concurrently backfilled to maintain a 100± foot buffer from the balance of extracted lands. At all times, safety will take precedent and over -ride all other conditions in time with a matter of safety or emergency respective to any and all aspects of the approved permit. To minimize the potential of river capture, planned setbacks from the two rivers was evaluated by Flow Technologies (refer to report at the back of Exhibit G: Water Information - titled: Two Rivers Riverside Berm Failure Analysis and Flood Control Mitigation Plan' of 22 January 2020). The report finds: '... that head cutting/erosion will not progress through the full length of a 100 -ft riverside berms. It is important to note that should a flood occur Adequacy Item 21 8 Adequacy Item 22 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 19 6.4.4 EXHIBIT D - Extraction Plan that results in head cutting/erosion of a riverside berm, Varra Companies, Inc. will act diligently to restore the damaged areas to pre - flood conditions. As mentioned, this analysis is conservative and riverside head cutting/erosion is based on the 100-yr flood. There is a small probability that such a flood event could occur during extraction and when the pit is dewatered. The DRMS in a supplemental adequacy response dated November 17, 2022 challenged the validity of the engineered design approach taken by Flow Technologies despite having accepted it as valid in the past. Raptor Materials believes the approach is valid and is in the process of performing an analysis by alternate methods incorporated in HEC-RAS. This, however, will take time. Raptor has per DRMS suggestion decided to adopt the 400 -foot setback from the top of the riverbanks to the top of the pit -side slope based on guidance developed using generic and non -site -specific empirical methods as adopted by the Mile High Flood District whose jurisdiction does not include the proposed operation. Raptor Materials intends after permit approval to present the results of the ongoing engineering evaluation as a Technical Revision to obtain relief from what we are confident are extreme setbacks. During extraction, a predominantly vertical advancing pit wall (the extraction front) is not anticipated due to the use of excavators in the removal of the material deposits. Excavators provide a great deal of control over the extraction process. The maximum length of the extraction front will likely never exceed the length of one side of a quarter section of land, or 1,320± feet, or less; in any given direction. The advancing front will result in a moving face with a slope typically equal to or flatter than 1.25H:1V, and commonly not greater than 1.25H:1V along the perimeter of the extraction limits to depth. The exception to cut perimeter slopes is shown with a distinct Red Boundary on Exhibit C-2: Extraction Plan Map, where cut slopes will not exceed 2H:1V in order to maintain integrity and stability along that designated perimeter area (refer to the AWES Slope Stability Analyses of 23 December 2019, located at the back of this exhibit). Internal transport of extracted materials to conveyor systems or other internal transport; or otherwise by approved public roadways, will be used in the transportation of extracted materials to the designated plant/stockpile location, described in greater detail, below. Acreage to be affected during the first year of extraction activities include the establishment of the initial Wash Pond and attending Settling Pond(s), Plant Site, and Initial Areas of Extraction and attending means of transportation by ground haulage or conveyor. While the acreage required for the Plant Site and Wash Pond are not expected to change, the Initial Area of Extraction will VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page X20 6.4.4 EXHIBIT D - Extraction Plan expand until concurrent reclamation follows as each location is exhausted of resource. Although initial extraction may otherwise result in temporary slopes up to I.2 5h:ly, all cut slopes will be backfilled with unconsolidated bedrock, overburden (on -site unmerchantable excess materials, or imported inert materials) and soil to advance the reclamation and completion of the desired basins. Final reclaimed slopes and grades will be concurrently established where practical to 3h:lv, or flatter, and at a minimum from 5± feet above to 10± below the expected water level of each location of extraction, and to the basin floor. Concurrent backfilling and grading of cut perimeter slopes, while desirable, may be obstructed in time and extent by the need to maintain keyways and basin discharge during extraction. Backfilling of slopes can only occur once enough of the floor is exposed to facilitate backfilling and finished grade of extracted basin slopes without interfering with basin discharge operations. This makes concurrent backfill difficult to accurately forecast. Regardless, any completed slope remediation will be indicated in any subsequent OMLR Annual Report. 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 203.61± acres of potential extraction, the resulting basins will function as multiple -use reservoirs with a slightly fluctuating combined water surface area covering 187.66± acres. The remaining balance of 37.3± acres of land above the anticipated high-water mark of the reservoirs, and not otherwise committed to existing or planned structures or infrastructure over the parcel, will be stabilized with vegetation; including the anticipated 15.95+ acres of basin slopes reflected in the total. NOTE: Shoreline irregularities and fill to establish and enhance the aesthetic and end -use functions of the resulting basins shown on Exhibit F: Reclamation Plan Map, are illustrative only, as this effect as to location and extent will be field -fit where practical, and may substantively different from that portrayed VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page X21 6.4.4 EXHIBIT D - Extraction Plan under the application. The actual location and extent will be identified in subsequent OMLR Annual Reports, and absent there, at the time of any applicable release of a location in part or whole from the permit. Since representations cannot be accurately portrayed in advance, Exhibit F simply identifies the near maximum extent [typical] of the resulting basins or ponds and the potential for shallows during lining and finished grading. The estimated timetable for extraction, commencing approximately spring to winter 2023; is estimated to take 23-28± years combined, or longer, followed by an additional five years to complete reclamation; or a total estimated life of the mine of 28-33± years; ending approximately winter 2051 to 2056. This is a life of the mine operation and all timetables are estimates and may prove shorter or longer than stated. The final determination will occur five years after the deposit is exhausted and all marketable product has been removed and necessary infill completed at the location to the point of final reclamation as approved or modified under the terms of the permit is completed. This submittal is unable to fully forecast the maximum extent of affected land expected at any given point in time, beyond an annual basis. As operational extraction and reclamation efforts will vary annually, the timing of extraction, reclamation, and life of operation as forecasts must be based on an initial estimate [refer to Exhibit L - Reclamation Costs], then subsequently verified and adjusted as reasonably determined at the time of the required OMLR Annual Report. If justified by field conditions, a rider to the warranty would follow in due course to reflect current or forecast conditions where such conditions cannot be reasonably attenuated in a timely manner prior to the due date of the next year's Annual Report. This will serve to assure flexibility and confidence in continued operations until completion of the desired end use. Additional information on the reclamation and restoration of affected lands is identified under Exhibit E: Reclamation Plan. All reclamation will follow guidelines established under Exhibit E - Reclamation Plan and Exhibit I/J: Soils and Vegetation Information, until and unless otherwise revised. To the extent possible, pond bottoms will be left rough, with the possible introduction of logs or other non -putrescent inert material to aid in aquatic habitat and cover [Refer to Exhibit H - Wildlife Information]. Plant Site Development & Operations: Plant operations are generally comprised of portable equipment. A small wash pond will be established near the onset of extraction operations as shown in Exhibit C-2: Extraction Plan Map. Deposit materials are predominantly transported or conveyed from the extraction areas to the plants or surrounding yard, where subsequently VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 122 6.4.4 EXHIBIT D - Extraction Plan processed and scaled for sale. Pit -run (unprocessed materials) may also be loaded and transported directly from the extraction areas to area markets as needed and where appropriate. Plant Site operations may also receive and process materials, and utilize fresh water supply, sourced from locations outside of the permit area or planned areas of extraction. Provisions for a material processing plant may at some point be joined by complementary processing that may include periodic use of on -site recycling facilities. While recycling activities may occur within the approved plant site/stockpile location; concrete and/or asphalt batch plant facilities and locations are not presently determined or sought at the time of this submittal. Due to the extended life of the mine the Operator desires an essential flexibility to complement future area needs according to permit requirements and approvals applicable at the time should such facilities be sought. Any facility development of this kind will be determined at that time as identified in a later Technical Revision to the OMLR under the approved permit. These potential activities are mentioned here solely for purposes of transparency in establishing these activities as acceptable, normal, and necessary activities to meet and facilitate the delivery of essential construction material needs of the area which may occur over time during the life of the approved OMLR Construction Materials Permit Operations. Initial Plant Site Theater as seen in Exhibit C-2: Extraction Plan Map With the exception of the wash pond, whose margins follow existing surface elevations; all plant site processing activities will occur on upland areas outside of the existing 100 -year floodplain. These lands occur north and north-west of the existing Evans Ditch as it winds north of the Big Thompson River. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 123 6.4.4 EXHIBIT D - Extraction Plan Plant activities will require a wash plant and attending wash pond to recycle wash water and receive discharge silts and other reject fines from the washed product. Plant and Wash Pond areas are identified on Exhibit C-2: Extraction Plan Map. The wash pond will function as recycling wash water and receiving basin for reject fines for the intended Plant/Processing activities. Since the basin functions in a closed system, it will not require dewatering. Once the wash pond is established, wet plant operations can be created and join any dry plant activities in progress. Dry Plant operations can be readily established since water is not integral to their operations. Once established, wash pond water will function as a closed system. Settled materials from wash Ponds will be utilized as product or for reclamation as desired. Plant equipment will include, but is not limited to, a crusher, screens, and conveyors, scale house and scale, and attending equipment. Resulting stockpiles of pit run and processed products may be temporarily stockpiled here with processed stockpiles, or combined as needed, until transported to market. `'The conveyor will be set on an elevated structure at varying heights to be situated about the 1 in 100 -year flood level. An average height of 7 feet is expected. The conveyor will be supported by legs at intervals of approximately 40 feet with typically 6- x 2- x 2 -foot concrete blocks sitting on ground surface used as necessary to anchor the legs. The conveyor will span the river channel and metal (or other appropriate material) pans will be installed under the conveyor structure to prevent spillage into the river. The design will be similar to other Raptor locations where an extended span has been required to cross a county road. Final conveyor specifications are to be determined however belt width is anticipated in the range 24-36". Ultimately, once the wash plant activities near the completion of extracted deposit material, the closed system wash pond will fill with silt and be revegetated in a manner consistent with Exhibit E - Reclamation Plan. Interim clean out of the wash pond will occur until that point, 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. Plant and material processing activity will divide materials into diverse and dynamic product stockpiles that will come and go with unpredictable variations in sale and production. To the extent possible, product material 9 Adequacy Item 24 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 124 6.4.4 EXHIBIT D - Extraction Plan will surround plant activities to further lessen visual and noise impacts to surrounding properties. Plant placement will assure that plant noise is well below that of the nearby traffic. Relative to noise, traffic travelling on area roads at 55 mph or above is approximately 70.0± decibels within 100 feet from the centerline of the Highway. Noise at ground zero at a cone crusher, as measured by a hand- held 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, achieving residential background levels at a total setback of 400± feet. 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. Plant stockpiles will aid muting of plant sourced noise just as noise levels at areas of extraction are buffered with increasing depth of extraction. The location of the portable scale and scale house and correlated 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, and desirable neighborhoods communities most desire. 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 under Table DI - Earth Products, 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. Explosives - will not be utilized. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Thursday 23 February 2023 8120 Gage Street • Frederick, CO 80516 Bus: (303) 666-6657 • Fax: (303) 666-6743 Weld County Clerk to the Board 1150 0 Street Greeley, CO 80631 RECEIVED FEB 2 4 2023 WELD COUNTY COMMISSIONERS Subject: Raptor Materials LLC Two Rivers Sand, Gravel and Reservoir Project - Permit No. M-2022-013, Third Adequacy Response Attachments: DRMS 3' Adequacy Response Letter Raptor 3rd Adequacy Response Reply • Updated Groundwater Monitoring Plan • Groundwater Monitoring Plan Response • Updated Exhibit D • Updated Exhibit E • Updated Exhibit L • Updated Exhibit G Map Your signature or stamp below acknowledges receipt of the above referenced materials, as attached. The materials should be added to the above referenced Application, as originally submitted to the Weld County Clerk to the Board, and made accessible for public review. Received On , 2023 By: Office of the Weld County Clerk to the Board of County Commissioners rr� A w RAPTOR RATTRIN.I tic FA fa a In' tRI a MUSA/A ASH mOa MI) w-wr Lon nlrCfw/K• P�npft4talus Lu^stsl+cnani�z+t PerraitC--� 14tr.e.'„405(1;971 aMTenni10b1It:6£4TATtCwrivo "co Cm.ktMq d ........................P,^.i ...._ Omar iGA x6373 3!l? m$. AiVA.4 « 11avitNwte-4t .....r.._iona )Jmuttal Oinked! .�SNi :lpn ......r • 1114.7044rVAIVACOMPAtitiS Conitn tird _ ._.. -Snot Gu+lotll1 popgun itrtipttrR �It1e 7 aa,A. CI Nebit eS Army, ,3 Tla 1rYrYfi1>ntaaeted q riser nerut Purr)* :ewe IP.14} :; `r*GEtet tlio4 • + c,�tt 1xt%61"n "fa. I ,nuwa4rt «•_•„ rVMlat ,;nl��,,�yyaa r^rauan I wined 1•41.9 1644504fh NA1t6t ana.SeU1f'!S PP&RTNM$ UC Veldt C4ntbr ird .. 5 1?i 2A7b ReSttntA.j ...... L1__otlie • 1tn x�; a�xte ,t{En. UC rvut? cvri"uasi' r Nry•I tp�wt,epµi�i P • w �1M /1114,.:;11.t114•4ail^f.1i.:4.tCK•?N.'anMiyl•�;trf W.l.r+.�h!ta••-<t •• 77101.2.,.t r•M.r11V:•Btr•• ?tr,?. ter, - MATERIAL PROCESSING AREA = 15.76± ACRES NW FIELD SURFACE WATER AREA = 34.99± ACRES AT ELEVATION 4675' • WASH POND = 5.60± ACRES NW FIELD= 41.04± ACRES CENTRAL FIELD = 162.56± ACRES CENTRAL FIELD SURFACE WATER AREA = 151.38± ACRES AT ELEVATION 4673' PRUICT: Two Rivers Sand, Gravel Reservoir Project DRAWING: Exhibit G: Water Information Map nflo./ND•46ih: 37 7JP PIPF-4604 44 NOTES: 203.59±Acres Basins Total Ma Drown by. M. Thompson Checked by. P. E. Christensen a.. SCALE: 1 Inch = 300 feet DATE 22 February 2022 RE !9ON: 20 November 2022 PACE: 1 cc 1 y 2S SC' :Co !' !Water%Weii ti_1a:1 •ernit Number 1394:O -R. -R 270-R 83303 -P -R 831 R 3200422- 78569-F i' Latitude ,Longitude 4:homer 40,35129 •104.769111005 RIOS ESTATES W IR CO 1 40.342653 ..04.78573 SHA61, ALVA I 40.342343 -104.78248 VARRA COMPANIES INC (VAiRRA. GARRETT) 40342642 •104.78099.1VARRACOMPANtESINCjVARRA,GARRETT). Well Constructed k.AFARGEHOLCOM/AGGREGGATE INDUSTRIES Well Constructed 40.3390431 -104.78599 40.3394041 .104.77663 Permit Status Construction Date Well Constructed Well Constructed Well Constructed 40.341719 SOR:N NATURAL RESOURCES PARTNERS LLC -104.763141DIXIEWATER. LLC 40.1' 1241 •1DI.761A2ISORIN NATURAL RT-SOURrc IRAATNFRS l if GROUND -0a e- TJP €-1C' a7 •&.00_1 COIS) ... C 1100 IC.Y lM PS ..:..t» Well Constructed Well Constructed Wen ranstrurled affi Permit Category 10/11/1989 General Purpose 6/20/1955 General Purpose 11/14/1999 General Purpose Use(s) Irrigation irrigation Irrigation _ W30/1952 Genera+ Purpose IrNation 1/22/2021 Monitoring/Observation Monitorine/Sarnpling 5/12/1975 Residential Domestic 4/23/1976 General Purpose Irrigation MATERIAL PROCESSING AREA = 15.76± ACRES r NW FIELD SURFACE WATER AREA = 34.99± ACRES AT ELEVATION 4675' WASH POND = 5.60± ACRES NW FIELD= 41.04± ACRES CENTRAL FIELD = 162.56± ACRES CENTRAL FIELD SURFACE WATER AREA = 151.38± ACRES AT ELEVATION 4673' •••••• no Wan allb -.:,eI SETT/LING BASIN ! SOUTH PLATTE RIVER tr.0 a -t'a ten.. _. MW -,t GROUND=4690.37 TOP PIPE=4694.44 aa 1 lOCZW•44.0 SO ,,,.R... - woe e o... a LEGEND: r7 V WF. 4871 2 RAPTOR MAIEMALS, tic al 20 caa rat ntaiE73O(. CatORAco 803.14 rrlrrRORG (313) aee-033/ PROJECT: Two Rivers Sand, Gravel Reservoir Project DRAWING. Exhibit G: Water In forrrluliori Map NOTES: 203.59±Acres Basins Total Drawn by. M. Thompson Checked by. P. E. Christensen SCALE: 1 inch = 300 feet DATE: 22 February 2022 REVISION: 20 November 2022 PAGE: 1 OF 1 a4P TOR Lys vart¢Miss 8120 Gage Street • Frederick, CO 80516 Bus: (303) 666-6657 • Fax; (303) 666-6743 Thursday 'Pt February 2023 To: Robert D. Zuber, R.E. Environmental Protection Specialist Colorado Division of Reclamation Mining and Safety Office of Mined Land Reclamation (OMLR) 1313 Sherman Street, Room 21.E Denver, Colorado 80203 From: Garrett C Varra, General Manager Raptor Materials, LLC 8120 Gage Street Frederick, Colorado 80516 Subject: Two Rivers Sand, Gravel and Reservoir Project, File No. Mr20 2 013, 112c Permit Application Adequacy Review #3 REPSPONSE Dear Rob, The following includes notes addressing both the supplemental Second Adequacy response submitted to the DRMS February 02, 2023 and the follo ► up Third Adequacy response. For reasons unknown, and upload error to the DRMS file transfer space did not result in a cover letter and Exhibit 6 Map being available to the DRMS. The Division of Reclamation, Mining and Safety (Division/ORMS), Office of Mined Land Reclamation (OMLR); reviewed the contents of the Original 112c permit application for the Two Rivers Sand, Gravel and Reservoir Project (TRP), File No. -2022-013 and submitted comments via Adequacy Letters of 24 June and 5 August 2023 which were responded to by Raptor Materials on 6 September 2022. Raptor Materials received a Second Adequacy Review dated 17 October 2022 which were responded to by Raptor Materials on 4 January 2023. In addition to the Second Adequacy Review dated 17 October 2022, DRMS on November 17,, 2022 provided an additional comment on the berm failure analysis included in the application. In the November 17, 2022 comment, DRIV1S challenged the validity of the engineered design approach taken by Flow Technologies despite having accepted it as valid in the past, Raptor Materials believes the approach is valid however appreciates DRMS recognition of the impact to Raptor's available resource and the intent of Title 34 both in fostering and encouraging development of an economically sound and stable extraction materials industry, and the orderly development of the state's natural resources, by providing options to address the setback proposed based on guidelines from district in which the proposed project is not located to something more reasonable. To that extent, Raptor has modified the relevant sections of the application to reflect the nominal 400 -foot setback and is performing an alternate analysis on the possibility of riverside berm failure using an alternate methodology using HEC-RAS and the incorporated DL Breach module. Raptor Materials intends after permit approval to present the results of this ongoing engineering evaluation as a Technical Revision to obtain relief from what we are confident are extremely conservative and resource wasteful setbacks while still providing more than adequate protection for the adjacent rivers. The following documents were included in our supplemental response on second adequacy on February 02, 2023: updated 112 Form Updated Exhibit D - Extraction Plan Updated Exhibit E , Reclamation Plan Updated Exhibit G - Water Information U pdated Exhibit I/J a Soils Information U pdated Exhibit L= Reclamation Costs Updated Exhibit Cl Map Existing Conditions U pdated Exhibit C2 Map- Extraction Plan Updated Exhibit F Map - Reclamation Plan U pdated Exhibit 6 Map - Water Information Updated Exhibit 1/J Map - Soils and vegetation Updated Exhibit L Map - Financial Warranty [Files did not include Updated Exhibit G map - Water Information] Raptor Materials received Third Adequacy Reviews dated 09 February, 10 February and 14 February, 2023. The items requiring a response in our third adequacy response are addressed by exception. Raptor's responses below follow the comments from the adequacy review and are highlighted in blue font for clarity. 6}42 Exhibit G -• Water Information Item 46) To ensure that the Two Rivers project does not impact the hydrologic balance of the rivers, the application needs to include a water quality monitoring plan, specifically for the alluvium. The groundwater monitoring plan should be developed in accordance with Rule 3.1.7(7)(b) and should include a Quality Assurance Project Plan (QAPP) for the collection of groundwater samples. The plan should provide mitigation steps if there is an exceeds nee at a groundwater or surface water monitoring location. Potential impacts to quality and/or quantity the nearby domestic wells should also be addressed. A copy of the Division's Groundwater Monitoring and Protection Technical Bulletin has been included as an enclosure to this letter for your reference. An addenda to the Second Adequacy review addressed several items from Exhibit G— Water information and these are further considered in a separate Third Adequacy review from Leigh Simmons dated February 14, 2023. These items are addressed by exception per the item number in the February 14 review. Item 4. (additional review) Eight wells are listed„ including two that are owned by Varra Companies and three more that are on the south side of the South Platte River which can be considered a groundwater divide. The three remaining well (Shable, Dos Rios and Lafarge) are each within the modeled cone of depression, which suggests that there is the potential for their yield to be impacted by the proposed operation. The data presented suggests that the water level in the Shable well could be reduced by around 10', and a bit less in the Dos Rios and Lafarge wells. Since impacts to three existing welts are predicted, please address in Exhibit G how such impacts will be mitigated. It is likely that this will take the form of a signed agreement with the welkowner that can be included in the Exhibit. The three wells are all more than Zoo=feet from affected land included in this application. Physically, the Dos Rios well is north of the Big Thompson River which can also be considered a groundwater divide. In order to operate Raptor will need to obtain a well permit through the Colorado Division of Water Resources. This may or may not necessarily involve agreements with neighbors. Raptor commits to obtaining a well permit prior to operation. Item 54 (additional review) Several symbols are used on the map but are riot identified in the key or labelled on the map, these Include (by exception): Dashed brown line (as shown in figure 2) o Blue marks (as shown in figure 3) — partially removed The map has not been signed, stamped, or otherwise certified by a registered land surveyor, professional engineer, or other qualified person. The revised map addresses some of the points from the previous adequacy review, but not all. In particular, the scale at which some of the labels are drawn renders them illegible, even at 300% zoom. The map has been digitally signed by Peter Christensen, but his q uallfying credentials are not given. As mentioned above, an upload error inadvertently resulted in the Exhibit G map not being included in the supplemental response to Second Adequacy capture on the DRMS file system. The revised Exhibit G — Water Information Map, we believe addresses both the labeling of the Settling Basin (brown line), blue marks, and other extraneous feature that were unimportant to the intent of the map but nonetheless distracting. Efforts have been made to ensure labels are not obscured and legibility improved. We believe first and foremost that the important information required is clear and legible. We also recognize an oversight in prior responses regarding the basis for Mr. Peter Christensen being a qualified person. The relevant statute and regulations as we understand them do not define a qualified person but require that maps "must be prepared and signed by a registered land surveyor, professional engineer, or other qualified person'}. Mr. Christensen is a qualified person by virtue of education, training, and experience. He holds a degree in Mining Engineering awarded by the University of Queensland (Australia) in 1985, During his subsequent 37 years in the mining industry, he has attained various statutory or professional designations including Registered Member of BRUME, New Mexico Mine Foreman, MSHA Underground and Surface Instructor, and Queensland (Australia) Site Senior Executive. He has attended short courses on environmental compliance and the NEPA process. His experience specific to permit preparation, permit review, and operating in conformance to permits includes preparation of state and federal permits in West Virginia, Wyoming, New Mexico, and Colorado, as well as foreign jurisdictions both state (or equivalent)and federal in Canada, Colombia, Indonesia and Australia. Review or audit of compliance with permit operating conditions has been undertaken in many more states and foreign jurisdictions. He has held responsibility for ensuring operational permit compliance and completing mining or exploration activity reclamation in West Virginia, Wyoming, and New Mexico, and has presented on the subject at conferences and educational workshops. Additional items were included in the Third Adequacy Review and have been addressed as follows: A groundwater monitoring plan, prepared by AWES, was submitted with the January 4, 2023 packet. The plan proposes to use 12 existing holes, which were completed as 1" monitoring wells in 2015. Boring logs are given as an appendix to the plan, but no well completion data is available. The elevation of each hole is given in a table in Exhibit G, Addendum .0, together with monthly water level data from September 2015 through June 2022. Adequacy comments on the proposed plan are given below, organized by the section of the plan itself. Section 1 of the proposed plan states the objectives and gives the background information. Item 16. Section 2.2 states that water levels will continue to be monitored on a monthly basis during dewatering operations, then quarterly for one year following reclamation, then annually until the permit is terminated. Item 16. Please amend section 2.2 of the plan to continue quarterly monitoring until the permit is terminated We have amended the Groundwater Monitoring plan (updated as a new addendum) as requested. Section 2.3 describes the monitoring of groundwater quality4 ity4 It states that "two baseline samples will be obtained from one upgradient and two downgradient wells no less than two months apart. The wells will be sampled for the laboratory parameters if there is an. exceedance in the stormwater laboratory parameters. On an annual basis field parameters of pH, specific conductance and temperature will be measured in waters obtained from the selected wells after three well bore volumes have been evacuated." The only laboratory parameters proposed to be measured are Arsenic (total) and Selenium (dissolved). Item 17. The proposed water quality monitoring program described in section 2.3 needs further consideration. In addition to enforcing the requirements of the Mineral Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials (ttMinerals Rules"), the Division is an implementing agency for Regulation No. 41 — The Basic Standards for Groundwater ("Reg. 41"), available from the Colorado Department of Public Health and the Environment website: http_:ficdphe.colorado.gov/water-quaylity-control-comr ission-regulations In order to better explain how the Division interprets its responsibilities under Reg. 41, a Groundwater Monitoring and Protection Technical Bulletin was produced in 2019 and is available on the DRMS website, or from the following link: htt•s: ` drive.;oo le.com file d121Uc Kr u x7xhc8he cROPnKK u_kcG—J. view?.li=i Since the proposed operation clearly has the potential to impact groundwater, and groundwater at the site has not yet been classified, the Division will apply the Interim Narrative Standard from Reg, 41. At least one downgradient groundwater point of compliance will need to be established, where the standard will be applied. Typically the Division requires 5 quarters of water quality data prior to disturbance in order to establish baseline conditions, (without reliable baseline data the most restrictive parameter values from Tables 1-4 of Reg. 41 would apply). When evaluating a groundwater monitoring plan the Division typically looks for an analytical suite that includes the parameters from Tables 1-4, however the parameter list may be reduced if justification is provided. The parameters listed in Table 1 were based on a USGS study of the South Platte River basin which listed several trace metals detected in stream bed sediment and fish tissue. Those elements included As, Cd, Cr, Cu, Pb, Hg, Ni, Se and Zn. A comprehensive groundwater study was performed by Joby Adams, P.G, REM, author of the Groundwater Monitoring Plan prepared by AWES, LLC and background levels of Win, U, nitrate and sulfate exceeded current drinking water standards and those parameters were added to the list. I also included gross alpha particle activity due to the presence of uranium in groundwater and the high background levels of radon in the area. Section 2.4 describes how water level data will be used for drawdown and mounding analyses. It states that "Variations in pre -mining water levels will be presented on a two dimensional contour map and will be compared to numerical predictions and will be provided to the Division upon request" Item 18. Please amend section 2.4 to specify that water monitoring data will be compiled into a report and submitted to the Division annually. Please also specify the date. The report should include the operator's analysis of the data, as well as the data itself. We have amended the Groundwater Monitoring plan (updated as a new addendum) as requested. 6.4.12 Exhibit L Reclamation Costs Item 51) This exhibit should be updated, as necessary, to match any revisions to Exhibits D and E, per the adequacy items for those sections. This includes details on structures, • Exhibit I requires a statement by RM committing to posting additional bond in the future as mining progresses beyond the initial extraction shown on the map in Exhibit C-2. • Page 3 must be updated to explain the value of 70.21 acres. The Division also recommends that an explanation for this value be added to page 16 in Exhibit D Regarding the dewate ring calculations on page 4, there appear to be errors and omissions in the way the calculations are shown. Please check this and add explanations. For example, what is the origin of 9,710,931 gallons per acre? Is this based on a water depth of 30feet in the pit? Also, please explain the origin of the inflow rate of 14,700,000 gallons per day as well as the volume percentage of 19.6, It appears that only one side of the crescent -shaped pit (the yellow hatching on the map in Exhibits C-2 and L) will require grading. Please provide a n explanation of this in Exhibit L (pages 5 - 7); in particular, discuss if the internal perimeter length will be graded concurrently as the extraction progresses. The explanation can entail a reference to the mining process in Exhibit [ or the reclamation process in Exhibit E, • More detail is needed for the liner installation in Exhibit L. Add a discussion on the construction process, including if and where the liner material will be sourced and where it will be stockpiled prior to use as a liner. Discuss the size of lifts and the need for compaction. Additional questions relating to Item 51) were provided in a second adequacy response as follows: As I look closer at the clay liner design and respective costs, i have identified some details that should be added to the exhibits of the IRP application. These could be included in Exhibit E or Exhibit L. These items complement the liner -related request in item #51 in my letter dated February 9, 2023. 1. Add a discussion of the anticipated soils available for liner material, including parameters such as plasticity, percentage of fines, and percentage of gravel. Also discuss how these parameters relate to hydraulic conductivity. Add a discussion of the material blending process for liner construction, if applicable. 3. Discuss requirements for and construction procedures related to moisture content. Can you estimate the amount of water that may be used to adjust moisture content? 4, Add a discussion on lifts, including the height of lifts and the number of compaction passes per lift What equipment will be used for compaction? How will bonding between lifts be achieved (e.g., scarification) ? S. The Division assumes that the liner will be covered with subsoil and topsoil. Please state that in the exhibit and provide some detail such as depth. Inclusion of a figure illustrating the design would be helpful, but not necessary. Raptor has reviewed and discussed these comments informally with DBMS and has made amendments to Exhibit D Extraction Plan, Exhibit E - Reclamation Plan, and Exhibit L Map Financial warranty.. The DRMS included in the Third Adequacy review, a condition for approval as new Adequacy Item 59. Item 59) Because of the phased nature of the mining and reclamation plans for the TRP, a condition of approval will be a commitment from RM that prior to moving from the initial (five- year) phase of the project, RM will notify the Division in writing of this transition. Also, at this time/ RM will submit a Technical Revision to update the mining plan, indicating that the first phase is over, and provide additional Financial Warranty. Pursuant to Rule 1.41(12), a condition or limitation to approval of the application, unless acknowledged and consented by the Applicant in writing, shall be treated as a denial. Please affirm in writing that RM accepts this condition of approval of the Reclamation Permit Application, Raptor Materials affirms acceptance of this condition of approval Please find attached the following documents as our response: Groundwater Monitoring Plan Groundwater Monitoring Response Letter Updated Exhibit fl - Extraction Plan -- Updated Exhibit E - Reclamation Plan Updated Exhibit L - Reclamation Costs - Updated Exhibit G Map - Water Information The current decision date is 03 March 2023. Regards gliPlaFrellisitawmae Garrett Varra General Manager STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 APPLICABILITY: CONSTRUCTION MATERIAL REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION PACKAGE COLORADO DIVISION OF RECLAMATION MINING SAFETY This application package is for a construction materials operation which affects 10 acres or more. If you plan to conduct a construction materials extraction operation which meets these criteria, please follow the instructions provided in this package, in the Rules and Regulations, and in the Colorado Land Reclamation Act for the Extraction of Construction Materials, as required. RECOMMENDATIONS PRIOR TO FILING: The Construction Material Rules and Regulations (the Colorado Land Reclamation Act for the Extraction of Construction Materials, Section 34-32.5-101, et seq., C.R.S., and 2 CCR 407-1) and the Colorado Mined Land Reclamation Board (the "Board") regulate the permitting, operational and reclamation requirements for all construction material extraction operations in Colorado. It is your obligation to comply with the Act and Regulations. You are encouraged to obtain and review a copy of the Rules, available for $8.00 from the Division of Reclamation, Mining, and Safety (the "Office"). In order to submit your application properly, it is recommended that you review the Act and: Rule 1.1 Rule 1.4.1 Rule 1.4.5 Rule 1.6 Rule 3.1 Rule 3.3.1 Rule 4 Rule 6 Rule 6.2 Rule 6.4 Rule 6.5 Definitions; Application Review and Consideration Process; Specific Requirements for Regular 112 Operations; Public Notice Procedures; Reclamation Performance Standards; Operating without a Permit - Penalty; Performance Warranties and Financial Warranties; Permit Application Exhibit Requirements; General Requirements of Exhibits; Specific Permit Application Exhibit Requirements; and Geotechnical Stability Exhibit. It is recommended that you contact the agencies listed in the application section titled "Com submitting the application to the Office . 2liance With Other Laws" prior to Office of Mined Land Reclamation Office of Denver • Grand Junction • Durango Active and Inactive Mines FILING REQUIREMENTS: In order to apply for a Reclamation Permit for a Regular 112 Operation, please provide: o One (1) signed and notarized completed ORIGINAL and one (1) copy of the completed original Regular 112 Operation Application Form. ORIGINAL SIGNATURES MUST BE DONE IN BLUE INK. o Two (2) copies of Exhibits A -S (required sections described in Rule 6). o Two (2) copies of Addendum 1 -Notice requirements (described in Rule 1.6.2(1)(b)). A sample of this notice is attached for your use. o The Geotechnical Stability Exhibit when required by the Division. o The application fee. The ninety (90) day period for review of the application and exhibits will NOT begin until all required information and fee are submitted. The Office will then review the submitted information for adequacy. NOTICE REQUIREMENTS: 1. You MUST send a notice, on a form approved by the Board, to the local board of county commissioners. A copy of this "Notice of Filing Application" form is attached for your use. 2. If the mining operation is within the boundaries of a conservation district, send a notice to the board of supervisors of the conservation district, PRIOR to filing the application. A copy of this "Notice of Filing Application" form is attached for your use. 3. You MUST include proof of notice #1 and #2 above with the application at the time the application is submitted to the Office for filing (Rule 1.6.2(1)(g)). 4. PRIOR to filing the application, place for public review a copy of the application, less confidential items, with the clerk or recorder of the county or counties in which the affected land is located. 5. You MUST include an affidavit or receipt demonstrating that the application was filed with the county clerk or recorder at the time the application is submitted to the Office for filing. 6. Any changes or additions made to an application submittal MUST be filed with the county clerk or recorder. You MUST also provide the Office with an affidavit or receipt demonstrating that the change was filed with the county clerk or recorder no later than the close of business on the day the change was filed with the Office (Rule 1.8.1(2)). 7. Within ten (10) days after your application is considered filed, you must publish four times in a newspaper of general circulation, in the locality of the proposed mining operation, the notice described in Rule 1.6.2(1)(d). 8. In addition, after the first publication you must mail or personally serve a copy of the notice described in Rule 1.6.2(1)(d) to all owners of record of surface rights to the affected land and all owners of record of lands that are within 200 feet of the boundary of the affected land (Rule 1.6.2(1)(e)). A copy of a form which includes all required information for the notice is attached for your use. 9. Prior to the Office making a decision (consideration ofthe application), you MUST submit a copy of the proof of publication from the newspaper and proof of all required notices. Proof of the notices may be by submitting copies of return receipts of a certified mailing or by proof of personal service (Rules 1.4.1(4), 1.4.2(4)(c), 1.6.2(1)(a)(ii), and 1.6.2(1)(g)). The copy of the application and any changes or additons placed at the office of the county clerk or recorder shall NOT be recorded, but shall be retained there for at least sixty (60) days after a decision on the application by the Office and be available for inspection during this period. At the end of this period, the application may be reclaimed by the applicant or destroyed (Rule 1.6.2(2)). APPLICATION REVIEW PROCEDURES: The Office shall approve or deny the application within ninety (90) days of filing unless the date for consideration by the Office is extended pursuant to Rule 1.8. The time for consideration shall not be extended beyond ninety (90) days after the last such change submitted. For complex applications, the review period may be extended an additional sixty (60) days. Please see Rule 1.1(10) for the definition of what constitutes a complex application. APPLICATION APPROVAL/DENIAL: If the requirements of the Act and Mineral Rules have been satisfied, the Office will approve the application. The Act also provides for automatic approval if no action is taken by the Office by the end of the review period. If the Act and Regulation requirements have not been satisfied, the Office will deny the application. If the Office denies the application, you may appeal to the Board for a final determination by submitting a written request for administrative appeal to the Board within 60 days of the decision date (Rule 1.4.7). PERFORMANCE AND FINANCIAL WARRANTIES: A performance warranty, and a financial warranty dollar amount determined during the application review process, must be submitted and approved by the Office PRIOR to permit issuance. A financial warranty should NOT be submitted until a decision on the application has been made. If the applicant is a unit of state or county government, then ONLY a performance warranty is required. Several different types of financial warranties are allowed by the law. Please review Rule 4.0 to determine which type of financial warranty you desire to use. You may obtain the appropriate warranty forms from the Office during the application review period. Please note that an application approval DOES NOT convey a right to begin operations. You MUST submit, and have approval of your performance and financial warranties, and receive your copy of the signed permit document PRIOR to beginning on -site mining activity. AUTOMATIC PERMIT APPROVAL: An automatic approval will occur where the Office fails to notify the applicant/operator that the application has been denied. This decision must be made ninety (90) calendar days from the date the application was determined to have been filed. However, the performance and financial warranties must be submitted and approved by the Office before the permit will be issued even if you receive an automatic approval. NO MINING OPERATIONS SHALL BEGIN UNTIL A PERMIT IS ISSUED (Section 34-32.5-109(1), C.R.S.). -iv - COMPLIANCE WITH OTHER LAWS: Compliance with the Act and Rules and Regulations of the Mined Land Reclamation Board DOES NOT relieve you of your responsibility to comply with all other applicable state and federal laws. We recommend that you contact the following agencies to determine whether you need to comply with their legal requirements: o The Colorado State Historical Preservation Office regarding properties of historical significance including the need for an archeological survey, procedures for requesting a file search, and inventory forms to identify structures. o Colorado Division of Water Resources with regard to water rights; Colorado Department of Health, Water Quality Control Division, with regard to the discharge of pollutants into the State waters; o Colorado Department of Health, Air Pollution Control Division, with regard to the need for a fugitive dust permit; o U.S. Bureau of Land Management or the U.S. Forest Service if the proposed operation will occur on federal lands; o U. S. Army Corps of Engineers regarding a dredge and fill (404) permit; and The County Planning Department for the county or counties in which your proposed operation is located. Section 34-32.5-109(3), C.R.S, requires a mining operator to be responsible for assuring that the mining operation and the post -mining land use comply with local land use regulations and any master plan for extraction adopted pursuant to Section 34-1-304, C.R.S. COMPLETION OF MINING: Upon completion of any phase of reclamation, you should consult Rule 3.1 for reclamation standards and 4.16 for details on how to request a reclamation responsibility release from the Board. STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 CONSTRUCTION MATERIALS REGULAR (112) OPERATION RECLAMATION PERMIT APPLICATION FORM CHECK ONE: ✓ There is a File Number Already Assigned to this Operation COLORADO DIVISION OF RECLAMATION MINING SAFETY Permit # MZ,g22 - 013 (Please reference the file number currently assigned to this operation) New Application (Rule 1.4.5) Conversion Application (Rule 1.11) Amendment Application (Rule 1.10) Permit # M - (provide for Amendments and Conversions of existing permits) The application for a Construction Materials Regular 112 Operation Reclamation Permit contains three major parts: (1) the application form; (2) Exhibits A -S, Addendum 1, any sections of Exhibit 6.5 (Geotechnical Stability Exhibit; and (3) the application fee. When you submit your application, be sure to include one (1) complete signed and notarized ORIGINAL and one (1) copy of the completed application form, two (2) copies of Exhibits A -S, Addendum 1, appropriate sections of 6.5 (Geotechnical Stability Exhibit, and a check for the application fee described under Section (4) below. Exhibits should NOT be bound or in a 3 -ring binder; maps should be folded to 8 1/2" X 11" or 8 1/2" X 14" size. To expedite processing, please provide the information in the format and order described in this form. GENERAL OPERATION INFORMATION Type or print clearly, in the space provided, ALL information requested below. 1. Applicant/operator or company name (name to be used on permit): Raptor Materials, LLC. 1.1 Type of organization (corporation, partnership, etc.): Limited Liability Company 2. Operation name (pit, mine or site name): Two Rivers Sand, Gravel & Reservoir Project 3 Permitted acreage (new or existing site) : 3.1 Change in acreage (+) 3.2 Total acreage in Permit area 4. Fees: 4.1 4.2 4.4 4.5 New Application New Quarry Application Amendment Fee Conversion to 112 operation (set by statute) 5 Primary commoditie(s) to be mined: sand 5.1 Incidental commoditie(s) to be mined: 1. 3. / lbs/Tons/yr 4. gravel earth products lbs/Tons/yr 2. 409.234 permitted acres acres acres $2,696.00 $3,342.00 $2,229.00 $2,696.00 application fee quarry application amendment fee conversion fee lbs/Tons/yr / lbs/Tons/yr 5. / lbs/Tons/yr 5.2 Anticipated end use of primary commoditie(s) to be mined: commercial urban & rurual infrastructure needs N/A 5.3 Anticipated end use of incidental commoditie(s) to be mined: 6. Name of owner of subsurface rights of affected land: Raptor Materials, LLC. If 2 or more owners, "refer to Exhibit O". 7 Name of owner of surface of affected land: Raptor Materials, LLC. 8. Type �e of mining operation: eration: Surface 1' Underground 9 Location Information: The center of the area where the majority of mining will occur: COUNTY: Weld PRINCIPAL MERIDIAN (check one): SECTION (write number): TOWNSHIP (write number and check direction) : RANGE (write number and check direction) : QUARTER SECTION (check one) : QUARTER/QUARTER SECTION (check one) : 6th (Colorado) 10th (New Mexico) s3 T4 R 66 i North East _ South West NE I " NW In SE r SW NE NW SE ' SW Ute GENERAL DESCRIPTION: (the number of miles and direction from the nearest town and the approximate elevation): 10. Primary Mine Entrance Location (report in either Latitude/Longitude OR UTM): Latitude/Longitude: Example: (N) 39° 44' 12.98" (W) 104° 59' 3.87" Latitude (N): deg min sec (2 decimal places) Longitude (W): deg nun sec (2 decimal places) OR Example: (N) 39.73691° (W) -104.98449° Latitude 40 .348174 (5 decimal places) P ) Longitude(W) -104 .776631 (5 decimal places) OR Universal Tranverse Mercator (UTM) Example: 201336.3 E NAD27 Zone 13 4398351.2 N s eci NAD27, NAD83 or WGS 84) N ad 83 Zone 13 UTM Datum (specify Easting Northing 11. Corresvondence reformation: APPLICANT/OPERATOR (name, address, and phone of name to be used on permit) Contact's Name: Kevin Jeakins Tide: Vice -President Company Name: Raptor Materials, LLC. Street/P.O. Box: 8120 Gage Street P.J. Box: City: Frederick State: Colorado Zip Code: 8°516 Telephone Number: (303 ) _ 666-6657 Fax Number: (303 ) .. 666-6743 PERMITTING CONTACT (if different from applicant/operator above) Garrett G. Varra Title: General Manager Contact's Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: INSPECTION CONTACT Contacts Name: Company Name: Street/P.O. Box: City: State: Telephone Number: Fax Number: Raptor Materials, , LLC. 8120 Gage Street Frederick P.O. Box: Colorado (303 )- 666-6657 (303 ) - 666-6743 Zip Code: 80°16 Garrett C. Varra Title: General Manager Raptor Materials, LL. 8120 Gage Street P.O. Box: Frederick Colorado (303 ) _ 666-6657 (303 ) s 666-6743 CC: STATE OR FEDERAL LANDOWNER if any) Agency: Street: City: State: Zip Code: 80516 Zip Code: Telephone Number: ( a CC: STATE OR FEDERAL LANDOWNER Of any) Agency: Street: City: State: Zip Code: Telephone Number: C ) r 4 12. Prima future (Post -mining) land use (check one): rcpland(CR) fl Pastureland(PL) El Rangeland(RL) r] Forestry(FR) El Residential(RS) flRection(R) Trif Developed Water Resources(WR) 13. Primary present land use (check one Cropland(R) Rangeland(RL) Residential(RS) Pastureland(PL) Forestry(FR) RecreationCR ) Developed Water Resources(WR) r General Agrictiiture(GA) Wildlife Habitat(WL) IndustrialJCommerci al(IC) n Solid Waste Disposal(WD) General Agricuiture(A) Wildlife Habitat(WL) Industrial/Commercial(1C) 14. Method of Mining: Briefly explain mining method (e.g, truck/shovel): Surface extraction, processing, and transport of aggregate resources until bedrock establishment of final basins is mplete. 15_ On Site Processing : 11717 Crushing/Screening 13.1 Briefly explain mining method (e.g. truck/shovel): In place extraction of unconselidate+d soil and aggregate by excavators, dozers, scrapers, or backhoes followed by transportation by conveyor or haul truck to a processing locations where material ps crushed, screened, end prepared and stockpiled for commercial sale and removal from property. All extracted materials may be utilized for either commercial purposes or on -site reclamation and development. List any designated chemicals or acid -producing materials to be used or stored within permit area: None 16. Description of Amendment or Conversion: If you are amending or converting an existing operation, provide a brief narrative describing the proposed change(s). N/A - Mans and Exhibits: Two (2) complete, unbound application packages must be submitted. One complete application package consists of a signed application form and the set of maps and exhibits referenced below as Exhibits A - S, Addendum 1, and the Cieotechnical Stability Exhibit. Each exhibit within the application must be presented as a separate section. Begin each exhibit on a new page. Pages should be numbered consecutively for ease of reference. If separate documents are used as appendices, please reference these by name in the exhibit. With each of the two (2) signed application forms, you must submit a corresponding set of the maps and exhibits as described in the following references to Rule 6.4, 6.5, and 1.6.2(1)(b): EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D EXHIBIT E EXHIBIT F EXHIBIT G EXHIBIT H EXHIBIT I EXHIBIT J EXHIBIT K EXHIBIT L EXHIBIT M EXHIBIT N EXHIBIT 0 EXHIBIT P EXHIBIT EXHIBIT R EXHIBIT S Rule 1.6.2(1)(b) Rule 6.5 Legal Description Index Map. Pre -Mining and Mining Plan Map(s) of Affected Lands Mining Plan Reclamation Plan Reclamation Plan Map Water Information Wildlife Information Soils Information Vegetation Information Climate Information Reclamation Costs Other Permits and Licenses Source of Legal Right -To -Enter Owners of Record of Affected Land (Surface Area) and Owners of Substance to be Mined Municipalities Within Two Miles Proof of Mailing of Notices to County Commissioners and Conservation District Proof of Filing with County Clerk or Recorder Permanent Man -Made Structures ADDENDUM I - Notice Requirements (sample enclosed) +eotechnical Stability Exhibit (any required sections) The instructions for preparing Exhibits A -S, Addendum I, and Geotechnical Stability Exhibit are specified under Rule 6.4 and 6.5 and Rule 1.6.2(1)(b) ofthe Rules and Regulations. If you have any questions on preparing the Exhibits or content ofthe information required, or would like to schedule a pre -application meeting you may contact the Office at 303-866-3567. Responsibilities as a Permittee: Upon application approval and permit issuance, this application becomes a legally binding document. Therefore, there are a number of important requirements which you, as a permittee, should fully understand. These requirements are listed below. Please read and initial each requirement, in the space provided, to acknowledge that you understand your obligations. If you do not understand these obligations then please contact this Office for a full explanation. I,. Your obligation to reclaim the site is not limited to the amount of the financial warranty. You assume legal liability for all reasonable expenses which the Board or the Office may incur to reclaim the affected lands associated with your mining operation in the event your permit is revoked and financial warranty is forfeited; VS. sts ‘4‘ Y.r 2. The Board may suspend or revoke this permit, or assess a civil penalty, upon a finding that the permittee violated the terms or conditions of this permit, the Act, the Mineral Rules and Regulations, or that information contained in the application or your permit misrepresent important material facts; 3. If your mining and reclamation operations affect areas beyond the boundaries of an approved permit boundary, substantial civil penalties, to you as permittee can result; 4. Any modification to the approved mining and reclamation plan from those described in your approved application requires you to submit a permit modification and obtain approval from the Board or Office; 5. It is your responsibility to notify the office of any changes in your address or phone number; 6. Upon permit issuance and prior to beginning on -site mining activity, you must post a sign at the entrance of the mine site, which shall be clearly visible from the access road, with the following information (Rule 3.1.12): a. the name of the operator; b. a statement that a reclamation permit for the operation has been issued by the Colorado Mined Land Reclamation Board; and, c. the permit number. 7. The boundaries of the permit boundary area must be marked by monuments or other markers that are clearly visible and adequate to delineate such boundaries prior to site disturbance. 8. It is a provision of this permit that the operations will be conducted in accordance with the terms and conditions listed in your application, as well as withthe provisions of the Act and the Construction Material Rules and Regulations in effect at the time the permit is issued. 9. Annually, on the anniversary date of permit issuance, you must submit an annual fee as specified by Statute, and an annual report which includes a map describing the acreage affected and the acreage reclaimed to date (if there are changes from the previous year), any monitoring required by the Reclamation Plan to be submitted annually on the anniversary date of the permit approval. Annual fees are for the previous year a permit is held. For example, a permit with the anniversary date ofJuly 1, 1995, the annual fee is for the period of July 1, 1994 through June 30, 1995. Failure to submit your annual fee and report by the permit anniversary date may result in a civil. penalty, revocation of your permit, and forfeiture of your financial warranty. It is your responsibility, as the pe . ettee, to continue to pay your annual fee to the office until the Board releases you from your total reclamation respo►ns b i l i ty . 10. For joint venture/partnership operators: the signing representative is authorized to sign this document and a power of attorney (provided by the partner(s)) authorizing the signature of the representative is attached to this application. 7 NOTE TO COMMENTORS/OBJECTORS: S/O ECToRS: It is likely there will be additions, changes, and deletions to this document prior to final decision by the Office. Therefore, if you have any comments or concerns you must contact the applicant or the Office prior to the decision date so that you will know what changes may have been made to the application document. The Office is not allowed to consider comments, unless they are written, and received prior to the end of the public comment period. You should contact the applicant for the final date of the public comment period. Ifyou have questions about the Mined Land Reclamation Board and Offices review and decision or appeals process., you may contact the Office at (303) 866-3567. Certification: As an authorized representative of the applicant, I hereby certify that the operation described has met the minimum requirements of the following terms and conditions: 1. To the best of my knowledge, all significant, valuable and permanent nnanemade structure(s) in existence at the time this application is filed, and located within 200 feet ofthe proposed affected area have been identified in this application (Section 34-32.5-115(4)(e), C.R.S.). 2. No mining operation will be located on lands where such operations are prohibited by law (Section 34-32.5-115(4)(i C.R.S., 3. As the applicantioperator, I do not have any extraction/exploration operations in the State ofColorado currently in violation of the provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials (Section 34-32.5-120, C.R.S.) as determined through a Board finding. 4. I understand that statements in the application are being made under penalty of perjury and that false statements made herein are punishable as a Class 1 misdemeanor pursuant to Section 18-8.503, C.R.S. This farm has been approved by the Mined Land Reclamation Board pursuant to section 34-32.5-I '2, R. '., of the Colorado Land Reclamation Actfor the Extraction of Construction Materials. Any alteration or modification °fats form shall result in voiding any permit issued an the altered or modified form and subject the operator to cease and desist orders and civil penalties, for operating without a permit pursuant to section 34-32.5-123, &. Signed and dated this 1 gstriA day of ital S , ev\A Applicant/Operator or Company Name Signed: Title: Kevin Jeakins, Vice -President State of County of tAi )ss If Corporation Attest (Seal) NO SEAL/NO CORPORATE SECRETARY - This is a Limited Liability Company Signed: The foregoing instrument was acknowledged before me this 4 % day of 20!2, by .e Viet dealt' ' A s as vP JESSICA HOOVER NOTARY PUBUC STATE OF COLORADO NOTARY ID 20044035571 MY COMMISSION EXPIRES OCTOBER 4, 2024 abs Corporate Secretary or Equivalent Town/City/County Clerk lake of €&04*or Make rs l,L My Commission expires: I DI 412 SIGNATURES MUST BE IN BLUE INK You must post sufficient Notices at the location of the proposed mine site to clearly identify the site as the location of a Pagel 6.4.12 EXHIBIT L - Reclamation Costs (1) 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. (2) 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: $ 12,427.45± Site Discharge $ 130,002.96± Total Grading per Extraction Front. $ 321,033.08± Total Liner Construction Expense $ 20,359.20± Total Re -soiling (inc. Processing area) $ 5,449.27± Total Re -vegetation Expense (inc. Processing area) $ 74,552.68± Total Processing/Conveyor Removal Expense $ 563,824.65± $ 10,000.00+ $ 573,924.65± $ 139,640.23± Sub -Total Possible Mobilization and Demobilization Costs (pending OMLR estimate) Sub -Total Direct Costs Possible Indirect Costs Pending DRMS Indirect Costs @ 24.335 % $ 713,464.87± of Total Reclamation Costs Grand Total - Financial Warranty Amount - Pending OMLR Review and estimates including estimated expenses for State of Colorado Mobilization and Demobilization and other `Indirect' cost determinations by the Office. SUMMARY OVERVIEW: Table 1 - Primary Data on Area of Total Proposed Affected Lands and Reclaimed Features: Entity Central Field North-West Field Combined Extraction — finished basin (Acres) 162.57 41.04 203.61 Static Water Area — surface (Acres) 151.38 36.28 187.66 Static Water Area — elevation (ft.) 4,673 4,675 Basin Level ( Lands Above h) Static Water 11.19 4.7 6 15.95 Basin Area Volume (cu.yds.) 7,278,366 1,649,937 8,928,303 Static Water Level Volume (Gallons) 1, 470, 040, 694 333, 244, 376 1, 803, 285, 070 Static Water Level Volume (Acre Feet) 4,511.4 1,022.7 5,534.1 Plant Processing Area (Acres) 15.76 Wash Pond Area (Acres) 5.60 Total Level Lands (Acres) Above Static Water 37.31 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I2 6.4.12 EXHIBIT L - Reclamation Costs NOTE Well: All lands within the 409.234± 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 on -set of Operations under this permit will not be reclaimed under the terms of this permit unless otherwise re -affected beyond their o riginal state. Public Lands and other easements and Right -of -Ways are offset from o perations and while they may fall within the 409.234± acre parcel — are excepted from the permit conditions to the extent of their approved setbacks. The following estimates utilize assumptions based upon the pre -disturbed state of the application 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 Colorado Office of Mined Land Reclamation (OMLR), as indicated. RECLAMATION EXPOSURE: 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 utilized to create a reasonably close estimate. The per unit basis from Division records are shown along with other sources used or referenced to determine unit costs, at the back of this exhibit. METHOD OF EXTRACTION: Before concurrent grading, resoiling, i ng, and revegetation for reclamation can commence, a perimeter keyway (dewatering trench') must first circumnavigate the area where the perimeter slopes form along the extraction limits. For Two Rivers, this includes four sequential areas of extraction: • 121.86± Acres - Central Field — Center Section • 15.58± Acres - Central Field — North-East Section • 25.09± Acres - Central Field - West Section • 41.04± Acres - North-West Field l Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I3 6.4.12 EXHIBIT L - Reclamation Costs Exhibit L: Financial Warranty Map, shows Initial Extraction will begin in the yellow hatch area shown on the Exhibit L Map, comprising 16± acres. The direction of extraction will follow the perimeter of the extraction limits in order to establish the perimeter keyway for the 121.86± acre Center Section of Central Field. The perimeter extraction comprises approximately 70.21± acres and will leave an approximately 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The initial extraction area is bordered to the South adjacent to a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). Extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed under Exhibit D: Extraction Plan. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary settling basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H :1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.00H:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and excise the bed dimensions where the resulting channel is sufficient to convey the groundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape and size presented. 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. UNITS OF DISTURBANCE: The life of the operation is based upon a base rate of extraction approximating 8.0± acres of disturbance in a given year. This time will pulse with the market and may average 8.0+ acres, but could be faster or slower. Starting out, initial warranty necessary to cover the costs of reclamation for the extent of disturbance in a given year will also vary in time and circumstance, as the initial disturbance is generally less at the onset. So, a rate of disturbance can be estimated and the warranty adjusted incrementally with time and circumstance. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I4 6.4.12 EXHIBIT L - Reclamation Costs Starting out in the initial projected 5 years of Operations, and incrementally thereafter, necessary warranty can be estimated and adjusted in incremental Units based upon the projected Life of the Operation. Essentially, a 28-33± year Life of Operations assumes a rate of extraction of approximately 8.0± acres per year. Considering the Mining -Regrading Schedule included as Table E-1 in Exhibit E, and the general development concept shown on Exhibit L: Financial Warranty Map, Raptor estimates for the initial 5 -year period, development of an initial 40 -acre excavation and development of a "Core" area in the Center Section of Central Field will result in creation of approximately 6,200 -foot of external perimeter pit wall. No reclamation or lining is anticipated in the initial 5 -year period. Raptor estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H:1 V and a 2,180 -foot wall at 1.25:1V slopes. It is important to note that the financial warranty estimates the closure cost of the operation at the end of the expected first 5 -year period. It is assumed in this initial estimate that no reclamation activities (regrading, lining, topsoiling) will take place. The cost estimate then reflects reclaiming the projected excavation at that point in time. The actual extents and shape of the excavation may change, and actual progress will be addressed in the annual reports. Raptor will update this Exhibit L, the reclamation cost estimate, and any other exhibits as required for purposes of determining financial warranty prior to disturbance reaching the limits projected in the initial 5 years of Operations as described in this Exhibit and shown conceptually on Exhibit map C-2 and L. In the following breakdown of components for estimating reclamation cost, factoring of the 5 -year projected disturbance against the final pits is used where appropriate to obtain a reasonable estimate of work required. 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: Raptor assumes that the pit would be in an unlined state and if operations had ceased, would recharge to static water level requiring dewatering of the pit to allow reclamation operations to be completed. 100 hp. 4,500 gal./min. pump x (up to) 3 pumps @ 24 hours/day VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I5 6.4.12 EXHIBIT L - Reclamation Costs Volumes: Total Central Field Volume at Static Water Level Area of Central Field at Static Water Level = Central Field average storage = For the initial 5 -year excavation: 1,470,040,694± gallons 151.38 surface water acres 9,710,931 gal./acre 917101931 gal ./acre x 40.0± acres 388,437,229± gallons Total Cost for initial 40.0± acres of Discharge = 388,437,229± ± gallons x $ 0.000026/gal. discharge (refer to Kurtz est. utilizing similar pump and rates.) $ 10,099.37 -Initial Discharge Cost for 40± acres It is assumed that ongoing dewatering will be required during reclamation of the pit and Raptor has allowed for 30 days once the pit has been dewatered. The estimated inflow rate to the fully excavated pits has been estimated at 15,190,000 gallons/day. The estimate is based on modeling of the groundwater by AWES in support of Exhibit G: Water Information. A memo summarizing the basis of the estimate is attached as a new addendum. The initial 40 -acre excavation area represents approximately 19.6% of total extraction area (203.acres). Total discharge to maintain dry conditions for reclamation then is: 15,190, 000 gallons/day x 19.6% x 30 days = 89,541681+ gallons Cost for 30 working days of Discharge = 89,541,681± gallons x $ 0.000026/gal. discharge (refer to Kurtz est. utilizing similar pump and rates.) $ 2,328.08 30 days Dewatering Cost for 40± acres $ 12,352.35 Total Dewatering Cost for 40± acres Please Note: 2The basins will be lined or otherwise segregated from the area groundwater, in order to liberate the water otherwise retained to supplement loss from evaporation in the unlined state. Adequacy Item 28 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I6 6.4.12 EXHIBIT L - Reclamation Costs GRADING: As stated above, Raptor conservatively estimates for Financial Warranty purposes an approximately 4,020 -foot wall excavated at 2H:1V and a 2,180 -foot wall at 1.25:1V slopes along the extraction limits flanking WCR 396; and 2H:1V along the South Platte River levee, as shown on Exhibit D: Extraction Plan, and Exhibit L: Financial Warranty Map. Actual volume of fill required to grade at 3H:1V for a respective cut slope is determined in the graphics, below. Square Foot volume of backfill x linear feet of slope divided by 27 will yield the required cubic yards needed for each section of highwall. A rate per Loose Cubic Yard of fill taken from the previously approved values determined by the OMLR, is used to better ensure the integrity of the resulting values. Fs' 211 0h _ Cato depth.F. 1 FILL TO GRADE 3H:1V FINISH= D GRADE fib 800 SQIFT. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I7 6.4.12 EXHIBIT L - Reclamation Costs 40.0'± depth RA 7 V eten, 1 `✓ INISI ED GRADE. FILL TO GRADE — 1,400 SQ. FT Hauls are expected to be very short excavating material from the core area where material is readily available to establish final grade on those walls at 3H:1V and placed on the exterior walls to establish the required grades. It is estimated that there would be approximately 4,610 -foot of core and side slopes in addition to the 6,200 -foot extraction limit wall. Due to the very short hauls it may only require a wheel loader operating in load/carry/dump mode with a supporting Tracked Dozer. At most, the method of fill will utilize one (1) Excavator/Loader, two (2) Haul Trucks, together with a supporting Tracked Dozer and one (1) Sheep's Foot Compactor. The concept for establishing the regraded slopes for financial warranty purposes is shown in the following figure. NW FIELD 41.04± ACRES C CENTRAL FIELD WEST SECTION INITIAL AREA OF EXTRACTION '1 Extraction Inmrt watt Malenal backfal►ed to -?.� reduce slope to 3H 'IV - - - ,,,« • Material excavated from -' anterior wall used as backlit' ate' ' on extracbon limit wall Interior wall material < excavated to reduce ;' slope to 3H:1V CENTRAL FIELD 162.56± ACRES GENERAL MINING PROGRESSION Interior wall Material excavated lo reduce slope to 3H:1V Mateiiul exrcavatud Irorn ; I ntenc% wall used as backlit' on extraction limit wail 1 • a M • For estimate of financial warranty reclamation cost material from interior walls is excavated reducing the slope to 3H:1V and that material is placed on the exterior extraction limit walls as backfill to establish 31.:11 slopes. CENTRAL FIELD CENTRAL SECTION NOTE WELL THE CORE AREA OF EXTRACTION MAY VARY IN SIZE. SHAPE AND EXTENT FROM THAT PORTRAYED DEPENDING UPON FIELD CONDITIONS I€CESSARY TO CIRCUMNAVIGATE THE KEYIVAY(S) WITHIN A DESIGNATED SECTION OR FIELD Intenar wall Material excavated to redu€e slope to 3H' IV • • • , Matonal ext_sleeted from intellor wall used aas backfill orl extractio1) limit Wall }�"2Hfl/Extraction fiini l wallMaternal back611ed to �`. c:t-`)r l reduce slope to 3H 1V iv cut sL0T:t /01,2 �.L•�rl#' GENERAL MINING PROGRESSIC*4 Exttactrnn limit wail „t�'• M.atenal I..facidlllied to rel."191,11 �2x - .,�rreduce slope to 3H 1V r r I, o actorsieltfors 2H -iv ("uT SLOPE Approach to regrading interior and extraction limit slopes for financial warranty purposes. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I8 6.4.12 EXHIBIT L - Reclamation Costs Assuming a mean depth of advancing cut of 1.25H:1V :1V at the extraction limits of 40.0+ feet depth: 2,180± lin.ft. (extraction limit) x 1,400.00± sq.ft. (required fill — Diagram 1, above) 113,037± LCY 113,037± LCY x $ 0.56± per LCY. $ 63,300.74± fill along an 2,180 -foot extraction limit cut at 1.25H:1 V. Assuming a mean depth of advancing cut of 2:1V at the extraction limits of 40.0± feet depth: 4,020± lin.ft. (extraction limit) x 800.00± sq.ft. (required fill — Diagram 1, above) 119,111± LCY 119,111± LCY x $ 0.56± per LCY. $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction limit cut at 2H:1V $ 63,300.74 Sub Total -Grading to 3H:1V along an 2,180 -foot extraction limit cut at 1.25H:1 V. + $ 66,702.22 Sub Total -Grading to 3H:1V along an 4,020 -foot extraction limit cut at 2H:1V. $130,002.96 Total - Initial Grading. Liner Installation: Raptor has made allowance for liner installation on the regraded slope. Assumptions are that a 4 -foot -thick liner will be keyed into bedrock at the base of the regraded slope and up the slope to approximately 5 -foot below the original surface elevation. The keyway dimensions in bedrock are assumed to be 4x4 -foot. For the exterior walls at extraction limits, the regrade and liner installation is as described in Exhibit E. For interior walls around the core, for the purposes of financial warranty estimate, regrading is performed as described above, and then the liner will be installed. Typical liner installation as described previously in Exhibit E is shown in the following figure. The volume of liner material required will vary according to the slope of the wall the liner is installed on. The volume of liner material is conservatively estimated based on the perimeter length at the top of the liner. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I9 6.4.12 EXHIBIT L - Reclamation Costs Typical Liner and Regrade for Extraction Limit Wall — Final Reclamation Original ground surface Topsoil Static Water Level Sequence 1. In cycles • Install liner in 6" lifts • Backfill to 3H:1V 2. Replace topsoil Regraded slope at 3H:1V Backfill material Unexcavated Perimeter Wall (slope 1.25H:1V) Typical Liner and Regrade for Extraction Limit Wall Raptor conservatively estimates for Financial Warranty purposes an approximately 4,020 - foot wall excavated at 2H:1V, a 2,180 -foot wall at 1.25:1V slopes, and a 4,610 -foot wall at 3H:1V. Perimeter liner at 2H:1V, 4,020 lin.ft. x 78 sq.ft./ft x 4 ft. / 27 = 46,610 CY of liner placed at an estimated cost of $2.20/CY = $ 102,541.11. Perimeter liner at 1.25H:1V, 2,180 lin.ft. x 56 sq.ft./ft x 4 ft. / 27 = 18,095 CY of liner placed at an estimated cost of $2.20/CY = $ 39,808.46. Perimeter liner at 3H:1V, 4,610 lin.ft. x 111 sq.ft./ft x 4 ft. / 27 = 75,590 CY of liner placed at an estimated cost of $2.20/CY = $ 166,298.33. Keyway at the base of the 3:1 slope is estimated at 9,500 lin.ft. x 16 sq.ft. / 27 = 5,630 CY of liner placed an estimated cost of $2.20/CY = $12,385.19. $ 321,033.08 Total Liner Installation Cost NOTE: This is a conservative approach to the estimation of reclamation cost for financial warrant at the projected 5 -year disturbance. The distance of 2H:1V wall is maximized which has a higher lining cost than wall at 1.25H:1V. Also, if sufficient backfill material were available or accessible on site from either topsoil or overburden material in temporary stockpiles, or readily accessible from bedrock exposed, backfilling all the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 10 6.4.12 EXHIBIT L - Reclamation Costs slopes with available material and installing the liner in typical fashion as described in Exhibit E would be significantly less expensive. Soil Demand AND Re -soiling of Affected Lands (refer to Exhibit D): Soil demand is limited to the cut basin slopes remaining above the static water level. For Central Field, the total area above the anticipated static water level of the basins is 11.19 ± acres. To estimate the area involved in resoiling the Center Section of Central Field — we'll use a percentage of the total perimeter length of the extraction limits involved: 14,311 Total perimeter length Central Field 6,200 External perimeter length Center —Central Field —extraction limits 4,610 Internal perimeter length on core area 10,810 Combined perimeter length 10,810 : 14,311 = 76% 11.19 acres x 76% = 8.5± acres requiring resoiling and revegetation (see Establishment of Vegetation over Affected Lands, below. At a depth of 0.5± feet, total volume = 8.5± acres x 0.5± feet of soil replacement, is: 8.5± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 6,857± cu.yds. @ 0.5' depth. The majority of soil placement can occur using the average placement distance of 600 ft., or less along embankments, (utilizing the same assumptions utilized at either Kurtz or Heintzelman Projects). 6,857± cu.yds of soil demand x $ 0.843 per LCY. $ 5,780.17to replace 0.5± feet of soil over the existing affected lands remaining above the anticipated final water level at the Center of Central Field along the perimeter cut slopes at the extraction limits. 3Although Raptor does not anticipate the areas of soil replacement to be extensively compacted, an allowance for disking or scarifying 25% of the area at a cost of $28.5/acre. 8.5± acres x 25% x $28.50/acre = $60.60 Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 11 6.4.12 EXHIBIT L - Reclamation Costs The processing area will also require soil replacement over the entire 21.35 acre area. 21.35± acres x 43,560.0± sq.ft./acre : 27 cu.ft./cu.yd. = 17,222± cu.yds. @ 0.5' depth. 17,222± cu.yds of soil demand x $ 0.843 per LCY. $ 14,518.43 to replace 0.5± feet of soil over the existing affected lands in the processing area. 4Raptor assumes disking or scarifying this entire area at a cost of $28.5/acre. 21.35± acres x 100% x $28.50/acre = $608.48 $ 20,359.20 Total Soil Replacement Cost NOTE: Total Soil Demand for the entire Central Field and the North-West Field: 11.19± Acres Central Field 4.76± Acres North-West Field 15.95± Acres Total — Combined Soil Replacement Demand 15.95± Acres x 43,560 sq.ft./acre : 27 cu.ft./cu.yd. = 25,732.67± cu.yds. @ 1' depth.25,732.67± cu.yds. @ 1' depth soil : 2 = 12,866.33± total cu.yds soil required at 6 inches in depth at Central and North-West Fields for all basin slopes remaining above the anticipated static water level and below the extraction limits. Establishment of Vegetation over Affected Lands: The demand establishment of vegetation over the affected lands will also diminish proportionately with the planned extraction of the Tracts. For now, the total exposure is estimated as indicated above to be 8.5± acres for the Center Section of Central Field (see Soil Demand): NOTE: The cost for seed is estimated on Exhibit L - Table L-1: Primary/Preferred Re - vegetation Seed Mixture; however, the costs are known to fluctuate seasonally — and are estimates based on prior seasons. The seed mixture includes a substitute for mulch in the inclusion of a wheatgrass hybrid. The Division has historically agreed with and approved the inclusion of this hybrid as a substitute for mulch. The Optional Seed Mix will be used if the Primary Mixture fails, but costs less, so that cost is accounted for. These costs are as follows: Adequacy Item 52 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 12 6.4.12 EXHIBIT L - Reclamation Costs $ 58.72± Preferred Seed Mix x 8.5± acres $ 499.12± Sub -Total Seed The cost for applying seed is based upon information derived in proximity to the Northern Colorado economy. Costs for tilling, fertilizing and seeding are based upon estimates from Longs Peak Equipment Co. These costs, including labor, are reflected as follows: $ 25.00± per acre Tilling $ 20.00± per acre Fertilizing $ 20.00± per acre Seeding $ 65.00± per acre Total Application Cost per Acre. x 8.5± acres $ 552.5± Sub -Total — Application Costs $ 1,051.62± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or $ 525.81± Sub -Total Re -seeding costs $ 1,577.43± Excavation Area Re -vegetation Expense Re -vegetation of the 21.35 acre processing area is also estimated. $ 58.72± Preferred Seed Mix x 21.35± acres $ 1,253.67± Sub -Total Seed $ 65.00± per acre Total Application Cost per Acre. x 21.35± acres $ 1,387.75± Sub -Total — Application Costs $ 2,641.42± Sub -Total Re -vegetation (seed + application) Costs. Assume a 50± percent failure and add half the expense back into the total for reseeding, or $ 1,320.71± Sub -Total Re -seeding costs $ 3,962.13± Processing Area Re -vegetation Expense $ 5,449.27 Total Re -vegetation Cost VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 13 6.4.12 EXHIBIT L - Reclamation Costs Processing Area and Decommissioning: Raptor has estimated decommissioning costs for the Processing Area and Conveyor that will deliver mined material to that area. All plant and equipment in the processing area is portable and would have more value that the cost of loading and removing it. Decommissioning will involve the removal of concrete pads for processing equipment, concrete supports for truck scales and temporary buildings, and the conveyor infrastructure and belting. Three 12 -inch -thick concrete pads are assumed in the processing area with dimensions 15- x 30 -feet, 15- x 60 -feet, and 15- x 25 -feet. Demolition and removal costs are estimated at $1.70/sq.ft. for 12" concrete pads. The truck scale will have concrete supports with an estimated volume of 10 CY. Additionally temporary buildings for the scale house/site entrance area and processing area will have concrete support blocks with estimated at 8 CY of concrete. Estimated costs for the concrete supports is $65.00/CY. Concrete pads: 1,725 sq.ft. x $1.70/sq.ft. _ $ 2,932.50 Concrete supports: 18 CY x $65.00/CY = $ 1,170.00 The decommissioning cost estimate for the conveyor structure is based on previous estimates provided by Divide Construction for other Raptor (previously Varra) operations and presented in Financial Warranty estimates. The costs have been updated to current using US Army Corps of Engineers Civil Works Construction Cost Index System (CWCCIS) indices. The regular conveyor structure in 40 -foot sections supported on concrete blocks is estimated to be 1,787± lin.ft. with an additional three extended span elevated truss sections 125 -foot in length for crossing WCR296 and the Big Thompson River. Decommissioning costs for the regular conveyor structure is estimated at $ 8.75/lin.ft. and the extended spans at $ 18,270.00 each. Conveyor decommissioning: 1,787± lin.ft. x $ 8.75/lin.ft. _ $ 15,640.18 Conveyor extended spans: 3 x $ 18,270.00 each = $ 54,810.00 $ 74,552.68 Total Processing and Conveyor Decommissioning Cost VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 14 6.4.12 EXHIBIT L - Reclamation Costs OTHER MISCELLANEOUS COSTS: 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 $10,000. Demolition of Structures: None. Building Permits for structures will be obtain where required from the Weld County Building Department. Please Note: Since there is no possibility of the applicant in fully reproducing the Division's methods, utilizing similarities from past OMLR 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. Extraction of the Core following completion of the Perimeter Extraction Keyway VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION American Water Engineering Services, LLC February 21, 2023 Raptor Materials, LLC 8120 Gage Street Frederick, Colorado 80516 Attn: Garrett Varra RE: Comments on Analytical Parameters 112C Permit Application Adequacy Review DRMS Letter Date February 14, 2023 Dear Mr. Varra: This letter provides responses to a review of the Groundwater Monitoring Plan generated by American Water Engineering Services, LLC (AWES) for the Raptor Materials, LLC (Raptor) mine located near Evans, Colorado. This letter is intended to address the issues raised in the Division of Reclamation, Mining and Safety (DRMS) letter dated February 14, 2303. The following summarize DRMS comments by item. 1. Comment 16 — Please amend section 2.2 of the plan to continue quarterly monitoring until the permit is terminated. The plan has been amended as recommended. 2. Comment 17 — Since the proposed operation clearly has the potential to impact groundwater, and groundwater at the site has not yet been classified, the Division will apply the Interim Narrative Standard from Reg. 41. At least one downgradient groundwater point of compliance will need to be established, where the standard will be applied. Typically the Division requires 5 quarters of water quality data prior to disturbance in order to establish baseline conditions, (without reliable baseline data the most restrictive parameter values from Tables 1-4 of Reg. 41 would apply). When evaluating a groundwater monitoring plan the Division typically looks for an analytical suite that includes the parameters from Tables 1-4, however the parameter list may be reduced if justification is provided. The parameters listed in Table 1 were based on a USGS study of the South Platte River basin which listed several trace metals detected in stream bed sediment and fish tissue. Those elements included As, Cd, Cr, Cu, Pb, Hg, Ni, Se and Zn. A comprehensive groundwater study was performed by the author and background levels of Mn, U, nitrate and sulfate exceeded current drinking water standards and those parameters were added to the list. I also included gross alpha particle activity due to the presence of uranium in groundwater and the high background levels of radon in the area. 3. Comment 18 — Please amend section 2.4 to specify that water monitoring data will be compiled into a report and submitted to the Division annually. Please also specify the date. The report should include the operator's analysis of the data, as well as the data itself. The plan has been amended to include recommended changes. J swifs 4ISCg Four Star Court, Fort Collins, CO S 424 - 41C-44C-3SC7 Groundwater Monitoring Plan Review Two Rivers Application February 21, 2023 Page 2 The majority of parameters (excepting sulfate and zinc) listed in Table 2 of Regulation 41 should be non -issues as the site is not located adjacent to any heavy industries and proposed mining activities cannot generate the parameters identified in Tables 1-4. If you have any questions or need additional information, please contact me at (970) 590-3807. Sincerely, AWES, LLC Joby Adams, P.G., REM Principal/Hydrogeologist -AJAWFS 4SCJ Four Star Court, Fort Collins, CC SC524 — HC-59C-3SC7 AMERICANWATERENGINEERINGSERVICES,LLC GROUNDWATER MONITORING PLAN RAPTOR TWO RIVERS MINE 14822 396 HWY EVANS, COLORADO AWES PROJECT # 2022-RM-P124 February 2023 1999' fi r Prepared for: Raptor Materials, LLC. 8120 Gage Street Frederick, CO 80516 Image-' Dat i_G/ 19,i 201'1 lat 10.31/131" Ion - IU'l. //2trhai.:' Orm.r't ,.'re alt 1'7 /I, 11 ' Prepared by: AWES, LLC 4809 Four Star Ct. Fort Collins, CO 80524 1016AWILS 4SC) Four Star Court, fort Collins, CO S 524 AWES, LLC Table of Contents 1.0 INTRODUCTION 1 1.1 Objectives 1 1.2 Background Information 1 2.0 GROUNDWATER MONITORING 1 2.1 Monitoring Well Installation 1 2.2 Groundwater Level Measurements 2 2.3 Chemical Analyses 2 2.4 Drawdown/Mounding Modeling 2 2.5 Contingency Plan and Abatement 2 3.0 ORGANIZATION AND STAFF ASSIGNMENTS 3 3.1 Project Personnel 3 3.2 Subcontractors 3 4.0 OVERVIEW - QUALITY ASSURANCE/QUALITY CONTROL 3 5.0 REMARKS 4 FIGURES Figure 1 - Site Location Map Figure 2 — Monitoring Well Location Map TABLE Table 1 Analytical Parameters APPENDIX Appendix A — Boring Logs Appendix B — Methods and Procedures AWES, LLC GROUNDWATER MONITORING WORK PLAN RAPTOR TWO RIVERS MINE PROJECT WELD COUNTY, COLORADO 1.0 INTRODUCTION This Groundwater Monitoring Plan (Plan) has been prepared by AWES, LLC on behalf of Raptor Materials, LLC (Raptor) for the proposed Two Rivers mine project located in Weld County, Colorado (Figure 1). The current mining plan includes dry mine gravel extraction from two pits that will encompass approximately 270 acres. This plan will be submitted to the Division of Reclamation, Mining and Safety (Division) as part of Raptor's mine permit application. 1.1 Objectives The objectives of this Plan are to identify potential liabilities with the extraction of aggregate under semi - saturated conditions. Specific objectives for the Raptor project are described below. • To determine the aerial extent of drawdown associated with mine dewatering; • To determine the effects of dry mine aggregate extraction on local hydrology and water quality; • To generate predictive models on possible adverse drawdown in adjacent domestic wells; and • To determine the effects of lined pit reclamation on the local groundwater flow regime. 1.2 Background Information The proposed gravel quarry is located in sections 3 and 4 of Township 4 North, Range 66 West and sections 33 and 34, Township 5 North, Range 66 West of the 6t" Principal Meridian. The surrounding land use consists of agricultural, rural residential and oil and gas gathering. The proposed mine area occupies an estimated 380 acres with an extraction area of 270 acres. The anticipated extraction depth will vary between 12 and 44 feet below grade. Information provided by geotechnical investigations, monitoring well water level data and water resource evaluation reports document the local and regional hydrogeology. In January 2015, 12 soil borings were drilled from ground surface to bedrock to determine the potential aggregate mass within the proposed mine boundary. These borings were completed as one -inch groundwater monitoring wells and the well locations are depicted on Figure 2. The depth to bedrock within the proposed mine pit boundaries varied between 12 and 44 feet below ground surface. In general soil conditions consist of less than one to six feet of top soil and sandy clay underlain by sand and gravel with occasional clay and poorly graded sand lenses. The coarse alluvial deposits are underlain by bedrock which consists of siltstone, sandstone and claystone. 2.0 GROUNDWATER MONITORING 2.1 Monitoring Well Installation As mentioned in January 2015, WesTest, LLC drilled 12 soil borings from ground surface to bedrock using hollow stem auger techniques and completed the borings as one -inch groundwater monitoring wells. The 1 AWES, LLC construction details of the monitoring wells were not reported in WesTest's summary report but are identified as one -inch monitoring wells by the operator. Boring logs are presented in Appendix A. 2.2 Groundwater Level Measurements All monitoring wells were surveyed to the nearest 0.01 foot for vertical elevation and to the nearest 0.5 foot for horizontal location. Groundwater level measurements in all wells have been measured by an electric water level indicator on a monthly basis since September 2015. Raptor will continue to measure water levels on a monthly basis during dewatering operations. After reclamation groundwater levels will be measured on a quarterly basis until the mine permit has been withdrawn. 2.3 Chemical Analyses Table 1 presents field parameters and laboratory analyses for samples obtained from one well selected as a compliance monitoring well. Water levels will be measured from all wells on a monthly basis. Five samples will be obtained from the compliance well on a quarterly basis will be analyzed for the parameters below to establish a baseline. The compliance well will be sampled annually thereafter. Table 1 —Analytical Parameters Parameter Analytical Method Units Water Standard Quality Frequency I Field Parameters pH Measurement Direct s.u. 6.5-9 Annual Specific Conductance Measurement Direct uS/cm N/A Annual Temperature Measurement Direct °F N/A Annual Water Level Measurement Direct Ft. N/A Monthly Laboratory Parameters Arsenic EPA 200.8 ug/L 10 5 quarters/annual Cadmium EPA 200.8 ug/L 5 5 quarters/annual Chromium EPA 200.8 ug/L 10 5 quarters/annual Copper EPA 200.8 ug/L 200 5 quarters/annual Lead EPA 200.8 ug/L 50 5 quarters/annual Manganese EPA 200.8 ug/L 50 5 quarters/annual Mercury EPA 200.8 ug/L 2 5 quarters/annual Nickel EPA 200.8 ug/L 100 5 quarters/annual Selenium EPA 200.8 ug/L 50 5 quarters/annual Uranium EPA 200.8 ug/L 30 5 quarters/annual Zinc EPA 200.8 ug/L 2000 5 quarters/annual Nitrate EPA 300 mg/L 10 5 quarters/annual Sulfate EPA 300 mg/L 250 5 quarters/annual Gross Alpha Particle EPA 900 pCi/L 15 5 quarters/annual Total Dissolved Solids EPA 160.1 mg/L Varied 5 quarters/annual AWES, LLC 2.4 Drawdown/Mounding Modeling Water level data will be used for drawdown and mounding analyses. The average of monthly water level data over a one year period will be input into the geostatistical software package Surfer®. Variations in pre - mining water levels will be presented on a two dimensional contour map and will be compared to numerical predictions and will be provided to the Division in an annual report which will be delivered during the first quarter after each sample year. All data and methods will be presented in the report. 2.5 Contingency Plan and Abatement As mine dewatering will create a groundwater sink it is highly unlikely that changes in groundwater quality will occur due to mining activities. As water levels will be measured on a monthly basis unanticipated groundwater drawdown can be predicted and evaluated for possible injury to off -site well owners. The extent of any abatement will be determined by negotiations with affected parties. 3.0 ORGANIZATION AND STAFF ASSIGNMENTS 3.1 Project Personnel Ms. Tana Kersting of Raptor will serve as field coordinator and will be responsible for obtaining water levels and will perform or supervise water quality sampling. Mr. Garrett Varra of Raptor will provide senior review of field and analytical data and will serve as project coordinator. 3.2 Subcontractors Subcontracted services for this project will include Technology Laboratories, Inc., of Fort Collins, Colorado who will perform analytical services. 4.0 OVERVIEW - QUALITY ASSURANCE/QUALITY CONTROL Quality assurance (QA) is a management system for ensuring that all information, data, and decisions resulting from the project are technically sound and properly documented. Quality Control (QC) is the functional mechanism through which quality assurance achieves its goals. Quality control programs, for example, define the frequency and methods of checks, audits, and reviews necessary to identify problems and dictate corrective action to resolve these problems, thus ensuring data of high quality. Thus, a QA/QC program pertains to all data collection, evaluation, and review activities that are part of the project. The use of qualified personnel for conducting various portions of the project is of paramount importance to an effective QA/QC program. This pertains not only to qualified QA/QC specialists, but also to specialists in other fields, including hydrogeologists, air quality specialists, soil scientists, analytical chemists and other scientific and technical disciplines. The project manager should ensure that qualified specialists, primarily individuals with the proper education, training, and experience, including licensed or certified professionals, are directing and performing the various project activities. The same general principles apply to selection of contractors and/or outside laboratories. Another important aspect of the QA/QC program is the communication between the QA/QC organization and the project manager. Regular appraisal by the project manager of the quality aspects related to the ongoing project data -gathering efforts provides the mechanism whereby the established objectives may be met. QA/QC procedures should provide details relating to the schedule, information to be provided, and the mechanism for reporting to the project manager. Reports to the project manager should include: 3 AWES, LLC • Periodic assessment of measurement data accuracy, precision, and completeness; • Results of performance audits; • Results of system audits; • Significant QA/QC problems and recommended solutions; and • Resolutions of previously stated problems. 5.0 REMARKS The scope of work is based upon current available information and our understanding of this project. As the project develops, changes to the project scope of work may be required. If changes in the scope of work are dictated by the needs of the project, these changes will be presented prior to implementation. This Groundwater Monitoring Plan was prepared by AWES, LLC. Date Joby L. Adams, P.G., REM Principal/Hydrogeologist 4 Figure 1- Site Location Map Varra Companies - Conrad Capital Group Property f l rl / II .a' r+" T i �". UN 4738 9 e: r / De 7-4 6b 4728 I • a *. 4723 - 4 ._ I II 1 MILE 0 1000 FEET 0 500 1000 METERS Map created with TGPO! ® ©2002 National Geographic (www_nai an.alea raphic _cooin'topci) ll p� 4727 * WOOS_ 47.0 43 4725 • w I` O s S`3 0 APPENDIX A SOIL BORING LOGS ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 1 LOGS OF BORINGS PROJECT: Two Rivers Property WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 2 REPORT DATE: February 12, 2015 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 3 0 5 10 15 20 25 30 35 40 45 50 50/4 50/5 W = 16.1 DD= 114.0 0 5 10 15 20 25 30 35 40 45 50 50/4 W = 15.9 DD = 108.8 #200 = 67.3 Qu = 11,090 0 5 10 15 20 25 30 35 40 45 50 0 ..u. 150/5 W=14.1 DD= 118.6 Qu = 18,440 FIGURE 2 ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 4 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 5 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 6 0 5 10 15 20 25 30 35 40 45 50 0 25/12 W = 21.1 DD = 105.2 0 5 10 15 20 25 30 35 40 45 50 #4=57 #10 = 36 #40 = 16 #200 = 5.9 #4 = 84 #10 = 60 #40 = 22 #200 = 1.9 ////////////// ////////////// 50/3 W = 20.1 LL=38 PI = 14 #200 = 88.4 0 5 10 15 20 25 30 35 40 45 50 0 • 4 ........................... ........................... 50/5 W = 15.6 DD = 115.9 Qu = 18,050 1 50/0 FIGURE 3 ST 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 7 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 8 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 9 0 5 10 15 20 25 30 35 40 45 50 #4 = 60 #10 = 30 #40 = 11 #200 = 3.8 2 0 50/4 0 5 10 15 20 25 30 35 40 45 50 0 Mat MIMMTNIT /%%%%%%%%%%%%i ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// V.......................... .......................... I' 50/3 0 5 10 15 20 25 30 35 40 45 50 #4=86 #10=61 #40 = 18 #200 = 4.1 d 50/6 W = 24.6 DD = 99.3 Qu = 4,120 FIGURE 4 �T25T 627 Sheridan Boulevard • Lakewood, CO 80214 303.975.9959 • office@westest.net Depth (ft.) Boring 10 LOGS OF BORINGS PROJECT: Two Rivers Property REPORT DATE: February 12, 2015 WesTest PROJECT NO.: 440515 CLIENT: Varra Companies LOGGED BY: Zachary Wheeler Depth (ft.) Boring 11 DATE DRILLED: January 27-30, 2015 DRILLER: Dakota Drilling Depth (ft.) Boring 12 0 5 10 15 20 25 30 35 40 45 50 U 150/3 0 5 10 15 20 25 30 35 40 45 50 0 ////////////// rrrrrrrrrrrrrr 11111111111111 rrrrrrrrrrrrr/ ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// "III", //////////////////////////////////////// /1/11/1/////// ////////////// ////////////// ////////////// ////////////// ////////////// ////////////// i _ ................... .................... .................... .................... i 50/3 0 5 10 15 20 25 30 35 40 45 50 #4 = 69 #10 = 55 #40 = 22 #200 = 2.7 0 50/4 FIGURE 5 627 Sheridan Boulevard • Lakewood. CO 80214 303.975.9959 • office@westest.net LEGEND AND NOTES TWO RIVERS PROPERTY PROJECT NO.: 440515 i X 0 0 Topsoil Overburden, silty sandy CLAY to silty SAND, TRACE GRAVEL, stiff, slightly moist to moist, light brown to dark brown SAND, occasional GRAVEL, loose to medium dense, slightly moist to wet, tan to brown SAND, with gravel, loose to medium dense, slightly moist to wet, tan to brown SAND, gravelly, medium dense, wet, tan to brown Silty clayey SAND, loose to medium dense, moist to wet, brown CLAY, soft to medium stiff, very moist to wet, brown SANDSTONE-CLAYSTONE-SILTSTONE BEDROCK, interbedded, hard to very hard, moist to very moist, gray to brown CLAYSTONE BEDROCK, very hard, moist to very moist, gray SANDSTONE-SILTSTONE BEDROCK, interbedded, hard to very hard, moist to very moist, brown to gray Indicates bulk sample location Indicates 2" Modified California Barrel Sample location (ASTM D 3550) Water level at number of days indicated Caved at number of days indicated W Indicates % moisture (ASTM D 2216) DD Indicates dry density (pcf) (ASTM D 7263) Qu Indicates unconfined compressive strength (psf) (ASTM D 2166) 50/4 Location of sample; indicates that 50 blows with a 140 pound hammer, falling 30 inches, were required to drive a 2 -inch diameter sampler 4 inches. The borings were drilled on January 27, 2015 through January 30, 2015, with a Longyear 66 Drill Rig and 4 1/4 I.D. Hollow Stem Augers. 2. The stratification lines represent the approximate boundary between soil types and the transition may be gradual. 3 4 The boring logs show subsurface conditions on the date and at the locations indicated. It is not warranted that they are representative of subsurface conditions at other locations and times within the project area. The boring locations were staked in the field by referencing to existing landmarks. The boring locations are adequate for purposes of this report, but should be considered as approximate for any other use. 5. Free water was encountered in the borings as indicated. Fluctuations in the water level should be anticipated. FIGURE 6 APPENDIX B METHODS AND PROCEDURES AWES, LLC METHODS AND PROCEDURES Groundwater Sampling All monitoring wells where groundwater is encountered will be sampled according to the protocols listed below. All pertinent information will be recorded on a sampling information form or field book. Field Protocol Step 1- Measure water level. Step 2 - A dedicated polyethylene bailer will be used to develop each well. Three well volumes will be evacuated from each well prior to sampling. Step 3 - Collect water samples. Water samples will be collected using a polyethylene bailer. Step 4 - Store samples in a cooler on ice for transport to the laboratory. Follow all documentation and chain - of -custody procedures. Step 5 - Clean equipment. Water level measurement equipment will be cleaned with ethanol followed by a deionized water rinse. Upon completion of soil or groundwater sampling, a chain of custody log will be initiated. A copy of the chain of custody will be returned to the project manager. Chemical Analysis All analytical parameters are presented on Table 1. Groundwater Elevation Measurements The following outlines our standard groundwater quality sampling methodology. Before purging any of the soil test borings or monitoring wells, water level measurements must be taken. Measuring Point Establish the measuring point for the well. The measuring point is marked on the north side of the top of the monitoring well riser. The top of the riser is normally a one or two inch casing inside a locked protective casing. The riser will generally be PVC pipe. The measuring point should be described on the groundwater sample collection record or field book. Access After unlocking or opening a monitoring well, the first task will be to obtain a water level measurement. Water level measurements will be made using an electronic water level indicator. Depth to water and total depth of the well will be measured for calculation of purge volume. AWES, LLC Measurement To obtain a water level measurement, lower a decontaminated electronic water level probe into the monitoring well. Care must be taken to assure that the electronic probe hangs freely in the monitoring well and is not adhering to the well casing. The electronic probe will be lowered into the well until the audible sound of the unit is detected and the light on the electronic sounder illuminates. At this time, the precise measurement should be determined by repeatedly raising and lowering the probe to obtain an exact measurement. The water level measurement is then entered on the groundwater sampling collection record sheet or field book to the nearest 0.01 feet. Decontamination The electronic probe shall be decontaminated immediately after use by wiping with isopropyl alcohol -soaked paper towels. If applicable always proceed in order from the suspected cleanest well or soil test boring to the suspected most contaminated one. Purge Volume Computation All monitoring wells will be purged prior to sample collection. Depending upon the rate of recovery, three to five volumes of groundwater present in a well or bore hole shall be withdrawn prior to sample collection. If a well or bore hole bails dry, the well or bore hole should be allowed to recharge and a sample taken as soon as there is sufficient volume for the intended analysis. The volume of water present in each well or bore hole shall be computed using the two measurable variables, length of water column in soil boring or monitoring well and diameter. Purging and Sample Collection Procedures Bailing • Obtain a laboratory decontaminated disposable bailer and a spool of nylon rope or equivalent bailer cord. Tie a bowline knot or equivalent through the bailer loop. Test the knot for adequacy by creating tension between the line and the bailer. Tie again if needed. New rope will be used for every sample or purge. New clean latex gloves will be used when touching the rope or bailer. • Spread a clean plastic sheet near the base of the well. The plastic sheet should be of sufficient size to prevent bailer or bailer rope from contacting the ground surface. • Place the bailer inside the well to verify that an adequate annulus is present between the bailer and the well casing to allow free movement of the bailer. • Lower the bailer carefully into the well casing to remove the sample from the top of the water column, taking care not to agitate the water in the well. • Pour the bailed groundwater into a bucket. Once the bucket is full, transfer the water to a barrel and contain on -site. If no regulated substances are suspected the evacuated water can be poured on the ground if local regulations allow. AWES, LLC • Raise the bailer by grasping a section of cord, using each hand alternately. This bailer lift method will assure that the bailer cord will not come into contact with the ground or other potentially contaminated surfaces. Sampling Instructions for obtaining samples for parameters are reviewed with the laboratory coordinator to insure that proper preservation and filtering requirements are met. • Appropriate sample containers will be obtained from the contract laboratory. After samples are collected, they will be put on ice in coolers (4°C). Care will be taken to prevent breakage during transportation or shipment. • Samples collected by bailing will be poured directly into sample containers from bailers. The sample should be poured slowly to minimize air entrapment into the sample bottle. During collection, bailers will not be allowed to contact the sample containers. • Upon completion of sampling a chain -of -custody log will be initiated. Chain -of -custody records will include the following information: project name and number, shipped by, shipped sampling point, location, field ID number, date, time, sample type, number of containers, analysis required and sampler's signature. The samples and chain -of -custody will be delivered to the laboratory. Upon arrival at the laboratory the samples will be checked in by the appropriate laboratory personnel. Laboratory identification numbers will be noted on the chain -of -custody record. Upon completion of the laboratory analysis, the completed chain -of -custody record will be returned to the project manager. Field Cleaning Procedures For all equipment to be reused in the field, the following cleaning procedures must be followed: • Disassemble the equipment to the extent practical. • Wash the equipment with distilled water and laboratory -grade detergent. • Rinse with distilled water until all detergent is removed. • Rinse the equipment with isopropyl or methanol, making sure all surfaces, inside and out, are rinsed. • Triple rinse the equipment with distilled water. Laboratory Selection The project manager should consider the following factors when selecting a laboratory: • Capabilities (facilities, personnel, instrumentation), including: • Participation in interlaboratory studies (e.g., EPA or other Federal or State agency sponsored analytical programs); • Certifications (e.g., Federal or State); • References (e.g. other clients); Experience. • Turnaround time; and • Technical input (e.g., recommendations on analytical procedures). AWES, LLC The project manager is encouraged to gather pertinent laboratory -selection information prior to extensively defining analytical requirements under the project. A request may be made to a laboratory to provide a qualifications package that should address the points listed above. Once the project manager has reviewed the various laboratory qualifications, further specific discussions with the laboratory or laboratories should take place. In addition, more than one laboratory should be considered. For large-scale investigations, selection of one laboratory as a primary candidate and one or two laboratories as fall -back candidates should be considered. The quality of the laboratory service provided is dependent on various factors. The project manager should be able to control the quality of the information (e.g., samples) provided to the laboratory. It is extremely important that the project manager communicate to the laboratory all the requirements relevant to the project. This includes the number of samples and their matrices, sampling schedule, parameters and constituents of interest, required analytical methodologies, detection limits, holding times, deliverables, level of QA/QC, and required turnaround of analytical results. Field and Laboratory Quality Control General Quality control checks are performed to ensure that the data collected is representative and valid data. Quality control checks are the mechanisms whereby the components of QA objectives ore monitored. Examples of items to be considered are as follows: 1. Field Activities: • Use of standardized checklists and field notebooks; • Verification of checklist information by an independent person; • Strict adherence to chain -of -custody procedures; • Calibration of field devices; • Collection of replicate samples; and • Submission of field blanks, where appropriate. 2. Analytical Activities: • Method blanks; • Laboratory control samples: • Calibration check samples; • replicate samples; • Matrix -spiked samples; • "Blind" quality control samplers; • Control charts; • Surrogate samples; • Zero and span gases; and • Reagent quality control checks. Page Ii 6.4.5 EXHIBIT E - Reclamation Plan (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. Operators/Applicants are encouraged to allow flexibility in their plans by committing themselves to ranges of numbers (e.g., 6"-12" of topsoil) rather than specific figures. (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: (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 e ar thmoving; (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; (c) A description of how the Reclamation Plan will be implemented to meet each applicable requirement of Rule 3.1; (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, fortis, 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; (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(1)(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; VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 12 6.4.5 EXHIBIT E - Reclamation Plan (ii) A description of the size and location of each area to be reclaimed during each phase; and (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.) (f) A description of each of the following: (I) Final grading - specify maximum anticipated slope gradient or expected ranges thereof; (ii) Seeding - specify types, mixtures, quantities, and expected time(s) of seeding and planting; (iii) Fertilization - if applicable, specify types, mixtures, quantities and time of application; (iv) Revegetation - specify types of trees, shrubs, etc., quantities, size and location; and (v) Topsoiling - specify anticipated minimum depth or range of depths for those areas where topsoil will be replaced. Acknowledged. Rule 6.4.5(1) is an advisory statement, the particulars of which are provided for, below. MISSION STATEMENT: Utilizing Resource Recovery of Sand and Gravel as a Method of Conservation to Establish DEVELOPED WATER RESOURCES; and to function as a Foundation for the implementation of other beneficial Multiple End -Uses over the Property. Reclamation and Development of the Property over Time. The majority of sand, gravel and other earth product demand, like water, is the consequence of market forces resulting from urbanization. The commercial, industrial, transportation, and other land use matrixes arise to support and sustain a growing residential population. Governments count the roof tops for they rely upon public and commercial revenue to sustain the roads, schools, water supply and infrastructure needed to secure it. With continued growth of human habitat and development in Colorado, the products that make possible the construction and maintenance of it all, comes from the ground. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 13 6.4.5 EXHIBIT E - Reclamation Plan Unconsolidated aggregate deposits simply must be taken where they are formed. The aggregate resource must be recovered from undeveloped locations first, before those locations are overtaken by ever expanding urban development; or it is lost. Now is the time and this is the geologically determined and economically feasible location from which the proposed extraction activity must occur. Hence, the Two Rivers Sand Gravel and Reservoir Project. Underlying earth resources are too often squandered when human development occurs in advance of resource extraction and recovery. Extraction and resource recovery are required by Colorado law to occur in advance of development where sand and gravel deposits are present. The resource is 'recovered' to benefit inevitable and unrelenting human habitat and infrastructure expansion, while providing a more enduring indigenous buffer to the very impacts it serves. The extraction of aggregate resource is in fact resource conservation. Beyond that, it is an essential social asset. Without earth products, transportation maintenance costs increase as infrastructure begins to fall apart. Industries begin to shrink, along with correlated revenues for state and local governments. Impacts would likely spread downstream from there, degrading schools and everything else dependent upon government revenue, as taxes increase to make up the difference. Affected populations would likely begins to flee an ever-increasing tax burden, further depreciating home values while accelerating loss of revenues from ever diminished home valuations, loss of businesses, jobs, and ultimately the very infrastructure itself. Without earth products, the economic engine and quality of life for everyone, begins to unravel. The secondary and enduring benefit of mineral extraction is in the reclamation and restoration of extracted lands. Extraction of aggregate resources is comparatively temporary and transitional by its very nature. 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. While residential, commercial, and industrial development will eventually be inspired by economic forces over portions of the Two Rivers property; the primary end use will be the creation of essential Developed Water Resources. An understanding of the vital importance of aggregate resources to the people of Colorado is not new, but well established; and protected. It remains the stated duty of any governing body in Colorado to aid in the lawful recovery of these vital mineral resources under Title 34. Section 22-5-80 of Weld County's Code of Regulations is consistent with Colorado law, both of which require that this resource must be recovered prior to other development which would otherwise impede access to it. Municipalities are obligated for the sake of their citizens to assert the same. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 4 6.4.5 EXHIBIT E - Reclamation Plan The subsequent development of a diverse multiple land use potential at this location, when complemented with sound environmental parameters, as advanced under this application and the attending OMLR permit exhibits, is in keeping with the spirit and intent of the policies and goals of the State of Colorado, Weld County, and the Towns of Evans and Milliken. Approval of the application will allow the resource to be accessed and utilized in a responsible and orderly manner as required under both Colorado law, and consistent with local County and Municipal Regulations. Specific Reclamation Elements and Methods: This application provides substantial detail of features utilizing aerial photography that is ortho-rectified to approximately 1.0± percent of surveyed accuracy. This highly accurate and detailed portrayal of planned extraction and reclamation is visible under Exhibit C-1: Existing Conditions, Exhibit C-2: Extraction Plan Map, and Exhibit F - Reclamation Map. How reclamation will occur over affected lands is further detailed under Exhibit L - Reclamation Costs. As extraction progresses over the Fields south of the Big Thompson River, the resulting 1.25H:1V slopes (2H:1V, where indicated) created during extraction will be concurrently modified when and where practical. Concurrent reclamation is a natural incentive for Operations to speed site recovery while generally serving to lower attending financial warranty burdens. The cut slopes along the extraction limits perimeter will be finish graded by methods including pushing the resulting pit bottom with a dozer upslope, excavation, hauling and placement of pit bottom material as backfill, or backfilling using previously excavated surplus material of limited or low market value until the resulting basin slopes conform with Rule 3.1.5(7). Since the primary end use is Developed Water Resources, the basins are intended to hold waters based upon the rights assigned by decree, or as stipulated in regulatory compliance with the Colorado Division of Water Resources, Office of the State Engineer (OSE). This may include the need to augment water sufficient to cover the anticipated exposed groundwaters of the basins in the unlined state. The entire unlined basin is or will be sufficiently covered under an approved substitute supply plan. In order to again liberate waters set aside for augmentation, the basins will at some point in the life of the activity be lined to segregate the basin from Colorado groundwaters. Lining of basins involves the placement of low permeability compactable fill, from on -site or other suitably sourced geologic materials, into the keyway (dewatering trenchl); the same keyway used to facilitate discharge to keep the basins dry and 1 Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page IS 6.4.5 EXHIBIT E - Reclamation Plan 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 it meets 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 OMLR on receipt; or as part of any request for release of the permit, in part or whole. Essentially, the pushed parent rock material will form the minimum 3h:lv slopes of the basin and be compacted to a permeability of 10 6; forming a lined basin that complies with Colorado Water Law and Guidelines mentioned, above. In this manner, the lined basins will maintain a required separation and accounting of stored water from the underlying ground waters. Evidence of compliance with the rules and regulations of the Colorado Division of Water Resources will be provided to the OMLR on completion of the lined basins. 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 claystone, 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 would be available from the temporary topsoil stockpile location in the North-East Section of Central Field. Other materials encountered within the sand and gravel deposit during excavation would be 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 South Platte river provides high confidence in the availability of suitable materials within the extraction area. The liner will be progressively constructed once the pit is developed sufficiently 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 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.5 EXHIBIT E - Reclamation Plan 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 3:1 or shallower slope. 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 the Figure 1 below. Typical Liner and Regrade for Extraction Limit Wall — Final Reclamation Original ground surface Topsoil Static Water Level Sequence 1. In cycles • Install liner in 6" lifts • Backfill to 3H:1V 2. Replace topsoil Regraded slope at 3H:1V Unexcavated Perimeter Wall (slope 1.25H:1V) Bedrock Figure 1: Typical Liner and Regrade for Extraction Limit Wall Backfill material 2A Backfill Notice is included with this application as an Addendum at the back of Exhibit E - Reclamation Plan, to facilitate the fill of portions of the extracted lands for final end -use potentials beyond water storage, which may include residential, commercial or industrial structures or uses otherwise approved, now or in the future, by Weld County, Colorado; or a Colorado municipality, as applicable. The extent and nature of the water storage basin represents the maximum build -out respective of optimal extraction of commercial product and resulting final slopes. As part of reclamation, lands situated above the anticipated final water level of the completed basins, and within 10.0± feet below the anticipated final water 2 Adequacy Item 28: Paragraph removed as proposed post mining land use is lined water storage. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 17 6.4.5 EXHIBIT E - Reclamation Plan level of the basins, will be graded to 3H:1V, or flatter. Lands below 10.0± feet from the anticipated final water level of the basins will also be graded to 3H:1V, or flatter, unless 2H:1V slopes are otherwise approved by subsequent permit revision. Naturally occurring or previously established slopes may exceed 2H:1V where not otherwise affected by extraction activities and may not be altered as part of reclamation unless necessary to facilitate the reclamation of affected lands. All affected lands between the extraction limits and remaining above the anticipated high-water mark of the basins will be capped with a minimum of six (6.0±) inches of soil, as supported by Exhibit I & J - Soils and Vegetation Information. Timing and use of soil are detailed further under Exhibit I & J - Soils and Vegetation Information and Exhibit L - Reclamation Costs. Where compacted lands exist, and are to be revegetated, those locations will be ripped prior to re - soil application. There are no known areas of compaction at the time of this application which would require such activity; and ripping remains a contingency of the application. The final land configuration will ultimately result in two (2) reservoir basins totaling 203.61± surface acres, with a static water elevation surface area of 187.66± acres (refer to Exhibit F: Reclamation Map). The balance of unoccupied affected lands above the anticipated static water level will be stabilized where necessary utilizing the seed mixture as shown under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. Lands not otherwise occupied for developed water resources will be later developed to the highest possible end -use, and will likely comprise a mixed use which may include other general agricultural uses as well as light residential, commercial or industrial uses. The Primary Revegetation 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. Should post resource recovery land development be deferred, or even negated, all affected land remaining above the anticipated final water level of the resulting ponds will be stabilized with a diverse and durable cover of predominantly native grasses. This is compatible with, and an improvement over the diminished lands located in the floodplain of the two rivers, and area monocultures of residential bluegrass lawns and surrounding cropped land. 'Generally, warm and cool seed mixtures can be treated in a myriad of ways. In Table L-1 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, 'Adequacy Item 33 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 18 6.4.5 EXHIBIT E - Reclamation Plan exceptions may apply. Some argue warm season grasses are better broadcast, while others like them drilled with the cool season grasses. Combined with the creation of waterfowl habitat, the baseline reclamation plan provided for under this submittal will provide less fragmentation of the area ecology than what may otherwise exist or transpire. As such, the operation will result in immediate and enduring positive impacts to area habitat as a long-term beneficial buffer against continued developmental impacts to the river ecosystem. Consistent with previous discussions with conservationists from the Division of Wildlife; operations will result in a desirable establishment of irregularities for the finished reservoirs. For example: The basin irregularities will be provided for, both by direct concurrent grading, post mine landform grading and establishment, and use of fill from excess or residual materials and reject fines from the operations. Shallower locations due to variations in site geology may allow for the creation of other shoreline features through the placement of fill. Due to the unpredictable nature of the anticipated geology [actual depth of material and type will vary - extraction and pond depths are approximated typical maximum extent] and other factors, it is a near misrepresentation to forecast the final appearance of the ponds, as it creates an unrealistic expectation in a regulated environment on the minds of various regulating agents, the general public, and on Operations. Simultaneously, setting false expectations about the final appearance of the ponds, beyond that already portrayed, will drain flexibility from Operations essential to the creation of more desirable effects, while simultaneously exerting pressure for needless and on- going revisions to the permit. It should be remembered that the Annual Report to the OMLR will provide a graphic record of this effort. Since the pace occurs over many years, there is ample time for reflection and analysis of the effort. Time and timing will also come into play respective of materials to be used as fill. The utilization of fill is dependent upon the space available for deposition over completed areas of extraction in relation to the rate of creation of reject fines and or other deposit materials. Other influences will be the attending space for stockpiling, uses, or market conditions for fill material. Some locations will be more advantageous to fill at a given point in time than others, and the attending circumstances cannot be reasonably anticipated. The random nature of this limitation will actually aid in furthering the establishment of preferred non -geometric patterns of the finished ponds. Exhibit F - Reclamation Plan Map, represents the regulated base for which reclamation must be judged as adequate for release. At the very least, the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 19 6.4.5 EXHIBIT E - Reclamation Plan basins delineated under Exhibit F - Reclamation Plan Map, provide desirable shoreline irregularity and slopes in conformance with existing statutory requirements. Anything more is a bonus, for everyone, and every opportunity will be made to take advantage of it, as stated above. Since the creation of aesthetic effects, edge effect, and other natural landforms, remain subjective and empirical, the stated intentions and any resulting efforts to achieve such effects, beyond those identified in the approved seed mixture and as portrayed in Exhibit F - Reclamation Plan Map, is commendable, and to be encouraged. Placement of soil and initial stabilization of affected lands with a stabilizing cover of grasses will better assure a foundation for later vertical development and establishment of cover; whether resulting from natural invasion or direct planning of trees, shrubs, and forbs. By themselves, the grasses will provide a stable foundation for later enhancements, while visibly improving wildlife habitat by interrupting area monocultures. While end use development beyond that already described cannot be fully determined or detailed at this time, the trend toward continued residential, commercial and industrial development is self- evident on surrounding lands. Although the establishment of native grasses is a primal requirement under this permit, the incorporation of forbs, shrubs and trees remains at the discretion of the landowner. Markets and the inherent values of the landowner to enhance the multiple end use worth of the property will serve to encourage the vertical development and diversity of the area vegetation with the contribution of forbs, shrubs, and trees. The purpose is to add cover, food source for wildlife and pollinators, and stratified creatures that will come to inhabit and depend upon the natural configuration, character and extent of the finished landform and diverse stabilizing cover. It should also be kept in mind that extraction is occurring within an area formerly occupied by monocultural crops, The cottonwoods along the lower terrace of the two rivers will be preserved in the majority. A light culling of a few cottonwoods may occur to assure the integrity of the intended conveyor line and wash basin; or as needed to assure the protection of personnel. The riverine areas will otherwise remain untouched, further complementing the utility of the reclaimed and restored expanse. Whatever long-term development occurs at the location, and on surrounding lands, resource recovery and correlated reclamation at this location will tend to direct human densities away from the two rivers. The reduced densities will produce direct and indirect long-term wildlife benefits and diverse multiple end -use potentials involving inherent wetland development, water resources development, water fowl improvement, and other desirable effects. The long-term worth of this effect will serve to VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 110 6.4.5 EXHIBIT E - Reclamation Plan increase the other long-term values for everyone in the area communities formed by the towns of Evans and Milliken; and greater Weld County. The final acreage of land remaining for development relative to surface acres of resulting ponds is illustrated on the following Exhibit F - Reclamation Plan Map. The map details the post resource recovery land form establishment. The size of the resulting basins is a function of area geology and available resource relative to man-made obstructions that serve to prohibit a greater linkage. 4Exhibit F presents Raptor Material's current expectation of the remaining above- ground and underground structures within the Affected Area at the point the reclamation of mining related disturbance is complete. Any revisions, additions, or modifications to this forecast of what may be the outcome of mining and reclamation operations some 30-35± years from now will be updated on required Annual Reports, or by Technical Revision, as warranted, or as otherwise directed consistent with Colorado Statute. The estimated timetable for extraction, commencing approximately spring to winter 2023; is estimated to take 23-28± years combined, or longer, followed by an additional five years to complete reclamation; or a total estimated life of the mine of 28-33± years; ending approximately winter 2051 to 2056. This is a life of the mine operation and all timetables are estimates and may prove shorter or longer than stated. The final determination will occur five years after the deposit is exhausted and all marketable product has been removed and necessary infill completed at the location to the point of final reclamation as approved or modified under the terms of the permit is completed. Table E-1 provides a projection of mine development and regrading/reclamation. The plan as described in Exhibit D and above in this Exhibit E, is a forecast and may vary according to market conditions with mining and subsequent regrading occurring faster or slower, sometimes significantly so. The geology may also dictate changes in the rate of extraction. If efficiency demands in a higher production demand scenario, separate areas could be developed in the manner described in Exhibit D simultaneously. Such changes may happen quickly and would be addressed in the Annual Report. Miscellaneous considerations: Fertilizer may be utilized as part of revegetation efforts. The need for fertilization and any subsequent fertilizer rates will be determined based upon soil tests taken at the time of reapplication of salvaged soil 4 Adequacy Item 41 5 Adequacy Item 29 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page i 11 6.4.5 EXHIBIT E - Reclamation Plan to affected lands remaining above water level. Status of fertilization and soil test results can be included in OMLR Annual Reports, as warranted. Refer to Exhibit I - Soils Information. Weed Control may involve a mix of mechanical or benign vinegar -based sprays as control methods. A detailed plan to control weeds is described in Exhibit I/J. Treatment and control of noxious or nuisance weeds will be reported in OMLR Annual Reports as warranted. A Backfill Notice follows this page. The flexible use of inert fill will facilitate the timely reclamation of affected lands. Continued ...next page... VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 12 6.4.5 EXHIBIT E - Reclamation Plan 6Table E-1 - Two Rivers Mining -Regrading Schedule Mining -Regrading Schedule Years Schedule 1-5 6-10 11-15 16-20 21-25 26-30 31-35 Area (ac) Area Mined (ac ±) Central Field Center Section 121.9 40.0 40.0 30.0 11.9 North-East Section 15.6 10.0 5.6 West Section 25.1 20.0 5.1 North West Field 41.0 2.5 34.9 3.6 Total 203.6 40.0 40.0 40.0 40.0 40.0 3.6 0.0 Length (ft) Pit wall Created (ft ±) Central Field 14,311 6,200 2,800 2,800 2,511 North West Field 6,672 1,000 5,672 Total 20,983 6,200 2,800 2,800 3,511 5,672 0 0 Length (ft) Pit wall Regraded (ft ±) Central Field 14,311 3,200 3,200 3,600 4,311 North West Field 6,672 489 5,400 783 Total 20,983 0 3,200 3,200 3,600 4,800 5,400 783 Length (ft) Pit wall Remaining (ft ±) Central Field 14,311 6,200 5,800 5,400 4,311 0 0 0 North West Field 6,672 0 0 0 1,000 6,183 783 0 Total 20,983 6,200 5,800 5,400 5,311 6,183 783 0 6 Adequacy Item 29 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 1 13 6.4.5 EXHIBIT E - Reclamation Plan BACKFILL 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 inert materials used for backfilling will be consistent with OMLR 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 OMLR 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 Office of Mined Land Reclamation 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 allowed under this application or locally approved land uses. The location and extent of fill utilized over extracted lands will be designated in required OMLR Annual Reports, permit revision, or as part of any request for release of the permitted area, in part or whole. I, Garrett C. Varra, hereby attest that the material to be utilized as inert fill in the area described as the Two Rivers Sand, Gravel and Reservoir Project; is clean and inert as defined in Rule 1.1(20), of the OMLR Rules and Regulations. Garrett C. Varra, General Manager Raptor Materials LLC VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I1 6.4.4 EXHIBIT D — Extraction Plan The mining plan shall supply the following information, correlated with the affected lands, map(s) and timetables: (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; (b)earthmoving; (c)all water diversions and impoundments; and (d)the size of area(s) to be worked at any one time. (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 operation. 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 operation 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: (i)an estimate of the periods of time which will be required for the various stages or phases of the operation; (ii)a description of the size and location of each area to be worked during each phase; and (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.) (f)A map (in Exhibit C - Pre -Mining and Mining Plan Maps(s) of Affected Lands, Rule 6.4.3) 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. (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. (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. (j) 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 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page I 2 6.4.4 EXHIBIT D — Extraction Plan 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. Prologue: Extraction of natural resources for rock products is essential to the well-being of a community. The urban infrastructure served by development of construction materials is a local and transitional benefit. The more remote these resources are from the need, the greater the cost to the private and public community. Unlike fixed urban impacts to the landform and area ecosystems, reclamation and restoration of extracted lands allow for preservation of natural buffers, and complementary alteration of both natural and human systems. Commencing on the family farm in 1948, the Varra family combines nearly 73± years of operational experience that serves as testimony to a history of sound and thoughtfully executed operations of this kind. For the Two Rivers Sand Gravel and Reservoir Project, lands not otherwise occupied for Developed Water Resources will be improved to the highest possible end -use. Post Extraction Uses beyond the Primary Use of Developed Water Resources will likely comprise continuing and diverse general agricultural uses; as well as possible light residential, commercial, or industrial uses; as determined by right, or as otherwise authorized by the governing authority. The restoration of above ground lands to native grasses and attending large water bodies are a baseline asset to area wildlife terrestrials and avifauna. Beyond good will, there are continuing landowner philosophical and economic enticements to further benefit area wildlife populations and diversity to further the value and enjoyment of the modified and surrounding lands. These efforts laid down over time involve the considerable experience of the landowner, staff, and other resources, including periodic consultation with the Colorado Division of Wildlife, the U.S. Natural Resources and Conservation Service, Colorado State University Natural Resource Departments and Extension Service, and a multitude of other natural resource professionals; including those highly qualified organizations and professionals who have already contributed to the Exhibits included under this application. Setting: The project area lies along and within the flood plain of the South Platte and Big Thompson Rivers. The predominant location of extraction is proximal to the geological delta found near the existing confluence of the two rivers (hence, the Two Rivers Sand Gravel and Reservoir Project (Two Rivers VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 13 6.4.4 EXHIBIT D - Extraction Plan Project; or TRP); and overlies bedrock that varies in depths as shallow as 20± feet in some locations, and more commonly 30-45± feet in depth from the surface. The permit area is flanked on its immediate western boundary by agricultural operations. To the north, residential uses expand, as remnant agriculture clings to the rising ground. Unfettered agricultural and rangeland uses still thrive as they extend beyond the permit boundary east, west, and south of the permit boundary along the alluvial influences of the two rivers. To the immediate east of the TRP, riverine lands are under active transformation into a created wetland bank. It should be understood that agricultural practices will remain active over the project area until converted by resource recovery and reclamation. America's first Transcontinental Railroad was being discussed in the 1840's, and surveyed in the 1850's. The railroads began the transformation of the American West on 10 May 1869 at Promontory Point, Utah. Railroad routes were being planned for this location and surrounding lands likely soon after the end of America's Civil War. The lines planned over the Two Rivers parcels were never built. Other lines were built nearby, like the Union Pacific's Dent line, that runs parallel to this day along the south bank of the South Platte River; and below the TRP. With area railroads came increased settlement, and with population the nature of the landscape became modified to complement growing market economies of agriculture and commerce since the early 1870's. We estimate the lands hugging the two rivers were farmed and the topography gradually manipulated for agriculture following the early establishment of Greeley and LaSalle, Colorado; in 1869-70. Area crops are commonly in corn, but this has not always been the case. We postulate that near the onset of the Twentieth Century sugar beet farming began to feed the demand of area sugar beet mills, further evidenced by speculative railroad routes over and near the parcel, itself. So, the appearance of the land that we see today, is commonly different than what it appeared at the time of settlement. In order to improve the area and extent of tillable lands, even early agricultural practices included landform modification to aid the plow. Prior floodplain modification is evidenced today by the historical placement of utilitarian levees flanking the existing agricultural fields along the outer cottonwood tree lined escarpments of each river. The levees are maintained to this day, and form perimeter access to the rivers and tillable fields. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 14 6.4.4 EXHIBIT D - Extraction Plan The later creation of farm to market County Road 396 eased access to the areas' agricultural fields, yet consequentially separates the fields at the TRP with its graveled surface, and subsequent rights -of -way and easements. The levees, public roads, cottonwood corridors and area tributaries are visible in the different map exhibit aerial images, and will not be impacted by planned extraction. All planned operations have conforming setbacks, and levee access will remain limited to wheeled vehicles during operations. Today, the upper terrace where extraction operations are planned, supports agricultural crops above the lower stream terrace formed further below and beyond the perimeter levees and cottonwood corridors that frame the adjacent active stream channels. The Fields designated for resource recovery (Central Field and North-West Field; as shown on Exhibit C - 2: Extraction Plan Map) lie over a nearly level upper terrace of the two rivers. The South Platte River borders the southern and eastern extent of planned extraction, and the Big Thompson River intersects the permit area north of the Fields. The stream terrace itself is a riparian area that supports on its flanking escarpment an uneven aged stand of Cottonwood trees. The uneven aged trees suggest this segment of the river has experienced some scouring in the past from periodic, yet commonly limited, flooding; which encourages natural regeneration of Cottonwoods. To determine the influence of past activities on groundwater, twelve (12) Piezometer Wells were located along and within the entire TRP boundary. Groundwater level information here, is based on 5.75 years of continuous monthly measurements at twelve (12) piezometer locations identified on the included Exhibit G: Water Information Map. Recorded groundwater depths vary in elevation below the surface, with a general (weighted) mean depth of 8.40± feet. Groundwater elevations are influenced by crop irrigation practices that run generally from April through September, and may occasionally lag into the middle of October. During this time groundwater depths may be skewed higher in elevation to the extreme North-eastern extents of Central Field, yet with few exceptions, groundwater elevations over the entire site remain significantly deeper than 5.11± feet from the surface, year over year, over the entire TRP area. Using the approximate surface elevation at the extreme eastern boundaries of North-West Field and Central Field, and noting that groundwater fluctuations will commonly meet at 8.40± feet below the surface, yet rarely rise more than 5.11± feet from the surface, we determined the Static Water Level using the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page IS 6.4.4 EXHIBIT D - Extraction Plan upper limit of 5.0± feet. The Cyan colored contour shown on Exhibit G: Water Information Map represents the Static Groundwater Elevation at 4675' at North-West Field, and 4673' at Central Field. Since completed reservoirs will be lined to meet State of Colorado Water Resources specifications and requirements, and since lined basins will ultimately equalize with the surrounding groundwater elevations, the Static Water Levels shown should reasonably reflect those of the both the lined or unlined state; and represent a proper reflection of the optimal surface area of the water over the finished basins. Raptor Materials, LLC has sufficient water to meet the circumstances and obligations of both the lined and unlined states; and as reflected under Exhibit G: Water Resources Information; until and unless the reservoirs have an approved liner, the Operator will dedicate sufficient waters to secure the reclamation of the resulting basins in the unlined state. Planned Field Activities: The 409.23± acre parcel boundary forms the permit boundary, as reflected on exhibit maps. All lands under its direct control within the 409.23± acre permit area, are affected lands under C.R.S. 34-32.5- 103(1), respective of this permit application. As a result, any changes required in the nature of planned extraction or reclamation will be made only through the Colorado Office of Mined Land Reclamation (OMLR), by Technical Revision only. If lands are needed beyond the designated permit boundary, those lands will be secured for the active OMLR permit by Amendment. Within the permit boundary, there are two* (2) identifiable areas designated for primary extraction, the description of which will help to explain the nature of planned extraction and reclamation. The Primary Areas of Extraction are as follows: 162.57± Acres 41.04± Acres 203.61± Acres 205.62± Acres 409.23± TOTAL Primary Extraction (***) Central Field: 15-25± years (2023- '48) ** Primary Extraction North-West Field: 4-8± years (2045- '53) ** Total Primary Extraction * Affected Lands beyond planned extraction limits (*) NOTE: The third area of secondary extraction is limited to approx. 5.60± Acres for a Plant Processing/Stockpile Area Pond, as further indicated, below; and is not included in this total. (**) NOTE: Final reclamation will add up to five (5.0±) years to the anticipated Life of the Mine, subsequent to completion of extraction and removal of all marketable materials. Life of Extraction is an approximation, and could lengthen or shorten the overall life of the mine depending upon market conditions. (***) NOTE: Of the 162.57± Acres of Primary Extraction, 4.09± Acres comprise an existing Farm Yard & Structures with residence. These facilities may be leased or VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 16 6.4.4 EXHIBIT D — Extraction Plan otherwise utilized as an Office and Support/Storage facilities for Operations, potable water and sanitation. Lands identified within a designated Extraction Limit may not be extracted, including the Farm Yard area, as circumstances warrant according to the discretion of the Operator. Of the outlying 205.62± Acres: 15.76± Acres = Plant Processing/Stockpile Area 5.60± Acres = Secondary Extraction - Plant Processing/Stockpile Area Wash Pond 21.35± TOTAL The remaining 184.2 7± acres of lands within the permitted limits may comprise planned or existing permanent access roads, levees, previously affected areas, and areas of minor to no disturbance (including public transportation corridors, right-of-way's, easements, permanent structures, river and stream terrace and cottonwood corridor buffer areas), or other farm land features or structures; or as otherwise determined from included maps and aerials. These lands may also include essential support operations, including: parked vehicles, equipment, plant site equipment and processing stockpiles, etc., not otherwise explicitly indicated or shown, but reasonably associated with operations of like kind, and may be varied in location and extent over time; or otherwise, field fit within the permit boundary as warranted. Wetland conditions appear confined within portions of the stream terrace and bank -full stage of the rivers, and along segments internal to the Evans Canal. Extraction will form a depression (basin) within the floodplain as shown in Exhibit C-2: Extraction Plan Map. Temporary above ground fill may occur within the floodplain, and as part of this permitted activity, provided the above ground volume does not exceed the below ground volume created by extraction. All product stockpiles and processing will occur within the city limits of Evans under this application, and North and outside of the floodplain boundary of the 100 -year floodplain of the Big Thompson River. The floodplain extent will be visually marked in the field to better assure the integrity of the floodplain. Material transport of raw materials from extraction locations to the plant site will occur via conveyor (see route on Exhibit C-2: Extraction Plan Map). This will in turn serve to minimize impacts to area transportation corridors. The actual location, extent, and nature of the conveyor systems not otherwise designated in this submittal will be provided as updates in the required OMLR Annual Reports. 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. Exhibit S: Stability Analysis - provides VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 17 6.4.4 EXHIBIT D - Extraction Plan certification from a registered professional engineer that these structures will not be harmed by planned extraction profiles and extents. 'For lands within the Extraction Limits, only those structures, easements, and rights -of -way shown in Exhibit C-2: Extraction Plan Map, are anticipated to remain from those shown in Exhibit C-1: Existing Conditions Map. If changes to existing or possible revised structures, easements, or right-of-way are in any manner retained, or where they might occur subsequent to OMLR approval of this application, then a Technical Revision will be submitted to update Exhibit C-2: Extraction Plan Map. All established setback distances from planned activities to any remaining features will be maintained regardless. Operations or related Processing Areas and Wash Pond are not intended to affect existing structures, Easements, or Right -of -Ways within the Planned Extraction Limits identified as remaining and are designed to avoid and retain any remaining structure, Easement or Right -of -Way on the surface, and subsurface. Future agreements may be reached allowing mining in areas currently identified as being restricted to mining containing certain structures, Easements or Right -of -Ways. Exhibit C-1 shows and identifies all these features understood by us, and the respective Surveyed information, and correlated Observation and Title Work upon which they are based and represented on the attending Maps. The Maps are not Surveys. They are Maps and as such, they comprise a reasonable representation of all site features, but must not be relied upon by themselves exclusively for location purposes. Maps and features are not a substitute for field identification of underground structures and will rely upon location services of the 811 service. Setbacks where required will be based on the actual field locations of site features. Exhibit C-2 shows the remaining Oil Wells and Lines within Planned Operations at the time of the Submittal. Any revisions, additions, or modifications of residual Oil Wells or Lines will be avoided as represented on updated Maps and Revisions to the Permit, and consistent with Setback Distances identified in this submittal. Removal of any Existing Structures such as the Oil and Gas structures and or lines, will be updated on required Annual Reports, or by Technical Revision, as warranted, or as otherwise directed consistent with Colorado Statute. Access to the Theater of Operations: Entry into the permitted areas is dependent upon the needs and necessary management of continued agricultural activities during operations, as well as essential management and 1 Adequacy Item 18 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page IS 6.4.4 EXHIBIT D - Extraction Plan mobility within the active areas of extraction, processing; and correlated need for transportation of human resources, equipment, and product. Human resources for operations, heavy equipment, and haul traffic will occur based upon the desired and dynamic activities necessitated by time and circumstance within the designated Fields. Access points for continued agricultural, extraction, and plant site operations are shown :; on Exhibit C-2: Extraction Plan Map, as follows (NOTE: Access purpose and usage may change in time from that indicated here -in. Also, General Existing Dimensions and length of existing access roads are represented in the aerial images on the Exhibit Maps relative to the Access locations detailed, below. Modifications may occur as needed and will be reported in OMLR Annual Reports.): * Entrance 1: Farmstead entrance. Limited Access. Note: Visitors will first access operations by checking in at an established plant scale -house, not here. Entrance 2: Primary Access to the lower boundary of Central Field. Entrance 3: Primary Western Access to the North-West Field. Entrance 4: Primary Eastern Access to the Wash Pond and designated Plant Site. Entrance 5: Adjacent Parcel Existing Access. Entrance 6: Oil & Gas Access into the Western Section of Central Field. Entrance 7: Primary Eastern Access to the North-West Field. Entrance 8: Primary Northern Access to Central Field. Entrance 9: Primary Northern Access into the designated Plant Site location. Entrance 10: Internal Access from Adjacent Lands. Entrance X — Agricultural/Mechanical Entrance WV — Agricultural/Mechanical — Westervelt R -O -W Access to adjacent Wetland Bank Existing roads outside of the permit boundary are shown on Exhibit C-1: Existing Conditions Map. Existing on -site internal access roads are also visible to scale in the aerial information provided under Exhibit C-2: Extraction Plan Map and other map exhibits included with this submittal. In general, Operations will predominantly utilize unmodified existing agricultural field access roads (unless otherwise indicated), which will themselves be subsequently extracted in time where they fall within the extraction limits shown on Exhibit C-2: Extraction Plan Map. 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. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Page 19 6.4.4 EXHIBIT D - Extraction Plan 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. For purposes of this submittal, all lands within the indicated permit boundary will be considered affected lands, but only those locations between the existing access roads, and which otherwise remain above the anticipated static water level of the resulting basins, will be soiled (where soil is absent) and seeded to establish vegetation consistent with the approved reclamation plan. Area and Site Soils: Soil formation surrounding and within the project area varies according to diverse geologic, natural, and man -caused influences. The United States Soil Conservation Service, Soil Surveys, are the foundation source for understanding area soils as identified on Soil Survey Maps by their Soil Unit Number. Unit 3 Soil formations for Weld County are not easily typified or quantified as other soil units, for a reason; natural and man-made alteration and use of the land over time. Planned extraction limits will affect predominantly Unit 3 Soils. Extract from Exhibit I/J. Unit 3 soils commonly form within floodplains. As a result, differing states of soil formation may exist within the soil unit designation; such as soils with little horizon development like Entisols and Inseptisols. Mollisols with deep well -developed horizons may exist in the minority and the near fringe of planned extraction. Refer to graphic above, and below. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I Zo 6.4.4 EXHIBIT D - Extraction Plan Enceptisol I nceptisol Molisol Soil Morphology With over a century of agricultural manipulation of area agricultural fields, prior mixing or importation of soils for land leveling, or flood plain management in the creation of levees, may have dramatically altered the original native soil profiles and properties. The native A profile of the upland terrace found within the agricultural Fields at the TRP, is predominantly modified as a plow (Ap) layer of 6.0± to 8.0± inches. The historic practice of incorporating manure into the plow layer should have served to maintain the organic base and quality of the cropped soils and accelerated soil horizon formation and development where it was lagging. Since the cropped soils have been irrigated, care should be taken not to salvage soils greater than 12.0± inches in depth to avoid mixing of potential accumulated salts. Generally, total soil depth (including all soil horizons) over the property may vary from approximately zero inches to four [4.0±] feet, yet predominantly having a shallow Ap plow layer of six to eight [6-8±] inches, lacking a B profile and having the potential for a mixture of silt, clay, or gravel outcrops over random areas. Gravel depth may occur from the surface to the underlying Fox Hills Sandstone varying at approximately 30.0± to 45.0± feet over the entire property. Suitable soil in excess of that needed for reclamation will be made commercially available to meet area infrastructure and residential demand. Soils found within the entire project area are described more thoroughly under Exhibit I - Soils Exhibit, and the attending Exhibit I/J - Soils and VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 6.4.4 EXHIBIT D - Extraction Plan Vegetation Map, shown not to scale, above. Additional geologic considerations are also included under Exhibit S - Stability Analysis. Area and Site Geology: The area geology is typified by mixed alluvial and aeolian development, that is commonly alluvial in nature at lower elevations. As viewed in the Geologic Timeline and shown in Figure 1, below, the aggregate deposit is found between the Laramie and Fox Hills Sandstone formations, both formed during the Upper Cretaceous Period nearly 65 million years ago. The alluvium of the river valleys and aeolian sands that cap the hills formed of the Laramie formation north of the permit area are more geologically recent, developing during the Quaternary Period. PERIOD EPOCH 1 eater nary Tprtia r i tie a Massie. s Phone kx eri e MFL .IONS OF YEARS AGO HOW IjEe It 0.1 0.6 16 5,3 112 116.4 73.7 2831 33) 4J.A S 54 i5 c3 144. 159 tan 206 221 242 .246 Geologic Time - Livescience.com VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 12 1 Figure 1: Area Geology Map sr tprig rink' • !74J1 r ig -�� SI S' `� 6.4.4 EXHIBIT D - Extraction Plan The areas of extraction are in the alluvium whose general morphology, area and extent are better understood in Figure 1 above, and 2 and 3, below (Colorado Geological Survey). -r `z ' 'r. 1' -. 7- - -� a. 4"Mat - • 47.7 - e--• "`r s... - •.. a -ra. ,� �. �• - 9.. 6 ' ..- Ik F• - a .•. —et az ,- • r- o• - :' . .- -Z _ r erg a_ • .. a- - %{! • a 1 r . • . di' -i_ • 1! L _tJtn i , a • V - - - - r. �.Y- t - ',. I . •- —° - - - ." as f st, a Ni` ' Y o r•a i a a 9, u u p• n Y. r a s ad.a! a u a iY• ra . • . _ - Ea 1 LIt no a • = , • a r i . • •. - S`t •� • X• 77 ! - v•'� 1� �.�' . _* •.s— r aal ••�. a • 9 r _ .. `.• • Tom. —s •. • • aa A. _ °IS Y r ▪ f� u a - r1`•41. r , ma y�. :a sa :1/1 as a. - .. _ +:�. a - o r-- a 'f• " . �.lt. —r-p. _ a .. - c . - .F • .1' 4 e ° AA — '.4 — -a ' _ r� , 1 ' �; er . ° ti_ a - -r• '• x a.. — Figure 2: Area Geology 3D Oblique View IT rm."...C • •.c . - . m -1 T 1 J. • es. . •• a"Y-Sr , • -- ,,° ', • a a r. w a .r • 1_R r . y"1; • • .•'!P.• -...g..'a •ar- .� - • L - .. —e M I :Alta - Pt a- • i, Z • • •• . rea i Y 1 Y.- 1 • '� _ a- •-t—r • _ !I• a iR �� - -° - • • �a 99 la air lee a. I o •• . —� 7 a Fa. r If -' I • • • - •— . a VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 1 13 6.4.4 EXHIBIT D - Extraction Plan CORRELATION OF MAP UNITS SURIICIAL DEPOSITS H i A DE DEPOSITS j_ I, J .L J DEPOSE!S GRAVEL EEC LLL2 '1 DEPOSITS DEPoSITS T'S, . - - ' a I • ry 47'1I - . '�y . .. GCS - f - �+y - . _1 1 ag3, unconformi O q 3 'Inconformity Cie _ -o_cc eine Figure 3: Surficial Deposits relative to areas shown in Figure 2, above. The aggregate deposits of Qal and Qa2 (Figure 3, above) form the bulk of the deposit planned for extraction. Depths vary by field from approx. 30 to 45 feet. Depths are shallower as the adjacent hillside rises to the north; while the deposit dips deeper toward the South -East of each designated Field. Soil Salvage: Resource recovery will commence by first removing the upper [A profile/plow layer] six to twelve inches of soil [six (6.0±) inches typical], combined with existing grass or crop stubble. Removal will utilize scrapers or excavators, aided by dozers where necessary, and hauled to the Northeast Section of Central Field. All extraction and surface related activities detailed in this application will occur under an approved Fugitive Dust Permit issued by the Colorado Department of Public Health and Environment (CDPHE). Until resoiling activity occurs, where harvested soils have been stockpiled and remain undisturbed for reclamation or sale, they will be seeded with the mixture specified under Exhibit L - Table L-1: Primary/Preferred Revegetation Seed Mixture. A stabilizing cover of native vegetation may take up to three years to fully establish the desired cover. In the event the native seed mixture fails, an optional mixture of predominantly introduced species will be used as a fall back to better assure a stabilizing cover of vegetation. Still, using the VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 14 6.4.4 EXHIBIT D - Extraction Plan preferred native seed mixture offers opportunity to gauge the potential performance of the selected species prior to utilizing it over larger areas requiring reclamation later in the life of the resource recovery operation. Once vegetation is established over the initial reclamation soil stockpiles, they will likely remain untouched for the life of the operation until final reclamation of remaining affected lands takes place. Where concurrent reclamation is possible, operations will utilize soil in an over the shoulder method when practical. In this manner, reclamation is expedited without increasing soil stockpile volumes while reducing expenditures related to labor, handling, and time. Soil salvaged as stated above will range six to twelve inches in thickness. Resulting volumes of salvaged soil will range from 131,100± - 262,300± cubic yards for Central field, and from 33,100± - 66,300± cubic yards for the North West field. Salvaged soil will generally be stockpiled on top of the Westervelt soil storage area in the North-East section of Central field. Smaller short-term stockpiles may be created along the pit edges where regrading is imminent or in progress and resoiling will follow. Resoiling oiling volumes required above the waterline of the lined water storage will require much less soil. The resoiling areas are estimated at 11.19 ± acres for Central field and 4.76 ± acres for the North West field with volumes at a nominal six inches of soil cover at 9,027 ± and 3,840± cubic yards respectively. Excess soil not needed on site may be sold. Dewatering: As extraction activity progresses into the aggregate profile, groundwater must generally be removed in advance through the use of pumps and subsequent discharge into area tributaries. A complete dewatering evaluation was performed by AWES in their report of 27 July 2020, as provided at the back of Exhibit G: Water Information. The report concludes that 'the results of analytical and numerical solutions indicate that the proposed mine dewatering activities will not adversely affect the regional groundwater hydrology.' The reader is further assured that all discharge of waters will be conducted under an approved CDPHE discharge permit. Initial dewatering of the property in preparation for extraction and resource recovery will occur by establishment of a dewatering pump and/or well in the Southern boundary near an existing agricultural pond. The point of discharge is on Exhibit G: Water Information Map. Other discharge locations may occur in time as needed and otherwise approved under the applicable 2 Adequacy Item 23/32 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 15 6.4.4 EXHIBIT D - Extraction Plan CDPHE discharge permit requirements. Subsequent CDPHE approved discharge locations will be field fit and the location updated in the following OMLR Annual Report. Active Resource Recovery: Following soil salvage, the balance of the extractable deposit will be removed to the depth of the unconsolidated or weathered bedrock, transported by conveyor to the plant site pit run, and subsequently manipulated as desired by screening, crushing, washing, and other methods to size and properly dimension the earth product into diverse merchantable materials for sale. Resource recovery will commence radially North and East from a point near the existing pond and planned first discharge point shown near the Southern boundary of Central Field. There are no fixed sequences or phases scheduled as part of the extraction plan. Instead, Fields are used instead of Phases to describe the activities, since each Field can be accessed concurrently instead of sequentially with the other; as reflected or otherwise updated as part of required OMLR Annual Reports. Under this method, extraction is 'pulsed.' As such, the rate of extraction and subsequent reclamation will slow or quicken according to influences of the markets, weather, and internal logistics. Flexibility in Operations encourages better outcomes when adapting to changing circumstance or unexpected field conditions, and may involve actively working different fields or different parts of the same field as necessary. 3For Two Rivers, there are four Fields, intended as sequential areas of extraction unless market demands warrant concurrent development: • 121.86± Acres - Central Field — Center Section • 15.58± Acres - Central Field — North-East Section • 25.09± Acres - Central Field - West Section • 41.04+ Acres - North-West Field Generally, flexibility aids integrity of operations and encourages optimizing operational activity and subsequent reclamation of affected lands. Therefore, any method that accelerates the extraction timeline will be utilized, and should be encouraged to better engage the unpredictable elements and variables that reasonably affect the capacities of the Operator. Exhibit C-2: Extraction Plan Map, shows the location and planned extraction limits, general direction of extraction, and related features described above; along with features made obvious in the included aerial image of the permit location and surrounding lands. 'Adequacy Item 17: Aspects of detail required. Other aspects addressed elsewhere. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 1 16 6.4.4 EXHIBIT D - Extraction Plan 4Exhibits C-2: Extraction Plan Map and L: Financial Warranty Map, shows Initial Extraction proposed to begin in the yellow hatch area shown on the Exhibit L Map, comprising 16± acre. The direction of extraction will follow the perimeter of the extraction limits in order to establish the perimeter keyway (dewatering trench') for the 121.86± acre Center Section of Central Field. The perimeter extraction comprises approximately 70.21± acres and will leave an approximately 51.65± acre Core, that may be extracted as needed as keyway drainage capacity allows. The Initial Extraction area is practical as it has no encumbrances and is adjacent to the existing pond. The initial extraction area is bordered to the South along a near 800± foot section of oil and gas line that is pending removal; along with the two oil and gas wells, also pending removal (refer to Exhibit C for ownership details). If or while this infrastructure is still in place, extraction will not occur within 10 feet of these lines, or 25 feet from the wells, as indicated in the setbacks detailed below. Below this gas line is an existing pond and well that will be used as a Settling Basin Area, containing at present a solitary settling basin and pump as a point of discharge of groundwater. This pond may be expanded or added to below this line and may then be extracted itself once discharge is discontinued for Central Field Operations. Perimeter Keyway Extraction will maintain a perimeter slope no steeper than 1.25H:1V, except for the perimeter shown in red along it's extraction limit, and respective toe where cut slopes will not exceed 2.00H:1V; as indicated (refer to Exhibit S: Stability Analysis for additional information). At the toe of the cut perimeter slope is the keyway that runs below the extracted deposit of the basin, into the bedrock, which allows the subsurface waters to flow to the settling basin and discharge pumps necessary to keep the cut basin dry during a time of extraction and reclamation of the affected perimeter slopes. The keyway dimensions may vary more or less from 4± to 8± feet in depth and 4± to 16± feet in width. Extraction must be broad enough to allow equipment to safely approach the toe and excise the bed dimensions where the resulting channel is sufficient to convey the groundwaters to the settling basin for discharge. Please Note: The graphic representation of the Perimeter Keyway Extraction and Core are idealized, and may vary in shape, size, and location presented. Annual Reports will report on the nature and extent of affected lands and 4 Adequacy Item 17: Modified from first adequacy response to better define the mining and reclamation plan and reference a schedule in Exhibit E. S Adequacy Item 15: Keyway clarification VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 17 6.4.4 EXHIBIT D - Extraction Plan more properly reflect actual conditions on the ground in a given year of operations. At anticipated production levels and production only from the Center Section of Central Field, extraction of the remaining perimeter excavation could take 6-7± years. Extraction of the core could then commence and take 6-8± years, overlapping with initial development of the next field. With sequential development, extraction of the North-East Section of Central Field could take 3- 5± years, the West Section of Central Field 4-6± years, and the North-West Field, 6-8± years. Please Note: The time periods will depend on the actual rate of production required to meet market demand, and the average annual advance may also vary with thickness of the sand and gravel and ground conditions. Some flexibility may also be exercised to optimize operations around or through existing infrastructure if scheduled for removal. Table E-1 provides a projection of mine development and regrading/reclamation. The plan as described in this Exhibit D and also in Exhibit E, is a forecast and may vary according to market conditions with mining and subsequent regrading occurring faster or slower, sometimes significantly so. The geology may also dictate changes in the rate of extraction. If efficiency demands in a higher production demand scenario, up to four separate areas could be developed in the manner described simultaneously. Such changes may happen quickly and would be addressed in the Annual Report. 'In discussing this flexing of production and scaling operations up or down with OMLR staff, a concern was raised as to impacts on mule deer habitat if there were separate production areas with a larger area under active production. This has been addressed as having minimal impact in a letter from Ron Beane, Senior Wildlife Biologist with wildlife consultant ERO Resources Corp attached as an addendum to this Exhibit D. As discussed above and considered in the letter from ERO Resources Corp, Raptor envisions up to four active mining areas (area of active extraction operations) of up to 16 acres could be in production simultaneously for an anticipated maximum active mining area of 64 acres. As noted in the ERO Resources letter, this area is only a small percentage of the riparian corridor within and adjacent to the extraction area and while Raptor would not anticipate exceeding 64 acres of active mining area, small and temporary variances may occur in response to market demands, coordinating operations around existing infrastructure, water management, or to ensure safe operations. The maximum disturbed area will continue to grow over the life of the operation as the post mining land use is lined water storage and as noted by the DRMS, until the basin is fully extracted and lined, and a leak test is 6 Adequacy Item 17: Wildlife concern VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION i 18 6.4.4 EXHIBIT D - Extraction Plan performed and approved by the State Engineer. Progressive regrading and lining however will be performed and is discussed in Exhibit L. Additional information is provided under Exhibit C-1: Existing Conditions Map; which shows all known current and active significant man-made structures located on or within 200 feet of the permit boundary detailed under 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; located over the permitted lands or within 200 feet of the same. A listing of the adjoining surface owner's names and addresses located within these areas are listed under Exhibit C Text, correlated with those shown in the afore -mentioned Exhibit C-1: Existing Conditions Map. The extraction limits assure through the use of setbacks that other interests are not affected by planned extraction. Extraction is set back uniformly at a minimum 10.0± feet from the edge of property lines; easements and rights -of - way; underground gas lines or other underground facilities, irrigation ditches and seep ditch, wells and other structures. '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 OMLR inspection in a timely manner, or by operator -initiated Revision to the Permit or otherwise via clarification in attending required OMLR Annual Reports. Extraction will not occur closer than 125+ feet from the face of a residential structure; unless there is a written accommodation with the owner of the residential structure that allows extraction to occur within a closer stated limit. Extraction will occur no closer than 25± feet from well heads and related above ground facilities. Extraction around well heads will be concurrently backfilled to maintain a 100± foot buffer from the balance of extracted lands. At all times, safety will take precedent and over -ride all other conditions in time with a matter of safety or emergency respective to any and all aspects of the approved permit. To minimize the potential of river capture, planned setbacks from the two rivers was evaluated by Flow Technologies (refer to report at the back of Exhibit G: Water Information - titled: 'Two Rivers Riverside Berm Failure Analysis and Flood Control Mitigation Plan' of 22 January 2020). The report finds: ' Adequacy Item 21 8 Adequacy Item 22 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 19 6.4.4 EXHIBIT D - Extraction Plan `... that head cutting/erosion will not progress through the full length of a 100 -ft riverside berms. It is important to note that should a flood occur that results in head cutting/erosion of a riverside berm, Varra Companies, Inc. will act diligently to restore the damaged areas to pre - flood conditions. As mentioned, this analysis is conservative and riverside head cutting/erosion is based on the 100-yr flood. There is a small probability that such a flood event could occur during extraction and when the pit is dewatere d. The DRMS in a supplemental adequacy response dated November 17, 2022 challenged the validity of the engineered design approach taken by Flow Technologies despite having accepted it as valid in the past. Raptor Materials believes the approach is valid and is in the process of performing an analysis by alternate methods incorporated in HEC-RAS. This, however, will take time. Raptor has per DRMS suggestion decided to adopt the 400 -foot setback from the top of the riverbanks to the top of the pit -side slope based on guidance developed using generic and non -site -specific empirical methods as adopted by the Mile High Flood District whose jurisdiction does not include the proposed operation. Raptor Materials intends after permit approval to present the results of the ongoing engineering evaluation as a Technical Revision to obtain relief from what we are confident are extreme setbacks. During extraction, a predominantly vertical advancing pit wall (the extraction front) is not anticipated due to the use of excavators in the removal of the material deposits. Excavators provide a great deal of control over the extraction process. The maximum length of the extraction front will likely never exceed the length of one side of a quarter section of land, or 1,320± feet, or less; in any given direction. The advancing front will result in a moving face with a slope typically equal to or flatter than 1.2 SH:lV, and commonly not greater than 1.2 5H:1V along the perimeter of the extraction limits to depth. The exception to cut perimeter slopes is shown with a distinct Red Boundary on Exhibit C-2: Extraction Plan Map, where cut slopes will not exceed 2H:1V in order to maintain integrity and stability along that designated perimeter area (refer to the AWES Slope Stability Analyses of 23 December 2019, located at the back of this exhibit). Internal transport of extracted materials to conveyor systems or other internal transport; or otherwise by approved public roadways, will be used in the transportation of extracted materials to the designated plant/stockpile location, described in greater detail, below. Acreage to be affected during the first year of extraction activities include the establishment of the initial Wash Pond and attending Settling Pond(s), Plant VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 1 zo 6.4.4 EXHIBIT D - Extraction Plan Site, and Initial Areas of Extraction and attending means of transportation by ground haulage or conveyor. While the acreage required for the Plant Site and Wash Pond are not expected to change, the Initial Area of Extraction will expand until concurrent reclamation follows as each location is exhausted of resource. Although initial extraction may otherwise result in temporary slopes up to I.2511:1v, all cut slopes will be backfilled with unconsolidated bedrock, overburden (on -site unmerchantable excess materials, or imported inert materials) and soil to advance the reclamation and completion of the desired basins. Final reclaimed slopes and grades will be concurrently established where practical to 3h:lv, or flatter, and at a minimum from 5± feet above to 10± below the expected water level of each location of extraction, and to the basin floor. Concurrent backfilling and grading of cut perimeter slopes, while desirable, may be obstructed in time and extent by the need to maintain keyways and basin discharge during extraction. Backfilling of slopes can only occur once enough of the floor is exposed to facilitate backfilling and finished grade of extracted basin slopes without interfering with basin discharge operations. This makes concurrent backfill difficult to accurately forecast. Regardless, any completed slope remediation will be indicated in any subsequent OMLR Annual Report. 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 203.61± acres of potential extraction, the resulting basins will function as multiple -use reservoirs with a slightly fluctuating combined water surface area covering 187.66± acres. The remaining balance of 37.3± acres of land above the anticipated high-water mark of the reservoirs, and not otherwise committed to existing or planned structures or infrastructure over the parcel, will be stabilized with vegetation; including the anticipated 15.95± acres of basin slopes reflected in the total. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 21 6.4.4 EXHIBIT D - Extraction Plan NOTE: Shoreline irregularities and fill to establish and enhance the aesthetic and end -use functions of the resulting basins shown on Exhibit F: Reclamation Plan Map, are illustrative only, as this effect as to location and extent will be field -fit where practical, and may substantively different from that portrayed under the application. The actual location and extent will be identified in subsequent OMLR Annual Reports, and absent there, at the time of any applicable release of a location in part or whole from the permit. Since representations cannot be accurately portrayed in advance, Exhibit F simply identifies the near maximum extent [typical] of the resulting basins or ponds and the potential for shallows during lining and finished grading. The estimated timetable for extraction, commencing approximately spring to winter 2023; is estimated to take 23-28± years combined, or longer, followed by an additional five years to complete reclamation; or a total estimated life of the mine of 28-33+ years; ending approximately winter 2051 to 2056. This is a life of the mine operation and all timetables are estimates and may prove shorter or longer than stated. The final determination will occur five years after the deposit is exhausted and all marketable product has been removed and necessary infill completed at the location to the point of final reclamation as approved or modified under the terms of the permit is completed. This submittal is unable to fully forecast the maximum extent of affected land expected at any given point in time, beyond an annual basis. As operational extraction and reclamation efforts will vary annually, the timing of extraction, reclamation, and life of operation as forecasts must be based on an initial estimate [refer to Exhibit L - Reclamation Costs], then subsequently verified and adjusted as reasonably determined at the time of the required OMLR Annual Report. If justified by field conditions, a rider to the warranty would follow in due course to reflect current or forecast conditions where such conditions cannot be reasonably attenuated in a timely manner prior to the due date of the next year's Annual Report. This will serve to assure flexibility and confidence in continued operations until completion of the desired end use. Additional information on the reclamation and restoration of affected lands is identified under Exhibit E: Reclamation Plan. All reclamation will follow guidelines established under Exhibit E - Reclamation Plan and Exhibit I/J: Soils and Vegetation Information, until and unless otherwise revised. To the extent possible, pond bottoms will be left rough, with the possible introduction of logs or other non -putrescent inert material to aid in aquatic habitat and cover [Refer to Exhibit H - Wildlife Information]. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 22 6.4.4 EXHIBIT D - Extraction Plan Plant Site Development & Operations: Plant operations are generally comprised of portable equipment. A small wash pond will be established near the onset of extraction operations as shown in Exhibit C-2: Extraction Plan Map. Deposit materials are predominantly transported or conveyed from the extraction areas to the plants or surrounding yard, where subsequently processed and scaled for sale. Pit -run (unprocessed materials) may also be loaded and transported directly from the extraction areas to area markets as needed and where appropriate. Plant Site operations may also receive and process materials, and utilize fresh water supply, sourced from locations outside of the permit area or planned areas of extraction. Provisions for a material processing plant may at some point be joined by complementary processing that may include periodic use of on -site recycling facilities. While recycling activities may occur within the approved plant site/stockpile location; concrete and/or asphalt batch plant facilities and locations are not presently determined or sought at the time of this submittal. Due to the extended life of the mine the Operator desires an essential flexibility to complement future area needs according to permit requirements and approvals applicable at the time should such facilities be sought. Any facility development of this kind will be determined at that time as identified in a later Technical Revision to the OMLR under the approved permit. These potential activities are mentioned here solely for purposes of transparency in establishing these activities as acceptable, normal, and necessary activities to meet and facilitate the delivery of essential construction material needs of the area which may occur over time during the life of the approved OMLR Construction Materials Permit Operations. Initial Plant Site Theater as seen in Exhibit C-2: Extraction Plan Map VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION I 23 6.4.4 EXHIBIT D — Extraction Plan With the exception of the wash pond, whose margins follow existing surface elevations; all plant site processing activities will occur on upland areas outside of the existing 100 -year floodplain. These lands occur north and north-west of the existing Evans Ditch as it winds north of the Big Thompson River. Plant activities will require a wash plant and attending wash pond to recycle wash water and receive discharge silts and other reject fines from the washed product. Plant and Wash Pond areas are identified on Exhibit C-2: Extraction Plan Map. The wash pond will function as recycling wash water and receiving basin for reject fines for the intended Plant/Processing activities. Since the basin functions in a closed system, it will not require dewatering. Once the wash pond is established, wet plant operations can be created and join any dry plant activities in progress. Dry Plant operations can be readily established since water is not integral to their operations. Once established, wash pond water will function as a closed system. Settled materials from wash Ponds will be utilized as product or for reclamation as desired. Plant equipment will include, but is not limited to, a crusher, screens, and conveyors, scale house and scale, and attending equipment. Resulting stockpiles of pit run and processed products may be temporarily stockpiled here with processed stockpiles, or combined as needed, until transported to market. 9The conveyor will be set on an elevated structure at varying heights to be situated about the 1 in 100 -year flood level. An average height of 7 feet is expected. The conveyor will be supported by legs at intervals of approximately 40 feet with typically 6- x 2- x 2 -foot concrete blocks sitting on ground surface used as necessary to anchor the legs. The conveyor will span the river channel and metal (or other appropriate material) pans will be installed under the conveyor structure to prevent spillage into the river. The design will be similar to other Raptor locations where an extended span has been required to cross a county road. Final conveyor specifications are to be determined however belt width is anticipated in the range 24-36". Ultimately, once the wash plant activities near the completion of extracted deposit material, the closed system wash pond will fill with silt and be revegetated in a manner consistent with Exhibit E - Reclamation Plan. Interim clean out of the wash pond will occur until that point, 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. 9 Adequacy Item 24 VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION 1 24 6.4.4 EXHIBIT D - Extraction Plan Plant and material processing activity will divide materials into diverse and dynamic product stockpiles that will come and go with unpredictable variations in sale and production. To the extent possible, product material will surround plant activities to further lessen visual and noise impacts to surrounding properties. Plant placement will assure that plant noise is well below that of the nearby traffic. Relative to noise, traffic travelling on area roads at 55 mph or above is approximately 70.0± decibels within 100 feet from the centerline of the Highway. Noise at ground zero at a cone crusher, as measured by a hand- held 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, achieving residential background levels at a total setback of 400± feet. 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. Plant stockpiles will aid muting of plant sourced noise just as noise levels at areas of extraction are buffered with increasing depth of extraction. The location of the portable scale and scale house and correlated 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, and desirable neighborhoods communities most desire. 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 under Table DI - Earth Products, 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. Explosives - will not be utilized. VARRA COMPANIES, INC. TWO RIVERS SAND GRAVEL AND RESERVOIR PROJECT MARCH 2022 A REGULAR IMPACT [112] CONSTRUCTION PERMIT APPLICATION - COLORADO DIVISION OF RECLAMATION MINING & SAFETY OFFICE OF MINED LAND RECLAMATION Hello