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Home My WebLink About20231623.tiffEiwiroineit, Iqc. LARRY E. O'BRIAN FOUNDER STEVAN L. O'BRIAN PRESIDENT August 1, 2023 Weld County Clerk to the Board Board of County Commissioners Office 1150 "O" Street Greeley, Colorado 80631 Re: L.G. Everist, Inc. - West Farm Reservoirs M-2023-048 Adequacy Response - 03 Packet Dear Sir/Madam: 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 We are delivering to you here with a copy of the third Adequacy response and supporting exhibits for the L.G. Everist, Inc, - West Farm Reservoirs application filed with you on November 17, 2022. Please place this packet with the original book. The original is on file with the Division of Reclamation, Mining & Safety. This copy of the permit application adequacy response is delivered to you pursuant to 34-32.5-112(9)(a), Colorado Revised Statutes 1995, as amended, which states in part: .... the applicant shall place a copy of such application for public inspection at the office of the Board and Office of the County Clerk and Recorder of the County in which the affected land is located. This packet must be kept with the book for public review until the application has been approved by the Division. We will contact you once it is and make arrangements to pickup this copy. Please acknowledge receipt of the copy of the permit adequacy response by signing in the appropriate space provided below and returning one copy of this letter to the person delivering it. Yours truly, ENVIRONMENT, INC. Stevan L. O'Brian enclosure Pu61;C ReV:et.J 006/23 RECEIVED AUG 0 2 2023 WELD COUNTY COMMISSIONERS RECEIVED THIS DAY OF , 20_, one copy of the adequacy response 02 packet for above referenced mine. Weld County Clerk to the Board By CC: pL(TP/HN/PA/KoiDA),PW(CH/ER/CK/DPAN) Og/I4 /23 2023-16.3 EiWiroi)n)ei)t, Inc. LARRY E. O'BRIAN FOUNDER STEVAN L. O'BRIAN PRESIDENT August 1, 2023 Mr. Eric Scott Division of Reclamation, Mining & Safety 1313 Sherman St., #215 Denver, CO 80215 Dear Eric; RE: L.G. Everist, Inc. West Farm Reservoirs, Permit # M-2022-048 Adequacy Response 03 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 On behalf of our client L.G. Everist, Inc., I will respond to your July 25, 2023 third adequacy review letter in the order and number format presented in that document. Response to Item 23a: Please clarify that the required TR submittal for the Phase 1 slurry wall design and french drain design, as well as the required bond increase required for those activities, must be submitted by the operator and approved by DRMS - prior to commencing slurry wall installation or other mining activity associated with Phase 1 of the proposed mining plan. L.G. Everist will commit to filing a Technical Revision prior to starting operations in Phase 1. This TR will include an estimate to increase the bond to the final operations level, and it will include the slurry wall design and french drian design for final approval prior to installing both items.. Response to item 22b: DRMS notes that the existing monitoring wells MW1 and MW2 which were previously included in the baseline water sampling plan have been removed. DRMS will require that water quality data be collected from these wells as previously specified, at least for the 5 consecutive quarters of baseline sampling. Please replace these 2 wells in the monitoring locations for baseline water quality data collection and in the provided groundwater monitoring plan and revise Exhibit G for consistency as needed. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR AUGUST 1, 2023 PAGE 2 ADEQUACY RESPONSE 03 The Groundwater Monitoring Plan and Exhibit 6 - Water have been revised to change monitoring wells 01 and 02 back to Water Quality Monitoring wells (WQM) for at least the first 5 quarters. Thereafter, they may revert to water level monitoring wells (WL) upon approval of the final long term water quality monitoring plan. I have included complete revised copies of the Water Quality Monitoring Plan and Exhibit G - Water. In the WQMP, the Table 2 and Map were revised. In Exhibit G, page 32 under Water Quality the 5th & 6th lines were changed and the revised Well Location Map was replaced. Please also provide a commitment to submit a subsequent TR for providing the 5 consecutive quarters of baseline water sampling data, comparisons of baseline data to Regulation 41 standards, updated water level data, and proposal for long term water quality monitoring by the end of calendar 2024. If you believe additional time is required, please provide the rationale, and propose a different deadline date for submittal of this TECHNICAL REVISION L.G. Everist will commit to filing a Technical Revision to submit the 5 consecutive quarters of water quality monitoring data, comparisons of baseline data to Regulation 41 standards, the updated water level data, and a proposal for long term water quality monitoring, prior to exposing groundwater. Since we are now in third quarter 2023 it would be nearly impossible to install 7 new monitoring wells in 4th quarter 2023. Drilling contractors are in most cases 6 months out and we do not feel it is possible to meet the tight time line you propose. Mining is not scheduled to start at this mine for a minimum of 3 years so there is plenty of time to get the wells installed and data collection started. For these reasons we request that LGE be given until the end of calendar year 2025 to file the Technical Revision to fulfill the above commitment. Available baseline water level and water quality monitoring data will be required to be submitted with the annual report until the baseline water characterization TR is approved and long term monitoring and reporting requirements are finalized — please acknowledge or include in the response to this item. L.G. Everist will commit to filing baseline water level and water quality monitoring data with the annual reports until the baseline water characterization TR is approved. DRMS will accept the applicant's request to leave MW9 out of the proposed water quality sampling locations Thank you DRMS is currently evaluating the provided reclamation bond calculation for the initial processing area and settling ponds. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR AUGUST 1, 2023 PAGE 3 ADEQUACY RESPONSE 03 We have reviewed the Circes Bond analysis and agree that the acreages and volumes match our estimate but that the unit costs used by Circes is larger then our estimates. That leaves little to discuss, we understand the discrepancies between the two estimates and request the amount, be rounded to the closest hundred dollars to make it an even number. I hope these responses have addressed the adequacy questions you had. If you have any more questions please call. LIST OF ATTACHMENTS TO THIS RESPONSE: Exhibit G - Water - revised • Map Exhibit G-1- Wells - revised Groundwater Monitoring Plan - revised Sincerely, Environment, Inc cs. Stevan L. O'Brian President cc L.G. Everist, Inc. Weld County Clerk file enclosures Exhibit G Water Information (cont) by the South Platte River, road corridor and the single irriga- tion return flow ditches surrounding the lined area. These existing water features will serve to regulate and balance groundwater elevations in the alluvium adjacent to the sealed pits. The GWM suggests that once the groundwater reaches the maximum predicted levels it will stabilize and the corridors left through and around the liners will allow water to pass around the liners. The operator does not anticipate any long-term post -reclama- tion ground water depletions, but if there are any, they would be replaced through a Colorado Water Court approved Plan of Augmen- tation. L.G. Everist, Inc. expects that prior to competition of the reservoirs a local government agency will purchase the storage rights and may begin final construction on the reservoirs. As water storage reservoirs are completed, they will be turned over to the purchaser for further development to complete the final features needed for developed water storage reservoirs. L.G. Everist will submit Technical Revisions to the DBMS if the pur- chaser makes changes prior to L.G. Everist receiving final recla- mation approval and acreage releases from the Division. Water Quality The attached report prepared by Molen Associates explains the plan for collecting the necessary background water quality information of the permit area. Included is a list of the chemi- cals to be tested for and their frequency. This plan includes installing 6-7 additional monitoring wells around the mine and will use 8 4 ells that lay outside the proposed slurry walls to collect the data needed for 5 quarters prior to mining and yearly testing Once the 5 quarterly samples are collected and analyzed a Technical Revision may be filed to reduce the required monitoring list for the life of the mine. Discharge Permits Surface Water Management When necessary, ground water will be pumped and discharged from the West Farm Reservoirs mine under a CDPS Permit which the operator will obtain from the Colorado Department of Public Health and Environment, Water Quality Control Division (CDPHE- WQCD). This permit will remain active during the life of the mine. The discharge points may change as mining progresses and all necessary changes will be submitted to the WQCD for modifica- tions to the discharge points. Runoff from disturbed areas will be managed and controlled to protect against pollution, of either surface or groundwater through the implementation best management practices which in- L.G. EVERIST, INC. - WEST FARM RESERVOIRS August 1, 2023 EXHIBIT G WATER INFORMATION Introduction The site is located about 1.5 miles west of Platteville, Colorado. Please refer to EXHIBITB-VICINITYMAP for the property configuration and the relationships to surrounding geological features. The site is bordered on the south, west and northwest sides by irrigated agricultural lands and on the east and part of the northeast side by the South Platte River. There are 2 irrigation return flow ditches that cross the property and other onsite temporary agricultural feeder ditches that carry water to the fields being irrigated. Two center pivot irrigation systems are fed by wells owned by L.G. Everist, Inc. There are 7 regis- tered irrigation wells, one domestic well and 6 piezometers on the property. Within 200 feet or the permit line there is 1 Domestic and one Geothermal wells located in the southwest corner of the site. Based on regional groundwater studies and the experience gained by L.G. Everist, Inc. during numerous previous permit applications they have found that slurry wall liners mitigate any impacts to groundwater on nearby areas surrounding a lined reservoir. Ground water in this area tends to flow from the west towards the river, the depth to water on the flood plane level averages 3.55 feet below the surface and along the western terrace deposit the depth to the water table is 19.5 feet. Data for the monitoring well information collected thru the month of submittal is shown on TABLE G-2 ON SITE GROUND WATER MONITORING DATA. If any significant groundwater changes do occur, they can be miti- gated as discussed below. In May 2023 a Groundwater Model (GWM) was prepared by Schnabel Engineering to provided potential impact information of the ground water levels by installing Slurry Wall liners around the reservoirs. That report is provided at the end of this exhibit. In addition, Molen and Associates was asked to prepare a Water Quality Monitoring Plan for the permit area. That plan is also included in this exhibit. These reports are used in the following text to establish the mitigation and testing plans for the West Farms Reservoirs mine. The mining operation will have minimal effect on the South Platte River in the form of minor groundwater depletions due to evaporation and water uses associated with mining. The depletions to the South Platte will be mitigated thru a temporary Substitute Water Supply Plan (as required and approved by the Division of Water Resources) to prevent injury to vested senior water rights. L.G. EVERIST, INC. - WEST FARM RESERVOIRS 28 August 1, 2023 The reclamation plan proposes the creation of 4 slurry wall, lined reservoirs that will not be hydraulically connected to the South Platte River or any alluvial aquifer. The reservoir areas will be sealed prior to mining, thereby eliminating the groundwa- ter draw down which is typically associated with mine site dewatering. This will also eliminate or minimize the possibility of any adverse impacts to the single nearby alluvial well. Potential Water Resource Impacts Ground Water Wells We expect this mining operation will have no or minimal impacts on the prevailing hydrologic balance. Sand and gravel mining related impacts to groundwater wells near the pit will be mitigated through the installation of slurry walls around the perimeter of new reservoir mining phases prior to the start of dewatering in each reservoir Phase (see ExHIBITD- MINING PLAN) . TABLE G-1 WATER WELLS WITHIN 200 FEET is a list of 12 wells from the Office of the State Engineer's files that are located within 200 feet of the permit area. (NOTE: THE WELL PERMIT LOCATION SHOWN IN THE TABLE HAVE BEEN GPS LOCATED BY THE STATE ENGINEERS OFFICE'S AND GROUND VERIFIED) . All wells except the geothermal well (Blue highlight) are shallow wells, at this time, there is one shallow well within 200 feet of the permit area that is not owned by L.G. Everist, Inc. The Palombo domestic well is located near the southwest corner and is up gradient from the mining area. LGE owns the 8 wells listed for Norgren Farms and is in the process of filing a name change. There are 2 monitoring wells along WCR 32.5 owned by Metro Wastewater Reclamation District, the eastern most one is more than 60o feet from the permit line. Prior to exposing groundwater or installing a slurry wall liner in any Phase, a well survey will be performed on any shallow wells within 200 feet of the phase. Wells that are located within 200 feet of the permit area, that do not need to be tested are(a) owned by L.G. Everist, Inc., (b) monitoring wells, (c) deep wells, because deep wells will not be affected by potential surface impacts due to mining. L.G. Everist will attempt to obtain for each shallow well to be tested the following data: Basic Well construction data that is currently available. Total well depth Depth to static water level, Depth of pump intake • Conduct pump test to determine well yield (subject to DWR Regulations) • Conduct analytical sampling of all Domestic Drinking Water parameters for any residential wells. All data collection will be completed at L.G. Everist's expense. Data will be provided to DRMS and the well owner upon their request. If a well owner chooses not to allow the permittee L.G. EVERIST, INC. - WEST FARM RESERVOIRS 29 August 1, 2023 Exhibit G Water Information (cont) access to collect the above data, they will be provided with a form that they can sign and date to document that they have been provided with an opportunity to have their well characterized at the permittee's expense, but have chosen to decline to partici- pate. L.G. Everist, Inc. has installed 6 piezometers (a.k.a. Monitoring Wells) around the mine and plan to install an addi- tional 6 wells to collect more groundwater elevation data and be used for water quality monitoring and research. Their locations are shown on the maps and on MAP EXHIBIT G-1 WELL MAP . L.G. Everist started data collection in July 2019 and will do monthly depth readings throughout the life of the mine. We will provide a summary of the data yearly with the Annual Report. Mitigation Trigger Starting in July 2019, L.G. Everist, Inc. began to collect groundwater elevations from newly installed monitoring wells on and around the mine area to establish historic ground water elevations around and on the site. The period July 2019 until installation of the Phase 1 liner will be used as the baseline for triggering mitigation actions. This way the baseline data needed for the areas are in place well before installation of the slurry walls will begin. The permit area has two areas where the depth below ground level area vastly different. The dividing line between these land features is a natural bank where the river valley transi- tions from the flood plain on the east side to the upland area along the west side. In the eastern area, Phases 1 and 2, the natural groundwater depths vary from 2.9 to 4.4 feet, average 3.5 ft. below the surface. On the western areas, Phases 3 and 4, the natural groundwater depths vary from 16.7 to 23.9 feet, average 19.5 ft., below the surface between June 2019 and October 2022. These ground water depths and averages may change prior to mining commencing. The important area for mitigation lies along the eastern section of the south line or area along the Abbett Farms land. Along this line the average depth to ground water varies from 7.2 on the west to 4.4 feet below the surface at MW #7, near the river. This covers a section approximately 1860 feet west of the river. The mitigation plan is designed for this area as it could likely be the most impacted if there was a significant increase to the groundwater elevations due to mounding. The model pre- dicts that the potential mounding affect would vary from as much as 2.5 feet on the west end of this strip to approximately 1 foot at the eastern corner of the slurry wall on the east. It also indicates that if needed, a simple perforated pipe, 12 inches in L.G. EVERIST, INC. - WEST FARM RESERVOIRS 30 August 1, 2023 Exhibit G Water Information (cont) diameter would be capable of regulating the groundwater to his- toric elevations. L.G. Everist will commit to installing said under drain along the above referenced section during slurry wall construction in that area. Once final design of the under drain is complete and prior to installation a Technical Revision will be filed with the Division for approval. In this mitigation trigger plan, the trigger limits will be set at as a two (2) foot plus or minus change over a 3 -month running average. Because the average groundwater levels are already close to 4 feet from the surface in the southeast corner of Phases 1, limiting the maximum rise before mitigation to 4.0 feet is too restrictive. The data collected to date shows the historic high to low swing is much as 1.44 feet up or downward possibly due to outside impacts such as, drought, storm events or decreased irrigation. A 2 foot increase over 3 month running averages will keep the minimum depth to below the 24 inches cover level required by the SEO exposed ground water requirements. As for the shadowing effect of the slurry walls, we do not expect this to be a problem where the slurry walls are in close proxim- ity to a flowing water body like the irrigation return flow ditch that bisects the mine site north to south and the South Platte River along the east and north sides. The Groundwater Model confirms that any shadowing or mounding along the river will only affect the property owned by L.G. Everist and will not cross over the river. If during the course of mining or reclamation complaints from the well owner or adjacent property owners are received by the permittee, the permittee will commence an evaluation and investigation, including providing replacement water to the well owner if necessary, within 48 hours. The method used to mitigate groundwater mounding may include a ground water drain along the Abbett property to maintain ground water elevation to the average level measured prior to installation of the slurry wall liner. This drain may be in the form of a ditch or a buried perforated pipe as described in the GWM. DRMS shall be notified within two business days of the complaint and the proposed initial steps for the evaluation of the complaint. A written report will be submit- ted to DRMS within 30 days detailing the information collected during the investigation of the complaint, and proposed mitiga- tion activity, if required. Post Reclamation Any slight groundwater mounding and shadowing associated with the slurry wall sealed portions of the pit are not antici- pated to produce any adverse impacts to adjacent properties. Potential groundwater mounding around the mine will be mitigated L.G. EVERIST, INC. - WEST FARM RESERVOIRS 31 August 1, 2023 Exhibit G Water Information (cont) by the South Platte River, road corridor and the single irriga- tion return flow ditches surrounding the lined area. These existing water features will serve to regulate and balance groundwater elevations in the alluvium adjacent to the sealed pits. The GWM suggests that once the groundwater reaches the maximum predicted levels it will stabilize and the corridors left through and around the liners will allow water to pass around the liners. The operator does not anticipate any long-term post -reclama- tion ground water depletions, but if there are any, they would be replaced through a Colorado Water Court approved Plan of Augmen- tation. L.G. Everist, Inc. expects that prior to competition of the reservoirs a local government agency will purchase the storage rights and may begin final construction on the reservoirs. As water storage reservoirs are completed, they will be turned over to the purchaser for further development to complete the final features needed for developed water storage reservoirs. L.G. Everist will submit Technical Revisions to the DRMS if the pur- chaser makes changes prior to L.G. Everist receiving final recla- mation approval and acreage releases from the Division. Water Quality The attached report prepared by Molen Associates explains the plan for collecting the necessary background water quality information of the permit area. Included is a list of the chemi- cals to be tested for and their frequency. This plan includes installing 7 additional monitoring wells around the mine and will use 8 wells that lay outside the proposed slurry walls to collect the data needed for 5 quarters prior to mining and yearly test- ing. Once the 5 quarterly samples are collected and analyzed a Technical Revision may be filed to reduce the required monitoring list for the life of the mine. Discharge Permits Surface Water Management When necessary, ground water will be pumped and discharged from the West Farm Reservoirs mine under a CDPS Permit which the operator will obtain from the Colorado Department of Public Health and Environment, Water Quality Control Division (CDPHE- WQCD). This permit will remain active during the life of the mine. The discharge points may change as mining progresses and all necessary changes will be submitted to the WQCD for modifica- tions to the discharge points. Runoff from disturbed areas will be managed and controlled to protect against pollution, of either surface or groundwater through the implementation best management practices which in- L.G. EVERIST, INC. - WEST FARM RESERVOIRS 32 August 1, 2023 Exhibit G Water Information (cont) clude sloping disturbed areas inward toward the site, vegetating berms and other disturbed areas, and other site -specific controls as needed. As per the State Engineers Office requirements all stormwater collected for treatment will be discharged within 72 hours after the storm event ends. Estimated Consumptive Water Use The annual consumptive uses of water for the West Farms Reservoirs mine are estimated to be: USES VOLUME Acre-feet 4% Moisture Loss in Materials (1.7 Million tons) 50.05 Dust Control 3.00 Water Surface Evaporation (10 ac) 23.80 Total Consumption (Augmented) 76.85 Substitute Water Supply Plan Ground water depletions associated with L.G. Everist's West Farm Reservoirs operation will be covered under a substitute water supply plan (SWSP) pursuant to C.R.S. 37-90-137, approved by the State Engineer's Office (SEO) for replacement of the ground water depletions due to mining. This plan will be updated and renewed every 2 years. The Applicant will maintain a SWSP throughout the life of the mine. After completion and reclamation of all lined reser- voirs there will be no long-term evaporative depletions. However, if any unlined open surface water areas created by mining remain at the end of reclamation, then a court approved augmentation plan will be applied for before reclamation is complete. 100 -Year Floodplain Portions of the West Farm Reservoirs mine are located within the 100 -year floodplain of the South Platte River. The applicant will obtain a Flood Hazard development Permit from the Town of Platteville if needed. The location of the 100 -year flood line shown on the affected lands was transferred from FIRM Panel 08123C1905E, effective 1/20/16 to all maps. L.G. EVERIST, INC. - WEST FARM RESERVOIRS 33 August 1, 2023 TABLE G-1 WEST FARM RESERVOIRS - WATER WELLS WITHIN 200 FT Cfri a Receipt Permit Number Contact Nome Section Q40 Q160 Latitude Longitude Permit Category Use(s) Completed Well Depth Perforated Casing Top Perforate d Casing Bottom Static Water Level Static Water 1Level Date WDID Associated Case Numbers SE/4-Sec 10 -3N -67W None within 200 feet SW/4-Sec 11 -3N -67W None within 200 feet. SE/4-Sec 11 -3N -67W None within 200 feet. NW/4-Sec 13 -3N -67W None within 200 feet. SW/4-Sec 13 -3N -67W 9063639 264636- METRO WASTEWATER RECLAMATION DISTRICT 13 NW SW 402252 -104.848492 Monitoring Observation (greater then 600 ft) Monitoring! Sampling 25 1. �. Sec 14 -3N -67W 19112 15331-R L G Everist. Inc (NORGREN FARMS) 14 5W NW 40.228169 -104.867362 General Purpose Irrigation 76 207463 W5677 89066 - METRO WASTEWATER RECLAMATION DISTRICT 14 SW NE 40 225342 -104.854051 Monitoring Observation Monitoring/ Sampling 20 10 20 256734 96398-A _ L G. Everrst Inc (NORGREN FARMS) 14 NW SW 40.224885 -104 863161 Residential Domestic 41 21 41 353828 15335-R L G. Everist Inc (NORGREN FARMS) 14 NE SW 40.223387 -104.861225 General Purpose Irrigation 207469 W5677 0353828A 15337-R L G Everist , Inc (NORGREN FARMS) 14 SW SE 40.219348 -104.851678 General Purpose Irrigation 30 10 30 207471 W5677 366352 15332-R L G. Everest Inc (NORGREN FARMS) 14 SW SW 40.249732 -104.8635 General Purpose Irrigation 207466 W5677 15333-R .G Everist. Inc L.G (NORGREN FARMS) 14 SE SW 40,218136 -104.860603 General Purpose Irrigation 53 207467 W5677 9062188 15334-R L G. Everest, Inc (NORGREN FARMS) 14 SE SW 40.2184 -104.857769 General Purpose Irrigation 9 207468 W5677 9062189 15336-R LS. Everest Inc (NORGREN FARMS) 14 SW SE 40.220489 -104.856153 General Purpose Irrigation 35 207470 W5677 NE/4-Sec 15 -3N -67W None within 200 feet. SE/4-Sec 15 -3N -67W None within 200 feet. NE/4-Sec 22 -3N -67W None within 200 feet. NW/4 Sec 23 -3N -67W 9058770 304711- PALOMBO, Jeff (MAGNESS LAND HOLDINGS) 23 NW NW 40.217618 -104.866466 Residential Domestic, Stock 75 20 4/26/2017 9058772 91-GX PALOMBO, JEFF 23 NW NW 40.217753 -104.866008 c&eoexchange System Loop Fivlric Geothermal 300 r NE/4-Sec 23 -3N -67W None within 200 feet. NW/4-Sec 24 -3N -67W None within 200 feet. updated 8/23/2022 slo EXHIBIT G - TABLE 2 MONITORING WELL DATA MONITOR WELL NO. MW 1 MW 2 MW 03 MW 04 MW 05 MW 06 MW 07 NORTHING, FT 1,327,768.61 1,325,656.48 1,326,568.90 1,324,539.64 1,322,997.25 1,323,208.40 1,323,173 33 EASTING, FT 3,176,657.95 3,176,688.06 3,179,344.2.3 3,179,763.21 3,176,684.67 3,179,342.95 3,181,259 32 ELEVATION (TOG), FT 4,799.803 4,801 272 4,779.160 4,782.169 4,804.36 4,802.13 4,791.08 CASING HEIGHT, FT 3.57 3.97 3.74 3.24 3.62 3 02 3.29 ELEVATION (TOC), FT 4,803 368 4,805.242 4,782.900 4,785.409 4,807.98 4,805.15 4,794.38 Adjusted (D08 -D05) 2019 7/10/2019 23_13 19.66 2.48 2 41 15.22 16.98 2.93 8/7/2019 23.37 18.03 3.20 1 75 14.12 16.85 4.36 9/10/2019 23.46 18.45 2.98 2.57 14.58 16.76 4.36 10/8/2019 23.92 19_16 3.01 2.63 15.40 16.87 4.35 11/7/2019 24.15 20.01 3.04 2.81 16.56 17.23 4.21 12/10/2019 24.25 20.65 3.21 2.96 17.52 17.61 4.06 2020 1/13/2020 24.31 20.97 3.24 3.11 18.23 17 86 4.31 2/11/2020 24.31 21.16 3.76 3.16 18.30 17.91 4.26 3/17/2020 24 21 20 93 3.99 3.11 17.43 17.72 4.16 4/29/2020 24.15 20.83 3.76 3 18 17.68 17 78 4.91 5/29/2020 23.95 20.18 3.41 3 ': 2 16.25 17.52 4.64 6/25/2020 23.85 19.68 3.14 2.81 16.01 17.24 4.07 7/20/2020 23.25 18.28 3.28 2.61 16.21 16.81 4.53 8/20/2020 23.60 17.41 3.45 4.56 12.89 16.65 4.81 9/30/2020 23.62 18.65 3.45 2.68 16.12 16.72 4.63 10/29/2020 23 64 19.52 3.24 2.76 14.39 16 89 4.60 11/18/2020 23.88 20.05 3.25 2.87 16.73 17.34 4.05 12/18/2020 24.04 3.11 3.05 16.60 17.71 4.21 20.55 2021 1/14/2021 24.29 20.89 3.25 3.17 18.40 17.8C 4 60 2/22/2021 24.92 21.38 4.05 3.36 19.07 17.97 5 27 3/9/2021 24.51 21.41 3.56 3.16 19.26 17.96 4.28 4/26/2021 24.31 21.22 3.74 3.21 18.53 17.77 4.52 5/25/2021 23.87 20.67 3.44 2.98 17.37 17.53 4.22 6/21/2021 23.83 20 22 3.17 2.57 16.67 17.26 3.89 7/19/2021 23.20 17.39 3.24 2.64 13.43 16.76 4.47 8/9/2021 22.95 20.22 3.20 2.56 12.59 16.65 4.05 9/17/2021 22.89 17.48 3.49 2.73 13.61 16.69 4.63 10/12/2021 23.62. 18.80 3.35 2.67 14.52 16.72 4.25 11/22/2021 23.89 19.97 3.19 2.78 16.71 17.27 4.46 12/2/2021 23.95 20.17 3.14 2.90 17.05 17.39 4.12 1/20/2022 24.99 21.15 4.08 3.42 18.43 17.87 5.26 2/9/2022 24.66 21.34 3.54 3.14 18.86 17.80 4.40 2/27/2022 24.72 21.19 3.50 3.27 18.65 17.86 4.88 3/4/2022 24.48 21.16 3.70 3.17 18.57 17.82 4.43 4/19/2022 24.76 21.37 3.98 3.36 18.42 17.93 5.33 2022 5/17/2022 24.80 20.85 3.88 3.20 16.92 17.63 4.92 6/13/2022 24.03 20.11 3.20 2.75 16.67 17.17 4.00 7/26/2022 23.54 17.75 3.19 2.56 13.24 16 86 4.62 8/30/2022 23.23 17.53 3.03 2.52 12.25 16.72 4.23 9/30/2022 23.58 17.90 2.68 13.62 16.72 4.70 3.12 10/24/2022 23.74 19.04 3.21 2.87 14.46 17.04 4.61 11/22/2022 23.86 19.73 3.30 2.93 15.78 17.28 4.51 12/21/2022 23.98 20.43 3.35 3.01 17.18 17.50 4.36 1/11/2023 24.24 20.63 3.50 3.11 17.88 17.68 4.61 2023 2/16/2023 24.48 21.03 3 55 3 26 18.63 17.86 4.91 3/8/2023 4 23.93 21.03 3 45 3.01 1 18.68 17.78 4.41 MEAN DEPTH TO WATER 23.94 20.20 3.29 2.95 16.69 17.37 4 42 MAX DEPTH TO WATER 24.99 21.41 4.08 4.56 19.26 17.97 5.33 MIN. DEPTH TO WATER 22.89 17.39 2.48 1.75 12.25 16.65 2.93 NET CHANGE 2.10 4.02 1.60 2.81 7.01 1.32 2.40 average depths terrace wells 19.55 FP wells 3.55 35 c. L.G. TESFARM RE5E1VOIR5T Map Exhibit G-1 - Water Wells Within 200 feet NOTES 6 5J id�4-�— 6Q I r2 6 I 2 6 Ipf '2 6 \I I 2 6 I" 1 2 6 6 /6k C.4:6 1 6 6- 6 6 n I 6 6 6 6 1 6 1 6 I 2 2 2 664:76_76__,`77_,___ -_6'."6..7 6.^"'6-" emir 2 6176 2 I 479 2... (en_ A MW -01 (WQM) 7 D-96398 O `' MW -09 (WL)- ` TV/ r N. WEST =ARM 1324949 ft. N 3176625 ft. E \��`�. MW -08 (WQM/POC) � • MW -03 (WL) N ll I ' I -15332R I -15335R i r S 6 MW -12 (WQM/POC) l I)l� 'It MW04 (WL) • -1 5336R Q • cD 0 c 0 IL \ M W -26463E f -:sNSA I -15337R MW -06 (WL);:kt 1 ‘ ' 1 'Y2` 6 MW -05 ,WQM)-MW-14 (WL) MW -10 (WQM) '� MW -13 VW -07 (WQM} 2 - 4- ,,o. . ril-15334R �� 2-2— l2 ' ' /61 --2—`"2—..2.-..2-2-2`2-2-2-2 . V 6 l 6 6 )O, t____)co II "or is - ' D3CM71 6, 6 066-6-6 co I) 1. Data for wells shown on this map are listed on Table G-1 and is from the State Engineer records. 2. Well locations shown on the map are confirmed via ground check. 3. All wells except the Geothermal (GX) well are shallow wells. 4. Proposed new WQM well locations shown on map may change when installed. 6-6-6--6--6--6 6 6 rr 6 WELL KEY 6 6 6 Verified Irrigation Well Domestic Wells I Geothermal Well 36 • ■ A • Site Monitoring Well WQM Well WQM/POC Well Third Party Monitoring Well 2 2 200 FT. Offset 6 6 600 FT. Offset 4 EXHIBIT 0 Monitoring Well Graphs WATER (CONY) 4805 00 4800.00 4795.00 4790.00 4785.00 a a a 4780.00 v v a 41. A A 0) czn v v 00 Cl' ' 4775.00 4770.00 4765.00 4760.00 A -4 • (O V UPI CP O) w in CP V' A A a -4 O) -4 OI O 00 O) N A V V A V V cn V O) V1 J A V V en ^ W A V A Co W v e CO A V V lA CP A V W N A V V A v V 'i. N A V ✓ 9) O) a a V V CVJ, cn CP N CP A ✓ ✓ In W N Ground elev. 4799.8' —0—MW1 Water Leve datal Ground Surface —Average (4775.86) —Max (+2) Min (-2) moo\,�\tio~ \�o\'1°��o\�\��\A\tio~ \moo\tio~��\1~��\no1'�\�A\fin a\�ch\so~y\�cb\tio��y\ti\%el%o \,yo\titio\')o\�°tioia\`ono�~o�o\��\tio�oa�o1,\ ti a tio titi titi ti ti tiois tiis tio-v. tio~. his "°~s '�~, ti°�. ~. 4)\a\ a\.y6\ yin'\ 43C. 10. �\o,\ 0,\'' % 1\ tio\�� C. ti se oel. a\~o1~ a\1o~� \�~� \�Q~ry o\�~~ \�~� \�o�� a\no~ti \titi titi \�oy� \�oy� 4,„ ,\ti 1.<4 "'\ a\~ y\� r,\~ ACV 48r ,\�o tio\ti titi\ti �ti\ti ti\ti \ti y\ WEST FARM RESERVOIRS MW #1 EXHIBIT O Monitoring Well Graphs 4805.00 4800.00 4795.00 4790.00 WATER (CONY) A V CO co 4785.00 " N a 4780 00 4775.00 4770.00 4765.00 • A V CO N Go N Ground lee 4801.27' a a laCo V/ da A en A V CO J 0 A V 03 J w O A v 03 J J O A V e O .1 a a a a v cp o o fa la se N A V CO J O) A A a V V V CO co C.,O <') CO v V N a G3 N N A a, A A V CO A a Pt lY� O 0 —f- MW2 Water Level data Ground Surface Average (4781.07) Max (+2) Min (-2) ,e).- 4 \��\�o~��\~o~ \�oct. \92\�~� �1`�O~titio) \�,ct9i �\~0~\�1\~o~\tip'\�o4 \tip'\~oti�'\�oti°\�o�oti°\~ono'°\�o~o°\~�`~oti`\~�\~oti�~o�°\~o~>' 1 of ti ti ti ti% 'Ii t h ro\ 1\ 4 A\ 1\ ~O~, .1gti� ,ti0ti� , ,ti0.yti ,ti~ .ti0ti% ASV \�~0 \�\,ti0 �, pC 0�\1��~ 11�~� p\1~� 0�\'16~) 1\'10~.)•\'1~� \1o~~ p\'1~~ p\�~� \ti\~O. •ti4. \4. ",o b\'tir°\ h\% 43\'� "k\N' c\o�\ \'tip\ 1 s �\ \ \ti \ 1\ 1. 4 1 1 N" ti i '5 % .%) of ti ti '1� p\ y\ ro\ 1\ �\ �\ 'L' WEST FARM RESERVOIRS MW #2 EXHIBIT O Monitoring Well Graphs 4780.00 4779.00 4778.00 WATER (CONY) Ground lee 4779.16' r N O) 4777 00 in 477600 4775 00 4774.00 4773.00 4772.00 A v v 4771.00 , , , „ 4:1 O ti0 ,yO 1O ti0 .tiO .tiO .yO .yO .yO .�O ` ,o.-ryO .tit 1\cb ~° \\~° q\~°\~° 1°\�\� '�1\1\~° �~~°� �~y\~° '1\�~\�'�4\ ' a\~cb\�° y\~�\~° 41. 'Or rb\�°\� o�\�\�° °\��\% ��'�\� \1 r �y\1ti MW 3 water level data Ground surface" Average (4775.87) — Max (+2) — Min (-2) • \ti°1' J e\�°ti~ y\ti� .,\+iv \no> o,\t 1\�°ti~ \may\ti° ��\ti° .��oti~ \�otiti \�°titi \�titi \�°titi \�yti \�°titi \�titi \�titi \ry°titi \�otiti ° ° ° ,6\ �1 y~ ro 1 \ O 1\ %�\ O \oi \p b 0 y -09 �O y0 O p\ \ y\\, O1� O1, O1b WEST FARM RESERVOIRS MW #3 EXHIBIT O Monitoring Well Graphs WATER (CONY) 4783.00 4782.00 Ground elev. 4782.17' 4781.00 N V N 4780.00 rn 4779.00 4778.00 4117.00 A cn -4 u) - v v en (n a w - A co a A a N a a v v o co 4776.00 • 4775.00 MW4 Water level data ground surface Average (477S.22) Max (+2) Min (-2) 4774.00 Ob°� 01O 01A 01O 01O 0ti9 0.10 O'1O 0110 ic19 on, 01'9 09. 019° 0.1,0 0'19 01O 01O O'11 0.* O1~ 01'1 01~ 0ft> 011• 011' 11 1~ 1~ 11 01~ 01~ Oil 'btFF�'\1\~ a\~O�~1\~~\� y\11\~ a\c�\1°'\~ \1h\~1\1O\� g\19\� o,\�O\~ 0\1�\� t\1�\,t\7\1a\~ 1\1ti\~\�\~ p\14°\~6\%AN N3\~ �\�\�\11\��0\tiAN �,\AN,�Lk x\19\1. 1\CP.,y\�1.0° \30\1, \�A �o\gypC �1\�,ti\' ��\�1\1. \�\11- fro\1. \�\1 WEST FARM RESERVOIRS MW #4 EXHIBIT O Monitoring Well Graphs 4810.00 4805.00 4800.00 4795.00 WATER (CONY) co a a k) to mai {p a V .a 0D 4790.00 rib. Age".. 4785.00 4780.00 a V CO CO a 03 0) v a 03 CO ema A V OD a) 0) V w rn A -1 A V OD CJ1 A V OD .rte a V V 03 03 -/ v 0) -+ W rn a ✓ CO a CO ti V • a v O) O) Eiji cri co \is:N...7i V OD cn co a V a CO "NJ al CO ✓ V O3 o3 V CD C71 Se A ✓ 03 a V W3 —5 V 8 V A A V 00 fn V 03 93 a V 4775.00 °tia e oti� oti3 \tio. Otio 09 a 019 09 o,Lo o,Lo c09 o,Lo aS %\.Lo o ti N ti ti ti ti ti o` o` ti 1- ti ti ti ti ti 1 1 ti o 1\%O\ti \1\ti yo\ti ,O\�\ti �1\,�\ti �.y\'ti° \�, „AN, \� \.y1\ti a\,Lai\� h\,y�\ti \1, 41O\1 p\'1' p\� \'tip A's \tip'\ a\ \ • q\t" \� \t' \I' \�' \�' � \% 4 '1' \'1' \1' \1' \1 \'1' \1' \1' \1' \1 \1 1a �'L �41. /91' \L Ground lee 4804.36' a A V V en cc W OD K --- MW 5 Water level data Ground Surface Average (4787.67) Max (+2) Min (-2) 'L L°% �L01� 01, Oti Oti Oti °ti 01. 011\ti 01. Q1�� °1. Oti °ti °1, °ti Oti 01, °ti pti \i, \10� ''� h a 1 L o a 1 a 1 �, o o \ \ \ \� h 0 1 � 'ti ti 1 (1\ �0 1 b � ti ti\ % a�\'� ti° ti titi ti\� , 4,\ t% 44 \ti \ \� �\ \� ti° ti \ti ti\ \1. ,,\ \ti ti \ti \1 \� \� tio titi tit \ti ti \�' WEST FARM RESERVOIRS MW #5 EXHIBIT 0 Monitoring Well Graphs WATER (CONY) 4805.00 4800.00 4795 00 4790.00 A V A V C31 (n 9CO CO 1 CO cn co V 0n S 4785.00 4780.00 4775.00 4770.00 A V N v a N A co co QVD cn th can U1 CO kr lib A a a a a V V V A Co CO V a co r.) co • a V a a a a a V V V v -4 a A a a 03 01 (( 00 U1 cn A es A a A 5f 4'' CO A A a O 'coO V N W W O (.i m V a) ?s ao V a a a a a A O a IV W N N O O CO V O V a a A V V A A A is A a N CO 90 � ¢ w � w Ov "" A 03 U1 A V 03 w t A ✓ 00 a A N en W A V A A Cr Ground lee 4802.13' A Cu A a N W ✓ 01 1►- MW 6 Water level data ground surface Average (4786.6S) Max (+2) —Min (-2) eeee cp. ocv of '1 ti cf of oN, oN 01'0 ti0 y0 10 .�O 19 ti0 1° ti0 y0 ,ti0 .ti0 ,L'` do \y6N\ e\�\�o�,\4 o\ti�'\�o�\.(1- o\oo,\'o\~ �o\ti%Cr ti\�\�oti\~�'\�o ~a\~oti\ or \\tio�~,�o\tio�~tiy\tio~~��1tio�~ti�\tior \o,\tio~~ti�\ti(yr �ti\nor rtc~y 3 +r\ 4 a A\ 4 0\ is. ,yoyy .e ,yoyti .yoyti tio~o% ^otiti ,yoyti yotiti dtion. yo • y\tio\ ti\o\ 41. '#\Q\ o\tip\ h\4' k\%* \s‘•ttP c3\'' o\t titi.\ 01~ 01~ 013 o" al. 4.3c• WEST FARM RESERVOIRS MW #6 EXHIBIT 0 Monitoring Well Graphs '1732.00 4790.00 WATER (CONY) A v 03 03 rn Ground lee 4791.08' 4788.00 \ v co \ \W 4786.00 4784.00 4782.00 NJ NI 03 03 O) O) W A v OD a ti CO A v CO rn 00 03 a coo covV a a COV0000 a 'V 4sNa A A V A CO • CO N v A a V O O0 a Vr O v a OD O OD O v N4 O) N O -.4 00 0o A 00 00 0o Cr) 00 OA a 03 CO O illQO) O O O O a a f fl 4 -'"\ a) O Z 00 / \ N. A N 00 a W A v 00 a a ✓ A 03 COVago o arn A V Cona O0 a CO a CO Co Oo J CO▪ 00 CO a 0) v v O O O v a) v 03 cn rn rn a rn �`�'` A 'CO OD ▪ in w 'A y� i` v ao Lao __/n\ (J1 �l OD v ��.. A N CO O�) Q) 03 MW 7 Water Level data —Ground Surface Average (4786.67) —Max (+2) — Min (-2) 4780.00 1 Lptiy \ ~p~� Y ,4pti� \ ti�~y ~O~y 1 ~O�� ti �O�O ti ti��o ~ ��1D �y�otiO �y�tio 1y\��19 yo\��'1��o\ryp'L�yo\�p'L� y°)\��L� 1�\�O'L� 1�\�6ti9,�\�0'L11 \�O'L, \ \��'L~�e1/2/eptecteol �'L1.y ��.1 ��L1 ��'L, 'L� ��1� ��'LA ��Ll�p'b� %O'L� 191129#0, �pLL ��1'1 �o.�'L oti'L .tiL oti1 ,�'3 �oti"� ��tih o\ �\ o\ �\ �\ o\ �\ ti\ �\ \ \ ti �, �ti\ o,\1\a\ �\ 1\ �\ co\ o\ o\ a\ -y\ ti\ �\ c,\ \'1\`b�i\1O yti'L\y\-y\'�\ p\ y\ ro\ 1\ �\ o)\ gyp\tip\ ��\ti\ -y\ ')p\gyp\ �1\ 1'L\ 1\'1 1\ 1\'1 ')\ p\� y\ti (o\'� \°' o�\'ti ,yp\1 ,�\1 '1> % r‘ ')\ WEST FARM RESERVOIRS MW #7 Protective Steel Casing Concrete Base II =1 IIIiIIi,IIIItIHHWIHH iillliiillliiillliii • i i • 1111-i - HHIIIHHHHIII HI I irIII -III -ir Bentonite--- Chips Silica Sand Backfill • Slotted PVC Pipe • Pt M 7 /, ///' / // // /////// r•• • . •• ••r h. . • •\ . •• C 5 :. •. de • / • • • • • .. A ,• •• • . ••,. .`. r• V• •• • •' • i 1 2" PVC Pipe • iii -iii - I 11=1TII 11�=WI-Hifir -III HI I HIIIIIHIIIIIHII Sand and Gravel Deposit • • • • • I. AA // e // / ;;;; an !LC( - ANN r PUN LIMO 3112010 WALE w► CAB rn.r, Fh silia Prlsl'no_ ' --Mal s aa� tn. Sea IMOa`baO.sa i( ) S-asta /<; SUN 13, 202J 34:4/ Typical Monitoring Well Installation Groundwater Monitoring Plan LGE - West Farm 10482 County Road 32.5 Platteville, CO July 29, 2023 Prepared for: L.G. Everist, Inc. 7321 E 88th Avenue, Suite 200 Henderson, CO 80640 Prepared by: Molen & Associates, LLC 2090 E 104th Ave, Unit 101 Thornton. CO 80023 Groundwater Monitoring Plan TABLE OF CONTENTS 1.0 INTRODUCTION 2 2.0 MONITORING PLAN COMPONENTS 2 2.1 Moritoring Well Site Selection 3 2.2 Water Level Monitoring 3 2.3 Water Quality Monitoring 4 3.0 REPORTING 5 4.0 VERIFICATION RE -SAMPLING 5 List of Tables Table 1: Existing Monitoring Wells Survey Data (7-7-2023) Table 2: Existing and new Well Locations Rationale Table 3: Sampling Parameter List (7-7-2023) Table 4: Parameter Exclusion Rationale (7-7-2023) List of Figures Figure 1: Map Exhibit G-1 Water Wells Within 200 Feet Figure 2: Groundwater Elevation Contour Map Figure 3: Typical Monitoring Well Installation LG Everist Monitoring Plan Page 1 of 5 Groundwater Monitoring Plan 1.0 INTRODUCTION LG Everist, Inc is planning to mine aggregate resources from the West Farm property as outlined in the mining permit. The LG Everist, Inc West Farm site, hereinafter referred to as LGE-WF site, has applications for approval of the mining permit. In the LGE-WF site plans, detailed descriptions of the physical geography, geology and hydrogeology have been made. The purpose of this Groundwater Monitoring Plan (GWMP) is to assess the potential of the introduction of pollutants into the groundwater during mining activities and to describe the program to assess if and how water quality may change over time. The plan also provides information about the collection of water level measurements to show water level changes over time. A separate Groundwater Sampling Plan GSP) is prepared and describes groundwater sampling procedures, sample handling, and laboratory analysis. This GWMP will designate what data is collected and how it may be interpreted and may be modified as the mining activities progress and new information arises or changes. The GSP presents the sampling methods used to obtain the groundwater samples. Both the GWMP and the GSP will be followed for all groundwater monitoring done at the LGE- WF site. The Division of Reclamation, Mining and Safety (DRMS) calls for a GWMP for the LGE- WF site for the mining permit. Existing groundwater wells have been used to measure water levels over the past two years. The groundwater well locations, to be used for water level measurements and groundwater quality sampling, are shown on Figure 1, Map Exhibit G-1 — Water Wells Within 200 Feet and are shown on other maps in the mining permit plans. Survey data for the existing wells is in Table 1. Some of these wells on the LGE-WF site will be used to obtain baseline groundwater quality data for the LGE-WF site. Additional groundwater monitoring wells are also planned as shown in Figure 1 and described in Table 2. Groundwater monitoring wells are generally in locations that will not be mined or will not be mined in the near future. New wells or replacement wells will be placed in the general area of the existing well and be installed to monitor the same water bearing zone. 2.0 MONITORING PLAN COMPONENTS The current groundwater monitoring well locations are shown in Figure 1. The well monitoring network includes fourteen wells all completed in the uppermost aquifer. A few of the existing groundwater monitoring wells are in areas that will be mined. These wells will not be used for groundwater quality monitoring and will be removed and abandoned in the future. Monitoring wells are located in up -gradient and down -gradient bi ASSOCIATES LG Everist Monitoring Plan Page 2 of 5 Groundwater Monitoring Plan positions in the alluvium. Additional monitoring wells may be included in the future as necessary, or in response to regulatory concerns. Water quality monitoring sampling will begin within the next quarter following regulatory approval or consensus from DRMS. As proposed, the data collected will be used to develop a baseline of data for which future comparisons can be made. Once the baseline data collection is completed, then future water quality samples collected from points downgradient of the mining operations can be used to assess potential changes in water chemistry that might cause overall changes in water quality downstream. Baseline data will be collected from each monitoring well designated as a groundwater quality monitoring well. Some groundwater wells will only be used to collect water level information (piezometers). 2.1 Monitoring Well Site Selection The Rationale for monitoring well placement is presented in Table 1. Figure 2 presents a groundwater elevation contour map that was constructed from water level data obtained from the existing monitoring wells. The average (mean) groundwater level was used to construct the groundwater elevation contour map. The groundwater levels generally followed the topographic gradient, with water flowing generally from a west- southwest and south direction to a north and northeast direction. All of the wells are (or will be) completed with a 2 -inch diameter PVC casing and screen. Typically, the wells are constructed with screening across the entire water bearing zone, with solid piping to the surface completion. A sand pack of natural or washed sand is placed from the base of the well to one foot above the screened interval. A locked metal casing will cover the PVC casing from a concrete pad installed at the ground surface. The tops of the monitoring well will be encased in a lockable metal casing. Figure 3 presents a typical monitoring well installation and construction. Three new groundwater monitoring wells (MW -08, MW -11, MW -12) will be installed as the downgradient water quality sampling points. These three downgradient water monitoring wells are considered point of compliance (POC) wells. Other wells may be installed as needed. All wells are, and will be, permitted with the State Engineers Office (SEO) Division of Water Resources All wells are and will be constructed (and abandoned) according to the SEO standards. 2.2 Water Level Monitoring Water level measurements will be made in accordance with this monitoring evaluation plan. All monitoring wells will have water level measurements on a monthly basis. Exiting wells and future wells are constructed in accordance with the typical water MOLCEN & ASSOIATES LG Everist Monitoring Plan Page 3 of 5 Groundwater Monitoring Plan monitoring well instillation diagram in Figure 2. Water level measurements collected in concert with water quality sampling will serve as quarterly water level measurements for the purposes of this monitoring evaluation plan. 2.3 Water Quality Monitoring L.G. Everest commits to obtain the water quality samples on a quarterly basis for five quarters prior to exposing water during mining. The water quality data will be used as a baseline, while subsequent water quality data, (obtained periodically) will be compared to the baseline data to assess water quality variations. Parameters with significant non - detects or are determined to be unrelated to mining and/or mining activities will be proposed for removal on a case -by -case variance. Sampling frequency after the five quarters of baseline data will be periodic and is assumed to be annually. The method proposed for the water quality assessments is discussed in the following section. Water quality monitoring wells and point of compliance wells will have water quality samples collected quarterly for the first five quarters and then on a regular basis (at least annually) using the Groundwater Sampling Plan. Table 3 lists all the parameters found in the DRMS June 9, 2023 Groundwater Monitoring Sampling and Analysis Plan Guidance — Appendix A with an asterisk on certain parameters. Several of the parameters are not relevant to the mining operations and it is requested that they be omitted. The Rationale for omitting the asterisked parameters is found in Table 4. Parameters for the initial five quarters of baseline sampling will be those on Table 3 that did not get approval for omission by DRMS. Collected samples will be preserved as recommended by the analytical laboratory and will be recorded on field data sheets and the laboratory chain of custody. Once baseline water quality data is obtained, a proposal will be submitted to reduce the number of wells and parameters to be quality monitored in the form of a DRMS Technical Revision (TR). Point of compliance wells will be utilized for the collection of water quality data for the life of the mine or until monitoring is released by DRMS. Monitoring wells in upgradient and downgradient positions from the specific phase of mining will be used to assess whether water quality degradation could be occurring. The first five quarters of samples collected from the water quality monitoring (WQM) and point of compliance (POC) wells will be analyzed for the parameters in Table 3, a list including parameters from the CDPHE Regulation 41 — Basic Standards for Groundwater. Groundwater samples collected after the first five quarters will be analyzed for a new list of parameters approved by DRMS in a TR. Parameters detected above the Table Value Standard on the Sampling Parameter List (Table 3), as revised or amended in the future, will be highlighted. r�-, MOLEN & assot�ares LG Everist Monitoring Plan Page 4 of 5 Groundwater Monitoring Plan 3.0 REPORTING Groundwater monitoring data will be presented in a table including the sampling date, parameter results with graphs and/or plots for selected parameters, and a comparison to predictions and to the groundwater quality standards. The parameters that exceed the Table Value Standard on the Sampling Parameter List will be highlighted with bold or colored fonts in the report. The groundwater quality data report will include a narrative analysis of the data and identify trends and anomalies. It is proposed that control charts, generated on a quarterly basis (for the baseline period, then annually after that), be provided to the Division on an annual basis to demonstrate changes in water quality with time. If exceedances of the control charts are noted after regular annual sampling, a specific response plan will be prepared by LGE to address that issue. The specific response plan would be based on an evaluation of the number of selected parameters that show exceedances and the duration of these exceedances. 4.0 VERIFICATION RE -SAMPLING Under certain circumstances a verification re -sampling may be collected, and samples submitted for analysis using the Groundwater Sampling Plan. The samples will be collected within four weeks of the analytical report date. A verification sample may be collected during the following sampling event depending on the frequency of sampling. Verification re -samples are designed to provide confirmation of the sample analytical data for sample result anomalies or statistical analysis. V`,MOLEN & assoaarEs LG Everist Monitoring Plan Page 5 of 5 Figures and Tables 1 dioneftdridISROMBRIMMO N 6t76 1 6 0Pa'21 3d134 6 . I ,A2 e- 6 i 6 1 6 6 i 6 2 r ne 2 1 2 g 1 _LA r27 I 2 6 I I 6 I 1 2 6 I I 2 6 I I 2 =6 P NOTES I 6 i 6 1 6 I 6 Z 2 2 2 )-2-al �r2-s 9 D3Cg71 6, 60 -6- L.G. Everist Inc. WEST FARM RESERVOIRS Map Exhibit G-1 - Water Wells Within 200 feet 6,i6 MW -08 (WQM/POC) � eTh A D-96398- eir' MW -09 (WL fas�' WEST FARM 1324949 ft.11 3176625 ft. E I-153358 4-1 ram\*C:itis i 1 I • I-1 5332R a 6—•6� 6 _ 6-�6''=6 2.2 , 6 ilL6 t.„ �� t4 .2. �•� sit •N a n a ..BMW -26463E i � 1ti MW -12 WQM/POC ^ 6 my R4 sir ‘1111 2 .,6 6 MWO4 (WL) • I -15336R MW -06 (WL) MW -05 (WQM). MW -14 (WL) - MW -10 WQM) • _ - ( MW 13 (WL) ..te <Lc 04. 4 l -15334R• 2 ;2 2-2-2 2 91 GX 2 2-1211321232 6-6-6-6--6-6---6-6 1. Data for wells shown on this map are listed on Table G-1 and is from the State Engineer records. 2. Well locations shown on the map are confirmed via ground check. 3. All wells except the Geothermal (GX) wel are shallow wells. 4. Proposed new WQM well locations shown on map may change when installed. WELL KEY 2 teAs,16 'MW —07 (WQM) 6 2-2 6---6 • Verified Irrigation Well Domestic Wells • Geothermal Well • Site Monitoring Well • WQM Well • WOM/POC Well * Third Party Monitoring Well 2 2 200 FT. Offset 6 6 600 FT. Offset Figure 2 m—Base.dwg D:\OOSRV\M\clients\Molen\LCE West V29.90 LEGEND Monitoring Well Location -4784:00- Groundwater Elevation Contour (feet amsl) 4779.30 Groundwater Elevation (feet amsl) Groundwater Flow Direction 0 600 1200 SCALE IN FEET 1 • lattevil! e LG EVEREST WEST FARM Groundwater Elevation Contour Map 10/24/2022 Figure 1 MOLEN & ASSOCIATES, LLC Figure 3 Protective Steel Casing Concrete Base I=III=1 II. H=1TI 1 IIIIIIIIIIII l III III tIliitIliiiIII iIII III i • = 11iII1t1Iit11'i1i'1111r1 II.IIIIIIIIIIIIIIIII.I 1 �� Bentonite Chips 1 Silica Sand Backfill • Slotted PVC Pipe •• u II'III'iii--ii i in • .• • • :• al • • .• •• • %.S • • •• • • .• • t'. • ,.•. •t • 4 •• — 4.1 •.. • A 0. ••♦ •:: •• ,••• . 45 . • - • •• .,• / • • • •% 4• •••••• • ' • •f •• V. '. . • .w• •• • •= • • • • • • • • • qt. • • ••! • ,. • • 1 •. . v• S. • S. • ..• • r. s• • •r .. • ••••. i i i 2" PVC Pipe i il•-ill Ii I1 III I1 ItHI II 11 III II II Illi III II III iillli Sand and Gravel Deposit • ///2 ..,..., ///// ;.>"// Iry • wr • NII A DRAWN iv. PUN DATE, Sao SCAM CAD FILE; L.O. tirerista Asp Si R. DIM a IPS f. Mali.... as ...w ONO Sys. I1:i4:-4/ Typical Monitoring Well Installation Groundwater Quality Monitoring Plan Table 1: Existing Monitoring Wells Survey Data (7-7-2023) MONITOR N WELL O . NORTHING, EASTING, FT ELEVATION FT (TOG), CASING FT HEIGHT, ELEVATION FT (TOC), FT MW 1 1327768.606 3176657.946 4,799.803 3.57 4,803.368 MW 2 1325656.483 3176688.055 4,801.272 3.97 4,805.242 MW 3 1326568.902 3179344.23 4,779.160 3.74 4,782.900 MW 4 1324539.638 3179763.207 4,782.169 3.24 4,785.409 MW 5 1322997.254 3176684.665 4,804.36 3.62 4,807.98 MW 6 1323208.398 3179342.954 4,802.13 3.02 4,805.15 MW 7 1323173.328 3181259.315 4,791.08 3.29 4,794.38 MOLEN - & ASSOCIATES LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Table 2: Existing and New Well Locations WELL NAME LOCATION GRADIENT TYPE RATIONALE MW -01 NW PHASE 3 DOWN WQM Existing — NW corner of Phase 3 MW 02 SW PHASE 3 CEN ALL CROSS/UP WQM Existing — SW corner of Phase 3 and west central of at mining, north of Phase 4 MW -03 NE COR PHASE 2 ALL DOWN WL Existing central east and north MW -04 MID N CEN PHASE 1 MID WL Existing central east and south MW -05 SW COR PHASE 4 UP WQM Existing SW corner of Phase 4 MW -06 S MID BDRY PHASE 1 UP WL Southern boundary central MW -07 SE COR PHASE 1 UP WQM Existing eastern boundary MW -08 NE COR PHASE 2 ALL DOWN WQM/POC New well northeast boundary of Phase 2 and all Phases, down gradient MW -09 MID N CEN PHASE 1 MID New well north boundary of Phase 1, south of Phase 2 and central for all Phases MW -10 S MID BDRY PHASE 1 UP WQM New well southern boundary central MW -11 NW PHASE 2 N ALL DOWN WQM/POC New for NW of Phase 2 and NE of Phase 3 MW 12 SE PHASE 2 E CEN ALL DOWN WQM/POC New for SE of Phase 2 and east central all Phases MW -13 SE PHASE 4/S CEN ALL UP WL New for SE of Phase 4 and S for all Phases MW -14 SE PHASE 1 SE ALL UP WL New for SE side DOWN = downgradient NW = northwest SE = southeast POC = point of compliance 17O MOLEN & ASSOtIATE5 UP = upgradient SW = southwest COR = corner BDRY = boundary CROSS = cross gradient NE = northeast WL = water level piezometer ALL = services all phases WQM = water quality monitoring LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Table 3: Sampling Parameter List (7-7-2023) Analyte Table Value Standard (mg/L unless other units given) Reg. 41 Table Reference (1-4) pH Field (pH unit) 6.50 - 8.50 2 and 3 Coliforms Total (30 day average)* 2.2 org/100 ml 1 Asbestos* 70000 fibers/L 1 Chlorophenol* 0.0002 2 Color* 15 color units 2 Corrosivity* noncorrosive 2 Foaming Agents* 0.5 2 Odor* 3 threshold numbers 2 Phenol* 0.3 2 Free Cyanide* 0.2 1 TDS 400 mg/L or 1.25X background 4 Aluminum - Dissolved 5 3 Antimony - Dissolved 0.006 1 Arsenic - Dissolved 0.01 1 Barium - Dissolved 2 1 Beryllium - Dissolved 0.004 1 Boron - Dissolved 0.75 3 Cadmium - Dissolved 0.005 1 Chloride - Dissolved 250 2 Chromium - Dissolved 0.1 1 and 3 Cobalt - Dissolved 0.05 3 Copper - Dissolved 0.2 3 Fluoride - Dissolved 2 3 Iron - Dissolved 0.3 2 Lead - Dissolved 0.05 1 Lithium — Dissolved* 2.5 3 Manganese - Dissolved 0.05 2 Mercury - Dissolved 0.002 1 Molybdenum - Dissolved 0.21 1 Nickel - Dissolved 0.1 1 Nitrate (NO3) 10 1 Nitrite (NO2) 1 1 Nitrite + Nitrate as Nitrogen 10 1 Selenium - Dissolved 0.02 3 Silver - Dissolved 0.05 1 Sulfate - Dissolved 250 2 Thallium - Dissolved 0.002 1 Uranium - Dissolved 0.0168 to 0.03 1 Vanadium - Dissolved 0.1 3 Zinc - Dissolved 2 3 Beta and Photon emitters* 4 mrem/yr 1 Gross Alpha* 15 pCi/L 1 * Parameters to be omitted from sampling requirements based upon the Parameter Exclusion Rational discussed in Table 4. I 1 MOLEN & ASSOCIATES LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Table 4: Parameter Exclusion Rationale (7-7-2023) Analyte Exclusion Rational Conforms Total (30 -day average) Human and animal waste contain fecal coliforms. Bacterial coliforms are naturally found in the environment. Ingestion of coliforms is dangerous and can cause serious illness or death. It is expected that coliforms may be present in groundwater throughout Colorado and the sources are associated with excrement from animals in the natural environment. There are no coliforms being generated from mining activities at the LSE -West Farm site and as such, coliforms should be excluded from the monitoring parameter list. Asbestos Asbestos is a mined mineral with special characteristics of strength, filtration, and fire resistance. Asbestos was widely used in products in the first part of the 20th century. Later it was found to be a lung carcinogen and is now known to be an ingestion hazard as well. Asbestos uses are limited, and it is generally omitted from products where it was once found. Asbestos abatement from schools and private structures has been ongoing since the mid -1980s. Asbestos from abatement products is strictly regulated and documented disposal is required. Asbestos fibers in soils are regulated by CDPHE, and when found, are required to be removed and disposed of properly. Asbestos is not associated with the geology of the LGE West Farm site and should not be in natural formations at the site. It is regulated because it is a known carcinogen and water containing asbestos should not be consumed. The groundwater at LGE-WF site should not contain asbestos. There are no asbestos mines in Colorado. Water at the LGE West Farm site is not used for drinking water. There is no reason to expect asbestos in the groundwater and it should be an excluded parameter for the LGE-West Farm site. Free Cyanide Free cyanides are the cyanide containing compounds that can liberate cyanide gas in a neutral or slightly acidic environment. Hydrogen cyanide is the most common free cyanide. Sodium cyanide and potassium cyanide are readily soluble in water and, like hydrogen cyanide, produce cyanide gas in slightly acidic water. Cyanide gas and free cyanide in water are extremely poisonous. However, cyanides have to be introduced from a source, a pollutant in the water. Cyanides are not used, produced, or found in any mining activities at a sand and gravel mine. Cyanides may be associated with precious metal mining during heap leaching or related activities, but they are not at a sand and gravel mine. There are no manufacturing facilities around the LGE West Farm site. For these reasons, free cyanides should be excluded from the groundwater monitoring parameter list. Chlorophenol and Phenols Chlorophenol is a group of organic compounds that are synthesized and not generally found in nature except as pollutants from a specific source. Chlorophenols are only slightly soluble in water. The most commonly identified chlorophenols are: • Monochlorophenol - used in modest volumes, as dyestuff intermediates and in the manufacturing of higher chlorinated phenols • Dichlorophenol - used in larger volumes in the manufacture of the herbicide 2,4-D and other related chlorinated herbicides MOLEN & AssOCIATEs LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Trichlorophenol - used in the manufacture of herbicides, primarily 2,4,5-TP (Silvex) which has been banned in the United States for decades. Tetrachlorophenol - used as a preservative. Pentachlorophenol (PCP) - used as an antimicrobial wood preservative and historically coating on utility poles and cross arms. PCP is often mixed with creosote or other wood coating products. The US EPA is phasing out the uses of PCP over five years beginning in 2022. Wood treatment facilities will be allowed to use their existing stocks of PCP for wood treatment until 2027. Due to the high toxicity of PCP, it is normally used for toxicity calculations for chlorophenols. Phenol is similar to chlorophenol and is an important industrial chemical used as a precursor to many different materials and useful compounds. Phenol is readily soluble in water and sources of it in groundwater would be limited to industrial facilities. In general, chlorophenols and phenol are considered a problem in drinking water systems because they have a strong pungent odor in very small concentrations. The odor makes the water undesirable to drink regardless of the risk factors associated with toxicity. Chlorophenol and Phenols (cont.) As stated in Reg 41 — Basic Standards for Groundwater (page 56) "The organic chemicals chlorophenol and phenol were moved from Table 1 (Human Health Standards) to Table 2 (Secondary Drinking Water Standards), and the proposed standards were set equal to the Ambient Water Quality Criteria for the chemicals. The reason for the change is that although the two chemicals pose a significant health risk at much higher concentrations, taste and odor considerations are a concern at lower concentrations." Chlorophenols and phenols are not associated with sand and gravel mining and may only be a concern if the mining site were adjacent to a wood treatment facility. Broderick Wood Products (BWP) Superfund site in Denver and is adjacent to the Koppers Wood Treatment facility. Both sites have been studied extensively and groundwater contamination was identified off -site and in the neighborhood. Molen & Associates has collected groundwater monitoring samples at the BWP site. Reports generated for the EPA demonstrate that the PCP concentrations are below the detection limits in many of the on -site and off -site wells. The reported concentrations indicate that even at a facility where PCP was used, the concentrations in groundwater are too low to be detected by standard analytical equipment with a detection limit of 1 microgram/liter. Reg 41 — Basic Standards for Groundwater generally considers chlorophenols and phenols as a pollutant of concern due to the odors and taste in drinking water, and if PCP or phenols are in detectable concentrations, a toxicity hazard. The LGE West Farm site is not near a wood treatment facility or any manufacturing facility and chlorophenols and phenols should not be in the groundwater. Mining activities will not introduce any chlorophenols or phenols into the environment. For these reasons chlorophenols and phenol should be excluded from the parameter monitoring list. LG Everist Monitoring Plan & ASSOCIATES Groundwater Quality Monitoring Plan Color The color and appearance of water is an aesthetic property that makes drinking water desirable. The color of groundwater is generally related to the turbidity of the water from natural sediments found in the well. Mining activities at the LGE West Farm site will not change or add to the color of the groundwater. The groundwater is not used as drinking water at the LGE-West Farm site and color should be excluded from the parameter monitoring list. Corrosivity Corrosivity is associated with a low pH (i.e.acidic) water. Natural water at the LGE West Farm site, like all waters along the South Platte River basin, are neutral with pH values within groundwater standard limits (pH 6.5-8.5). Corrosive conditions are not found at the LGE West Farm site and mining activities will not create corrosive conditions at the site. As such, corrosivity should be excluded from the monitoring parameter list. Foaming Agents Foams and foaming agents are generally listed in Reg 41 due to the appearance of the water for drinking purposes. Different types of foams occur naturally in lakes and streams where water is churned up from wind or water flowing over riprap structures. The most common foaming agents are detergents and simple soaps. Foaming agents typically come from industrial processes or consumer wastewater and are generally not expected to be associated with sand and gravel operations. LGE will commit to not using detergent, soaps, or other foaming agents at the LGE-WF site. Analysis for foaming agents should be excluded from the LGE-West Farm site. Odor Odor is an aesthetic property of drinking water and is difficult to quantify the substance creating the odor. Measuring odor in samples is subjective to the analyst. Mining at the LGE West Farm site will not introduce odors to the groundwater and odor testing should be excluded from the monitoring parameter list. Lithium - Dissolved Lithium is an alkali metal with very limited abundance in the earth's crust, estimated to be about 20 ppm (mg/L). The US Governmental report, Lithium Resources in North America, Geological Survey Bulletin 1027-G (found at https://pubs.usgs.gov/bul/1027g/report.pdf) indicates that the abundance of lithium in Colorado is generally limited to the Gunnison area. The United States Geological Service (USGS) published a report with the mean concentrations of lithium in specific locations in Colorado. Comparing all the lat/long information in the USGS report file (file title - Lithium_Statistics.cvs), there is no lithium identified near the LGE West Farm site. The report and statistics file are found at https://www.sciencebase.gov/catalog/item/5ed8f70f82ce7e579c6739c1 . It should be safe to assume that lithium would not be found naturally occurring in the groundwater near the LGE West Farm site. Mining activities at LGE West Farm do not involve any lithium -based materials that would impact groundwater. The only materials that contain lithium are standard AA or AAA batteries that are managed and recycled off -site. For these reasons, we think lithium should be excluded from the groundwater monitoring parameter list. Gross Alpha/Beta Gross alpha and gross beta particle emitting constituents present health hazards in drinking water. Quantification of gross alpha and gross beta includes wide uncertainties with reported values from well samples varying widely. There are no sources of gross alpha or gross beta particle emitting constituents during the mining activity at the LGE West Farm site and the parameters should be excluded from the monitoring list. I 11 MOLEN & ASSOCIATES LG Everist Monitoring Plan Eiwiroi)n)eit, Iic. LARRY E. O'BRIAN FOUNDER STEVAN L O'BRIAN PRESIDENT July 10, 2023 Weld County Clerk to the Board Board of County Commissioners Office 1150 "0" Street Greeley, Colorado 80631 Re: L.G. Everist, Inc. - West Farm Reservoirs M-2023-048 Adequacy Response - 02 Packet Dear Sir/Madam: 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303.423-7297 FAX 303-423-7599 RECEIVED JUL 13 2023 COMMISSIONERS We are delivering to you here with a copy of the Adequacy response and supporting exhibits for the L.G. Everist, Inc, - West Farm Reservoirs application filed with you on November 17, 2022. Please place this packet with the original book. The original is on file with the Division of Reclamation, Mining & Safety. This copy of the permit application adequacy response is delivered to you pursuant to 34-32.5-112(9)(a), Colorado Revised Statutes 1995, as amended, which states in part: .... the applicant shall place a copy of such application for public inspection at the office of the Board and Office of the County Clerk and Recorder of the County in which the affected land is located. This packet must be kept with the book for public review until the application has been approved by the Division. We will contact you once it is and make arrangements to pickup this copy. Please acknowledge receipt of the copy of the permit adequacy response by signing in the appropriate space provided below and returning one copy of this letter to the person delivering it. Yours truly, ENVIRONMENT, INC. Stevan L. O'Brian enclosure RECEIVED THIS DAY OF , 20_, one copy of the adequacy response 02 packet for above referenced mine. Weld County Clerk to the Board By Pubt ; C Rev; e J O7/26/23 CC:PLiKP/NW/Dp/Ko/DAi,Pw(cHIER/cKbDbN) 2o23' (623 O7/24/2.3 Ei)virol)n)ei)t, iqc. LARRY E. O'BRIAN FOUNDER STEVAN L. O'BRIAN PRESIDENT July 10, 2023 Mr. Eric Scott Division of Reclamation, Mining dl Safety 1313 Sherman St., #215 Denver, CO 80215 Dear Eric; RE: L.6. Everist, Inc. West Farm Reservoirs, Permit # M-2022-048 Adequacy Response #2 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 On behalf of our client ,L.6. Everist, Inc., I will respond to your June 9, 2023 adequacy review letter in the order and number format presented in that document. EXHIBIT D - Mining Plan (Rule 6.4.4): 12) Please provide USACE documentation... Please provide the supporting documentation (approved jurisdictional determ/nation/maps) that accompany the USACE cover letter dated February 3, 2021 Attached is a copy of the REQUEST FOR CORPS JURISDICTIONAL DETERMINATION (JD) DEN(R RERULA TORY OFFICE, OMAHA DISTRICT prepared by Savage & Savage dated 06/20/2020 and is enclosed copy of the NWO-2020-01166-DEN-Approved JD Letter with attachments. 14) For Phase 1, no pitside slope protection has been proposed, therefore, please adjust the mining setback from the river to be no less than 400. If you wish to use a 300' setback for Phase 1, provide pitside slope protection in the' mining and reclamation plansfor that phase. The provided plan to only armor a portion of the eastern bank of Phase 1 is insufficient. If any portion of the setback between the top of the pit slope and the river will be less than 400 feet, the pennittee will be required to armor the entire east (river facing) side of the pit at a minimum. Based on experience from recent flood events, DRMS strongly recommends that the permittee also consider armoring the north and south sides of the ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR JULY 10, 2023 PAGE 2 ADEQUACY RESPONSE 02 pit at least up to the elevation break from the terrace bench on the west side to preserve the slurry wall during potential inflow events. If the applicant does not wish to armor, at least, the entire river facing (east) side of the Phase 1 pit, they may alternatively provide a design for reinforced inlet/outlet structures for Phase 1 designed to safely pass filling and overflow for a 100 year flood event. Please also modify the provided cost estimate as needed for any updates. We have added armoring to the east bank of Phase 1 and modified Table L-1 to included the additional length and cost. EXHIBIT F - Reclamation Plan Map (Rule 6.4.6): 21) The reclamation plan map will need to be modified as necessary... No contour elevations or interval data are provided on the reclamation plan map. Please provide elevation data for the reclamation map contours. A copy of the revised Exhibit F - Reclamation Plan Map is enclosed. The elevation numbers were added to the map and the approximate location of the under drain is shown along the SE section of Phase 1 from the toe of terrace to the east, approximately 1,880 feet.. Also added was the armoring on the east bank of Phase 1. EXHIBIT G - Water Information (Rule 6.4.7): 22) The applicant will need to provide a site characterization and groundwater monitoring plan, including at least five quarters of baseline/background water level and groundwater analytical data, sufficient to demonstrate compliance with the requirements of the "Water Quality Control Commission Regulation No. 41 - The Basic Standards for Groundwater" for the life of the proposed operation. Please note that permanent monitoring wells and Point of Compliance (POC) wells should be placed where they will not be mined through. 23) The Mining Plan as submitted only includes a 15 foot setback from the permit boundary/utility corridor to the slurry wall on the south side of Phase 1, and does not include any provisions such as a French drain, to allow groundwater to flow unimpeded around the proposed slurry wall. No groundwater modeling data has been provided to demonstrate that the construction of this slurry wall will not result in excessive groundwater mounding on the adjacent property to the south of Phase 1, or adverse impacts to the irrigation return flows to the South Plate River which currently flow through Phase 1. Please provide a detailed groundwater model illustrating the projected impacts to groundwater levels adjacent to the site after installation of the proposed slurry walls. This should include a groundwater contour map showing projected depths to groundwater and any mounding or shadowing on properties adjacent to the proposed permit area. If the modeling predicts excessive groundwater mounding on adjacent property, the applicant will need to provide a plan to minimize the impacts and maintain the prevailing hydrologic balance during and after mining activity. Based on the historic data available for the site, please propose trigger levels for groundwater level mitigation and where the monitoring points will be located. For example: excessive mounding ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR JULY 10, 2023 PAGE 3 ADEQUACY RESPONSE 02 requiring mitigation could be a groundwater level increase of over 2 feet from baseline, or groundwater levels within 4 feet of the ground surface measured at the property boundary. 24) Please provide proposed locations for installation of additional groundwater monitoring wells outside of the proposed slurry wall along the south side of Phase 1 to monitor for excessive mounding on the south side of Phase 1. The following comments refer to the provided Groundwater Elevation Model (Deere & Ault, May 19, 2023) and the Groundwater Quality Monitoring/Sampling Plans (Molen & Associates, May 17, 2023) which have been submitted to address adequacy items 22-24 listed above. Please revise these plans as needed to reflect the following comments. DRMS will also take this opportunity to reiterate that at least 5 consecutive quarters of baseline analytical data will be required prior to exposure of groundwater at the site. Please acknowledge. 22a) Groundwater Quality Monitoring Plan section 2.1/Table 1— DMRS will require that MW -8, MW -11, and MW -12 be designated as the POC wells (MW -1 does not need to be designated a POC well). The included map from Exhibit G should also be corrected, wherever included in the application, to show MWs 1, 2, and 5 as water quality monitoring points as designated in Table 1 of the GWMP. 22b) Groundwater Quality Monitoring Plan section 2.1/Table 1- DRMS will require that MW -9 be included in the list for "regular monitoring". Please clarify that the RM designation indicates that a well will be sampled for Groundwater Quality Parameters as outlined in the Plan. (or revise RM to WQM for consistency with the map from G-1 previously mentioned) MW # 9 will eventually be surrounded by slurry walls and being nearly in the center of the Mine area would serves little purpose as the WQM well. LGE request that this requirement be dropped. During review of the previous Groundwater Quality Monitoring Plan to fix the deficiencies noted in the Staff review Mr. Molen determined that MW -01 and MW -02 were not needed also for Water Quality measurements, so the revised GQMP contains 6 WQM wells instead of 9. 22c) Groundwater Quality Monitoring Plan section 2.2- A generalized well construction diagram maybe included for reference here. Also, please delete the last paragraph of this section as the POC wells have already been defined by Table 1. 22d) Groundwater Quality Monitoring Plan section 2.3 - DRMS will require that water level data be collected from all wells at least monthly, not quarterly. 22e) Groundwater Quality Monitoring Plan section 2.4 — DRMS would recommend that the first two paragraphs of this section be deleted as this information is more appropriately discussed in the Groundwater Sampling Plan (GSP), and the references to the Tables in these paragraphs do not seem to correlate. 220 Groundwater Quality Monitoring Plan sections 3.0 through 3.3- These sections maybe deleted. It is not likely that valid statistical analysis can be conducted on 5 data points, although if LGE wishes to attempt to include 95% confidence intervals for the baseline data, DRMS will review them. LGE will be required to highlight where baseline data for listed analytes exceed INS Table Value Standards in a Baseline Water Quality Summary ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR JULY 10, 2023 PAGE 4 ADEQUACY RESPONSE 02 Report to be submitted as a TR when the data is collected and reviewed. If LGE wishes to reduce the list of analytes to an abbreviated set of "indicator parameters" upon review of the baseline data, this request can be made and justified in the Baseline Water Quality Summary Report submittal. 22g) Groundwater Sampling Plan (GSP) Section 4.3.4- Delete last sentence in second paragraph (Portions of the list will...) Also edit last sentence in this section with reference to section 4.2.1 (which does not exist in this plan) to 4.3.1 which discusses decontamination. 22h) Groundwater Sampling Plan (GSP) Section 4.4- Generally dissolved metals samples are preserved with HNO3 to pH <2 after filtering. It maybe more useful to state something to the effect of - LGE will consult with the lab providing the containers and analysis prior to sampling events to determine the required containers and preservation for samples to be collected. LGE will preserve all samples in accordance with lab and method requirements. Preservation methods will be documented on field forms for all samples, as well as on the COC. 22i) Groundwater Sampling Plan (GSP) Section 4.6- Trip blanks maybe omitted (see following comment on Appendix II), and Equipment/rinsate blanks are only required when non -dedicated sampling equipment is utilized. DRMS recommends that QA/QC samples focus on a Duplicate Sample to verify lab results unless there is reason to believe additional QA/QC is needed. 22j) Groundwater Sampling Plan (GSP) Section 5.0— Analytical Reporting Limits must be low enough to determine if standards for applicable analytes in Tables 1-4 of the Interim Narrative Standards have been exceeded. (See comment on Appendix II) 22k) LGE will need to commit to retaining all completed field forms for submittal with the annual report, or upon request for DRMS review. LGE will commit to retaining all completed field forms for submittal with the annual report, or upon request for DRMS review. 221) Groundwater Sampling Plan (GSP) Appendix II -Water Quality Parameter List- This appendix is titled Appendix II on the divider sheet, and possibly as Appendix B in the TOC of this document. However, the materials in it are titled Appendix I - Tables Water Quality Parameter Lists. Please revise for consistency throughout. 22m) Groundwater Sampling Plan (GSP) Appendix II —Water Quality Parameter List — Organic Parameters/Table 2— Although DRMS will review any organic parameters LGE wishes to sample to establish baseline data, collection of samples/data for organic parameters listed in Table 2, (or in Table A of Reg. 41) is generally not required by DRMS unless there is a specific reason to believe they may be present within the permit area in elevated levels. 22n) Groundwater Sampling Plan (GSP) Appendix II —Water Quality Parameter List — Tables 3 and 4 — The analyte lists provided in these tables are inconsistent with the parameters contained in Tables 1-4 of Reg. 41 Interim Narrative Standards, and no benchmark levels have been provided. Several analytes included in Tables 1-4 were omitted. Please revise Tables 3 and 4 to include all analytes in Reg. 41 tables 1-4, and include the ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR JULY 10, 2023 PAGE 5 ADEQUACY RESPONSE 02 lowest numerical standard for that analyte in those tables. Justification must be provided for removing any analytes from the baseline sampling program. DRMS certainly does not object to the collection of additional parameters (such as alkalinity, calcium, magnesium, potassium and sodium as included in Table 3) which may be useful for the purposes of groundwater chemistry. Responses to points 22a thru 22n have been addresses in the revised Groundwater Sampling Plan (GSP) and the Groundwater Monitoring Plans . Copy attached. A revised Map Exhibit G1 - Water Wells within 200 ft. making the well designations uniform is attached. 23a) Based on the information provided in the Groundwater Elevation Model, and the shallow pre -pining depth to groundwater (less than 5' b.g.s. in MW7), DRMS will require the installation of an underdrain as depicted in Figure 5 of the Groundwater Elevation Model along the southeast area of the permit to maintain the prevailing groundwater levels in this area. Please provide detailed design/installation specifications for this underdrain and a commitment to install the underdrain in conjunction with the slurry wall installation for Cell 1. L.G. Everist will commitment to installing the under drain in conjunction with the slurry wall installation for the Phase 1 reservoir from the base of the terrace to the east along the southeast side. The approximate location of the under drain is shown on the Exhibit F - Reclamation Plan Map revised 7-06-2023. It is premature to actually provided the design and installation specifications until the exact location of the slurry wall will be known . The design information will be provided as a Technical Revision prior to installation of the under drian. In general the plan is to use a 12 inch diameter perforated PVC pipe that will be placed along the outside of the slurry wall at an elevation consistent with the average historic groundwater elevation along the south side of the proposed slurry wall. The pipe will be surrounded with gravel bedding and then covered with native backfill. The pipe will be sloped so it drains to the east and either empties into the river or the irrigation return flow ditch that will run north along the east side of the Phase 1 slurry wall, emptying into the river. 24a) DRMS concurs with the placement of the additional groundwater monitoring wells shown in Exhibit G, and the Groundwater Quality Monitoring Plan. Please commit to providing well construction diagrams for all currently installed wells, and proposed wells upon installation. A Typical Monitoring Well diagram for the existing monitoring wells is attached. L.G. Everist will commit to providing well construction diagrams for the proposed monitoring wells when they are installed. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR JULY 10, 2023 PAGE 6 ADEQUACY RESPONSE 02 EXHIBIT L - Reclamation Costs (Rule 6.4.12); 25) DRMS will evaluate the reclamation bond calculation when the other adequacy issues have been resolved and the appropriate revisions made. Attached is a revised Reclamation estimate cost providing information on the items revised.• In particular the preliminary estimate was not affected since the installation of the -under drain and additional armoring and the under drain in Phase 1 will not occur until mining begins in that Phase. Schnabel provided an underdrain construction unit cost of $82.03 per foot using •12 inch plastic perforated. Proof that a copy of this response and attachment was placed with the Weld County Clerk of the Board will be provided under separate cover. I hope these responses have addressed the adequacy questions you had. If you have any questions please call. LIST OF ATTACHMENTS TO THIS RESPONSE: Mining Plan & Timetable - revised • Groundwater Sampling Plan - revised Reclamation Plan & Timetable & Figure • Exhibit L - Reclamation costs - revised E-1- revised Exhibit F - Reclamation Map - revised Bank Armoring Plan Exhibit 6 - Water revised Copy Savage & Savage Corps - JD • Map Exhibit 6-1- Wells - revised Request 6-26-2020 • Typical Monitoring Well diagram USACE AJD Letter & attachments • Groundwater Monitoring Plan - 2-3-21 revised Sincerely, environment, Inc Stevan L. O'Brian President cc L.G. Everist, Inc. Weld County Clerk file enclosures 2 more items not listed above: - Exhibit C-1 Mining Plan Map (placed after Mining Plan & Timetable) - Typical Trench Section, Underdrain Detail drawing (placed after Exhibit F - Reclamation Map) Exhibit D MINING PLAN AND TIMETABLE LOCATION This is an open pit mine located about 1 mile west of Platteville, with the entrance on the east side of County Road 21 just south of 32.5 Road. To reach the mine from Platteville, starting at the intersection of HWY 85 and Justin Ave (HWY 66) go west on Justin Ave 2.5 miles to Weld County Road 21, then north 1.37 miles to the entrance. The coordinates of the entrance are 40°13'25.1536", -104°52'02.8563". Please refer to ExHIBITB-ViclNmr MaP for the property configuration and the relationships to sur- rounding geological features. The area to be mined lies between County Road 21 and the South Platte River, straddling 32.5 Road and lies within the Town of Platteville, Colorado. GENERAL INFORMATION The primary commodities to be mined are sand, gravel, top- soil, overburden, and borrow materials. No incidental commodi- ties will be produced at this mine. Throughout this application we will refer to the two areas, (a) the south area containing Phases 1 & 4 and (b) the north area containing Phases 2 & 3. The roadways (transportation corridors) are left out of the permit since L.G. Everist, Inc. does not own them. Permit/affected lands and mining lines and setbacks vary throughout the site, depending on ROWs and proximity to the South Platte River. Along the river the permit/affected lands line is 100 feet from the western bank of the river. Along the river in Phase 2 (north of CR 32.5), mining will take place within 300 feet of the river bank and the bank will be rebuilt so the top of the slope into the reservoir area will be 300 feet from the top of the river bank. This will be done by backfilling from the 2h:ly mining face to the top -of -slope (TOS) line using shale from the floor of the mined area. Along the river in Phase 1 (south of CR 32.5), the mining line will be along the west side of the old railroad grade, which is greater than 345 feet from the river bank. There is a 1305 feet section of reservoir bank in this area that will be armored since it is less then 400 feet from the river. MAP EXHIBIT C-1 -MINING PLAN show the location of the armored sec- tions Along the County and Local Roads, the permit lines use the ROW lines associated with the roads. Platteville requires 80 feet ROW for CR 32.5, and Weld County requires 40 feet, east of L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 4 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) the section line, for the ROW along CR 21. The slurry walls will be constructed 15 feet from the Per- mit/Affected lines or utility ROW lines, whichever is greater. The mining setback will be 25 feet inside the slurry walls. Mining in all Phases will be done after the slurry walls are completed around them so they can be dewatered and mined dry. Dewatering will continue until mining ends in each Phase to re- move any stormwater or leakage that accumulates in the mining areas and facilitate certification of the slurry wall. The area being permitted and much of the surrounding areas has historically been used as irrigated and non -irrigated cropland and vacant land. This site lays adjacent to the South Platte River, so it contains an alluvial gravel deposit in the eastern area, which extends west into a large terrace of gravel on the western areas. All mined areas will be reclaimed as ground water storage reservoirs using slurry wall liners. CURRENT CONDITIONS Large portions of the land to be permitted are currently operated as an irrigated farm, or used as rangeland. There are two rental houses and various barns and sheds in Phase 1 that are owned by the operator and will not be disturbed by mining. How- ever, the owner may choose to remove these at any time. There are various oil/gas lines and facilities on the permit area and 6 wells in Phases 3 & 4 that have been "shut in" and will eventually be plugged and abandoned. The oil and gas facil- ities will be removed by the producers and the supporting feeder lines will be abandoned and removed if they lie within the areas to be mined. They are shown on EXHIBIT C - CURRENT CONDITIONS MAP and EXHIBIT C-2 - STRUCTURES, but left off of EXHIBIT C-1 - MINING PLAN MAP and EXHIBIT F - RECLA- MATION PLAN MAP because they will be removed prior to mining those areas. If they remain when mining starts in those areas, a Tech- nical Revision will be filed to show how LGE will deal with them. Where needed, the active farm facilities and support struc- tures, i.e. water wells, sprinkle pivots, distribution ditches, pipes and diversion structures will be removed as mining pro- gresses. There are no County Roads or public facilities on the permit area. The oil and gas facilities lying outside the slurry walls will not be disturbed by mining. EXHIBIT C- CURRENT CONDITIONS MAP, shows the outline of the Affected Lands/permit area, the adjacent landowners within 200 feet of the L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 5 MINING PLAN AND TIMETABLE EXHIBIT D(coNT) facility, current topography, hydrologic and surface features of the property. Of particular note, along the South Platte River the permit/affected lands line is established one -hundred (100) feet west and parallel to the top side of the west bank along the South Platte River. Over the years, it appears this bank has been lined in places with armoring materials by previous landown- ers The initial access to the site is via an existing Private Road located on the east side of CR 21 and approximately 1.37 miles north of Highway 66. In most cases, existing farm roads within the permit area will be used for mining needs and existing farm entrances on the paved roads will be used to cross the pub- lic ROW's. The initial Plant Site will be located on approxi- mately 50.00 acres of Phase 4, located on the southeast corner of CR 21 and CR 32.5. This Plant Site will be used throughout the life of the mine, as material will be conveyed or hauled to the plant from each Phase. In the future, 2 conveyor crossings may be installed from the northern area to the southern area. These crossings will be self-contained clear span units over CR 32.5 with all support structures to be built outside the road ROW's, but within the affected lands. They are part of the approved Platteville Devel- opment Plan and this would only happen after LGE has filed and received approval for a Technical Revision with the Division that would include showing the proposed location and design details for the crossings. The approximate proposed locations are shown on EXHIBIT C-1 MINING PLAN MAP . The phase access roads will be constructed of gravel ob- tained from on site. They will be at least 20 feet wide and graded to allow for drainage into the site and have ditches as necessary to collect runoff. Any runoff from the roads will be retained on -site and allowed to soak into the ground or evapo- rate. The roads will be maintained as needed. Access roads will be built around each water storage reservoir to provide access during mining, reclamation, and after release. The access roads will remain when reclamation ends as they will be used to access the property. GEOLOGIC SETTING The affected lands are located along the South Platte River in a Quaternary age, Piney Creek alluvial deposit. The eastward L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 6 MINING PLAN AND TIMETABLE EXHIBIT D(coNT) dipping beds of upper Cretaceous age Laramie formation are over- lain at an angular unconformity, by the Piney Creek alluvium. The sand and gravel encountered in the Piney Creek alluvium are a result of water erosion and redisposition of rock materials from the Front Range of the Rocky Mountains. The deposition of this material occurred during a time when the river was much larger than it is now. But, judging from the scarcity of large rocks found at the location, the velocity of the river must have slowed sufficiently to have dropped boulders and most large cobble be- fore it reached this point. This type of material is typically found from south of Denver to the Colorado state line along the South Platte River. The thickness of the gravel deposit in West Farm Reservoirs varies from 27 to 75+ feet and the average depth is approximately 50+ feet. This site has a 10 to 12 inch layer of topsoil, con- sisting of loam and zero to 5 feet of a clay loam to sandy clay loam overburden. The alluvium is a well -sorted gravel, sand and silt, predominantly granitic and quartzite material with minor amounts of gneiss, schist and sandstone. The bedrock under the surface gravel is part of the Laramie formation and is a grey to grey black shale that is impervious. SOILS AND OVERBURDEN The information presented in this section is an overview of the Soils and Overburden types, quantities and depths found throughout the property, and also how these materials will be integrated into the mining and reclamation plans. The informa- tion has been obtained from the National Resource Conservation Service (NRCS) website, and from drilling reports. The NRCS Soils Report and SOILS MAP INEXHIBIT I/J, show the soil types delineated in the permit area and will provide background levels for the site as reclamation begins on the entire area. There are seven (7) types of soils found on the site. These soils are typically found throughout Weld County. They have no unusual qualities. The soils are designated as map Units 3, 10, 21, 22, 39, 41 and 68. Soil unit 68 lies along the slope from the upper level to the lower level that will not be mined. The NRCS report contains detailed information including the soils description, and chemical, physical, and engineering qualities. he depths of the topsoil and overburden, shown in the following table, is from a drilling report on the property. L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 7 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) SOIL UNIT UNIT NAME APPROX AREA (AC) DEPT OF TOPSOIL, (INCHES) DEPTH OF OVERBURDEN (FEET) 3 Aquolfs and Aquents, gravelly substra- tum 256.7 12 3.5 10 Ellicott -Ellicott sandy -skeletal corn - plex, 0 to 3 percent slopes, rarely flooded 56.8 12 3.5 21 Dacono clay loam, 0 to 1 percent slopes 103.0 12 4.0 22 Dacono clay loam, 1 to 3 percent slopes 6.3 12 3.0 39 Nunn barn, 0 to 1 percent slopes 7.5 12 0.0 41 Nunn clay loam, 0 to 1 percent slopes 4.6 12 5.0 68 Ustic Torriorthents, moderately steep 37.3 3 0.0 85 Water 0.6 NA NA Based on the soils report and on site observations there are sufficient quantities of soil available to reclaim the disturbed lands to their present condition. The excess topsoil and over- burden will be used on site for reclamation or removed from the site The soils on the permit area that will be salvaged and re- placed should be capable of growing vegetation consistent with what is required by the Reclamation Plan. Enough topsoil will be retained to place an average of 10-12 inches on the areas to be revegetated. As each area is stripped, L.G. Everist will deter- mine how much soil will be needed to reclaim the area and it will be stockpiled for use in reclamation. Over the life of the mine, an estimated 588,400 yards of topsoil will be stripped from the mined area but, a minimum of 60,200 yards will be retained for resoiling the areas to be revegetated. In addition, there is from 0 to 3 feet of overburden on most of the site. Much of this overburden will be retained and used to backfill the reservoir slopes and used during slurry wall construction or removed from the site. The topsoil and overburden stockpiles will be located around the excavation, typical pile locations are shown on the ExHIBrrC-1 - MININGPLANMAP. If the soil stockpiles remain undisturbed for more L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 8 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) than one year, a cover crop of the approved seed mix, at the rate called for in the EXHIBITE - RECLAMATION PLAN, will be used to revegetate them. MINING PLAN This mining plan is designed as a two -stage startup that will allow for issuance of the permit at a lower initial bond. Operations Stage A covers the preparation of the Plant Site area. Operations Stage B will cover full implementation of the mining plan. A Technical Revision for a bond increase will be filed prior to starting Operations Stage B that will allow construction of a slurry wall, land stripping and mining in the first mining Phase and covers the Operations Stage A disturbed area. OPERATIONS STAGE A Activities during this stage of startup would allow for de- velopment of the permanent Plant Site to be located in Phase 4. It will cover the northern 50.00 acres of Phasel and will include stripping, salvaging topsoil and overburden, and processing plant construction. As a part of this development a wash water set- tling pond and fresh water pond facility will be constructed in Phase 1 that covers approximately 6.0 acres. The Plant Site will contain the processing plant/stockpile area, equipment storage area, temporary overburden and topsoil piles, drying pads and other axillary uses needed at the mine. Processing equipment may include but is not limited to conveyors, crushers and screen plants. A scale and scale house will be built at the entrance and auxiliary uses may include a Concrete Batch Plant, an Asphalt Batch Plant and a recycling facility, that will be placed in the Plant Site Area. EXHIBITL - RECLAMATION COSTS contains the information needed to establish the Operations Stage A financial warranty amount and an analysis for the transition to Operations Stage B - full mining activities. OPERATIONS STAGE B Prior to full mine operations and the move into Phase 1 a Technical Revision will be filed to increase the financial war- ranty adequate to cover the mining plan as described in the fol- lowing text. The plan is to have no more than 205 acres ± of disturbance bonded to allow for flexibility during mining. This 205 acre L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 9 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) area will include stripped, partially mined, partially reclaimed, the Plant Site area, materials stockpile area, settling pond fa- cility and the slurry wall around future reservoir areas. As mining progresses across the property some parts of the property will remain undisturbed while other areas will be either stripped, mined, partially reclaimed or totally reclaimed. The ExHIBITC-1-MININGPLANMAPprovides information of how the Phases will develop during mining. Initially the 205 acres would include having stripped and partially mined Phase 1, the 50 acre Plant Site and installed the slurry wall around Phase 1 and the instal- lation of the under drain along the southeast section of the phase. Much of the 205 acres would be within the highwater line of the reservoirs that would be covered with water and would need no soiling or revegetation. This amount of disturbance may change as the mine develops but prior to exceeding the initial 205 acres, a Technical Revision will be filed to increase the bond and allow for more disturbance and address the design of the un- der drain. This map shows the estimated location of the final slopes around the perimeter of the entire areas to be mined. The esti- mated reservoir highwater line, bank areas to be armored, the top of mining slope and slurry wall locations are shown. It also shows the maximum working face (highwall) for each Phase and the estimated cut/fill volume per foot to grade the working face highwall back to 3h to lv. No more than 1000 feet of total per- manent bank sloping will be needed (500' on each side of highwall). The volume to complete the backfilling on the exte- rior slopes is shown. In Phase 2 this volume will be greater because any area mined within 300 feet of the river bank will be backfilled so a 300 foot setback can be maintained when the res- ervoirs are built. This river bank excavation area will be done in 500 feet or less section that will not be left open for more the 12 months before backfilling, sloping and armoring begins in any given section. Of the 472.40 acres ± in the permit area, approximately 385.79 acres ± will be disturbed by mining. Within the disturbed area 356.92 acres will be mined. The 28.87 acres of unmined area will be the setback margins between the slurry wall and the top of slope into the reservoirs. This area will contain roads for access to the reservoir areas during and after mining. ExHIBITF- RECLAMATIONPLAN MAP SNOWS how the reservoirs will be developed. As mining progresses a reservoir area will be sold and a L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 10 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) condition of the sale may require LGE to permit the owner of the reservoir to start construction of facilities related to the res- ervoir(s) - such as installation of pump houses, inlet/outlet structures, rip -rap, etc. This would only happen if the reservoir owner does not want to wait for DRMS permit acreage release of that Phase. In this case, L.G. Everist would have already re- claimed the reservoir phase (including liner certification, final grading of the reservoir slopes, armoring and initial seeding), but the phase acreage is not yet released from the DRMS permit (due only to vegetation growth). L.G. Everist would file Techni- cal Revisions as needed to incorporate the changes. At any given time, mining and "concurrent reclamation" may be occurring in one or more phases to accommodate the blending of materials, the natural progression of mining from one Phase to the next. This concurrent reclamation allows for reclamation work being completed in one phase while mining begins in another phase. The "direction of mining" arrows on EXHIBIT C-1 -MINING PLAN MAP show the applicant's best guess on how mining will progress through the mine areas at this time. Natural ground conditions and un- foreseen circumstances may necessitate changes to the mining di- rection throughout the life of the mine. The RECLAMATION COST ESTIMATE- EXHIBIT L 1S based on the Operations Stage A plan to bond for initial setup of the Plants Site and support facilities. Included is an estimate for the Operations Stage B where it is based on an estimated disturbance area when the Phase 1 has been open for a few years. The acreage disturbed may increase or decrease as mining progresses. If it increases, a Technical Revision will be filed to adjust the bond amount to cover the changed cost estimate. Mining will start on the southwest side of Phase 1 and prog- ress to the east and south until the mining limits are reached. This will leave an open working face across the Phase as shown on the MININGPLANMAP. This face will have a 1:l slope and will be worked to the north, the exterior final slopes will be con- structed using the overburden or shale from the excavated floor material. If mining ends prematurely, the east/west working face will be reclaimed using a cut/fill sloping method instead of backfilling. The setbacks to be used in each Phase are shown in the table on the EXHIBIT C-2 -STRUCTURES MAP. The aggregates will be removed and stored on the Plant Site area in Phase 4 for processing. The L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 11 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) plan is to use conveyors or off -road haul trucks to move the ma- terial from the working face to the Plant. As mentioned above, the proposed mining sequence may change due to unforeseen circumstances such as market conditions, varia- tions in the natural deposit, agreement restrictions with struc- ture owners, etc. At this time, the plan is to mine them sequen- tially from 1 through 4 as shown on the maps. The following mining methods will apply to all of the reser- voir Phases. Operations will begin in each Phase of reservoir construction by stripping the area where mining will start. Ini- tially a 30 acre area will be stripped and periodically as min- ing progresses it will be extended so there is approximately 30 acres ready for mining at any -one-time as each Phase is mined. The topsoil needed for resoiling the above -water areas will be separated from the overburden and stored around the mining area for use in reclamation. Once enough topsoil is salvaged to resoil the above -water disturbed areas with an average of 10-12 inches, the rest may be sold. These stockpiles will be placed strategically as mining progresses. In some cases the stripped topsoil will be placed on areas where grading and shaping, are complete so it only has to be handled once. In Phases 1 and 2, all topsoil storage piles will be located as far from the river as practical, and will run parallel to the river's flow if lo- cated in the floodplain. During the stripping, a slurry wall pad will be built around the reservoir mining area using the excess topsoil and overbur- den. When the slurry wall pad has been completed, the bentonite slurry wall construction will begin. This is done by excavating a trench in the pad that is keyed into the underlying bedrock and filled with a mix of overburden, bentonite and water to create the slurry that becomes the liner. The soil and overburden not used in slurry wall construction or sloping will be placed around the mined area or sold. After the slurry wall liner is in place within a phase, a dewatering trench will be excavated inside the perimeter of the slurry wall. A pump will be installed and dewatering will begin. This will allow the area within the slurry wall to be dry mined. The trench will be extended around the area as mining progresses. Some of the soil will be used to construct a sight berm along road areas in each Phase. These berms will limit visibil- ity into the active mining areas from the transportation corri- dors. The berms will vary in height depending on the area to be L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 12 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) screened, with 3:1 slopes on each side and revegetated using the approved seed mix. The active mining area in the reservoirs will remain dry. After mining is completed, final reclamation of the phase can be completed, including liner certification, final grading of slopes and initial seeding for revegetation. ' Dewatering as mining progresses, facilitates early testing of the slurry wall liner, this is required to receive liner ap- proval certification from the State Engineer's Office in the Di- vision of Water Resources. In general, mining will commence in Phases 1, 2 & 4 on the south end and work north as shown by the arrows on the MINING PLAN MAP. In Phase 3, mining will start on the north and work south. The maximum length and cut/fill volumes of the working face and backfill on the side wings in each stage are shown on the MINING PLAN MAP . The mining setbacks will vary from the permit boundary and structures as allowed by each agreement for said structures and/or the Geotechnical Stability Analysis. This analysis shows that using the 25 feet setback from the slurry wall is adequate to meet the factors of safety in the DRMS Rules and Regulations, (see D&A Slope Stability Factor of Safety Results Summary Table on Page 4 of their report). The proposed setbacks are shown in the Setback Table on EXHIBIT C-2 - STRUCTURES MAP The material will be mined using loaders and excavators (track hoes) to remove material from the face. The material will then be delivered to the Plant for processing using haul trucks or a conveyor system. No blasting will take place at this mine. Reclamation will run concurrent with mining to control the amount of disturbed area in the mine at any -one-time. Reclamation begins in an area once the section is fully mined, and large enough for efficient reclamation (backfilling, compacting, slop- ing, soiling, etc.) that will not have to be re -disturbed. This pit will be operated year -around by L.G. Everist, Inc., weather permitting. There may be periods when the demands for material are slow and no mining will take place, creating an in- termittent operation situation. Areas not included in the bonded area will remain in agri- cultural production. Please refer to the MINING TIMETABLE for the estimated acreage of each area associated with the mining part of this operation. Mining equipment may include but is not limited to, L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 13 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) front-end loaders, scrapers, excavators, a drag line, dozers, off -road haul trucks, dump trucks and a water truck. Most of the water used on site will be for dust control used on haul roads or with sand and gravel processing. Please refer to EXHIBITG-WATERfor the discussion of how water will be used at the site, the estimated yearly needs, and the source(s) of said water. Prior to mining into the groundwater table, the appli- cant/operator/permittee will obtain a Substitute Water Supply Plan approval from the Division of Water Resources. All interior pit slopes will be maintained, when actively mining, with a pit -ward attitude to prevent off -site stormwater runoff. The general slope of reclaimed areas will be graded in a similar way so that stormwater drains into the site, not out. This same slope management plan will prevent any offsite erosion or other disruptions. In addition to the pit and reclamation sloping, isolation berms or ditches will be constructed around the mine as needed to prevent off -site stormwater from contacting the on -site disturbed areas. All stormwater contacting the dis- turbed area will be retained on -site to be discharged as part of the Colorado Discharge permit or allowed to evaporate or soak into the underlying gravel. The applicant had a jurisdictional delineation of the site conducted by environmental consultants and submitted to the U.S. Army Corps of Engineers (USACE). The Corps has determined that there are no jurisdictional wetlands on the West Farms site. The Corps determined that irrigation return flow ditch on the west side of Phases 1 and 2 is jurisdictional and must remain. So the ditch may be slightly improved by defining its course, but it will remain and not be impacted by the mining operation. If the irrigation ditch dries up once the area is no longer irrigated, the applicant may request a change in status (for the ditch) from the Corps. MINING TIMETABLES This estimated mining timetable is based on an average year, and L.G. Everist expects some years to vary widely from the aver- age. If there are changes in the mining timetable, we will dis- cuss the reasons for the change in the annual report that follows the change and modify it at that time if needed. L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 14 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) ESTIMATED MINING TIMETABLE ACRES ± Phase ESTIMATED YEARS TOTAL AREA TOTAL DISTURBED AREA TOTAL MINED MINED 100% MINED SLOPES EST. SLURRY WALL LENGTH 1 '1-9 190.23 153.23 147.55 116.24 31.32 10,203 2 5-7 145.39 121.32 106.87 76.97 29.90 10,166 3 2-3 60.36 45.38 41.31 18.65 22.66 7,155 4 3-5 76.42 65.86 61.19 29.65 31.53 8,244 TOTALS 17-24 472.40 385.79 356.92 241.51 115.41 35,765 L.G. EVERIST, INC - WEST FARM RESERVOIRS July 2023 15 LEGEND PERMIT BOUNDARY/AFFECTED LANDS 200 FOOT LIMIT TT COMMUNICATION LINES DHE OVERHEAD POWER LINES x x x FENCE w ABANDONED RAILROAD GRADE WATER LINE -1R- - - IRRIGATION LINES FO co FIBER OPTIC LINES c c GAS LINES FD UNDERDRAIN (Approximate Location) PAVED ROADS (OFFSITE) ROADS (HAUL, ACCESS) (TYP.) MIME MIMI IBM =MI NOTES RIVER DITCH 1. The four Phases shown on this map are the operations areas for the mining and reclamation activities that constitute the development of this property as a series of water storage reservoirs. 2. Activities within each Phase will include, but is not limited to, mining of sand and gravel, construction of reservoir liners, grading, resoiling and revegetation of the above -water perimeter areas of said reservoirs. 3. The Plant Site shown in the Phase 4 will be used throughout the life of the mine and activities may include, but are not limited to, processing the sand and grovel (crushing, washing and screening); crushing and recycling of concrete and asphalt materials; botching of ready -mixed concrete; botching of hot -mix asphalt; stockpiling of raw and finished products, and sales of said materials. 4. The Plant Site shall include the necessary portable processing plants and equipment to conduct the activities listed above. For the sand and gravel processing, and the concrete and asphalt recycling, the processing equipment shall include, but is not limited to, crushers, screens, conveyors, stackers, feeders, log -washers, and other necessary processing equipment. For ready -mixed concrete, and hot -mix asphalt, a portable concrete batch plant and a portable asphalt botch plant may be installed and used for the life of the mine. 5. The conveyor crossing envelopes shown on this map are the approved proposed crossings in the Town of Platteville PDP agreement. The conveyor design and final locations will be approved prior to construction of the conveyors. 6. The approximate locations of (2) Conveyor Crossing Envelopes are hown hereon. The exact location and size of the crossing areas will be determined prior to installation. A Technical Revision will be filed showing the exact location if different fro in shown on the Map Exhibit C-1 Mining Plan Map. These crossings will be used, when approved by the Town of Platteville, to build overhead portable conveyor facilities to transport raw material from the north side of County Road 32.5 to the processing plant. Using over -the -road conveyors would greatly reduce heavy off -rood truck traffic that would cross the paved road. Conveyor facilities will be removed when reclamation is complete. OWNER: PUBLIC SERI C OAIP, i. VYOFCOLORAOO BEVHUDSON FP FLOOD PLAIN So SLURRY WALL (PROPOSED) ToS Tos TOP OF MINING SLOPE BUILDINGS WATER WELL OIL/GAS WELL 15322R ESTIMATED MINING DIRECTION PUBLIC ROAD RIGHT OF WAY RESERVOIR SLOPE AREAS VARIES 3:1 TO 4:1 BANK ARMORING (Approximate Location) WORKING FACE AREA /A TEMPORARY SOIL PILES (APPROX. LOCATIONS) 7. The reservoirs will have gravel access roads around the perimeters of each reservoir and the rest of the perimeter area will be revegetated with a state -approved seed mix. 8. Access points for each Phase are shown on this map. The accesses to the Phases will be used to move equipment, needed during mining and reclamation, from one area to the other. The access point into the Plant Site from County Road 21 will be used by customers' over -the -road trucks to transport finished materials to market. 9. Each Phase may continue to be used for agricultural purposes until the permitted mining operations begin in the area. 10. The FEMA Flood Plain (Zone A) shown hereon is approximate and represents the best information available at the time this document was created and is subject to change. 11. The four mining Phases shown hereon may change as mining and reclamation progresses, depending on future Oil and Gas activities at the site. 12. Working faces show on the map are located at points where they will be the longest in each Phase. Volume shown is based on average depth of the Phase. 13. The approximate access points for each Phase are shown hereon. These accesses will be used to move equipment, and access each Phase during mining, development and maintenance of each Phase. 14. The unmined areas shown hereon may be used during mining and reclamation for placement of soil stockpiles, staging areas and as setbacks. If disturbed, they will be reseeded. 15. The settling and fresh water ponds shown in Phase 1 will be used for cleaning process water from the plant. Location may change to the reservoir floor once that area is mined. 16. In Phase 2 along the river, mining will occure within 300 feet of the top of bank and backfilled with on -site material so there is a 300 foot wide setback. No more then 500 feet of backfill area will be open at any -one-time. U • ie Ott WER: FPI BURL/ApTC\ R-1 Rift L `2- =s3 ?nom SIJ // �• / • Fee/ ......... / 3 M f t. / //////e/////e W //, //,,. ,,,,` /lee/ /e fleet, /e e >/ I '',,` /eee; /tee/ BACKFILL SLOPE lee 1/,!/e ,e/Zee v 1, l,r/ UME 161.16 CY/LFT feefe/ /: /l„ e://// ,/,,,/ el/,// !.1//e DORKING FACE AREA /' / / e SLOPE VOLUME 40.29 On; f„ ,,, ,/,// /////////1111//// A t •. ,,, „ 1j :•I , , , , h�\ v f -. PHASE 3 TOTAL60.36AC: "/ ,,,/• , ':• ;,{Pg11Q)�1' ATE RESERVOIR AREA. 37. ' i;$, e e \ J " '///,/// WING AREA 41.31 ACRES- ! llll < - c:•1; /r e e e e e TO 1 SLOPES 22.66 AGIES _ ' '''''' -' •1;:, Js /,// ,. /lee,/f' e „ GETA ON AREA. 5.35 ACRES „/eeee: RP % •:1 '?..s x3:Fr� ,,, //e////rae�� , tl. RM \\ \�.• .• • _-• • L.1 , ,, ,, ,f/� /J'f qv r,,,,,-.�_ „ee/e/Gc "-_.'•'. A ESa IPAI111: 'v r O1;AER: PUBLIC SERVICE CO,IMP-IA'YOFCOLOR-WO Le Nba Yr(' R,IyIFWIX/SHGUS7on ! BACKFILL SLOPE VOLUME 115.54 CY/LFT TTE VER , ee tee .,, •,1 C. ,1111/„l///e//„////, „e, ,1111/„ ,//„//,„///,/,,,,,e /I, //,,....... ele ,,,//// I/„ I/// • eed I/// I Fe , ,,, PHASE 2 ,,,/ TOTAL 145.39 AC - 1// APPROXIMATE RESERVOIR AREA. 100.15 ACRES: '''' MINING AREA 106.87 ACRES : "" 3H TO IV SLOPES 29.90 ACRES / REVEGETATTON AREA. 18.38 ACRES: WORKING FACE AREA - CUT/FILL SLOPE VOLUME 21.11 CY/LFT e e /,,, ,lee/ ///e/ e//1 ee/ee zee/It/Fee/lee/• �•.• /,ell///// e,/,:�'• n �rP r, � f • ♦ f N♦. / /NIINIi .i/e/, d ' t.•)1 / 4`l•l / z, f/ / ! / / / / / fV 00 i l•( 3� se, . ee e e , , • , IF /, / / ee /, le 1/ Xe ee ee el „ / A /. ee , / ▪ /e / ▪ ,/ / / / 1//, of 0'1 / / / lee ee I „ „ „ e. E ENTRANC / ,/ • /, e e ,/ PLANT SITE 50.00 AC. F CK0P U' 2.38' el e/ ee ,/ le ee ee el e, • • ee ., / ee ee ee l/ ee ee O 7 2A.• MA • R• ER IR •E 56. A, EA 1.I CR O 1 SL • ES 1 5 CR EG A •N EA. 7.•- CRc l/1 e ll/ fee// feel e „ I ele ,,,, ,/I/ BACKFILL SLOPE e / e / VOLUME 208.33 CY/LFT ` BMW#3 i 7/,,,�,/,,,,,,,,/,,,,/l/,/ ///e1//,///,A01t90192:42,,,,4,//,////l// I ` 60 Ft. MW -2645 ' a ✓ / - (( f.. ,. ,,,,/III/ eeeeea/e//e//,11.71C. Vat ft i,-i-/PUee/Atieee „If W YY 0 /�.^...:.Fie-••,•-,/S- '?//e,/I/ /MI =.0 k SSINGENVE ENVELOPE• ,,,,/„„/,,,,,,, b: N... 4.7 " nis# 7 PS6%. //tee // ...... z l . /l/ e,ee,///////,//!////,////////e 1111/ /fsf I / 4-;4c1,, , 'fl( //eel ,,,,,,� �• /III/ I �,- • ,7 I • t „e, 1�4V „,, eee, e'� ,ee/ 2 11 • A ! /.• ,,,,,M� A.At I�...f_ .3rn 6.00 AC _ + + + F},,,/ ;zee,/ 1•••••••//e J/,//e ' :\_/,,,, �> ieeee r. \�,!„ BACKFILL SLOPE i i • , '•/'ii' VOLUME 115.54 CY/LFT e//,,,,. , TOTAL 190.23 AC: APPROXIMATE RESERVOIR AREA 141.67 ACRES: MINING AREA 147.56 ACRES: 3H TO IV SLOPES 31.32 ACRES REVEGETATION AREA. 8.54 ACRES : WORKING FACE AREA _ air/Fla SLOPE VOLUME 21.11 CY/LFT ////E// le ell/ 1111/, /1/teeeel//e//!////II////„ ///el///„ ///l, ♦ ,//e//,,,I,/ //e!,/ !//1// ///11////////a/////!I!//!///!///!/!,//,!,!!,//////////////,TrA///e////////////e/ 1111//l////////// l BACKFILL SLOPE VOLUME 11554 CY/LFT 4•HlCOu/.f ICCr/.W 0 Att/lK ,2 r' JJl. MCC • / \ Oµ ON 1111/// /!,!/!Y / Pt//////////////!!/!//////II/! l!!/!,//, ! ,/,/!!, /! ,'a;/>!,/,!!,1!11,,1,/„//„�' �"////3AHX S#i41 NEpitEPltn '91=RM!////!///e/11/l/!///I////////////// E J///I/!!!//!!/e!I/ /!///!!///I//lI OS �. i '•/ / / ! !/t /!!/!!I/////!!!! !II!//e//lee/I/Fe / ee/ _/ !!/ Ife/r/////e//e...... Terr 4,,, ,//e/eee///lee/ \\\ /.�\q•I.\, \\l•// \\W/♦\\ Y/I ,Il/.\\!//.\ NIA\ //% . - Ih\1111 //p // //N/Il/•/////. //! I •//b •/ �•� • • ��./-/./ !� / / / / / / / !_,•f / / / / / e / e / / e i e e e / / e e e e 2 e e e e e e e e e e e / / • w115 -45 —GS —GS —GS GS 1 ��r •.TG I!4/l let/ 1//,I//,/ e// ww US GS�G--US—US— W IA'ER• f,4LO,4f,W2 JF_F?REY A A` Pit O4ISO. Kh_A'OR4 Al Fopic4� ORA N RE D O.. t - /„� I \ --Gl--GAS—GL—GS-41—GS--CAS f• GL I•'~^ I/ f� —Cf fJfa-�-•• f • � — "z L CAS f Gs 38fu,1= yc f zt—te /� 1 `U$ER DRAIN APPROXIMATE LOCA\TION O I VlVER. , I /A C.. VESS I- 4 A D HOLDINGS L L C 2 Ft. O1VNER: ABBL•TT TRUSTE-1 RMMSL/_C 100 Ft 0 150 300 20O F • • 408 Ft SCALE 1 s=300' 600 Map Exhibit C-1 - MINING PLAN MAP PREPARED BY' ENVIRONMENT, INC. 7985 VANCE DR., N 205A ARVADA, CO 80003 (303) 423-7297 LEGAL DESCRIPTION Ports of the SEINE+, SWINE}, NEISE+, SEISE*, NWISWI. SISWI, and SINWI of Section 14, Township 3 North, Range 67 West, 6th P Weld County, Colorado, EXCEPT County Roads 21 dr 324. containing 472 40 aLt Mine Entrance: 40°13'25.1536N, 104°52'02.8563"W WG584 DATE: ORIGINAL PERMIT ADEQUACY 02 REVISIONS 11/10/2022 7/06/2023 APPLICATION FOR A 112 PERMIT WEST FARM RESERVOIRS L.G. Everist, Inc. 7321 East 88th Avenue I Henderson. Colorado 80640 phone: (303) 287-4656 I fax: (303) 289-1348 o frr -C :AO NMVbO rn O OMO'dVn-I-3 SrwC :3WVN 3lld 0 O SHEET EXHIBIT E RECLAMATION PLAN AND TIMETABLE OVERVIEW The proposed future use is to create 4 in -ground, developed water storage reservoirs with a vegetated border around the highwater lines of each reservoir. Each of the proposed reser- voir areas will be sealed with a slurry wall liner. Eventually the reservoirs will be sold to a municipality or water company who will be responsible for the construction of any additional reservoir operations facilities (pump houses, inlet/outlet struc- tures, etc.) on each reservoir. This will occur once L.G. Everist, Inc. has resoiled and seeded the perimeters. (If the facilities construction is anticipated prior to the release from the DRMS permit on a Phase, a Technical Revision will be filed to add the locations of any reservoir facilities to be built.) The reclamation methods and plans described below will apply to all Phases but may require minor variation depending on the conditions found in each Phase. Reclamation will run concurrent with mining so it will commence as soon as enough area is avail- able to reclaim and not be redisturbed. The setbacks and side slopes from the water's edge to the slurry wall or setback limit will be resoiled and revegetated using the methods described in the following plan. On -site generated inert material will be placed in backfill areas or will be recycled/sold. The existing oil and gas wells shown on MAPExHIBITC are all shut-in, meaning they are on the list to be plugged and abandoned in the future. Once the wells are removed, all of the support facilities will be removed and the feeder lines abandoned. This reclamation plan assumes they will be removed prior to mining in the areas they affect. Should the O&G facilities still exist when mining reaches them, a Technical Revision will be filed to show how they will be mined around and reclaimed. The applicant proposes bonding the site in two Operations Stages. For Operations Stage A, the initial bond is calculated on having only the Plant Site and settling ponds bonded until mining is ready to start in Phase 1. Upon competition of prepa- ration of the Plant Site a Technical Revision would be filed to increase the bond to allow for full development of the mine as explained below. This second bond would be to cover the maximum amount of disturbance throughout the mine (205 acres), this would including a sufficient length of liner construction, under drain installa- tion and bank sloping, the Plant Site, areas of seeding, back - filling, etc. If the applicant determines that the amount of L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 16 EXHIBIT E RECLAMATION PLAN (mm) disturbance at the mine may soon exceed the bonded amount, the applicant shall submit a bond revision to the Division. Currently, the proposed mine site is primarily irrigated agricultural land, but is broken into 4 different use areas. The current uses are, irrigated crop areas; non -irrigated pasture; ditch and return flow corridors; and oil/gas operations areas with some high capacity gas pipeline ROW's around the perimeter. The agricultural uses will continue in areas where mining opera- tions have not yet begun. There is very little native vegetation present on the majority of the site because of the intensive agricultural practices that have taken place on the land. In most cases, the oil/gas operations areas have little vegetation and the high pressure gasline ROW's have been farmed for many years and the vegetation cover on those areas is consistent with farmed areas. The ditch and return flow corridors have been disturbed by ditch maintenance over the years. This leaves only isolated areas around the permit area with vegetation that may be considered native. The typical vegetation descriptions in EXHIBITsi &Jwill not match the actual current vegetation on the site due to the agricultural activities - pastureland (cattle grazing) and farming with various crops. RECLAMATION PLAN This section covers reclamation on the developed water storage reservoirs in Phases 1 thru 4. As discussed in the MINING PLAN text, reclamation will run concurrent with mining. Initially this will happen when the reservoir slope areas are being mined and graded. The plan is to use overburden or shale from the mine floor to create compacted slopes around each reser- voir. The APPENDIX contains the Deere & Ault Geotechnical Slope Stability Analysis where on page 4 they explain this method of sloping. Backfilling will be done, then once mining has reached the outer limits of a Phase, the sloping materials will begin to be placed against the working face so only minor amounts of slope work will be necessary as mining ends. In Phase 2 where mining will take place within 400 feet of the river, the bank will be backfilled to 300 feet at which point the slope into the reservoir will be backfilled and sloped. In this area no more the 500 feet will need backfilling nor will it be left open for more than 12 months. Armoring will begin as soon as bank sloping is complete on each 500 ft section. No more than 1000 feet of outside bank backfilling and sloping will be needed at any given time. This will also ensure, that if mining L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 17 EXHIBIT E RECLAMATION PLAN (coNT) ceases before the resource is exhausted, only a minor amount of work would have to be done to finish reclamation on the disturbed area. The temporary topsoil and overburden stockpiles in the various mining phases will be available for reclamation needs. Armoring in both Phase 1 and Phase 2 will progress with sloping, so no more than 1000 feet will need to be completed at any time. No armoring will be done along the Irrigation Return flow trench south of CR 35.5. The BANK ARMORING PLANis in the APPENDIX and explains how and where the armoring will be placed. There are no plans to install Inlets or Outlets for the reser- voirs. Those will be the responsibility of the reservoir devel- opers. LGE will be working with the Town of Platteville for directions on Flood Plain development. This facility is not in an Urban Area, not near public land, or facilities where public safety is a concern so, inlet/outlet structures for private reservoirs are not needed. When grading and shaping is completed on a large section of reservoir banks, the areas above the high water line will be resoiled and then seeded during the next seasonal planting win- dow. The EXHIBITF- RECLAMATIONPLANMAP shows the sloping plans, where armoring will be installed, the area to be revegetated and areas that will be reservoirs in this plan. All reservoir bank sloping will be completed to the stated 3:1 slopes or flatter. All areas that are above the high water line, and are not being reclaimed as graveled access roadways, will have an average of 10-12 inches of soil placed and prepped for seeding. All top soiled areas will be seeded with the seed mix described in this plan, and effective weed control measures will be implemented until the Phase is released from the permit area. GENERAL DISCUSSION There are sufficient amounts of topsoil on the site so the mined areas can be resoiled to an average depth of 10-12 inches. Sufficient topsoil will be saved for use in reclamation. The available topsoil to be salvaged from the stripping process will preclude having to haul additional soils onto the site for revegetation. The existing soils on the property have been capable of producing healthy crops and grasses and are expected to work well for revegetation of mined areas. The vegetation information was obtained from site visits and data provided in the NRCS Web Soil Survey page. A copy of that report is in ExHIBITIANDJand describes the current soils and vege- tation on the properties in more detail. L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 18 EXHIBIT E RECLAMATION PLAN (coNT) As outlined in the EXHIBITD-MININGPLAN, approximately 388.12 acres ± of the permitted area will be disturbed as a result of mining activities. Once mine development begins, the plan calls for the initial bond to have 205.00 acres± disturbed at any -one-time and the disturbed area may be divided between the reservoir Phases and the Plant Site in Phase 4. As mining pro- gresses across the property, some parts of the property will remain undisturbed while other areas will be either stripped, mined, partially reclaimed or totally reclaimed. The ExHIBITC-1 - MININGPLAN MAP shows how the pit will be developed. The ExHIBIT F - RECLAMATIONPLAN MAP show how the area will look when reclamation is complete. Careful analysis of the growth medium and salvageable soil will permit the operator to carry out a soil additive program and to monitor the prescribed seeding plan to determine if the plan requires revision. Under normal weather conditions, an adequate moisture reserve will be present for establishment of the pro- posed seed mixture. No irrigation is planned for the reclaimed areas. No revegetation will take place on undisturbed areas, roads or oil/gas operations access roads or facilities. The reclamation timetable shows the types and amount of land use in each Phase when reclamation is complete. Approximately 19% of the area in the permit will not be disturbed by mining, either because it is setbacks around the permit line, gasline ROW's, along the ditch and areas too small to mine that will be kept in their natural state. REVEGETATION PROGRAM The revegetation program to be implemented on the areas to be seeded with grass by L.G. Everist is detailed below. The topsoiling plan presented above and this revegetation program are devised after careful review of the existing soil conditions and present vegetation, both on the site and in the NRCS report. "Revegetation will be carried out in such a way so as to estab- lish a diverse, effective and long-lasting vegetative cover that is capable of self -regeneration without continued dependence on irrigation, soil amendments or fertilizers." (CRS 34-32.5-116 (4) (f) ) The plan is designed to create a vegetative cover around the reservoirs that is at least equal in extent to the cover of natural vegetation before mining. The use of species native to the area are included as part of this plan. Since the intended use of the reclaimed land along the reservoirs is rangeland, any slopes created will be commensurate with this final land use. L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 19 EXHIBIT E RECLAMATION PLAN (co.-) Seed will be drilled wherever possible, when drilling is not possible, the seed will be broadcast. The revegetation plan provides for the greatest probability of success in plant estab- lishment and vegetative development by considering environmental factors such as seasonal patterns of precipitation, temperatures and wind. Other considerations, such as soil texture, fertility, slope stability and the direction in which slopes face, have been considered. A weed control plan is included in this submittal, see the APPENDIX. Graveled maintenance roads will be built around each reser- voir and around each gas/oil wells, should any remain, where no seeding or resoiling will take place. This will provide room around each well or reservoir to service it as needed by the well or reservoir owners. These access roads and graveled areas are shown on EXHIBIT F - RECLAMATION PLAN MAP . SEEDBED PREPARATION When mining on an area is complete or there is room to begin reclamation, any compacted areas will be ripped and scarified to created a deeper root zone under the resoiled areas. Once this is complete, the stockpiled soils will be spread. If tests show a fertilizer is needed, it will be broadcast spread on the seed- bed at an adequate rate suggested by NRCS or a seed- ing/revegetation contractor. On the areas where seed is broad- cast, the surface will be left fairly rough to trap the seed and keep it from being affected by wind. SEEDING TIME The grass seed mixture will be planted from early fall through spring (October through May). The time of planting will be controlled by when the resoiled areas are ready for planting. If fall planting is convenient, the seeding will be done before the first freeze (about the time Winterwheat is planted). If spring planting is called for, it will be done in March or April, weather permitting, after the last frost. Both periods assure there will be adequate residual ground moisture available for the newly planted seeds. GRASSES The following seed mix was developed by the NRCS office in Brighton many years ago and is used on all L.G. Everist mining operations in Weld County. It has proven to be very reliable. This mix will place approximately 41.2 seeds per pound per sq-ft as prescribed by the NRCS planting guidelines. If the seed is broadcast, the amount will be doubled and spread on a rough L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 20 EXHIBIT E RECLAMATION PLAN (cone) surface. The seeded areas will then be dragged or raked thor- oughly to set the seed. Under normal conditions, the operator will strive for a 30 to 40 percent cover rate on the grass revegetated areas when reclamation is complete. No trees will be planted, because they are not compatible with reservoir development as their root systems affect the liners. It is expected some natural invasion from adjoining areas will occur. PROPOSED SEED MIX Species Lbs. PLS/Acre Western Wheatgrass (Aribba) 5.0 Big Bluestem (Champ) 2.5 Blue Grama (Hachita) 0.6 Switchgrass (Blackwell) 1.75 Total 9.85 It has been our experience on other operations, that the seeded area may have a heavy cover of weeds after the first year. The second year, there are fewer weeds as the grasses start to take hold. By the third year the weeds are mostly gone and the grass has established itself so it will grow in future years. These weeds also tend to shade the seedbed, retain snow in the winter and act as a wind break for the newly emerging grasses. The area will then be monitored for success of revegetation until it is released from the permit area by the Mined Land Reclamation Board. WEED CONTROL The revegetated areas will be monitored closely each spring for the first two years to determine if noxious weeds are invad- ing the area. L.G. Everist, Inc. will implement a weed monitor- ing and control plan that covers the areas actively used by their operations. LGE understands their responsibility for weed control on th permit area and will ensure that weed control on non -mining areas is performed. Weed control in the mining and reclamation areas will be initiated if the problem becomes serious or if an excessive weed cover is still present at the end of the second year. In no way should this be taken to mean that L.G. Everist will try to eradi- cate all the weeds from the site. Some weeds are beneficial to the upland game species in the area, they provide important L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 21 EXHIBIT E RECLAMATION PLAN (coNT) protection from the elements during winter, and nesting sites during the spring. Total eradication of weeds from the site is not necessarily desirable or possible, so we will be using stron- ger controls on the noxious weeds and controlling the rest as needed. Weed control may be done through mowing or chemical means. Control of noxious weeds is important to the state, so we will follow USDA Extension Service recommendations to control them. Our Weed Control Plan is included in the APPENDIX. IRRIGATION No irrigation is planned for the revegetated area around the reservoirs. It makes the vegetation dependent on water and does not promote a vegetation cover that is diverse and capable of self regeneration. RECLAMATION PERFORMANCE STANDARDS (The following information is presented to address specific parts or Rule 3 as required by the MLRB Rules and Regulations.) L.G. Everist, Inc intends to operate the mine in compliance with the Reclamation Performance Standards of Rule 3. Grading will be done to create a final topography that is compatible with the intended final land use. These slopes will be 3:1 or shal- lower and on the unmined areas they will remain in their current configuration in an attempt to retain the present drainage pat- tern across the property as much as possible. A mine entrance sign that conforms to the requirements in Rule 3.1.12 (1996) will be installed at the entrance to this facility prior to commencement of mining. The material used to create the slopes will be native mate- rial found on the site. It will consist of sand, gravel, over- burden and topsoil. The Phases will be reclaimed so that a suitable grade for drainage exists. All surface runoff within the mine site will be directed into the excavated area, and all surface runoff outside of the permitted area will be allowed to flow into natural existing drainages outside the site. All grading will be done in a manner to control erosion and to protect areas outside the affected lands. All backfilling and grading will be completed as soon as feasible after mining is completed. All refuse will be hauled away or disposed of in a manner that will control unsightliness and protect drainage systems from pollution. L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 22 EXHIBIT E RECLAMATION PLAN (cony) There are no acid-forming or toxic materials inherent in the sand and gravel deposit. If petroleum products are stored at the site for mining equipment and operations, they will be stored as prescribed by applicable laws. Any storage tanks will be surrounded by a berm or be of the latest multi -wall construction, adequate to contain any fluid spilled, should a tank rupture. In addition, there is adequate absorbent materials on site to contain any spills that would occur. Maximum slopes within the mined area will be within the limits set forth in the Rules and Regulations of the Board and will be capable of being traversed by machinery. The slopes between the eastern and western reservoirs will remain undis- turbed and in their natural state, slope and appearance. The operator does not expect prevailing hydrologic condi- tions to be disturbed. L.G. Everist will comply with applicable Colorado water laws and regulations (as the operator understands them) which govern existing water rights. The operator does not expect to adversely affect the prevailing hydrologic balance of the affected land and surrounding areas. Nor does the operator expect to affect the quality of water in surface and ground -water systems both during and after the mining operation and during reclamation. In addition, the operator shall comply with appli- cable Federal and Colorado water quality laws and regulations. Any water used in the mining operation and the processing plants will come from water owned or leased by L.G. Everist and legally suitable for use in mining operations. EXHIBIT G -WATER INFORMATION contains specific information concerning impacts and uses of water at this mining operation. A Groundwater Model and Water Quality Monitoring plan are included in EXHIBITG- WATER. No dredging takes place at this facility, there are no temporary siltation structures involved in this operation and no mining will be done in a river or waters of the United States. A U.S. Army Corps of Engineers 404 Permit is not required for this operation because there are no jurisdictional wetlands on the site. The operator has been approved for a RGP-5 from the Corps for the relocation of 1 irrigation return flow ditch in Phase 1, along the eastern side of the phase A copy of the JD and RP5 are included in the file. Temporary settling ponds will be constructed on the site to collect water from the material washing at the processing plant. The settling ponds will be removed during final reclamation. The fines in the wash -water settle out in the ponds and the water is then recirculated to be used again in the processing plant. There will be no earthen dams on the mined area. L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 23 EXHIBIT E RECLAMATION PLAN (coer) Groundwater collected from the dewatering trenches may be discharged from the site, after any natural fines have settled out. The discharged groundwater quantities will be measured and sampled as per the requirements under a CDPS - Sand and Gravel Mining Process Water and Stormwater Combined Permit. The mining and reclamation plans have taken existing wild- life conditions into consideration. The final reclamation will enhance the area for wildlife use. The mining and reclamation plans allow for the safety and protection of wildlife remaining on the mine site, at the processing site and along all access roads on the site. In practice this is done by limiting the amount of disturbance, restricting truck and equipment speeds to 15 mph or less and doing concurrent reclamation. Mine employees are trained to deal with wildlife found on the mine, during operating hours to avoiding harming them. See EXHIBITH-WILDLIFEfor more information. As mentioned previously, topsoil on the mine area is of good quality, so it should be a decent growth medium for reclamation. When topsoil is removed, to reach the sand and gravel deposit, it will be segregated and stored in graded stockpiles, generally located in areas where disturbances by ongoing mining operations will be at a minimum, i.e., along setbacks on the pit perimeter. If the topsoil (and overburden) stockpiles remain undisturbed for more than a year, the approved seed mix will be applied to pre- vent erosion, to control weeds, and to keep them viable for reclamation. Fertilizer and other soil amendments may be used as discussed in this plan. If revegetation problems occur before release, an analysis of the problem area will be done and the area will be revegetated again as necessary. The seed mixture and rates may be revised as needed to complete reclamation, if a substantial modification is required, the Division will be notified prior to making the change. This gives us the most flexibility to complete reclama- tion successfully. RECLAMATION TIMETABLE Reclamation will begin once enough area has been opened so that any reclamation completed will not be disturbed as mining progresses. This may take 5 or more years depending on the economic conditions in the area and the amount of material mined. The operator anticipates approximately 81% of the total mined land will be reclaimed by the time mining is completed. L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 24 EXHIBIT E RECLAMATION PLAN (ciii) Table E-1: Reclamation Phases Phase Years ACRES ± TOTAL WATER AREA REVERE- TATION ROAD Misc. (DITCHES , UNDIS- TURBED AREAS, ETC.) 1 3 to 5 190.23 141.67 8.54 3.02 37.00 2 3 to 5 145.39 100.15 18.38 2.80 24.06 3 3 to 5 60.36 37.71 5.35 2.31 14.99 4 3 to 5 76.42 56.14 7.05 2.67 10.56 Totals 472.40 335.67 39.33 10.80 86.61 L.G. EVERIST, INC. - WEST FARMS RESERVOIR July 2023 25 • L.G. EVERIST, INC FIRESTONE GRAVEL RESOURCE • • • • • • • • • • • • • • • • • • • • • • • • • •J.-. ..••••.••••••••••••••...•.••.•••y. ••••••••••••••••••••.••••••5.- •.....••••••••• -.••••••••- ••••••••••••••••• ..• •• x ••••••.. • PHASE 2 TOTAL 145.39 AC t APPROXIMATE RESERVOIR AREA. 100.15 ACRES. •1. es FIGURE E -I • - VAR.•••••••••••••••• _ _1i&F.VF.R/,ST.Arr •••••• 100 Ft. •••• •... • • • • • \••• • • • • ••••••• •••...•• ,••••••• ..••••. ••..... •...... • ... •••. - • • • • • .. • ••••... •••.... •••..••• .••r••.•••• >4.• ..••••• ••••••••• •••••••••• •..••••••• �•••••••• . • • • • • • • • *z. • •!t • Sr N• • ..•••••• -11::• • • • • • . • •J • • • • • • •.t. • • • • • • • • • • • • ••••• • • • • • • • • • • • • • • • • • • • • • • . • • • • • • • • ,•• •.•• • \•••••• ••..•• \ ••• •••••• \ • \ ... ....... �... ••••••••• ... .• .••••• ... •••... /. . . • • . . • • • f_• • • . . • e • Set ..••••••• ... •••....•• •• .. • •.• •. • • ••. •.. •••••••• ••••••• •••••••• . • • • • • . . ••.... •••... • . . . • . ....... 4w .. . •c •c • • ••••• • • • OOOOOO ••••••••• •••. / I� 1 l T ��. \ •�.ss. - � .si' �► srer�r�idii��.fiiii�ii�:�/*,iii.>�iii�i/iriri� �%ii' .��'.'rr".' rtir':�?`%' �v?r%i7�iTi%liiii��.i •�� _��. 1' G ` dorakk .r.trdeart !!. //.,r/"..•hrr s•y,*.►j s e�%-''e st.1// OTI_ /r/_lAtf/ar4?-t �?tiZg/ I ultra- /t%j ��//twI' ...: cal'. ••es '46717,,a,.c*rss ��.�%s i��.►L�71�• !/ F ��i�.ri �flil�' na..• / �f1�PI/ D/I%l Rr I. .. 1 •��i..��r fI �!/! �..�Jdr� ./i'/ � v �//�� /�/ �� _ ♦ I"1� / �'�.•� _ ♦I �I=li_..I___-� ��'�l+.L•4 ••••• ••••. ••..• ••••• ••••• AFFECTED LANDS/PERMIT LINE DITCH PHASE 1 TOTAL 19023 AC APPROXIMATE RESERVOIR AREA. 141.67 ACRES LAKE AREA REVEGETATED ROADS & GRAVELED AREAS NON DISTURBED AREA •• •• *It ..a_ • .•••t• .. • • • • • • • • • • • • • • • • • • • • • •I• • • • • • • ♦ • • • • • • • • • • . • • • • • • • • • • • • • ► • • • • • • • • • • • • • • • • • , 1 • • • • • • • l • • • • • • • • • • • ••••• ..•.•. OOOOOO • • • • • • •••••• •••••.. '!q!3M • • • • . • ••• •••.•. • • • • • • • • . ••...••••• • •••••••..• ...•••••• '•••••..•• •••••••• . • • . • • ••• • • • • • • •• • • • • • .I.i.•• • • •• CI .• • • •• • • • • • • •• . • • • I .• • • . • •• • •�• • •• • • • • • •• • • • JUN 29. 2023 - 12: 23:09 • _ 26 LEGEND PERMIT BOUNDARYIAFFECTED LANDS 200 FOOT LIMIT T T _ COMMUNICATION LINES OHE OVERHEAD POWER LINES x x x FENCE ABANDONED RAILROAD GRADE w WATER LINE IRRIGATION LINES FIBER OPTIC LINES c c GAS LINES SLURRY WALL LINER UNDERDRAIN ROADS (OFFSITE) e= e= ROADS (HAUL, ACCESS) (TYP.) �.•�°�� TOPO CONTOUR - IR- - FO F d Q FO VD FP �atr�-En,3�'l O RIVER DITCH FLOOD PLAIN BANK ARMORING (Approximate Location) BUILDINGS OIL/GAS WELL PUBLIC ROAD RIGHT OF WAY WATER LEVEL (ESTIMATED) I 0 150 3OO 600 tot SCALE 1"=300' O16N£R: PL/BLJCSER COMP.LV1'OFCOLORADO BEN HUDSON OWNER: 1731BL/RLLN FARM O11Nat: d` P,4LOMRO KENDR4 M OWNER: PUBLIC SERVICE COALF4A'YOFCOLORADO C A'im Yd' R?vmond SHoaston avert tf� •IAA7 r:Jl�w S' L.21.EY. Ji'7?IAVA 0 c C1 - OI t�vFJ4-tl.4QiN£SSLAND HOLDINGS £1? 21 ,., + it v S 'TILE •lo A A It Cc. 4.• •• f`L / • ,-'it . Map Exhibit F - RECLAMATION PLAN MAP AtbeS PREPARED HY' ENVIRONMENT, INC. 7905 VANCE DR., N 205A 7905 V, CO 80003 (303) 423-7297 Environment-incQouldrs. net LEGAL ithe SE}Ni }, SW}NE}, NE}NW,, AND NW*NWI. and 5$5W}, and 5}NW} of Section 14, Weld County, Colorado, EXCEPTCounty Mine Entrance: 40°13'25.1536"N,104°52'02.8563"W DESCRIPTION NW}NE}, NE}SE}, all of the WISE}, NW}SE}, Township 3 North, Range Roads 21 d 32}, containing SE}SE}, NE}SW}, 67 West, 472.40 W6584 NW}SW}, 6th P.M., at: REVISIONS: DATE: I CHECKED BY: LGE/LMS DRAWN BY: ENV/SLO SCALE: 1"-300' i FILE NAME: ORMS_F-MAP m -- \ a o N O N 1J . Everist, •. IncParts ORIGINAL PERMIT 11/tH/2O22 PP O f �1 FORA 112 PERMIT A LI CA TI SHEET 4 O F 4 ADEQUACY 02 REVISIONS 7/06/2023 732 1 �'aSt 8Hf�1 1��CIIliC Henderson, Colorado 80640 �% WEST F A' a AA RESERVOIRS E.Ahcnohx [,: p1101]C: (303) 287-46 6 fax: (303) 289-1348 JUL 05, 2023 - 7 t: 57: 54 6" ROADBASE T VARIES NATIVE BACKFILL 1L 11 (Copy and Paste from Directory) 1 GRAVEL BEDDING 12" DRAIN PIPE TI I TYPICAL TRENCH SECTION eiSchnabel WEST FARM ENGINEERING UNDERDRAIN DETAIL FIGURE 1 © Schnabel Engineering 2023 All Rights Reserved EXHIBIT G WATER INFORMATION Introduction The site is located about 1.5 miles west of Platteville, Colorado. Please refer to EXHIBITB-VICINITYMAP for the property configuration and the relationships to surrounding geological features. The site is bordered on the south, west and northwest sides by irrigated agricultural lands and on the east and part of the northeast side by the South Platte River. There are 2 irrigation return flow ditches that cross the property and other onsite temporary agricultural feeder ditches that carry water to the fields being irrigated. Two center pivot irrigation systems are fed by wells owned by L.G. Everist, Inc. There are 7 regis- tered irrigation wells, one domestic well and 6 piezometers on the property. Within 200 feet or the permit line there is 1 Domestic and one Geothermal wells located in the southwest corner of the site. Based on regional groundwater studies and the experience gained by L.G. Everist, Inc. during numerous previous permit applications they have found that slurry wall liners mitigate any impacts to groundwater on nearby areas surrounding a lined reservoir. Ground water in this area tends to flow from the west towards the river, the depth to water on the flood plane level averages 3.55 feet below the surface and along the western terrace deposit the depth to the water table is 19.5 feet. Data for the monitoring well information collected thru the month of submittal is shown on TABLE G-2 ON SITE GROUND WATER MONITORING DATA . If any significant groundwater changes do occur, they can be miti- gated as discussed below. In May 2023 a Groundwater Model (GWM) was prepared by Schnabel Engineering to provided potential impact information of the ground water levels by installing Slurry Wall liners around the reservoirs. That report is provided at the end of this exhibit. In addition, Molen and Associates was asked to prepare a Water Quality Monitoring Plan for the permit area. That plan is also included in this exhibit. These reports are used in the following text to establish the mitigation and testing plans for the West Farms Reservoirs mine. The mining operation will have minimal effect on the South Platte River in the form of minor groundwater depletions due to evaporation and water uses associated with mining. The depletions to the South Platte will be mitigated thru a temporary Substitute Water Supply Plan (as required and approved by the Division of Water Resources) to prevent injury to vested senior water rights. L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 28 The reclamation plan proposes the creation of 4 slurry wall, lined reservoirs that will not be hydraulically connected to the South Platte River or any alluvial aquifer. The reservoir areas will be sealed prior to mining, thereby eliminating the groundwa- ter draw down which is typically associated with mine site dewatering. This will also eliminate or minimize the possibility of any adverse impacts to the single nearby alluvial well. Potential Water Resource Impacts Ground Water Wells We expect this mining operation will have no or minimal impacts on the prevailing hydrologic balance. Sand and gravel mining related impacts to groundwater wells near the pit will be mitigated through the installation of slurry walls around the perimeter of new reservoir mining phases prior to the start of dewatering in each reservoir Phase (see EXHIBITD-MININGPLAN) . TABLE G-1 WATER WELLS WITHIN 200 FEET is a list of 12 wells from the Office of the State Engineer's files that are located within 200 feet of the permit area. (NOTE: THE WELL PERMIT LOCATION SHOWN IN THE TABLE HAVE BEEN CPS LOCATED BY THE STATE ENGINEERS OFFICE'S AND GROUND VERIFIED) . All wells except the geothermal well (Blue highlight) are shallow wells, at this time, there is one shallow well within 200 feet of the permit area that is not owned by L.G. Everist, Inc. The Palombo domestic well is located near the southwest corner and is up gradient from the mining area. LGE owns the 8 wells listed for Norgren Farms and is in the process of filing a name change. There are 2 monitoring wells along WCR 32.5 owned by Metro Wastewater Reclamation District, the eastern most one is more than 600 feet from the permit line. Prior to exposing groundwater or installing a slurry wall liner in any Phase, a well survey will be performed on any shallow wells within 200 feet of the phase. Wells that are located within 200 feet of the permit area, that do not need to be tested are(a) owned by L.G. Everist, Inc., (b) monitoring wells, (c) deep wells, because deep wells will not be affected by potential surface impacts due to mining. L.G. Everist will attempt to obtain for each shallow well to be tested the following data: Basic Well construction data that is currently available. Total well depth Depth to static water level, Depth of pump intake • Conduct pump test to determine well yield (subject to DWR Regulations) • Conduct analytical sampling of all Domestic Drinking Water parameters for any residential wells. All data collection will be completed at L.G. Everist's expense. Data will be provided to DBMS and the well owner upon their request. If a well owner chooses not to allow the permittee L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 29 Exhibit G Water Information (cont) access to collect the above data, they will be provided with a form that they can sign and date to document that they have been provided with an opportunity to have their well characterized at the permittee's expense, but have chosen to decline to partici- pate. L.G. Everist, Inc. has installed 6 piezometers (a.k.a. Monitoring Wells) around the mine and plan to install an addi- tional 6 wells to collect more groundwater elevation data and be used for water quality monitoring and research. Their locations are shown on the maps and on MAPEXHIBITG-1 WELLMAP. L.G. Everist started data collection in July 2019 and will do monthly depth readings throughout the life of the mine. We will provide a summary of the data yearly with the Annual Report. Mitigation Trigger Starting in July 2019, L.G. Everist, Inc. began to collect groundwater elevations from newly installed monitoring wells on and around the mine area to establish historic ground water elevations around and on the site. The period July 2019 until installation of the Phase 1 liner will be used as the baseline for triggering mitigation actions. This way the baseline data needed for the areas are in place well before installation of the slurry walls will begin. The permit area has two areas where the depth below ground level area vastly different. The dividing line between these land features is a natural bank where the river valley transi- tions from the flood plain on the east side to the upland area along the west side. In the eastern area, Phases 1 and 2, the natural groundwater depths vary from 2.9 to 4.4 feet, average 3.5 ft. below the surface. On the western areas, Phases 3 and 4, the natural groundwater depths vary from 16.7 to 23.9 feet, average 19.5 ft., below the surface between June 2019 and October 2022. These ground water depths and averages may change prior to mining commencing. The important area for mitigation lies along the eastern section of the south line or area along the Abbett Farms land. Along this line the average depth to ground water varies from 7.2 on the west to 4.4 feet below the surface at MW #7, near the river. This covers a section approximately 1860 feet west of the river. The mitigation plan is designed for this area as it could likely be the most impacted if there was a significant increase to the groundwater elevations due to mounding. The model pre- dicts that the potential mounding affect would vary from as much as 2.5 feet on the west end of this strip to approximately 1 foot at the eastern corner of the slurry wall on the east. It also indicates that if needed, a simple perforated pipe, 12 inches in L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 30 Exhibit G Water Information (cont) diameter would be capable of regulating the groundwater to his- toric elevations. L.G. Everst will commit to installing said under drain along the above referenced section during slurry wall construction in that area. Once final design of the under drain is complete and prior to installation a Technical Revision will be filed with the Division for approval. In this mitigation trigger plan, the trigger limits will be set at as a two (2) foot plus or minus change over a 3 -month running average. Because the average groundwater levels are already close to 4 feet from the surface in the southeast corner of Phases 1, limiting the maximum rise before mitigation to 4.0 feet is too restrictive. The data collected to date shows the historic high to low swing is much as 1.44 feet up or downward possibly due to outside impacts such as, drought, storm events or decreased irrigation. A 2 foot increase over 3 month running averages will keep the minimum depth to below the 24 inches cover level required by the SEO exposed ground water requirements. As for the shadowing effect of the slurry walls, we do not expect this to be a problem where the slurry walls are in close proxim- ity to a flowing water body like the irrigation return flow ditch that bisects the mine site north to south and the South Platte River along the east and north sides. The Groundwater Model confirms that any shadowing or mounding along the river will only affect the property owned by L.G. Everist and will not cross over the river. If during the course of mining or reclamation complaints from the well owner or adjacent property owners are received by the permittee, the permittee will commence an evaluation and investigation, including providing replacement water to the well owner if necessary, within 48 hours. The method used to mitigate groundwater mounding may include a ground water drain along the Abbett property to maintain ground water elevation to the average level measured prior to installation of the slurry wall liner. This drain may be in the form of a ditch or a buried perforated pipe as described in the GWM. DRMS shall be notified within two business days of the complaint and the proposed initial steps for the evaluation cf the complaint. A written report will be submit- ted to DRMS within 30 days detailing the information collected during the investigation of the complaint, and proposed mitiga- tion activity, if required. Post Reclamation Any slight groundwater mounding and shadowing associated with the slurry wall sealed portions of the pit are not antici- pated to produce any adverse impacts to adjacent properties. Potential groundwater mounding around the mine will be mitigated L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 31 Exhibit G Water Information (cont) by the South Platte River, road corridor and the single irriga- tion return flow ditches surrounding the lined area. These existing water features will serve to regulate and balance groundwater elevations in the alluvium adjacent to the sealed pits. The GWM suggests that once the groundwater reaches the maximum predicted levels it will stabilize and the corridors left through and around the liners will allow water to pass around the liners. The operator does not anticipate any long-term post -reclama- tion ground water depletions, but if there are any, they would be replaced through a Colorado Water Court approved Plan of Augmen- tation. L.G. Everist, Inc. expects that prior to competition of the reservoirs a local government agency will purchase the storage rights and may begin final construction on the reservoirs. As water storage reservoirs are completed, they will be turned over to the purchaser for further development to complete the final features needed for developed water storage reservoirs. L.G. Everist will submit Technical Revisions to the DRMS if the pur- chaser makes changes prior to L.G. Everist receiving final recla- mation approval and acreage releases from the Division. Water Quality The attached report prepared by Molen Associates explains the plan for collecting the necessary background water quality information of the permit area. Included is a list of the chemi- cals to be tested for and their frequency. This plan includes installing 6-7 additional monitoring wells around the mine and use 4 existing wells that lay outside the proposed slurry walls to collect the data needed for 5 quarters prior to mining and yearly testing as needed. Once the 5 quarter samples are col- lected and analyzed a Technical Revision may be filed to reduce the required monitoring list for the life of the mine. Discharge Permits Surface Water Management When necessary, ground water will be pumped and discharged from the West Farm Reservoirs mine under a CDPS Permit which the operator will obtain from the Colorado Department of Public Health and Environment, Water Quality Control Division (CDPHE- WQCD). This permit will remain active during the life of the mine. The discharge points may change as mining progresses and all necessary changes will be submitted to the WQCD for modifica- tions to the discharge points. Runoff from disturbed areas will be managed and controlled to protect against pollution, of either surface or groundwater through the implementation best management practices which in- L.G. EVERIST, INC. - WEST FARM RESERVOIRS 32 July 2023 Exhibit G Water Information (cont) clude sloping disturbed areas inward toward the site, vegetating berms and other disturbed areas, and other site -specific controls as needed. As per the State Engineers Office requirements all stormwater collected for treatment will be discharged within 72 hours after the storm event ends. Estimated Consumptive Water Use The annual consumptive uses of water for the West Farms Reservoirs mine are estimated to be: USES VOLUME Acre-feet 4% Moisture Loss in Materials (1.7 Million tons) 50.05 Dust Control 3.00 Water Surface Evaporation (10 ac) 23.80 Total Consumption (Augmented) 76.85 Substitute Water Supply Plan Ground water depletions associated with L.G. Everist's West Farm Reservoirs operation will be covered under a substitute water supply plan (SWSP) pursuant to C.R.S. 37-90-137, approved by the State Engineer's Office (SEO) for replacement of the ground water depletions due to mining. This plan will be updated and renewed every 2 years. The Applicant will maintain a SWSP throughout the life of the mine. After completion and reclamation of all lined reser- voirs there will be no long-term evaporative depletions. However, if any unlined open surface water areas created by mining remain at the end of reclamation, then a court approved augmentation plan will be applied for before reclamation is complete. 100 -Year Floodplain Portions of the West Farm Reservoirs mine are located within the 100 -year floodplain of the South Platte River. The applicant will obtain a Flood Hazard development Permit from the Town of Platteville if needed. The location of the 100 -year flood line shown on the affected lands was transferred from FIRM Panel 08123C1905E, effective 1/20/16 to all maps. L.G. EVERIST, INC. - WEST FARM RESERVOIRS 33 July 2023 TABLE G-1 WEST FARM RESERVOIRS - WATER WELLS WITHIN 200 FT CA) Receipt Permit Number Contact Name Section Q40 Q160 Latitude Longitude Permit Category Use(s) Completed Well Depth Perforated Casing Top Perforate d Casing Bottom Static Water Level Static Water Level Date WDID Associated Case Numbers 5E/4-5ec 10 -3N -67W None within 200 feet. 5W/4 -Sec 11 -3N -67W None within 200 feet. SE/4-Sec 11 -3N -67W None within 200 feet. NW/4-5ec 13 -3N -67W None within 200 feet. SW/4-Sec 13 -3N -67W 9063639 13 NW SW 40 2252 -104.848492 Monitoring Observation (greater then 600 ft) Monitoring/ Sampling 15 15 25 METRO WASTE WA TER RECLAMATION DISTRICT Sec 14 -3N -67W 19112 15331-R L.G. Everist. Inc (NORGREN FARMS) 14 SW NW 40.228169 -104.867362 General Purpose Irrigation 76 207463 W5677 89066 264638 METRO WASTEWATER RECLAMATION DISTRICT 14 SW NE 40.225342 -104.854051 Monitoring Observation Monitoring/ Sampling LO 10 20 256734 96398-A L.G. Everist. Inc (NORGREN FARMS) 14 NW SW 40.224885 -104.863161 Residential Domestic 41 21 41 353828 15335-R L.G.Everist, Inc (NORGREN FARMS) 14 NE SW 40.223387 -104.861225 General Purpose Irrigation 207469 W5677 0353828A 15337-R L .G EveristInc , (NORGREN FARMS) 14 SW SE 40.219348 -104.851678 General Purpose Irrigation 30 10 30 207471 W5677 366352 15332-R L G Everist, Inc (NORGREN FARMS) 14 SW SW 40.249732 -104.8635 General Purpose Irrigation 207466 W5677 0541454C 15333-R L.G.Everist, Inc (NORGREN FARMS) 14 SE SW 40.218136 -104.860603 General Purpose Irrigation 53 207467 W5677 9062188 15334-R L.G. Everist, Inc (NORGREN FARMS) 14 SE SW 40.2184 -104.857769 General Purpose Irrigation 207468 W5677 9062189 15336-R L G EveristInc , (NORGREN FARMS) 14 SW SE 40.220489 -104.856153 General Purpose Irrigation 35 207470 W5677 NE/4-Sec 15 -3N -67W None within 200 feet. 5E/4 -Sec 15 -3N -67W None within 200 feet. NE/4-5ec 22 -3N -67W None within 200 feet. NW/4 Sec 23 -3N -67W 9058770 304711- PALOMBO, Jeff (MAGNESS LAND HOLDINGS) 23 NW NW 40.217618 -104.866466 Residential Domestic, Stock 75 20 4/26/2017 9058772 91-GX PALOMBO, JEFF 23 NW NW 40.217753 -104.866008 Cieoexchange System Loop Finlds Geothermal 300 NE/4-5ec 23 -3N -67W None within 200 feet. NW/4-5ec 24 -3N -67W None within 200 feet. updated 8/23/2022 slo EXHIBIT G - TABLE 2 MONITORING WELL DATA MONITOR WELL NO. MW 1 MW 2 MW 03 MW 04 MW 05 MW 06 MW 07 NORTHING, FT 1,327,768.61 1,325,656.48 1,326,568.90 1,324,539.64 1,322,997.25 1,32.3,208.40 1,323,173.33 EASTING, FT 3,176,657.95 3,176,688.06 3,179,344.23 3,179,763.21 3,176,684.67 3,179,342.95 3,181,259.32 ELEVATION TAG), FT 4,799.803 4,801.272 4,779.160 4,782.169 4,804.36 4,802.13 4,791.08 CASING HEIC HT, FT 3.57 3.97 3.74 3.24 3.62 3.02 3.29 ELEVATION (TOC), FT 4,803.368 4,805.242 4,782.900 4,785.409 4,807.98 4,805.15 4,794.38 Adjusted (D08 -D05) 2019 7/10/2019 23.13 19.66 2.48 2.41 15.22 16.98 2.93 8/7/2019 23.37 18.03 3.20 1.75 14.12 16.85 4.36 9/10/2019 23.46 18.45 2.98 2.57 14.58 16.76 4.36 10/ 8!2019 23.92 19.16 3.01 2.63 15.40 16.87 4.35 11/ 7/2019 24.15 20.01 3.04 2.81 16.56 17.23 4.21 12/1C/2019 24.25 20.65 3.21 2.96 17.52 17.61 4.06 2020 1/13/2020 24.31 20.97 3.24 3.11 18.23 17.86 4.31 2/11/2020 24.31 21.16 3.76 3.16 18.30 17.91 4.26 3/17/2020 24.21 20.93 3.99 3.11 17.43 17.72 4.16 4/29/2020 24.15 20.83 3.76 3.18 17.68 17.78 4.91 5/29/2020 23.95 20.18 3.41 3.12 16.25 17.52 4.64 6/25/2020 23.85 19.68 3.14 2.81 16.01 17.24 4.07 7/20;2020 23.25 18.28 3.28 2.61 16.2.1 1 16.81 4.53 8/a ,'2020 23.60 17.41 3.45 4.56 12.89 16.65 4.81 9/30/ 2020 23.62 18.65 3.45 2.68 I 16.12 16.72 4.63 10/29/2020 23.64 19.52 3.24 2.76 14.39 16.89 4.60 11/_8/2020 23.88 20.05 3.25 2.87 16.73 17.34 4.05 121:8/2020 . 24.04 4 20.55 3.11 3.05 16.60 17.71 4.21 2021 1/11/2021 24.29 20.89 3.25 3.17 18.40 17.80 4.60 2/22/2021 24.92 21.38 4.05 3.36 19.07 17.97 5.27 3/9/2021 24.51 21.41 3.56 3.16 19.26 17.96 4.28 4/25/2021 24.31 21.22 3.74 3.21 18.53 17.77 4.52 5/25/2021 23.87 20.67 3.44 2.98 17.37 17.53 4.22 6/21/2021 23.83 20.22 3.17 2.57 16.67 17.26 3.89 7/1)/2021 23.20 17.39 3.24 2.64 13.43 16.76 4.47 8/S/2021 22.95 20.22 , 3.20 2.56 12.59 16.65 4.05 9/17/2021 22.89 17.48 3.49 2.73 13.61 16.69 4.63 10/12/2021 23.62 18.80 3.35 2.67 14.52 16.72 4.25 11/22,'2021 23.89 19.97 3.19 2.78 16.71 17.2.7 4.46 12/2/2021 23.95 20.17 3.14 2.90 17.05 17.39 4.12 2022 1/20/2022 24.99 21.15 4.08 3.42 18.43 17.87 5.26 2/9./022 24.66 21.34 3.54 3.14 18.86 17.80 4.40 2/2'/2022 24.72 21.19 3.50 3.27 18.65 17.86 4.88 3/4/2022 24.48 21.16 3.70 3.17 18.57 17.82 4.43 4/15/2022 24.76 21.37 3.98 3.36 18.42 17.93 5.33 5/17/2022 24.80 20.85 3.88 3.20 16.92 17.63 4.92 6/13/2022 24.03 20.11 3.20 2.75 16.67 17.17 4.00 7/26/2022 23.54 17.75 3.19 2.56 13.24 16.86 4.62 8/30/2022 23.23 17.53 3.03 2.52 12.25 16.72 4.23 9/30/2022 23.58 17.90 3.12 2.68 13.62 16.72 4.70 10/24/2022 23.74 19.04 3.21 2.87 14.46 17.04 4.61 11/22/2022 23.86 19.73 3.30 2.93 15.78 17.28 4.51 12/21/2022 23.98 20.43 3.35 3.01 17.18 17.50 4.36 207R 1/11/2023 24.24 20.63 3.50 3.11 17.88 17.68 4.61 2/1E/2023 24.48 21.03 3.65 3.26 18.63 17.86 4.91 3/8/2023 23.93 21.03 3.45 3.01 18.68 17.78 4.41 MEAN DEP-I- TO WATER MAX. DEPTH TO WATER 23.94 20.20 3.29 2.95 16.69 17.37 4.42 24.99 21.41 4.08 4.56 19.26 1 1.991 5.33 MIN. DEPTH TO WATER 22.89 17.39 2.48 1.75 12.25 113 6`, 2.93 NET CHANGE 2.10 4.02 1.60 2.81 7.01 1.32 2.40 average Depths terrace wells 19.55 FP wells 3.55 35 a, L.U. Everist Inc. WEST FARM RE5E1VOIR5 Map Exhibit C-1 - Water Wells Within 200 feet 434 6 •�' f6- s J-{1:01 MW—ta 1 (WL) 6 6 I 6. 6 d 6 s 6 6 2 c I 6 2 2 2 I 2 2 6 I 6 del f\6 D3 T NOTES r l 155331 R � MW -02 (WL) • D-96398 r*� jet—. MW -09 (WL) n. irice le - I , -4. e\lik 1 • MW-03(WL) WEST FARM 1324949 ft. N 3176625 ft. F♦ 7 1 MW -95 (WQM) MW -14 (WLJ a 804. is*8.10 2--2-2--.2-1=514L 91 GY I -15335R 4.4O I aNii1/4‘‘a,. 6-6 1. Data for wells shown on this map are listed on Table G-1 and is from the State Engineer records. 2. Well locations shown on the map are confirmed via ground check. 3. All wells except the Geothermal (GX) well are shallow wells. 4. Proposed new WQM well locations shown on map may change when installed. MW -10 (WQM) 6------6--6-6a6-6 WELL KEY \\\A) ie MWO4 (WL) • I -15336R MW -06 (WL) • r 4:,E -15334R 2-2-2 \\IA O .......%-b--_,-,......._ _ , it - LO)* o 71 Lt-, --..,.....A il 1 1 it ii 00 €), t S .a s 6-) 6a ', MW -26463€ %Ls _ uts:jun al - L t YY�,.�r 1; i i 4:: 2 11n 6 2)/3 6i1 i 1 i 6 t 2 6 A 2 i 1-15337R! el Wit Itiy, .‘6 MW -13 (WL) ' 'MW -07 (WQM) , sisakeN . { li --?- 2-2--2-2 "�► /6 6jr 6a6 6—.6--' I Verified Irrigation Well Domestic Wells Geothermal Well 6 ♦ ■ A Site Monitoring Well WQM Well WQM/POC Well • Third Party Monitoring Well 2— 200 FT. Offset 6 600 FT. Offset 36 4 EXHIBIT 0 Monitoring Well Graphs 4805 00 4800.00 4795.00 4790.00 4785.00 WATER (CONY) A 4780.00 o) r _ 4775.00 4770.00 4765.00 w A V V CO A V VCr' 65 A V V 01 A to A <3) to CO A A a V A V V N 9 wrnl 57 rn irril V V 91 10 N A V • V I v rn cn Co A V (n CD A to v A V V Q) w cp _ Ground elev. 4799.8' V V v A A A a ca A V V V V A A V rn V A �+ V V v 'v^ .) rn " '- -4 V 'T v V-14 9) V• V V, O WtL'O_�O- 6):.-44a Ncan 00 ♦ �- 4760.00 °1" °�9' °tip °tip °tia �°' �O ti0 ti° ti° ti° ti° oti° oti° o° or. oti° oti° °ti~ cy. ce. oti on> 61> O% ( I> 0A °ti�' °ti~ o~ o"1,' °� oti" o1, oti1 otiif oti1 otile oti1 otile oy^, °yti °�1 °tip ti� ti3 ock co,ti ti ti A V a -.- MW 1 Water Leve datal Ground Surface Average (4775.86) Max (+2) Min (-2) ti\�\ L\\°\ 1\N" L\~> b\�1\ A\1°)\ y1°)\ b\'Ly\ \1°\ g1°\ o\,°\ O\`�i\� 1\�\� L\1�\� \'tib\� 't\L1\� y\0i\� A\1(°\� y\tip\� �o\�~\y 1\~O\% \C o,\��\^, O\~�\�#1" \t%\ •\-1? 1.11 v\�O\1\O\1L\��\19 �\A\19 A\�O\1 \~1\~ ��\1 ' \� ') \~ '� \� L L L L v ti 1 ti L° '�\ �o O O A\ - 1\ �\ h\ 6\9 'Sr ti h• �\ �\ cb\ o\ °\ ti\ ti\ \ ti\ WEST FARM RESERVOIRS MW #1 EXHIBIT O Monitoring Well Graphs WATER (CONY) 4805.00 4800.00 4795.00 4790.00 4785.00 �V A V OD Ground lee 4801.27' crect,C0 • V 00 CO y��-�. N V e - CO CO V V V CO _. V --` • V V V �l COv1 N CO co �! V (,) W A fI1 N N W (n (� O C7 Ut L7 O O W O O (n p O A CO O O n a a OD coO O ,,, O N a A A A A V V -.4 A v A CO V CO CO A CO CO CO A Oo AV W C• O N V A ,s 'CO A rl ONO -3/44 A 'co Oo A a a • 0VD Uj co CO COVV A a a a V C▪ O A 00 a a A a p a COVN V N v a a - VJ I -4)V1 Gig_ iiZIL 4780.00 it a a at 4775.00 4770.00 4765.00 -f- MW2 Water Level data Ground Surface Average (4781.07) Max (+2) Min (-2) Na) Na) Nall Na) Na) .1O'' .1O /9 .1O „O ,1O .1O .LO 1O ,1O ,1O''. LO'` LO' 1N ,1'b �� 61 61, 1N tiN .1L ,Lti tiL ,10',. ,1O .11 1L n1 1L ,tiy n% .yti .yL n1 Lb 1L 1O'• .1O' 1O .1J ti� L'J •\\\\ tip 4 tip a\.` Itip ~o\�\tip �N\��tiO N�NOS N\N\tip �\NN\tip 4.CNItip a\its I \��\tip �\1h\ti��\�o\tide\�o\tip a\�p \Qttip\ NN\N4\ Ny\N�\ N\NA\tip \��\tip ^'\��ti� \evc3I y\tv(II 1>I °\ \�\�O \�1\tio No\N�\ N�\��y\ N�\�\.yO N\�O\.yO \�\,yO�\�\tiO 4)\ t-\% a\Nc'\,�9 h\IN\tiO \��\1O \�tiO' \�\y� \�tiO No\gyp\ NN\ti\ ��1N\ \NN\V N�\.yO \- 1\ 1\ FARM RESERVOIRS MW #2 EXHIBIT 0 Monitoring Well Graphs WATER (CONY) 4780.00 - 4779.00 4778.00 Ground lee 4779.16' a ti v rn 4777.00 4776.00 4775.00 - 4774.00 4773.00 4772.00 4771.00 a V 571 a v rn es 03 a v rn Cn a v v id a -4 a a v v a v V C11 C)D CO a V v C11 V a -4 v O) V cn " o v, re in cn a v cn a v v a v v a v v a V fd a w a v (71 (Y) a v C11 a V Cn a v v C11 a v a v v 9' a v v a v v 51) a v v O) a a V v 91 a (71 bo a 1 a Cr1 a C11 MW 3 water level data Ground surface" Average (4775.87) Max (+2) Min (-2) \y�\�ei°yc)\y°y� �`b\~°y� �1\�Oti\ti°co- \y3\�O� \yy\~°~ '��°~ �oi\�°� \af\~°~ \,Lh\�°\°� \\�°~ �O\�°%O\��\~° y\tip\~° tiy�\� y¢\�°~y ai 'y 'ti y '1 a h A? b y ti\ °tt ,\3\ti°�' \�(e �\ti°�'�\�y�ti° \1��ti°� �\ti°ti \�,�ct• o\F%r h a) • co\�\.1Q'1' \�O\,ti°'Lryelse �\,ti0'L~\��\,ti0'11\A\,L°'L~\y�\,ti0'L~\y1\,LOL~\y�\,LO'~\fib\,LO'~\�°\,LO'i \�°\,10'1'1\,�a\1° y ti a h d A WEST FARM RESERVOIRS MW #3 EXHIBIT 0 Monitoring Well Graphs WATER (CONY) 4783.00 4782.00 4781.00 a V V cn 4780.00 a`) 4779.00 !i77M.00 4777.00 4776.00 4775.00 a O3 O N Ground elev. 4782.17' a V v cn a) O a V V cn a a V V V) W rn a V V 9) a V V 0 a V v CO a V V 0 a v v 9) w rn a V V 9, CJ1 CO V V V A W O a V V (n N a v O3 a V V 0 a V V 9) a V V cn rn 0 a V v a) a V v a v V a v O Cn N v a v v a V V 0 a v v OD a V v a v V O3 a V V 0 v a a v V 0 a V V N a a a V -.4 V v a V v 03 a V V -so) MW4 Water level data ground surface Average (477S.22) Max (+2) Min (-2) 4774.00 - 01a1 01ai O.tiA 010 01A 010 01,0 O.LO 01,0 _ O.LO 01,0 01,0 01,0 10 O,yO 01,0 01,0 01,0 be O.ti1 O,ti1 O.y1 .L1 O,ti1 O,y1 01'1 O.y1 O.ti1 O.y1 O,L1 01ti 01''1' 01''1' 01ti 1ti .y'L O.L'L 1ti 1ti O1ti O1ti 1ti 1ti 01,3 1\,yO�~ ��'1�~ 010\~ 10\�\� 11��ti 'L�1ov 1�1�`~ 'L�11\~ 311\~ �\,ti@� h�~O`- �o�1h\� 1`.ti0� �,�0�� A\,5O� O`,tio�1 1\1��ti ti�1�\~ 11 0\~ ti��~\~ �\��ti b\,y(p� h�1y\� O\L1�1 1\,tio)�1 ��ti 011`~ O\,y1\1 y\,L1\1 1ti1\,tip�1 �\O�ti \,ti1\1 \A�ti 1 \ti 11`~ tip\~ ,\Q"1/4S1. LtpS1 �O�'L ,5O1 ,Lp�1 tip\~ ti ti 1 ti 1 0 1� nor b� WEST FARM RESERVOIRS MW #4 EXHIBIT O Monitoring Well Graphs WATER (CONY) .4010.00 4805.00 4800.00 4195.00 a 1! A A v A CO � CO (/� a V1 Nn V O° a i' CO v Du CD a a ac'D oa 4790.00 A7 ✓ r` a • -4--"r00 ...1V CY) OD 03 (Tca) V1 A 0) v p v C) C) C> • v a a • V v O O C) IS Q) W C) CO v ---4 Cn CT03 CO CO CO CO U cn (n ▪ 03 NP,,e,i\-) ca W � O 4785.00 4780.00 4775.00 \1°• .�O 0,10 ,�O �0 0,�° O1O O1° ,,1° O19 \.�.9\,1O 1°• Ois is' �� ,1� O11 1\O ��\� \�°\� \OVe ,,�V �ti\~° .s\N"''% N\\n a\� \tia\� \��\� \ti°\ \ti°\r \�'°\r °\~� ��\~� �ti\1 \gyp\~ ti\tip\� '�\�\� ,\ti6 y\tih\� O v A Ground lee 4804.36' a • v OD . CO co C) OD MW 5 Water level data Ground Surface Average (4787.67) Max (+2) Min (-2) eL1 Off~ 1� �O NCP - tie O ti ti 1 't 1 .'L 'L ti L L l O O' ^' ^' . �\�ti °\,�°ti `\A\�°�\�1\�°tip\DV' \,A\,�oh\�AV. e\�4 1\x(401- �°P. C\Voti �°\gyp\ti 1�\��\ti ��\� \ti \1�\,� n. tX149. \,‘°ti WEST FARM RESERVOIRS MW #5 EXHIBIT O Monitoring Well Graphs WATER (CONY) .;8u5 +;L' 4800.00 4795.00 4790.00 Ground lee 4802.13' .. 4s a A a a '4 a -4v a .s - a V a a 4 A CO CO~co COJv a A a p v O CO CO CO a a A A �! CO CO O CO �! - v CO v CO CO cn LP 01 cn OD N co a w 7.)1 ?wA .� -4v ! -4 O CJ1 01 00 O�0 r4 rl v vA v 00 01 CIi cep v v -s4 (P OU11aA00N • A �!pAQp v ODpA V Oco Aco 40 A N NA A Co • w v O A N C.) N C ▪ J Ut Cri Ccn A O 4785.00 "e'lit- N �4 N c1i N w O `l O� O _ ---v tir wz O CO �J 4s N O %ti` -a, -r - cn k.) w O -+ - v Cn 4780.00 4775.00 4770.00 MW 6 Water level data ground surface Average (4786.6S) Max (+2) Min (-2) 0~A o O'1°1 010 0�0 OHO o 0ti0 010 0 , 0 , 0, 01° O.LO O,LO 01.0 0 , 01.0 01.1 0 , 01. 0 , 0 , 011 01~ 01~ 01~ 0.• 01'1 0 , 01'b O'V 1'L 0111 ti 111 titi titi tit ICI' 11' 1`L 1Q- 11, 1, ,1'� ti°\~ \A\~ ti611 \�\� \1\~ ti01. ti�\� ti`\ti sACV tie\� ti�\ ,n41# ti°\� °\� ,„°\ti ti°'\ s4\�" ties\� s0\ti ,1S1 \o)S1 ti`°\ti 1`'\n` titi\� so)\ti \°'\~ ti�\ titi\ti titi\� \ti\� 199' \O)\i tit\� \°\n' ice '199 ti�\�° 1` P �o\1O 0Q9 tiQ\-O tit\~o ti�\ tiN\19 �\y0 \�\y0 1\ 0,\ \ ti, ,tti\ �\ 1\ �\ a\ (,\ O 1\ Or o,\ sO\ sN\ ,y1,\ ti\ 1\ n) a\ h\ Co\ 1\ 4 0,\ yp\ �ti\ titi ,\ L 1\ ') p,\ c,\ c,\ �\ o\ o,\ ,60\ ,1ti\ 1\ ti\ 1.\'s ^� WEST FARM RESERVOIRS MW #6 EXHIBIT O Monitoring Well Graphs WATER (CONY) 4792.00 4790.00 A 03 03 Ground lee 4791.08' a) 4788.00-N\ A v co 4786.00 4784.00 4782.00 4780.00 A CO Cn v A A V O (3) Co A v O a) V O A v CO 0) W A co a) A v CO Cn A v O A v O O N A v O rn Cri a) A v CO rn Cn A v CO rn A -I A O -4 rn A A CO O Co a) A C� A V rn th A v CO .CO) A v CO a) CJ) v A v O a) 'CO A -4 A A O ti a) O O pD Cr) O A a7 A W Cr) A v co Cn A My CO a) A -41 O a) A v CO v O Cn A O a) Co a) A V O a) W A v O C) O A v 03 *al O A v O a) CO A v O C1) A v CD Cr) en co CO Ccji v O MW 7 Water Level data Ground Surface Average (4786.67) Max (+2) —Min (-2) 0•� Oy°� °Nc) °1ci n9 19 Ois, °10 0 0 °19 19 19 °te 01 1 01,0 19 ^O 01.0 °10 0,1,0 09 es. 1\�°C1. %\,�\1 \�°� ti°\�\ ��1\1 �\*$ \ti'\\ ,��,,�� \.,�\1a\ti4 h��4 ��(IV 1\1O• r Cr °�ti°'v"��„ ��47\\ ��tip�� INti 1,1 Otiti O'11' 01.1 \\19 Qv() O1 01,' O'lti 01� Old O'1" 01� O'l1 ^O'l1 O1� O11 O1). O'11' 'l1 11 '11 11 '11.• 11' 1� '1� nts >�ti°\~ 41,7 4t- 1\~"\� \�\ti c5s\ o\�~\~ ti\ -t). sco.1 ,\t0�1 eve L\11\ r ��p\1 A\,�\1 \~�\,O\e,,,'''! �\��^° 4\�OO c,\,°\1° O\�p`L° ,\�,L\L° \��\'L° \\,11° \,�\1° fea „ ti „ 1 titi 1 'L WEST FARM RESERVOIRS MW #7 Protectiv Steel Casing Concrete Base • T-1TI U IJ I I-1 I I -TI r=lit m =El TIT I i III I=III I 1 111 IIIIIIIIIii=III =i i_ i III i i i 41• • • • • • • • Bentonite- Chips Silica Sand Backfill • • Slotted PVC Pipe 1JIIImLifIIiIiIIIIJIHftIHH NM 11 trill III II III II - nrni _ iu ui _ iii iu in in —u • •. . •.., ••v • • ••• a •.tsg :.•: :.. • • -• ••• • • .' f6 • •• .• • O. • .• •.•r, • • •,••• . • .w. .. •• •• •% t • ,•l • • •••.l ... A we* •• •:1 • •••.• *J• •• �• • • •. • •'• •; •••• M••`• • he •' • •N • • 5,• • e I .••• ••• •1/4. • .. ••. $4'.: • • • • 'f ••r 45. I' III. %• •%. • • • N• •• • V • 'a • •Ai. • 4. ••I' 2" PVC Pipe • Sand and Gravel Deposit • • • • • • • • • 4 • 4 • 4 • • • • .1' S. .• �• .♦ .5 .• 0. • , . ,,.. • •ti•• • //// //// j j /;;; SPAM m MID 3/fl SOLO ao FILL G. a a. a la lbasessaa a IPSO tap) w..-+ JUN 13, 2023 - ' 1:34:47 Typical Monitoring Well Installation Groundwater Monitoring Plan LGE - West Farm 10482 County Road 32.5 Platteville, CO July 7, 2023 Prepared for: L.G. Everist, Inc. 7321 E 88th' Avenue, Suite 200 Henderson, CO 80640 Prepared by: Molen & Associates, LLC 2090 E 104th Ave, Unit 101 Thornton, CO 80023 Groundwater Monitoring Plan TABLE OF CONTENTS 1.0 INTRODUCTION 2 2.0 MONITORING PLAN COMPONENTS 2 2.1 Monitoring Well Site Selection 3 2.2 Water Level Monitoring 3 2.3 Water Quality Monitoring 4 3.0 REPORTING 5 4.0 VERIFICATION RE -SAMPLING 5 List of Tables Table 1: Existing Monitoring Wells Survey Data (7-7-2023) Table 2: Existing and new Well Locations Rationale Table 3: Sampling Parameter List (7-7-2023) Table 4: Parameter Exclusion Rationale (7-7-2023) List of Figures Figure 1: Map Exhibit G-1 Water Wells Within 200 Feet Figure 2: Groundwater Elevation Contour Map Figure 3: Typical Monitoring Well Installation MA" «I►1 & ASSOCIATES LG Everist Monitoring Plan Page 1 of 5 Ii Groundwater Monitoring Plan 1.0 INTRODUCTION LG Everist, Inc is planning to mine aggregate resources from the West Farm property as outlined in the mining permit. The LG Everist, Inc West Farm site, hereinafter referred to as LGE-WF site, has applications for approval of the mining permit. In the LGE-WF site plans, detailed descriptions of the physical geography, geology and hydrogeology have been made. The purpose of this Groundwater Monitoring Plan (GWMP) is to assess the potential of the introduction of pollutants into the groundwater during mining activities and to describe the program to assess if and how water quality may change over time. The plan also provides information about the collection of water level measurements to show water level changes over time. A separate Groundwater Sampling Plan GSP) is prepared and describes groundwater sampling procedures, sample handling, and laboratory analysis. This GWMP will designate what data is collected and how it may be interpreted and may be modified as the mining activities progress and new information arises or changes. The GSP presents the sampling methods used to obtain the groundwater samples. Both the GWMP and the GSP will be followed for all groundwater monitoring done at the LGE- WF site. The Division of Reclamation, Mining and Safety (DRMS) calls for a GWMP for the LGE- WF site for the mining permit. Existing groundwater wells have been used to measure water levels over the past two years. The groundwater well locations, to be used for water level measurements and groundwater quality sampling, are shown on Figure 1, Map Exhibit G-1 — Water Wells Within 200 Feet and are shown on other maps in the mining permit plans. Survey data for the existing wells is in Table 1. Some of these wells on the LGE-WF site will be used to obtain baseline groundwater quality data for the LGE-WF site. Additional groundwater monitoring wells are also planned as shown in Figure 1 and described in Table 2. Groundwater monitoring wells are generally in locations that will not be mined or will not be mined in the near future. New wells or replacement wells will be placed in the general area of the existing well and be installed to monitor the same water bearing zone. 2.0 MONITORING PLAN COMPONENTS The current groundwater monitoring well locations are shown in Figure 1. The well monitoring network includes fourteen wells all completed in the uppermost aquifer. A few of the existing groundwater monitoring wells are in areas that will be mined. These wells will not be used for groundwater quality monitoring and will be removed and abandoned in the future. Monitoring wells are located in up -gradient and down -gradient LG Everist Monitoring Plan Page 2 of 5 Groundwater Monitoring Plan positions in the alluvium. Additional monitoring wells may be included in the future as necessary, or in response to regulatory concerns. Water quality monitoring sampling will begin within the next quarter following regulatory approval or consensus from DRMS. As proposed, the data collected will be used to develop a baseline of data for which future comparisons can be made. Once the baseline data collection is completed, then future water quality samples collected from points downgradient of the mining operations can be used to assess potential changes in water chemistry that might cause overall changes in water quality downstream. Baseline data will be collected from each monitoring well designated as a groundwater quality monitoring well. Some groundwater wells will only be used to collect water level information (piezometers). 2.1 Monitoring Well Site Selection The Rationale for monitoring well placement is presented in Table 1. Figure 2 presents a groundwater elevation contour map that was constructed from water level data obtained from the existing monitoring wells. The average (mean) groundwater level was used to construct the groundwater elevation contour map. The groundwater levels generally followed the topographic gradient, with water flowing generally from a west- southwest and south direction to a north and northeast direction. All of the wells are (or will be) completed with a 2 -inch diameter PVC casing and screen. Typically, the wells are constructed with screening across the entire water bearing zone, with solid piping to the surface completion. A sand pack of natural or washed sand is placed from the base of the well to one foot above the screened interval. A locked metal casing will cover the PVC casing from a concrete pad installed at the ground surface. The tops of the monitoring well will be encased in a lockable metal casing. Figure 3 presents a typical monitoring well installation and construction. Three new groundwater monitoring wells (MW -08, MW -11, MW -12) will be installed as the downgradient water quality sampling points. These three downgradient water monitoring wells are considered point of compliance (POC) wells. Other wells may be installed as needed. All wells are, and will be, permitted with the State Engineers Office (SEO) Division of Water Resources All wells are and will be constructed (and abandoned) according to the SEO standards. 2.2 Water Level Monitoring Water level measurements will be made in accordance with this monitoring evaluation plan. All monitoring wells will have water level measurements on a monthly basis. Exiting wells and future wells are constructed in accordance with the typical water I�-1 ,49,4" LG Everist Monitoring Plan Page 3 of 5 Groundwater Monitoring Plan monitoring well instillation diagram in Figure 2. Water level measurements collected in concert with water quality sampling will serve as quarterly water level measurements for the purposes of this monitoring evaluation plan. 2.3 Water Quality Monitoring L.G. Everest comrnits to obtain the water quality samples on a quarterly basis for five quarters prior to exposing water during mining. The water quality data will be used as a baseline, while subsequent water quality data, (obtained periodically) will be compared to the baseline data to assess water quality variations. Parameters with significant non - detects or are determined to be unrelated to mining and/or mining activities will be proposed for removal on a case -by -case variance. Sampling frequency after the five quarters of baseline data will be periodic and is assumed to be annually. The method proposed for the water quality assessments is discussed in the following section. Water quality monitoring wells and point of compliance wells will have water quality samples collected quarterly for the first five quarters and then on a regular basis (at least annually) using the Groundwater Sampling Plan. Table 3 lists all the parameters found in the DRMS June 9, 2023 Groundwater Monitoring Sampling and Analysis Plan Guidance — Appendix A with an asterisk on certain parameters. Several of the parameters are not relevant to the mining operations and it is requested that they be omitted. The Rationale for omitting the asterisked parameters is found in Table 4. Parameters for the initial five quarters of baseline sampling will be those on Table 3 that did not get approval for omission by DRMS. Collected samples will be preserved as recommended by the analytical laboratory and will be recorded on field data sheets and the laboratory chain of custody. Once baseline water quality data is obtained, a proposal will be submitted to reduce the number of wells and parameters to be quality monitored in the form of a DRMS Technical Revision (TR). Point of compliance wells will be utilized for the collection of water quality data for the life of the mine or until monitoring is released by DRMS. Monitoring wells in upgradient and downgradient positions from the specific phase of mining will be used to assess whether water quality degradation could be occurring. The first five quarters of samples collected from the water quality monitoring (WQM) and point of compliance (POC) wells will be analyzed for the parameters in Table 3, a list including parameters from the CDPHE Regulation 41 — Basic Standards for Groundwater. Groundwater samples collected after the first five quarters will be analyzed for a new list of parameters approved by DRMS in a TR. Parameters detected above the Table Value Standard on the Sampling Parameter List (Table 3), as revised or amended in the future, will be highlighted. LG Everist Monitoring Plan Page 4 of 5 Groundwater Monitoring Plan 3.0 REPORTING Groundwater monitoring data will be presented in a table including the sampling date, parameter results with graphs and/or plots for selected parameters, and a comparison to predictions and to the groundwater quality standards. The parameters that exceed the Table Value Standard on the Sampling Parameter List will be highlighted with bold or colored fonts in the report. The groundwater quality data report will include a narrative analysis of the data and identify trends and anomalies. It is proposed that control charts, generated on a quarterly basis (for the baseline period, then annually after that), be provided to the Division on an annual basis to demonstrate changes in water quality with time. If exceedances of the control charts are noted after regular annual sampling, a specific response plan will be prepared by LGE to address that issue. The specific response plan would be based on an evaluation of the number of selected parameters that show exceedances and the duration of these exceedances. 4.0 VERIFICATION RE -SAMPLING Under certain circumstances a verification re -sampling may be collected, and samples submitted for analysis using the Groundwater Sampling Plan. The samples will be collected within four weeks of the analytical report date. A verification sample may be collected during the following sampling event depending on the frequency of sampling. Verification re -samples are designed to provide confirmation of the sample analytical data for sample result anomalies or statistical analysis. MOLEAI & SSOCATESN LG Everist Monitoring Plan Page 5 of 5 Map Exhibit G-1 - Water Wells Within 200 feet 1. Data for wells shown on this map are listed on Table G-1 and is from the State Engineer records. Figure 2 CO RD 34 I LEGEND 4784:00- 4779.30 CO RD S2 S Monitoring Well Location Groundwater Elevation Contour (feet amsl) Groundwater Elevation (feet amsl) Groundwater Flow Direction 600 1200 SCALE IN FEET Platteville LG EVEREST WEST FARM Groundwater Elevation Contour Map 10/24/2022 4/18/2023 Figure 1 MOLEN & ASSOCIATES, LLC Figure 3 Protective Steel Casing Concrete Base 1:=.111=111=11-1E111=III-11 I Tr=i i=fii T-iii-r-i i =IIIIll HI Hi HI n • I Bcntonitc- Chips 1 Silica Sand Backfill Slotted PVC Pipe • • •. •. • • • . a. •1 • • . 1 i • 11 i i i i ittIli itIltIliiiIII 2" PVC Pipe Sand and Gravel Deposit 11ffl1HI IH11HI111HI_ 1=1 11=1 11=1 11111111 I Ili illl1117-- i illl ii • • .1 • j j j///i j%>// j / 7/ // /////;///;/< DRAWN m Ian DATED 9/RIt/ CAB rn.n LO��+� � 7rt a. sea Ss. Olt S Meese (in) S -S41 JUN 13, 2023 - 11:34:47 Typical Monitoring Well Installation Groundwater Quality Monitoring Plan Table 1: Existing Monitoring Wells Survey Data (7-7-2023) MONITOR WELL NO. NORTHING, FT EASTING, FT ELEVATION (TOG), FT CASING HEIGHT, FT ELEVATION (TOC), FT MW 1 1327768.606 3176657.946 4,799.803 3.57 4,803.368 MW 2 1325656.483 3176688.055 4,801.272 3.97 4,805.242 MW 3 1326568.902 3179344.23 4,779.160 3.74 4,782.900 MW 4 1324539.638 3179763.207 4,782.169 3.24 4,785.409 MW 5 1322997.254 3176684.665 4,804.36 3.62 4,807.98 MW 6 1323208.398 3179342.954 4,802.13 3.02 4,805.15 MW 7 1323173.328 3181259.315 4,791.08 3.29 4,794.38 MOLEN & AssoaATN LG Everist Monitoring Plan 6. Groundwater Quality Monitoring Plan Table 2: Existing and New Well Locations WELL NAME LOCATION GRADIENT TYPE RATIONALE MW -01 NW PHASE 3 DOWN WL Existing — NW corner of Phase 3 MW 02 SW PHASE 3 CEN ALL CROSS/UP WL Existing — SW corner of Phase 3 and west central of all mining, north of Phase 4 MW -03 NE COR PHASE 2 ALL DOWN WL Existing central east and north MW -04 MID N CEN PHASE 1 MID WL Existing central east and south MW -05 SW COR PHASE 4 UP WQM Existing SW corner of Phase 4 MW -06 S MID BDRY PHASE 1 UP WL Southern boundary central MW -07 SE COR PHASE 1 UP WQM Existing eastern boundary MW -08 NE COR PHASE 2 ALL DOWN WQM/POC New well northeast boundary of Phase 2 and all Phases, down gradient MW -09 MID N CEN PHASE 1 MID WL New well north boundary of Phase 1, south of Phase 2 and central for all Phases MW -10 S MID BDRY PHASE 1 UP WQM New well southern boundary central MW -11 NW PHASE 2 N ALL DOWN WQM/POC New for NW of Phase 2 and NE of Phase 3 MW -12 SE PHASE 2 E CEN ALL DOWN WQM/POC New for SE of Phase 2 and east central all Phases MW -13 SE PHASE 4/S CEN ALL UP WL New for SE of Phase 4 and S for all Phases MW -14 SE PHASE 1 SE ALL UP WL New for SE side DOWN = downgradient NW = northwest SE = southeast POC = point of compliance r�-1 MOLEI" & ASSOCATES UP = upgradient SW = southwest COR = corner BDRY = boundary CROSS = cross gradient NE = northeast WL = water level piezometer ALL = services all phases WQM = water quality monitoring LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Table 3: Sampling Parameter List (7-7-2023) Analyte Table Value Standard (mg/L unless other units given) Reg. 41 Table Reference (1-4) pH Field (pH unit) 6.50 - 8.50 2 and 3 Coliforms Total (30 day average)* 2.2 org/100 ml 1 Asbestos* 70000 fibers/L 1 Chlorophenol* 0.0002 2 Color* 15 color units 2 Corrosivity* noncorrosive 2 Foaming Agents* 0.5 2 Odor* 3 threshold numbers 2 Phenol* 0.3 2 Free Cyanide* 0.2 1 TDS 400 mg/L or 1.25X background 4 Aluminum - Dissolved 5 3 Antimony - Dissolved 0.006 1 Arsenic - Dissolved 0.01 1 Barium - Dissolved 2 1 Beryllium - Dissolved 0.004 1 Boron - Dissolved 0.75 3 Cadmium - Dissolved 0.005 1 Chloride - Dissolved 250 2 Chromium - Dissolved 0.1 land 3 Cobalt - Dissolved 0.05 3 Copper - Dissolved 0.2 3 Fluoride - Dissolved 2 3 Iron - Dissolved 0.3 2 Lead - Dissolved 0.05 1 Lithium — Dissolved* 2.5 3 Manganese - Dissolved 0.05 2 Mercury - Dissolved 0.002 1 Molybdenum - Dissolved 0.21 1 Nickel - Dissolved 0.1 1 Nitrate (NO3) 10 1 Nitrite (NO2) 1 1 Nitrite + Nitrate as Nitrogen 10 1 Selenium - Dissolved 0.02 3 Silver - Dissolved 0.05 1 Sulfate - Dissolved 250 2 Thallium - Dissolved 0.002 1 Uranium - Dissolved 0.0168 to 0.03 1 Vanadium - Dissolved 0.1 3 Zinc - Dissolved 2 3 Beta and Photon emitters* 4 mrem/yr 1 Gross Alpha* 15 pCi/L 1 * Parameters to be omitted from sampling requirements based upon the Parameter Exclusion Rational discussed in Table 4. LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Table 4: Parameter Exclusion Rationale (7-7-2023) Analyte Exclusion Rational coliforms Total (30 -day average) Human and animal waste contain fecal coliforms. Bacterial coliforms are naturally found in the environment. Ingestion of coliforms is dangerous and can cause serious illness or death. It is expected that coliforms may be present in groundwater throughout Colorado and the sources are associated with excrement from animals in the natural environment. There are no coliforms being generated from mining activities at the LGE-West Farm site and as such, coliforms should be excluded from the monitoring parameter list. Asbestos Asbestos is a mined mineral with special characteristics of strength, filtration, and fire resistance. Asbestos was widely used in products in the first part of the 20th century. Later it was found to be a lung carcinogen and is now known to be an ingestion hazard as well. Asbestos uses are limited, and it is generally omitted from products where it was once found. Asbestos abatement from schools and private structures has been ongoing since the mid -1980s. Asbestos from abatement products is strictly regulated and documented disposal is required. Asbestos fibers in soils are regulated by CDPHE, and when found, are required to be removed and disposed of properly. Asbestos is not associated with the geology of the LGE West Farm site and should not be in natural formations at the site. It is regulated because it is a known carcinogen and water containing asbestos should not be consumed. The groundwater at LGE-WF site should not contain asbestos. There are no asbestos mines in Colorado. Water at the LGE West Farm site is not used for drinking water. There is no reason to expect asbestos in the groundwater and it should be an excluded parameter for the LGE-West Farm site. Free Cyanide Free cyanides are the cyanide containing compounds that can liberate cyanide gas in a neutral or slightly acidic environment. Hydrogen cyanide is the most common free cyanide. Sodium cyanide and potassium cyanide are readily soluble in water and, like hydrogen cyanide, produce cyanide gas in slightly acidic water. Cyanide gas and free cyanide in water are extremely poisonous. However, cyanides have to be introduced from a source, a pollutant in the water. Cyanides are not used, produced, or found in any mining activities at a sand and gravel mine. Cyanides may be associated with precious metal mining during heap leaching or related activities, but they are not at a sand and gravel mine. There are no manufacturing facilities around the LGE West Farm site. For these reasons, free cyanides should be excluded from the groundwater monitoring parameter list. Chlorophenol and Phenols Chlorophenol is a group of organic compounds that are synthesized and not generally found in nature except as pollutants from a specific source. Chiorophenols are only slightly soluble in water. The most commonly identified chlorophenols are: • Monochlorophenol - used in modest volumes, as dyestuff intermediates and in the manufacturing of higher chlorinated phenols • Dichlorophenol - used in larger volumes in the manufacture of the herbicide 2,4-D and other related chlorinated herbicides WAINASSOCIATES LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Trichlorophenol - used in the manufacture of herbicides, primarily 2,4,5-TP (Silvex) which has been banned in the United States for decades. Tetrachlorophenol - used as a preservative. Pentachlorophenol (PCP) - used as an antimicrobial wood preservative and historically coating on utility poles and cross arms. PCP is often mixed with creosote or other wood coating products. The US EPA is phasing out the uses of PCP over five years beginning in 2022. Wood treatment facilities will be allowed to use their existing stocks of PCP for wood treatment until 2027. Due to the high toxicity of PCP, it is normally used for toxicity calculations for chlorophenols. Phenol is similar to chlorophenol and is an important industrial chemical used as a precursor to many different materials and useful compounds. Phenol is readily soluble in water and sources of it in groundwater would be limited to industrial facilities. In general, chlorophenols and phenol are considered a problem in drinking water systems because they have a strong pungent odor in very small concentrations. The odor makes the water undesirable to drink regardless of the risk factors associated with toxicity. Chlorophenol and Phenols (cont.) As stated in Reg 41— Basic Standards for Groundwater (page 56) "The organic chemicals chlorophenol and phenol were moved from Table 1 (Human Health Standards) to Table 2 (Secondary Drinking Water Standards), and the proposed standards were set equal to the Ambient Water Quality Criteria for the chemicals. The reason for the change is that although the two chemicals pose a significant health risk at much higher concentrations, taste and odor considerations are a concern at lower concentrations." Chlorophenols and phenols are not associated with sand and gravel mining and may only be a concern if the mining site were adjacent to a wood treatment facility. Broderick Wood Products (BWP) Superfund site in Denver and is adjacent to the Koppers Wood Treatment facility. Both sites have been studied extensively and groundwater contamination was identified off -site and in the neighborhood. Molen & Associates has collected groundwater monitoring samples at the BWP site. Reports generated for the EPA demonstrate that the PCP concentrations are below the detection limits in many of the on -site and off -site wells. The reported concentrations indicate that even at a facility where PCP was used, the concentrations in groundwater are too low to be detected by standard analytical equipment with a detection limit of 1 microgram/liter. Reg 41 — Basic Standards for Groundwater generally considers chlorophenols and phenols as a pollutant of concern due to the odors and taste in drinking water, and if PCP or phenols are in detectable concentrations, a toxicity hazard. The LGE West Farm site is not near a wood treatment facility or any manufacturing facility and chlorophenols and phenols should not be in the groundwater. Mining activities will not introduce any chlorophenols or phenols into the environment. For these reasons chlorophenols and phenol should be excluded from the parameter monitoring list. LG Everist Monitoring Plan ASSOCIA7E5 Groundwater Quality Monitoring Plan Color The color and appearance of water is an aesthetic property that makes drinking water desirable. The color of groundwater is generally related to the turbidity of the water from natural sediments found in the well. Mining activities at the LGE West Farm site will not change or add to the color of the groundwater. The groundwater is not used as drinking water at the LGE-West Farm site and color should be excluded from the parameter monitoring list. Corrosivity Corrosivity is associated with a low pH (i.e.acidic) water. Natural water at the LGE West Farm site, like all waters along the South Platte River basin, are neutral with pH values within groundwater standard limits (pH 6.5-8.5). Corrosive conditions are not found at the LGE West Farm site and mining activities will not create corrosive conditions at the site. As such, corrosivity should be excluded from the monitoring parameter list. Foaming Agents Foams and foaming agents are generally listed in Reg 41 due to the appearance of the water for drinking purposes. Different types of foams occur naturally in lakes and streams where water is churned up from wind or water flowing over riprap structures. The most common foaming agents are detergents and simple soaps. Foaming agents typically come from industrial processes or consumer wastewater and are generally not expected to be associated with sand and gravel operations. LGE will commit to not using detergent, soaps, or other foaming agents at the LGE-WF site. Analysis for foaming agents should be excluded from the LGE-West Farm site. Odor Odor is an aesthetic property of drinking water and is difficult to quantify the substance creating the odor. Measuring odor in samples is subjective to the analyst. Mining at the LGE West Farm site will not introduce odors to the groundwater and odor testing should be excluded from the monitoring parameter list. Lithium - Dissolved Lithium is an alkali metal with very limited abundance in the earth's crust, estimated to be about 20 ppm (mg/L). The US Governmental report, Lithium Resources in North America, Geological Survey Bulletin 1027-5 (found at https://pubs.usgs.gov/bul/10278/report.pdf) indicates that the abundance of lithium in Colorado is generally limited to the Gunnison area. The United States Geological Service (USGS) published a report with the mean concentrations of lithium in specific locations in Colorado. Comparing all the lat/long information in the USGS report file (file title - Lithium_Statistics.cvs), there is no lithium identified near the LGE West Farm site. The report and statistics file are found at https://www.sciencebase.gov/catalog/item/5ed8f70f82ce7e579c6739c1 . It should be safe to assume that lithium would not be found naturally occurring in the groundwater near the LGE West Farm site. Mining activities at LGE West Farm do not involve any lithium -based materials that would impact groundwater. The only materials that contain lithium are standard AA or AAA batteries that are managed and recycled off -site. For these reasons, we think lithium should be excluded from the groundwater monitoring parameter list. Gross Alpha/Beta Gross alpha and gross beta particle emitting constituents present health hazards in drinking water. Quantification of gross alpha and gross beta includes wide uncertainties with reported values from well samples varying widely. There are no sources of gross alpha or gross beta particle emitting constituents during the mining activity at the LGE West Farm site and the parameters should be excluded from the monitoring list. ,�-, M OLEN LG Everist Monitoring Plan Groundwater Sampling Plan LGE - West Farm 10482 County Road 32.5 Platteville, CO July 7, 2023 Prepared for: L.G. Everist, Inc. 7321 E 88th Avenue, Suite 200 Henderson, CO 80640 Prepared by: Molen & Associates, LLC 2090 E 104th Ave, Unit 101 Thornton, CO 80023 TABLE OF CONTENTS 1.0 PURPOSE 2 2.0 APPLICABILITY 2 3.0 RESPONSIBILITIES 2 3.1 Sampling Personnel 2 3.2 Task Manager 2 3.3 Project Manager 2 4.0 GROUNDWATER SAMPLING PROCEDURES 3 4.1 Preparation for Sampling 3 4.2 Field Work Prior to Sampling 3 4.3 Sample Collection 4 4.3.1 Decontamination 4 4.3.2 Sampling Equipment and Materials 5 4.3.3 Purging 5 4.3.4 Withdrawal of Sample 6 4.4 Sample Preservation, Handling, and Shipment 7 4.5 Chain -of -Custody of Samples 8 4.6 Quality Assurance and Quality Control 8 5.0 Analytical Procedures 9 6.0 Analytical Data Review 9 7.0 Verification Re -sampling 10 Appendices Appendix A — Sampling Field Data Sheet Appendix B — Sampling Parameter List Groundwater Quality Sampling Plan 1.0 PURPOSE This technical procedure for groundwater sampling establishes a standard methodology for collecting groundwater samples for laboratory analysis which are representative of aquifer water quality. Data collected during the sampling process will be recorded on field sampling forms, copies of which will be submitted with sample data reports. 2.0 APPLICABILITY This technical procedure is applicable to field personnel engaged in the collection of groundwater samples from wells for the purposes of laboratory analysis. This document should be read in conjunction with all regulatory, work plan, orders, client -specific requirements, and other project -specific guidelines. 3.0 RESPONSIBILITIES 3.1 Sampling Personnel Sampling Personnel are responsible for sample collection, sample custody in the field, sample preservation, total and accurate completion of field and data sheets, field parameter measurements, sample delivery, and data delivery to the Project Manager, as described in this technical procedure. 3.2 Task Manager The Task Manager is responsible for supervising Sampling Personnel. Supervision includes ensuring that samples are collected, documented, preserved, field analyzed, handled and shipped or delivered to the appropriate laboratory as specified in project work documents and this technical procedure. 3.3 Project Manager The Project Manager is responsible for overall management of the project, sampling program design and implementation and providing any required clarifications in the use of this procedure. In most cases, the Project Manager will also fill the role of Task Manager. VjMOLEN ASSOgATE5 LG Everist Sampling Plan Page 2 of 10 Groundwater Quality Sampling Plan 4.0 GROUNDWATER SAMPLING PROCEDURES 4.1 Preparation for Sampling Following the determination of a sampling event date, sample bottles will be ordered from the contracted analytical laboratory. Sampling personnel will coordinate with the contracted lab so that sample bottles can be ordered in sufficient time for shipping, bottle inspection, and corrections. If any changes have been made to the site analyte list, the laboratory should be informed prior to bottle shipment. Sufficient sample bottles for each parameter group (total metals, anions, etc.) for each well will be verified upon receipt. Additional bottles for Quality Assurance/Quality Control (QAQC) samples (duplicates, trip blanks, field blanks, and/or equipment blanks) will also be arranged, as necessary, with the laboratory prior to shipment. The laboratory will also provide sample labels, chain -of -custody (COC) forms, and COC seals with delivery of the sample bottles. 4.2 Field Work Prior to Sampling Sampling personnel will inspect each well prior to sampling. The condition of the well casing, concrete pad, reference mark for water level measurements, protective steel casing, well identification markings, and security lock will be recorded. Additionally, the following will be recorded on a sampling data sheet (Appendix A) for each monitor well: Observations made during visual inspection. • Static water level of well measured with electronic signal on measuring tape. • Total depth of the well measured or recorded from previous events. • Date and time of well measurements and well sampling • Purge water volumes calculated or rate of purging, if needed. Observation of sample odor, presence of immiscible layers, and relative turbidity Prior to purging and groundwater sampling of any well, the static water level will be measured in the monitor well. The water levels for all the groundwater monitoring network wells will be measured on the same day or within a 36 -hour period of time. In addition to the water levels, total depth will be measured annually in all wells in the monitoring network. Water level and total depth measurements will be made to the nearest 0.01 foot from a dedicated reference mark on the riser pipe using a portable electric water level indicator and will be re -measured for consistency. Depths to water will be compared in the field to previous measurements to minimize the possibility of recording incorrect readings. 1MOLEN & ASSOC► LG Everist Sampling Plan Page 3 of 10 Groundwater Quality Sampling Plan To avoid potential cross -contamination, the water level probe and tape will be washed before the initial use and between well locations using an AlconoxTM/water solution followed by a rinse with distilled water, or use of a disposable alcohol water swab. A pair of new disposable gloves (nitrile or latex) will be worn while performing groundwater level measurements. If the total depth measurement indicates that 25% or more of the effective screen length of a well has become filled in with sediment, the well will be re -developed. Re- development will consist of purging a minimum of five casing volumes from the well, or purging the well dry twice if the yield is insufficient for continuous purging. In wells with sufficient yield, purging will continue until the sediment is removed and field parameters (pH, temperature, and conductivity) stabilize. Parameters are considered stabilized when there is less than a ±10 percent change in three consecutive measurements of temperature and conductivity, and pH readings are within ±0.2 standard units. For wells that purge dry, field parameters will be measured at the start and end of both purging cycles, if possible. The volume of water standing in each well will be calculated using the static water level measurement, the total depth of the well, and the casing diameter. One casing volume will be considered the water present in the well casing. Well depths for the purpose of well volume determination will be obtained from well completion records. The equation for calculation of one casing volume is: V = [TT x (r casing)2 x h] x 7.48 V= 0.16 xh for a 2 inch well where: V= r casing = h= volume of water in well casing [gallons] radius of well casing [feet] height of water column (total well depth - depth to water) [feet] 4.3 Sample Collection 4.3.1 Decontamination All re -useable, non -dedicated sampling equipment will be decontaminated between each well location to provide representative samples. Decontamination will be performed by washing all equipment with an AlconoxT./water solution followed by a rinse with distilled water. Water generated from decontamination procedures will be disposed of at least 20 feet from the well site. All clean or unused sampling equipment will be handled by personnel wearing new disposable gloves (e.g., nitrile or latex). After the re -useable sampling equipment has been decontaminated it will be wrapped in new clean plastic sheeting or placed in new clean plastic bags. The sampling equipment will remain in plastic sheeting or bags until it is used again at the next sampling event. O ML & A55OCIATESEN LG Everist Sampling Plan Page 4 of 10 Groundwater Quality Sampling Plan 4.3.2 Sampling Equipment and Materials Purging and sampling equipment will consist of bailers and/or pumps. The bailers may be disposable or dedicated, and the pumps either dedicated or re -useable, to be decontaminated prior to each sample location, or dedicated. This equipment will be constructed of materials that will not alter the quality of the groundwater samples. Other sampling equipment may include the following: Water level indicator; Combination water quality meter for measuring pH, temperature, and conductivity; • Water quality meter calibration solutions; • Disposable gloves (nitrile, latex, or other appropriate material); • Distilled or deionized water; • Phosphate -free environmental detergent such as AlconoxTM; • Spray bottles for decontamination solution wash and rinse; • Peristaltic pump with associated tubing; • Battery or power for peristaltic pump; • 0.45 -micron filter(s) if field -filtering is necessary; • Plastic sheeting to prevent possible contamination of sampling equipment; • ZiplocTM freezer bags for sample storage and shipping; • Paper towels; • 5 -gallon plastic buckets for decontamination and purge volume measurement; Sample bottles and sample preservatives; Field forms including groundwater sampling data sheets, COC forms, and sample labels; Coolers and ice. All of the groundwater purging and sampling equipment will be maintained in a clean and working condition. Sampling personnel will wear new disposable gloves while handling the sampling equipment that will be in contact with water samples. 4.3.3 Purging Prior to sample collection, each well will be purged of stagnant water using disposable or dedicated sampling equipment such as bailers and rope. Bailing will be performed at a rate that will minimize agitation of recovery waters and will continue until a minimum of three casing volumes have been purged and field parameters (pH, temperature, and conductivity) have stabilized, or the well is bailed dry. IF \ MOLEN St ASSOCIATES LG Everist Sampling Plan Page 5of10 Groundwater Quality Sampling Plan Field parameters will be measured at a frequency no greater than once per casing volume and purging will continue until there is less than ±10 percent change in three consecutive measurements of temperature and conductivity, and pH readings are within ±0.2 standard units. If a well is bailed dry before removing three casing volumes, sample collection will begin when a sufficient amount of groundwater has entered the well. In this situation, field parameters will be measured at the start of sample collection and again after sample collection is complete, if possible. The collection of these groundwater samples must be within 24 hours of purging. All field parameter measurements will be recorded on a field data sheet along with a description of the sample appearance at the time of field parameter measurement. The water quality meter used to measure field parameters will be calibrated according to manufacturer's recommendations prior to purging. Purge water generated during sampling events will be discharged on the ground, at least 20 feet from the well site, unless previous analyses have indicated that groundwater contamination has occurred at that well location. If previous analytical results indicate that groundwater contamination has occurred, purge water may need to be containerized and disposed of in accordance with state and federal regulations. 4.3.4 Withdrawal of Sample After purging is completed, sampling personnel will re -glove with new disposable gloves in preparation for sample collection. Sample containers will be filled based on parameter sensitivity to volatilization and pH change as follows: • Other organics (SOCs) • Dissolved Metals • Anions/Cations • Other inorganics and miscellaneous analytes Monitor wells will be sampled for analysis of the Regulation No. 41- The Basic Standards for Ground Water 5 CCR 1002-41, Colorado Department of Public Health and Environment Water Quality Control Division. The table with parameters from the Reg 41 Standards is provided in Appendix B and is also found in the Groundwater Monitoring Plan. Some low yield wells may produce insufficient volume to fill all of the sample containers within 24 hours of purging. Sample containers for these wells will be filled in the order listed above until the sample volume is depleted. Filled bottles will be submitted to the laboratory for limited analysis. MOLENT & A550CIAES LG Everist Sampling Plan Page 6 of 10 Groundwater Quality Sampling Plan After consulting with the analytical laboratory, sample bottles, preservatives, and coolers will be ordered and used. Samples will be collected in containers of appropriate capacity. The sample containers, preservatives, and coolers will be provided by the analytical laboratory. Every effort will be made to reduce contact between the bottles and sampling equipment. As an added precaution, contact time of the sample with ambient air will be minimized by replacing caps immediately after the bottles are filled. If VOC samples are collected, it will be done without air bubbles. This will be achieved by adding sample slowly until a convex meniscus form at the top of the vial (i.e., the vial is slightly overfilled) before replacing the cap. Once the cap is firmly attached, the vial will be inverted and examined for air bubbles. Metal samples will be field filtered when possible, utilizing a peristaltic pump and 0.45 -micron filters. Sometimes field filtering will not be possible, and samples will be submitted for laboratory for filtering prior to analysis. Following completion of groundwater sampling at each monitor well, all re- usable, non -dedicated sample equipment will be decontaminated in accordance with the procedures specified above in Section 4.3.1. 4.4 Sample Preservation, Handling, and Shipment Groundwater samples will be preserved as recommended by the analytical laboratory in accordance with the analytical method. Preservation methods will be documented on the field forms and on the sample chain of custody. Preservatives will either be included with the sample containers in small vials or will be pre -added to the sample containers by the laboratory. If the preservatives need to be added to the sample containers, sampling personnel will place the specified volume of preservative to the container during the sampling. Sample filtration may need to be performed in the field or in the analytical laboratory. After sample collection, filled and capped containers will be wiped clean, appropriately labeled, and stored with ice or frozen icepacks in insulated coolers. Sufficient ice or icepacks will be added to the coolers to maintain sample temperatures at or below 4°C. Packing material will be added to the coolers as necessary to prevent breakage of glass containers when they are shipped. rjT�, MOLEN & ASSOCIATES LG Everist Sampling Plan Page 7 of 10 Groundwater Quality Sampling Plan At the end of each day of sampling, collected samples will be delivered or shipped to the analytical laboratory. A completed and signed COC form will accompany all samples contained within the cooler. The COC will be kept preventing moisture damage and may need to be sealed inside a gallon -size ZiplocT. bag and placed in the cooler for shipment. If the sample cooler is shipped for overnight delivery, the cooler will be sealed with shipping tape and a signed COC seal, provided by the laboratory, will be affixed to the outside of the cooler. Sampling schedules and deliveries or shipments to the laboratory will be coordinated such that every attempt will be made to meet the recommended holding times of the analyses. Laboratory analyses performed outside the recommended holding times will be flagged or qualified appropriately in the report of analyses provided by the laboratory. 4.5 Chain -of -Custody of Samples EPA -accepted chain -of -custody (COC) procedures will be followed to maintain the validity of the groundwater samples being delivered to the laboratory. From the time the empty sample containers leave the laboratory until the issuing of the laboratory results, the samples and/or sample containers will be: 1) in sight of the assigned custodian, or 2) locked in a tamper proof location, or 3) sealed with a tamper proof seal. A written record of sample container possession and transference of samples will be documented on appropriate COC forms. The forms will also be used as a mechanism of communication between the sampling personnel and the analytical laboratory to note any specific details or requirements regarding the requested laboratory analysis. At the completion of the sampling event, a copy of the completed COC form, signed by all the appropriate entities handling the samples, will be retained with the laboratory report. 4.6 Quality Assurance and Quality Control Quality assurance (QA) and quality control (QC) procedures will be followed so that laboratory preparation, field sampling, and transport activities do not bias the results of the chemical analysis. QA/QC samples are collected to provide a quantitative basis for evaluating the analytical results. Typical QA/QC samples collected for groundwater sampling programs may include one or more of the following: Duplicate Sample - Duplicate samples are collected by the sampling personnel in a manner identical to the primary sample. The duplicate sample will be analyzed by the laboratory just as the primary sample is analyzed. The duplicate is intended to verify that the results from the primary sample are accurate and reproducible. 10 MARS LG Everist Sampling Plan Page 8 of 10 Groundwater Quality Sampling Plan Field Blank - A field blank consists of empty sample bottles filled with distilled or deionized water at the sample site by sampling personnel. The field blank will also be analyzed by the laboratory as if it was a "real" sample. Equipment Blank - A variation of the field blank is the equipment blank. Equipment blanks are prepared in a manner identical to field blanks, except that distilled or deionized water is poured through clean (field decontaminated) sampling equipment and into the sample bottle. Equipment blank samples are analyzed for all analyses and are used to verify that sampling equipment is uncontaminated. The equipment blank samples are only needed with the use of "non -dedicated" sampling equipment. The QA/QC samples will be used to verify lab results if there is a reason to believe additional QA/QC is needed. 5.0 Analytical Procedures Samples will be analyzed using the appropriate EPA analytical method as described in the Regulation 41 — Basic Standards for Groundwater or other appropriate EPA methods with laboratory certifications and approvals. Reporting limits (RLs) for the parameters analyzed will be the lowest concentrations that can be reliably achieved within the specified limits of precision and accuracy during routine laboratory operating conditions and will be below any promulgated maximum contaminant levels (MCLs). Instrument detection limits will be kept at or below the RLs. Some analytical results may be reported below the RL and above the Method Detection Limit (MDL) with an estimated value. These results will be flagged, and the result determined as an estimate and not a reported value. Analytical reporting limits will be low enough to determine if the Table Value Standards have been exceeded.... 6.0 Analytical Data Review Upon receipt of the analytical results, general analytical data evaluation (i.e., data validation) will be performed. At a minimum, this evaluation will address the following: • Overall data completeness; • A review of laboratory qualified data; • Comparison of field duplicate results to original sample results; • Comparison of trip blank and method blank results to sample results; • Review of data accuracy based on cation -anion balances, etc.; and • Review of laboratory QA/QC sample results including comparison to spike recoveries to control limits. Results of the data review will be documented and used to initiate additional review by the laboratory or possibly addition qualifications of the analytical data by the reviewer & ASSOCIATES LG Everist Sampling Plan Page 9 of 10 Groundwater Quality Sampling Plan 7.0 Verification Re -sampling Under certain circumstances a verification re -sampling may be collected, and samples submitted for analysis using this Groundwater Sampling Plan. The samples will be collected within four weeks of the analytical report date. A verification sample may be at the following sampling event depending on the frequency of sampling. Verification re - samples are designed to provide confirmation of the sample analytical data for sample result anomalies or statistical analysis. I , MOLEN & ASSOCIATES LG Everist Sampling Plan Page 10 of 10 Appendix A Sampling Field Data Sheet MOLEN 8g ASSOCIATES GROUND WATER SAMPLING FIELD DATA SHEET CLIENT SITE PROJECT Well No. (Date: Time: 'Personnel: Weather: Well Inspection (condition) Casing Diameter (in) Meter Calibration: Casing Stick-up: (0) Sampling Kit: Total Well Depth: (from top ofcasing)(ft) Sample ID: Time Taken Preservative Analysis Requested Static Water Level: (from top of casing) (ft) Purging Equip. Purge Rate (if pump used) Saturated Thickness:(ft) Sampling Equip. Casing Volume: (gal) Puree Parameters: Time Volume Purged Temp. (F°) pH Cond (us/cm) Relative Turbidity Odor Comments (color, odor, appearance) Well evacuated to dryness? (Y/N) Time to recarge well? Sampli Information: Date Time Puree Volumd Tem H Cond Other Sample Equipment Used Sample Appearance Pump Rate: Sampler Name(s) Checked for: ORP Diss 02 % Immiscible Layer (Y/N) Appendix B Sampling Parameter List Groundwater Quality Monitoring Plan Appendix B: Sampling Parameter List (7-7-2023) Analyte Table Value Standard (mg/L unless other units given) Reg. 41 Table Reference (1-4) pH Field (pH unit) 6.50 - 8.50 2 and 3 Coliforms Total (30 day average)* 2.2 org/100 ml 1 Asbestos* 70000 fibers/L 1 Chlorophenol* 0.0002 2 Color* 15 color units 2 Corrosivity* noncorrosive 2 Foaming Agents* 0.5 2 Odor* 3 threshold numbers 2 Phenol* 0.3 2 Free Cyanide* 0.2 1 TDS 400 mg/L or 1.25X background 4 Aluminum - Dissolved 5 3 Antimony - Dissolved 0.006 1 Arsenic - Dissolved 0.01 1 Barium - Dissolved 2 1 Beryllium - Dissolved 0.004 1 Boron - Dissolved 0.75 3 Cadmium - Dissolved 0.005 1 Chloride - Dissolved 250 2 Chromium - Dissolved 0.1 land 3 Cobalt - Dissolved 0.05 3 Copper - Dissolved 0.2 3 Fluoride - Dissolved 2 3 Iron - Dissolved 0.3 2 Lead - Dissolved 0.05 1 Lithium — Dissolved* 2.5 3 Manganese - Dissolved 0.05 2 Mercury - Dissolved 0.002 1 Molybdenum - Dissolved 0.21 1 Nickel - Dissolved 0.1 Nitrate (NO3) 10 1 Nitrite (NO2) 1 1 Nitrite + Nitrate as Nitrogen 10 1 Selenium - Dissolved 0.02 3 Silver - Dissolved 0.05 1 Sulfate - Dissolved 250 2 Thallium - Dissolved 0.002 1 Uranium - Dissolved 0.0168 to 0.03 1 Vanadium - Dissolved 0.1 3 Zinc - Dissolved 2 3 Beta and Photon emitters* 4 mrem/yr 1 Gross Alpha* 15 pCi/L 1 * Parameters to be omitted from sampling requirements based upon the Parameter Exclusion Rational discussed in Table 4. LG Everist Monitoring Plan 64 Groundwater Quality Monitoring Plan Appendix B: Parameter Exclusion Rationale (7-7-2023) Analyte Exclusion Rational Coliforms Total (30 -day average) Human and animal waste contain fecal coliforms. Bacterial coliforms are naturally found in the environment. Ingestion of coliforms is dangerous and can cause serious illness or death. It is expected that coliforms may be present in groundwater throughout Colorado and the sources are associated with excrement from animals in the natural environment. There are no coliforms being generated from mining activities at the LGE-West Farm site and as such, coliforms should be excluded from the monitoring parameter list. Asbestos Asbestos is a mined mineral with special characteristics of strength, filtration, and fire resistance. Asbestos was widely used in products in the first part of the 20th century. Later it was found to be a lung carcinogen and is now known to be an ingestion hazard as well. Asbestos uses are limited, and it is generally omitted from products where it was once found. Asbestos abatement from schools and private structures has been ongoing since the mid -1980s. Asbestos from abatement products is strictly regulated and documented disposal is required. Asbestos fibers in soils are regulated by CDPHE, and when found, are required to be removed and disposed of properly. Asbestos is not associated with the geology of the LGE West Farm site and should not be in natural formations at the site. It is regulated because it is a known carcinogen and water containing asbestos should not be consumed. The groundwater at LGE-WF site should not contain asbestos. There are no asbestos mines in Colorado. Water at the LGE West Farm site is not used for drinking water. There is no reason to expect asbestos in the groundwater and it should be an excluded parameter for the LGE-West Farm site. Free Cyanide Free cyanides are the cyanide containing compounds that can liberate cyanide gas in a neutral or slightly acidic environment. Hydrogen cyanide is the most common free cyanide. Sodium cyanide and potassium cyanide are readily soluble in water and, like hydrogen cyanide, produce cyanide gas in slightly acidic water. Cyanide gas and free cyanide in water are extremely poisonous. However, cyanides have to be introduced from a source, a pollutant in the water. Cyanides are not used, produced, or found in any mining activities at a sand and gravel mine. Cyanides may be associated with precious metal mining during heap leaching or related activities, but they are not at a sand and gravel mine. There are no manufacturing facilities around the LGE West Farm site. For these reasons, free cyanides should be excluded from the groundwater monitoring parameter list. Chlorophenol and Phenols Chlorophenol is a group of organic compounds that are synthesized and not generally found in nature except as pollutants from a specific source. Chlorophenols are only slightly soluble in water. The most commonly identified chlorophenols are: • Monochlorophenol - used in modest volumes, as dyestuff intermediates and in the manufacturing of higher chlorinated phenols • Dichlorophenol - used in larger volumes in the manufacture of the herbicide 2,4-D and other related chlorinated herbicides & ASSOCIATESEN LG Everist Monitoring Plan Groundwater Quality Monitoring Plan • Trichlorophenol - used in the manufacture of herbicides, primarily 2 4,5-TP (Silvex) which has been banned in the United States for decades. • Tetrachlorophenol - used as a preservative. • Pentachlorophenol (PCP) - used as an antimicrobial wood preservative and historically coating on utility poles and cross arms. PCP is often mixed with creosote or other wood coating products. The US EPA is phasing out the uses of PCP over five years beginning in 2022. Wood treatment facilities will be allowed to use their existing stocks of PCP for wood treatment until 2027. Due to the high toxicity of PCP, it is normally used for toxicity calculations for chlorophenols. Chlorophenol and Phenols (cont.) Phenol is similar to chlorophenol and is an important industrial chemical used as a precursor to many different materials and useful compounds. Phenol is readily soluble in water and sources of it in groundwater would be limited to industrial facilities. In general, chlorophenols and phenol are considered a problem in drinking water systems because they have a strong pungent odor in very small concentrations. The odor makes the water undesirable to drink regardless of the risk factors associated with toxicity. As stated in Reg 41— Basic Standards for Groundwater (page 56) "The organic chemicals chlorophenol and phenol were moved from Table 1 (Human Health Standards) to Table 2 (Secondary Drinking Water Standards), and the proposed standards were set equal to the Ambient Water Quality Criteria for the chemicals. The reason for the change is that although the two chemicals pose a significant health risk at much higher concentrations, taste and odor considerations are a concern at lower concentrations." Chlorophenols and phenols are not associated with sand and gravel mining and may only be a concern if the mining site were adjacent to a wood treatment facility. Broderick Wood Products (BWP) Superfund site in Denver and is adjacent to the Koppers Wood Treatment facility. Both sites have been studied extensively and groundwater contamination was identified off -site and in the neighborhood. Molen & Associates has collected groundwater monitoring samples at the BWP site. Reports generated for the EPA demonstrate that the PCP concentrations are below the detection limits in many of the on -site and off -site wells. The reported concentrations indicate that even at a facility where PCP was used, the concentrations in groundwater are too low to be detected by standard analytical equipment with a detection limit of 1 microgram/liter. Reg 41 — Basic Standards for Groundwater generally considers chlorophenols and phenols as a pollutant of concern due to the odors and taste in drinking water, and if PCP or phenols are in detectable concentrations, a toxicity hazard. The LGE West Farm site is not near a wood treatment facility or any manufacturing facility and chlorophenols and phenols should not be in the groundwater. Mining activities will not introduce any chlorophenols or phenols into the environment. For these reasons chlorophenols and phenol should be excluded From the parameter monitoring list. LG Everist Monitoring Plan Groundwater Quality Monitoring Plan Color The color and appearance of water is an aesthetic property that makes drinking water desirable. The color of groundwater is generally related to the turbidity of the water from natural sediments found in the well. Mining activities at the LGE West Farm site will not change or add to the color of the groundwater. The groundwater is not used as drinking water at the LGE-West Farm site and color should be excluded from the parameter monitoring list. Corrosivity Corrosivity is associated with a low pH (i.e.acidic) water. Natural water at the LGE West Farm site, like all waters along the South Platte River basin, are neutral with pH values within groundwater standard limits (pH 6.5-8.5). Corrosive conditions are not found at the LGE West Farm site and mining activities will not create corrosive conditions at the site. As such, corrosivity should be excluded from the monitoring parameter list. Foaming Agents Foams and foaming agents are generally listed in Reg 41 due to the appearance of the water for drinking purposes. Different types of foams occur naturally in lakes and streams where water is churned up from wind or water flowing over riprap structures. The most common foaming agents are detergents and simple soaps. Foaming agents typically come from industrial processes or consumer wastewater and are generally not expected to be associated with sand and gravel operations. LGE will commit to not using detergent, soaps, or other foaming agents at the LGE-WF site. Analysis for foaming agents should be excluded from the LGE-West Farm site. Odor Odor is an aesthetic property of drinking water and is difficult to quantify the substance creating the odor. Measuring odor in samples is subjective to the analyst. Mining at the LGE West Farm site will not introduce odors to the groundwater and odor testing should be excluded from the monitoring parameter list. Lithium - Dissolved Lithium is an alkali metal with very limited abundance in the earth's crust, estimated to be about 20 ppm (mg/L). The US Governmental report, Lithium Resources in North America, Geological Survey Bulletin 1027-G (found at https://pubs.usgs.gov/bul/1027g/report.pdf) indicates that the abundance of lithium in Colorado is generally limited to the Gunnison area. The United States Geological Service (USGS) published a report with the mean concentrations of lithium in specific locations in Colorado. Comparing all the lat/long information in the USGS report file (file title - Lithium_ Statistics.cvs), there is no lithium identified near the LGE West Farm site. The report and statistics file are found at https://www.sciencebase.gov/catalog/item/5ed8f70f82ce7e579c6739c1 . It should be safe to assume that lithium would not be found naturally occurring in the groundwater near the LGE West Farm site. Mining activities at LGE West Farm do not involve any lithium -based materials that would impact groundwater. The only materials that contain lithium are standard AA or AAA batteries that are managed and recycled off -site. For these reasons, we think lithium should be excluded from the groundwater monitoring parameter list. Gross Alpha/Beta Gross alpha and gross beta particle emitting constituents present health hazards in drinking water. Quantification of gross alpha and gross beta includes wide uncertainties with reported values from well samples varying widely. There are no sources of gross alpha or gross beta particle emitting constituents during the mining activity at the LGE West Farm site and the parameters should be excluded from the monitoring list. VAZI MOLE" LG Everist Monitoring Plan EXHIBIT L RECLAMATION COSTS The following information is provided to evaluate the amount of bond needed for Operations Stage A that allows for premining development of the Plant Site and support facilities. In this analysis L.G. Everist, Inc. will have approximately 56 acres dis- turbed in some form or another. The activities planned in this Operations Stage will include stripping, soil and overburden storage, sloping to the plant working floor, processing plant construction in Phase 4 and con- struction of the 6.0 acres ± recycled water facility in Phase 1. If development ended here the reclamation required would be to remove an estimated 200 yds of concrete foundations at processing plant, resoil the 50 acres and revegetate the disturbed area in Phase 4. In Phase 1 the settling ponds would have to be back - filled, resoiled and revegetated. We estimate 20,000 cyds would be needed to backfill the ponds. Adequate soil and overburden will be stored around the water recycling facility in Phase 1 for use on this area. The slurry wall in Phase 4 is not bonded as it is not installed in either Phase since mining will not start dur- ing Operations Stage A. From the TABLEL calculations we request the financial warranty amount for this scenario be set at $198,500.00 Doing this initial bonding will require LGE to file a Tech- nical Revision to increase the bond before starting mining. Ta- ble L shows the estimated cost for this phase. Tables L-1, L-2, L-3 and L-4 show the estimated cost to reclaim each of the mining phases based on to days costs and are included for future refer- ence. The Equipment Used in the Estimate Is: Scraper teams - 2 -Cat 627G scraper, D9R Dozer, 140H grader & water truck - Resoiling & backfilling Grader - Cat 140H - seedbed prep and ripping plant site Loader — Cat 688 — armoring placement Dozers - 2 - Cat D9R - cut/fill working face sloping Seeding team - standard farm tractor and pull behind drill, and crimping disk attachment L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 84 EXHIBrr L RECLAMATION COSTS (CONT) Unit Costs Used In Estimate 001 - Revegetation - per acre $850.00 002 - Replace Topsoil Cat 627G and scraper team $0.00 003 - Cat 140H blade Rip seed beds per acre $99.00 004 - Cat 140H blade Grade and shape per acre. $93.00 005 - Concrete demo per yard $7.00 006 - Secondary seeding per acre $212.00 007- Mob/demob - Haul distance 5.0 miles average speed 50 mph $6,406.48 008 - Weed Control per year $5,000.00 L.G. EVERIST, INC. - WEST FARM RESERVOIRS July 2023 85 L.G. Everist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE 6/29/2023 001 002 Table L Operations Stage A Plant site setup (Phase 4) TOTAL AREA Acres Undisturbed (AC) Revegetate (AC.) Resoil (AC.) Rip seed bed (AC.) Grading and Shaping (AC.) Freshwater/ setteling - backfill Concrete Demo (Cuycs) Secondary seeding (AC. ) @25% Annual Weed Control L.G. EVERIST, INC. CYD/FT Push/Haul Distance 500 Bond Estimate EXHIBIT L (CONT) Permit # M-2022-048 Unit Cost Total cost $47,600.00 $74,445.65 $93.71 $5,550.16 $5,247.76 $119,644.80 $2,100.00 $11,900.00 $5,000.00 $271,488.37 Direct costs Total bond for Phases 1, 4 & stripped $271,488.37 Task Indirect costs Liability 2.02% $5,484.07 Profit 10.00% $27,148.84 Performance 1.05% $2,850.63 009 Mob $6,406.48 Engineering and management 6.00% $16,289.30 DRMS Management 5.00% $13,574.42 Total Working bond $343,242.10 Recommend Bond be set at $343,300.00 July 2023 86 L.G. Everist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE 6/29/2023 Table L-1 EXHIBIT L (CONT) Permit # M-2022-048 Task Phase 1 Acres Length Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 190.23 TOTAL MINED 147.56 WATER AREA 141.67 Undisturbed (AC) 37.00 001 Revegetate (AC.) 8.54 $850.00 $7,260.10 002 Resoil (AC.) 8.54 1.00 13,780 900 $0.824 $11,354.69 003 Rip seed bed (AC.) 8.54 $99.11 $846.53 ooa Grading and Shaping (AC.) 5a 8. $93.71 $800.41 007 Secondary seeding (AC.)@25% 2.14 $212.50 $453.76 008 Annual Weed Control $5,000.00 009 Mob $6,406.48 010 Backfill sloping (Cuyds) 1,079,259 500 $1.25 $1,349,073.93 011 SO -FT.) Slurry Wall (LINEAR 10,203 52 $5.00 $2,627,169.50 012 Reservoir armoring (Feet) 2 410 ' 2.35 5,664 500 $0.72 $4,077.72 013 Onderdrain Instalatcae (Feet) 1,880 $82.03 $154,216.40 Phase total project Table L-2 $4,166,659.51 Task Phase 2 Acres Length Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 145.39 TOTAL MINED 106.87 WATER AREA 100.15 Undisturbed (AC) 24.07 001 Revegetate (AC.) 18.38 $850.00 $15,622.27 002 Resoil (AC.) 18.38 1.00 29,652 900 $0.824 $24,432.99 003 Rip seed bed (AC.) 18.38 $99.11 $1,821.56 004 and Shaping Grading AC ) ( 18.38 $93.71 $1,722.31 007 Secondary seeding (AC.)@25% 26.72 $0.00 $0.00 008 Annual Weed control $5,000.00 009 Mob $6,406.48 010 Backfill sloping along river (Cuyds) 4450 208.33 929,295 500 $1.25 $1,161,618.75 O10A Backfill sloping non river sides (Cuyds) 4225 115.54 488,160 500 $1.25 $610,200.00 011 Slurry wall (LINEAR SO -FT.) 10,166 52 $5.00 $2,633,118.32 012 Reservoir armoring (Feet) 9,605 2.35 22,572 500 $0.72 $16,251.66 Phase total project $4,476,194.33 L.G. Everist - West Farm Reservoirs 87 July 2023 L.G. Everist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE 6/29/2023 Table L-3 EXHIBIT L (CONT) Permit # M-2022-048 Task Phase 3 Acres Length (ft) Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 60.36 TOTAL MINED 41.31 WATER AREA 37.71 Undisturbed (AC) 14.98 001 Revegetate (AC.) 5.35 $850.00 $4,551.63 002 Resoil (AC.) 5.35 1.00 8,639 900 $0.824 $7,118.68 003 Rip seed bed (AC.) 5.35 $99.11 $530.72 004 Grading and Shaping () 5.35 $93.71 $501.80 007 Secondary seeding (AC.)@25% 3.75 $0.00 $0.00 008 Annual weed control $5,000.00 009 Mob $6,406.48 010 Baokf ill sloping (Cuyds) 6,900 233.53 1,611,357 500 $1.25 $2,014,196.25 011 Slurry wall (LINEAR SO -FT.) 7,152 61 $5.00 $2,181,381.35 Phase total Table L-4 $4,219,686.92 Task Phase 4 Acres Length (ft) Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 76.42 TOTAL MINED 61.19 WATER AREA 56.14 Undisturbed (AC) 10.56 001 Revegetate (AC.) 7.05 $850.00 $5,993.87 002 Resoil (AC.) 7.05 1.00 11,377 900 $0.82 $9,374.32 003 Rip seed bed (AC.) 7.05 $99.11 $698.88 004 Grading and Shaping (AC.) 7.05 $93.71 $660.81 006 Concrete Demo (Cuyds) 500 $7.00 $3,500.00 007 Secondary Seeding (AC.)@25% 76.42 $212.50 $16,239.31 008 Annual Weed control $5,000.00 009 Mob $6,406.48 010 Backfill sloping (Cuyds) 6,160 161.16 992,746 500 $1.25 $1,240,932.00 011 Slurry FT j (LINEAR 8,244 73 $5.00 $3,008,877.50 Phase total $4,297,683.17 L.G. Everist - West Farm Reservoirs 88 July 2023 L.G. Everist, Inc West Farm Reservoirs BANK ARMORING PLAN This bank protection plan is presented to explain the bank armoring proposed for reservoir bank protection in a 1305 foot section of Phase 1 where mining will be within 400 feet of the River and around the entire perimeter of Phase 2. Only the reservoir side armoring is being proposed since the river bank will be 300 feet or more east of the top of the slope of the mining limits. The location of the proposed armoring is shown on MAP EXHIBIT F - RECLAMATION PLAN MAP . The attached FIGURE1shows the cross-section of the area discussed below and details of the armoring to protect the banks along the east side of Phase 1 and entirely around Phase 2. The armor is intended to protect the reservoir banks should a 100 -year flood event occur after an area has been reclaimed. The armoring will be covered with a 10-12 inch layer of growth medium and seeded with the approved seed mix. The toe of the slope armoring will be at least 5 feet below the thalweg of the adjacent riverbed. The base of the armoring will average 10 feet below the existing ground surface at the mine. The 100 -year Floodplain line information has been included on all of the MAP EXHIBITS in the application Packet. Armoring material will be recycled concrete fragments with surface rebar removed, so that it meets the definition of Inert Materials. The concrete will be sized 9 to 15 inches averaging 12 inches. Fines will be mixed in to fill voids. This size material will have a Safety Factor of 1.26. See Bank Armoring Calculation page following this text. The operator will keep enough material stored on the mine to complete armoring needed on any area where sloping is being completed and is ready for armoring. At a minimum, 2,350 cubic yards will be stockpiled on the mine for use in armoring. This is enough to armor a minimum of 1,000 feet of excavation bank. At no time will there be more than 1,000 feet of armoring needing to be placed. LGE - WEST FARMS RESERVOIR July 2023 114 West Farm Reservoirs Bank Armoring Plan (cent) The stockpile cf armoring material will be placed parallel to the water flow so it will not interfere with flows in the flood plain if flooding occurs. It will be within the setback between the permit boundary and the mine highwall so it is close to the area where it will be placed on the bank. Reservoir Bank Armoring. Armoring will be placed inside of the mined areas adjacent to the South Platte River channel in Phase 1. In Phase 1 the east bank will be armored from the southeast corner of the reservoir north along the west side of the old railroad berm that protects Phase 1. This section will be armored as mining progresses thru Phase 1. In Phase 2 the entire perimeter of the reservoir area will be armored. Phase 3 is above the Flood Plain so will not be impacted by flooding and will not be armored. The armoring will be placed on the slopes starting from the existing ground surface elevation. The toe of the armoring will be a minimum of 5 feet below the river thalweg, have a 3h to lv slope and will be 2 feet or more thick. This will require approximately 2.35 cyd/lft along the excavated bank slopes. Once sloping begins, the armoring will be installed on 1,000 foot sections until completed. This will leave an armored face along the top of the bank and the slope into the reservoir that is 35 feet wide. Supplied supporting documents Figure 1 - Bank Protection Plan cross section Safety factor calculation page LGE - WEST FARMS RESERVOIR July 2023 L.G. Everist, Inc. Revised 0512023 WEST FARM RESERVOIRS BANK ARMORING PLAN �MI-� SIN RRy W ? 5�v 10' U- `� 0 _-10'-`I -50 NOTES: 1. III -45 6 ft TOP OF SLOPE 25 f't, 4. channel' th>Jweg .' a a 30 f't. 2.35 Syd/lft 2 ft. I I I I I �I I'r I I.. I I IP -30 -20 -10 0 10 20 TYPICAL RESERVOIR BANK ARMORING NO SCALE BANK ARMORING SHOWN ON RECLAMATION MAPS IS APPROXIMATE LOCATION. ACTUAL LOCATION WILL DEPEND ON LOCATION OF TOP OF SLOPE AT THE TIME IT IS INSTALLED. 2. MATERIAL USED FOR ARMORING WILL BE WELL AGES BROKE CONCRETE. THAT HAS ALL EXPOSED SURFACE REBAR REMOVED. AT A MINIMUM 2,350 CUBIC YARDS WILL BE STOCKPILED ON THE MINE FOR USE IN ARMORING. THIS IS ENOUGH TO ARMOR MATERIAL TO ARMOR A MINIMUM OF 1000 FEET OF EXCAVATION BANK.. 3. STOCKPILES OF ARMORING MATERIAL WILL BE PLACED PARALLEL TO THE RIVERBANK 50 IT WILL NOT INTERFERE WITH FLOWS IN THE FLOOD PLAIN. THE STOCKPILES WILL BE PLACED BETWEEN THE PERMIT LINE AND THE TOP OF SLOPE WITHIN 500 FEET TO THE AREA WHERE IT WILL BE PLACED. NOV 03, 2022 - 16:02:23 III 30 40 FIGURE 1 50 F H W I -10' 4. BANK ALONG THE EXCAVATED AREA WILL ARMORED FROM THE EXISTING SURFACE TO A POINT AT LEAST 5 FEET BELOW THE CHANNEL THALWEG. 5. THE SIZE OF THE MATERIAL WILL FALL IN THE RANGE OF 9 TO 15 INCHES AVERAGING 12 INCHES AS DISCUSSED IN THE BANK ARMORING PLAN AND WILL BE PLACED BELOW GRADE. 6. THE ARMORING WILL BE COVERED WITH A 10-12 INCH LAYER OF GROWTH MEDIUM AND SEEDED WITH THE APPROVED SEED MIX. L.G Everist, Inc. Bank Armoring Plan (cont) West Farm Reservoirs Safety Factor Calculations SF cos 9 tan 0 ntang) + sin e T5 = yRS n 21r, (Ss -1)Y 0so 9 = face slope of pitside bank, in degrees to the horizontal 0 = angle of repose of pitside bank construction materials is degrees n = stability factor s, = specific gravity of riprap particles Y = specific weight of water = 62.4 lbs:`83 Dso = median riprap particle size, in feet R = hydraulic radius at normal depth of flow down pitside dope, in feet S = face slope of pitside bank, in feet per foot Ts = yRS Y= 62.4 R=2 S= 0.01 1.248 n 21 T5 (S5 -1)y Dso Ts= 1.248 SS= 2.4 D50 = 1 26.2 n 87.4 n-0.3 SF cos 9 tan 0 nran 0+sin g n = 0.3 cos0 = 0.9487 8 =18.43° to n0 = 0.7002 0=35° sin()= 0.3161 SF = 0.6643 0.5262 SF = 1.26 117 REQUEST FOR CORPS JURISDICTIONAL DETERMINATION (JD) DENVER REGULATORY OFFICE, OMAHA DISTRICT Requested Location: L.G. Everist, Inc. -West Farm site, located north and south of Weld County Road 32Y2, west of the South Platte River, and east of Weld County Road 21, Weld County, Colorado. Acreage of JD Review Area: approximately 600 acres Section/Township/Range: Section 14, Township 3 North, Range 67 West of the 6th PM.. Weld County, Colorado Latitude/Longitude: 40.225274° N, -104.858926° W Maps: A Vicinity Map, and Project Area (JD review area) Map are provided in the Appendix. Property Features Description: A description of potential waters of the United States and wetlands is provided in the Appendix. JD Requestor Status: Savage and Savage, Inc. is a consultant acting on behalf of the property owner and requestor, L.G. Everist, Inc. Reasons for Requesting the JD: The property owner intends to construct/develop a project or perform activities on this parcel which may require authorization from the Corps, and the JD would be used to avoid and minimize impacts to jurisdictional aquatic resources and as an initial step in a future permitting process. Type of Determination being Requested: An approved JD is being requested. Authorization: With the signature below, the undersigned is indicating that they have the authority, or are acting as the duly authorized agent of a person or entity with such authority, to and do hereby grant Corps personnel right of entry to legally access the site if needed to perform the JD. The signature is an affirmation that the signer has the requisite property rights to request a JD on the subject property. Requestor Signature: Date: June 20, 2020 Printed Name: Michael S. Savage, Principal Company Name: Savage and Savage, Inc. Address: 4610 Haystack Dr, Windsor, Colorado 80550 Daytime Phone: 970.674.8080 Email: savageandsavage@earthlink.net L.G. Everist West Farm Jurisdictional Determination Request Page 1 of 14 L.G. Everist West Farm General Location Map @2008 National Geographic; Q2007 NATIONAL GEOGRAPHIC 0.0 0.5 1.0 1.5 2.0 2.5 3.0 miles 171/2° 06/06/20 L.G. Everist West Farm Jurisdictional Determination Request Page 3ofl4 Description of West Farm Surface Water Features Savage and Savage Environmental conducted on-line and on -site background investigations of surface water features of the L.G. Everist West Farm property in April and May 2020. The investigations included reviews of current and historic aerial photography, USGS topographic mapping (1978), Natural Resource Conservation Service web soil surveys, and interviews of L.G. Everist personnel regarding the historic uses and management of the West Farm property. In April 2020, an on -site investigation of the property and surface water features was undertaken, with attendant mapping and feature descriptions. West Farm Historic Uses and Management Agriculture and Livestock Grazing The West Farm is located on both the primary and secondary alluvial terraces above the South Platte River, with the majority of the property (eastern %) sited on the primary alluvial terrace. During the twentieth century the property was farmed using flood irrigation and pivot irrigation methods. Both terraces were used for agriculture. Additionally, the areas were utilized for cattle grazing when not in crop production. To facilitate irrigation, numerous irrigation delivery ditches and tailwater collection ditches were constructed within and adjacent to the agricultural fields. The sources for the irrigation water included on -site groundwater wells and surface irrigation water from irrigation canals and ditches originating off -site. Ultimately, irrigation tailwater was (and is) returned to the South Platte River via constructed ditches and existing flood plain drainage features. From historic aerial photography and USGS mapping it is evident that modifications to the irrigation supply and collection system have taken place over the last fifty years to facilitate agricultural production and a subsequent use. Waterfowl Hunting Prior to 1999, developers modified surface features of the West Farm to promote waterfowl habitat through retention of flood and irrigation waters along irrigation tailwater collection and return ditches. Field dikes and diversions into mesic agricultural fields promoted shallow puddles for duck habitat, while control of surface waters within collection and return ditches enlarged the waters behind the control point (upstream) providing additional stream -like habitat for waterfowl. Management of the property for waterfowl habitat and hunting continued until the recent purchase of the West Farm property by L.G. Everist. Current and Future Management L.G. Everist plans to return the property to an agricultural and grazing use. As part of this return, upland surface features constructed to promote wildfowl habitat that flooded agricultural field have been modified or removed, including field dikes and restrictive drainage blocks, to ensure surface water flow while irrigating. This has returned agricultural fields to mesic vegetation communities compatible with annual row crops and hay production. L.G. Everist West Farm Jurisdictional Determination Request Page 4 of 14 In the future (>10 years), L.G. Everist may propose aggregate extraction at West Farm, as economic aggregate reserves are present in both the primary and alluvial terraces. This jurisdictional determination request will assist L.G. Everist in further managing the property through reconstructing the agricultural irrigation distribution and tailwater collection system for more efficient agricultural production, while avoiding and minimizing impacts to waters of the United States (including jurisdictional wetlands). West Farm Surface Water Features Man-made and natural surface water features are depicted on the appended Figure 1 (L.G. Everist West Farm Surface Water Features). A description of the surface water features is contained in Table 1. (L.G. Everist West Farm Surface Hydrologic Features). The following text contains further descriptions of the features to assist the Corps in determining the jurisdictional nature of each. Descriptions will follow the alpha -numeric designations of the above figure and table. Al. This feature is a man-made tailwater collection ditch that collects irrigation water runoff from the field to the north and terminates at a tailwater sump (A2) on the southeast edge of the secondary alluvial terrace. A2. This feature in a constructed tailwater sump (Figure 2) that collects water from the tailwater collection ditch to the west (A 1). Water within A2 ultimately decants through a culvert to the primary alluvial terrace below, where tailwater enters surface water feature B4 and ultimately enters the South Platte River to the north. Bl. This drain is a constructed ditch that originates at the irrigation pivot pump in the southeast corner of the property. Water from the installed pivot pump flows into this feature and ultimately to the irrigation tailwater pond (B2). Water may also enter this feature from the off -site irrigation pond (D1) through irrigation ditch D2. Ultimately, water from B1 can be used for flood irrigation (pumped from B2) or discharged into the tailwater ditch B3, which ultimately discharges into the South Platte River to the north. B2. B2 is a man-made irrigation tailwater collection pond, situated downgradient from the irrigation pivot pump (F3) and the irrigation water drain (B1). Based on the 1978 USGS topographic map, this feature, while anthropogenic, was likely constructed in a natural alluvial terrace channel (depicted as a blue line on the 1978 topography). The origin of this natural drainage feature is to the south of West Farm, though no water source is identifiable on the topographic map. Currently, water flowage into B2 (and B1) is from the irrigation pivot pump (F3) and/or the off -site irrigation pond (D1) on the adjacent farm to the south of West Farm. B3. This feature is currently a tailwater collection ditch, originating at B2, traversing the south parcel of West Farm to the north, crossing under Weld County Road 32.5, and entering the surface drainage B4 within the north parcel (Figure 3). The current alignment of B3 reveals that it is man-made, aligned along the east boundary of an irrigated agricultural field. The 1978 topographic map depicts the blue line drainage in the general vicinity of the current B3, however, this surface drainage is no longer present on the site. It was concluded L.G. Everist West Farm Jurisdictional Determination Request Page 5 of 14 that surface modification in the area occurred to better site the tailwater drainage ditch for agricultural operations. Any such modification took place prior to 1999, as the current alignment for B3 is observable in those dated aerial images. B4. This feature is a surface water drainage (Figure 4.) that follows the depicted blue line on the 1978 USGS topographic map. This feature follows a natural sinuous drainageway, and is fed by irrigation tailwater from sources within the south parcel of West Farm. It flows from south to north along the west boundary of the primary alluvial terrace and terminates at feature B5, ultimately flowing into the South Platte River. B5. B5 is the northern terminus of the surface water features that originate in the south parcel of West Farm and end at the South Platte River to the north. This feature is an extension of B4 and continues within the natural drainageway to the terminus at the South Platte River channel. Cl. This man-made ditch is a tailwater collection ditch with water origins at the irrigation pivot pump (F3) and/or the off -site irrigation pond (131). This feature collects irrigation tailwater from agricultural fields in the southeast quadrant of West Farm, and conveys the water to the north, crossing under Weld County Road 321/2, onto the West Farm north parcel, discharging into the South Platte River at the north boundary of West Farm. C2. This feature is a cattail marsh (Figure 5.) located in a topographic low, possibly excavated, north of West Farm south parcel agricultural fields, and above the culvert conveying tailwater drainage under Weld County Road 321/2. This feature has origins along Cl, and was concluded to exist due to high water levels present as tailwater backs up prior to exiting through the culvert under the county road. This feature likely would not exist without the presence of tailwater accumulation. C3. This feature consists of two man-made irrigation ditches, portions of which are concrete lined, running east -west, draining fields immediately south of the county road, and conveying tailwater to the culvert under Weld County Road 32 %2. C4. This tailwater collection ditch (Figure 6.) is a man-made feature, originating at the culvert under Weld County Road 32 %2 and proceeding northwest along the primary alluvial terrace toward the riparian corridor. Tailwater within the ditch has sources from the West Farm South Parcel, as well as irrigated agricultural and pastures to the west within the West Farm North Parcel. In historical imagery from 1999, this ditch appears to provide water to several of the wildfowl habitat locations within the North Parcel. C5. C5 is a continuation of the tailwater collection ditch C4, with less definition of a constructed drainage channel. Historical imagery (1999) reveals that this feature appears to originate from the fringes of upland dikes installed for wildfowl habitat, when water levels reached the upland edge of the dike. At that point, excess water flowed across the primary alluvial terrace downgradient toward the South Platte River. While not appearing as a defined constructed ditch, the overland flow resulted from the man-made wildfowl habitat improvement features. Flow likely continues at this time due to increased tailwater volumes in feature C4 that are not diverted by dikes into shallow wildfowl habitat pools. L.G. Everist West Farm Jurisdictional Determination Request Page 6 of 14 C6. This feature (Figure 7.) is a continuation of C5, and directs surface tailwater runoff through the primary alluvial terrace to a terminus at the South Platte River. As with feature C5, this feature is not a defined drainage channel, but a flow path following topographic lows to the South Platte River. Dl. This feature is a constructed irrigation water pond, located south of the West Farm South Parcel on an adjacent farm. This feature is one source of irrigation water for locations within West Farm. Water from this pond is conveyed through the irrigation ditch D2. D2. This is a man-made irrigation water ditch to convey water from the irrigation water pond D1 to features B1 and Cl, and ultimately to the irrigated agricultural fields at the West Farm South Parcel. Fl. This feature is the Hogson Ditch, a constructed irrigation supply ditch conveying irrigation water from off -site, south of West Farm to irrigate fields in the West Farm South Parcel. Portions of this ditch are concrete lined. F2. This excavated feature is a man-made irrigation sump that contains Hogson Ditch irrigation water, prior to release to West Farm South Parcel agricultural fields. F3. This feature is a groundwater irrigation pivot pump, supplying irrigation water to West Farm agricultural fields through a system of earthen and concrete lined ditches. Gl. G1 is a man-made irrigation tailwater ditch (Figure 8.) originating below the pivot irrigated field in the southwest quadrant of the West Farm. G2. This tailwater drainage feature is distinguished from feature G1 as it appears on the USGS 1978 topographic map as a designated blue line drainage. As with feature B3, the current alignment of G2 appears to have been modified from the original noted USGS feature to better accommodate agricultural operations. The source of water in the ditch appears to originate solely from irrigation to the agricultural operations. G3. Feature G3 (Figure 9.) conveys agricultural water through the West Farm South Parcel from south to north. Segments of the feature follow the identified blue line of the 1978 USGS topographic map closely while in reaches to the north, the drainage channel has been significantly straightened and realigned. H. This feature is a relict of the railroad grade construction to the east along the South Platte River. This feature is a swale running north -south along the elevated rail corridor, and is presumed to be the source of fill for the railroad grade. It does not connect to any of the other features of West Farm, and though it exhibits some features of wetlands, its discontinuous nature, anthropogenic origins, and lack of hydrologic connectivity to the regional groundwater aquifer system led us to conclude it was likely non jurisdictional. L.G. Everist West Farm Jurisdictional Determination Request Page 7 of 14 Table 1. L.G. Everist West Farm Surface Hydrologic Features Feature I.D. Name Location PIN Origin Terminus Description Al Tailwater ditch N. Parcel, west side Irrigation Ditch below irrigated field Tailwater sump (A2) man-made ditch for tailwater collection A2 Tailwater sump N. Parcel, west side Irrigation Sump Feature Al Feature Al man-made sump for tailwater collection 81 Irrigation water drain S. Parcel, lower right Irr gation Drain Irrigation Pivot Pump Tailwater Sump B2 man-made for pump drainage collection 82 Irrigation Tailwater Pond S. Parcel, lower right Irrigation Pond Feature B3 Feature 83 man-made for pump drainage collection 83 Tailwater ditch S. Parcel, center right Irrigation Ditch South of current pivot center Joins E3 south of CR 32.5 man-made ditch for tailwater collection 84 Surface Drainage N. Parcel, center natural drainage culverted from S. Parcel contnues to 85 unnamed blue line drainage USGS 1978 85 Surface Drainage N. Parcel, west side natural drainage South Parcel South Platte River unnamed blue line drainage USGS 1978 Cl Tailwater ditch S. Parcel, SE corner Irrigation Ditch S. Parcel, SE, west of RR grade Feature D2 man-made ditch for tailwater collection C2 Cattail Marsh S. Parcel, 5 of CR32.5 Swale Feature Cl Feature D3 man-made sump for tailwater collection C3 Tailwater ditch S. Parcel, S of CR32.5 Irrigation Ditch Tailwater Ditches along CR 32.5 Culvert under CR 32.5 man-made ditch for tailwater collection C4 Tailwater ditch N. Parcel, N of CR 32.5 Irrigation Ditch Culverted from S. Parcel, E side Feature D5 man-made ditch for tailwater collection CS Tailwater ditch N. Parcel, center E Irrigation Ditch Feature D4 diffuse microswales natural topography C6 Tailwater ditch N. Parcel, NW boundary Irrigation drainage Feature CS South Platte River natural topography D3 Offsite Irrigation Pond S of S. Parcel Irrigation Pond Irrigation to S Feature F2 man-made pond for irrigation water D2 Irrigation Ditch SE area of S. Parcel Irrigation Ditch Feature D1 Feature 81 man-made irrigation water ditch Fl Hogson Ditch SE corner of S. Parcel Irrigation Ditch Offsite Irrigation Source Feature F2 man-made irrigation water ditch F2 Tailwater sump SE corner of S. Parcel Irrigation Sump Feature F3 Feature 81 man-made irrigation water sump F3 Irrigation Pivot Pump SE corner of S. Parcel Water Pump groundwater Feature B3 Irrigation Pump Si Tailwater ditch S. Parcel, center Irrigation Ditch below irrigated field Feature G2 man-made Irrigation tailwater ditch G2 Tailwater ditch S. Parcel, west of center Irrigation Ditch & natural drainage below irrigated field Feature G3 man-made Irrigation tailwater ditch and natural drainage G3 Tailwater ditch S. Parcel, west and north c Irrigation Ditch & natural drainage below irrigated field Feature B3 man-made irrigation tailwater ditch and natural drainage H Railroad Grade Swale S. Parcel, E side Railroad excavation SE of project site N of project site Swale from ecavation to build RR grade L.G. Everist West Farm Jurisdictional Determination Request Page 9 of 14 Figure 2. Feature A2 Tailwater Sump in foreground with Tailwater Ditch Al toward the horizon (April 20, 2020) Figure 3. B3 Tailwater Collection Ditch, view to the South (April 20, 2020) L.G. Everist West Farm Jurisdictional Determination Request Page 10 of 14 Figure 4. Feature B4 Surface Drainage as it enters the West Farm North Parcel from the South (April 20, 2020) t- �._ ._ ._ _ as- • i - , o'1MRR • L... Mr - 'It I. l .[b4 • Iii t• t. r'S v C I • a :.1t?+ rat :ht 3 ft It `iI .esay sr4‘ai.• t 4, • M• 'met •+f Figure 5. Feature C2, Cattail Marsh Immediately south of Weld County Road 321/2 L.G. Everist West Farm Jurisdictional Determination Request Page 11 of 14 (April 20, 2020) Figure 6. Feature C4, Tailwater Ditch, North Parcel, West Farm (April 20, 2020) L.G. Everist West Farm Jirisdictional Determination Request Page 12 of 14 Figure 7. Feature C6 Tailwater Flow to South Platte River (April 20, 2020) M1 - =i"�KX• r. QM. � " • '1/2•14.6- - - y-•_'' y� Ste. rtP. 4ditv 4. <, li Cd 4• sOf t '� w ? w. L. —• L 1_: , ,.• * i !re -[t _• 4144s4t t% -y Arc •YA.febnl- • Lr� •tZ_,, - , K S• •b. �jk •i •1 I f r. Io , a ; ✓ g . 0044) S\ I fir. •. Kp , ) C � � \ 1 .. •L. 4.,„ t 1it •. 1; . •e. , ., • 31:61-t ' r �.► �• �V... ,� �� • 1, Y . pi. ' c.d • - - �1 is t. F I • 1' . 1' 1 1 r :I n`. 1 j_. 4 4KP. Ala -rte.". r, -4441- T t = r♦ _• �� .T y ` • . A 1.. so -,,,,y. A t{. ;.4 A. . : ; tz,* n •,e X i t 4 nilikal edit 4;" AkT•4` 1:1 `� 3. �� ? �fig_ ..'• ' . - •••• SW ra ••• r t �.• f� s; t.4 •• Figure 8. Feature G1 Tailwater Ditch origin (April 20, 2020) L.G. Everist West Farm Jurisdictional Determination Request Page 13 of 14 I - _o w 7 r•Iffil t' Alic 04; b ze, ;.. r!`" wilbtit t. r v leCie^ ' . .r. - • :4'. - 1.1:1"1"1:74....a- 4.1:4;a7sf: fre..a.4%.• • a. :Sale_-_- Nike • Y Figure 9. Feature G3 Tailwater Ditch looking South (April 20, 2020) L.G. Everist West Farm Jurisdictional Determination Request Page 14 of 14 DEPARTMENT OF THE ARMY CORPS OF ENGINEERS, OMAHA DISTRICT DENVER REGULATORY OFFICE, 9307 SOUTH WADSWORTH BOULEVARD LITTLETON, COLORADO 80128-6901 February 3, 2021 SUBJECT: Approved Jurisdictional Determination - Corps File No. NWO-2020- 01166-DEN, West Farm Michael Savage Savage and Savage Inc 4610 Haystack Dr. Windsor, CO 80550 Dear Mr. Savage: This letter is in reference to the property located at approximately 40.225274°N, -104.858926°W, in Weld County, Colorado. The submittal dated August 26, 2020, consists of a request for an Approved Jurisdictional Determination for the above project. The delineated area located on the subject property has been reviewed in accordance with Section 404 of the Clean Water Act under which the U.S. Army Corps of Engineers regulates the discharge of dredged and fill material, and any excavation activity associated with a dredge and fill project in waters of the United States. At your request, an Approved Jurisdictional Determination (JD), a written indication that wetlands and waterways within your project area are or are not waters of the United States has been prepared. The review area contains the following that are considered waters of the United States (WOTUS). Within the review area, the South Platte River is a Traditionally Navigable Waterway (TNVV) and is therefore jurisdictional. Feature G/B and Feature C are relatively permanent tributaries to the South Platte River and are therefore jurisdictional. All other aquatic resources within the review area are not jurisdictional. The JD is attached to this letter. If you are not in agreement with the JD decision, you may request an administrative appeal under regulation 33 CFR 331, by using the attached Appeal Form and Administrative Appeal Process form. The request for appeal must be received within 60 days from the date of this letter. It is not necessary to submit a Request for Appeal if you do not object to the JD. This JD is valid for a period of five years from the date of this letter, unless new information warrants revisions of the JDs before the expiration date, or unless the Corps has identified, after a possible public notice and comment, that specific geographic areas with rapidly changing environmental conditions merit re -verification on a more frequent basis. -2 - If there are any questions please feel free to contact Nicholas Franke at (303) 979- 4120 or by e-mail at Nicholas.A.Franke@usace.army.mil, and reference Corps File No. NWO-2020-01166-DEN. Sincerely, Kiel Downing Chief, Denver Regulatory Office Enclosure(s) Approved Jurisdictional Determination (February 3, 2021) Notice of Administrative Appeal Options Administrative Appeal Process Flowchart APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook. SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD): February 3, 2021 B. DISTRICT OFFICE, FILE NAME, AND NUMBER: Denver Regulatory Office, West Farm, NWO-2020-01166-DEN C. PROJECT LOCATION AND BACKGROUND INFORMATION: State: ('( ) County/parish/borough: Weld County City: Platteville Center coordinates of site (lat/long in degree decimal format): Lat. 40.225274°N; Long.- 104.858926°W Universal Transverse Mercator: 13 512002.370926 E, 4452770.459333 N Name of nearest waterbody: South Platte River Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: South Platte River Name of watershed or Hydrologic Unit Code (HUC): I-IUC8: 10190003; HUC12: 101900030603 Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request. Check if other sites (e.g., offsite mitigation sites, disposal sites, etc...) are associated with this action and are recorded on a different JD form. ■ D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY): Office (Desk) Determination. Date: February 3, 2021 Field Determination. Date(s): August 26, 2020 SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION. There Are no "navigable waters of the U.S." within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area. [Required] Waters subject to the ebb and flow of the tide. Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain: ■ ■ B. CWA SECTION 404 DETERMINATION OF JURISDICTION. There are and are not "waters of the U.S.," within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required] 1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): 1 TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs Non-RPWs that flow directly or indirectly into TNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs Impoundments of jurisdictional waters Isolated (interstate or intrastate) waters, including isolated wetlands ■ ■ ■ ■ ■ • ■ b. Identify (estimate) size of waters of the U.S. in the review area: Non -wetland waters: 3,672 linear feet: 5 width (ft) and/or acres. Features B and G, which are the same channel 6,033 213 South Platte River Wetlands: acres. c. Limits (boundaries) of jurisdiction based on: Elevation of established OHWM (if known): Established by OHWM. 2. Non -regulated waters/wetlands (check if applicable):' ►�1 Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain: Reference is made to the November 13, 1986 Federal Register (Page 41217), Part 328 (a), "Non -tidal drainage and irrigation ditches excavated in dry land." The Corps of Engineers generally does not consider these types of aquatic resources waters of the U.S. except on a case -by -case basis. In this case, features Al, D2, Fl, and H are irrigation ditches constructed in uplands, partially lined with concrete through the review area, and terminating in uplands. Features A 1, D2, F1, and H satisfy the criteria of this section and are therefore not jurisdictional. Boxes checked below shall be supported by completing the appropriate sections in Section III below. 2 For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least "seasonally" (e.g., typically 3 months). Supporting documentation is presented in Section III.F. Further reference is made to the November 13, 1986 Federal Register (Page 41217), Part 328 (b), "Artificially irrigated areas that would revert to uplands if the irrigation ceased." The Corps of Engineers generally does not consider these types of aquatic resources waters of the U.S. except on a case -by -case basis. In this case, features A2, C2, F2, and F3 are artificially irrigated areas associated with agricultural irrigation at the site. Features A2, C2, F2, and F3 would likely revert to uplands if the irrigation ceased; therefore, these features satisfy the criteria of this section and are not jurisdictional. Further reference is made to the November 13, 1986 Federal Register (Page 41217), Part 328 (c), "Artificial lakes or ponds created by excavating and/or diking dry land to collect and retain water and which are used exclusively for such purposes as stock watering, irrigation, settling basins, or rice growing." The Corps of Engineers generally does not consider these types of aquatic resources waters of the U.S. except on a case -by -case basis. In this case, feature D1 is an artificial irrigation pond constructed in uplands and terminating in feature F2, which is not jurisdictional as described above. Feature D1 satisfies the criteria of this section and is therefore not jurisdictional. SECTION III: CWA ANALYSIS A. TNWs AND WETLANDS ADJACENT TO TNWs The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section III.A.1 and Section III.D.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.1 and 2 and Section III.D.1.; otherwise, see Section 1II.B below. 1. TNW Identify TNW: South Platte River. Summarize rationale supporting determination: The South Platte River is present at the eastern edge of the review area. The South Platte River is acknowledged as a TN W, due to its connection to interstate commerce, especially in the form of recreational opportunities. A Corps Navigability Study completed December 6, 1974 by Donald E. Spritzer concluded that "if past interstate commercial use is the criterion for navigability ... the South Platte... should be classified as navigable waters." Though navigability may be altered from its initial state due to bridges, development, etc., the connection to interstate commerce remains and the South Platte River is therefore a TNW. 2. Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is "adjacent": There are no jurisdictional wetlands adjacent to the South Platte River within the review area. B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY): This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met. The agencies will assert jurisdiction over non -navigable tributaries of TNWs where the tributaries are "relatively permanent waters" (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a "TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4. A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law. If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section I11.8.1 for the tributary, Section 111.8.2 for any onsite wetlands, and Section I1I.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section III.C below. 1. Characteristics of non-TNWs that flow directly or indirectly into TNW a Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West. 2 (i) General Area Conditions: Watershed size: Pick List Drainage area: Pick List Average annual rainfall: inches Average annual snowfall: inches (ii) Physical Characteristics: (a) Relationship with TNW: Tributary flows directly into TNW. Tributary flows through Pick List tributaries before entering TNW. ■ ■ Project waters are Pick List river miles from TNW. Project waters are Pick List river miles from RPW. Project waters are Pick List aerial (straight) miles from TNW. Project waters are Pick List aerial (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain: Identify flow route to TNW5: Tributary stream order, if known: . (b) General Tributary Characteristics (check all that apply): Tributary is: ■ Natural Artificial (man-made). Explain: Manipulated (man -altered). Explain: ■ ■ Tributary properties with respect to top of bank (estimate): Average width: feet Average depth: feet Average side slopes: Pick List. Primary tributary substrate composition (check all that apply): Sands Gravel Vegetation. Type/% cover: ■ ■ ■ ■ Silts Cobbles Bedrock Other. Explain: ■ ■ ■ ■ ■ Concrete Muck Tributary condition/stability [e.g., highly eroding, sloughing banks]. Explain: Presence of run/riffle/pool complexes. Explain:. Tributary geometry: Pick List Tributary gradient (approximate average slope): % (c) Flow: Tributary provides for: Pick List Estimate average number of flow events in review area/year: Describe flow regime: Other information on duration and volume: Surface flow is: Pick List. Characteristics:. Subsurface flow: Pick List. Explain findings:. ■ Dye (or other) test performed: Tributary has (check all that apply): Bed and banks OHWM6 (check all indicators that apply): clear, natural line impressed on the bank changes in the character of soil shelving vegetation matted down, bent, or absent leaf litter disturbed or washed away sediment deposition water staining ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Pick List the presence of litter and debris destruction of terrestrial vegetation the presence of wrack line sediment sorting scour multiple observed or predicted flow events abrupt change in plant community 5 Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW. 'A natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody's flow regime (e.g., flow over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break. 3 ■ • other (list): Discontinuous OHWM.7 Explain: If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply): ■ High Tide Line indicated by: ■ Mean High Water Mark indicated by: ■ ■ ■ ■ ■ oil or scum line along shore objects fine shell or debris deposits (foreshore) physical markings/characteristics tidal gauges other (list): ■ ■ ■ survey to available datum; physical markings; vegetation lines/changes in vegetation types. (iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain:. Identify specific pollutants, if known: (iv) Biological Characteristics. Channel supports (check all that apply): Riparian corridor. Characteristics (type, average width):. Wetland fringe. Characteristics: Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally -sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: ■ ■ ■ ■ ■ ■ ■ 2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW (i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: acres Wetland type. Explain: . Wetland quality. Explain: Project wetlands cross or serve as state boundaries. Explain: (b) General Flow Relationship with Non-TNW: Flow is: Pick List. Explain: Surface flow is: Pick List Characteristics: Subsurface flow: Pick List. Explain findings: ■ Dye (or other) test performed: (c) Wetland Adjacency Determination with Non-TNW: Directly abutting Not directly abutting Discrete wetland hydrologic connection. Explain: Ecological connection. Explain: Separated by berm/barrier. Explain: ■ ■ ■ ■ ■ (d) Proximity (Relationship) to TNW Project wetlands are Pick List river miles from TNW. Project waters are Pick List aerial (straight) miles from TNW. Flow is from: Pick List. Estimate approximate location of wetland as within the Pick List floodplain. (ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear. brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: . Identify specific pollutants, if known: (iii) Biological Characteristics. Wetland supports (check all that apply): ■ Riparian buffer. Characteristics (type, average width): 'Ibid. 4 • ■ Vegetation type/percent cover. Explain: Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally -sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: ■ ■ ■ ■ 3. Characteristics of all wetlands adjacent to the tributary (if any) All wetland(s) being considered in the cumulative analysis: Pick List Approximately ( ) acres in total are being considered in the cumulative analysis. For each wetland, specify the following: Directly abuts? (Y/N) Size (in acres) Directly abuts? (YIN) Size (in acres) Summarize overall biological, chemical and physical functions being performed: C. SIGNIFICANT NEXUS DETERMINATION A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNS\'. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus. Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? • Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream foodwebs? • Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW? Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below: 1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section III.D: 2. Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: 3. Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: D. DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY): I. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: TNWs: 6,033 linear feet 213 width (ft), Or, 29.500 acres. Wetlands adjacent to TNWs: acres. ■ 2. RPWs that flow directly or indirectly into TNWs. 5 ■ Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: Historic aerial photography indicates that Feature B/G transmits flow to the South Platte River on a perennial basis. Flow originates from an irrigation pivot pump and flows generally north before emptying into the South Platte River at the north edge of the review area. This flow is relatively permanent and connects to a TNW: therefore, Feature B/G is a relatively permanent waterway and is therefore jurisdictional. Tributaries of TNW where tributaries have continuous flow "seasonally" (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section III.13. Provide rationale indicating that tributary flows seasonally: Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: ■ ■ 3. Non-RPWs8 that flow directly or indirectly into TNWs. Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C. ■ Provide estimates for jurisdictional waters within the review area (check all that apply): Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: ■ ■ 4. Wetlands directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: ■ ■ ■ Wetlands directly abutting an RPW where tributaries typically flow "seasonally." Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: Provide acreage estimates for jurisdictional wetlands in the review area: acres. 5. Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C. • Provide acreage estimates for jurisdictional wetlands in the review area: acres. 6. Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C. ■ Provide estimates for jurisdictional wetlands in the review area: acres. 7. Impoundments of jurisdictional waters.9 As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional. Demonstrate that impoundment was created from "waters of the U.S.," or Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below). ■ ■ ■ E. ISOLATED [INTERSTATE OR INTRA-STATE] WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK ALL THAT APPLY):10 "See Footnote # 3. `' To complete the analysis refer to the key in Section III.D.6 of the Instructional Guidebook. " Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos. 6 • ■ ■ ■ ■ which are or could be used by interstate or foreign travelers for recreational or other purposes. from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. which are or could be used for industrial purposes by industries in interstate commerce. Interstate isolated waters. Explain: Other factors. Explain: Identify water body and summarize rationale supporting determination: Provide estimates for jurisdictional waters in the review area (check all that apply): ■ ■ ■ Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: Wetlands: acres. • F. NON -JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY): If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. ■ ■ ■ ■ Prior to the Jan 2001 Supreme Court decision in "SWANCC," the review area would have been regulated based solely on the "Migratory Bird Rule" (MBR). Waters do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction. Explain: Other: (explain, if not covered above): See Section II.B.2 above. Provide acreage estimates for non jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply): Non -wetland waters (i.e., rivers, streams): linear feet width (ft). Lakes/ponds: acres. Other non -wetland waters: acres. List type of aquatic resource: Wetlands: acres. ■ ■ ■ ■ Provide acreage estimates for non jurisdictional waters in the review area that do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction (check all that apply): Non -wetland waters (i.e., rivers, streams): linear feet, width (ft). Lakes/ponds: acres. Other non -wetland waters: acres. List type of aquatic resource: Wetlands: acres. ■ ■ ■ ■ SECTION IV: DATA SOURCES. A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and requested, appropriately reference sources below): ►,1 Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: Figure 1,LG Everist West Farm Surface Water Features; and Figure 2, General Location Map, Request for AID, Savage and Savage., June 21, 2020 Data sheets prepared/submitted by or on behalf of the applicant/consultant. ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Office concurs with data sheets/delineation report. Office does not concur with data sheets/delineation report. Data sheets prepared by the Corps: Corps navigable waters' study: U.S. Geological Survey Hydrologic Atlas: USGS NHD data. USGS 8 and 12 digit HUC maps. HUC8: 10190003; HUC 12: 101900030603 U.S. Geological Survey map(s). Cite scale & quad name: 1:24000 — Platteville USDA Natural Resources Conservation Service Soil Survey. Citation: National wetlands inventory map(s). Cite name: State/Local wetland inventory map(s): FEMA/FIRM maps: 100 -year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) Photographs: /1 Aerial (Name & Date): Google Earth, 1999-2019 or Other (Name & Date): Site photographs by consultant Previous determination(s). File no. and date of response letter: Applicable/supporting case law: Rapanos and Carabell cases. ■ 7 • ■ Applicable/supporting scientific literature: Other information (please specify): B. ADDITIONAL COMMENTS TO SUPPORT JD: 8 APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook. SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD): February 3, 2021 B. DISTRICT OFFICE, FILE NAME, AND NUMBER: Denver Regulatory Office, West Farm, NWO-2020-01166-DEN C. PROJECT LOCATION AND BACKGROUND INFORMATION: State: CO County/parish/borough: Weld County City: Platteville Center coordinates of site (lat/long in degree decimal format): Lat. 40.225274°N; Long.- 104.858926°W Universal Transverse Mercator: 13 512002.370926 E. 4452770.459333 N Name of nearest waterbody: South Platte River Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: South Platte River Name of watershed or Hydrologic Unit Code (HUC): HUC8: 10190003: HUC 12: 101900030603 Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request. Check if other sites (e.g., offsite mitigation sites, disposal sites, etc...) are associated with this action and are recorded on a different JD form. ■ D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL TIIAT APPLY): ►1 Office (Desk) Determination. Date: February 3, 2021 Field Determination. Date(s): August 26, 2020 SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION. There Are no "navigable waters of the U.S." within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area. [Required] Waters subject to the ebb and flow of the tide. Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain: ■ ■ B. CWA SECTION 404 DETERMINATION OF JURISDICTION. There Are "waters of the U.S." within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required] 1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): I TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs Non-RPWs that flow directly or indirectly into TNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs Impoundments of jurisdictional waters Isolated (interstate or intrastate) waters, including isolated wetlands ■ ■ ■ ■ ■ ■ • ■ b. Identify (estimate) size of waters of the U.S. in the review area: Non -wetland waters: linear feet: 3.712 width 3 (ft) and/or acres. Wetlands: acres. c. Limits (boundaries) of jurisdiction based on: Elevation of established OHWM (if known): Established by OHWM. 2. Non -regulated waters/wetlands (check if applicable):' Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain: ■ ' Boxes checked below shall be supported by completing the appropriate sections in Section III below. 2 For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least "seasonally" (e.g., typically 3 months). 3 Supporting documentation is presented in Section III.F. SECTION III: CWA ANALYSIS A. TNWs AND WETLANDS ADJACENT TO TNWs The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section III.A.I and Section III.D.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.1 and 2 and Section III.D.1.; otherwise, see Section III.B below. 1. TNW Identify TNW:. Summarize rationale supporting determination: 2. Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is "adjacent": B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY): This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met. The agencies will assert jurisdiction over non -navigable tributaries of TNWs where the tributaries are "relatively permanent waters" (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4. A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law. If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section I1I.B.1 for the tributary, Section III.B.2 for any onsite wetlands, and Section III.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section III.C below. 1. Characteristics of non-TNWs that flow directly or indirectly into TNW (i) General Area Conditions: Watershed size: Pick List Drainage area: Pick List Average annual rainfall: inches Average annual snowfall: inches (ii) Physical Characteristics: (a) Relationship with TNW: Tributary flows directly into TNW Tributary flows through Pick List tributaries before entering TNW. ■ Project waters are Pick List river miles from TNW. Project waters are Pick List river miles from RPW. Project waters are Pick List aerial (straight) miles from TNW. Project waters are Pick List aerial (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain Identify flow route to TNW5: Tributary stream order, if known: . Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West. 5 Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW. 2 (b) General Tributary Characteristics (check all that apply): Tributary is: ■ ■ ■ Natural Artificial (man-made). Explain: Manipulated (man -altered). Explain: Tributary properties with respect to top of bank (estimate): Average width: feet Average depth: feet Average side slopes: Pick List. Primary tributary substrate composition (check all that apply): ■ ■ ■ ■ Silts Cobbles Bedrock Other. Explain: ■ ■ ■ Sands Gravel Vegetation. Type/% cover: ■ ■ Concrete Muck Tributary condit_on/stability [e.g., highly eroding, sloughing banks]. Explain: Presence of run/riffle/pool complexes. Explain: . Tributary geometry: Pick List Tributary gradient (approximate average slope): % (c) Flow: Tributary provides for: Pick List Estimate average number of flow events in review area/year: Describe flow regime: Other information on duration and volume: Surface flow is: Pick List. Characteristics: . Subsurface flow: Pick List. Explain findings. ■ Dye (or other) test performed: Tributary has (check all that apply): Bed and banks OHWM6 (check all indicators that apply): clear, natural line impressed on the bank changes in the character of soil shelving vegetation matted down, bent, or absent leaf litter disturbed or washed away sediment deposition water staining other (list): Discontinuous OHWM.7 Explain: ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Pick List the presence of liner and debris destruction of terrestrial vegetation the presence of wrack line sediment sorting scour multiple observed or predicted flow events abrupt change in plant community If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply): ■ High Tide Line indicated by: oil or scum line along shore objects fine shell or debris deposits (foreshore) physical markings/characteristics tidal gauges other (list): ■ ■ ■ ■ ■ ■ Mean High Water Mark indicated by: survey to available datum; physical markings; vegetation lines/changes in vegetation types. ■ ■ ■ (iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain. Identify specific pollutants, if known: (iv) Biological Characteristics. Channel supports (check all that apply): GA natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody's flow regime (e.g., flow over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break. 'Ibid. 3 ■ ■ Riparian corridor. Characteristics (type, average width): Wetland fringe. Characteristics: . Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally -sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: ■ ■ ■ ■ 2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW (i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: acres Wetland type. Explain: . Wetland quality. Explain: Project wetlands cross or serve as state boundaries. Explain: (b) General Flow Relationship with Non-TNW: Flow is: Pick List. Explain: Surface flow is: Pick List Characteristics: Subsurface flow: Pick List. Explain findings: ■ Dye (or other) test performed: (c) Wetland Adjacency Determination with Non -NW: Directly abutting Not directly abutting Discrete wetland hydrologic connection. Explain: Ecological connection. Explain: Separated by berm/barrier. Explain: ■ ■ ■ ■ ■ (d) Proximity (Relationship) to TNW Project wetlands are Pick List river miles from TNW. Project waters are Pick List aerial (straight) miles from TNW. Flow is from: Pick List. Estimate approximate location of wetland as within the Pick List floodplain. (ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear, brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: . Identify specific pollutants, if known: (iii) Biological Characteristics. Wetland supports (check all that apply): Riparian buffer. Characteristics (type, average width): Vegetation type/percent cover. Explain: Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally -sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: ■ ■ ■ ■ ■ ■ ■ 3. Characteristics of all wetlands adjacent to the tributary (if any) All wetland(s) being considered in the cumulative analysis: Pick List Approximately ( ) acres in total are being considered in the cumulative analysis. For each wetland, specify the following: Directly abuts? (Y/N) Size (in acres) Directly abuts? (YIN) Size (in acres) Summarize overall biological, chemical and physical functions being performed: 4 C. SIGNIFICANT NEXUS DETERMINATION A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus. Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? • Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream foodwebs? • Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW? Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below: 1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section III.D: 2. Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: 3. Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: I). DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY): 1. 1'NWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: TNWs: linear feet width (ft), Or, acres. Wetlands adjacent to TNWs: acres. ■ ■ 2. RPWs that flow directly or indirectly into TNWs. Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: Historic aerial photography indicates that Feature C transmits flow to the South Platte River on a perennial basis. Flow originates from an irrigation pivot pump and flows generally north before emptying into the South Platte River at the north edge of the review area. This flow is relatively permanent and connects to a TNW; therefore, Feature C is a relatively permanent waterway and is therefore jurisdictional. Tributaries of TNW where tributaries have continuous flow "seasonally" (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section III.13. Provide rationale indicating that tributary flows seasonally: ■ Provide estimates for jurisdictional waters in the review area (check all that apply): ■ ■ Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: 3. Non-RPWs$ that flow directly or indirectly into TNWs. Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C. ■ 'See Footnote # 3. 5 Provide estimates for jurisdictional waters within the review area (check all that apply): ■ ■ Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: 4. Wetlands directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: ■ ■ ■ Wetlands directly abutting an RPW where tributaries typically flow "seasonally." Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: Provide acreage estimates for jurisdictional wetlands in the review area: acres. 5. Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C. ■ Provide acreage estimates for jurisdictional wetlands in the review area: acres. 6. Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C. ■ Provide estimates for jurisdictional wetlands in the review area: acres. 7. Impoundments of jurisdictional waters.9 As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional. ■ ■ ■ Demonstrate that impoundment was created from "waters of the U.S.," or Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below). E. ISOLATED [INTERSTATE OR INTRA-STATEI WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK ALL THAT APPLY): 10 ■ ■ ■ ■ ■ which are or could be used by interstate or foreign travelers for recreational or other purposes. from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. which are or could be used for industrial purposes by industries in interstate commerce. Interstate isolated waters. Explain: Other factors. Explain: Identify water body and summarize rationale supporting determination: Provide estimates for jurisdictional waters in the review area (check all that apply): ■ ■ ■ Tributary waters: linear feet width (ft). Other non -wetland waters: acres. Identify type(s) of waters: Wetlands: acres. • F. NON -JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY): '' To complete the analysis refer to the key in Section III. D.6 of the Instructional Guidebook. 10 Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos. 6 ■ ■ ■ ■ If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. Prior to the Jan 2001 Supreme Court decision in "SWANCC," the review area would have been regulated based solely on the "Migratory Bird Rule" (MBR). Waters do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction. Explain: Other: (explain, if not covered above): ■ • Provide acreage estimates for non jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply) Non -wetland waters (i.e., rivers, streams): linear feet width (ft). Lakes/ponds: acres. Other non -wetland waters: acres. List type of aquatic resource: Wetlands: acres. ■ ■ ■ ■ Provide acreage estimates for non jurisdictional waters in the review area that do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction (check all that apply): Non -wetland waters (i.e., rivers, streams): linear feet, width (ft). Lakes/ponds: acres. Other non -wetland waters: acres. List type of aquatic resource: Wetlands: acres. ■ ■ ■ ■ SECTION IV: DATA SOURCES. A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and requested, appropriately reference sources below): Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: Figure 1,LG Everist West Farm Surface Water Features: and Figure 2, General Location Map, Request for AJD, Savage and Savage., June 21, 2020 Data sheets prepared/submitted by or on behalf of the applicant/consultant. Office concurs with data sheets/delineation report. Office does not concur with data sheets/delineation report. Data sheets prepared by the Corps: Corps navigable waters' study: U.S. Geological Survey Hydrologic Atlas: ■ ■ ■ ■ ■ ■ ■ ■ ■ • ►1 • ■ ■ ■ USGS NHD data. USGS 8 and 12 digit HUC maps. HUC8: 10190003: HUC 12: 101900030603 U.S. Geological Survey map(s). Cite scale & quad name: 1:24000 — Platteville USDA Natural Resources Conservation Service Soil Survey. Citation: National wetlands inventory map(s). Cite name: State/Local wetland inventory map(s): FEMA/FIRM maps: 100 -year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) Photographs: Aerial (Name & Date): Google Earth, 1999-2019 or Other (Name & Date): Site photographs by consultant Previous determination(s). File no. and date of response letter: Applicable/supporting case law: Rapanos and Carabell cases. Applicable/supporting scientific literature: Other information (please specify): • B. ADDITIONAL COMMENTS TO SUPPORT JD: 7 NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS ANI) _ REQUEST : R APPEAL Applicant: LG Everist Inc. File Number: NWO-2020-01166-DEN Date: February 3, 2021 Attached is: See Section below INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission) A PROFFERED PERMIT (Standard Permit or Letter of permission) B PERMIT DENIAL C X APPROVED JURISDICTIONAL DETERMINATION D PRELIMINARY JURISDICTIONAL DETERMINATION F SECTION decision. http://www.usace.army.mil/Missions/CivilWorks/RegulatoryProgramandPermits/FederalRegulation.aspx I Additional - The following information identifies may your be found rights and in Corps options regulations regarding at 33 an CFR administrative Part 331, appeal or at of the above A: • • to the INITIAL ACCEPT: authorization. signature to OBJECT: the Your modify district appeal appeal permit permit objections the engineer on the the If If be having PROFFERED the permit permit, you permit you If modified Standard you must will received object to determined including in address send received be accordingly. the to received Permit a the future. you Standard PERMIT: all that a its permit a Letter of proffered or terms by the Upon your acceptance You the (Standard permit Permit, of and district receipt concerns, Permission must You permit conditions, should you of or complete of may engineer the (b) for may LOP) your (LOP), be your accept sign LOP letter, modify issued and Section because within reconsideration, the means you approved the the or as permit II of 60 permit previously object may that district of certain days this accept you jurisdictional document of engineer to to accept terms form the address as the the written. indicated and date LOP permit. and the and will some determinations return of return permit conditions After and this evaluate in the of Section your notice, evaluating it in your form to its work therein, your the objections, entirety, or B associated to district you below. is the objections your authorized. you district will and objections, engineer or may forfeit with (c) waive and engineer. request not the Your your for all may: the permit. modify final rights right (a) that B: PROFFERED PERMIT: You may accept or appeal the permit • • ACCEPT: authorization. signature to APPEAL: appeal on the If If the you permit, If Standard you received including received Permit a decline Standard a its Letter or terms acceptance Permit, of and Permission you conditions, of may the (LOP), LOP sign and the means you approved permit may that document accept you jurisdictional accept the and LOP the determinations return permit and it your in to the work its entirety, district associated is authorized. and engineer waive with the Your for all permit. final rights may form date appeal and of this sending the notice. you declined choose the form to permit to the under division the the proffered Corps engineer. of permit Engineers This (Standard form Administrative must or LOP) be received because Appeal by the of certain Process division by terms completing engineer and conditions within Section 60 therein, II days of of this the you C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by engineer completing within Section 60 II days of of the this date form of and this sending notice. the form to the division engineer. This form must be received by the division D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide • ACCEPT: date new of this information. You notice, do not means need that to notify you the accept Corps the approved to accept JD an in approved its entirety, JD. Failure and waive to all notify rights the to Corps appeal within the approved 60 days of JD. the • APPEAL: Appeal by the division Process If you by engineer disagree completing within with the Section 60 days approved II of of the this JD, form date you of this may and appeal sending notice. the the approved form to the JD division under the Corps engineer. of This Engineers form Administrative must be received E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps regarding the preliminary appealed), consideration JD. by contacting by The the Preliminary Corps the to Corps reevaluate JD district is not the appealable. for JD. further If instruction. you wish, Also you may request you may provide an approved new information JD (which may for further be SECTION II - REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial proffered permit in clear concise statements. You may attach additional information to this form to clarify where your reasons or objections are addressed in the administrative record.) ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the record of the appeal conference or meeting, and any supplemental information that the review officer has determined is needed to clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record. However, you may provide additional information to clarify the location of information that is already in the administrative record. POINT OF CONTACT FOR QUESTIONS OR INFORMATION: If you have questions regarding this decision and/or the appeal process you may contact: US Army Corps of Engineers, Denver Regulatory Office Attn: Nicholas Franke, Regulatory Project Manager 9307 S. Wadsworth Blvd Littleton, CO 80128 Telephone (303) 979-4120 Nicholas.A.Franke@usace.army.mil If you only have questions regarding the appeal process you may also contact: US Army Corps of Engineers, Northwestern Division Attn: Melinda Larsen, Regulatory Appeals Review Officer 1201 NE Lloyd Blvd Ste 400 Portland, OR 97232-1257 Telephone (503) 808-3888 Melinda.M.Larsen@usace.army.mil RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15 day notice of any site investigation, and will have the opportunity to participate in all site investigations. Signature of appellant or agent. Date: Telephone number: Eiviroineit, Inc. LARRY E. O'BRIAN FOUNDER STEVAN L. O'BRIAN PRESIDENT May 24, 2023 Weld County Clerk to the Board Board of County Commissioners Office 1150 "0" Street Greeley, Colorado 80631 Re: L.G. Everist, Inc. - West Farm Reservoirs M-2023-048 Adequacy Response - 01 Packet Dear Sir/Madam: 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 We are delivering to you here with a copy of the Adequacy response and supporting exhibits for the L.G. Everist, Inc, - West Farm Reservoirs application filed with you on November 17, 2022. Please place this packet with the original book. The original is on file with the Division of Reclamation, Mining & Safety. This copy of the permit application adequacy response is delivered to you pursuant to 34-32.5-112(9)(a), Colorado Revised Statutes 1995, as amended, which states in part: .... the applicant shall place a copy of such application for public inspection at the office of the Board and Office of the County Clerk and Recorder of the County in which the affected land is located. This packet must be kept with the book for public review until the application has been approved by the Division. We will contact you once it is and make arrangements to pickup this copy. Please acknowledge receipt of the copy of the permit adequacy response by signing in the appropriate space provided below and returning one copy of this letter to the person delivering it. Yours truly, ENVIRONMENT, INC. Stevan L. O'Brian enclosure RECEIVED THIS DAY OF , 20, one copy of the adequacy response 01 packet for above referenced mine. By Weld County Clerk to the Board RECEIVED A1 2 5 2023 WELD COUNTY COMMISSIONERS Pub I :C Rev ;e(,) O6 /12/23 CC: PL(TP/MN/DA/Ko/DA) PW(cH/ER/CK/Do/ON)� 06/07/23 2023-1623 Ei)viroUn)ei)t, Iqc. LARRY E. O'BRIAN FOUNDER STEVAN L. O'BRIAN PRESIDENT May 23, 2023 Mr. Eric Scott Division of Reclamation, Mining & Safety 1313 Sherman St., #215 Denver, CO 80215 Dear Eric; RE: L.6. Everist, Inc. West Farm Reservoirs, Permit # M-2022-048 Adequacy Response #1 7985 VANCE DRIVE, SUITE 205A ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 On behalf of our client L.6. Everist, Inc., I will respond to your February 6, 2023 adequacy review letter in the order and number format presented in that document. I have also provided responses to the State Engineers Letter, and the Colorado Parks and Wildlife letter and the Colorado Open Lands (Abbett Centennial Farm) letter. During the public comment period we found a number of addresses for ROW and Structure owners that did not match the original list be obtained from the source of record. I updated Exhibit O, Exhibit S and the Lists on Map Exhibits C & C-1 to match the mailing lists used for the owner notification and structure agreement mailings. EXHIBIT C - Pre -mining and Mining Plan Maps) of Affected Lands (Rule 6.4.3): 1) Parcels owned by LG Everist and Town of Platteville within 200' of the eastern permit boundary have not been identified with other adjacent property owners on the current existing conditions map - please revise as needed. L.G. Everist owns all the property within 200 feet of the permit line along the east side except the 40 foot wide ROW's on both side of CR 32.5. I added the ownership names to the missing areas south of CR 32.5 and moved the Town of Platteville name to the east end of the road. To make this it clearer on the maps, I fixed the 200 foot boundary line so it is clearer on the maps and added dimensions on the Map Exhibits. As a side note, I ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 2 ADEQUACY RESPONSE 01 found that the notes on the C map did not match what was on the map so it was moved to the Exhibit C-1 Mining Plan Map. 2) Information for structures within the permit and within 200' of the permit as listed on Exhibit C-1 Mining Plan Map should be identified on the provided Exhibit C-2 Structures Map. All structures listed should be identified on this map so that they may be correlated to the correct structure owner. The structure information list on Map Exhibit C-1 -Mining Plan Map was moved to Map Exhibit C-2. This structures list has key letters added to each owner that corresponds to the location of the structure and their owners marked on the map. 3) The surface drainage corridor which conveys irrigation return flows from the adjacent property to the south, back to the South Platte River, as observed during the pre -operational inspection, has not been shown on the existing conditions map - Please revise as needed. I have hatched and labeled the return flow drainages so they are easily identified on the Map Exhibit C. 4) No description of existing vegetation has been provided as required by (e). I added the vegetation information Exhibit J to Map Exhibit C. 5) Please show the location of the 50 acre Plant Site as described on the Mining Plan Map, including the location of the gravel washing/processing area, concrete batch plant, asphalt plant and recycling facility. Sufficient detail will need to be provided for these facilities so that an accurate bond for removal and reclamation can be calculated. The 50 acre Plant Site envelope is show as the \\\ hatched area in Phase 4 on Map Exhibit C-1. L.G. Everist does not have a specific Plant Site Layout at this time, and it is unreasonable to require this as it hinders LGE's flexibility to operate the mine if they have to file a change of plans every time they make an operations change. to the Plant Site area that is already designated in Phase 4 on Map Exhibit C-1 is where the various processing plants and stockpile areas will be located. For bonding purposes, the gravel processing plant, scales, asphalt and concrete plants will be portable equipment and would be removed if the mine failed. We have included a cost to remove an estimated 300 cu-yds of concrete foundations from the Plant Site to cover the temporary foundations for the listed equipment. When mining is scheduled to begin, this will increase to 500 cubic yards to cover all foundations, including the conveyor crossing and runs as Shown on Table L4 in the cost estimate. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 3 ADEQUACY RESPONSE 01 6) Please show the locations and expected volumes of the topsoil and overburden stockpiles on the Mining Plan map. Please note that the rule requires segregation of Topsoil from Overburden and that the topsoil be maintained for use in reclamation. Stockpiles located within the floodplain should be oriented parallel to flood flows. Map Exhibit C-1 - Mining Plan Map has the approximate location of soil berms in all 4 mining Phases. Where applicable, they have been located outside the floodplain and or parallel to the river's flow as you suggested or along the roads in Phases 3 & 4. They are labeled as, "TEMPORARY GROWTH MEDIUM BERMS" or "SOIL BERM". The volume of material in each pile will far exceed the amount needed to resoil the areas around the site. Any excess material will be removed through sales or used to create liners or slopes in the reservoirs. The estimated approximate locations and volumes shown on the map may change as mining progresses. As the operations get into full swing, the plan is to replace soil as it is stripped, back on the areas that are ready for resoiling so it is handled only once. L.G. Everist, Inc. is aware the overburden and topsoil (growth medium) must be segregated. EXHIBIT D - Mining Plan (Rule 6.4.4): 7) Please describe in detail, and show on the mining plan and reclamation plan maps, how irrigation return flow from the adjacent property to the south will be preserved/conveyed to the South Platte River during and after mining of Phase 1. The plan is to relocate the irrigation return flow that enters the permit area from the Abbett Trust Farm, so it flows along the south side of the liner and connects to an existing ditch that parallels the west side of the old railroad embankment, then west along CR 32.5 to the existing culvert that crosses under the road, allowing it to return to the river north of the road. The location was shown on the Reclamation Map but I have enhanced the line so it shows better. This may also be used as the return flow for the ground water elevation drain depending on how the land slopes in the southeast corner of Stage 1. 8) If two different types of reclamation will be utilized to achieve the final interior reservoir slopes of 3H:1 V (backfill from %H:1 V to 3H:1 V vs. cut/fill) you will need to clearly specify on the mining and reclamation plan maps where each of these methods will be used and what the required bench width will be where cut/fill is proposed. Please also remove the statement on P22 about mining to final slopes if this is not the proposed plan. LGE has determined they will use the backfill method for creating the final slopes in the reservoir areas, The material to be used for this will be a combination of overburden and ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 4 ADEQUACY RESPONSE 01 shale from the mine floor that is suitable of that purpose. The Mining and Reclamation Plans and Exhibit L - Reclamation Cost Estimate have been revised to explain this change. 9) The last sentence on P13 states that "...the responsibility for weed control and agricultural area maintenance is retained by the landowners". Please remove this statement. Weed control, site maintenance, and accountability for other activities occurring within the permit area, is the responsibility of the pennittee. This statement will also need to be removed from P21. LGE understands they are the responsible party for activities on the permit area. These statements have been removed from Pages 13 & 21 and copies of the revised pages are enclosed. 10) Changes to the mining sequence shown in the provided plan will need to be approved through the Technical Revision process - please acknowledge. LGE understands they are responsible for filing a Technical Revision if any changes are made to the mining sequences in the provided plan. 11) The operator will be required to remove all constructed berms unless otherwise specified in the reclamation plan during final reclamation - please acknowledge. L.G. Everist, Inc. agrees that all berms constructed along the setbacks or the mining area will be removed during reclamation. 12) Please provide USACE documentation supporting the statement on P14 of the provided mining plan, as well as in Exhibits J and M, that no jurisdictional wetlands are present on the site. This statement also seems to conflict with the following sentence which states that the irrigation return flow ditch on the west side of Phases 1 and 2 IS jurisdictional and must remain. Please clarify. Attached is a copy of the Jurisdictional Determination (JD) showing there are no wetlands on the permit area. There are 3 ditches that have been determined to be jurisdictional and would need a permit if disturbed. These ditches are not considered wetlands but rather "Water of the US". The western ditch, which flows between Phases 1 and 4 (south of CR 32.5) and Phases 2 and 3 (north of CR 32.5) will remain along the base of the upland area. The eastern two ditches, run parallel to the old railroad embankment (south of CR 32.5), and serve as part of the irrigation return flow drain for the Abbett Farm to the south. The southern part of the irrigation return ditch is not jurisdictional for the first 800 feet ± from the south permit boundary. This 800 foot section is dry unless irrigation is taking place on the property to the south. LGE has received a USACE Regional General Permit 5 for relocation of a section of the eastern ditch. This Corps approval allows LGE to relocate the ditch outside the proposed slurry ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 5 ADEQUACY RESPONSE 01 wall. (A copy of the Corps approval letter dated 05/10/23 is enclosed, "RE: Regional General Permit Verification - Corps File # NWO-2020-01166-bEN, West Farm, Weld County, Colorado".) Comments 13-16 are based on the guidance provided by the Urban Drainage and Flood Control District - Technical Review Guidelines for Gravel Mining and Water Storage Activities Within or Adjacent to the 100 Year Floodplain. 13) From section 2.6.1: "When the river is allowed to maintain an existing unstable alignment, and no bank protection is provided beyond the necessary revegetation, the minimum allowable top width of riverside berms will be 400 feet. This is the maximum setback requirement imposed on gravel mining operators." "When the river is left in an existing unstable alignment and no riverbank protection is provided, but pitside slope protection is provided in accordance with the requirements of Section 2.4- Pitside Bank Protection, the allowable minimum top width will be 300 feet." Please adjust the mining setbacks shown for Phase 2 to be a minimum of 300 feet from the river. Revisions have been made to the Exhibit C-1 Mining Plan Map, Figure E-1 and the Exhibit F - Reclamation Plan Map showing the required 300 foot setback from the top of the slope to the adjacent river bank. As we discussed, LGE will mine closer than 300 feet from the South Platte River in Phase 2 but no closer than 215 feet since the Slurry wall will be installed on a 200 ft. setback. This will be done in 500 ft. sections that stay open no more than 12 months. Backfilling will include filling in the 85 foot wide section from the slurry wall setback to the Top of Slope (TOS) to its original elevation so there is 300 feet of setback from the river and construct the bank slopes into the reservoir. The newly filled area will be armored and seeded. Exhibits b and E have been revised to explain the mining and backfilling plans proposed. 14) For Phase 1, no pitside slope protection has been proposed, therefore, please adjust the mining setback from the river to be no less than 400'. If you wish to use a 300' setback for Phase 1, provide pitside slope protection in the mining and reclamation plans for that phase. We have added armoring in Phase 1 where the river is within 400 feet of the Top of Slope (TOS) along the east side of the Phase. This was added to the Mining and Reclamation Maps. It is approximately 1305 feet long and will require approximately 3,080 yards or armoring materials. Note that at its closest point, the river is still 347 feet away from the top of slope and east of the railroad embankment that was not overtopped in 2013 by flooding. 15) Due to the immediate and direct connection between the irrigation return flow ditch on the west side of Phases 1 and 2 and the South Platte River, the west sides of the Phase 1 and 2 reservoirs should also have pitside slope protection in ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 6 ADEQUACY RESPONSE 01 areas where they are adjacent to this ditch. Please revise mining and reclamation plans as needed. Per our discussion, LGE does not believe this irrigation return flow ditch needs armoring south of CR 32.5 because no flood water reached it during the 2013 flood event. This ditch was constructed by a previous land owner that excavated a trench into the groundwater table to create a slough for hunting ducks. This trench started south of CR 32.5 and extended to the river and the only reason there is water flow is because it has intercepted the ground water table. LGE will armor the reservoir bank in Phase 2 along this ditch (on the north side of CR 32.5) as suggested by the bivision. Map Exhibits C-1, F, and Exhibits b, E and L have been revised to reflect this change. 16) The area between Phase 1 and Phase 2 containing County Road 32.5 is considered by DRMS to be a "Type B Lateral Benn" as described in section 2.5.2. As such, the minimum berm widths given in sections 2.7.2.1 and 2.7.2.2 will apply. These are: 350 feet minimum width for an unprotected berm, and 200 feet minimum width if the berm is protected in accordance with the requirements of section 2.5.3. (The current 160' width proposed is well below the requirement for either scenario) Please modify the mining and reclamation plans accordingly to reflect these setback requirements. Per your suggestion, we have increased the setbacks north and south of CR 32.5 by 20 feet each, thus making the distance between the TOS's 200 feet and added 1,390 feet of armoring to the north side. The Mining and Reclamation maps have been revised showing the location of the armoring and the widening of the Lateral Berm. A complete copy of the revised Exhibit b - Mining Plan as discussed in this section is enclosed. EXHIBIT E - Reclamation Plan (Rule 6.4.5): 17) As stated in item #8, if two different types of slope reconstruction will be utilized to achieve 3H:1 V interior slopes for reclamation, you will need to clearly identify where each type will be used. Please modify the reclamation plan and reclamation plan map accordingly. As noted in adequacy item # 8, they will mine vertical and backfill the slope areas, instead of using a cut/fill method for all exterior slopes around the reservoirs. For bonding purposes, the internal working face slopes would be sloped using a cut/fill method if mining ended prematurely. The Reclamation Plan and Map Exhibit F and Exhibit L have been revised to reflect this change. 18) Please remove the statement on the top of P23 "There are no drill or auger holes on the land." There are several monitoring wells already present in the interior of the permit area. • ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 7 ADEQUACY RESPONSE 01 Page 23 has been revised by removing this text. A copy of the revised Exhibit E - Reclamation Plan is enclosed. 19) Note #6 on the provided bank armoring plan states that the armoring will be covered with a 6" layer of growth medium and seeded, however the reclamation plan and text on P114 calls for 10"12" of topsoil to be replaced prior to seeding. Please revise Note #6 for consistency as needed. Thanks for pointing this out. Note #6 has been revised to match the 10-12 inches of topsoil cover. A copy of the Bank Armoring Plan with a revised Figure 1 is enclosed. 20) DRMS notes that the Minimum allowable Factor of Safety (FOS) for the proposed bank armoring is 1.25 and the calculated FOS for the armoring plan provided is 1.26. You may wish to consider revising the bank armoring plan to allow for more than a 0.01 margin of error in Factor of Safety. It seems a little odd to me to provide a FOS for the FOS. The FOS formula requires an average minimum size be used for b50. The size of material committed to in the Bank Armoring plan was 9 to 15 inches with fines mixed in. Twelve (12) inches was chosen, as it is the average size proposed, for use in the formula so the minimum FOS could be calculated. If the average overall riprap size is increased to 13.5 inch average, the FO5=1.30. EXHIBIT F - Reclamation Plan Map (Rule 6.4.6): 21) The reclamation plan map will need to be modified as necessary for consistency and accuracy when addressing adequacy revisions. A copy of the revised Exhibit F - Reclamation Plan Map is enclosed. EXHIBIT G - Water Information (Rule 6.4.7): 22) The applicant will need to provide a site characterization and groundwater monitoring plan, including at least five quarters of baseline/background water level and groundwater analytical data, sufficient to demonstrate compliance with the requirements of the "Water Quality Control Commission Regulation No. 41 - The Basic Standards for Groundwater" for the life of the proposed operation. Please note that permanent monitoring wells and Point of Compliance (POC) wells should be placed where they will not be mined through. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 8 ADEQUACY RESPONSE 01 Attached is a Water Quality Monitoring Plan prepared by Molen and Associates. The plan includes installing 7 additional monitoring well outside the mining area and a list of compounds that will be tested for in the first 5 quarters. 23) The Mining Plan as submitted only includes a 15 foot setback from the permit boundary/utility corridor to the slung wall on the south side of Phase 1, and does not include any provisions such as a French drain, to allow groundwater to flow unimpeded around the proposed slurry wall. No groundwater modeling data has been provided to demonstrate that the construction of this slurry wall will not result in excessive groundwater mounding on the adjacent property to the south of Phase 1, or adverse impacts to the irrigation return flows to the South Platte River which currently flow through Phase 1. The actual setback is 15 feet from the ANG gas line 50' ROW and 40 feet from the actual gas line. The south line of the ROW is 18 feet north of the property line so there is 80 feet from the permit line to the liner. The ROW agreement does not limit the land owner's use of that area, so the necessary precautions will need to be taken to install a ground water elevation drain if needed and/or the irrigation return flow ditch. Please provide a detailed groundwater model illustrating the projected impacts to groundwater levels adjacent to the site after installation of the proposed slurry walls. This should include a groundwater contour map showing projected depths to groundwater and any mounding or shadowing on properties adjacent to the proposed permit area. If the modeling predicts excessive groundwater mounding on adjacent property, the applicant will need to provide a plan to minimize the impacts and maintain the prevailing hydrologic balance during and after mining activity. Attached is a detailed ground water model prepared by Schnabel Engineering addressing your suggested parameters. Based on the historic data available for the site, please propose trigger levels for groundwater level mitigation and where the monitoring points will be located. For example: excessive mounding requiring mitigation could be a groundwater level increase of over 2 feet from baseline, or groundwater levels within 4 feet of the ground surface measured at the property boundary. A mitigation plan was addressed in Exhibit G - Water, on pages 29 & 30. It was based on the average LGE has seen over many years mining gravel in the South Platte River valley. It has been revised using information from the Ground Water Model prepared by Schnabel that is site specific. The Schnabel model predicts a change of as much as 3 feet along the southwest and west sides of the Permit area in an area where it is 16 plus feet to the water table and a decrease of as much as 1.5 feet immediately along the river in the north central part of the permit area. ENVIRONMENT, INC_ L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 9 ADEQUACY RESPONSE 01 The important area for mitigation lies along the eastern section of the south permit boundary line - the area along the Abbett Farms land. Exhibit G - Water has been revised and updated to include a mitigation plan based on the data collected to date and the Groundwater Model prepared by Schnabel. 24) Please provide proposed locations for installation of additional groundwater monitoring wells outside of the proposed slurry wall along the south side of Phase 1 to monitor for excessive mounding on the south side of Phase 1. Map Exhibit 6-1- Water wells within 200 ft. map shows the locations of the 7 new monitoring wells to be installed outside the slurry walls for water quality testing and groundwater level collection. Wells 1, 2, 5 and 7 will also be sampled. The Molen report suggests collecting 5 quarters of water quality data from the 11 wells, which will be used to determine what chemical compounds need to be tested for, and as background for future comparisons. Once mining begins, the 11 wells will be tested yearly for the compounds determined to be relevant for this mine. 25) Please remove the statement on P28 that "There are no ditches that cross the property." Page 28 has been revised by removing this text. A copy of the revised page is enclosed. 26) Please remove the reference to the Ragsdale site in the first sentence of P32. Page 32 has been revised by replacing Ragsdale with West Farms. Thank you for noting this. A copy of the revised page is enclosed. 27) Please provide trend -line water level data charts for the existing 7 wells over the period of monitoring based on either: depth to groundwater from ground surface, or groundwater elevation based on surveyed well elevation data. Attached are the 7 graphs for the monitoring wells showing the surveyed ground elevation for each well, the data collected from 2019 to present and the average elevation line based on the last date a well was measured. The 2 foot plus or minus mitigation lines are also shown. A copy of the revised Exhibit 6 - Water is attached with the changes noted above. EXHIBIT H - Wildlife Information (Rule 6.4.8): 28) Please fully review and address the recommendations provided by Colorado Parks and Wildlife in their comment letter dated December 28, 2022. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 10 ADEQUACY RESPONSE 01 Responses to the CPW letter are presented on page 14 of this response. EXHIBIT L - Reclamation Costs (Rule 6.4.12): 29) DRMS will evaluate the reclamation bond calculation when the other adequacy issues have been resolved and the appropriate revisions made, however, the following items were noted in the initial review which you may want to address at this time. Why are there 26.42 acres listed as "undisturbed" in Stage A? It may be useful to show acreage breakdowns on the reclamation plan map. This is because of the total 76.42 acres in Phase 4 only 50 would be disturbed by the Plant Site until mining starts in Phase 4. Included on page 26 of the Reclamation Plan, Figure E-1, is a color rendition of how the site will be reclaimed. This sketch shows the reservoirs, the areas to be resoiled and revegetated and the undisturbed area for each Phase of the operation. Table L does not include any costs for backfilling or other reclamation of fresh water or sediment ponds. Thank you for catching this. Exhibit L noted it would need to be done but we forgot to include a cost. An estimate of 20,000 cy is given for backfilling approximately 6 acres of settling pond area, however, 20,000 cy would only fill a 6 acre excavation to a depth of approximately 2 feet. What is the proposed volume of the settling ponds that would need to be backfilled? I have corrected this and included a cost to backfill 6 acres at an average depth of 15 feet. The cost to resoil and revegetate this area is included in the table. No cost for demolition/hauling/disposal of any processing facilities or conveyor structures/crossings has been provided, please address. As explained earlier in this response, for bonding purposes, the gravel processing plant, scales, asphalt and concrete plants are portable equipment and would be removed if the mine failed so the Division would not need to remove them. We did not include the cost on Table L to remove conveyor supports or crossing foundations since the first one would not be built until mining moved into Phase 2. I have included a cost to remove an estimated 500 cu-yds of concrete foundations on Table L4 to cover the temporary foundations for the listed equipment and conveyor crossings. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 EXHIBIT M - Other Permits and Licenses (Rule 6.4.13): Will County permitting be required for future conveyor crossing(s) ? PAGE 11 ADEQUACY RESPONSE 01 No, this site is located in the Town of Platteville and CR 32.5 is a Town street. When the annexation agreement was approved in December 2020 the proposed conveyor crossings and equipment crossings were approved as part of that agreement. When the final Development Plan is approved LGE will make sure they are included and allowed. EXHIBIT S - Permanent Man -Made Structures (Rule 6.4.19): During review of the south line setback, we found that the gas line owned by Snyder Oil has been abandoned and the north -south section that is west and parallel to the old railroad embankment was physically removed. In addition, early this month Kerr-McGee began to plug the north well (West Farm 4-14A) in Phase 3 and will remove it and the associated gas feeder line. These structures have been removed for all maps or if abandoned are labeled as such on Map Exhibit C-2 Structures. Copies of the 3 structure agreement received as of this date are enclosed for the file. If more are received at a later date they will be provided for the file. 30) Please make sure that any adjustments made to the setbacks, armoring, and interior pit sloping methods made to the proposed mining and reclamation plans through the adequacy process are accurately reflected in the slope stability analysis provided, and/or provide a discussion as to why the submitted analysis is still valid. The existing analysis was prepared to show that the Factors of Safety are to the closest structure, in this case the slurry wall. Since the slurry walls are within the permit area the FOS for the permit boundary or any structures outside the Slurry walls would be within the FOS minimums required. Any changes to the setback or the interior pit slopes would have no impact to the FOS provided in the Slope Analysis. Additional Information: You will also need to provide the Division with proof of notice publication as well as proof of notice to surrounding property owners within 200' of the permit. Attached are copies of the return receipt cards for the notices to surrounding property owners within 200' that have been received to date. L.G. Everist, Inc. has not received 3 return receipts back, so we printed the tracking information for those items and provided a copy of the mailing receipts for cross reference. Attached is a copy of the Proof of Publication. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 12 ADEQUACY RESPONSE 01 Any letters from other commenting agencies/entities received by the Division for this permit to date are available for review through the imaged document data link provided below, or through the DRMS website. http://www.colorado.gov/pacific/drms/data-search OFFICE OF THE STATE ENGINEER L.G. Everist, Inc. understands the requirement for obtaining a well permit and preparing a Substitute Water Supply Plan for this mine. This will be done prior to exposing ground water. A copy of the permit and SWSP will be provided to the Division for the File. The SWSP will remain in effect until the proposed reservoir liners are approved and all lagged depletions have been met. L.G. Everist, Inc. will follow all plugging and abandonment requirements for any wells removed during mining. An abandonment report will be filed for each well as needed. L.G. Everist, Inc. understands the issue with groundwater mounding, shadowing and return flows associated with liners around reservoirs. The attached groundwater impact report addresses how the company plans to mitigate these concerns by installing a french drain or ground water trench along the up gradient (south) side to regulate the ground water elevation to historic maximums and divert the water back to the river system. In addition, the 4 reservoirs are not linked as one big liner but rather have a 200+ foot wide east to west corridor and a north to south corridor that varies from 85 to 245 feet wide where water that backs up along the west and south sides will return to the river across the mine site. There are no adjoining reservoirs and the site is flanked on the east and north side by the South Platte River. The river acts as a water barrier so any adjoining properties will not be impacted by draw down (shadowing). We believe the temporary impacts that may slow the groundwater flow around the liners will have little impact on the system and will be resolved once the ground water levels stabilize. L.G. Everist, Inc. will comply with the requirement to release any out of priority stormwater that collects in the mine within 72 hours or provided for the evaporative loss in the SWSP if not released. Dewatering will be taking place during mining, so any stormwater will be discharged under the MPS Permit to be obtained from Colorado Department of Health and Environment - Water Quality Control Division. COLORADO PARKS AND WILDLIFE L.G. Everist, Inc. wishes to thank Mr. Brandon Marette for taking time to review the permit and provided the information in his 12/28/2022 comment e-mail. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 13 ADEQUACY RESPONSE 01 AVOIDANCE In this section of their comments they suggest avoiding any of the high priority habitats (HPH) shown on the map they provided. It is not possible for this project to avoid those areas entirely as they appear to cover the entire site. Portions of each HPH will not be disturbed as those areas cover sections that will not be mined. A 200 foot buffer along the river will prevent impacts to the aquatic species area and still provide a deer migration corridor. The suggestion to delay construction startup between December 1 and April is not needed since the slow development of the mine and the abundance of undisturbed area surrounding the mine site will provide area for the wildlife to relocate and utilize as the mine develops. We believe this minimizes the long term impacts mining will have on the wildlife using the property. L.G. Everist, Inc., retained Savage and Savage to investigate what needs to be done in the short and long terms to mitigate impacts to wildlife from the mine. They performed a nest survey on November 11 and 30, 2021 and determined there are no raptor or eagle nests within or immediately adjacent to the mine perimeter. The closest eagle nest was 1.3 miles SE of the mine perimeter near HWY 66 and an red -tail hawk nest approximately 500 feet south of the perimeter. In addition, they report there is no Preble's meadow jumping mouse habitat or Ute Orchids on the mine area. There were no wetlands identified on the mine site as confirmed by the JD issued in 2021 as discussed above. CPW suggests leaving the mature cottonwood trees along the river. The Savage & Savage report explains that "A riparian woodland community approximately 75 feet in average width of plains cottonwoods (Populus deltoides) dominates the riparian corridor immediately adjacent to the South Platte River. This riparian corridor is dominated by mature cottonwoods with a sparse to moderate herbaceous understory component. Remaining vegetation of the project site is characteristic of managed agricultural fields and livestock grazing lands. There is no notable overstory or shrubby understory, though a few individual trees are found along the irrigation ditches traversing the site." The majority of cottonwood trees on this permit area are not in the permit, but rather in the setback that was left along the river, so will not be disturbed by L.G. Everist. The only trees that will be removed are those few that are within the active mining areas. A USACE Jurisdictional Determination (JD) (NWO-2020-01166-DEN, West Farm dated February 3, 2021, stated that only 3 water features (ditches) were jurisdictional and "All other aquatic resources within the review area are not jurisdictional." (copy attached) This included the cattail infested areas along irrigation return flows, depressions that collect irrigation water and internal ditches. In other words, there are no wetlands on the mine site that will be disturbed by mining. A nest survey will be conducted if tree removal occurs between April 1 and August 31 of any given year. If a bird nest is found, the tree will not be removed until the nest is abandoned for the year. If a prairie dog colony will be disturbed between March 15 and August 31, a Borrowing owl survey will be completed prior to working in the area. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 14 ADEQUACY RESPONSE 01 MINIMIZATION A weed control plan was submitted in the original application and the use of native species for revegetation was also provided for in the Reclamation Plan. There will always be sloped areas around the excavated areas to provide escape ramps for wildlife if they enter the excavation. The existing wire fencing will continue to be used at the mine. At this time there is 3 strand wire fence around most of the permit area, it will be fixed and maintained as mining progresses to prevent livestock from entering the mining area but still allow the deer to move thru the areas as they currently do. COLORADO OPEN LANDS (ABBETT CENTENNIAL FARM) When reviewing COL'S comment letter we believe they raised 7 concerns that have been addressed in our responses to the Divisions Adequacy Review. We have pulled sections of the comments from their letter to address and respond below. Their complete comment letter can be reviewed in the file. 1. 'Any changes to the groundwater level or property's irrigation due to the neighboring mining operation will negatively impact the conservation values on the conservation easement properly." LGE understands this concern and is preparing a study to establish background information to be able to react and monitor the impacts of the slurry wall on the Abbett Farm property. Information in Exhibit & - Water explains how the company will react if there is evidence of groundwater changes impacting off -site areas. The Groundwater study has been prepared with recommendations that will be implemented as the liner is installed to mitigate or prevent impacts to the groundwater elevation behind the liner. 2. "...we believe the proposed slurry wall construction will change the groundwater levels on the Abbett Centennial Farm property." The ground water report prepared by Schnable, and submitted with this response addresses these concerns. The mitigation plan proposed in Exhibit G - Water explains how LGE will determine what actions will be needed if this occurs. 3. "Given that the proposed slurry wall construction will be 15 feet away from the permit/affected lines, any groundwater mounding will negatively impact the conservation easement and affect the soil quality on Abbett Centennial Farm "We would like additional monitoring wells constructed along the property boundary to monitor for groundwater level changes and that the operator ensures that the groundwater mounding does not occur or impact the Abbett Centennial Farm." ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 15 ADEQUACY RESPONSE 01 With all the current structures along the south property line, the actual minimum distance of the slurry wall will be 80 feet from the property line. (There is a 50 ft. wide easement for a high-pressure gasline located 15 ft north of the property line, plus the 15 ft. setback from the north side of the ROW equals 80 ft.) This leaves adequate room to install any groundwater drain feature in this 80 feet. Our engineer recommended installing an additional 2 Monitoring wells along the south side of the permit area as shown on the revised Figure G-1 - Wells, submitted with this response. We also have provided a groundwater mitigation plan in Exhibit G - Water intended to provide a way to work through an unforeseen increase or decrease in the groundwater elevation over and above the groundwater drain feature. There is no way we can totally ensure there will never be a groundwater elevation change, only that we will make sure it is not caused by our facility. 4. "...we are concerned about the surface disturbance..." "During mining operations and construction, we suggest that the operator mitigate dust impacts and ensure that additional soil does not blow onto the Abbett Centennial Farm." Prior to commencement of mining the necessary Air Pollution Emissions Permit and dust control plan will be obtained from the Colorado Department of Health and Environment. The operator will reseed disturbed areas, and growth medium stockpiles as soon as they are ready. The use of water on roads and at plant sites is intended to reduce and control dust at the mine. In addition, once the mine is opened, the surface will become gravel that is less susceptible to wind-blown dust than the surrounding agricultural fields that exist there now. 5. ":.. we request that the operator repair the fence line and fence out the cattle. Repairing the fence will ensure the operator does not harm the cattle if they escape Abbett Centennial Farm." Fence maintenance and installation is a neighbor issue, not a reclamation or MLRB permit issue. With that said, L.G. Everist, Inc. strives to be a good neighbor and will work with Abbett Farm to keep cattle out of the mining areas. 6. "The mining operation may change the irrigation pathway of water along the northern portion of Abbett Centennial Farm by blocking water leaving the Abbett Centennial Farm that traditionally enters the north property as part of its traditional return flow." The plan has always been to re -channel the irrigation return ditch so it flows around the Phase 1 reservoir. The new ditch will be sized to assure it can carry any water entering the mine from the south so it can be returned to the river north of CR 32.5. Please see the response to the Division's item 12 for more details. ENVIRONMENT, INC. L.G. EVERIST, INC. - WEST FARM RESERVOIR MAY 23, 2023 PAGE 16 ADEQUACY RESPONSE 01 7. "Finally, we are concerned about the introduction and proliferation of noxious weeds on the Abbett Centennial Farm as result of the mining operation." LGE, has prepared and filed with the Division a Weed Control Plan for this mining operation. The weed plan will be implemented and carried out throughout the life of the mine and until reclamation is successful. The plan uses various controls and maintenance (mowing and spraying weeds) to ensure that weeds are controlled or eliminated as per state and county noxious weed guidance., I hope these responses have addressed the adequacy questions you had. I will place a copy of this packet with the Weld County Clerk's office as required. If you have any questions please call. LIST OF ATTACHMENTS TO THIS RESPONSE: Exhibit C - Pre Mining Map - revised Exhibit C-1 - Mining Plan Map - revised Exhibit C-2 - Structures - revised Mining Plan & Timetable - revised Redamation Plan & Timetable & Figure E-1- revised Exhibit F - Reclamation Map - revised Exhibit G - Water - revised • Table G-1 - Water wells within 200'. Table G-2 - Monitoring well data thru 3-2023 - revised Map Exhibit G-1 - Wells - revised Well Graphs for MW#1 thru MW#7 - new • Groundwater analysis - new Water Quality monitoring Plan - new 5iriterely, Environment, Inc Stevan L. O'Brian President cc L.G. Everist, Inc. Weld County Clerk file Exhibit L - Reclamation costs - revised Exhibit O - Owners of Record - revised Exhibit S - Permanent Man-made Structures 3 - Signed Structure agreements Central Weld County Water District, Magness, Town of Platteville Bank Armoring Plan revised Adjoining Landowner Notice Receipts Proof of Publication Copy USACE JD answer 2-3-2021 Copy USACE RPG-5 approval 5-8-23 enclosures FP //////// LEGEND - FO h G F= G PERMIT BOUNDARY/AFFECTED LANDS 200 FOOT LIMIT COMMUNICATION LINES OVERHEAD POWER LINES FENCE ABANDONED RAILROAD GRADE WATER LINE IRRIGATION LINES FIBER OPTIC LINES GAS UNES ROADS (OFFSITE) ROADS (HAUL, ACCESS) (TYP.) TOPO CONTOUR RIVER DITCH FLOOD PLAIN . BUILDINGS p MW —6 MONITORING WELL db15322R WATER WELL o 011/GAS WELL PUBLIC ROAD RIGHT OF WAY Owners on or within 200 feet of permit tine (12-14-22) L.G. Everist, Incorporated 7321 E. 88th Ave. Suite 200 Henderson, CO 80640 Abbelt Trust Farms LLC C/O Dunham Trust Co. 241 Ridge St, Ste 100 Reno, NV 895012055 FPI Burlington Farms LLC 4600 S Syracuse SI. Ste 1450 Denver, CO, 802372766 Hergert Family Revocable Trust 15883 County Road 21 Platteville, CO 806517935 Ben R Houston 9053 County Road 34 Platteville, CO 806519218 Kim Y & Raymond S Houston 15649 County Road 17 Platteville, CO 806519424 Magness Land Holdings LLC C/O Magness Investment Group LLC 4643 $ Ulster St Ste 1400 Denver, CO 802372889 Town of Platteville 400 Grand Avenue Platteville, CO 805637503 Jeffrey A & Kendra M Palombo 14900 County Road 21 Platteville. CO 806517930 Xcel Energy Tax Service Department PO Box 1979 Denver, CO 802011979 Rosalie E Rusch 15225 County Road 21 Platteville. CO. 806517933 PREPARED BY,/ f C Vegetation Information The following vegetation types were observed and mapped on the site. Location of discussed areas shown on Map Exhibit J2 in Exhibit I/J . Irrigated cropland - covers about 77.0% (a364 acres) of the mine. Historically, these areas have been used as irrigated fields in which corn, sorghum, grass hay or other cash crops have been grown. The farmer who leases the land will continue to cultivate these areas that are not being mined throughout the life of the mine. The farmer will determine what crops will be grown year to year and they will be responsible for planting and caring for the crops grown. Non -Irrigated Grass land and/or Vacant Land - covers approximately 10.1% (=47 acres). Most of the acreage covers the area between the terrace deposit of gravel and the floodplain on the west side of the river and is used as rangeland. Sonic wet soils are associated with the irrigation return flow ditch on the western parcels. The vegetation consists of mostly grass, weeds, and some cactus. The plant community is 80 to 85 percent grasses and 5 to 15 percent cactus and weeds. Grass species makeup 85 % to 90%, by weight, of the non -cropland vegetation found on the site. Open Range Pasture - covers about 6.9% (832 acres). Historically, these areas have been used as open livestock grazing area along the South Platte River. The vegetation present in this area is mostly grass intermixed with weeds, scattered trees and brush. There are also areas were no vegetation exists as the underlying gravel has been exposed due to past flooding. The plant community is 50 to 70 percent grasses and 30 to 50 percent, trees, cactus and weeds. Grass species makeup 40 % to 45%, by weight, of the non -cropland vegetation found on the site. Field Buffer - these areas cover approximately 2.6% (a12 acres) and cover the area between he Irrigation return flow ditch and the terrace deposit or along the old railroad bed that. The plant community and covers are consistent with the Non Irrigated grass land areas. Most of this area will not be mined. Farming Facilities - these areas cover approximately 2.0% (a9 acres). They contain houses, barns, sheds, livestock pens. corrals, Irrigation pumping areas and equipment parking/storage areas. Vegetation on these areas Is usually very sparse and consists of weedy patches and grass. Oil & Gas operations areas - cover approximately 0.4% (a2 acres). These areas will not be disturbed by mining and have little or no vegetation of any value. It is mostly weeds with some sparse grass areas surrounding the roads and bare ground. If the O&G areas remain after mining they will not be resorted or seeded but graded for use by the oil companies. As mining progresses these facilities may be abandoned and if removed they may be mined. Transportation Corridors. - This Is City and County ROW along WCR's 32.5, and 21. These areas are not in the permit and will not be disturbed by mining so are excluded from the permit. Water areas - these areas are within the banks of the irrigation return flow ditch that crosses the permit. The water surface areas at this time cover approximately 1.1 % (85.4 Acres). The irrigation return ditch may be removed if it dries up and is not be needed once the reservoirs are constructed. ROW's and Easements on or within 200 feet of Permit line (12-5-22) Metro Wastewater Reclamation District 6450 York St. Denver, CO 80229 Central Weld County Water District cro Stan Linker 2235 2nd Avenue Greeley, CO 80631 Western Mutual Ditch CO P.O. Box 282 LaSalle, CO 80645 Beeman Irrigation Ditch & Milling Company Ulrich Farms, Inc. wo Ken Ulrich, Ken 14605 County Road 21 Platteville, CO 80651 Weld County Commissioners 1150 0 Street P.O. Box 758 Greeley. CO806331 CenturyLink Communications LLC (Lumen Technologies) Timothy Kunldeman 931 14tH Street Suite 1230 Denver, CO 80202 Kerr - McGee., C/O Anadarko Energy Attn: Cattle Fiddes P.O. Box 173779 Denver, CO 80217.3779 Snyder Oil Corporation co Devon Energy 333 West Sheridan Avenue Oklahoma City, OK 731025015 Associated Natural Gas MA Panhandle Eastern Pipeline 635 N 7th Ave. Brighton, CO 80601 DCP Midstream LRDCP Midstream Attn: Lew Hagentodc 6900 E. Layton Ave, Ste 900 Denver, CO 80237 OWNER. PUBLIC SERV? COMP-INY OFCLZOtt4DO .&V HOLM"' OWNER: TTI H1.WL/ ARMS' f t i':1 \.tit SHUT IN 10 FT. NEW R.O.W. _ _ t:OR-WEST FARM 1 - 4A s \) SHUT IN el t�S -.-.e � wrte O W/v'ZR..' PAL et PALO, L� r / tr1 -r3147t OWNER: PUBLIC- SERVICE C0MPANYOPLI2LpRAgp et Kim Ft Raymond S Houston v r ------------ jVANESSLAND f oLDINGSLLt `lam` \ • v.: -> . t\ :s �- "4 r��.. \ -a. ABB67T TRUST FARMS LLC ill 0 150 300 Oaf —e.:, 600 SCALE 1"=300' t'y 1 ) f 1\ \ `'Io 4, osk �y\\ 1felt or r 1 1 I-' re; 1_/ r ,/ (te\ i ey• ,' Map Exhibit C - CURRENT CONDITIONS MAP jgg t �� ENVIRONMENT, INC. '985 vANCE DR.. » 205A �RVADA, CO 80003 3037 423-7297 rnvironnuncinoO0uMrs. lFt SOW}, Parts of the SE}NE},5W}NEI.NW}NE},NEI`SE3,SE}5E3,NW}SW}, NEINWI, AND NW}NW}, and S}NW} of Section Weld County, Colorado, EXCEPT Mine Entrance: 40°13'25.1536"N, LEGAL DESCRIPTION and all of the WISE}, NW}SE}, 14, Township 3 North, Range 67 County Roads 21 h 32}. containing 104°52'02.8563"W NE}SW}, West, 6th P.M., 472.40 ac.t WG584 REVISIONS: DATE: I L.G. EvergSt, • e Inc • g 5 1 ; m "- �, E \ re FOR ORIGINAL PERMIT 11/18/2022 APPLICATION A 112 PERAAIT z ADEQUACY REVISIONS 5/23/2023 SHEET ', 7321 East 88th Avenue I Henderson, Colorado 80640 W ` z r C o Q c; r1+ -• 0 O 1 OF 4 RESERVOIRS WEST FARM phone: (303) 287-4656 ! fax: (303) 289-1348 O ''' MAY 23. 2023 - 09:29:17 LEGEND TT ❑HE —IR— Eo NOTES PERMIT BOUNDARY/AFFECTED LANDS 200 FOOT LIMIT COMMUNICATION LINES OVERHEAD POWER LINES FENCE ABANDONED RAILROAD GRADE WATER LINE IRRIGATION LINES FIBER OPTIC LINES GAS LINES PAVED ROADS (OFFSITE) ROADS (HAUL, ACCESS) (TYP.) RIVER DITCH The four Phases shown on this map are the operations areas for the mining and reclamation activities that constitute the development of this property as a series of water storage reservoirs. Activities within each Phase will include, but is not limited to, mining of sand and gravel, construction of reservoir liners, grading, recoiling and revegetation of the above -water perimeter areas of said reservoirs. The Plant Site shown in the Phase 4 will be used throughout the life of the mine and activities may include, but are not limited to, processing the sand and gravel (crushing, washing and screening) ; crushing and recycling of concrete and asphalt materials; botching of ready -mixed concrete; botching of hot -mix asphalt; stockpiling of raw and finished products, and sales of said materials. 4. The Plant Site shall include the necessary portable processing plants and equipment to conduct the activities listed above. For the sand and gravel processing, and the concrete and asphalt recycling, the processing equipment shall include, but is not limited to, crushers, screens,conveyors,stackers, feeders, log -washers, and other necessary processing equipment. For ready -mixed concrete, and hot -mix asphalt, a portable concrete batch plant and a portable asphalt batch plant may be installed and used for the life of the mine. 5. The conveyor crossing envelopes shown on this map are the approved proposed crossings in the Town of Platteville PDP agreement. The conveyor design and final locations will be approved prior to construction of the conveyors. 6. The approximate locations of (2) Conveyor Crossing Envelopes are hown hereon. The exact location and size of the crossing areas will be determined prior to installation. A Technical Revision will be filed showing the exact location if different fro m shown on the Map Exhibit C-1 Mining Plan Map. These crossings will be used, when approved by the Town of Platteville, to build overhead portable conveyor facilities to transport raw material from the north side of County Road 32.5 to the processing plant. Using over -the -road conveyors would greatly reduce heavy off -road truck traffic that would cross the paved road. Conveyor facilities will be removed when reclamation is complete. EP -T- FLOOD PLAIN SLURRY WALL (PROPOSED) TOP OF MINING SLOPE �15322R a ' '''''ii / / //iii OWNER' PUBLIC SERI COMPANY REM HUDSON / BUILDINGS WATER WELL OIL/GAS WELL ESTIMATED MINING DIRECTION PUBLIC ROAD RIGHT OF WAY RESERVOIR SLOPE AREAS VARIES 3:1 TO 4:1 BANK ARMORING WORKING FACE AREA TEMPORARY SOIL PILES (APPROX. LOCATIONS) 7. The reservoirs will have gravel access roads around the perimeters of each reservoir and the rest of the perimeter area will be revegetated with a state -approved seed mix. 8. Access points for each Phase are shown on this map. The accesses to the Phases will be used to move equipment, needed during mining and reclamation, from one area to the other. The access point into the Plant Site from County Road 21 will be used by customers' over -the -road trucks to transport finished materials to market. 9. Each Phase may continue to be used for agricultural purposes until the permitted mining operations begin in the area. 10. The FEMA Flood Plain (Zone A) shown hereon is approximate and represents the best information available at the time this document was created and is subject to change. 11. The four mining Phases shown hereon may change as mining and reclamation progresses, depending on future Oil and Gas activities at the site, 12. Working faces show on the map are located at points where they will be the longest in each Phase, Volume shown is based on average depth of the Phase. 13. The approximate access points for each Phase are shown hereon. These accesses will be used to move equipment, and access each Phase during mining, development and maintenance of each Phase. 14. The unmined areas shown hereon may be used during mining and reclamation for placement of soil stockpiles, staging areas and as setbacks. If disturbed, they will be reseeded. 15. The settling and fresh water ponds shown in Phase 1 will be used for cleaning process water from the plant. Location may change to the reservoir floor once that area is mined. 16. In Phase 2 along the river, mining will occure within 300 feet of the top of bank and backfilled with on -site material so there is a 300 foot wide setback. No more then 500 feet of backfill area will be open at any -one-time. OWNER: FP/BURLIN FARM • :vs/ 1: /////////l/,/f// ,,,, /tell/,///// e▪ / • ,/ e▪ el 'e, ' et , /lfe eee ///t,// t // / // PHASE 3 TOTAL 60.36 AC 1 TE RESERVOIR AREA 37. WING AREA 4131 ACRES! 4 TO 1SLOPES 22_66 ACRES EGETA ON AREA. 5.35 ACRES ,////, IIIII�1 V ��,Id sa , ,,,,,/eeee, . . , „.p e,,, ,� ./.ef /'// NN . 4 /liii, ,/eeee eee etef/ f/, VV 77 / hell./,/ II//// e///////, ///////... / //////// //,////, //////////f/,t/,/// II,I * eeee,, //l, At+lvP eeereeeereeeee /,/ iY t.' -;'M,,,, OWNER: PUBLIC SERVICE C 12 bIP. 4 NY OF C VL O ADO <$ Kim Y& Raymond SHouston ;' ,, !„/ „! fee ,/ ,ter/!//,/;/.,, /, f ee... SCAT y'. E ENTRANC 50.00 AC. ± • WORKING FACE AREA . • '._ =ti34 /LFT /, ee ee ee ee / ee e y1IMNG AREA 61 19 ACRES t FfTo 1V SLOPES 31.53 ACRES t • RATION AREA. 7.05 ACRES t — 6AS — OW bli kto. JEFFRFY .4 E PALOMBU AENDR4 Al /e , // Ze , // e/ e/ / 1 BACKFILL SLOPE VOLUME 115.54 CY/LET e/ ee/e/ /e// ,/• /e/ te////// „e / i / / / I I,,,, fe// e/ /,//f, ,/deli////,/ /eft r �;///e/e„'/;:////„f„/ „ ,////u////,//,,,////t,///// tee/ le/ /,// /, 'ere 'ere /err ///e I,/, t,,, le„ le/l fee/ ,I/, e/// //e, ee,e tee/ e/e/ /,/f /// I „ e,/ ere/ ee/ //e, eeee/ PHASE 2 TOTAL 145.39 AC t APPROXIMATE RESERVOIR AREA. 100.15 ACRES t MINING AREA 106.87 ACRES t 3H TO IV SLOPES 29.90 ACRES REVEGETATION AREA. 18.38 ACRES t WORKING FACE AREA - CUT/FRL SLOPE VOLUME 2LIt CY/LFT „& IIr •r ///re,v J I Ay.. \Ct-1' j'' /.' /eel ,/„ /ee ee // efele S '7••P7Y ee \ a ! r// i rr % /. /Iii,, f 1�3-Ri eee,/\ Pn 1, Ile !! Ift/e/ � II r ,!� Ve /re e fee •///I,'.Y"9 ♦ /!!N/ V4� ..�� "" 11„„1,,„1„,,„„„„,„„„„„„„,„„„„,,..,/,e/,//lTr.lr r///f////f/////// eeee,///////r„// F GA rtO // r,.i,' ir,ir,;�.i,,,,/„�// e s,,,,,,,,,.•iI/W/ f.; )!' ' /r//!/!//!//,/.eel///e//e////////!/ ___k! NR' N !� /„,„„//////I///////„///,/t/let: CAI ��R AtAr �Al rl+�1�ST �FMfty - .. aa�w„�: T•..w.:.... e.,... ewnvi/.a•, -. - of .l — �" "1/er///„/_,f///,/ (/Ir/,,fee: i;; .///.•f; / /, _ - en:.. on. u-.�vur. /. v:.. /iu.•ti.. J-[1,LiI+ / /[,r -+,I�!//!/// r!„rtrel;!//r _1\1 GAS—GAS—WS—CAt• lY� ter GAS ` Y 4a��}}}� la/�zy - I' F{ cA`- t�A,5�- _ {'^`."▪ C;A'.1��. /lY COO At 1: + + + 11 /,e I - ,t1 eee BACKFILL SLOPE VOLUME 208.33 CY/LFT /, r le ,/ //e ele e ,/, „ f „ �,„. p,„ , ' , 'T/t,e /err,,,//f////f/ t* /ee/ eeee/,/,/////!/,////,/,eeeelee, ,// 4% , wee/ /„fete„eeee,/ „e/mot/,/tee„/,,:,/rte //ell„/,/tr, „zee/ /,/„e!,/ ,., eee �tilllAlP9Cil� ES ,eeee/e„e//,/,;;: 4.xrt ..;1' ,eeee -� , //// : �. ,_ _ :r , , , Af�I Rb u�r(dt>`' NVEY6 '1P/e/e//,/l/ �N/,eel/e///,f,//f,:: . CROSSING ENVELOPE I,,, e////,e,// ,,,,ref//////e„eeee,// 1// f/////////,////I//////////r/// I, .. r///,,,,,,,,,,,///, //,/f/I,/,// PHASE 1 .igior /-f �p e„/rf,,,ee3tefeeee.1'I • eeee/'it,'rrIeeer. /r/t„t/r//e///e/e .eeee///r,//„eeee,,, TOTAL 190.23 AC t APPROXIMATE RESERVOIR AREA. 14125 ACRES- MINING AREA 146 67 ACRES t 3H TO IV SLOPES 31.40 ACRES: REVEGEETATION AREA. 809 ACRES: /fee/ex/zee//ee,/ t„ /e//e/,///f/fret IF et,////,/et//f/e/efe eeeetuft,////e ele/,/ ,t/e,,. / //f/.: / /e/e ewe '''1'., //tee /. /re„ r,,,, .: Fee,/ / ,,, / 'e/ / „ e ////, / /,//. ,f//" ,/// /t,/ //,/ • 6/ „t / e r., e/e, /,,, r/If /// ///. /// //e/ t/,; f/„ ' r, e „ • ee e „ t er/ lee / e, ✓ f, f VOLUME 21.11 CY4FT 13331-! BACKFILL SLOPE VOLUME 11534 CY/LFT r SACKFUL aQ V0LMAE 115.54 CY/LFT OWNER.' MAONF.5•SLA.ND HOLDINGS LLC 200 Ft $ ♦rfA044.7!0:4/016 Mnrr04~ (POW a-!: PIA' axt Aa c OWNER' .4BBETT TRUST F4RNSLLC 'L%/1F SCALE 1"=300' Map Exhibit C-1 - MINING PLAN MAP PREPARED BY. ENVIRONMENT, INC. 7985 VANCE OR,. A 205A ARVADA, CO 90003 (303) 423-7297 Environment_ ino0outdre. ne t LEGAL DESCRIPTION Parts of the 5E}NEt, SWINEI, NW=NE+. NEISE§, 5EISE3, NW35W+, NEINWI, AND NW}NW+, and all of the WISE+, NW+SE+, NE}5W}, 51SW+, and 5}NW} of Section 14, Township 3 North, Range 67 West, 6th P.M.. Weld County. Colorado, EXCEPT County Roads 21 d, 323. containing 472.40 ac ± Mine Entrance: 40°13'25,1536"N. 104°52'02.8563"W WG584 REVISIONS: DA1h: ORIGINAL PERMIT 11/18/2022 5/22/2023 ADEQUACY REVISIONS APPLICATION FOR A 112 PERMIT WEST FARM RESERVOIRS L.G. Everist, Inc. 7321 East 88th Avenue I Henderson, Colorado 80640 phone: (303) 287-4656 I fax: (303) 289-1348 9 03N33H0 r U to !IdVW-t-D Sri80 c rr SHEET 2 OF 4 MAY 22. 2023 - 14.i FO FO _ GAS - GAS LEGEND PERMIT BOUNDARY/AFFECTED LANDS 200 FOOT LIMIT - COMMUNICATION LINES OVERHEAD POWER LINES FENCE WATER LINE - IRRIGATION LINES FIBER OPTIC LINES GAS LINES = DIRT ROADS PAVED ROADS (OFFSITE) MINING AREA ENTRANCES TOPO CONTOUR STREAM DITCH (DIM \V-6 815331-R a FLOOD PLAIN FEMA FLOOD PLANE LINE BUILDINGS MONITORING WELL WATER WELL OIL/GAS WELL ROAD CORRIDORS Phew Key Oar Shantung.%) Status for eudng IYw mkt* Own SW ntbrk (m D4On. setback (m Notes e L.fr Evan. tnetranmd °ulb•aM•y. cent Haire br. 1- pnvl pwon watt- mei. frees ep year par Rsnwted If M man ease MA N* nee 9e° a Nona ore ,",.hated ®*al Envy 6i• PS. t%inv Co of Cc - 111154 A Sabridtay of /swarYnn, E.!6W �adehrdad. Re t.wd if used fn it gran a i n t an are YseW H 4g Ira,bas;'n s•a•ky 40W 325)6W ride of WCR 21 Reyepd 6 Oa M4usten We uedaaMd et Hart Fauly Rene* Trust num.In 1-nvd en ten ut'et,eted • 00 note WP• 21 ® Tanta Pancras. WCa 123 ue6nwWd 80 35 m triode raetrolW ManlryYsl novas nod Bent Conn thlt Od clew a t•cMokguit Inc) 2- tanauk Mai/phase tndtltral nom 23 40 front Oast (near a. ROW 12.5)6W ads of WCa 21 Wear, Martini With Conn* D "nip* entsrhAa sit river uldltst•d 409 IS h. rteah of prormtv Is n mar 2 6 3 (Nal%) m wOJ Cony WC% 21 wdalelred 70 33 60 ...bait orarrld by pa I utiry Yal esi ode Carr-alWaldfslmly War pimiat .ee brae undstabW ISM IS 30 from ROW lint ® OJV Ervg/ Fin Oran, )ric Jab V, NJ= pis line uS b.4 d nom Ind II 40 from gs law ® I n. Ira (en P ,t 'db Finn Radr) WrYW ps bas ene/NIMa UM is 10 Of M1s two nrow Ohre awl see) T W t Inman Dnd. ((Inmanton�si al•[n 6 WWI CO. (de thickuMmrwted Tonne Tae SAHA. Sin11) tortman e°rcl, "Co guru am sins .115 206 219 Wanof WO!21 CD Melia (oho *hop) wda HAS Watt In 5 line FH5 Well Feew 6-!4A. 2-h.. Nice Madman epdann:it* Mtiry. YOC W,rnr. Shed, MI web obit • new of SAM Will b• rand (pawed ad obenabandoned Rebuild 100• Re 70 7311 dig Iron will bad rebuilt to I50rat-skO 1•. 610 M oath on of feeder buss b ® Man WmMrbr atadw t.. Dsilrkt nertvng rib undone -bed ROW N ode o/ 32 5 (Rent . 2646341 © Lb Swat. atorpaMed I- hw.w, 3.660244iye- aaroh. ekwnt lbes.3yolrrwl pips ink (4 - as esehrO), I- renesmd, him, 110044181. prat Rerotad if in nag arm In PIA 144 m Raga 2ILah Ha 1- autbwliep, oral wend interbed 400 III IR West of Welt It FIT Bur -try —of. Fonts Ur sees uMrnrted e Jeffrey d t:iaan Pisan Nees, tw9s. •trlpwnt btildMn. 9olenal on. wane lmano err ee0. 6.atltenid .dl rMenind u 40 Erma 04.14464 475 Mag•ss Lad Aslant 'AC .-' i n lamed Abbelr True Farms Ul ADM .adettnbsd Wert of WCa2t CD WAW COW),WOb21 wdinrbsd '30 35 e0 rink pee6vhb yue inn slat I 6 4 (south) CIO Central Wed Grimy WWr Drano Inter Met tndourbed 19.19 IS 30 OH 310 ROW a watt. lira s6ldt nor a t Se0er ® hdgdh horn apses e 1r Amman Natural Ow In ) Natural 9s Me undisturbed 50 15 10 off ROW abng Sarin Nn e Nike Envy F.W Saves.. Inc Wu DO Mdi.-666) IIer+rel gee In ueNNrbsd um 25 40 from gin on WC92I awtsM. © era -Mhos (de Anane4en MI5 -Wen raw IS-I4A./4S- Wert Fro 53$4A,11R5-West Pew 22.14*, 3•f.. lures, Pinata% tannins 2 -tan tethree, 2- VOC Ranea, .beds AU welts aut- n as of 11/5/2 2 Will be ns.ovo f plena ant national137 ° N4 75 77 fe deb rr.n.•Y bend rebuff re 1`0 h.emharch oh at tend. tires cpLon -wry lJse (u roW,.twntadatearid Tni .—'- ller In ) line undisturbed 123 I3S Want MWa21 ® XlaI Early (or PWIn Soma 4 4 CC•PiCa a naSay of %net) Pnsrl.a d apnea W 65 undisturbed taw 23 d0 F.11.1 POMP' nett 4 sire oaths et Wta 21 Rained 04/11/2151* 7985 VANCE DR., It 205A ARVADA, CO 80003 (303) 423-7297 Bnairenman.t`(ncOontdr4.nt I LEGAL DESCRIPTION Parts of the SEINE}. SW}NEI, NW1NEi, NE}SE}, SEISE}. NW}SW}• NE}NW -, AND NW}NW;, and all of the W45Et, NW}SE+, NE�•SW}, 5}S W, and 5#NW} of Section 14. Township 3 North, Range 67 West, 6th P.M., Weld County, Colorado, EXCEPT County Roads 21 & 324, containing 472.40 acs Mine Entrance: 40°13'25.1536'N, 104°52'02.8563"W W&584 REVISIONS: ORIGINAL PERMIT ADEQUACY REVISIONS DATE: 11/18/2024 5/22/2023 OWNER- PUNICSER VICE Cn4eAVYOPCnLORAQ7 AWN FiVDS0N OWAtall: JANY/JAO7 FARN LL(' OWNER. PALAI/AQ K-M-)4SR-WE 0 SHUT IN SHUT IN .•.••••••••••...... '..r • •• .•;•'•;• ••••.........••'• ..•..•.Y •• • • • • Ot1PIm1wLRArrM • • • •a J // Latent arn'it 0 22-14 IN OWNER: M LINESSI.A.47) /AQt DI/1C*S/J!- APPLICATION FOR A 112 PERMIT WEST FARM RESERVOIRS • •••- GAS- GAS GIS- GAS GAS GAS - GAS - GAS 150 300 600 NIS SCALE 1"=300' •.- .. emessesemesemie moss 6560..44 MOOOSoot `. • • • • • • • 1'••• • • 14 *0 10001404I Oa 44040444S OW:ItigR.• AARETT7RL5TFARMSLLC 7321 East 88th Avenue I Henderson, Colorado 80640 phone: (303) 287-4656 I fax: (303) 289d 348 • • • • • • • - ••i•• • •''• • •• • 1••• . . . • • . . .• _• • 3 • • • • • • • . • • • . • in • SHEET 3OF4 MAY 22. 2023 - 14:19:38 LEGEND TT 0HE w -1R- PERMIT BOUNDARY/AFFECTED LANDS 200 FOOT LIMIT COMMUNICATION LINES OVERHEAD POWER LINES FENCE ABANDONED RAILROAD GRADE WATER LINE IRRIGATION LINES FO FO - FIBER OPTIC LINES C - 0 GAS LINES SLURRY WALL LINER ROADS (OFFSITE) ROADS (HAUL, ACCESS) (TYP.) TOPO CONTOUR MEN FP al 15322R RIVER DITCH FLOOD PLAIN BANK ARMORING BUT!. DINGS WATER WELL 0 OIL/GAS WELL 0/////7 PUBLIC ROAD RIGHT OF WAY ••••••••••••••••••• WATER LEVEL (ESTIMATED) 0 150 300 600 SCALE 1"=300' OWNER. PUBLICSER C SAN DID ORA OWNER: FPIB FAR, /O PALO OMBQ 4BOA JEFFREY OWNER: PUBLIC SERVILEWAWA/VT OFGnLORADO d+ Kim Y,$ Raymond S Houston m SLAND HOLDINGS LLC 200 Ft. 17/J E O asok Ic 4BBETT TRUST FARIIS LLC Map Exhibit F - RECLAMATION PLAN MAP see-�� °REPARED 7985 VANCE DR.. 4 205A ARVADA. CO 80003 (303) 423-7297 t LEGAL DESCRIPTION Parts of the SEINE}. SWINE+, NW}NET, NE}SET, SEISE}, NW}SWT, S}SWT• and STNW+ of Section 14, Township 3 North, Range 67 West, bth P.M., Weld County, Colorado, EXCEPT County Roads 21 a 324. containing 472.40 ac.t." Mine Entrance: 40°13'25.1536°N, 104°52'02.8563"W WG584 REVISIONS: DATE: ICHECKED BY: I DRAWN BY: ENV/SLO m W 0 9LE NAME: DRMS_F-MAP n - '� r.) �' ' ,)4 C J 4 H EET OF L.G. Everi st, Inc . APPLICATION FOR A 112 PERMIT ORIGINAL PERMIT H/18/202. EST FARM RESERVOIRS 0 7321 East 88th Avenue Henderson, Colorado 80640 BY' ENVIRONMENT, INC. NE}NWI, AND NWINW}, and all of the WISE+, NWTSE+, NETSWI, ADEQUACY REVISIONS 5/22/2023 II' - - _ ,�/ WEST - sm.E'nvirotunn�,.incOouldri.ne phone: (303) 287-4656 fax: (303) 289-1348 MAY 22. 2023 - 14:16:29 Exhibit D MINING PLAN AND TIMETABLE LOCATION This is an open pit mine located about 1 mile west of Platteville, with the entrance on the east side of County Road 21 just south of 32.5 Road. To reach the mine from Platteville, starting at the intersection of HWY 85 and Justin Ave (HWY 66) go west on Justin Ave 2.5 miles to Weld County Road 21, then north 1.37 miles to the entrance. The coordinates of the entrance are 40°13' 25.1536", -104°52'02.8563.. Please refer to ExHIBITB-VICINITY MAP for the property configuration and the relationships to sur- rounding geological features. The area to be mined lies between County Road 21 and the South Platte River, straddling 32.5 Road and lies within the Town of Platteville, Colorado. GENERAL INFORMATION The primary commodities to be mined are sand, gravel, top- soil, overburden, and borrow materials. No incidental commodi- ties will be produced at this mine. Throughout this application we will refer to the two areas, (a) the south area containing Phases 1 & 4 and (b) the north area containing Phases 2 & 3. The roadways (transportation corridors) are left out of the permit since L.G. Everist, Inc. does not own them. Permit/affected lands and mining lines and setbacks vary throughout the site, depending on ROWs and proximity to the South Platte River. Along the river the permit/affected lands line is 100 feet from the western bank of the river. Along the river in Phase 2 (north of CR 32.5), mining will take place within 300 feet of the river bank and the bank will be rebuilt so the top of the slope into the reservoir area will be 300 feet from the top of the river bank. This will be done by backfilling from the 2h:ly mining face to the top -of -slope (TOS) line using shale from the floor of the mined area. Along the river in Phase 1 (south of CR 32.5), the mining line will be along the west side of the old railroad grade, which is greater than 345 feet from the river bank. There is a 1305 feet section of reservoir bank in this area that will be armored since it is less then 400 feet from the river. MAPExHIBITC-1-MININGPuwshow the location of the armored sec- tions Along the County and Local Roads, the permit lines use the ROW lines associated with the roads. Platteville requires 80 feet ROW for CR 32.5, and Weld County requires 40 feet, east of L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 4 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) the section line, for the ROW along CR 21. The slurry walls will be constructed 15 feet from the Per- mit/Affected lines or utility ROW lines, whichever is greater. The mining setback will be 25 feet inside the slurry walls. Mining in all Phases will be done after the slurry walls are completed around them so they can be dewatered and mined dry. Dewatering will continue until mining ends in each Phase to re- move any stormwater or leakage that accumulates in the mining areas and facilitate certification of the slurry wall. The area being permitted and much of the surrounding areas has historically been used as irrigated and non -irrigated cropland and vacant land. This site lays adjacent to the South Platte River, so it contains an alluvial gravel deposit in the eastern area, which extends west into a large terrace of gravel on the western areas. All mined areas will be reclaimed as ground water storage reservoirs using slurry wall liners. CURRENT CONDITIONS Large portions of the land to be permitted are currently operated as an irrigated farm, or used as rangeland. There are two rental houses and various barns and sheds in Phase 1 that are owned by the operator and will not be disturbed by mining. How- ever, the owner may choose to remove these at any time. There are various oil/gas lines and facilities on the permit area and 6 wells in Phases 3 & 4 that have been "shut in" and will eventually be plugged and abandoned. The oil and gas facil- ities will be removed by the producers and the supporting feeder lines will be abandoned and removed if they lie within the areas to be mined. They are shown on EXHIBIT C -CURRENT CONDITIONS MAP and EXHIBIT C-2 - STRUCTURES, but left off of EXHIBIT C-1 - MINING PLAN MAP and EXHIBIT F - RECLA- MATION PLAN MAP because they will be removed prior to mining those areas. If they remain when mining starts in those areas, a Tech- nical Revision will be filed to show how LGE will deal with them. Where needed, the active farm facilities and support struc- tures, i.e. water wells, sprinkle pivots, distribution ditches, pipes and diversion structures will be removed as mining pro- gresses. There are no County Roads or public facilities on the permit area. The oil and gas facilities lying outside the slurry walls will not be disturbed by mining. EXHIBIT C -CURRENT CONDITIONS MAP, shows the outline of the Affected Lands/permit area, the adjacent landowners within 200 feet of the L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 5 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) facility, current topography, hydrologic and surface features of the property. Of particular note, along the South Platte River the permit/affected lands line is established one -hundred (100) feet west and parallel to the top side of the west bank along the South Platte River. Over the years, it appears this bank has been lined in places with armoring materials by previous landown- ers The initial access to the site is via an existing Private Road located on the east side of CR 21 and approximately 1.37 miles north of Highway 66. In most cases, existing farm roads within the permit area will be used for mining needs and existing farm entrances on the paved roads will be used to cross the pub- lic ROW's. The initial Plant Site will be located on approxi- mately 50.00 acres of Phase 4, located on the southeast corner of CR 21 and CR 32.5. This Plant Site will be used throughout the life of the mine, as material will be conveyed or hauled to the plant from each Phase. In the future, 2 conveyor crossings may be installed from the northern area to the southern area. These crossings will be self-contained clear span units over CR 32.5 with all support structures to be built outside the road ROW's, but within the affected lands. They are part of the approved Platteville Devel- opment Plan and this would only happen after LGE has filed and received approval for a Technical Revision with the Division that would include showing the proposed location and design details for the crossings. The approximate proposed locations are shown on EXHIBIT C-1 MINING PLAN MAP . The phase access roads will be constructed of gravel ob- tained from on site. They will be at least 20 feet wide and graded to allow for drainage into the site and have ditches as necessary to collect runoff. Any runoff from the roads will be retained on -site and allowed to soak into the ground or evapo- rate. The roads will be maintained as needed. Access roads will be built around each water storage reservoir to provide access during mining, reclamation, and after release. The access roads will remain when reclamation ends as they will be used to access the property. GEOLOGIC SETTING The affected lands are located along the South Platte River in a Quaternary age, Piney Creek alluvial deposit. The eastward L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 6 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) dipping beds of upper Cretaceous age Laramie formation are over- lain at an angular unconformity, by the Piney Creek alluvium. The sand and gravel encountered in the Piney Creek alluvium are a result of water erosion and redisposition of rock materials from the Front Range of the Rocky Mountains. The deposition of this material occurred during a time when the river was much larger than it is now. But, judging from the scarcity of large rocks found at the location, the velocity of the river must have slowed sufficiently to have dropped boulders and most large cobble be- fore it reached this point. This type of material is typically found from south of Denver to the Colorado state line along the South Platte River. The thickness of the gravel deposit in West Farm Reservoirs varies from 27 to 75+ feet and the average depth is approximately 50+ feet. This site has a 10 to 12 inch layer of topsoil, con- sisting of loam and zero to 5 feet of a clay loam to sandy clay loam overburden. The alluvium is a well -sorted gravel, sand and silt, predominantly granitic and quartzite material with minor amounts of gneiss, schist and sandstone. The bedrock under the surface gravel is part of the Laramie formation and is a grey to grey black shale that is impervious. SOILS AND OVERBURDEN The information presented in this section is an overview of the Soils and Overburden types, quantities and depths found throughout the property, and also how these materials will be integrated into the mining and reclamation plans. The informa- tion has been obtained from the National Resource Conservation Service (NRCS) website, and from drilling reports. The NRCS Soils Report and SoiLs MAP IN EXHIBIT I/J, show the soil types delineated in the permit area and will provide background levels for the site as reclamation begins on the entire area. There are seven (7) types of soils found on the site. These soils are typically found throughout Weld County. They have no unusual qualities. The soils are designated as map Units 3, 10, 21, 22, 39, 41 and 68. Soil unit 68 lies along the slope from the upper level to the lower level that will not be mined. The NRCS report contains detailed information including the soils description, and chemical, physical, and engineering qualities. he depths of the topsoil and overburden, shown in the following table, is from a drilling report on the property. L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 7 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) SOIL UNIT UNIT NAME APPROX AREA (AC) DEPT OF TOPSOIL, (INCHES) DEPTH OF OVERBURDEN (FEET) 3 Aquolls and Aquents, gravelly substra- tum 256.7 12 3.5 10 Ellicott -Ellicott sandy -skeletal corn - plex, 0 to 3 percent slopes, rarely flooded 56.8 12 3.5 21 Dacono clay loam, 0 to 1 percent slopes 103.0 12 4.0 22 Dacono clay loam, 1 to 3 percent slopes 6.3 12 3.0 39 Nunn loam, 0 to 1 percent slopes 7.5 12 0.0 41 Nunn clay loam, 0 to 1 percent slopes 4.6 12 5.0 68 Ustic Torriorthents, moderately steep 37.3 3 0.0 85 Water 0.6 NA NA Based on the soils report and on site observations there are sufficient quantities of soil available to reclaim the disturbed lands to their present condition. The excess topsoil and over- burden will be used on site for reclamation or removed from the site The soils on the permit area that will be salvaged and re- placed should be capable of growing vegetation consistent with what is required by the Reclamation Plan. Enough topsoil will be retained to place an average of 10-12 inches on the areas to be revegetated. As each area is stripped, L.G. Everist will deter- mine how much soil will be needed to reclaim the area and it will be stockpiled for use in reclamation. Over the life of the mine, an estimated 588,400 yards of topsoil will be stripped from the mined area but, a minimum of 60,200 yards will be retained for resoiling the areas to be revegetated. In addition, there is from 0 to 3 feet of overburden on most of the site. Much of this overburden will be retained and used to backfill the reservoir slopes and used during slurry wall construction or removed from the site. The topsoil and overburden stockpiles will be located around the excavation, typical pile locations are shown on the ExHIBuTC-1 - MINING PLAN MAP . If the soil stockpiles remain undisturbed for more L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 8 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) than one year, a cover crop of the approved seed mix, at the rate called for in the EXHIBITE- RECLAMATIONPLAN, will be used to revegetate them. MINING PLAN This mining plan is designed as a two -stage startup that will allow for issuance of the permit at a lower initial bond. Operations Stage A covers the preparation of the Plant Site area. Operations Stage B will cover full implementation of the mining plan. A Technical Revision for a bond increase will be filed prior to starting Operations Stage B that will allow construction of a slurry wall, land stripping and mining in the first mining Phase and covers the Operations Stage A disturbed area. OPERATIONS STAGE A Activities during this stage of startup would allow for de- velopment of the permanent Plant Site to be located in Phase 4. It will cover the northern 50.00 acres of Phasel and will include stripping, salvaging topsoil and overburden, and processing plant construction. As a part of this development a wash water set- tling pond and fresh water pond facility will be constructed in Phase 1 that covers approximately 6.0 acres. The Plant Site will contain the processing plant/stockpile area, equipment storage area, temporary overburden and topsoil piles, drying pads and other axillary uses needed at the mine. Processing equipment may include but is not limited to conveyors, crushers and screen plants. A scale and scale house will be built at the entrance and auxiliary uses may include a Concrete Batch Plant, an Asphalt Batch Plant and a recycling facility, that will be placed in the Plant Site Area. EXHIBITL- RECLAMATIONCOSTS contains the information needed to establish the Operations Stage A financial warranty amount and an analysis for the transition to Operations Stage B - full mining activities. OPERATIONS STAGE B Prior to full mine operations and the move into Phase 1 a Technical Revision will be filed to increase the financial war- ranty adequate to cover the mining plan as described in the fol- lowing text. The plan is to have no more than 205 acres ± of disturbance bonded to allow for flexibility during mining. This 205 acre L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 9 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) area will include stripped, partially mined, partially reclaimed, the Plant Site area, materials stockpile area, settling pond fa- cility and the slurry wall around future reservoir areas. As mining progresses across the property some parts of the property will remain undisturbed while other areas will be either stripped, mined, partially reclaimed or totally reclaimed. The EXHIBIT C -1 -MINING PLAN MAP provides information of how the Phases will develop during mining. Initially the 205 acres would include having stripped and partially mined Phase 1, the 50 acre Plant Site and installed the slurry wall around Phase 1. Much of the 205 acres would be within the highwater line of the reservoirs that would be covered with water and would need no soiling or revegetation. This amount of disturbance may change as the mine develops but prior to exceeding the initial 205 acres, a Techni- cal Revision will be filed to increase the bond and allow for more disturbance. This map shows the estimated location of the final slopes around the perimeter of the entire areas to be mined. The esti- mated reservoir highwater line, bank areas to be armored, the top of mining slope and slurry wall locations are shown. It also shows the maximum working face (highwall) for each Phase and the estimated cut/fill volume per foot to grade the working face highwall back to 3h to lv. No more than 1000 feet of total per- manent bank sloping will be needed (500' on each side of highwall). The volume to complete the backfilling on the exte- rior slopes is shown. In Phase 2 this volume will be greater because any area mined within 300 feet of the river bank will be backfilled so a 300 foot setback can be maintained when the res- ervoirs are built. This river bank excavation area will be done in 500 feet or less section that will not be left open for more the 12 months before backfilling, sloping and armoring begins in any given section. Of the 472.40 acres ± in the permit area, approximately 388.12 acres ± will be disturbed by mining. Within the disturbed area 364.71 acres will be mined. The 23.41 acres of unmined area will be the setback margins between the slurry wall and the top of slope into the reservoirs. This area will contain roads for access to the reservoir areas during and after mining. ExHIBITF- RECLAMATION PLAN MAP shows how the reservoirs will be developed. As mining progresses a reservoir area will be sold and a condition of the sale may require LGE to permit the owner of the L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 10 MINING PLAN AND TIMETABLE EXHIBIT D(coNT) reservoir to start construction of facilities related to the res- ervoir(s) - such as installation of pump houses, inlet/outlet structures, rip -rap, etc. This would only happen if the reservoir owner does not want to wait for DRMS permit acreage release of that Phase. In this case, L.G. Everist would have already re- claimed the reservoir phase (including liner certification, final grading of the reservoir slopes, armoring and initial seeding), but the phase acreage is not yet released from the DRMS permit (due only to vegetation growth). L.G. Everist would file Techni- cal Revisions as needed to incorporate the changes. At any given time, mining and "concurrent reclamation" may be occurring in one or more phases to accommodate the blending of materials, the natural progression of mining from one Phase to the next. This concurrent reclamation allows for reclamation work being completed in one phase while mining begins in another phase. The "direction of mining" arrows on ExHIBITC-1-MINING PLAN MAP show the applicant's best guess on how mining will progress through the mine areas at this time. Natural ground conditions and un- foreseen circumstances may necessitate changes to the mining di- rection throughout the life of the mine. The RECLAMATION COST ESTIMATE- EXHIBIT L is based on the Operations Stage A plan to bond for initial setup of the Plants Site and support facilities. Included is an estimate for the Operations Stage B where it is based on an estimated disturbance area when the Phase 1 has been open for a few years. The acreage disturbed may increase or decrease as mining progresses. If it increases, a Technical Revision will be filed to adjust the bond amount to cover the changed cost estimate. Mining will start on the southwest of Phase 1 and progress to the east and south until the mining limits are reached. This will leave an open working face across the Phase as shown on the MININGPLANMAP. This face will have a M:1 slope and will be worked to the north, the exterior final slopes will be constructed us- ing the overburden or shale from the excavated floor material. If mining ends prematurely, the east/west working face will be re- claimed using a cut/fill sloping method instead of backfilling. The setbacks to be used in each Phase are shown in the table on the EXHIBIT C -2 -STRUCTURES MAP. The aggregates will be removed and stored on the Plant Site area in Phase 4 for processing. The plan is to use conveyors or off -road haul trucks to move the ma- L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 11 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) terial from the working face to the Plant. As mentioned above, the proposed mining sequence may change due to unforeseen circumstances such as market conditions, varia- tions in the natural deposit, agreement restrictions with struc- ture owners, etc. At this time, the plan is to mine them sequen- tially from 1 through 4 as shown on the maps. The following mining methods will apply to all of the reser- voir Phases. Operations will begin in each Phase of reservoir construction by stripping the area where mining will start. Ini- tially a 30 acre area will be stripped and periodically as min- ing progresses it will be extended so there is approximately 30 acres ready for mining at any -one-time as each Phase is mined. The topsoil needed for resoiling the above -water areas will be separated from the overburden and stored around the mining area for use in reclamation. Once enough topsoil is salvaged to resoil the above -water disturbed areas with an average of 10-12 inches, the rest may be sold. These stockpiles will be placed strategically as mining progresses. In some cases the stripped topsoil will be placed on areas where grading and shaping, are complete so it only has to be handled once. In Phases 1 and 2, all topsoil storage piles will be located as far from the river as practical, and will run parallel to the river's flow if lo- cated in the floodplain. During the stripping, a slurry wall pad will be built around the reservoir mining area using the excess topsoil and overbur- den. When the slurry wall pad has been completed, the bentonite slurry wall construction will begin. This is done by excavating a trench in the pad that is keyed into the underlying bedrock and filled with a mix of overburden, bentonite and water to create the slurry that becomes the liner. The soil and overburden not used in slurry wall construction or sloping will be placed around the mined area or sold. After the slurry wall liner is in place within a phase, a dewatering trench will be excavated inside the perimeter of the slurry wall. A pump will be installed and dewatering will begin. This will allow the area within the slurry wall to be dry mined. The trench will be extended around the area as mining progresses. Some of the soil will be used to construct a sight berm along road areas in each Phase. These berms will limit visibil- ity into the active mining areas from the transportation corri- dors. The berms will vary in height depending on the area to be L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 12 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) screened, with 3:1 slopes on each side and revegetated using the approved seed mix. The active mining area in the reservoirs will remain dry. After mining is completed, final reclamation of the phase can be completed, including liner certification, final grading of slopes and initial seeding for revegetation. Dewatering as mining progresses, facilitates early testing of the slurry wall liner, this is required to receive liner ap- proval certification from the State Engineer's Office in the Di- vision of Water Resources. In general, mining will commence in Phases 1, 2 & 4 on the south end and work north as shown by the arrows on the MINING PLAN MAP. In Phase 3, mining will start on the north and work south. The maximum length and cut/fill volumes of the working face and backfill on the side wings in each stage are shown on the MINING PLAN MAP . The mining setbacks will vary from the permit boundary and structures as allowed by each agreement for said structures and/or the Geotechnical Stability Analysis. This analysis shows that using the 25 feet setback from the slurry wall is adequate to meet the factors of safety in the DRMS Rules and Regulations, (see D&A Slope Stability Factor of Safety Results Summary Table on Page 4 of their report). The proposed setbacks are shown in the Setback Table on EXHIBIT C-2 -STRUCTURES MAP The material will be mined using loaders and excavators (track hoes) to remove material from the face. The material will then be delivered to the Plant for processing using haul trucks or a conveyor system. No blasting will take place at this mine. Reclamation will run concurrent with mining to control the amount of disturbed area in the mine at any -one-time. Reclamation begins in an area once the section is fully mined, and large enough for efficient reclamation (backfilling, compacting, slop- ing, soiling, etc.) that will not have to be re -disturbed. This pit will be operated year -around by L.G. Everist, Inc., weather permitting. There may be periods when the demands for material are slow and no mining will take place, creating an in- termittent operation situation. Areas not included in the bonded area will remain in agri- cultural production. Please refer to the MININGTIMETABLE for the estimated acreage of each area associated with the mining part of this operation. L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 13 MINING PLAN AND TIMETABLE EXHIBIT D(coNT) Mining equipment may include but is not limited to, front-end loaders, scrapers, excavators, a drag line, dozers, off -road haul trucks, dump trucks and a water truck. Most of the water used on site will be for dust control used on haul roads or with sand and gravel processing. Please refer to EXHIBITG-WATERfor the discussion of how water will be used at the site, the estimated yearly needs, and the source(s) of said water. Prior to mining into the groundwater table, the appli- cant/operator/permittee will obtain a Substitute Water Supply Plan approval from the Division of Water Resources. All interior pit slopes will be maintained, when actively mining, with a pit -ward attitude to prevent off -site stormwater runoff. The general slope of reclaimed areas will be graded in a similar way so that stormwater drains into the site, not out. This same slope management plan will prevent any offsite erosion or other disruptions. In addition to the pit and reclamation sloping, isolation berms or ditches will be constructed around the mine as needed to prevent off -site stormwater from contacting the on -site disturbed areas. All stormwater contacting the dis- turbed area will be retained on -site to be discharged as part of the Colorado Discharge permit or allowed to evaporate or soak into the underlying gravel. The applicant had a jurisdictional delineation of the site conducted by environmental consultants and submitted to the U.S. Army Corps of Engineers (USACE). The Corps has determined that there are no jurisdictional wetlands on the West Farms site. The Corps determined that irrigation return flow ditch on the west side of Phases 1 and 2 is jurisdictional and must remain. So the ditch may be slightly improved by defining its course, but it will remain and not be impacted by the mining operation. If the irrigation ditch dries up once the area is no longer irrigated, the applicant may request a change in status (for the ditch) from the Corps. MINING TIMETABLES This estimated mining timetable is based on an average year, and L.G. Everist expects some years to vary widely from the aver- age. If there are changes in the mining timetable, we will dis- cuss the reasons for the change in the annual report that follows the change and modify it at that time if needed. L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 14 MINING PLAN AND TIMETABLE EXHIBIT D(CONT) ESTIMATED MINING TIMETABLE Phase ESTIMATED YEARS TOTAL AREA A TOTAL DISTURBED AREA TOTAL MINED MD 100°%INE MINED SLOPES EST. SLURRY WALL LENGTH 1 7-9 190.23 152.36 146.67 115.27 31.40 10,218 2 5-7 145.39 121.32 106.87 76.97 29.90 10,166 3 2-3 60.36 45.38 41.31 18.65 22.66 7,155 4 3-5 76.42 65.86 61.19 29.65 31.53 8,244 TOTALS 17-24 472.40 384.92 356.04 240.55 115.49 35,780 L.G. EVERIST, INC - WEST FARM RESERVOIRS May 2023 15 EXHIBIT E RECLAMATION PLAN AND TIMETABLE OVERVIEW The proposed future use is to create 4 in -ground, developed water storage reservoirs with a vegetated border around the highwater lines of each reservoir. Each of the proposed reser- voir areas will be sealed with a slurry wall liner. Eventually the reservoirs will be sold to a municipality or water company who will be responsible for the construction of any additional reservoir operations facilities (pump houses, inlet/outlet struc- tures, etc.) on each reservoir. This will occur once L.G. Everist, Inc. has resoiled and seeded the perimeters. (If the facilities construction is anticipated prior to the release from the DRMS permit on a Phase, a Technical Revision will be filed to add the locations of any reservoir facilities to be built.) The reclamation methods and plans described below will apply to all Phases but may require minor variation depending on the conditions found in each Phase. Reclamation will run concurrent with mining so it will commence as soon as enough area is avail- able to reclaim and not be redisturbed. The setbacks and side slopes from the water's edge to the slurry wall or setback limit will be resoiled and revegetated using the methods described in the following plan. On -site generated inert material will be placed in backfill areas or will be recycled/sold. The existing oil and gas wells shown on MAPExHIBITC are all shut-in, meaning they are on the list to be plugged and abandoned in the future. Once the wells are removed, all of the support facilities will be removed and the feeder lines abandoned. This reclamation plan assumes they will be removed prior to mining in the areas they affect. Should the O&G facilities still exist when mining reaches them, a Technical Revision will be filed to show how they will be mined around and reclaimed. The applicant proposes bonding the site in two Operations Stages. For Operations Stage A, the initial bond is calculated on having only the Plant Site and settling ponds bonded until mining is ready to start in Phase 1. Upon competition of prepa- ration of the Plant Site a Technical Revision would be filed to increase the bond to allow for full development of the mine as explained below. This second bond would be to cover the maximum amount of disturbance throughout the mine (205 acres), this would including a sufficient length of liner construction and bank sloping, the Plant Site, areas of seeding, backfilling, etc. If the applicant determines that the amount of disturbance at the mine may soon L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 16 EXHIBIT E RECLAMATION PLAN (coNx) exceed the bonded amount, the applicant shall submit a bond revision to the Division. Currently, the proposed mine site is primarily irrigated agricultural land, but is broken into 4 different use areas. The current uses are, irrigated crop areas; non -irrigated pasture; ditch and return flow corridors; and oil/gas operations areas with some high capacity gas pipeline ROW's around the perimeter. The agricultural uses will continue in areas where mining opera- tions have not yet begun. There is very little native vegetation present on the majority of the site because of the intensive agricultural practices that have taken place on the land. In most cases, the oil/gas operations areas have little vegetation and the high pressure gasline ROW's have been farmed for many years and the vegetation cover on those areas is consistent with farmed areas. The ditch and return flow corridors have been disturbed by ditch maintenance over the years. This leaves only isolated areas around the permit area with vegetation that may be considered native. The typical vegetation descriptions in ExHIBITsI &Jwill not match the actual current vegetation on the site due to the agricultural activities - pastureland (cattle grazing) and farming with various crops. RECLAMATION PLAN This section covers reclamation on the developed water storage reservoirs in Phases 1 thru 4. As discussed in the MINING PLAN text, reclamation will run concurrent with mining. Initially this will happen when the reservoir slope areas are being mined and graded. The plan is to use overburden or shale from the mine floor to create compacted slopes around each reser- voir. The APPENDIX contains the Deere & Ault Geotechnical Slope Stability Analysis where on page 4 they explain this method of sloping. Backfilling will be done, then once mining has reached the outer limits of a Phase, the sloping materials will begin to be placed against the working face so only minor amounts of slope work will be necessary as mining ends. In Phase 2 where mining will take place within 400 feet of the river, the bank will be backfilled to 300 feet at which point the slope into the reservoir will be backfilled and sloped. In this area no more the 500 feet will need backfilling nor will it be left open for more than 12 months. Armoring will begin as soon as bank sloping is complete on each 500 ft section. No more than 1000 feet of outside bank backfilling and sloping will be needed at any given time. This will also ensure, that if mining L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 17 EXHIBIT E RECLAMATION PLAN (core) ceases before the resource is exhausted, only a minor amount of work would have to be done to finish reclamation on the disturbed area. The temporary topsoil and overburden stockpiles in the various mining phases will be available for reclamation needs. Armoring in both Phase 1 and Phase 2 will progress with sloping, so no more than 1000 feet will need to be completed at any time. No armoring will be done along the Irrigation Return flow trench south of CR 35.5. The BANK ARMORING PLANis in the APPENDIX and explains how and where the armoring will be placed. There are no plans to install Inlets or Outlets for the reser- voirs. Those will be the responsibility of the reservoir devel- opers. LGE will be working with the Town of Platteville for directions on Flood Plain development. This facility is not in an Urban Area, not near public land, or facilities where public safety is a concern so, inlet/outlet structures for private reservoirs are not needed. When grading and shaping is completed on a large section of reservoir banks, the areas above the high water line will be resoiled and then seeded during the next seasonal planting win- dow. The EXHIBITF-RECLAMATIONPLANMAP - RECLAMATION PLAN MAP shows the sloping plans, where armoring will be installed, the area to be revegetated and areas that will be reservoirs in this plan. All reservoir bank sloping will be completed to the stated 3:1 slopes or flatter. All areas that are above the high water line, and are not being reclaimed as graveled access roadways, will have an average of 10-12 inches of soil placed and prepped for seeding. All top soiled areas will be seeded with the seed mix described in this plan, and effective weed control measures will be implemented until the Phase is released from the permit area. GENERAL DISCUSSION There are sufficient amounts of topsoil on the site so the mined areas can be resoiled to an average depth of 10-12 inches. Sufficient topsoil will be saved for use in reclamation. The available topsoil to be salvaged from the stripping process will preclude having to haul additional soils onto the site for revegetation. The existing soils on the property have been capable of producing healthy crops and grasses and are expected to work well for revegetation of mined areas. The vegetation information was obtained from site visits and data provided in the NRCS Web Soil Survey page. A copy of that report is in ExHIBITIANDJand describes the current soils and vege- tation on the properties in more detail. L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 18 EXHIBIT E RECLAMATION PLAN (cow) As outlined in the EXHIBITD-MININGPLAN, approximately 388.12 acres ± of the permitted area will be disturbed as a result of mining activities. Once mine development begins, the plan calls for the initial bond to have 205.00 acres± disturbed at any -one-time and the disturbed area may be divided between the reservoir Phases and the Plant Site in Phase 4. As mining pro- gresses across the property, some parts of the property will remain undisturbed while other areas will be either stripped, mined, partially reclaimed or totally reclaimed. The EXHIBIT C-1- MININGPLAN MAP shows how the pit will be developed. The EXHIBIT F - RECLAMATIONPLAN MAP show how the area will look when reclamation is complete. Careful analysis of the growth medium and salvageable soil will permit the operator to carry out a soil additive program and to monitor the prescribed seeding plan to determine if the plan requires revision. Under normal weather conditions, an adequate moisture reserve will be present for establishment of the pro- posed seed mixture. No irrigation is planned for the reclaimed areas. No revegetation will take place on undisturbed areas, roads or oil/gas operations access roads or facilities. The reclamation timetable shows the types and amount of land use in each Phase when reclamation is complete. Approximately 19% of the area in the permit will not be disturbed by mining, either because it is setbacks around the permit line, gasline ROW's, along the ditch and areas too small to mine that will be kept in their natural state. REVEGETATION PROGRAM The revegetation program to be implemented on the areas to be seeded with grass by L.G. Everist is detailed below. The topsoiling plan presented above and this revegetation program are devised after careful review of the existing soil conditions and present vegetation, both on the site and in the NRCS report. "Revegetation will be carried out in such a way so as to estab- lish a diverse, effective and long-lasting vegetative cover that is capable of self -regeneration without continued dependence on irrigation, soil amendments or fertilizers." (CRS 34-32.5-116 (4) (f) ) The plan is designed to create a vegetative cover around the reservoirs that is at least equal in extent to the cover of natural vegetation before mining. The use of species native to the area are included as part of this plan. Since the intended use of the reclaimed land along the reservoirs is rangeland, any slopes created will be commensurate with this final land use. L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 19 EXHIBIT E RECLAMATION PLAN (coNT) Seed will be drilled wherever possible, when drilling is not possible, the seed will be broadcast. The revegetation plan provides for the greatest probability of success in plant estab- lishment and vegetative development by considering environmental factors such as seasonal patterns of precipitation, temperatures and wind. Other considerations, such as soil texture, fertility, slope stability and the direction in which slopes face, have been considered. A weed control plan is included in this submittal, see the APPENDIX. Graveled maintenance roads will be built around each reser- voir and around each gas/oil wells, should any remain, where no seeding or resoiling will take place. This will provide room around each well or reservoir to service it as needed by the well or reservoir owners. These access roads and graveled areas are shown on EXHIBIT F - RECLAMATION PLAN MAP . SEEDBED PREPARATION When mining on an area is complete or there is room to begin reclamation, any compacted areas will be ripped and scarified to created a deeper root zone under the resoiled areas. Once this is complete, the stockpiled soils will be spread. If tests show a fertilizer is needed, it will be broadcast spread on the seed- bed at an adequate rate suggested by NRCS or a seed- ing/revegetation contractor. On the areas where seed is broad- cast, the surface will be left fairly rough to trap the seed and keep it from being affected by wind. SEEDING TIME The grass seed mixture will be planted from early fall through spring (October through May). The time of planting will be controlled by when the resoiled areas are ready for planting. If fall planting is convenient, the seeding will be done before the first freeze (about the time Winterwheat is planted). If spring planting is called for, it will be done in March or April, weather permitting, after the last frost. Both periods assure there will be adequate residual ground moisture available for the newly planted seeds. GRASSES The following seed mix was developed by the NRCS office in Brighton many years ago and is used on all L.G. Everist mining operations in Weld County. It has proven to be very reliable. This mix will place approximately 41.2 seeds per pound per sq-ft as prescribed by the NRCS planting guidelines. If the seed is broadcast, the amount will be doubled and spread on a rough L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 20 EXHIBIT E RECLAMATION PLAN (cotes) surface. The seeded areas will then be dragged or raked thor- oughly to set the seed. Under normal conditions, the operator will strive for a 30 to 40 percent cover rate on the grass revegetated areas when reclamation is complete. No trees will be planted, because they are not compatible with reservoir development as their root systems affect the liners. It is expected some natural invasion from adjoining areas will occur. PROPOSED SEED MIX Western Wheatgrass (Aribba) 5.0 Big Bluestem (Champ) 2.5 Blue Grama (Hachita) 0.6 Switchgrass (Blackwell) 1.75 Total 9.85 It has been our experience on other operations, that the seeded area may have a heavy cover of weeds after the first year. The second year, there are fewer weeds as the grasses start to take hold. By the third year the weeds are mostly gone and the grass has established itself so it will grow in future years. These weeds also tend to shade the seedbed, retain snow in the winter and act as a wind break for the newly emerging grasses. The area will then be monitored for success of revegetation until it is released from the permit area by the Mined Land Reclamation Board. WEED CONTROL The revegetated areas will be monitored closely each spring for the first two years to determine if noxious weeds are invad- ing the area. L.G. Everist, Inc. will implement a weed monitor- ing and control plan that covers the areas actively used by their operations. LGE understands their responsibility for weed control on th permit area and will ensure that weed control on non -mining areas is performed. Weed control in the mining and reclamation areas will be initiated if the problem becomes serious or if an excessive weed cover is still present at the end of the second year. In no way should this be taken to mean that L.G. Everist will try to eradi- cate all the weeds from the site. Some weeds are beneficial to the upland game species in the area, they provide important L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 21 EXHIBIT E RECLAMATION PLAN (co.) protection from the elements during winter, and nesting sites during the spring. Total eradication of weeds from the site is not necessarily desirable or possible, so we will be using stron- ger controls on the noxious weeds and controlling the rest as needed. Weed control may be done through mowing or chemical means. Control of noxious weeds is important to the state, so we will follow USDA Extension Service recommendations to control them. Our Weed Control Plan is included in the APPENDIX. IRRIGATION No irrigation is planned for the revegetated area around the reservoirs. It makes the vegetation dependent on water and does not promote a vegetation cover that is diverse and capable of self regeneration. RECLAMATION PERFORMANCE STANDARDS (The following information is presented to address specific parts or Rule 3 as required by the MLRB Rules and Regulations) L.G. Everist, Inc intends to operate the mine in compliance with the Reclamation Performance Standards of Rule 3. Grading will be done to create a final topography that is compatible with the intended final land use. These slopes will be 3:1 or shal- lower and on the unmined areas they will remain in their current configuration in an attempt to retain the present drainage pat- tern across the property as much as possible. A mine entrance sign that conforms to the requirements in Rule 3.1.12 (1996) will be installed at the entrance to this facility prior to commencement of mining. The material used to create the slopes will be native mate- rial found on the site. It will consist of sand, gravel, over- burden and topsoil. The Phases will be reclaimed so that a suitable grade for drainage exists. All surface runoff within the mine site will be directed into the excavated area, and all surface runoff outside of the permitted area will be allowed to flow into natural existing drainages outside the site. All grading will be done in a manner to control erosion and to protect areas outside the affected lands. All backfilling and grading will be completed as soon as feasible after mining is completed. All refuse will be hauled away or disposed of in a manner that will control unsightliness and protect drainage systems from pollution. L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 22 EXHIBIT E RECLAMATION PLAN (cow) There are no acid-forming or toxic materials inherent in the sand and gravel deposit. If petroleum products are stored at the site for mining equipment and operations, they will be stored as prescribed by applicable laws. Any storage tanks will be surrounded by a berm or be of the latest multi -wall construction, adequate to contain any fluid spilled, should a tank rupture. In addition, there is adequate absorbent materials on site to contain any spills that would occur. Maximum slopes within the mined area will be within the limits set forth in the Rules and Regulations of the Board and will be capable of being traversed by machinery. The slopes between the eastern and western reservoirs will remain undis- turbed and in their natural state, slope and appearance. The operator does not expect prevailing hydrologic condi- tions to be disturbed. L.G. Everist will comply with applicable Colorado water laws and regulations (as the operator understands them) which govern existing water rights. The operator does not expect to adversely affect the prevailing hydrologic balance of the affected land and surrounding areas. Nor does the operator expect to affect the quality of water in surface and ground -water systems both during and after the mining operation and during reclamation. In addition, the operator shall comply with appli- cable Federal and Colorado water quality laws and regulations. Any water used in the mining operation and the processing plants will come from water owned or leased by L.G. Everist and legally suitable for use in mining operations. EXHIBIT G -WATER INFORMATION contains specific information concerning impacts and uses of water at this mining operation. A Groundwater Model and Water Quality Monitoring plan are included in ExHIBITG-WATER. No dredging takes place at this facility, there are no temporary siltation structures involved in this operation and no mining will be done in a river or waters of the United States. A U.S. Army Corps of Engineers 404 Permit is not required for this operation because there are no jurisdictional wetlands on the site. The operator has been approved for a RGP-5 from the Corps for the relocation of 1 irrigation return flow ditch in Phase 1, along the eastern side of the phase A copy of the JD and RP5 are included in the file. Temporary settling ponds will be constructed on the site to collect water from the material washing at the processing plant. The settling ponds will be removed during final reclamation. The fines in the wash -water settle out in the ponds and the water is then recirculated to be used again in the processing plant. There will be no earthen dams on the mined area. L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 23 EXHIBIT E RECLAMATION PLAN (corn) Groundwater collected from the dewatering trenches may be discharged from the site, after any natural fines have settled out. The discharged groundwater quantities will be measured and sampled as per the requirements under a CDPS - Sand and Gravel Mining Process Water and Stormwater Combined Permit. The mining and reclamation plans have taken existing wild- life conditions into consideration. The final reclamation will enhance the area for wildlife use. The mining and reclamation plans allow for the safety and protection of wildlife remaining on the mine site, at the processing site and along all access roads on the site. In practice this is done by limiting the amount of disturbance, restricting truck and equipment speeds to 15 mph or less and doing concurrent reclamation. Mine employees are trained to deal with wildlife found on the mine, during operating hours to avoiding harming them. See ExHIBITH-WILDLIFE for more information. As mentioned previously, topsoil on the mine area is of good quality, so it should be a decent growth medium for reclamation. When topsoil is removed, to reach the sand and gravel deposit, it will be segregated and stored in graded stockpiles, generally located in areas where disturbances by ongoing mining operations will be at a minimum, i.e., along setbacks on the pit perimeter. If the topsoil (and overburden) stockpiles remain undisturbed for more than a year, the approved seed mix will be applied to pre- vent erosion, to control weeds, and to keep them viable for reclamation. Fertilizer and other soil amendments may be used as discussed in this plan. If revegetation problems occur before release, an analysis of the problem area will be done and the area will be revegetated again as necessary. The seed mixture and rates may be revised as needed to complete reclamation, if a substantial modification is required, the Division will be notified prior to making the change. This gives us the most flexibility to complete reclama- tion successfully. RECLAMATION TIMETABLE Reclamation will begin once enough area has been opened so that any reclamation completed will not be disturbed as mining progresses. This may take 5 or more years depending on the economic conditions in the area and the amount of material mined. The operator anticipates approximately 81% of the total mined land will be reclaimed by the time mining is completed. L.G. EVERIST, INC. - WEST FARMS RESERVOIR May 2023 24 EXHIBIT E Table E-1: Reclamation Phases RECLAMATION PLAN (corer) ACRES `± 1 3 to 5 190.23 141.25 8.09 3.02 MISC. (DITCHES UNDIS- TURBED AREAS, ETC.) 37.87 2 3 to 5 145.39 100.15 18.38 2.80 24.06 3 3 to 5 60.36 37.71 5.35 2.31 14.99 4 3 to 5 76.42 56.14 7.05 2.67 10.56 Totals 472.40 335.25 38.88 10.80 87.48 L.G. EVERIST, INC. e WEST FARMS RESERVOIR May 2023 25 L.G. EVERIST, INC FIRESTONE GRAVEL RESOURCE FIGURE E -I I 1 uat'�.cd: I a •./1n I b• •• la/ If •••••••• ✓ . /vW..{M/ • • • • • • • • • • • • • • • • • • • • • • • f-. • • • • • • •. 0000••••••••••••••••• • • • • • • • 000000000000005000500000000 •••.•.••••.••.• •.•••••• 0000000000000m* 4,000.000. • • • • • • • • • • • • • • • 00000•0 • • • • • • PHASE 2 TOTAL 145.39 AC: APPROXIMATE RESERVOIR AREA 100.15 ACRES • - _ • • • • • • • • • • • • • • • • N • • • • EVfiRlsi, 100 Ft. • • • • • • • •••••••• S.....• •••••••• ••••••• ••••••• ••••••• •• NI •••• •• •••• .•.. ••••• ... •••• ••• •••••• • • • •••••• •• ••••••• • • ••••••• ••••••••••• •• ••••••• •• ••••••• •••••••••• •••••••••• ••••• . • • . • •••••••• • 0•••.•• .••••.• .�i • •• • • • • • • • • Q• ••..•• ••� •••.•• . 4•••••• . •••.• . �3• •••.• •••• • ••• ••• •• •••• •••••• • •.•:•••••• •••••• S . • • • • • S.....• •OOOOO • ▪ •• • • • . • • • ••• ••••••• ••• ••••••• • • • • • • • • • • • •.• } ••••••• .•• c •••••• • • • • • • •••••••• •••••••• ••••••••• •••••••• •••••••• 5.....•• ••••••• 5.....•• •••••••• •••••••• S.....• •••••• •••••• • • • • • • • .• /••••• ••• •••••• ••••••••• •••• •••• ••• ••••• • •. _r }_ - _v• �_iI _ • • _ ••• ••••• •:Y�:— --_!►ter: _ __ __-. �•. • • ��o s� rd i.iia ll %i%i//iii.�/�/%Ni viii . �. _ ��s Illi• • • • • • • • _an��-iil� . �Nww.rri�j�4R/e•OI /�//II%afirll f P oh•• a%I: - .. • • • • • • /../^ii�� jai.. /�! Ia I On I 'I / /I7/// //!/I9R ... , 7,40We1/LI.✓I.•ia��.•///�/II/.!///1_� 4 '%isr?•7•i /., it daD�+hw � /�>rii..�l.�r • • • • • • • • • j sue•_ �r-��.�� i ii��. � �r�ii� .w__ �/�_ �'r�� • ♦Ii'I/' !%IL//�'��Q�. .. • • _• 1d:1�if=.9':? III "OA i ' ` • • • • • Ii//�O I I sr•� w.. • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •••••••••• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • Se • • • • • • • • • • • • • • • • • • AFFECTED LANDS/PERMIT LINE DITCH PHASE 1 TOTAL. 19023 AC t APPROXIMATE RESERVOIR AREA 13125 ACRES!. LAKE AREA REVEGETATED ROADS & GRAVELED AREAS NON DISTURBED AREA .•• ......... •• ••••••••• • .•••••••••••• �• ••••••••• .• •••••••• ..• ••••••••• •••••••••••• •••••••••••• ••••••••••••• •••••••••••• • •••••••••••• ••••••••••••• .• •••••••• ••:•........ .• • • • • • •• ••••••• • • • • • • • • .. •••••• ••. et..•• • IIIIIII... 1. A • • • • • • • • • 555 •• • •• • • ,• • • • • •. • • . 0\ 443•.M ♦ ..E t• • •..,lC• . • o I� •• • • • • • • •• • • • • • • • • • • • • • • • • • •• • • • • • •• • • • • • • • • • I. • • • • • • • MAY 22. 2023 14:18:54 EXHIBIT G WATER INFORMATION Introduction The site is located about 1.5 miles west of Platteville, Colorado. Please refer to EXHIBIT B - VICINITY MAP for the property configuration and the relationships to surrounding geological features. The site is bordered on the south, west and northwest sides by irrigated agricultural lands and on the east and part of the northeast side by the South Platte River. There are 2 irrigation return flow ditches that cross the property and other onsite temporary agricultural feeder ditches that carry water to the fields being irrigated. Two center pivot irrigation systems are fed by wells owned by L.G. Everist, Inc. There are 7 registered irrigation wells, one domestic well and 6 piezometers on the property. Within 200 feet or the permit line there is 1 Domestic and one Geothermal wells located in the southwest corner of the site. Based on regional groundwater studies and the experience gained by L.G. Everist, Inc. during numerous previous permit applications they have found that slurry wall liners mitigate any impacts to groundwater on nearby areas surrounding a lined reservoir. Ground water in this area tends to flow from the west towards the river, the depth to water on the flood plane level averages 3.55 feet below the surface and along the western terrace deposit the depth to the water table is 19.5 feet. Data for the monitoring well information collected thru the month of submittal is shown on TABLE G-2 ON SITE GROUND WATER MONITORING DATA. If any significant groundwater changes do occur, they can be miti- gated as discussed below. In May 2023 a Groundwater Model (GWM) was prepared by Schnabel Engineering to provided potential impact information of the ground water levels by installing Slurry Wall liners around the reservoirs. That report is provided at the end of this exhibit. In addition, Molen and Associates was asked to prepare a Water Quality Monitoring Plan for the permit area. That plan is also included in this exhibit. These reports are used in the following text to establish the mitigation and testing plans for the West Farms Reservoirs mine. The mining operation will have minimal effect on the South Platte River in the form of minor groundwater depletions due to evaporation and water uses associated with mining. The depletions to the South Platte will be mitigated thru a temporary Substitute Water Supply Plan (as required and approved by the Division of Water Resources) to prevent injury to vested senior water rights. L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 28 The reclamation plan proposes the creation of 4 slurry wall, lined reservoirs that will not be hydraulically connected to the South Platte River or any alluvial aquifer. The reservoir areas will be sealed prior to mining, thereby eliminating the groundwa- ter draw down which is typically associated with mine site dewatering. This will also eliminate or minimize the possibility of any adverse impacts to the single nearby alluvial well. Potential Water Resource Impacts Ground Water Wells We expect this mining operation will have no or minimal impacts on the prevailing hydrologic balance. Sand and gravel mining related impacts to groundwater wells near the pit will be mitigated through the installation of slurry walls around the perimeter of new reservoir mining phases prior to the start of dewatering in each reservoir Phase (see ExHIBITD-MININGPLAN) . TABLE G-1 WATER WELLS WITHIN 200 FEET is a list of 12 wells from the Office of the State Engineer's files that are located within 200 feet of the permit area. (NOTE: THE WELL PERMIT LOCATION SHOWN IN THE TABLE HAVE BEEN GPS LOCATED BY THE STATE ENGINEERS OFFICE'S AND GROUND VERIFIED). All wells except the geothermal well (Blue highlight) are shallow wells, at this time, there is one shallow well within 200 feet of the permit area that is not owned by L.G. Everist, Inc. The Palombo domestic well is located near the southwest corner and is up gradient from the mining area. LGE owns the 8 wells listed for Norgren Farms and is in the process of filing a name change. There are 2 monitoring wells along WCR 32.5 owned by Metro Wastewater Reclamation District, the eastern most one is more than 600 feet from the permit line. Prior to exposing groundwater or installing a slurry wall liner in any Phase, a well survey will be performed on any shal- low wells within 200 feet of the phase. Wells that are located within 200 feet of the permit area, that do not need to be tested are(a) owned by L.G. Everist, Inc., (b) monitoring wells, (c) deep wells, because deep wells will not be affected by potential surface impacts due to mining. L.G. Everist will attempt to obtain for each shallow well to be tested the following data: Basic Well construction data that is currently available. Total well depth Depth to static water level, Depth of pump intake Conduct pump test to determine well yield (subject to DWR Regulations) Conduct analytical sampling of all Domestic Drinking Water parameters for any residential wells. L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 29 Exhibit G Water Information (cont) All data collection will be completed at L.G. Everist's expense. Data will be provided to DRMS and the well owner upon their request. If a well owner chooses not to allow the permittee access to collect the above data, they will be provided with a form that they can sign and date to document that they have been provided with an opportunity to have their well characterized at the permittee's expense, but have chosen to decline to partici- pate L.G. Everist, Inc. has installed 6 piezometers (a.k.a. Monitoring Wells) around the mine and plan to install an addi- tional 6-7 wells to collect more groundwater elevation data and to be used for water quality monitoring and research. Their locations are shown on the maps and on MAP EXHIBIT G-1 WELL MAP . L.G. Everist started data collection in July 2019 and will do monthly depth readings throughout the life of the mine. We will provide a summary of the data yearly with the Annual Report. Mitigation Trigger Starting in July 2019, L.G. Everist, Inc. began to collect groundwater elevations from newly installed monitoring wells on and around the mine area to establish historic ground water elevations around and on the site. The period July 2019 until installation of the Phase 1 liner will be used as the baseline for triggering mitigation actions. This way the baseline data needed for the areas are in place well before installation of the slurry walls will begin. The permit area has two areas where the depth below ground level area vastly different. The dividing line between these land features is a natural bank where the river valley transi- tions from the flood plain on the east side to the upland area along the west side. In the eastern area, Phases 1 and 2, the natural groundwater depths vary from 2.9 to 4.4 feet, average 3.5 ft. below the surface. On the western areas, Phases 3 and 4, the natural groundwater depths vary from 16.7 to 23.9 feet, average 19.5 ft., below the surface between June 2019 and October 2022. These ground water depths and averages may change prior to mining commencing. The important area for mitigation lies along the eastern section of the south line or area along the Abbett Farms land. Along this line the average depth to ground water varies from 7.2 on the west to 4.4 feet below the surface at MW #7, near the river. This covers a section approximately 1860 feet west of the river. The mitigation plan is designed for this area as it could likely be the most impacted if there was a significant increase to the groundwater elevations due to mounding. The model pre- dicts that the potential mounding affect would vary from as much L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 30 Exhibit G Water Information (cont) as 2.5 feet on the west end of this strip to approximately 1 foot at the eastern corner of the slurry wall on the east. It also indicates that if needed, a simple perforated pipe, 12 inches in diameter would be capable of regulating the groundwater to his- toric elevations. In this mitigation trigger plan, the trigger limits will be set at as a two (2) foot plus or minus change over a 3 -month running average. Because the average groundwater levels are already close to 4 feet from the surface in the southeast corner of Phases 1, limiting the maximum rise before mitigation to 4.0 feet is too restrictive. The data collected to date shows the historic high to low swing is much as 1.44 feet up or down- ward possibly due to outside impacts such as, drought, storm events or decreased irrigation. A 2 foot increase over 3 month running averages will keep the minimum depth to below the 24 inches cover level required by the SEO exposed ground water requirements. As for the shadowing effect of the slurry walls, we do not expect this to be a problem where the slurry walls are in close proxim- ity to a flowing water body like the irrigation return flow ditch that bisects the mine site north to south and the South Platte River along the east and north sides. The Groundwater Model confirms that any shadowing or mounding along the river will only affect the property owned by L.G. Everist and will not cross over the river. If during the course of mining or reclamation complaints from the well owner or adjacent property owners are received by the permittee, the permittee will commence an evaluation and investigation, including providing replacement water to the well owner if necessary, within 48 hours. The method used to mitigate groundwater mounding may include a ground water drain along the Abbett property to maintain ground water elevation to the average level measured prior to installation of the slurry wall liner. This drain may be in the form of a ditch or a buried perforated pipe as described in the GWM. DBMS shall be notified within two business days of the complaint and the proposed initial steps for the evaluation of the complaint. A written report will be submit- ted to DBMS within 30 days detailing the information collected during the investigation of the complaint, and proposed mitiga- tion activity, if required. Post Reclamation Any slight groundwater mounding and shadowing associated with the slurry wall sealed portions of the pit are not antici- pated to produce any adverse impacts to adjacent properties. Potential groundwater mounding around the mine will be mitigated by the South Platte River, road corridor and the single irriga- L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 31 Exhibit G Water Information (cont) tion return flow ditches surrounding the lined area. These existing water features will serve to regulate and balance groundwater elevations in the alluvium adjacent to the sealed pits. The GWM suggests that once the groundwater reaches the maximum predicted levels it will stabilize and the corridors left through and around the liners will allow water to pass around the liners. The operator does not anticipate any long-term post -reclama- tion ground water depletions, but if there are any, they would be replaced through a Colorado Water Court approved Plan of Augmen- tation. L.G. Everist, Inc. expects that prior to competition of the reservoirs a local government agency will purchase the storage rights and may begin final construction on the reservoirs. As water storage reservoirs are completed, they will be turned over to the purchaser for further development to complete the final features needed for developed water storage reservoirs. L.G. Everist will submit Technical Revisions to the DRMS if the pur- chaser makes changes prior to L.G. Everist receiving final recla- mation approval and acreage releases from the Division. Water Quality The attached report prepared by Molen Associates explains the plan for collecting the necessary background water quality information of the permit area. Included is a list of the chemi- cals to be tested for and their frequency. This plan includes installing 6-7 additional monitoring wells around the mine and use 4 existing wells that lay outside the proposed slurry walls to collect the data needed for 5 quarters prior to mining and yearly testing as needed. Once the 5 quarter samples are col- lected and analyzed a Technical Revision may be filed to reduce the required monitoring list for the life of the mine. Discharge Permits Surface Water Management When necessary, ground water will be pumped and discharged from the West Farm Reservoirs mine under a CDPS Permit which the operator will obtain from the Colorado Department of Public Health and Environment, Water Quality Control Division (CDPHE- WQCD). This permit will remain active during the life of the mine. The discharge points may change as mining progresses and all necessary changes will be submitted to the WQCD for modifica- tions to the discharge points. Runoff from disturbed areas will be managed and controlled to protect against pollution, of either surface or groundwater through the implementation best management practices which in- clude sloping disturbed areas inward toward the site, vegetating L.G. EVERIST, INC. - WEST FARM RESERVOIRS 32 May 2023 Exhibit G Water Information (cont) berms and other disturbed areas, and other site -specific controls as needed. As per the State Engineers Office requirements all stormwater collected for treatment will be discharged within 72 hours after the storm event ends. Estimated Consumptive Water Use The annual consumptive uses of water for the West Farms Reservoirs mine are estimated to be: USES VOLUME Acre-feet 4% Moisture Loss in Materials (1.7 Million tons) 50.05 Dust Control 3.00 Water Surface Evaporation (10 ac) 23.80 Total Consumption (Augmented) 76.851 Substitute Water Supply Plan Ground water depletions associated with L.G. Everist's West Farm Reservoirs operation will be covered under a substitute water supply plan (SWSP) pursuant to C.R.S. 37-90-137, approved by the State Engineer's Office (SEO) for replacement of the ground water depletions due to mining. This plan will be updated and renewed every 2 years. The Applicant will maintain a SWSP throughout the life of the mine. After completion and reclamation of all lined reser- voirs there will be no long-term evaporative depletions. However, if any unlined open surface water areas created by mining remain at the end of reclamation, then a court approved augmentation plan will be applied for before reclamation is complete. 100 -Year FloodPlain Portions of the West Farm Reservoirs mine are located within the 100 -year floodplain of the South Platte River. The applicant will obtain a Flood Hazard development Permit from the Town of Platteville if needed. The location of the 100 -year flood line shown on the affected lands was transferred from FIRM Panel 08123C1905E, effective 1/20/16 to all maps. L.G. EVERIST, INC. - WEST FARM RESERVOIRS 33 May 2023 TABLE G-1 WEST FARM RESERVOIRS - WATER WELLS WITHIN 200 FT Receipt Permit Number Contact Name Section Q40 Q160 Latitude Longitude Permit Category Use(s) Completed Well Depth Perforated Casing Top Perforate d Casing Bottom Static Water Level Static Water Level Date WDID Associated Case Numbers SE/4-Sec 10 -3N -67W None within 200 feet. 5W/4 -Sec 11 -3N -67W None within 200 feet. SE/4-Sec 11 -3N -67W None within 200 feet NW/4-Sec 13 -3N -67W None within 200 feet. SW/4-Sec 13 -3N -67W 9063639 264636 METRO WASTEWATER RECLAMATION DISTRICT r ! !'.';' `f, 40.2252 -104.848492 Monitoring Observation (greater then 600 ft) Monitoring/ Sampling Sec 14 -3N -67W . ., ; 15331-R L.G. Everest. Inc (NORGREN FARMS) 14 SW NW 40.228169 -104.867362 General Purpose Irrigation 76 207463 W5677 89066 264638 METRO WASTEWATER RECLAMATION DISTRICT 14 ',r .• 40.225342 -104.854051 Monitoring Observation Monitoring/ Sampling 20 96398-A L G. Everest Inc (NORGREN FARMS) 14 NW SW 40 224885 -104 863161 Residential Domestic 41 21 41 ' '--H �ti;' 15335-R L G. Everest, Inc (NORGREN FARMS) 14 NE SW 40.223387 -104.861225 General Purpose Irrigation 207469 W5677 0353828 A 15337-R L G. Everest, Inc (NORGREN FARMS) 14 SW SE 40.219348 -104.851678 General Purpose Irrigation 30 10 30 207471 W5677 366352 15332-R L.G Everest, Inc (NORGREN FARMS) 14 SW SW 40 249732 -104.8635 General Purpose Irrigation 207466 W5677 0541454C 15333-R L.G- Everest, Inc (NORGREN FARMS) 14 SE SW 40.218136 -104.860603 General Purpose Irrigation 53 207467 W5677 9062188 15334-R L.G Everist, Inc (NORGREN FARMS) 14 SE SW 40.2184 104.857769 General Purpose Irrigation 207468 W5677 9062189 15336-R L.G Everest, Inc (NORGREN FARMS) 14 SW SE 40 220489 -104.856153 General Purpose Irrigation 35 207470 W5677 NE/4-Sec 15 -3N -67W None within 200 feet. 5E/4 -Sec 15 -3N -67W None within 200 feet. NE/4-Sec 22 -3N -67W None within 200 feet. NW/4 Sec 23 -3N -67W �i 1' � F bE 770 304711- PALOMBO, Jeff (MAGNESS LAND HOLDINGS) 23 NW NW 40.217618 -104.866466 Residential Domestic, Stock 75 20 4/26/2017 9058772 91-GX PALOMBO, JEFF 23 NW NW 40.217753 -104.866008 &eoexchange System Loop Fly Irk Geothermal 300 NE/4-Sec 23 -3N -67W None within 200 feet. NW/4-Sec 24 -3N -67W None within 200 feet. updated 8/23/2022 slo EXHIBIT G - TABLE 2 MONITORING WELL DATA MONITOR WELL NO. MW 1 MW 2 MW 03 MW 04 MW 05 MW 06 MW 07 NORTHING, FT 1,327,768.61 1,325,656.48 1,326,568.90 1,324,539.64 1,322,997.25 1,323,208.40 1,323,173.33 EASTING, FT a 3,176,657.95 3,176,688.06 3,179,344.23 3,179,763.21 3,176,684.67 3,179,342.95 3,181,259.32 ELEVATION (TOG), FT 4,799.803 4,801.272 a 4,779.160 4,782.169 4,804.36 4,802.13 4,791.08 CASING HEIGHT, FT 3.57 3.97 3.74 3.24 3.62 3.02 3.29 ELEVATION (TOC), FT 4,803.368 4,805.242 4,782.900 4,785.409 4,807.98 4,805.15 4,794.38 Adjusted (D08 -DOS) 2019 7/10/2019 23.13 19.66 2.48 2.41 15.22 16.98 2.93 8/7/2019 23.37 18.03 3.20 1.75 14.12 i 16.85 4.36 9/10/2019 23.46 18.45 2.98 2.57 14.58 16.76 4.36 10/8/2019 23.92 19.16 3.01 2.63 15.40 16.87 4.35 11/7/2019 24.15 20.01 3.04 2.81 16.56 17.23 4.21 12/10/2019 24.25 20.65 3.21 2.96 17.52 17.61 4.06 2020 1/13/2020 24.31 20.97 3.24 3.11 18.23 17.86 4.31 2/11/2020 24.31 21.16 3.76 3.16 18.30 17.91 4.26 3/17/2020 24.21 20.93 3.99 3.11 17.43 17.72 4.16 4/29/2020 24.15 20.83 3.76 3.18 17.68 17.78 4.91 5/29/2020 23.95 20.18 3.41 3.12 16.25 17.52 4.64 6/25/2020 23.85 19.68 3.14 2.81 16.01 17.24 4.07 7/20/2020 23.25 18.28 3.28 2.61 16.21 16.81 4.53 8/20/2020 23.60 17.41 3.45 4.56 12.89 16.65 4.81 9/30/2020 23.62 18.65 3.45 2.68 16.12 16.72 4.63 10/29/2020 23.64 19.52 3.24 2.76 14.39 16.89 4.60 11/18/2020 23.88 20.05 3.25 2.87 16.73 17.34 4.05 12/18/2020 ■ 24.04 20.55 3.11 3.05 16.60 17.71 4.21 2021 1/14/2021 24.29 20.89 3.25 3.17 18.40 17.80 4.60 2/22/2021 24.92 21.38 4.05 3.36 19.07 17.97 5.27 3/9/2021 24.51 21.41 3.56 3.16 19.26 17.96 4.28 4/26/2021 24.31 21.22 3.74 3.21 18.53 17.77 4.52 5/25/2021 23.87 20.67 3.44 2.98 17.37 17.53 4.22 6/21/2021 23.83 20.22 3.17 2.57 16.67 17.26 3.89 7/19/2021 23.20 17.39 3.24 2.64 13.43 16.76 4.47 8/9/2021 22.95 20.22 3.20 2.56 12.59 16.65 4.05 9/17/2021 22.89 17.48 3.49 2.73 13.61 16.69 4.63 10/12/2021 23.62 18.80 3.35 2.67 14.52 16.72 4.25 11/22/2021 23.89 19.97 3.19 2.78 16.71 17.27 4.46 12/2/2021 23.95 20.17 3.14 2.90 17.05 17.39 4.12 1/20/2022 24.99 21.15 4.08 3.42 18.43 17.87 5.26 2/9/2022 24.66 21.34 3.54 3.14 18.86 17.80 4.40 2/27/2022 24.72 21.19 3.50 3.27 4 18.65 17.86 4.88 3/4/2022 24.48 21.16 3.70 3.17 18.57 17.82 4.43 4/19/2022 24.76 21.37 3.98 3.36 18.42 17.93 5.33 2022 5/17/2022 24.80 20.85 3.88 3.20 16.92 17.63 4.92 6/13/2022 24.03 20.11 3.20 2.75 16.67 17.17 4.00 7/26/2022 23.54 17.75 3.19 2.56 13.24 16.86 4.62 8/30/2022 23.23 17.53 3.03 2.52 12.25 16.72 4.23 9/30/2022 23.58 17.90 3.12 2.68 13.62 16.72 4.70 10/24/2022 23.74 19.04 3.21 2.87 14.46 17.04 4.61 11/22/2022 23.86 19.73 3.30 2.93 15.78 17.28 4.51 12/21/2022 23.98 20.43 3.35 3.01 17.18 17.50 4.36 1/11/2023 24.24 20.63 3.50 3.11 17.88 17.68 4.61 2023 2/16/2023 24.48 21.03 3.65 3.26 18.63 17.86 4.91 3/8/2023 23.93 21.03 3.45 3.01 18.68 17.78 4.41 MEAN DEPTH TO WATER MAX. DEPTH TO WATER MIN. DEPTH TO WATER NET CHANGE 23.94 20.20 3.29 2.95 16.69 17.37 4.42 24.99 21.41 4.08 4.56 19.26 17.97 5.33 22.89 17.39 2.48 1.75 12.25 16.65 2.93 2.10 4.02 1.60 2.81 7.01 1.32 2.40 average depths terrace wells 19.55 FP wells 3.55 35 WEST L.G.FARM RESEVOIR5 Map Exhibit G-1 - Water Wells Within 200 feet • r* ts I 0 Or, • 4 L ;2 2 I 2 r r� 2 I I 2 I 2I I 2 t 2 I • 2 I 2 I 2 I 2 I 2 12\aor- tOth---6� 1 GX NOTES saalen6}-6 2 WF-MW-1 1-15331 R WF-MW-5 Proposed • Proposed i ♦ WF-MW-3 01W-264638 D-96398 - r w. -- d Thtop51ed /7. •-Nt‘ r WEST FARM 040° 13' 25.1536" N 104° 52' 02.8563" W-\\ i 6-6-6 1. Data for wells shown on this map islisted on Table G-1 and is from the State Engineer records. 2. Well locations shown on the map are confirmed via ground check. 3. All wells except the Geothermal (GX) well are shallow wells. el -15335R 5332R .11 WF-MW-4 It •I-153368 C 6 Proposed 6 I a • U MW -264636 6 2f 1 V toii2 � f�, Lt 2 2 2 -153378 2.. WF-MW-6 1 IA•2 kt `11/-7 153347RnmLansairoposed.WF-MTI 2■ 2-2--2--2-2-2 2--2-2 6--6-6--6--6 6-6 61-6. —6 2-2 2-2 6--6x6 WELL KEY I 6 6 6 1 s Verified Irrigation Well Domestic Wells • Geothermal Well ♦ ♦ a p• 0• Site Monitoring Well Proposed WQM Well Third Party Monitoring Well 2 2 200 FT. Offset 6 6 600 FT. Offset I. 4. Proposed new WQM well locations shown on map may change when installed. 36 MAY 12, 2023 — 15:41:51 E; BIT O Monitoring Well Graphs WATER (CONY) 4805.00 4800.00 . 4795.00 4790.00 4785.00 A A 4780.00 v rn a) i ✓ t 4775.00 4770.00 4765.00 A V V V V v v J v v v -4 V V ' U' U' Sn P F' cn (n co cn O1 co co cn A A (J1 a) A V v 91 A v V a) A V v a) A v V a) A V a) A V V 5-n „„ O co O• N v -4 V a A v v 01 A v A v v in A A v 91 A a A a a1 V v ••••.1 A O cn .264 v w• A fgs cn b A A V v Vi O A v V at 'CO N A v A -4 V A r V (n Tat yr O O A v V a A V v a N A y ti 9, e a Ground elev. 4799.8' A V v A J cn A N) A V 91 0) A V w 4760.00 0 Ar 9 09 09 4:"04))OHO o909 49 09 019 019 O1'9 �O 1019\~ 0\.\'L q\1' '1°\q\1. isN'y~ ,y'L�~�\~ '��1�\~ ~ 151\'�i�11`� \ %CI. <P. (aCt. 41. 40. q�" ~ ,4O\�� ft$t � ,ti�►�,q� ��b� % tMW1 Water Leve datal Ground Surface —Average (4775.86) Max (+2) Min (-2) O,Lo at 09 09 O.5 ,yO11 ,itsb 42 O'L~ OI% O'LS O'L~ O1 ' O1~ O'L~ 6* cp. or °titi ce F titi P) e ti.ti °% titi titi pi> tip ASV �1' o f 1q1. 11 1q tie "D \1619 ��1ti 1� 1 %Cs a\ h� d� 1� q O 1O1' titic' 11.11' %\ - 3 WEST FARM RESERVOIRS MW #1 E; BIT O Monitoring Well Graphs WATER (CONY) 4805.00 4800.00 4795.00 4790 00 4785.00 Ground lee 4801.27' �' CO CO a V N A -NJA CO a a W V V A .A V N V a A N A °D W Co - a A A a a oo ~ °° COVa W va CO W V co a a a U1 V W CO a N }n a co N co �! A A A A V Co cn co V a A L, Co V �l 'A' V V co --' U? O _' CO V� V A a V A v 0OD �0 V 00 (n N V V V N a W N a is V A V A ..� V N 45 �j m 4780.00 • 4775.00 4770.00 4765.00 Oti, O O W W A in N V • U) A - N co cD (n O O (71 p0• O V1 in PP O O 0 fn O O A cn A O N N ( N a VI CLru —e—MW2 Water Level data Ground Surface Average (4781.07) Max (+2) Min (-2) O.cc, O.s, O,1,OO1O O1,OO,1,O O,1OO,1OO,1O01,\1\�1ti~ '1,' Ose/%ij \~1\,L b\��\,L h\��\,L (o\�h\L 1\�O\\�O\,L °'\�O\1 1O\l, 11\~g 1�\~�\ 'y\~b\tip L��\1p 1>n>ti>, \�\,LO b\��\Lp h\�hSI' O\��c' \\��ct- \ " °1\~1ce y,1ti1.tititi1111 ,1O ~(cit. 1~\L\ ~\L\ 1\~�\.yO1\~b\,LO \%\1O �O\~,L\ ~�\�,L\ 'y�cS1- 'y\�O\,LO �\�\.1O 1\,i,cr \tP# A\~s\,1O `,\11\,tiO O\��\, 1,1/4)\.1' /t WEST FARM RESERVOIRS MW #2 E; BIT O Monitoring Well Graphs WATER (CONY) 4780.00 4779.00 4778.00 Ground lee 4779.16' A v v rn 4777.00 4776.00 4775.00 4774.00 4773.00 4772.00 a v rn O NJ v v Ut a -4 cn 4771.00 O1° O1° e O1° O1° O1° O1° O1° otio \1°; 1O . L1 �\~ ��41' oCe 1°\tb\� 1 Act 1ti\1° 419 1\1L~1\� �i\11' a\tip'\ - h\tip 1' �o\tih� 1\ti°\� \ti°\� \°\~ 1°\�� 11\1 ~ti\1�\ ,\1a\�° `\ti MW 3 water level data Ground surface" Average (4775.87) —Max (+2) Min (-2) O% O11 O> O1, ,1,1 O11 �1 OL1 \�° 0) 'L 'L 'L 'L 'L c5.3 ti Atip\ �\n,\ �0\�1\ \1�\ �'\�of\<> 1°\ 11\ C • oti1 oti� cy otiy otin oti , otiti otiy Otiy oti1' otiy °Cb \1°.. ,\t°:. 11\~ N 1\ oti" oti e WEST FARM RESERVOIRS MW #3 E; IT O Monitoring Well Graphs 4783 00 1782 00 WATER (CONY) a Ground elev. 4782.17' a v v rn V 1780 00 a) 1779 00 4778.00 4777.00 4776 00 4775.00 4774.00 00 C a N a v 07 a) O a v V CJ1 a a CO C7) a N a J CD 0�0 O.ti�i OtiA Otis OVA Oti0 ° s) °\~ \�\~ a\~o\~„b. �\� titi\'o\� ti\, ti\� a -4 v U) a V 9) a v v CO a) a v U) O1 O a v v a a v -4 a U) a v v C.) O a J 9) N) a v -4 U) a v CO 00,tiO O o •�o oil. oil, 01, O O ,LO ° OLo O•Lo ,10 -v° •L'y 1 tiAO OKI. LA\ am'\ " h\V l°\� °\~ 3°\~ 1°P\' , 19 'tip\ 1 Nit �\ 4 o\ � a\ 4.4 titi .,1\ N\ ti a v v 9) a -4 v w a v 9) a v U) CO a v Cn a) J a v a a a v v O1 O a J v CO V) a N v oti~ oti~ oti' oti~ oti~ oti~ o, ) oti oti' Ott~ .5\°�\~ o\'L"°\~ h\Lh\~ O\�\~ 41i1\'ti' `°�\� Ac1°\ti1\~,y\L1-11 <>\ a v V a C a v -4 CO a v C a a v v 00 a v a N a v v 9, a) O1 a v 9) a a V CO O a -4 v N a a v 9, 0) a V 9) a v -4 03 —u—MW4 Water level data ground surface Average (477S.22) Max (+2) Min (-2) ti� titi titi titi titi titi titi titi titi titi titi titi titi titi ti� �, 61, LO LO �O LO ,LO LO 10 LO LO 10 LO �O ,LO O O n\ti�\ \a\ 4,4 �\6 :\,�,\ ,s0 :\�°\-°\,v°\ sy\titi\ ��\ti \ti % 4\ti Oti1 411 ti ti\% 3\ WEST FARM RESERVOIRS MW #4 a BIT O Monitoring Well Graphs 4810.00 4805.00 4800.00 4795.00 4785.00 4780.00 4775.00 WATER (CONY) A Q) 00 V 00 O) W A V 03 OD U1 A 00 A V OD OD is A CA V e qe le es A V A ✓ OD Q) of 4~°tis'�°~• s,yti'�°�>\°'�°~�/tfj°~1°~~°�1°�y \°~ �\�°~\~~\~°, ti\ ,y\ % ��' q\ti ti ' A COO _, A V a a ▪ V V CD OD I CA V V as Ground lee 4804.36' A V OD a) cc —w—MW 5 Water level data Ground Surface Average (4787.67) Max (+2) Min (-2) ti• °'ti▪ ti titi titi ti,319' ~° ti°i° 1:5\v titi ti\ ti ti \�°~~\ps°�~�°�°~~ti's\~,61) °~~ �°\�°� °\le \ao�t�titi�s\~ e se '5 A\ h\ co\ •I'(4 b� o,_p WEST FARM RESERVOIRS MW #5 E BIT O Monitoring Well Graphs WATER (CONY) 4800.00 4795.00 4790.00 4780 00 4775.00 4770.00 0 O.;oi 0�O 0,� 0�O O,ti�i 019 '19 0 01' 01' 01" On' 0% On' On' On' On' On' On' On' On' 01' 1 O1' 1\'10\~ ��\� of\'O\� 1O\�� 1\ ti'y\'�O\~ ti\1�\� \y,\� 3\'1�\1 b\�\� c�\'L�\� \'lh\� ,�\'lO\� \'lO\� o�\�O\� y0\l�\� ,Y'ti\~�\ ti`L�\� gyp\� 1\�� II' \-t. c�\et) (:)\ 01~ 01~ O�1 01~ 01~ Ground lee 4802.13' MW 6 Water level data ground surface Average (4786.6S) Max (+2) Min (-2) ,., O�� O�� Off~ O�� O�� Off~ O�� O�� O�� O�� 01� O�� 01� O�� 01� O\'L\'1\L A\L\'L ,�\L 5\'L �\'L O\'b O\'L\L ,L\L\L ,y\'L O\L\L ti ti� ti~ \ a\ \\ eti 1 c a� 1O1' �ti ,vti \% ti~ \ WEST FARM RESERVOIRS MW #6 E BIT O Monitoring Well Graphs 4792.00 4790.00 4786.00 4784.00 4782.00 .1780 00 WATER (CONY) a v Ground lee 4791.08' a V O O a a V CO O O CO a V CO O W A ✓ O O ✓ OD A a V O CO O) . V O YR A co C,,) CO CO O a 7 \. co a O V a V CO V op a O Co O0 a V CO O U) A V rn U) .CO N a V CO O O a V O O 01 V A v O O O V a V O N O a V O O O a O CO 'co O a W A V O O a V rn O O CA) a V CO a CO O V 0 s A V O O Cr) ▪ a A V CO O) es O V V a) a CO a) a V CO O O A V CO O co a V CO O V W A V O O a co A V co O co A v O O a) O MW 7 Water Level data Ground Surface Average (4786.67) Max (+2) Min (-2) e ~� �� o o o e e OLO op e e e e e e e OiO 1'y 0.11 O1'� O,1> O,11 '1�1O �S1 �i�~O tiO\� 1��\ti ��\.O\ti ti�1�\� ti�~�\� ��\~ b\ 11- h��0\� (o\�h\L 1�1O\� g��O\� �i��O\� O�_�\� ,�\� 1\\L \fibSi? ti�~ '��\1b�~�\� h��h\� O\ 6* ,1> oet> oi`• O,ti'� O�1> 0-% oil' O0. 41' O0'L 6i)- O� - on). 0.1," O.1' - O•L'1• O•L'L 61,- A �\� \�\ti 03\ I � I~ ��\L\L 1\�O�1 \�\ti 'L\��\� 13) \a\ti a�%op) h�~\ ��\ ��\ ��O\� ��O\� �o\tea\ ' ti�ti1\� y1 Off~ On3 O1^) O1�„sb WEST FARM RESERVOIRS MW #7 DEERE & AULT A SCHNABEL ENGINEERING COMPANY TECHNICAL MEMORANDUM 600 South Airport Road, Suite A-205 Longmont, Colorado 80503 303-651-1468 schnabel-eng.com I deereault.com TO: Matthew Noteboom DATE: May 19, 2023 COMPANY: L.G. Everist, Mountain Division SUBJECT: West Farm Groundwater Model ADDRESS: 7321 E. 88th Ave., Suite 200, PROJECT L.G. Everist West Farm Henderson, CO 80640 NAME/NO.: 20C26026.02 FROM: Naveen Kumar CC: Victor deWolfe, P.E., P.G. This memorandum discusses the groundwater impact analysis at the proposed future West Farm mine site. The purpose of the analysis is to provide information related to the potential groundwater mounding upgradient of the proposed slurry walls at the site. The site is located approximately two miles west of the town of Platteville, Colorado. The property is bordered on the east by the South Platte River and on the west by Weld County Road (WCR) 21. The mine plan for the site consists of two main mining areas (North and South) divided by WCR 32.5. In each area there are two mine cells planned: one on the lower portion of the property (to the east), and a second along the upper terrace on the western portion of the site. Slurry walls will be constructed around the perimeter of each of the four planned cells, as shown on Figure 1. A standard offset of 200 feet from the river, and 15 feet from property lines, rights -of -way or utilities was used for the proposed slurry wall alignment. A groundwater model was constructed to evaluate the impact of the slurry walls on groundwater levels. The objectives of the groundwater model are to: 1. Approximate the pre -slurry wall groundwater hydrology using available data 2. Simulate the hydraulic effect of the slurry walls by predicting potential groundwater mounding upgradient of the property and shadowing downgradient 3. Simulate the conditions if a drain was installed to mitigate high groundwater To satisfy these objectives, steady state groundwater models were constructed for: 1) pre -slurry wall conditions, 2) post -slurry wall construction conditions and 3) mitigated slurry wall conditions. The model domain was set within the alluvial floodplain of the South Platte River just upstream from the confluence with Saint Vrain Creek. The South Platte is the primary surface hydraulic feature in the area. The topography slopes gently from the south along the valley with alluvial terraces immediately above the floodplain. The near surface bedrock is the Cretaceous Laramie Formation. Land use in the area consists of mining and agricultural uses. This modeling memorandum presents a general conceptual model of the aquifer system followed by a discussion of the groundwater modeling software; construction of the model; calibration of the model in terms of target residuals and mass balance; and finally, a discussion of the predictive simulations and conclusions. The groundwater modeling was conducted in general conformance with ASTM standards for groundwater modeling. L.G. Everist West Farm Groundwater Modeling GEOTECHNICAL INVESTIGATIONS The general subsurface lithology at the West Farm site consists of one to four feet of overburden at the surface, underlain by alluvial sand and gravel deposits, followed by weathered Laramie Formation bedrock measuring about 2 feet thick, and finally less weathered Laramie Formation bedrock. The total depth to bedrock for this model was estimated to vary from about 27 to 74 feet thick. Subsurface lithology data was obtained from three separate geotechnical investigations. The first investigation on the property, consisting of 31 borings, was performed by L.G. Everist in October of 2018. In July of 2019, Drilling Engineers installed seven monitoring wells. The third investigation, consisting of four borings, was conducted by Deere & Ault in January of 2022. The information from these three investigations was used to create the bedrock contours used in the groundwater model. These boring locations are shown on Figure 1. ANALYTICAL PARAMETERS Conceptual Model The conceptual model of the aquifer system analyzed for this investigation consists of one layer, the unconfined sand and gravel of the South Platte River alluvial aquifer. Hydrologically the aquifer is bounded on the bottom by bedrock consisting of low permeability Laramie Formation. The bedrock acts as no -flow boundaries because the permeability of the rock is much lower than that of the alluvial aquifer. The aquifer is comprised of alluvial deposits, which consist primarily of well graded to poorly graded gravelly sand. The hydraulic conductivity (K) of the aquifer is generally around 500 feet per day (Colorado's Decision Support Systems GIS map). The saturated thickness ranges from 25 to 30 feet. The principal source of water for the aquifer is the South Platte River. Other minor sources include precipitation and seepage from irrigation ditches. In the project area, the South Platte River acts as a drain (sink) because it is a gaining stream, that is, the adjacent groundwater is higher than the water in the river. Steady-state conditions were simulated because the maximum water level rise is of principal interest and the time required to reach steady state is not of concern. Groundwater Modeling Software The MODFLOW-2005 computer code was used to simulate ground water flow by solving the 3 -dimensional groundwater flow equation using a finite -difference method where the model domain is subdivided into a grid of cells, and the hydraulic head is calculated at the centroid of each cell (Harbaugh, et al., 2000). Groundwater flows into and out of the model via constant head, head -dependent flux, and constant flux boundaries. These flows are calculated in the same manner for each simulation. Pre- and post -processing of MODFLOW-2005 files were completed using Groundwater Vistas Version 8.03 Build 3 (Rumbaugh & Rumbaugh, 2017), a graphical design system for MODFLOW. Groundwater Vistas facilitates model construction, data analysis and data presentation. It summarizes results as contours, shaded contours, velocity vectors and detailed mass balance analyses. This section discusses the modeling assumptions, limitations, solution techniques, and the way that they affect the models. When analyzing the groundwater flows in the model, as implemented, MODFLOW-2005 simulates the system as unconfined with isotropic hydraulic conductivity. One limitation is that cells can go "dry" or "flood". If the calculated head is above the top of the aquifer (ground surface) at any model cell, then that cell is flooded and will be treated as if the aquifer is confined (i.e., the saturated thickness will equal the top -elevation minus the bottom -elevation). If the calculated head falls below the bottom of the aquifer, that cell is dry and will be assigned a zero value for hydraulic conductivity. Project 20C26026.02 / May 19, 2023 Page 2 Deere & Ault, a Schnabel Engineering Company L.G. Everist West Farm Groundwater Modeling The preconditioned conjugate -gradient (PCG2) solver package of MODFLOW-2005 was used to solve the groundwater flow equations for the model. This package defines the number of outer and inner solver iterations, as well as criteria for both maximum head and residual change between iterations before allowing convergence. Tolerances for the maximum change in head and flow residual between iterations were specified as 1x10-3 feet and 100 cubic feet per day (cfd), respectively. These tolerances result in a mass balance of less than 0.001%, indicting model convergence and solution accuracy. MODEL CONSTRUCTION The West Farm groundwater model was developed using a Geographic Information System (GIS) database and GIS data analysis techniques. (ESRI, 2023). The model was constructed by importing shapefiles representing aquifer parameters and boundary conditions into Groundwater Vistas. The model domain is a rectangular area 8,550 feet wide by 8,850 feet long (Figure 1). The domain was divided into a grid of cells measuring 150 feet each side. Active cells contain values representing the following parameters: 1. The elevation of the top of the aquifer 2. The elevation of the bottom of the aquifer 3. The hydraulic conductivity of the aquifer 4. The initial groundwater head within the aquifer 5. The boundary conditions for the model The following sections discusses the general procedure used for determining hydraulic parameters, boundary conditions, delineation of calibration targets, and goals of model calibration as related to the conceptual model. Hydraulic Parameters The maximum top of the alluvial aquifer is represented by the topography of the ground surface. Topographic data used for this model input are from a 10 -meter digital elevation model (DEM) obtained from the USGS National Elevation Data set contoured at 5 -foot intervals. Because of this 5 -foot contour interval there is some variance between model elevations and actual ground elevations. The low permeability Laramie Formation bedrock forms the bottom of the alluvial aquifer. Therefore, the model contains an elevation map of the bedrock surface. To create this surface, bedrock elevation data was obtained from the geotechnical investigations described above. The bedrock elevations were contoured in AutoCAD. The resulting bedrock elevation contour map was imported into Groundwater Vistas as the bottom of the aquifer. Overall, the spatial reliability of the bedrock data is considered good and deemed appropriate for the scope of this groundwater model. The hydraulic conductivity (K) of the alluvial aquifer used in the model was input as 500 feet per day (fpd). This value is based on average values from the Colorado's Decision Support Systems GIS map and our experience in the area. We assumed an anisotropy ratio of 0.1 (Kv/Kr), meaning that the value in the vertical direction (Kv) is one order of magnitude lower than the value in the radial direction (Kr). A groundwater elevation contour map for the alluvial aquifer provided the starting heads for the finite difference solution and was used to define constant head boundary values. This surface was developed using the groundwater level data collected from the on -site monitoring wells. The pre -slurry wall heads or initial conditions depth to groundwater is shown on Figure 2. Project 20C26026.02 / May 19, 2023 Page 3 Deem & Ault, a Schnabel Engineering Company L.G. Everist West Farm Groundwater Modeling Calibration Targets and Goals The calibration targets for the model include the measured groundwater elevations observed in seven monitoring wells measured at the end of August 2022. The calibration goal is to adjust model inputs such that the steady state groundwater heads for the pre -slurry wall conditions are similar to measured heads in the field. Of the seven wells, two have been installed upgradient from the proposed slurry wall (Wells MW -07 and MW -06). Therefore, these two wells are the best targets for the predictive mounding simulations. Although well MW -06 is located inside the slurry wall, a surrogate target was used just south of MW -06, outside the proposed slurry wall. This target was modeled with the same head value as MW -06. These two targets (Wells MW -07 and MW -06) were used to estimate groundwater mounding upgradient of the proposed slurry walls. The goals of the predictive simulation targets are: 1) to show how field measured groundwater heads differ from those in the predictive simulations, 2) to show how pre -slurry wall groundwater heads differ from those in the predictive simulations, and 3) to compare post -mitigation heads to pre -mitigation mounded groundwater heads. Boundary Conditions The boundary conditions used for the model include three constant head boundaries and one no -flow boundary. Specified groundwater head values (elevations) from the input groundwater surface were assigned to the constant head boundaries and do not vary during the simulations. Two constant head boundaries are present at the southern and northern ends of the model domain and a third one at the South Platte River. The no -flow boundary is the hydraulic divide between the South Platte basin and the Saint Vrain Basin. This boundary is based on topography which divides the two drainage basins and roughly follows the Meadow Island Ditch. These boundaries are shown on Figures 2 through 5. The proposed slurry walls are also modeled as no -flow boundaries. These boundary conditions define the sources and sinks for the water budget of the model. The sinks in the model are the northern boundary where alluvial underflow leaves the model, and the South Platte River constant head boundary. The water source into the model is alluvial flow through the southern boundary. No other recharge sources are included in the model, as precipitation is considered a negligible source within the domain and irrigation records were not reviewed. The system is assumed to be in equilibrium under pre -slurry wall conditions. The model domain is inactive outside of the defined boundary conditions. This includes the cells within the slurry wall no -flow boundaries. CALIBRATION The model is simple and homogeneous, containing heads that are well constrained by measured values for boundary conditions as well as a reasonable estimate of hydraulic conductivity. The calibration targets used for the pre -slurry wall condition steady state model illustrate that the input groundwater heads are generally within two feet of measured heads where mounding is expected. Monitoring wells MW -01, MW -4 and MW -7 showed a residual of less than one foot. The mass balance reported by MODFLOW for the steady state pre -slurry wall model is as follows: Inflows = 236,094.43cfd Outflows = 236,091.98 cfd Difference = 2.45cfd (0.001%) This illustrates that the initial steady state model is accurately solved. Because the pre -slurry wall groundwater table represents data from measured groundwater levels, and the mass balance is accurate, this suggests the Project 20C26026.02 / May 19, 2023 Page 4 Deere & Ault, a Schnabel Engineering Company L.G. Everist West Farm Groundwater Modeling model is sufficiently calibrated to be used for predicting water levels after construction of the slurry walls and following mitigated conditions with a drain. PREDICTIVE SIMULATIONS Using the steady state model for pre -slurry wall condition as the base model, predictive simulations were performed for the following conditions: 1. Groundwater mounding after the slurry walls were constructed. 2. Mitigated groundwater mounding with an underdrain along a portion of the south property boundary. Predicted Unmitigated Groundwater Mounding Groundwater mounding was predicted for the reclaimed condition representing the proposed slurry walls. To understand the magnitude and extent of potential groundwater mounding upgradient of the slurry walls, a steady state simulation including slurry walls was performed. The pre -slurry wall model was changed by inputting the slurry wall as a no -flow boundary. All other aquifer parameters and boundary conditions were unchanged. Initial heads were the model simulated heads from the pre -slurry wall steady state model. The steady state model for the post -slurry wall conditions produced higher groundwater elevation heads than those produced for the pre -slurry wall steady state condition. The difference between these two groundwater surfaces are the predicted mounding levels shown on Figure 2. For the predictive simulation, positive residuals are reported as values of groundwater mounding (warm colors) and negative values represent groundwater shadowing (cool colors). The magnitude of the maximum groundwater mounding is approximately 3 feet upgradient in the southwest corner of the model area. The magnitude of the maximum groundwater shadowing is almost 1 foot, downgradient of the proposed slurry wall. Due to the terrace on the west, the change in topography on the site is significant, so the location of highest groundwater mounding is not where the groundwater is closest to the surface. Because of the terrace and change in topography across the site a figure (Figure 3) showing the depth to groundwater from the surface was created. The groundwater is closest to the surface (approximately 3 feet) in the southeast corner of the model, near the South Platte River. Predicted Mitigated Groundwater Mounding with an Underdrain The predictive model showing groundwater mounding for the reclaimed conditions was changed by adding a drain along a portion of the southern property boundary. The drain would most likely be a slotted PVC pipe surrounded by washed gravel bedding. The beginning elevation of the drain in the model represents the approximate elevation of the unmitigated groundwater mound upgradient of the property. The ending elevation is based off a drain slope of 0.25%. These elevations are approximate and set higher than measured groundwater levels in the monitoring wells. The modeled drain begins near the toe of the slope of the terrace and discharges to the east into the South Platte River. The actual design of the drain, if deemed necessary, may differ from these parameters and would go through any required permitting process. The simulated drain was given the following parameters: • Drain width, w = 1 foot (based on a 1 -foot wide trench filled with a gravel bedding) • Drain bed thickness, dl = 1 foot • Hydraulic conductivity, K = 500 feet per day (same as aquifer K, which is assumed to be smaller than gravel bedding K and therefore controlling) • Drain conductance = 75,500 square feet per day, C=K*(dl/w)*L Project 20C26026.02 / May 19, 2023 Page 5 Deere & Ault, a Schnabel Engineering Company L.G. Everist West Farm Groundwater Modeling The simulated drain parameters are more conservative in terms of dimensions (width, length, slope) and hydraulic conductivity. Thus, the mitigation (reduction of groundwater mounding) provided by an actual drain should be more than shown in the model. The results of the simulation with the drain are presented on Figure 4. This map is the same as Figure 3, showing depth to groundwater, except it shows the mitigated groundwater mounding, and the location of the proposed drain. The mitigated groundwater mounding upgradient of the property is less than one foot, an improvement of about two feet in the most critical area. The drained mound is limited by the downgradient elevation of the drain, which roughly reestablishes the pre -slurry wall groundwater condition. CONCLUSIONS This groundwater impact analysis was performed to evaluate the mounding and shadowing effect the construction of slurry walls has on the local groundwater table. It also was used to evaluate a potential mitigation alternative for draining the groundwater mound up -gradient of the property line. The model accurately replicated the conditions of the South Platte River alluvial aquifer based on data available from recent geotechnical investigations. Model construction was facilitated by using an extensive GIS to inventory, analyze and present the data. Three constant head boundaries were used at the southern, and northern ends of the model domain and a third one at the South Platte River. The no -flow boundary is the hydraulic divided between the South Platte basin and the Saint Vrain Basin. The mass balance had a 0.001 percent error. The model simulated the hydrologic changes caused by construction of the slurry walls. The predictive simulation showed that the magnitude of the maximum groundwater mounding upgradient of the southem slurry wall is about 3 feet, and a minimum depth to groundwater of about 3 feet. The simulation also indicates that the maximum shadowing effect caused by the reclamation activities is about 2 feet downgradient of the proposed slurry wall. The model also predicted the effect of a groundwater underdrain installed up -gradient of the slurry walls to lower the groundwater mound. This simulation results in a maximum groundwater mound up -gradient of the property line of less than one foot, a more than two -foot decrease in mounded groundwater heads. Installation of a drain, if necessary, would result in a groundwater table that roughly approximates the pre -slurry wall heads. Additional wells are planned, including one between MW -6 and MW -7. The site wells will be monitored approximately monthly. If the depth to groundwater, following the construction of the slurry wall(s) in any exterior well approaches 2 feet, we recommend that a drain be installed." The results of the groundwater modeling and conclusions drawn from them represent an approximation and are based on the best available data. Conservative assumptions were made during the calibration process so that groundwater mounding was not under -predicted. Given the unknown heterogeneity of the aquifer in the field and variations in ground surface from the topographic data used, the groundwater mounding and/or drainage mitigation may deviate from the model simulation. There is a possibility that mounding may be higher than predicted, although the conservative assumptions of this work make the deviation toward a lower mound in the field a more likely possibility. GA2020\Longmont\20C26026.02 West Farm \03_SE Products\03-Reports\01-Draft\Groundwater Model Memo.Docx Project 20C26026.02 / May 19, 2023 Page 6 Deere & Ault, a Schnabel Engineering Company LEGEND O Groundwater Monitoring Wells 0 Borings Proposed Slurry Wall Boundary Roads Model Domain Schnabel - South Platte River ® • • Mw 3 O • • • • - MW County Road 32 1/2 WEST FARM General Site Map JOB NO: 21 C26026.02 I) SCALE: 1 1,000 2,000 Feet FIGURE NO. 1 w i r-1 "rteN LEGEND Mounding Contours (ft) No Flow Boundary Constant Head Boundary Mounding Depth (ft) 3.5 1 -91w -. 4T Schnabel Area Encompassed by Slurry Walls MA/ 60 (Suriagate)Q 1 MW 7o 'W WEST FARM Unmitigated Condition - Mounding Depth JOB NO: 20C26026.02 0 2,000 4,000 FIGURE NO. SCALE: zz vtr LEGEND No Flow Boundary Constant Head Boundary Depth to Groundwater (ft) h�O r J N N N co Lrte. is/""` Area Encompassed by Slurry Walls "II Schnabel MW 6O MW 6 (Surrogate)O 20 - oo k r•», Asaetw - a. Q NJ CO 4 MW 7O 11 • 6 4 :ounty Road 32 1/2 WEST FARM Unmitigated Condition - Depth to Groundwater JOB NO: 20C26026.02 SCALE: 2,000 4,000 ." Fee • tzts FIGURE NO. • LEGEND No Flow Boundary MIMS Constant Head Boundary Depth to Groundwater (ft) Proposed Drain • I f•- NJ Area Encompassed by Slurry Walls Schnabel Nao MW 6° 26 MW (Surrogate) Cb cc ti� N } 6 L 6) v� dt w4 - a MW7 10 0 WEST FARM Mitigated Condition - Depth to Groundwater •Y JOB NO: 20C26026.02 S LEGEND No Flow Boundary Constant Head Boundary GW Monitoring Wells 0 Depth to Groundwater (ft) 1110 n-sa. wee Schnabel 14 MW 6 (Sut 1 ogate)O L WEST FARM Initial Condition - Depth to Groundwater 0 2,000 4.000 FIGURE NO. 5 JOB NO: 21C26026.02 SCALE: Feet Groundwater Quality Monitoring Plan LGE - West Farm 10482 County Road 32.5 Platteville, CO May 17, 2023 Prepared for: L.G. Everist, Inc. 7321 E 88`x' Avenue, Suite 200 Henderson, Co 80640 Prepared by: Molen & Associates, LLC 2090 E 104th Ave, Unit 101 Thornton, CO 80023 • TABLE OF CONTENTS 1.0 INTRODUCTION 2 2.0 MONITORING PLAN COMPONENTS 2 2.1 Monitoring Well Placement 3 2.2 Monitoring Well Site Selection 3 2.3 Water Level Monitoring 4 2.4 Water Quality Monitoring 4 3.0 WATER QUALITY EVALUATION 4 3.1 Baseline Data Collection 5 3.2 Indicator Parameters 5 3.3 Selection of Indicator Parameters 6 3.4 Statistical Analysis 6 4.0 REPORTING 7 5.0 VERIFICATION RE -SAMPLING 7 List of Tables Table 1: Existing and potential new Well Locations Table 2: Example of Indicator Parameters in the South Platte River basin List of Figures Figure 1: Map Exhibit G-1 Water Wells Within 200 Feet Figure 2: Groundwater Elevation Contour Map Appendices Appendix A — Groundwater Sampling Plan Groundwater Quality Monitoring Plan 1.0 INTRODUCTION LG Everist, Inc is planning to mine aggregate resources from the West Farm property as outlined in the mining permit. The purpose of this Groundwater Quality Monitoring Plan (GWMP) is to assess the potential of the introduction of pollutants into the groundwater during mining activities and to describe the program to assess if and how water quality may change over time. The plan also provides information about the collection of water level measurements to show water level changes over time. A separate Groundwater Sampling Plan is prepared and describes groundwater sampling procedures, sample handling, and laboratory analysis. This GWMP will designate what data is collected and how it may be interpreted and may be modified as the mining activities progress and new information arises or changes. Both the GWMP and the Groundwater Sampling Plan (GSP) will be followed for all groundwater monitoring done at the LGE-WF site. The Division of Reclamation, Mining and Safety (DRMS) calls for a GWMP for the LG Everist — West Farm (LGE-WF) for the mining permit. Existing groundwater wells n used to measure water levels over the past two years. The groundwater well locations are shown on Figure 1, Map Exhibit G-1 — Water Wells Within 200 Feet and are shown on other maps in the mining permit plans. Most or all of these wells will be used to obtain baseline groundwater quality data for the LGE-WF site. Additional groundwater monitoring wells are also planned as shown in Figure 1. Groundwater monitoring wells are generally in locations that will not be mined or will not be mined in the near future. New wells or replacement wells will be placed in the general area of the existing well and be installed to monitor the same water bearing zone. 2.0 MONITORING PLAN COMPONENTS The current groundwater monitoring well locations are shown in Figure 1. The current system includes seven wells completed in the uppermost aquifer. A few of the existing groundwater monitoring wells are in areas that will be mined. These wells will not be used for groundwater quality monitoring. Monitoring wells are located in up -gradient and down -gradient positions in the alluvium. Additional monitoring wells may be included in the future as necessary, or in response to regulatory concerns. Water quality monitoring sampling will begin within the next quarter following regulatory approval or consensus from DRMS. As proposed, the data collected will be used to develop a baseline of data for which future comparisons can be made. Once the baseline data collection is completed, then future water quality samples collected from points downgradient of the mining operations can be used to assess potential changes in water chemistry that might cause overall changes in water quality downstream. VA maps LG Everist Monitoring Plan Page 2 of 7 Groundwater Quality Monitoring Plan MW -2 CROSS/UP SW RM PH 3/CEN ALL Existing — SW corner of Phase 3 and west central of all mining, north of Phase 4 Baseline data will be collected from each monitoring well designated as a groundwater quality monitoring well. Some groundwater wells will only be used to collect water level information (piezometers). 2.1 Monitoring Well Placement Table 1: Existin • and • otential new Well Locations MW -3 DOWN NE COR PH 2/ALL WL Existing central east and north MW -4 MID N CEN PH 1 WL Existing central east and south Existing SW comer of Phase 4 MW -5 UP SW COR PH 4 RM MW -6 UP S MID BDRY PH 1 WL Southern boundary central MW -7 MW -8 MW -9 UP SE COR PH 1 DOWN NE COR PH 2/ALL MID N CEN PH 1 RM RM/POC WL Existing eastern boundary Potential new well northeast boundary of Phase 2 and all Phases, down gradient Potential new well north boundary of Phase 1, south of Phase 2 and central for all Phases MW --10 UP S MID BDRY PH 1 WL Potential new well southern boundary central MW -11 NW PH 2/N ALL RM/POC Potential new for NW of Phase 2 and NE of Phase 3 MW -12 SE PH 2/E CEN ALL RM Potential new for SE of Phase 2 and east central all Phases MW -13 SE PH 4/S CEN ALL WL Potential new for SE of Phase 4 and S for all Phases MW -14 SE PH 1/SE ALL WL Potential new for SE side DOWN = downgradient NW = northwest SE = southeast POC = point of compliance BDRY = boundary UP = upgradient SW = southwest PH = phase COR = corner CROSS = cross gradient NE = northeast WL = water level piezometer ALL = services all phases RM = regularly monitored 2.2 Monitoring Well Site Selection Figure 2 presents a groundwater elevation contour map that was constructed from water level data obtained from the existing monitoring wells. The average (mean) groundwater level was used to construct the groundwater elevation contour map. The groundwater levels generally followed the topographic gradient, with water flowing generally from a west-southwest and south direction to a north and northeast direction. VOLEN LG Everist Monitoring Plan Page 3 of 7 Groundwater Quality Monitoring Plan It is proposed that the water quality monitoring wells be completed with a 2 -inch diameter PVC casing and screen. Typically, the wells are constructed with screening across the entire water bearing zone, with solid piping to the surface completion. At least one groundwater monitoring well is proposed as the downgradient water quality sampling point. The one downgradient water monitoring well will also be considered a point of compliance (POC) well. 2.3 Water Level Monitoring Water level measurements will be made in accordance with this monitoring evaluation plan. Typically, all monitoring wells will have water level measurements at least on a quarterly basis. Water level measurements collected in concert with water quality sampling will serve as quarterly water level measurements for the purposes of this monitoring evaluation plan. 2.4 Water Quality Monitoring Existing wells are currently being measured for water levels and will have water quality samples collected using the Groundwater Quality Sampling Plan as agreed to by DRMS and LGE. The proposed parameters listed in Table 1, would be included in the baseline water quality data collection. Once baseline water quality data is obtained, only certain monitoring wells will be utilized for the collection of water quality data. Monitoring wells in upgradient and downgradient positions from the specific phase of mining will be used to assess whether water quality degradation could be occurring. It is believed that this monitoring and water quality evaluation plan should focus on inorganic parameters that are likely to change as a result of the mining operations. The water quality parameters that are proposed for the water quality evaluation monitoring program are shown in Table 2. It is proposed that water quality samples are obtained at least quarterly prior to mining for the first five quarters. This water quality data will be used as part of the baseline, while subsequent water quality data, obtained annually, will be compared to the baseline data to assess water quality variations. The method proposed for the water quality assessments is discussed in the following section. 3.0 WATER QUALITY EVALUATION The proposed water quality evaluation is based on statistical analysis, where the baseline data is statistically analyzed to evaluate expected natural water quality variations within each aquifer system. The statistical analysis is necessary to provide a means to evaluate the expected range of values in the representative baseline data, so that when future samples are obtained, variations outside the statistical norms can then be evaluated regarding the potential of water quality degradation from mining activities. MOLEN LG Everist Monitoring Plan &��+aT Page 4 of 7 Groundwater Quality Monitoring Plan 3.1 Baseline Data Collection To initially evaluate the baseline data, a normal distribution and a 95 percent confidence interval around the mean will be used to establish a baseline range of values. This is a standard statistical analysis commonly used for data management to establish an anticipated range of naturally occurring values that may occur. Water quality changes within the baseline data could be related to (a) seasonal variations, (b) changes in precipitation recharge, (c) spatial variations within an aquifer due to heterogeneous geologic conditions and/or (d) changes in water levels and hydraulic gradients with time that could affect water flow in the aquifer. Therefore, there may be a need to update the baseline data over time because the data has changed due to a particular change in natural conditions at the mining site. It is impractical to conduct extensive statistical analysis on every water quality parameter tested. Several "indicator parameters", i.e., water quality parameters that would be used to identify potential water quality degradation, will be selected for statistical analyses and charting. Volatile organic or semi -volatile organic hydrocarbons (VOC and SVOC) will be utilized as present or absent in any initial phases of monitoring and as needed to show increases or decreases in concentrations. To accomplish monitoring of VOCs and SVOCs they will be analyzed for baseline sampling and then only once a year at the most, unless detected and confirmed. After the initial five quarters of baseline data is collected, sampling will occur annually for specific parameters that are determined by the baseline data. Prior to starting the mining, sampling will be conducted within 90 days. 3.2 Indicator Parameters Indicator parameters are considered the most likely to change based upon conditions developed during the mining activities. However, the changes in indicator parameters do not confirm that pollution is occurring at the site, and only that conditions are changing in the water quality parameters. A further in-depth review of the groundwater quality would be needed to determine whether mining is resulting in any type of pollution in the aquifer. Site specific information at a mining site with similar locations and circumstances along the South Platte River approximately 12 miles upstream near Brighton, CO, can be useful in early evaluation and indicator selection at the LGE-WF site. Statistics information from some of the parameters in the South Platte River site approximately 12 miles upgradient are as follows: VIZ MOLEN &,assc7cia�s LG Everist Monitoring Plan Page 5 of 7 Groundwater Quality Monitoring Plan Table 2: Example of Indicator Parameters in the South Platte River basin # Analyte # Sample Events 2010 to 2019 % Non Detects Statistical Anomaly 1 Alkalinity Carbonate 25 100 2 Antimony 25 100 3 Beryllium 25 100 4 Cadmium 25 62 Yes 5 Cobalt 25 80 6 Mercury 25 100 7 Nickel 25 80 8 Nitrite 25 100 9 Silver 25 100 10 Thallium 25 100 11 Vanadium 25 80 3.3 Selection of Indicator Parameters The groundwater data obtained from baseline sampling will provide similar information that can be used to determine the appropriate analytes for statistical analysis and which analytes should be excluded in future sampling events. The proposed set of analytes will be determined after the baseline data is obtained. The set of analytes will be evaluated on an annual basis and if any anomalous trends develop for parameters, subsequent statistical analysis will be conducted to assess anomalous trends outside the expected naturally occurring water quality variability. 3.4 Statistical Analysis The water quality database will be preliminarily assessed for representativeness of the water quality data. Any anomalous, or non -representative, water quality data will be excluded from the baseline data prior to conducting the statistical analysis. If data points are excluded, LGE will provide a written rationale to the Division for the exclusion. Once the representative database has been established, the baseline mean and standard deviation for each of the indicator parameters will be calculated. The data collected will provide the standard deviation used to establish a control limit (95 % confidence interval around the mean), beyond which any changes in water chemistry for that parameter will be assessed to evaluate if conditions in the mining area may be affecting ground water quality. /, aV LEN LG Everist Monitoring Plan Page 6 of 7 Groundwater Quality Monitoring Plan It is proposed that "control charts" be constructed for each of the indicator parameters in each of the water systems so that annual water quality data can be tracked to evaluate any potential trends in water quality. For all of the parameters there will be an upper control limit beyond which a significant change in ambient water quality can be assumed. It is also proposed that the stream standard for each of the indicator parameters be shown on the control chart, as, for some parameters, stream standards may have already been exceeded in the background water quality, while, for other parameters, stream standards are above the expected range of natural variations in water chemistry. These control charts would be prepared on an annual basis as additional water quality data become available from additional sampling events. 4.0 REPORTING It is proposed that control charts, generated on a quarterly basis, will be provided to the Division on an annual basis to demonstrate changes in water quality with time. If exceedances of the control charts are noted after regular annual sampling, a specific response plan will be prepared by LGE to address that issue. The specific response plan would be based on an evaluation of the number of indicator parameters that show exceedances and the duration of these exceedances. 5.0 VERIFICATION RE -SAMPLING Under certain circumstances a verification re -sampling may be collected, and samples submitted for analysis using the Groundwater Sampling Plan. The samples will be collected within four weeks of the analytical report date. A verification sample may be at collected the following sampling event depending on the frequency of sampling. Verification re -samples are designed to provide confirmation of the sample analytical data for sample result anomalies or statistical analysis. McLEN LG Everist Monitoring Plan Page 7 of 7 Figures L.G. WEST FARM RESEIV0IR5l Map Exhibit G-1 - Water• Wells Within 200 feet 6rairat es' { iL1 eet 2 2 2_ 2 I 2 l 2 I 2 -�1 2 I 2 I 2 I 2 I 2 L 2 I w I 2 I 2 I I 2 I 2 t a 1 1\1\11.2. 6 D-96398 • 2111- 2 2 - Proposed NEST FARM 040° 13' 25.1536" N 104° 52' 02.8563" W WF-MW-5 2 t6 D 30471 I NOTES 4-----6r6 Mri&x I-153358 I-1 5332R Proposed 1-1 53338 2--2 6-6 1. Data for wells shown on this map islisted on Table G-1 and is from the State Engineer records. 6 Zaws2iirsaa46is 2 Ir6 • WF-MW-4 • I -15336R WF-MW-6 Pry ostd l -"15334R■ 2_2-2-2-2_2,— —2_2 6-6--6-6 ?. Well locations shown on the map are confirmed via ground check. 3. All wells except the Geothermal (GX) well are shallow wells. 6—`6--6 2 2•-2-2-2-2 I % Na bcNINC: Pro posed 2 6\ 6k MW -264636 4, 6 6 1 6 1 6 y 6 I-153378 2 • 4, 1 l• t2 ' I •WF-MW-7 Pro p�sed _ 254 1 ■ 2* -2 Yetit 6,-6--6 6 6 — 6 ,4,6 CorentNyc.A o. WELL KEY • A • Verified Irrigation Well ♦ Site Monitoring Well Domestic Wells Proposed WQM Well Geothermal Well • Third Party Monitoring Well 2 2 200 FT. Offset 6 6 600 FT. Offset 4. Proposed new WQM well locations shown on map may change when installed. 'r")T 15: 41:51 m\LGE—West—Farm—Base.dwg O L D:\OOSRV\M\clients\Molen\LGE West LEGEND CO RD 34 • • • • CO RD N�5tat MW -5 4789.90 Monitoring Well Location 4784:00— Groundwater Elevation Contour (feet amsl) 4779.30 Groundwater Elevation (feet amsl) Groundwater Flow Direction • *74785.09 M W-6 0 600 1200 SCALE IN FEET egaoss - eiSso Plattev ill e MW -7 4°' 4124788.48 LG EVEREST WEST FARM Groundwater Elevation Contour Map 10/24/2022 XX-XXX 4/18/2023 Figure 1 MOLEN & ASSOCIATES, LLC Appendix A LGE Groundwater Sampling Plan • Groundwater Sampling Plan ME - West Farm 10482 County Read 32.5 Platteville, CO May 17, 2023 Prepared for: L.G. Everist; Inc. 7321 E 88t" Avenue, Suite 200 Henderson, CO 80640 Prepared by: Molen & Associates, LLC 2090 E 104th Ave, Unit 101 Thornton, CO 80023 TABLE OF CONTENTS 1.0 PURPOSE 2 2.0 APPLICABILITY 2 3.0 RESPONSIBILITIES 2 3.1 Sampling Personnel 2 3.2 Task Manager 2 3.3 Project Manager 2 4.0 GROUNDWATER SAMPLING PROCEDURES 2 4.1 Preparation for Sampling 2 4.2 Field Work Prior to Sampling 3 4.3 Sample Collection 4 4.3.1 Decontamination 4 4.3.2 Sampling Equipment and Materials 4 4.3.3 Purging 5 4.3.4 Withdrawal of Sample 6 4.4 Sample Preservation, Handling, and Shipment 7 4.5 Chain -of -Custody of Samples 8 4.6 Quality Assurance and Quality Control 8 5.0 Analytical Procedures 9 6.0 Analytical Data Review 9 7.0 Verification Re -sampling 10 Appendices Appendix A — Sampling Field Data Sheet Appendix B — Groundwater Quality Sampling Plan 1.0 PURPOSE This technical procedure for groundwater sampling establishes a standard methodology for collecting groundwater samples for laboratory analysis which are representative of aquifer water quality. 2.0 APPLICABILITY This technical procedure is applicable to field personnel engaged in the collection of groundwater samples from wells for the purposes of laboratory analysis. This document should be read in conjunction with all regulatory, work plan, orders, client -specific requirements, and other project -specific guidelines. 3.0 RESPONSIBILITIES 3.1 Sampling Personnel Sampling Personnel are responsible for sample collection, sample custody in the field, sample preservation, total and accurate completion of field and data sheets, field parameter measurements, sample delivery, and data delivery to the Project Manager, as described in this technical procedure. 3.2 Task Manager The Task Manager is responsible for supervising Sampling Personnel. Supervision includes ensuring that samples are collected, documented, preserved, field analyzed, handled and shipped or delivered to the appropriate laboratory as specified in project work documents and this technical procedure. 3.3 Project Manager The Project Manager is responsible for overall management of the project, sampling program design and implementation and providing any required clarifications in the use of this procedure. In most cases, the Project Manager will also fill the role of Task Manager. 4.0 GROUNDWATER SAMPLING PROCEDURES 4.1 Preparation for Sampling Following the determination of a sampling event date, sample bottles will be ordered from the contracted analytical laboratory. Sampling personnel will coordinate with the MOLEN ASSOCIATES LG Everist Sampling Plan Page 2 of 10 Groundwater Quality Sampling Plan contracted lab so that sample bottles can be ordered in sufficient time for shipping, bottle inspection, and corrections. If any changes have been made to the site analyte list, the laboratory should be informed prior to bottle shipment. Sufficient sample bottles for each parameter group (total metals, anions, etc.) for each well will be verified upon receipt. Additional bottles for Quality Assurance/Quality Control (QAQC) samples (duplicates, trip blanks, field blanks, and/or equipment blanks) will also be arranged, as necessary, with the laboratory prior to shipment. The laboratory will also provide sample labels, chain -of -custody (COC) forms, and COC seals with delivery of the sample bottles. 4.2 Field Work Prior to Sampling Sampling personnel will inspect each well prior to sampling. The condition of the well casing, concrete pad, reference mark for water level measurements, protective steel casing, well identification markings, and security lock will be recorded. Additionally, the following will be recorded on a sampling data sheet (Appendix I) for each monitor well: • Observations made during visual inspection. • Static water level of well measured with electronic signal on measuring tape. • Total depth of the well measured or recorded from previous events. • Date and time of well measurements and well sampling • Purge water volumes calculated or rate of purging, if needed. • Observation of sample odor, presence of immiscible layers, and relative turbidity Prior to purging and groundwater sampling of any well, the static water level will be measured in the monitor well. The water levels for all the groundwater monitoring network wells will be measured on the same day or within a 36 -hour period of time. In addition to the water levels, total depth will be measured annually in all wells in the monitoring network. Water level and total depth measurements will be made to the nearest 0.01 foot from a dedicated reference mark on the riser pipe using a portable electric water level indicator and will be re -measured for consistency. Depths to water will be compared in the field to previous measurements to minimize the possibility of recording incorrect readings. To avoid potential cross -contamination, the water level probe and tape will be washed before the initial use and between well locations using an AlconoxT./water solution followed by a rinse with distilled water, or use of a disposable alcohol water swab. A pair of new disposable gloves (nitrile or latex) will be worn while performing groundwater level measurements. If the total depth measurement indicates that 25% or more of the effective screen length of a well has become filled in with sediment, the well will be re -developed. Re - /RI MOLECIATENS &ASSO LG Everist Sampling Plan Page 3 of 10 Groundwater Quality Sampling Plan development will consist of purging a minimum of five casing volumes from the well, or purging the well dry twice if the yield is insufficient for continuous purging. In wells with sufficient yield, purging will continue until the sediment is removed and field parameters (pH, temperature, and conductivity) stabilize. Parameters are considered stabilized when there is less than a ±10 percent change in three consecutive measurements of temperature and conductivity, and pH readings are within ±0.2 standard units. For wells that purge dry, field parameters will be measured at the start and end of both purging cycles, if possible. The volume of water standing in each well will be calculated using the static water level measurement, the total depth of the well, and the casing diameter. One casing volume will be considered the water present in the well casing. Well depths for the purpose of well volume determination will be obtained from well completion records. The equation for calculation of one casing volume is: V = [Tr x (r casing)2 x h] x 7.48 V= 0.16 x h for a 2 inch well where: V= r casing = h= volume of water in well casing [gallons] radius of well casing [feet] height of water column (total well depth - depth to water) [feet] 4.3 Sample Collection 4.3.1 Decontamination All re -useable, non -dedicated sampling equipment will be decontaminated between each well location to provide representative samples. Decontamination will be performed by washing all equipment with an AlconoxTM/water solution followed by a rinse with distilled water. Water generated from decontamination procedures will be disposed of at least 20 feet from the well site. All clean or unused sampling equipment will be handled by personnel wearing new disposable gloves (e.g., nitrile or latex). After the re -useable sampling equipment has been decontaminated it will be wrapped in new clean plastic sheeting or placed in new clean plastic bags. The sampling equipment will remain in plastic sheeting or bags until it is used again at the next sampling event. 4.3.2 Sampling Equipment and Materials Purging and sampling equipment will consist of bailers and/or pumps. The bailers may be disposable or dedicated, and the pumps either re -useable, to be decontaminated prior to each sample location, or dedicated. This equipment will Va MOLEN ASSOCIATES LG Everist Sampling Plan Page 4 of 10 Groundwater Quality Sampling Plan be constructed of materials that will not alter the quality of the groundwater samples. Other sampling equipment may include the following: Water level indicator; Combination water quality meter for measuring pH, temperature, and conductivity; Water quality meter calibration solutions; Disposable gloves (nitrile, latex, or other appropriate material); • Distilled or deionized water; • Phosphate -free environmental detergent such as AlconoxTM; • Spray bottles for decontamination solution wash and rinse; Peristaltic pump with associated tubing; Battery or power for peristaltic pump; 0.45 -micron filter(s) if field -filtering is necessary; Plastic sheeting to prevent possible contamination of sampling equipment; ZiplocTM freezer bags for sample storage and shipping; Paper towels; 5 -gallon plastic buckets for decontamination and purge volume measurement; Sample bottles and sample preservatives; Field forms including groundwater sampling data sheets, COC forms, and sample labels; Coolers and ice. All of the groundwater purging and sampling equipment will be maintained in a clean and working condition. Sampling personnel will wear new disposable gloves while handling the sampling equipment that will be in contact with water samples. 4.3.3 Purging Prior to sample collection, each well will be purged of stagnant water using disposable or dedicated sampling equipment such as bailers and rope. Bailing will be performed at a rate that will minimize agitation of recovery waters and will continue until a minimum of three casing volumes have been purged and field parameters (pH, temperature, and conductivity) have stabilized, or the well is bailed dry. Field parameters will be measured at a frequency no greater than once per casing volume and purging will continue until there is less than ±10 percent change in three consecutive measurements of temperature and conductivity, and pH readings are within ±0.2 standard units. If a well is bailed dry before removing three casing volumes, sample collection will begin when a sufficient amount of groundwater has entered the well. In this situation, field parameters will be measured at the start of sample collection and again after sample collection is VfMOLEN ASSO LG Everist Sampling Plan Page 5 of 10 Groundwater Quality Sampling Plan complete, if possible. The collection of these groundwater samples must be within 24 hours of purging. All field parameter measurements will be recorded on a field data sheet along with a description of the sample appearance at the time of field parameter measurement. The water quality meter used to measure field parameters will be calibrated according to manufacturer's recommendations prior to purging. Purge water generated during sampling events will be discharged on the ground, at least 20 feet from the well site, unless previous analyses have indicated that groundwater contamination has occurred at that well location. If previous analytical results indicate that groundwater contamination has occurred, purge water may need to be containerized and disposed of in accordance with state and federal regulations. 4.3.4 Withdrawal of Sample After purging is completed, sampling personnel will re -glove with new disposable gloves in preparation for sample collection. Sample containers will be filled based on parameter sensitivity to volatilization and pH change as follows: • Volatile Organic Compounds (VOCs) • Other organics (SVOC & PAH) • Dissolved Metals • Anions/Cations • Other inorganics Monitor wells will be sampled for analysis of the Regulation No. 41- The Basic Standards for Ground Water 5 CCR 1002-41, Colorado Department of Public Health and Environment Water Quality Control Division. Tables with parameters from the Reg 41 Standards are provided in Attachment 2. Portions of the list will be determined for specific sampling events and is likely limited to volatile organic compounds (VOC), semi -volatile organic compounds (SVOC) and possibly polycyclic aromatic hydrocarbons (PAH) along with a list of metals and indicator parameters. Some low yield wells may produce insufficient volume to fill all of the sample containers within 24 hours of purging. Sample containers for these wells will be filled in the order listed above until the sample volume is depleted. Filled bottles will be submitted to the laboratory for limited analysis. VOC samples will be collected in 40 milliliter glass vials, SVOC and PAH samples will be collected in glass sample containers appropriate to the laboratory's analytical capability. Metals and other inorganic samples will be MO &ASSOLN CIEATES LG Everist Sampling Plan Page 6 of 10 Groundwater Quality Sampling Plan collected in plastic or glass containers of appropriate capacity. New sample containers with appropriate preservatives will be provided by the analytical laboratory. Every effort will be made to reduce contact between the bottles and sampling equipment. As an added precaution, contact time of the sample with ambient air will be minimized by replacing caps immediately after the bottles are filled. VOC samples will be collected without air bubbles. This will be achieved by adding sample slowly until a convex meniscus form at the top of the vial (i.e., the vial is slightly overfilled) before replacing the cap. Once the cap is firmly attached, the vial will be inverted and examined for air bubbles. Metal samples will be field filtered when possible, utilizing a peristaltic pump and 0.45 -micron filters. Sometimes field filtering will not be possible, and samples will be submitted for laboratory for filtering prior to analysis. Following completion of groundwater sampling at each monitor well, all re- usable, non -dedicated sample equipment will be decontaminated in accordance with the procedures specified above in Section 4.2.1. 4.4 Sample Preservation, Handling, and Shipment Groundwater samples will be preserved as follows: • VOCs — hydrochloric acid (HCI) or no preservative • Dissolved Metals - none • Anions/Cations - none • Other organics and inorganics — none Preservatives will either be included with the sample containers in small vials or will be pre -added to the sample containers by the laboratory. If the preservatives need to be added to the sample containers, sampling personnel will place the specified volume of preservative to the container during the sampling. Sample filtration may need to be performed in the field or in the analytical laboratory. After sample collection, filled and capped containers will be wiped clean, appropriately labeled, and stored with ice or frozen icepacks in insulated coolers. Sufficient ice or icepacks will be added to the coolers to maintain sample temperatures at or below 4°C. Packing material will be added to the coolers as necessary to prevent breakage of glass containers when they are shipped. At the end of each day of sampling, collected samples will be delivered or shipped to the analytical laboratory. A completed and signed COC form will accompany all samples contained within the cooler. The COC will be kept preventing moisture damage and may VAMP, LG Everist Sampling Plan Page 7 of 10 Groundwater Quality Sampling Plan need to be sealed inside a gallon -size ZiplocTM bag and placed in the cooler for shipment. If the sample cooler is shipped for overnight delivery, the cooler will be sealed with shipping tape and a signed COC seal, provided by the laboratory, will be affixed to the outside of the cooler. Sampling schedules and deliveries or shipments to the laboratory will be coordinated such that every attempt will be made to meet the recommended holding times of the analyses. Laboratory analyses performed outside the recommended holding times will be flagged or qualified appropriately in the report of analyses provided by the laboratory. 4.5 Chain -of -Custody of Samples EPA -accepted chain -of -custody (COC) procedures will be followed to maintain the validity of the groundwater samples being delivered to the laboratory. From the time the empty sample containers leave the laboratory until the issuing of the laboratory results, the samples and/or sample containers will be: 1) in sight of the assigned custodian, or 2) locked in a tamper proof location, or 3) sealed with a tamper proof seal. A written record of sample container possession and transference of samples will be documented on appropriate COC forms. The forms will also be used as a mechanism of communication between the sampling personnel and the analytical laboratory to note any specific details or requirements regarding the requested laboratory analysis. At the completion of the sampling event, a copy of the completed COC form, signed by all the appropriate entities handling the samples, will be retained with the laboratory report. 4.6 Quality Assurance and Quality Control Quality assurance (QA) and quality control (QC) procedures will be followed so that laboratory preparation, field sampling, and transport activities do not bias the results of the chemical analysis. QA/QC samples are collected to provide a quantitative basis for evaluating the analytical results. Typical QA/QC samples collected for groundwater sampling programs may include one or more of the following: Duplicate Sample - Duplicate samples are collected by the sampling personnel in a manner identical to the primary sample. The duplicate sample will be analyzed by the laboratory just as the primary sample is analyzed. The duplicate is intended to verify that the results from the primary sample are accurate and reproducible. Trip Blank - A trip blank consists of an analyte-free water sample prepared by the laboratory. The trip blank will accompany the sample container shipment from the laboratory to the field and back. At no time will the trip blank container(s) be opened in the field. Trip blanks will be analyzed by the laboratory only for volatile organic compounds. rATMOLEN & Assoc�ar�s LG Everist Sampling Plan Page 8 of 10 Groundwater Quality Sampling Plan Field Blank - A field blank consists of empty sample bottles filled with distilled or deionized water at the sample site by sampling personnel. The field blank will also be analyzed by the laboratory as if it was a "real" sample. Equipment Blank - A variation of the field blank is the equipment blank. Equipment blanks are prepared in a manner identical to field blanks, except that distilled or deionized water is poured through clean (field decontaminated) sampling equipment and into the sample bottle. Equipment blank samples are analyzed for all analyses and are used to verify that sampling equipment is uncontaminated. At least one of the QA/QC sample methods will be conducted every 4 sample events, one in four, during the first five years of sampling. 5.0 Analytical Procedures Volatile organic constituents (VOCs) will be analyzed in accordance with Method 8260 of EPA Report SW -846, Test Methods for Evaluating Solid Waste, while inorganic constituents will be analyzed by Method 6010 of SW -846, or other appropriate EPA methods. Reporting limits (RLs) for the parameters analyzed will be the lowest concentrations that can be reliably achieved within the specified limits of precision and accuracy during routine laboratory operating conditions and will be below any promulgated maximum contaminant levels (MCLs). Instrument detection limits will be kept at or below the RLs. Some analytical results may be reported below the RL and above the Method Detection Limit (MDL) with an estimated value. These results will be flagged, and the result determined as an estimate and not a reported value. 6.0 Analytical Data Review Upon receipt of the analytical results, general analytical data evaluation (i.e., data validation) will be performed. At a minimum, this evaluation will address the following: • Overall data completeness; • A review of laboratory qualified data; • Comparison of field duplicate results to original sample results; • Comparison of trip blank and method blank results to sample results; • Review of data accuracy based on cation -anion balances, etc.; and • Review of laboratory QA/QC sample results including comparison to spike recoveries to control limits. Results of the data review will be documented and used to initiate additional review by the laboratory or possibly addition qualifications of the analytical data by the reviewer. MA M,assoOLEN c�a7Es LG Everist Sampling Plan Page 9 of 10 Groundwater Quality Sampling Plan 7.0 Verification Re -sampling Under certain circumstances a verification re -sampling may be collected, and samples submitted for analysis using this Groundwater Sampling Plan. The samples will be collected within four weeks of the analytical report date. A verification sample may be at the following sampling event depending on the frequency of sampling. Verification re - samples are designed to provide confirmation of the sample analytical data for sample result anomalies or statistical analysis. /ra MOLENCIATES ASSO LG Everist Sampling Plan Page 10 of 10 Appendix I Sample Field Data Sheet f L.G. EVERIST WEST FARM GROUND WATER SAMPLING FIELD DATA SHEET SAMPLER SITE PROJECT MANAGER Well No. (Date: Time: 'Personnel: Weather: Well Inspection (condition) Casing Diameter (in) Meter Calibration: Casing Stick-up: (ft) Sampling Kit: Total Well Depth: (from top of casing) (ft) Sample ID: Time Taken Preservative Analysis Requested Static Water Level: (from top of casing) (ft) Purging Equip. Purge Rate (if pump used) Saturated Thickness:(ft) Sampling Equip. Casing Volume: (gal) Purse Parameters: Time Volume Purged Temp. (F°) PH Cond (us/cm) Relative Turbidity Odor Comments (color, odor, appearance) Well evacuated to dryness? (Y/N) Time to recarge well? Samnli Information: Date Time Purge Volumd Temp PH Cond Other I Sample Equipment Used Sample Appearance Pump Rata Sampler Name(s) Checked for: mmiscible Layer (Y/N) ORP Diss 02 % Appendix II Water Quality Parameter List Appendix I Tables Water Quality Parameter Lists Sample parameters: The sampling parameter list is based on collecting baseline data and obtaining recorded water quality sample results from regular groundwater monitoring. Five quarters of baseline data will be collected for the parameters as described below. After five quarters of baseline data, annual sampling of the wells will be collected and reported for parameters as described below. Parameters in italics are also listed on the South Platte River stream segment COSPMS01a for discharge permitting purposes. FIELD MEASUREMENTS Field Measurements are completed during the sample event to determine water quality stability for sampling purposes and to obtain field measurements for comparison to laboratory provided data. is K I� � �, �a � '4t Ss 4x: �„ �, � E'a r4-:,a�v $ 45 u• ,�-, ,, i.1 2 , ,. 4 k. ccp ii 5��-�ns , 4M r 9 u 8 e a a y� 3 s t 4 J `�'.r �*,m �y �.e�2"` �.ai� .s",�., pH Every Sampling event Specific Conductance Every Sampling event Temperature Every Sampling event ORGANIC PARAMETERS Table 2: ORGANIC PARAMETER RATIONAL Monitoring for organic pollutants listed is useful for background or baseline data collection. The parameters will not be collected for ongoing regular monitoring because they are "source" driven. A source of the organic contaminant, e.g., a spill, a landfill, a drycleaning facility, parked equipment with excessive leaks not regularly cleaned up, or a petroleum storage tank or similar incidents would have to have contaminated soil and groundwater for the organic compounds to be detected. Baseline data should provide knowledge that organics are "not present" and should be discontinued. Groundwater monitoring wells can be resampled for verification if a parameter is detected. The organics are listed in Table A in Reg 41— Colorado Basic Groundwater Standards. The list does not include pesticides, herbicides, PCBs, and other site -specific organics that are not expected to be in groundwater. ,�F°j n9A b.:,'^ `£',. `"�� '� �k' .��-. iY','•+r7' exa P . Wq—"'3^�- L "`�..i' uiS�Y 9r 0 `'G'v+.' "y " W t 'i'a� '� ryl�"^�7c,xgpP4T J 6 M�'a' M'1'(Yrl iy4 G 9 v` 5 d,.5's5 t,. VOCs Volatile Organic Compounds Five Quarters of Baseline; annually unless omitted for non -detects or other factors SVOC Semi -Volatile Organic Compounds Five Quarters of Baseline; annually unless omitted for non -detects or other factors PAH Polycyclic Aromatic Hydrocarbons Five Quarters of Baseline; annually unless omitted for non -detects or other factors Organics will be evaluated after 5 quarters of data analysis and if no detections will automatically be omitted from future analysis. If there is a confirmed and verified analytical result that is not explained in the evaluation period, quarterly analysis will continue until the issue is resolved or the data continues to show a downward trend and discontinuing is approved by DRMS. �1OLEN sstcrc LG Everist Sampling Plan List of Parameters Page 1 of 3 Appendix I Tables Water Quality Parameter Lists INDICATOR PARAMETERS Table 3: INDICATOR PARAMETERS RATIONAL The parameters in Table 2 are common for comparison of changes to groundwater chemistry, and not a reflection of pollution, unless a source is identified. The parameters provide information about anion - cation balance and the salts, solids, and nitrogen that is in the groundwater. Baseline data of the parameters will help understand groundwater chemistry. The metals are listed in Table 1 Human Health Standards or Table 2 Domestic Water Supply Drinking Water Standards in Reg 41— Colorado Basic Groundwater Standards. Parameters can be left out of regular groundwater monitoring depending on the data collected. The parameters to be removed from regular monitoring are those with significant number of non -detectable concentrations (80% or greater) or are determined to be unreliable based upon other factors. Other factors include, but are not limited to, nitrates from fertilizers used by farmers on land in the area and total suspended and total dissolved solids from wells that have high turbidity. ��jj 1 t4aiA ri sy ca K t �II a'vKra,tk �d: ...`$ iTC § d `'s L k ( 3TM@ hx'p T ameter , s I �� `.1 I r ,.bf Alkalinity (BiCarb/Carb) Five Quarters of Baseline; annually unless omitted for non -detects or other factors Calcium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Chloride Five Quarters of Baseline; annually unless omitted for non -detects or other factors Fluoride Quarterly Five Quarters of Baseline; annually unless omitted for non -detects or other factors Magnesium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Nitrite Five Quarters of Baseline; annually unless omitted for non -detects or other factors Nitrate Five Quarters of Baseline; annually unless omitted for non -detects or other factors pH Five Quarters of Baseline; annually unless omitted for non -detects or other factors Potassium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Sodium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Specific Conductance Five Quarters of Baseline; annually unless omitted for non -detects or other factors Sulfate Five Quarters of Baseline; annually unless omitted for non -detects or other factors Total Dissolved Solids (TDS) Five Quarters of Baseline; annually unless omitted for non -detects or other factors Total Suspended Solids (TSS) Five Quarters of Baseline; annually unless omitted for non -detects or other factors IOLEN vso 9AT S LG Everist Sampling Plan List of Parameters Page 2 of 3 Appendix I Tables Water Quality Parameter Lists METAL PARAMETERS Table 4: METAL PARAMETER RATIONAL Metal concentrations are commonly collected in groundwater. The metals are listed in the tables in Reg 41— Colorado Basic Groundwater Standards. This is a long list of common metals analyzed in groundwater and will be shortened after baseline data is collected and evaluated. The metals subject to removal from ongoing regular monitoring are those with a significant number of non -detectable concentrations (80% or greater) or if the data is determined to be unreliable based upon other factors. g'r,,.�, , e@ vv55 €k�,=#�'zY„' 1 ewi .py 's E' r dig Y Yt1aS d l#€�, +,x{,y a,,ra tww .lpf� �C Ir' � i, h X2..(f;n 5`:,Yl .`"Y e+` I �(S,"i iw" }R"x`£ Z�"a ₹!, � d i-� `vX's yY?4�'E:#i'Y-,! ' "`i `T'-' Freq ncy � ' F_s'"J' "T•,.l m�hwY"'a` 3 -.c,.. .,,_ .. - N'._`_ e x* q� ,n �..d- xic_�h Aa. tr _ �r�P-�'�i�. i'ry ffxk'Sv Antimony Five Quarters of Baseline; annually unless omitted for non -detects or other factors Arsenic Five Quarters of Baseline; annually unless omitted for non -detects or other factors Barium Quarterly Five Quarters of Baseline; annually unless omitted for non -detects or other factors Beryllium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Boron Five Quarters of Baseline; annually unless omitted for non -detects or other factors Cadmium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Chromium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Cobalt Five Quarters of Baseline; annually unless omitted for non -detects or other factors Copper Five Quarters of Baseline; annually unless omitted for non -detects or other factors Iron Five Quarters of Baseline; annually unless omitted for non -detects or other factors Lead Five Quarters of Baseline; annually unless omitted for non -detects or other factors Manganese Five Quarters of Baseline; annually unless omitted for non -detects or other factors Molybdenum Five Quarters of Baseline; annually unless omitted for non -detects or other factors Mercury Five Quarters of Baseline; annually unless omitted for non -detects or other factors Nickel Five Quarters of Baseline; annually unless omitted for non -detects or other factors Selenium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Silver Five Quarters of Baseline; annually unless omitted for non -detects or other factors Thallium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Vanadium Five Quarters of Baseline; annually unless omitted for non -detects or other factors Zinc Five Quarters of Baseline; annually unless omitted for non -detects or other factors LG Everist Sampling Plan List of Parameters Page 3 of 3 EXHIBIT L RECLAMATION COSTS The following information is provided to evaluate the amount of bond needed for Operations Stage A that allows for pre -mining development of the Plant Site and support facilities. In this analysis L.G. Everist, Inc. will have approximately 56 acres disturbed in some form or another. The activities planned in this Operations Stage will include stripping, soil and overburden storage, sloping to the plant working floor, processing plant installation in Phase 4 (50 acres) and construction of the 6.0 acre" water recirculating area (i.e. freshwater and settling ponds) in Phase 1. If development ended here the reclamation required would be to remove an estimated 300 yds of concrete foundations at the processing plant, resoil the 50 acres and revegetate the disturbed area in Phase 4. In Phase 1, water recirculating area would have to be backfilled, resoiled and revegetated. We estimate 145,200 cyds (6 ac @ 15 ft. average depth) would be needed to backfill the ponds. Adequate soil and overburden will be stored around the water recirculating area in Phase 1 for re -use on this area. Because mining will not start during Operations Stage A, we are not including any bonding for slurry walls. From the TABLE L calculations we request the financial warranty amount for this scenario be set at $343,300 LGE will file a Technical Revision to increase the bond before starting mining as explained in Operations Stage B. Table L shows the estimated cost for this phase. Tables L-1, L-2, L-3 and L-4 show the estimated cost to reclaim each of the mining phases based on today's costs and are included for future reference. The Equipment Used in the Estimate Is: Scraper teams - 2 -Cat 627G scraper, D9R Dozer, 140H grader & water truck - Resoiling, backfilling ponds, and bank fill placement Grader - Cat 140H - seedbed prep and ripping plant site Loader — Cat 688 — armoring placement Dozers - 2 - Cat D9R - cut/fill working face sloping Seeding team - standard farm tractor and pull behind drill, and crimping disk attachment L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 84 EXHIBIT L RECLAMATION COSTS (CONT) Unit Costs Used In Estimate Task Description y Direct Cost 001 - Revegetation - per acre $850.00 002 Replace Topsoil Cat 627G team — Haul distance - 900 feet or less and scraper per cubic yard $0.824 003 - Cat 140H blade Rip seed beds per acre $99.00 004 - Cat 140H blade Grade and shape per acre. $93.00 005 — Backfill Ponds Cat 627G team - using a and scraper per cubic yard Haul distance 500 feet or less $0.82 006 - Concrete demo per yard $7.00 007 - Secondary seeding per acre $212.00 008 -Weed Control per year $5,000.00 009 - Mob/demob - Haul distance 5.0 miles average speed 50 mph $6,406.48 010 - Bank fill using a Cat 627G and scraper team - per cubic yard Haul distance 500 feet or less $1.25 011 - Slurry wall Installation per face foot $5.00 012 - Reservoir armoring with Broken Concrete, placed per foot. $0.72 L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 85 L.G. Etaerist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE EXHIBIT L (CONT) Permit # M-2022-048 Table L Operations Stage A Length (ft) Average Depth (ft) CYD/FT 7olume (Cyds Sqft) or Push/Haul Distance Unit Cost Total cost Task Plant (Phase site setup 4) Acres 1 TOTAL AREA 76.42 TOTAL MINED 0.00 WATER AREA 0.00 Undisturbed (AC) 26.42 001 Revegetate (AC.) 56.00 $850.00 $47,600.00 002 a Resoil (AC.) 56.00 1.00 90,347 900 $0.824 $74,445.65 003 Rip seed bed (AC.) 56.00 $99.11 $5,550.16 004 Grading and Shaping (AC.) 56.00 $93.71 $5,247.76 15 145,200 500 $0.82 $119,644.80 005 Freshwater/ backfill setteling - 6.00 006 Concrete Demo (Cuyds) 0.00 300 $7.00 $2,100.00 007 Secondary seeding (AC.)@250 56.00 $212.50 $11,900.00 008 Annual Weed Control $5,000.00 Bond Estimate $271,488.37 Direct costs Total bond for Phases 1, 4 & stripped $271,488.37 Task Indirect costs Liability 2.02% $5,484.07 Profit 10.00% $27,148.84 Performance 1.05% $2,850.63 009 Mob $6,406.48 Engineering and management 6.00% $16,289.30, DRMS Management 5.00% $13,574.42 Total Working bond $343,242.10 Recommend Bond be set at $343,300.00 L.G. E7ERIST, INC. May 2023 86 L.G. Everist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE EXHIBIT L (CONT) Permit # M-2022-048 Table L-1 Task Phase 1 Acres Length Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 190.23 TOTAL MINED 146.67 WATER AREA 141.25 Undisturbed (AC) 37.87 001 Revegetate (AC.) 8.09 $850.00 $6,877.95 002 Resoil (AC.) 8.09 1.00 13,055 900 $0.824 $10,757.00 003 Rip seed bed (AC.) 8.09 $99.11 $801.97 004 Grading and Shaping (AC.) 8.09 $93.71 $758.27 007 Secondary seeding (AC.)@25% 2.02 $212.50 $429.87 008 Annual Weed Control $5,000.00 009 Mob $6,406.48 010 Backfill sloping (Cuyds) 1,079,259 500 $1.25 $1,349,073.93 011 Slurry wall (LINEAR SO -FT.) 10 218 ' 52 $5.00 $2,631,109.25 012 Reservoir armoring (Feet) 1,310 2.35 3,079 500 $0.72 $2,216.52 Phase total project Table L-2 $4,013,431.24 Task Phase 2 Acres Length Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 145.39 TOTAL MINED 106.87 WATER AREA 100.15 Undisturbed (AC) 24.07 001 Revegetate (AC.) 18.38 $850.00 $15,622.27 002 Resoil (AC.) 18.38 1.00 29,652 900 $0.824 024,432.99 003 Rip seed bed (AC.) 18.38 $99.111 $1,821.56 004 Grading (ACd)Shaping 18.38 $93.71 $1,722.31 007 Secondary seeding (AC.)@25% 26.72 $0.00 $0.00 008 Annual Weed control $5,000.00 009 Mob $6,406.48 010 Backfill sloping along river (Cuyds) 4450 208.33 929,295 500 $1.25 $1,161,618.75 010A Backfill sloping non river sides (Cuyds) 4225 115.54 488,160 500 $1.25 $610,200.00 011 Slurry wall (LINEAR SO -FT.) 10,166 52 $5.00 $2,633,118.32 012 Reservoir armoring (Feet) 9,605 2.35 22,572 500 $0.72 $16,251.66 Phase total project $4,476,194.33 L.G. Everist - West Farm Reservoirs 87 May 2023 L.G. Everist, Inc - West Farm Reservoirs RECLAMATION COST ESTIMATE EXHIBIT L (CONT) Permit # M-2022-048 Table L-3 Task Phase 3 Acres Length (₹t) Average Depth (FT) CYD/FT Volume (Cyds or Sqft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 60.36 TOTAL MINED 41.31 WATER AREA 37.71 Undisturbed (AC) 14.98 001 Revegetate (AC.) 5.35 $850.00 $4,551.63 002 Resoil (AC.) 5.35 1.00 8,639 900 $0.824 $7,118.68 003 Rip seed bed (AC.) 5.35 $99.11 $530.72 004 Grading and Shaping (AC.) 5.35 $93.71 $501.80 007 Secondary seeding (AC.)@25,0 3.75 $0.00 $0.00 008 Annual weed control $5,000.00 009 Mob $6,406.48 010 Backfill Sloping (Cuyds) 6,900 233.53 1,611,357 500 $1.25 $2,014,196.25 011 Slurry; wall, (LINEAR SO -FT.) 7,152 61 $5.00 $2,181,381.35 Phase total Table L-4 $4,219,686.92 Task Phase 4 Acres Length - (ft) Average Depth (FT) CYD/FT Volume (Cyds or $qft) Push/Haul Distance Unit Cost Total cost TOTAL AREA 76.42 TOTAL MINED 61.19 WATER AREA 56.14 Undisturbed (AC)'- 10.56 001 Revegetate (AC.) 7.05 $850.00 $5,993.87 002 Resoil (AC.) 7.05 1.00 11,377 900 $0.82 $9,374.32 003 Rip seed bed (AC.) 7.05 $99.11 $698.68 004 Grading and ,Shaping,, (AC.) 7.05 $93.71 $660.81 006 Concrete. Demo (CuydS), 500 $7.00 $3,500.00 007 Secondary seeding (AC.)@25°0 76.42 $212.50 $16,239.31 008 Annual Weed control'; $5,000.00 009 Mob $6,406.48 000 Backfill sloping (Cuyds): 6,160 161.16 992,746 500 $1.25 $1,240,932.00 011 Slurry wall (LINEAR FT.) 8,244 73 $5.00 $3,008,877.50 Phase total $4,297,683.17 L.G. Everist - West Farm Reservoirs 88 May 2023 EXHIBIT 0 OWNERS OF RECORD SURFACE AREA AND SUBSTANCE TO BE MINED L.G. Everist, Incorporated 7321 E. 88th Ave, Suite 200 Henderson, CO 80640 Surface owners and owners within 200 feet of permit line as of 4/25/2023 Abbett Trust Farms LLC C/O Dunham Trust Co, 241 Ridge St, Ste 100 Reno, NV 895012055 FPI Burlington Farms LLC 4600 S Syracuse St, Ste 1450 Denver Co, 802372766 Hergert Family Revocable Trust 15883 County Road 21 Platteville, CO 806517935 Ben R Houston 9053 County Road 34 Platteville, CO 806519218 Kim Y & Raymond S Houston 15649 County Road 17 Platteville, CO 806519424 Magness Land Holdings LLC C/O Magness Investment Group LLC 4643 S Ulster St Ste 1400 Denver, CO 802372869 Town of Platteville 400 Grand Avenue Platteville, CO 805637503 Jeffrey A & Kendra M Palombo 14900 County Road 21 Platteville, CO 806517930 Xcel Energy Tax Service Department PO Box 1979 Denver, CO 802011979 Rosalie E Rusch 15225 County Road 21 Platteville, CO, 806517933 L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 91 EXHIBIT 0 OWNERS OF RECORD (CONT) ROW's AND EASEMENTS ON OR WITHIN 200 FEET OF PERMIT LINE (8-23-22) Metro Wastewater Reclamation District 6450 York St. Denver, CO 80229 Central Weld County Water District c/o Stan Linker 2235 2nd Avenue Greeley, CO 80631 Western Mutual Ditch CO PO Box 282 LaSalle, CO 80645 Beeman Irrigation Ditch & Milling Company Ulrich Farms, Inc. c/o Ken Ulrich, Ken 14605 County Road 21 Platteville, CO 80651 Weld County Commissioners 1150 O Street P.O. Box 758 Greeley, CO 80631 CenturyLink Communications LLC (Lumen Technologies) c/o Timothy Kunkleman 931 14th Street Suite 1230 Denver, CO 80202 Kerr - McGee/ C/O Anadarko Energy Attn: Callie Fiddes PO Box 173779 Denver , CO 80217-3779 Associated Natural Gas AKA Panhandle Eastern Pipe- line 635 N 7th Ave. Brighton, CO 80601 DCP Midstream LP/ DCP Midstream Attn: Lew Hagenlock 6900 E. Layton Ave, Ste 900 Denver, CO 80237 L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 92 EXHIBIT S PERMANENT AND MAN-MADE STRUCTURES (10/11/2022) Owner(s) of Record of a Structure(s) within 200 feet of the mine, will receive a letter and Structure Agreement as required by the Colorado Division of Reclamation, Mining and Safety (DRMS). As per the DRMS rules, when a permit application is filed, the rules require either: a. The operator/applicant requests a Structure Agreement with owners of any permanent man-made structures within 200 feet of the permit area. In the agreement, the operator agrees to reimburse the structure owner for any damage done to their structure as a result of the mining operation. OR b. The operator/applicant can provide the DBMS with a Geotechnical Stability analysis which demonstrates that any structures within 200 feet of the permit area shall not be damaged by mining or reclamation activities occurring at the above -referenced site. We are sending letters and Structure Agreements to the Own- ers of Record for the structures listed in this exhibit and ex- pect to have some completed in the next 30 to 60 days. Copies of the completed agreements will be provided to Division when they are received. In lieu of receiving agreements from Structure Owners, L.G. Everist is including a Geotechnical Stability analysis in this permit application that has been prepared by Deere & Ault. It shows that the required safety factors are greater than State requirements at the slurry wall boundary, so the safety factors for any structure outside the boundary will be well above the state's requirements. This list represents the permanent man-made structures within 200 feet of or on the new permit area. Some offsite structures are within 200 feet of the permit area but not within 200 feet of an area to be mined. These structures are noted on the list with a * behind them. L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 98 PERMANENT AND MAN-MADE STRUCTURES EXHIBIT S (CONT) WITHIN 200 FEET OF PERMIT AREA (8-24-22) Surface owners Structures L.G. Everist, Inc. 7321 E. 88th Ave, Suite 200 Henderson, CO 80640 Fences, , powerlines 3 - House, 3 -houses, 3- sheds, 5 - irrigation water well, 1 -residen- tial well, numerous fences , Sprin- kler pivot pump houses Hergert Family Revocable Trust 15883 CR 21 Platteville, CO 806517935 House*, Barn* 3 -strand wire fence Magness Land Holdings LLC C/O Magness Investment Group LLC 4643 S Ulster St Ste 1400 Denver, CO 802372869 Fence (South side) Metro Wastewater Reclamation District 6450 York St. Denver, CO 80229 1 monitoring well Rosalie E Rusch 15225 County Road 21 Platteville, CO, 806517933 House, 3 - outbuildings, wood corral Jeffrey & Kendra Palombo 14900 County Road 21 Platteville, CO 806517930 House, garage, equipment building, swimming pool, wood fences, water well, Geothermal well. L.G. EVERIST, INC. - WEST FARM RESERVOIRS May 2023 99 PERMANENT AND MAN-MADE STRUCTURES EXHIBIT S (CONT) Rights of Way & Easements (4-25-23) Weld County Commissioners 1150 O Street P.O. Box 758 Greeley, CO 80631 County Roads 21* Town of Platteville 400 Grand Ave. Platteville, CO 805637503 CR 32.5 & Bridge* Beeman Irrigation Ditch & Milling Company Ulrich Farms, Inc. c/o Ken Ulrich, Ken 14605 County Road 21 Platteville, CO 80651 Irrigation canal* CenturyLink Communications LLC Lumen Technologies Timothy Kunkleman 931 14th Street Suite 1230 Denver, CO 80202 Underground communication lines Xcel Energy P.O. Box 1979 Denver, CO 802011979 4-Powerlines Central Weld County Water District c/o Stan Linker 2235 2nd Avenue Greeley, CO 80631 water lines Associated Natural Gas AKA Panhandle Eastern Pipeline 635 N 7th Ave. Brighton , CO 80601 natural gasline DCP Midstream LP DCP Midstream Attn: Lew Hagenlock 6900 E. Layton Ave, Ste 900 Denver, CO 80237 natural gasline Kerr - McGee/ North American Re- sources C/O Anadarko Energy Attn: Callie Fiddes P O Box 173779 Denver , CO 80217-3779 HRS-West Farm 5-14A, HRS-West Farm 6-14A, HRS-West Farm 12-14A, HRS-West Farm 13-14A, HRS-West Farm 22-14A, 5 -flow lines, Production equipment, 3 -tank batteries, 3-VOC Burner, 2 -sheds, Misc. Production equipment L.G. EVERIST, INC. - WEST FARM RESERVOIRS 100 May 2023 L.G. EVERIST, INC. Roca Spun SINCE 1876 7321 E. 88TH AVENUE. SUITE 200 HENDERSON, COLORADO 80640 PHONE 303-287-9606 • FAX 303-289-1348 PERMITTEE / STRUCTURE OWNER AGREEMENT By and Between Permittee (L.G. Everist, Inc.) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site The Colorado Division of Reclamation, Mining and Safety (DRMS), abiding by the Colorado Mined Land Reclamation (MLR) Law, requires the permit applicant/operator to agree to reimburse the owner of any permanent man-made structure(s) within 200 feet of the permitted mining area for damage done to the structure(s) as a result of the permitted operation. L.G. Everist, Inc. shall be the permittee (applicant/operator) of the following: Site: West Farm Reservoirs, a proposed sand and gravel mine, which has a reclamation plan of developed water storage (and is located in parts of Section 14, Township 3 North, Range 67W, 68 P.M., Town of Platteville, Weld County, Colorado). Central Weld County Water District owns the following structure(s) listed below, which are located within 200 feet of the permitted area: Structure(s): 2 -waterlines The permittee, L.G. Everist, Inc., does hereby certify that the Structure Owner named in this Agreement shall be compensated for any damage to their Structure(s) named in this Agreement, which is/are located within 200 feet of the permitted area, and damaged as a result of the mining operation to be known as West Farm Reservoirs. A notarized signature by a Representative of L.G. Everist, Inc., and a notarized signature by the Structure Owner (Landowner or Company Representative) in the spaces provided below shall satisfy the MLR law requirement and certify this agreement. A copy of the signed notarized agreement shall be kept by L.G. Everist and the Structure Owner. Signatures on following page Page 1 of 2 WF-DRMS-ExS-StructureLetter&Agmt-CWCWD-Nov2022 L.G. EVERIST, INC. ROCK SOLD SINCE 1876 7321 E. 88m AVENUE, SurrE 200 HENDERSON, COLORADO 80640 PHONE 303-287-9606 • FAX 303-289-1348 PERMITTEE / STRUCTURE OWNER AGREEMENT By and Between Permittee (L.G. Everist, Inc.) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site PERMIT APPLICANT/OPERATOR ACKNOWLEDGED BY: Permittee: L.G. Everist, Inc. Mail Address: 7321 E 88th Ave., Suite 200, Henderson, CO 8O64O Contact: Lynn M. Shults, Regulatory Manager - Signature: 1. Date: /l /6-1Z2_ STATE OF Colorado ) ) ss COUNTY OF Adams ) The foregoing was acknowledged before me this 15#4, day of Alovtwl% o r , 2O22, by Lynn M. Shults as Regulatory Manager of L.G. Everist, Inc. Notary Public: '6-4 My Commission Expires: lZ/ZgT202y STRUCTURE OWNER ACKNOWLEDGED BY: Owner(s): Central Weld County Water District Mail Address: Attn: Stan Linker, 22352nd Avenue, Greeley, CO 80631 Contact (owner/representative): %CLrin AiacbG L r BRANDON wEscoTT oSTERT I NOTARY PUBLIC - STATE OF COLORADO I NOTARY ID 20204045113 MY COMMISSION EXPIRES DEC 29, 2024 Signature: STATE OF Colorado ) COUNTY OF UV ) ss The foregoing was acknowledged before me this by d fan 1.-1 n Ker Notary Public: J7 L�1,C",tl.J ROXANNE'GARCIA NOTARY PUBLIC STATE OF COLORADO NOTARY ID 19974001261 MY' eb2all99IO# EAFlRES MF ee 2025 Date: ///,//f2,___ OQ1 day of NoVefllb-eV' , of C.er4r a,l Veld Cow -41 Wokr . My Commission Expires: 5-a Page 2 of 2 WF-DRMS-ExS-StructureLetter&Agmt-CWCWD-Nov2022 L, EVERIST, T, INC. ROCK Soup &vs 1876 7321 5. 88m AVM. Sur= 200 limpotsm Coto80640 ?twine 303-287-9606 * FAx 303-289-1348 PERMITTEE t STRUCTURE OWNER AGREEMENT By and Between Psrmittee (L.G. Everist, Inc) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site The Colorado Division of Reclamation, Mining. and Safety (0RMS), abiding by the Colorado Mined Land Reclamation (MLR) Law, requires the permit applicant/operator to agree to reimburse the owner of any permanent man-made structure(s) within 200 feet of the permitted mining area for damage done to the structure(s) as a result of the permitted operation. L.G. Everist. Inc. shall be the permittee (applicant/operator) of the following: g_ : West Faint Reservoirs, a proposed sand and gravel mine, which has a reclamation plan of developed water storage (and is located in parts of Section 14, Township S North, Rang 67W,. P'A4, Town of Platteville, Weld County, Colorado). Town of Platteville owns the following structure(s) listedbelow, which are located within 200 feet of the permitted area: Structure(s): County Road 32.5 The permitter?, L.G. Everist, Inc., does hereby certify that the Structure Owner named in this Agreement shall be compensated for any damage to their Structure(s) named In this Agreement, which islare located within 200 feet of the permitted area, and damaged as a result of the mining operation to be known as West Farm Reservoirs. A notarized signature by a Representative of L.G. Everitt, inc. and a notarized signature by the Structure Owner (Landowner or Company Representative) in the spaces provided below, shah satisfy the MLR law requirement and certify this agreement. A copy of the signed notarized agreement shall be kept by L.G. Everist and the Structure Owner. Signatures on following page Page 1 of 2 WFFARMS Ex5 slnicto to rMw P(attev6 e -N002022 L.G. EVERIST, INC. Rocs Sour, SINCE 1876 7321 E. 88TH AVENUE. SurrE 200 HENDERSON, COLORADO 80640 PHONE 303-287-9606 • FAx 3O3-289-1348 PERMITTEE / STRUCTURE OWNER AGREEMENT By and Between Permittee (L.G. Everist, Inc.) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site PERMIT APPLICANT/OPERATOR ACKNOWLEDGED BY: Permittee: L.G. Everist, Inc. Mail Address: 7321 E 88th Ave., Suite 200, Henderson, CO 80640 Contact Lynn M. Shults, Regulatory Manager Signature: STATE OF Colorado COUNTY OF Adams ) ) ss } Date: O122 - The foregoing was acknowledged before me this 151-N day of Novirukev' , 2022, by Lynn M. Shults as Regulatory Manager of L.G. Everist, Inc. " Notary Public: O(A-My Commission Expires: 22/Za%2029 STRUCTURE OWNER rdirdirawhahaihdbribiabrir 0 a BRANDON WESCOTr OSTERT I NOTARY PUBLIC - STATE OF COLORADO NOTARY ID 20204045113 MY COMMISSION EXPIRES DEC 29, 2024 ACKNOWLEDGED BY: Owner(s): Town of Platteville Mail Address: 400 Grand Avenue, Platteville,' CO 80566'05/ 5'/ ;tits &txthiJ Contact (owner/representative): Signature: , ld STATE OF Colorado ) ss COUNTY OF 1,{)6J ) The foregoing was acknowledged before me this — day of .-ee &en/X--, 62°,7 lvh Or etj-iC vi by Mr/ eJiJ -L It hdAtet,.J/ of Notary Public; Date: 4247,7 a � j �S My Commission Expires: I 7 /21 3 DANETTE M SCHLEGEL NOTARY PUBLIC STATE OF COLORADO Elision 1Q_2�Q'Fdbruary 3 My Commissl � ruary 27 2023 WF-r11414,,,.Ctriwimp' PMarRAnmt-Plathwilla-Nn Onn L.G. EVERIST, INC. Root( Soup SINCE 1876 7321 E. 88m AVENUE, SurN 200 HENDERSON, COLORADO 80640 Pxooe 303-287-9606 • Fox 303-289-1348 PERMITTEE / STRUCTURE OWNER AGREEMENT By and Between Permittee (L.G. Everist, Inc.) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site The Colorado Division of Reclamation, Mining and Safety (DRMS), abiding by the Colorado Mined Land Reclamation (MLR) Law, requires the permit applicant/operator to agree to reimburse the owner of any permanent man-made structure(s) within 200 feet of the permitted mining area for damage done to the structure(s) as a result of the permitted operation. L.G. Everist, Inc. shall be the permittee (applicant/operator) of the following: Site: West Farm Reservoirs, a proposed sand and gravel mine, which has a reclamation plan of developed water storage (and is located in parts of Section 14, Township 3 North, Range 67W eh P.M., Town of Platteville, Weld County, Colorado). Magness Land Holdings LLC owns the following structure(s) listed below, which are located within 200 feet of the permitted area: Structure(s): Fence The permittee, L.G. Everist, Inc., does hereby certify that the Structure Owner named in this Agreement shall be compensated for any damage to their Structure(s) named in this Agreement, which is/are located within 200 feet of the permitted area, and damaged as a result of the mining operation to be known as West Farm Reservoirs. A notarized signature by a Representative of L.G. Everist, Inc., and a notarized signature by the Structure Owner (Landowner or Company Representative) in the spaces provided below shall satisfy the MLR law requirement and certify this agreement. A copy of the signed notarized agreement shall be kept by L.G. Everist and the Structure Owner. Signatures on following page Page 1 of 2 WF-DRMS-EoS-StructureLetter&Agmt-Magness-Nov2022 L.G. EVERIST, INC. Roca SOLID SINCE 1876 7321 E. 88111 AVENUE, Surrc 200 HENDERSON. Coueouoo 80640 PHONE 303-287-9606 • FAX 303-289-1348 PERMITTEE / STRUCTURE OWNER AGREEMENT By and Between Permittee (L.G. Everist, Inc.) and Owners of Structure(s) Listed Below within 200 feet of proposed sand and gravel mine site PERMIT APPLICANT/OPERATOR ACKNOWLEDGED BY: Permittee: L.G. Everist, Inc. Mail Address: 7321 E 88th Ave., Suite 200, Henderson, CO 80640 Contact: Lynn M. Shults, Regulatory Manager Signature: STATE OF Colorado COUNTY OF Adams ) ss Date: ////6-#2_ The foregoing was acknowledged before me this i S ' day of JVOlIWt Jatt! , 2022, by Lynn M. Shults as Regulatory Manager of L.G. Everist, Inc. Notary Public: My Commission Expires: l i-/Z17Z0 2,1 STRUCTURE OWNER 1 BRANDON WESCOTT OSTERT I NOTARY PUBLIC - STATE OF COLORADO I NOTARY ID 20204045113 0 MY COMMISSION EXPIRES DEC 29, 2024 ACKNOWLEDGED BY: Owner(s): Magness Land Holdings LLC Mail Address: Attn: Magness Investment Group LLC, 4643 S Ulster St, Suite 1400, Denver, CO 80237 Contact (owner/representative): Signature: STATE OF Colorado ) ss COUNTY OF '4fkv-f l ) The foregoing was acknowledged before me this 1J' day of D 1114( , 7AYL2, by crilsea. Ntica �Iticts Date: lap/a). Notary Pu of f‘k),.h4 UtA,4l \J 4 S / . My Commission Expires: Iq,D2 2-o Z3 Page 2of2 SHAUNA NOLTE Notary Public State of Colorado Notary 113820104059464 My Commission Expires 04-02-2023 WF-DRMS-ExS-StructureLetter&Agmt-Magness-Nov2022 L.G. Everist, Inc West Farm Reservoirs BANK ARMORING PLAN This bank protection plan is presented to explain the bank armoring proposed for reservoir bank protection in a 1305 foot section of Phase 1 where mining will be within 400 feet of the River and around the entire perimeter of Phase 2. Only the reservoir side armoring is being proposed since the river bank will be 300 feet or more east of the top of the slope of the mining limits. The location of the proposed armoring is shown on MAP EXHIBIT F - RECLAMATION PLAN MAP . The attached FIGURE1shows the cross-section of the area discussed below and details of the armoring to protect the banks along the east side of Phase 1 and entirely around Phase 2. The armor is intended to protect the reservoir banks should a 100 -year flood event occur after an area has been reclaimed. The armoring will be covered with a 10-12 inch layer of growth medium and seeded with the approved seed mix. The toe of the slope armoring will be at least 5 feet below the thalweg of the adjacent riverbed. The base of the armoring will average 10 feet below the existing ground surface at the mine. The 100 -year Floodplain line information has been included on all of the MAP EXHIBITS in the application Packet. Armoring material will be recycled concrete fragments with surface rebar removed, so that it meets the definition of Inert Materials. The concrete will be sized 9 to 15 inches averaging 12 inches. Fines will be mixed in to fill voids. This size material will have a Safety Factor of 1.26. See Bank Armoring Calculation page following this text. The operator will keep enough material stored on the mine to complete armoring needed on any area where sloping is being completed and is ready for armoring. At a minimum, 2,350 cubic yards will be stockpiled on the mine for use in armoring. This is enough to armor a minimum of 1,000 feet of excavation bank. At no time will there be more than 1,000 feet of armoring needing to be placed. The stockpile of armoring material will be placed parallel to the water flow so it will not interfere with flows in the flood plain if flooding occurs. It will be within the setback between the permit boundary and the mine highwall so it is close to the area where it will be placed on the bank. LGE - WEST FARMS RESERVOIR May 2023 114 West Farm Recervnirs Bank Armoring Plan (ennt) Reservoir Bank Armoring. Armoring will be placed inside of the mined areas adjacent to the South Platte River channel in Phase 1 & 2. In Phase 1 the top of bank into the reservoir is more then 400 feet away from the mining line except on and approximately 1305 Fees section that is approximately 347' from the river and is protected from direct flooding flow by the old railroad embankment. This section will be armored as mining progresses thru Phase 1. The small section in Phase 3 is above the Flood Plain so will not be impacted by flooding. The armoring will be placed on the slopes starting from the existing ground surface elevation. The toe of the armoring will be a minimum of 5 feet below the river thalweg, have a 3h to lv slope and will be 2 feet or more thick. This will require approximately 2.35 cyd/lft along the excavated bank slopes. Once sloping begins, the armoring will be installed on 1,000 foot sections until completed. This will leave an armored face along the top of the bank and the slope into the reservoir that is 35 feet wide. Supplied supporting documents Figure 1 - Bank Protection Plan cross section Safety factor calculation page LGE - WEST FARMS RESERVOIR May 2023 115 L.G. Everist, Inc. Revised 0512023 WEST FARM RESER RS BANK ARMORING PLAN -50 -45 -30 -20 -10 0 10 20 30 40 50 NOTES: MzT SINE 51-v RRy W AU - PER 'TOP P OF SCOPE TYPICAL RESERVOIR BANK ARMORING NO SCALE 1. BANK ARMORING SHOWN ON RECLAMATION MAPS IS APPROXIMATE LOCATION. ACTUAL LOCATION WILL DEPEND ON LOCATION OF TOP OF SLOPE AT THE TIME IT IS INSTALLED. 2. MATERIAL USED FOR ARMORING WILL BE WELL AGED BROKE CONCRETE. THAT HAS ALL EXPOSED SURFACE REBAR REMOVED. AT A MINIMUM 2,350 CUBIC YARDS WILL BE STOCKPILED ON THE MINE FOR USE IN ARMORING. THIS IS ENOUGH TO ARMOR MATERIAL TO ARMOR A MINIMUM OF 1000 FEET OF EXCAVATION BANK.. 3. STOCKPILES OF ARMORING MATERIAL WILL BE PLACED PARALLEL TO THE RIVERBANK SO IT WILL NOT INTERFERE WITH FLOWS IN THE FLOOD PLAIN. THE STOCKPILES WILL BE PLACED BETWEEN THE PERMIT LINE AND THE TOP OF SLOPE WITHIN 500 FEET TO THE AREA WHERE IT WILL BE PLACED. FIGURE 1 4. BANK ALONG THE EXCAVATED AREA WILL ARMORED FROM THE EXISTING SURFACE TO A POINT AT LEAST 5 FEET BELOW THE CHANNEL THALWEG. 5. THE SIZE OF THE MATERIAL WILL FALL IN THE RANGE OF 9 TO 15 INCHES AVERAGING 12 INCHES AS DISCUSSED IN THE BANK ARMORING PLAN AND WILL BE PLACED BELOW GRADE. 6. THE ARMORING WILL BE COVERED WITH A 10-12 INCH LAYER OF GROWTH MEDIUM AND SEEDED WITH THE APPROVED SEED MIX. NOV 03, 2022 - 16:02;23 L.G Everist, Inc. West Farm Reservoirs SF = cos 0 tan ° _ 21 r, n tan 0 + sin 0 Ts = yRS " (s —1)y D s so B = face slope of pitside bank, in degrees to the horizontal 0 = angle of repose of pitside bank construction materials in degrees n = stability factor s, = specific gravity of riprap particles Y = specific weight of water = 62.4 lbslft Do, = median riprap particle size, in feet R = hydraulic radius at normal depth of flow down pitside slope, in feet S = face slope of pitside bank, in feet per foot Bank Armoring Plan (cont) Safety Factor Calculations T, = yRS 1= 62.4 R=2 S=0.01 1.248 It 21 r (SS.-1)y Dan ti s = 1.248 Ss = 2.4 D50 = 1 SF cos 8'tan C nton 0+sin 0 n = 0.3 cos0 = 0.9487 0 = 18.43° tano = 0.7002 0 = 35° sine = 0.3161 SF = 0.6643 0.5262 F_ .26 117 West Farm DRIES Exhibit 0 - Public Notice List Ex O (list) Owner Deaarfptlon Certified Nell # date acted NOTES on Ex O List LANDOWNER L.G. Everist, Incorporated aPPicant. s rot needed- applicant and land owner not sent Na app0cant LANDOWNER Abbett Trust Farms, LLC "...a 200 ft 7020 0090 0001 0134 6539 12/08/22 green earl net returned yes LANDOWNER FPI Burlington Farms LLC landwfm 200 ft 7020 0090 0001 0134 6546 12108/22 o 12/141 yes LANDOWNER Hergert Family Revocable Trust tend whin 200 ft 7020 0090 0001 0134 6553 12/08/22 9 yes LANDOWNER Ben R Houston land w8n 200 ft 70220 0090 0001 0134 6560 1260/22 green, relutn 2/22/22 Yes LANDOWNER Kim Y & Raymond S Houston lend Mtn 200 ft 7020 0090 0001 0134 6577 12/08/22 greenivirets" yes LANDOWNER Magness Land Holdings LLC hand wrm 200 ft 7020 0090 0001 0134 6584 12/08/22 w714120, -yes tA1NDOVWNER Town of Platteville Land wnn 200 h 7020 0090 0001 0134 6591 120002 aZia yes LAND/STRUC Jeffrey & Kendra Palombo tanawfinno n 7020 0090 0001 0134 6607 12100122 !Ti eium 1znt3tz2 yes LANDOWNERService Xcel Energy (aka Public Co of CO) land vain 200 ft 7020 0090 0001 0134 6614 12/08/22 gmen 21 y. LANDOWNER Rosalie E: Rusdr Land., 200 fl 7020 0090 0001 01346621 12/00/22 green roam" 12/14/22 yes Rom Metro WaoteWate' Redamation District 2 mandating wa8d1 7020 0090 0001 0134 6638 12106122 main green return tes ROW E/SE Central Weld County Water District,returned 3....... n 70200090 00010134 6645 12/08/22 n card not ves • ROVWEASE Westem Mutual Dftch Co. ...ROW 7020 0090 0001 0134 6652 12/0efY2 green u12/14122 fires ROW/EASE Beeman Irrigation Ditch & ittg hripa8on o 7020 0090 0001 01346669 12/08122 a ! ROVWEASE Weld County Commissioners WCR 21 7020 0090 0001 0134 6676 12/09/22 "enretum yes ROVWEASE Century Lirtk Communications LLC (aka Lumen Technologies, Inc.) 7020 0090 0001 0134 6683 12108122 arean cant not. returned yen ROVWEASE Kerr-McGee (aka Anadarko) wells Itossines 7020 0090 0001 0134 6690 12/08/22 eroett return 12H4r22 ROWIEASE Snyder' O9 Corporation (c►o Enef9Y oY line EL facilities 7020 0090 0001 0134 6706 12100/22 yes ROW/EASE Associated Natural Gas, Inc (aka Panhandle Eastern Pipeline), natur. gas line 7020 0090 0001 0134 6713 12/08/22 green reWnf elm= yes ROW/EASE DCP Midstream LLC noso0 gas tine 7020 0090 0001 0134 6720 12/06/22 9,7;i -turn yes ROW/EASE' Auke12/03/22 - D. rcpt.(' by DCP not eent n/a no Eat O Notice's Green Card not Returned from the following, but all 3 have been notified of the West Faou permit application, Abbett Trust Farms, LLC (applicant & DRMS 'net with Abbett landowner reps) Central Weld County Water District (Central received Ex S notice - and sued Structure agreement) Century Link Communications LLC (aka Lumen'Tech., Inc.) (Century Link received Ex S notice) Note: See t1SPS Tracking info, showing proof of mailing of Ex O notices, and Gentry fink's Ex S notice. WF-DRMS-ExO'Putric Notice gist & E/S-Structure List Dec2022 West Farm - DRMS Exhibit O - Public Notice List ABBETT T/rrk- rcti"Pt.-S ihfb) Complete Morns 1. 2., and 3. ■ Print your name.anaddress on the reverse so that we can return the card to you. ■ Attach this card to the back of the maeplece. or ors the tmnt if space permits. ,. Article Addressed FPI Burlington -•r .ne_1 LC 4600 S Syra*_+ne St, Suite 1450 Denver, CO )237 VI��IN�I�IIIAIIIV�IIIVIIY 9590 9402 5860 0038 5399 06 a Amide Number Mosier from service lsbef ?020 0090 0001 0134 6546 Pa Form 3811, July 2015 PM 7530.^ 000-9053 a: o rrrtorayMea eaa Registered mem Adult soon.w� edDalkon ono**, CeeMed Ru heseeuemy NWe100httor 0:1104.100 Dellaity O Coeecton Detvay t eebtcted Davey D Corftletbri. d hewed Mee D Sputum Condon of eedmitmoldedoolveryr RMreadt)eMry Domestic Return WF ORMS-Ex0-Public Notice Us $ EuS-Structure UstOec2o22 West Farm ARMS Exhibit O - Public Notice List SENDER: COMPLETE. THIS SECTION a Attach this cartel to the back of the ma tplece, or on the front if Space punks. 1 Mete Addaessed to: Hergert Fairiiy t5, `bcable Trust 15883 County ad 21 Platteville, CO IIIIIIWIIY��IIINNaulll� 9590 9402 00333398 90 7020 0090 0001 0134 m 3811, Juiy2016 t rsso.os SENDER: Ccts^•PLETE THIS SECTION Ben R klc053 Co"t"ty Road 34 Platteville, CC) 80651 IJIIi1fIII!lllilfl 1i1f II1Fll 1111111 9590 9402 5860 0038 5398 76 Article Number (mart, 7020' 01090 r11, my am se►vke lal j 101 01134 6'560 0. Is deWvecy address dttrerentfrom Item 1? C Yes it Yea, enter de rey address Otto X a C SECTION UN OE Li, FRY Q Apent Addressee 11%me [C. Date of Delivery t ETE Tr -VS StrYrorJ O^t Dpi.rt%ERy d rrleti iiaadbrd OulPmy only 0 Gated on Dallvery ti rtapdtkdrety a s CanpmettbrtTM Qom. Rtae ct p� ANF RM5-Exa.puaee Notice List a Ex.Structure Lista5,2s22. West Farm - DRMS Exhibit O - Public Notice List :23 its ur flarne on so that we can return the card to ysru. • Macneill; card tot* tack of the man or on thefts* it space permits. 1. Mists Adder to: Kim Y & Rayr. Houston 15649 County Road 17 Platteville, CC 6O651 11111111111 9590 9402 5860 0038 5398 2. ;AddafeNi"` r 7020 0090 0001 01347 Ps p e 3811,4* SENDER: COMPLETE T, -rid Magness,- Holdings LW : Ma g f. Investment Group MC S St, Suite 1400 Denver, CO 80237 IIIIIIItIII9590 9402 5860 0038 5398 69 IIIB II�IIIENdI I II � Number (Tre from service lab 7020 0090 0001 0134 6584 5 Form 3811.Julyr 2815 7580;02.-0o04053 A�rJ"7F'Ef ,, rll Ji x ES, enter deliYely 3. Sen ice y° aAot dines MAO INF-RRMS-Es -Puke Notice list d[ ExS-Structu a U.0.Q22 West Farm - DRMS Exhibit O Public Notice List SENDER: COMPLETE THIS SECTION tt Complete items 1, 2. 811C1 3. ■ Print your name and adebass on the reverse so that we can refum the card to you. ■ Attach this card to the back of the maipiece, or on the front if space permits. 1. Artide'Addressed to: Town of Platteville 400 Grand Avenue Si Platteville, CO OP5 11111111111111111111111111141 9590 9402 5860:0038 5398 52 3. ',micelle o Natty Mar e OAdd Ogaden RegisimpdM O Poilt SignstureRestkied&Avow 0eepredMeleeebwed IbCertad o Mil �Rulddedt y l: eAMn Flumdfdtx O calvedon osevery OCollect= Whew ReeckledWow fl OO Ins. a ldedodity W 2. Ankle Number (Tra from sermke 7020 0090 0001 0134 6591 PS Form 3811, Juhr 2015 MN 7530-02-000 -9053 ' ■ Co mpleto items 1.2. and 3. • Print yournatne and addniss on the reverse so that we'cari return the carat to you. is Attach this card to the hack of the noilpieca, or on the front if space permits. 1. Article Addressed to: --- lllIlllillIlllIllllif 11011 IllOlIllIlIlllilt 9590 9402 5860 0038 5398 45 2. Article Number (Transferfrom service (rbe° Domestic Return Receipt Jeffrey & Kendra Palombo 14900 County Road 21 Platteville, CO 80651 3. SenteType O PflorkyMee Expose O AdultAdult SIgnattn Reetrbred Amboy oy , 0 Mgref Lid Besotted !� McN�1 [7Ce�epA�iddWheioktedDelay 210RetuntReceipt O Collect on WW1,O Calm on DediwyResbicted Deem. O SW.. MacSee ke O wow wit Og Confirmation , 7020 0090 0001 0134 6607 0 s PS Form 3811, July 2015 PSN 7530.02.000-9053 Domestic Return Receipt t W,11RMS-FunPut c Naha* I kt R Fur...CMu w* I Lutalpr tiri West Farm - DRMS Exhibit O - Public Notice List SENDER: COMPLETE THIS SECTION • Complete Rents 1.2. aid a • Fait your name and address on the reverse so that we can return the card to you. ■ Attach this card to the book of the matlpiece, or on the front if space pernmlls. 1. Artcle Addressed to: Xcel Energy (aka Public Service Co) Tax Service Department PO Box 1979 Denver, CO 60201 111IlIII1!II1IIIIIIIIll1JUhiif Hill 11111 9590 9402 5860 0038 5398 38 2. Article `Rumba (Transfer from service latch, 7020 0090 0011 0134 6614 PS Form 3811. Jidfi2oi5 s }oz000-8oss COWLETE THIS SECTION ON DEc IVEF; r O Addressee D. 1? O Yes OYES, delivery address below: a No a Service Rio* Ohl Express* OO M$ Slgoee e D OAdrreegreueaeaeeedOehMry DReeUMeed e$sr .d O e pee k OMwry VI ter O Caged an Delivery eSued ted Delray O Sondem Ceeens roes Otlenwd We I k 4,, , i a *rim eonennallar O 'undid lAill ReeldcluiNan y aeeakbdOdrmy SENDER. COMPLETE TH, SE CON CompisteItems 1.2end a if Prhrt your name artci address on the mv!erse twe that we can return the cani to you. ■ Attach this card to the book of the mollpfece. or on the front if space pemits. 1. Ankle Addressed to Rosalie E Punch 1522o'Cou. ty Road 21 *Platteville, n 80651 IlIIlIlIlIIIllIIHhII1hIh1l1hIIfIllIhhiiiiiij 9590 9402 5860 0038 5398 21 2 Article Nwabef (rrar>sfertrarthskthep 7020 0090 0001 0134 6621 PS f'orm"3811, July 2015 psi 5•aao-sow ° mann Fletum Receipt , Slime ss O Addnssaea C. Received by ('dated IC. Date of oeuvery D. Is delivery address d lte r:et from item l? 0 Yes q YES, enter delivery address below p No 3. Service type p Priority Mee " O Adult SOON, 1 otk t:t asleep iaeeht�fed s • riAdteac tedouueey *ee esaeoereNa Delivery oC Ca eon Mary eueelcted Delany ClAirst.C.dradionmind Oxiirmatian lit Delivery Return WF-ORMS.EXO-Pubes Notice List a ExS-Structure List.osc2on West Farm - DRMS Exhibit O - Public Notice List SENDER: COMPLETE THIS SECT/ON I ■: Pile so w Attach this cae or on the float t,Aildsik�dmsse i Metro Wastewater Reclamation District 6450 York St. Denver, CO 80229 I1I1IItIIIIIIiIIIIllhII1IILIIItIII0IIIIIl III 9590 94025860-00385398 1.4 a . A+tide t Mangier from service 1.00 7000 0091) ❑001 0134 6636 ,047,P! ET E 7H,S SECTION ON DELIVERY a as a PS f=orm 38# i, Sri C. of Delivery Semi? o Yes w: a No: WFORMS xa•public Note* list & ExS-Structure List dee2022 West Farm - DRF/IS Exhibit O - Public Notice List SENDER: COMPLETE THIS SECTION • com Clete Items 1.2. sad 8. ■ Print your name and address on the reverse so that we can return the card to you. $ Attach this card to the back of the mallpiece► or on the front if space permits. 1. Article Addressed to: Western Mutual Ditch Co. PD Sex 232 LaSalle, CO 80645 —04/1 I11ItIIII1I1tI1lllhIIILIt1ii1IIII1llhItIIII 95909402 58%0638 5397 91 „OMPLE, THIS SECT/ON ON DE:.!VERY 2. Article Nttnber ,,..(11reiskikorn label 7020 00913001 0134 6652 PS Form 1 Juty2O)5 PSN 7530.02-030-9053 SENDER :0; 1PLE T4,IL :I. • 'Oamplela Item 1.2. ands. pnntyaw non* and 000reno on the revenge So that We can return the;Card to you. ■ Attadt tits ,card to the bank of the rrai fOlenn. or on the Sant if noncepems.. 1. Article Added to: Beeman Irrigation Ditch & Milling Co. i clo Ulrich Fawns Inc (Ken Ulrich) I 14605 County Road 21 Plattev= 3+, x 80651 110111110111111111131111111111 .9590940258600038'6397 84 2. Article Number (Transfer from servke kW 7020 O090 0001 0],34 6669 PS Form 3811. July2015 PSN 7530-02.000-9053 lackhdo aft.* %Addressee B. Received by Netp0 C. Date of Delivery Ikarey glaar 649 9- D. is delivery Witless dim -fit Item 12 Yes If YES, ender delivery address below: CI No 3, Service 'Ms Priority MOW.. 0 ed D 0 Adult tiltronseRestfoMd OAMwy t7 :girl Mel Reamed Certeled DC«UiedM etlieMdeMdOm*wy Receipt tor tNereheniMe 0 (Medea 00very Collect enDellowyRestelded Delray xGSanto. �rrArrnatlorr e D trrerrred Mel Reuse Whey o neestoMaDrhary Domestic Return flerielPt t ,adders. eiee frontt em 1. _ E YEs, enter delver), addt+ess beroyw : O No 3. Service Type 0 Nut Skean artglaftliftedNtrdri'le". "Mottled Md. 0(WSed tAstriNttionoDawn ii eew„R!eekleser a Coeax en Delivery Coiled on Ode, Reenloted Dewy a Inured Mil Restricted Dewey A. 55es save" too WOO) Montt Retum Rsoekit West Farm - DRMS Exhibit 0 • Public Notice List SENDER: COMPLETE THIS SECTION Cotr pietoe items 1.2. end 3. ■ Print Your name end .eddress on tfMe Ir3i►81 so that we can return the card to you. Is Attach this card to the back of the'rrlipiece, or on the front it space permits. 1. ktide Addressed to:' Weld County Commissioners 1150 O Street '.to. t ©1 7g3 - Greeley, CO oto3 jb 11111111111111111 III 9590 9402 5860 0038 5397 77 Aw#Ide uurnber (limier *ow se,wce 104 7020 0090 0001 0134 6676 IForr� 3811;Juiyt5 t 7 ' ' wF-RRMS-Ex4Pubic Nodce Luca Exs West Farm - DRMS Exhibit O - Public Notice List SENDER: COMPLETE THIS SECTION ■ Complete hems 1, 2. and 3. ■ Mit nano and address an the reverse so that we can retum the card to you. ■ Attach this card to the back of the mailPfece, or on the front if space permits. 1. Article Addressed to: Kerr-McGee (aka Anadarko) Attn: Cagle Fiddes PD Box 173779 Denver O 80217 II IIIIIIIUIIIII1IIIIIIII1IIIIIII IIN 9590 9402 5860 0038 5397 53 ...Jo Num.. ffinmsfar from soy. kind 7020 ,0092 0001 0134 6690 P, 'arm 3811: +Julit 2015 f t;753o-oe= 00.9053 COMPLETE THIS SECT/ON Of, DELIVERY A. Slpatwe X JODt8R00KS g A D Atidreeeae a Received by pint mei 2 C. Date of Delivery a b delivery address dfferentirom item 1? D Yes ff YES, enter No s. Service Nee ' '1 11Expanse O AdultMandan ' O Adam Ord.. ,' AepltM�ed dell Rnabled JICCatilled kW* 0 Ceded eallAsst cerl tteevery' la rieoetattor CollectonNewry O Cobol ortWaxy Rtewicled Delaney DSOON Conlemetion. Olowed Mel loteuerraldMO y r.Mraeeoel�nnr $4264laytetom Racer 0 Cott rtt 1.2, grid a ■`Print your noire and address on the !MISS so that we can nAtrn the carts to you. ■ Attach this card to the back of the mica, or on the front it space permits. 1. Article Addressed to:. Snyder Oil Corporation cin *,on Energy 333 Vest Iherdan Avenue Oklahoma City, OK 73102 9590 9402 5860 0038 5397 46 2. Article Number (Transfer kern service 7020 0090 0001 0134 6706 FS"Fomc 3811, July2o15 Psri 7530-02-00019053 O kW* 13 Addressee Received by(PrefedName) IC. Dslso(vent' D. is deavety adc4!ess 1? D Yes EYES ender delivery address belowr 3 No Registered Mul OMiro 0 OW Squid. Reetdoted MagaryIfCerteled ndMee R O aMe as lted IAA Restricted Delve, l� Rearpt for DCoMiotonDe Restricted Cobol D e roeContmiaearR"' o sd o slime Cor*meaanr. O Insured MeltReitected,Dellveiy RusetotedOsttcsyr Domestic Retain Rat West Farm - DRMS Exhibit O Public Notice List Complete Kama 1.3.8.0 a Prfr� y that , t yourm can me and addro o onf eifele so ��return the caa� ■ Attach this card to the back a the. , or on the front if she parmlts. 1. Article Addressed to Asso.gd Natural Gas, Inc. {aka :"'handle Eastern Pipeline) 635 r 7.th Avenue Stighton, CO 80601 SENDER' C0IHFLHT,_ THIS SECTICIT Cornplets Items 1, 2. and 3. ■ Piety ornamea daddressontherevrerse so that we of return the card to you. II Attach this card to the back of the .ma , Ott the front if space permits. , 1, Mk* Addressed to: DCP Midstream LLC 6900 E. Layton Ave, Ste. 900 Denver, CO 80237 91�1N�IIANIIIIRIel�llll@ 9590 9402 5860 0038 5397 22 11lomeetic Robins Flooeipt 2. Mile Number (Transfer boa? sake 5 ?a2n 0090 Otani 0134 1,720 PS Ferrn 3811, July 2015 7530-02-000.0053 a Acklressee a Adult St Type 0 O Adult SIgnatunfledlc101Dellvey aRAtedMMAe14lcted Caged We o catecom o at«aree O bowed Mat ReelrietedDelivery 0 Mona WIWI O A Date or 0e 0. le de eery address different from Rear 1? O Yes If YES, enter clayey address below 3 No 3. O CI _ Re llt Codified Male WWI tt 0 Collect on Delivery Merchandise 0 Caxton DeNyety Restrkted Delvero et ataane Bantu QOPDXIMIII D *SW Want* 0k w 450C1 Domestic Return Receipt i 2/7/23,1:45 PM USPS:camt - USPS Treddng® Results USPS Tracking 'Racking Number: 70200090000101346539 Copy, Add to Informed Delmer J/informeddelive,y,usps.cmmJ) /rr Tom- Reki.s FAQe > emove X Latest Update Your item was delivered to an individual at the address at 12:06 pm on December 12, 20221n RENO, NV 89501, Get More Out of LISPS lbeoldne LISPS 1baotdng Russ Delivered Delivered, Left with 6tdixldual RENO, NV 89501 December 12, 2022,12:06 pm SeeAO Trekking History Text & Email Updates v USPS Tracking Plus® Product Information Postal Features+ See tracking for related items 9590940258600038539913 Product: Certified Mait`" V ?u a s1 First -Class Mae See Less A Track Another Package n I Enter tracking or barcode numbers httpalitools.asps comJgoffrackCcrtflmkAdfoetilef itpage&tL&text2g777zEdLabels.70200090000101 Ise 112 2/7/23,1 A8 PM USPS.com5 - USPS Tracking® Results USPS Tracking 741,IaA TrUs�� Tracking Number: 9590940258600038539913 Copy Add to Informed Delivery .11informeddelivery.usps,com4 1 i FAQs> Remove X Latest Update The U.S. Postal Service has received elecbnnic notification on December 8, 2022 at 4:22 pm that you have iodated a return receipt to your item. Get More Out of IMPS nracidnfp IMPS Thiddng Pius. Prue -..Shipment Return Receipt Associated December 8, 2022, 4:22 pm g 3t - Text & Email Updates USPS Traddng Plus® Product Information Postal Product Features: See tracking for reiatad No=70200090000101348839 First -Class -Package Return Receipt VgoritrackConfirmAction?tLabele.70200090000101348539) Service - Retail USPS Tractdng See Less " TrackAnotherPackage fEnter tracking or bar rode numbers https:/Mcts.asps;ccmlgo/TrsckConffmAclioa?ILa 13 1/2 USPS:cort0- LISPS l addng® Results USPS Tracking® Remove x 7 000101346►645 Copy Add to Informed Delivery gittpsJtinforrneNddelivrotyr usps.com/j Text & EmailUpdates t were unable to deliver your pie at a am on December 10, 2022 to BEY, CO 80631 because the Mistress vw as closed. We win redeliver on the next business day. No action needed. USPS blacking Plus® Mail® See tracking for related item; 9590840258800038539807 (/Sof1rackCornfirmAction. htlpe•J/tiools uspe. -70 1/2 2/7`123,1:47 PM USPS.com®- USPS Tracking® Results USPS Tracking Ikacidng Number: 9590940258600038539807 Copy Add to Informed Delivery d/informeddelivery usps.com/} FAQs > Remove X Latest Update The U.S. Postal Service has received electronic notification on December 8, 2022 at 4:0 pm that you have associated a return refit to your item.. Get More Out of USPS hacking: IMPS Tracking Plus. Pre -Shipment IP Retum Receipt Associated December 8, 2022, 4:30 pm Text & Email Updates "s/' LISPS Tracking Rust) Product information Postai Product Features: See tracldng for related item; 70200080000101348845 Rrst-Class Package Return Receipt (/go/ilackconfrmActlonTti abeis=7020009000010134s645 Service - Retail USPS Tracking. See Less Track Another Package IEnter tracking or barcode numbers httpsd/toolsuspS.comfgorr ackCcnikmAction?La 112 217/23, 203 PM USPacorns - USPS Treddngs Results USPS Tracking 'hacking Number: 702000900001 01346683 Copy Add to Informed Delivery (fittps/JAnformeddeliveryusps corm) I th,t,c-fy ZAL vinviTeit (Extvibi- Latest Update Your package will arrive later than expected, but is still on its way. It is currently In transit to the next faclity. FAQs} Remove X Get More Out of USPS -Racking: USPS 'Racking Plus* Preparbia for Whom Moving Through Network • in' Arriving Late December 14, 2022 Departed USPS Regional Facility DENVER CO DISTRtBU11ON CENTER December10, 2022, 2:46 am • See Mtiia g Histe.y Text & Email Updates USPS'7iecidng Pius® Product Information Postal Features See tracking for related item: 9590940258600038539760 Product Certified Mail"' ygeffracicConfirmAction?ttabels=9590940256600038539760) First -Class Mans`' htfpsipools.usps rNgarrfadtConfinnAcfi IrMR0-4ulltl_atre1s=70200080000101346883142C 1/2 2/1/23, 2.03 PM USPS.corne - USPS Tracking Results USPS Tracking® Tracking Number: 9590940258600038539760 Copy Add to Informed Delivery tps:J/informeddelivery.usps co J) FAQs > Remove X Latest Update The U.S. Postal Service has received electronic notification on December 8, 2022 at 4:32'ptn that you have associated a return receipt to your item. Get Afore Out of Lars 1b eddrg: UM 'Racking Pluse Return Receipt Associated December 8, 2022.412 pm Text & Email Updates V LISPS Tracking Pius® v Product Information Postal Product Features: See tracking for related Item 70200090oo0101 First -Class Package Return Receipt Y an tUabelft7020oo9000010134ao8 Service - Retail LISPS liradcig5 See Less A Track Another Package IEnter tracking or barcode numbers n hltpa:/l600lsaazpa oaNgofT o5 1/2 2/7/3, 2:27PM USPS.cam®- USPS T ng* Results USPS Tracking* co* lracldng: Number: 70200090000101346409 LAIL Zvi O44,Teot C9dv't1') Copy Add to Informed Dewy (hrips://informeddeliveiy usps com/) FAQs> Remove X Latest Update Yam item was delivered to the front desk, reception area, or mail room at 8:44 am on Noverr er 18, 2022 it DENVER, CO 80202. Get More Out of LISPS 7lracidng: LISPS lbackIng Phase f'aered Delivered, Front Room DENVER, CO 80202 November 18, 2022, 8:44 am See All Trucking Hlatory Text & Email Updates USPS Decking Plus. Product Information See Less /\ 'neck Another Package I Enter tracking or barcode numbers Need More Help? Contact LISPS Tracking support for further ass€stance.. Nitps://tDols.gaps.CgmlgoffredcConfirmActloetReMullpage&tic-2&text28777=dKabetw70200090000101346409%2C 1/2 L.V. LVLK15 I , INC. F'KUOt- Oh F'UtiLICA I ION WEST FARM RESERVOIRS PERMIT # M-2022-048 AFFIDAVIT OF PUBLICATION STATE OF COLORADO COUNTY OF WELD PUBLIC NOTICE PUBLISHED NOTICE OF APPLICATION FHING FOR A REGULAR (112) CONSTRUCTION MATERIALS RECLAMATION PERMIT L.G. Eraist, Incorporated Ms flied ot *ppdedioo to obtain a Reciaaatlos Permit with tie Coloreds Mined Laid Redmond. Board ender the pro.. of. Col- orado Mined Lad Rednmtloa Aet ter the eslradisa of eeaanatfen aNeeisk This applt atisn for 472.4 meraito he iodated in the permit area. The mine b knot. as West Fees Reservoirs (Persdt 9M-21122 rd b healed in pole of Sidles 14, ail within liwaddp 3 North, Range CT Wart, eh Prim.. Meridiem, lbw. d Plat- teville, Weld County, Colorado. The pawned dale of oosasoemeat tier the which 2125 and the props. doe d ample.. 21155. The prom. Akre we d fee bad b developed wader stoop. Additlm al Worm.. and the taatative decides date so. be °btah. Asa tin D4 vision d Aeelaaaties Minlnd d Safety, 1313 Shen. St.. Ssile 215, Deaver, CO 80203, (303) 8fifi-3587,orat the Weld County Gish b the Bead's Odin at 1150 "O" Sheet, Geteley, Coloradotl0f31, or tee above -named append. nt. Comments mast be in writ* aid mast be received by the DOM. of Mierab decd Geoiop by 4:M pa. o wednmdq,iaua .y 18, 202.3. Phase nose that comments rehire/ in noise, back balk, hours of operation, wiaetua- F , effects on pea,pardy rebus end other secret er aoonomk concerns are Own not subject to this Office: jaded... Thera subject, and similar mar, err *pia* ad- d resit by your local germane., rather than the Didsiou M'Rock. A(.,1 al. E Safetyalbs bfiesd Henderson; Corm.. Published Dec.8,15,22 &29,2022 in Tke North Weld Heraidired d wdd Voice,Eiton,CO and uploaded Da.8,15,221d; 29,2022 N www pebrweedeecohsndo am ss. I, Bruce J. Bormann, of said County of Weld, being duly sworn, say that I am Publisher of THE NORTH WELD HERALD/THE CENTRAL WELD VOICE a combined weekly newspaper having a general circulation in said County and State, published in the Town of Eaton, in said County and State; and that the notice, of which the annexed is a true copy, has been published in said weekly newspaper for FOUR weeks, that the notice was published in the regular and entire issue of every number of the paper during the period and time of publication, and in the newspaper proper and not in a supplement, and that the publication of said notice: PUBUC NOTICE — VIP MINE LLC Was published in said newspaper bearing the dates of: Thursday, the 8th day of December, 2022 and Thursday, the 15th day of December, 2022 and Thursday, the 22nd day of December, 2022 and Thursday, the 29th day of December, 2022 and uploaded December 8, 15, 22 & 29, 2022 to www.publicnoticecolorado.com and that the said NORTH WELD HERALD/CENTRAL WELD VOICE 21610 5t., Suite H, Eaton, CO 80615 (970) 454-5551 northweldherald@gmail.com has been published continuously and uninterruptedly for the period of 52 consecutive weeks, in said County and State, prior to the date of first publication of said notice, and the same is a newspaper within the meaning of an Act to regulate printing of legal notices and advertisements, approved May 18, 1931, and all prior acts so far as in force. BRU E J. ORMANN, PUBLISHER Publication Cost: $252.00 Subscribed and sworn to before me this 29th day of December, 2022. OTARY PUBLIC AMANDA NICOLE HAM NOTARY PUBLIC STATE OF COLORADO NOTARY ID 20184016073 MY COMMISSION EXPIRES 4-124028 DEPARTMENT OF THE ARMY CORPS OF ENGINEERS, OMAHA DISTRICT DENVER REGULATORY OFFICE, 9307 SOUTH WADSWORTH BOULEVARD LITTLETON, COLORADO 80128-6901 May 10, 2023 SUBJECT: Regional General Permit Verification — Corps File No. NWO-2020- 01166-DEN, West Farm, Weld County, Colorado Matthew Noteboom L.G. Everist, Inc. 7321 E 88th Avenue Henderson, CO 80640 Dear Mr. Noteboom: This letter is in reference to the above -mentioned proposed project located at approximate latitude 40.225274, longitude -104.858926, in Weld County, Colorado. The work as described in your submittal consists of the discharge of fill and dredged material to fill in 2.658 acres of existing ditches and to relocate 0.433 acre of ditch C1. Based on the information that has been provided, this project meets the criteria established for the Regional General Permit (RGP) - Ditch Related Activities in the State of Colorado (RGP-5-DEN). Accordingly, for purposes of Section 404 of the Clean Water Act (33 USC 1344) and in accordance with 33 CFR 325.5(c) (1), the project is authorized provided the stipulations, conditions, mitigation requirements and other criteria of RGP 37 are satisfied. This RGP is valid until July 30, 2024. Although an Individual Department of the Army permit will not be required for this work, this does not eliminate the requirement that any other applicable Federal, state, tribal or local permits be obtained as required. Please be advised that deviations from the original plans and specifications of this project could require additional authorization from this office. The applicant is responsible for all work accomplished in accordance with the terms and conditions of the Regional General Permit. If a contractor or other authorized representative will be accomplishing the work authorized by the Regional General Permit on behalf of the applicant, it is strongly recommended that they be provided a copy of this letter and the attached conditions so that they are aware of the limitations of the Regional General Permit. Any activity which fails to comply with all the terms and conditions of the Regional General Permit will be considered unauthorized and subject to appropriate enforcement action. -2 - If there are any questions please feel free to contact Celena Cui at (303) 979-4120 or by e-mail at Celena.H.Cui@usace.army.mil, and reference Corps File No. NWO- 2020-01166-DEN. Sincerely, Kiel Downing Chief, Denver Regulatory Office Enclosure(s) cc: U.S. Fish and Wildlife Service Colorado Department of Public Health and Environment Environmental Protection Agency Colorado Parks and Wildlife Lynn Shults, L.G. Everist, Inc. DEPARTMENT OF THE ARMY CORPS OF ENGINEERS, OMAHA DISTRICT DENVER REGULATORY OFFICE, 9307 SOUTH WADSWORTH BOULEVARD LITTLETON, COLORADO 80128-6901 February 3, 2021 SUBJECT: Approved Jurisdictional Determination — Corps File No. NWO-2020- 01166-DEN, West Farm Michael Savage Savage and Savage Inc 4610 Haystack Dr. Windsor, CO 80550 Dear Mr. Savage: This letter is in reference to the property located at approximately 40.225274°N, -104.858926°W, in Weld County, Colorado. The submittal dated August 26, 2020, consists of a request for an Approved Jurisdictional Determination for the above project. The delineated area located on the subject property has been reviewed in accordance with Section 404 of the Clean Water Act under which the U.S. Army Corps of Engineers regulates the discharge of dredged and fill material, and any excavation activity associated with a dredge and fill project in waters of the United States. At your request, an Approved Jurisdictional Determination (JD), a written indication that wetlands and waterways within your project area are or are not waters of the United States has been prepared. The review area contains the following that are considered waters of the United States (WOTUS). Within the review area, the South Platte River is a Traditionally Navigable Waterway (TNW) and is therefore jurisdictional. Feature G/B and Feature C are relatively permanent tributaries to the South Platte River and are therefore jurisdictional. All other aquatic resources within the review area are not jurisdictional. The JD is attached to this letter. If you are not in agreement with the JD decision, you may request an administrative appeal under regulation 33 CFR 331, by using the attached Appeal Form and Administrative Appeal Process form. The request for appeal must be received within 60 days from the date of this letter. It is not necessary to submit a Request for Appeal if you do not object to the JD. This JD is valid for a period of five years from the date of this letter, unless new information warrants revisions of the JDs before the expiration date, or unless the Corps has identified, after a possible public notice and comment, that specific geographic areas with rapidly changing environmental conditions merit re -verification on a more frequent basis. -2 - If there are any questions please feel free to contact Nicholas Franke at (303) 979- 4120 or by e-mail at Nicholas.A.Franke@usace.army.mil, and reference Corps File No. NWO-2020-01166-DEN. Sincerely, W t7 Kiel Downing Chief, Denver Regulatory Office Enclosure(s) Approved Jurisdictional Determination (February 3, 2021) Notice of Administrative Appeal Options Administrative Appeal Process Flowchart Hello