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Home My WebLink AboutDERR-2025-004220Mayfiower Mine VCP Site Management Plan 1 SITE MANAGEMENT PLAN MAYFLOWER MINE PROPERTY UTAH VOLUNTARY CLEANUP PROGRAM FACILITY ID C090 PREPARED FOR: BLX UTAH LLC 9109 NORTH MAYFLOWER VILLAGE DRIVE PARK CITY UTAH 84098 May 23, 2025 REVISIONS TO FINAL APPROVED SITE MANAGEMENT PLAN Revision No. Date Submitted Summary of Revision DERR Approval Date Mayfiower Mine VCP Site Management Plan 2 Contents 1. INTRODUCTION ................................................................................................................... 4 1.1 Site Description .......................................................................................................... 4 1.2 Project Background ..................................................................................................... 4 1.3 Remedial Actions ........................................................................................................ 5 2. WATER MONITORING PLAN ................................................................................................. 6 2.1 Sampling Procedure.................................................................................................... 6 2.2 Screening Levels ......................................................................................................... 7 2.3 Quality Assurance and Quality Control ....................................................................... 8 2.4 Chain-of-Custody Documentation .............................................................................. 9 3. SITE MANAGEMENT ......................................................................................................... 9 3.1 Environmental Covenant ............................................................................................ 9 A. Waste Rock Repository ................................................................................................. 9 B. Railroad Grade Lens of Impacted Soils .......................................................................... 9 C. Mine Portal Area ......................................................................................................... 10 3.3 Inspection and Maintenance Items ........................................................................... 10 A. Railroad Grade Lens of Impacted Soils ........................................................................ 10 B. Glencoe Canyon Sediment Retention Pond ................................................................. 10 C. Big Dutch Pete Hollow Subsurface Water Cut Off Wall ................................................. 11 D. Big Dutch Pete Hollow Spring Water Collection and Pipeline ........................................ 12 E. Big Dutch Pete Hollow Stormwater Detention Pond Relocation .................................... 13 F. Mayflower Mine Portal Water Diversion ....................................................................... 13 G. Wetland Replacement ................................................................................................ 14 H. Waste Rock Repository ............................................................................................... 14 I. Property Line Sump and Extraction Well ...................................................................... 15 J. Legacy Mining Era Pond .............................................................................................. 16 K. Mine Portal Area ......................................................................................................... 17 3.4 Contingency Plan ...................................................................................................... 17 3.5 Notification ............................................................................................................... 17 4. INSPECTION & MAINTENANCE CHECKLISTS ................................................................ 18 5. REFERENCES ................................................................................................................ 22 Mayfiower Mine VCP Site Management Plan 3 Exhibit A – Site Location Map .................................................................................................... 23 Exhibit B – Greenspace Cover and Hard Surface Cover ............................................................ 24 Exhibit C – Map #4 from the Remedial Action Report ................................................................ 25 Exhibit D – Map #2 from the Remedial Action Report ................................................................ 26 Exhibit E – Map #3 from the Remedial Action Report ................................................................ 27 Exhibit F – Map #1 from the Remedial Action Report ................................................................ 28 List of Acronyms BLXM BLX Mayfiower LLC COC Contaminant of Concern DERR Division of Environmental Remediation and Response DRO Diesel Range Organics DWQ Division of Water Quality EC Environmental Covenant NOV Notice of Violation RAP Remedial Action Plan RAR Remedial Action Report SMP Site Management Plan TPH Total Petroleum Hydrocarbons UDEQ Utah Department of Environmental Quality USACE United States Army Corps of Engineers VCP Voluntary Cleanup Program Mayfiower Mine VCP Site Management Plan 4 1. INTRODUCTION 1.1 Site Description The subject property (“Site”) is approximately 451.135 acres in size and is located along the west side of U.S. Highway 40, south of the Mayfiower highway exit in Wasatch County, Utah. An orthophoto base site location map is included in Exhibit A. 1.2 Project Background The Site includes the historical Mayfiower Mine. The mine and parts of the surrounding area were impacted by historic mining activities that began in 1873 and occurred periodically through the early 1980’s. These mining activities resulted in contaminated soils, water, and sediments in and around the Site. Stichting Mayfiower Recreational Fonds (“Stichting”) purchased the Site and surrounding properties in the 1970s with the intention to redevelop the area. Stichting was issued a Ground Water Quality Discharge Permit (No. UGW520002) (“Permit”) by the Utah Department of Environmental Quality, Division of Water Quality (“DWQ”) in 1993. In August of 1995, the Utah Water Quality Board issued a Notice of Violation (“NOV”) and Consent Order in response to elevated concentrations of total dissolved solids in the groundwater downgradient of the Site and a release from the tailings ponds on the east side of U.S. Highway 40 due to stormwater discharges. Stichting’s response to the NOV did not satisfactorily address DWQ’s concerns, and accordingly, the Permit was not reissued upon its expiration in December 1998. In 2003, Stichting and DWQ entered into a Final Amended Stipulation and Consent Order (“Consent Order”) to address the violations identifled in the NOV. Stichting submitted to DWQ a Plan for Reclamation of the Mayfiower Mine and Adjacent Areas in 2014 to address the environmental impacts associated with historic mining activities on its property and to resolve the Consent Order. DWQ approved the plan in April of 2015, and stated that it superseded the 1995 NOV and 2003 Consent Order, and that completion of the proposed reclamation activities would satisfy the obligations set forth in the Consent Order. In October of 2016, BLX Mayfiower LLC (“BLXM”) purchased the property from Stichting. As part of the purchase agreement, BLXM agreed to assume the responsibility for the obligations under the Consent Order for the Site. Because the remediation as set forth in the 2014 reclamation plan did not contemplate residential and commercial development, BLXM put the Site into the Utah Department of Environmental Quality’s (“UDEQ’s”) Voluntary Cleanup Program (“VCP”) administered by the Division of Environmental Response and Remediation (“DERR”) to remediate the property to a level that would accommodate residential and commercial use. Under the VCP, BLXM agreed to complete a site characterization report, propose a remedial action plan, and complete the cleanup under the guidance of DERR. Mayfiower Mine VCP Site Management Plan 5 1.3 Remedial Actions BLXM and its consultants prepared, and DERR approved, a Remedial Action Plan (“RAP”) in May 2019, which set forth the procedures to be used to remediate the contaminated soil, sediment, and surface water at the Site. The Contaminants of Concern (“COCs”) identifled included arsenic and lead in topsoil; arsenic, cadmium, copper, lead, and TPH-DRO in subsurface soil; arsenic, cadmium, copper, lead, nickel, and zinc in sediment; cadmium, copper, iron, lead, and zinc in surface water; and TPH-DRO in groundwater. The work as described in the RAP commenced in August 2019 and was completed in 2024, which included the following: • Capping of impacted soils: Soils and sediments from across the Site with impacts exceeding site-speciflc cleanup levels were gathered and consolidated in an onsite repository, located within the footprint of the former mine’s waste rock area (the “Repository”). The Repository has been capped with an engineered cover to prevent migration and potential leaching of the encapsulated materials. • Confirmation soil sampling: BLXM and its consultants collected soil samples for laboratory analyses to document concentrations of any remaining COCs. Where levels exceeded the cleanup objectives set forth in Section 4.2 of the RAP, the extent of contamination was deflned and excavated, with the additional removed soils moved to the Repository. During excavation activities in and around Lower McHenry Canyon, a small lens of impacted soils was identifled as being unable to be excavated due to the potential undermining of the elevated road under which it was located. DERR approved a Contingency Request in February 2020 to allow a small localized lens of contaminated materials to be left in place. As implementation of the RAP progressed, it also became apparent that unanticipated surface water and groundwater were inflltrating and compromising the integrity of the Repository area and associated cap. In response, BLXM developed additional water management strategies that separated surface water and groundwater from the waste rock, as further described in the Supplemental RAP Activities to Address Water Inflltration and Management document. All cleanup objectives of the RAP have been satisfled as demonstrated in the Remedial Action Report (“RAR”). This Site Management Plan (“SMP”) outlines the surface water and groundwater monitoring requirements, as well as the monitoring and maintenance requirements for the protective cap installed atop the Repository, the discrete location of the lens of impacted soils remaining in place, and the water management objectives to ensure the integrity of the waste rock Repository and cap. 1.4 Implementation of this SMP Implementation of this SMP will be the responsibility of the Mountainside Master Association (“Master HOA”) pursuant to the Master Declaration of Covenants, Conditions, Restrictions and Mayfiower Mine VCP Site Management Plan 6 Easements for Mountainside village and Resort, dated August 20, 2020, and recorded in the Wasatch County Recorder’s Office on August 21, 2020, at bk 1308, pg 27-142, that covers the Site. The Master HOA may impose assessments to cover the costs of implementation of this SMP. This SMP may be amended from time to time if proposed by the Master HOA and accepted by DERR. The Master HOA shall also be responsible for the performance of annual site-wide inspections of the Mayfiower VCP area. The Master HOA shall also be responsible for notifying DERR (801-536- 4100) at least 10 days in advance of each annual inspection to allow a DERR representative to be present during the inspection, as applicable. Modiflcation to the frequency of the inspections will require approval from DERR. All inspections shall be documented on the form contained in Section 4 of this SMP or an equivalent form. Site-wide inspections shall also be performed in the event of an emergency (e.g., flre, natural disaster, or other unforeseen events or disturbances) that may have affected any of the remedial actions. The Master HOA shall give verbal notice to DERR within 24 hours if such an emergency occurs that reduces or has the potential to reduce the effectiveness of the remedial actions completed at the Site. If such an emergency event occurs, an inspection of the Site, using the form contained in Section 4 or an equivalent, shall be conducted within 5 days of the event to verify the continued effectiveness of the remedial actions completed at the Site. Written conflrmation of such an inspection shall be provided to DERR within 5 days of the inspection. This conflrmation shall include a summary of actions taken, or to be taken, and the potential impact of the event on the public. The results of all inspections (whether routine or in response to an emergency) shall be provided within 10 business days of the inspection to the following: Utah Division of Environmental Response and Remediation Voluntary Cleanup Program 195 North 1950 West P.O. Box 144840 Salt Lake City, UT 84114-4840 2. WATER MONITORING PLAN 2.1 Sampling Procedure Surface water quality sampling for total metals shall be conducted at the McHenry Campground sampling point (4997675) on a monthly basis through May 2026. Monthly samples shall be analyzed for zinc and cadmium by EPA Method 200.8, and iron by EPA Method 200.7. Thereafter, water quality sampling shall be conducted at the same sampling location twice annually – with one sample collected and analyzed in late April or early May, to coincide with the approximate peak of the runoff season, and one sample collected and analyzed in the Fall, in early October – through October 2031. These semi-annual samples shall be analyzed for the following metals, using the analytical methods identifled herein: arsenic, barium, cadmium, chromium, copper, iron, lead, Mayfiower Mine VCP Site Management Plan 7 mercury, selenium, silver, and zinc. During all surface water sampling, turbidity will be measured with a properly calibrated meter in the fleld and reported using the NTU scale. If any sampling result exceeds the applicable levels set forth below in Table 1, a secondary water sample will be collected and sent for testing within one day of receipt of the initial water quality analysis with an expedited (typically 24 hour) turnaround time for laboratory analysis. If this conflrmatory sample still exceeds any of the applicable levels, water shall be pumped from the Property Line Sump as soon as possible, but in no event later than 4 days after receipt of the sample results, to mitigate impacts. All water pumped from the Property Line Sump will be properly disposed and DERR shall be consulted regarding next steps and follow-up actions. If the conflrmatory sample does not exceed any of the applicable levels, a third water sample shall be collected and sent for expedited laboratory analysis within three business days of receipt of the secondary water quality analysis. If this third sample exceeds any of the applicable levels, water shall be pumped from the Property Line Sump as soon as possible, but in no event later than 4 days from receipt of the sample results, and DERR will be consulted regarding next steps and follow-up actions. If the third sample still does not exceed any of the applicable levels, no further follow-up action is required, and sampling shall continue per this SMP. Groundwater quality sampling for dissolved metals shall be conducted annually from the Property Line Sump, GW-2 and GW-4 through October 2031, and will be conducted in late May/early June to coincide with the end of the spring runoff each year. Sampling shall follow approved sampling procedures and analytical results shall be compared to screening levels in Table 1. Piezometers (GW-6, GW-8, and GW-9a) in the Repository shall be measured for water levels every two weeks during the Spring months of March, April, and May. During the Fall, in October, a water level measure will be taken during surface water sampling activity. The water level information shall be used to help evaluate the wave of water that can often be observed (with water levels collected from the piezometers on a seasonal basis) in the Repository and how this may impact the remedy. At the end of 2031, DERR shall be consulted to evaluate whether the Supplemental RAP Activities to Address Water Inflltration and Management (Appendix I of the Remedial Action Report) are effective as planned, and whether additional sampling and analysis for water quality is warranted moving forward. If the results continue to be below screening levels, the Master HOA may petition DERR to discontinue water monitoring. A report shall be submitted after each sampling event, following the established reporting format for the project. 2.2 Screening Levels Table 1 provides the regulatory standards for which the water samples shall be analyzed. Mayfiower Mine VCP Site Management Plan 8 Table 1 – Screening Levels Analyte Surface Water Screening Level (mg/L) Analytical Testing Method for Surface Water Groundwater Screening Levels (mg/L) Analytical Testing Method for Groundwater Arsenic 0.010 EPA Method 200.8 0.010 EPA Method 6020 Barium 1.0 EPA Method 200.7 2.0 EPA Method 6010 Cadmium 0.00239 EPA Method 200.8 0.005 EPA Method 6020 Chromium 0.268 EPA Method 200.8 0.1 EPA Method 6010 Copper 0.0305 EPA Method 200.8 1.3 EPA Method 6010 Iron 1.0 EPA Method 200.7 14.0 EPA Method 6010 Lead 0.0186 EPA Method 200.8 0.015 EPA Method 6020 Mercury 0.0000121 EPA Method 245.1 0.002 EPA Method 7470 Selenium 0.0046 EPA Method 200.8 0.05 EPA Method 6020 Silver 0.0411 EPA Method 200.8 0.10 EPA Method 6010 Zinc 0.388 EPA Method 200.8 5.0 EPA Method 6010 2.3 Quality Assurance and Quality Control Sample collection and analysis procedures shall follow the QAPP referenced in the Remedial Action Plan for the Site. Laboratory analysis of water samples shall be performed by a lab certifled by the National Environmental Lab Accreditation Program and United States Environmental Protection Agency quality control standards will be met for all samples. All laboratory analytical reports will include Level 3 documentation, including a Case Narrative. On a frequency of one for every flve sampling events, a fleld duplicate sample shall be collected for analysis. One Field Blank shall be collected during the sampling program to assess potential sample contamination due to sample bottles, preservative, ambient site conditions, or cross-contamination during transport. The fleld duplicate will be collected closely in time and location to the actual sample and will be placed in an identical sample container flxed with nitric acid (HNO3). The duplicate sample will be handled in the same way as the other samples and will be secured in the same cooler for laboratory 1 Due to the limits of the analytical method results can only be reported down to 0.00015 mg/L. Mayfiower Mine VCP Site Management Plan 9 analysis. The fleld duplicate will measure the additive effects of fleld precision (i.e. sample collection, handling, and transportation) and lab precision (such as sample handling and analysis). 2.4 Chain-of-Custody Documentation All samples submitted for laboratory analysis will be accompanied by completed Chain-of-Custody forms. Forms will be completed and submitted with the samples to the laboratory during each sampling event. The Chain-of-Custody will identify the contents of each shipment and maintain the custodial integrity of the samples. Samples will be in the custody of the sampler, locked up, or kept in a secured area that is restricted to authorized personnel. Samples will remain in the custody of the sampler until released to the lab. Upon arrival at the lab, the sampler will sign the Chain-of-Custody form in the “relinquished by” box and note date and time. 3. SITE MANAGEMENT 3.1 Environmental Covenant An Environmental Covenant (“EC”) will be prepared consistent with this SMP after approval by DERR, outlining the continuing obligations and limitations associated with impacts remaining at three speciflc locations within the Site. The three locations are (1) the railroad grade lens of impacted material, (2) the waste rock repository, and (3) the mine portal area. The EC will be recorded on the Site’s title. If any disturbance of these three locations is necessary, a work plan will be submitted to DERR prior to any land disturbance covered by the Environmental Covenant. Such work plan must be reviewed and approved by DERR prior to any land disturbance activity. 3.2 Land Use Limitations A. Waste Rock Repository The waste rock Repository shall be limited to use as a repository. This area shall not be used or developed for use other than as a repository without amendment to the EC. The Repository cap includes various protective cover types tailored to different sections of the area, including a hard surface cover (asphalt) and a green space cover for planted areas. The cap thickness is described in the RAR, speciflcally in Appendix J. The Repository cap shall not be disturbed or breached other than pursuant to a work plan approved by DERR prior to any disturbance of the cap. The hard surface cover and greenspace cover cap areas are depicted in Exhibit B. B. Railroad Grade Lens of Impacted Soils The lens of impacted soil shall not be disturbed or excavated. If soil removal is required in or around the lens of impacted soil, a work plan must be submitted to DERR for review and approval prior to any earthwork being done in the area. Mayfiower Mine VCP Site Management Plan 10 C. Mine Portal Area The mine portal area contains naturally occurring mineralization in both the bedrock and soils surrounding the historic portal. If any disturbance of this area, or the demarcation fabric placed over the top of the portal is planned, a work plan is required to be submitted to DERR for review and approval prior to any disturbance of the portal area. 3.3 Inspection and Maintenance Items The following features require an inspection at least annually during the third quarter, or at an additional frequency specifled below, to ensure they are functioning as intended and are not compromising the completed remedial activities at the Site. Additional maintenance and repair activities may be required, as specifled in the Maintenance Items Checklist, to ensure their functionality. A comprehensive inspection checklist for the following items is included in Section 4 of this SMP. A. Railroad Grade Lens of Impacted Soils The lens of impacted soils left in place is depicted on the map attached hereto as Exhibit C, Map #4. An orange demarcation layer has been placed directly atop the contaminated soils, and several feet of soil was placed on top as an earthen cap. This area is subject to the Environmental Covenant as described above, and a work plan is required to be submitted to DERR for review and approval prior to any disturbance of the lens area. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Soil erosion or disturbance o Evidence of excavation in the immediate area o Evidence of the soil cap being disturbed or removed Maintenance • Maintain earthen cap which protects impacted soils • Maintain orange warning demarcation fabric Restoration and Repairs • As necessary, perform the following tasks: o Repair cap with imported clean material o Replace any lost or displaced topsoil o Hydroseed with the upland seed mix referenced in the Remedial Action Plan o Ensure orange warning demarcation layer is left in place B. Glencoe Canyon Sediment Retention Pond The Glencoe Canyon Sediment Retention Pond is designed to allow sediment-laden water to pond, with sediments settling out of suspension. This will protect the lower McHenry Canyon from the Mayfiower Mine VCP Site Management Plan 11 potential impact of legacy mining materials that could migrate during spring runoff or other high stream fiow conditions, preventing them from entering the remediated area of McHenry Canyon. The Sediment Retention Pond is depicted on the map attached hereto as Exhibit C, Map #4. In the event that dredging is needed in the Sediment Retention Pond to maintain 2’ of freeboard from the bottom of the outlet structure, the dredged material will be consolidated and placed on a liner to allow the sediment material to dry. Appropriate controls will be implemented to prevent windblown materials such as a plastic cover. A representative sampling plan using an XRF will be prepared and implemented with DERR oversight to conflrm the sediments do not exceed Remedial Action Plan cleanup levels of 500 mg/kg for lead and 100 mg/kg for arsenic. The representative sampling plan will include requirements for disposal of any soil that exceeds these regulatory clean-up levels. Inspection Checklist • Frequency of inspection – annual, and in the case of a 100-year storm event • Inspect area for the following: o Outlet structure – check for debris impacting the grated outlet o Verify minimum freeboard of 2’ from the bottom of the grated water outlet to the sediment retention layer Maintenance • Clear debris from outlet grate • Remove sediments from pond to maintain minimum freeboard of 2’ from the bottom of the grated water outlet to the sediment retention layer to allow sediment to drop out of suspension and maintain outfiow water quality Restoration and Repairs • As necessary, perform the following tasks: o Clear debris from outlet grate o Remove sediments from pond to maintain minimum freeboard of 2’ from the bottom of the grated water outlet to the sediment retention layer to allow sediment to drop out of suspension and maintain outfiow water quality o Rebuild or repair pond if damaged by fiooding C. Big Dutch Pete Hollow Subsurface Water Cut Off Wall The Big Dutch Pete Hollow subsurface water collection system was designed and constructed to capture subsurface water that was migrating into the waste rock area. The "cutoff wall" is located approximately 850’ upstream from the waste rock repository boundary. The collected water is transported through an 18" HDPE pipe to the Big Dutch Pete Hollow storm drain detention pond and eventually offsite to the Jordanelle Reservoir. There are a total of three surface inlets that capture water from the surface and transport it through the 18" pipeline to the storm water detention pond. The Big Dutch Pete Hollow cut off wall is depicted on the map attached hereto as Exhibit D, Map #2. Inspection Checklist • Frequency of inspection – annual, and in the case of a 100-year storm event Mayfiower Mine VCP Site Management Plan 12 • Inspect area for the following: o Inspect surface inlets for proper function o Inspect water bars on the adjacent ski run to prevent water fiow from steep slopes eroding into the collection system o Visually inspect to verify that the collection system is collecting water o Inspect the discharge of the pipeline at the storm drain detention pond to ensure water is passing through the pipeline and ensure there is not a signiflcant difference in fiow between the inlet and the outlet Maintenance • Clear debris from inlet grate • Inspect rock check dams for proper function • Visually inspect for soil erosion that could impact the surface inlets and lead to sediment in the pipeline • Camera inspect the pipeline if there is evidence of debris or sediment blockages Restoration and Repairs • As necessary, perform the following tasks: o Clear debris from inlet grate o Reconstruct rock check dams for erosion control in the stream channel if damaged o Remove sediment from the stream channel that is adversely impacting the system's functionality o Flush the pipeline with a water truck or high-pressure jet hose if sediment has built up in the pipeline o Reshape the water bars and remove sediment using an excavator to resolve malfunctions D. Big Dutch Pete Hollow Spring Water Collection and Pipeline A historic spring water source approximately 1500’ up the canyon southwest of the Repository, initially improved by miners several decades ago, had deteriorated over time. To restore its functionality, a new subsurface collection system was installed, incorporating perforated pipe and coarse free-drain gravel to efficiently capture and direct the spring water into a collection box and pipeline. The collected water is diverted through a newly installed 6-inch HDPE pipeline, which routes it around the waste rock Repository and into the reclaimed wetland area. Additionally, a diversion box with fiow control was implemented to regulate water fiow and allow for necessary maintenance when required. The spring water collection system, speciflcally the diversion box and pipeline, are depicted on the map attached hereto as Exhibit E, Map #3. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Verify that water is fiowing out of the end of the pipeline, and compare the volume of outfiow to the volume exiting the diversion box Mayfiower Mine VCP Site Management Plan 13 o Inspect the collection box for damage o Inspect the diversion box for proper functionality o Inspect the pipeline right-of-way for signs of damage o Inspect the area for signs of water escaping the collection system Maintenance • Make necessary repairs to ensure water is collected and diverted into pipeline Restoration and Repairs • As necessary, perform the following task: o Make necessary repairs to ensure water is collected and diverted into pipeline E. Big Dutch Pete Hollow Stormwater Detention Pond Relocation The Big Dutch Pete Hollow Stormwater Detention Pond was relocated 300’ above the waste rock Repository boundary, signiflcantly enhancing protection against runoff water during storms. This relocation, along with the pond’s outfiow structure and pipeline, helps divert water away from the waste rock pile. A low permeability clay barrier was also installed between the detention pond and the Repository boundary. The detention pond is depicted on the map attached hereto as Exhibit F, Map #1. Inspection Checklist • Frequency of inspection – annual, and in the case of a 100-year storm event • Inspect area for the following: o Inspect the outfiow structure for debris and blockages Maintenance • Arrange for clearing of debris, sediment, and blockages from outlet structure and pond and provide documentation to DERR that clearing has occurred F. Mayfiower Mine Portal Water Diversion The Mayfiower Mine Portal continuously discharges water at a fiow rate of 0.4–0.6 CFS, with temporary increases during snowmelt. To prevent contact with the waste rock Repository and support construction activities for mitigating contaminated soils and waste rock, the water fiow was redirected away from the waste rock pile. An 18-inch HDPE pipeline was installed to effectively convey the water away from the waste rock Repository. The mine portal and route of water is depicted on the map attached hereto as Exhibit F, Map #1. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Inspect manhole covers for damage and proper flt o Open manhole covers and visually inspect for fiowing water o Inspect the pipeline for damage and signs of leakage Mayfiower Mine VCP Site Management Plan 14 o Inspect the pipeline right-of-way for evidence of excavation or disturbances that could cause damage to the pipeline o Verify water is discharging from the end of the pipe at volumes at least consistent with 0.4-0.6 CFS Maintenance • 10-year camera inspection of the pipeline to ensure the integrity of the system Restoration and Repairs • As necessary, perform the following tasks: o Replace damaged manhole covers o Replace damaged manholes o Repair damaged pipelines G. Wetland Replacement The VCP project involved the relocation of an established wetland area. A plan was submitted to the U.S. Army Corps of Engineers (“USACE”), and a Nationwide 404 Permit was acquired to perform the work. The relocated wetland was replaced at a 1:1 ratio. The source of water used to feed the wetland is the Big Dutch Pete Hollow Spring. The reestablished wetland area is depicted on the map attached hereto as Exhibit F, Map #1. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Inspect the outfiow for debris and blockages o Inspect for water infiow into the wetland area Maintenance • Remove debris or blockages from outfiow • Maintain fiow of water to wetland area Restoration and Repairs • As necessary, perform the following tasks: o Remove debris or blockages from outfiow o Maintain fiow of water to wetland area H. Waste Rock Repository The Repository is protected from stormwater intrusion by two types of cap design. The majority of the Repository is covered with a minimum of 24” of granular material topped with an asphalt cap. The remainder of the area is covered with a GCL liner and a minimum of 22” of granular material topped with 6” of topsoil and greenspace and/or desert scape plantings. These areas are shown in the typical drawings in the Kimley-Horn Figures in the Remedial Action Report. An aerial view of the Repository is depicted on the map attached hereto as Exhibit F, Map #1. Mayfiower Mine VCP Site Management Plan 15 Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Inspect asphalt for shrinkage around the perimeter, especially next to the concrete curb and light pole bases o Inspect asphalt for cracks and deterioration or other unauthorized intrusions into the repository cap ▪ Confirm proper procedures followed under the Site Management Plan for intrusions into the repository cap as stated in Section 3.2 o Inspect the asphalt area for settlement to avoid ponding of water, and as an indication that water could be migrating into the subsurface of the Repository. o Inspect greenspace area for soil rills or damage o Inspect drainage outlet pipe in greenspace cover area (x3 pipes) o Confirm 50-foot lateral buffer from buildings next to repository boundary unless otherwise approved by DERR on a case-by-case basis o Confirm no deep-rooted plants in greenspace cover o Storm drains free from debris and confirm no other obvious signs of stormwater system failure o Confirm piezometers GW-6, GW-8, and GW-9a remain undisturbed and are accessible Maintenance (Further deflned Section 4 – Scheduled Maintenance Item Checklist) • 2” mill of asphalt and overlay of the asphalt surface required every 12 years • Asphalt cracks must be sealed annually • Asphalt surface must be sealed every 3 years • Areas of settlement must be removed and replaced as needed to ensure the integrity of the cap • Replant greenspace area as needed Restoration and Repairs • As necessary, perform the following tasks: o 2” mill of asphalt and overlay of the asphalt surface required every 12 years o Asphalt cracks must be sealed annually o Asphalt surface must be sealed every 3 years o Areas of settlement as deflned above must be removed and replaced as needed to ensure the integrity of the cap o Replant greenspace area as needed I. Property Line Sump and Extraction Well Subsurface water fiowing from Big Dutch Pete Hollow and beneath the waste rock Repository required a system to manage the underground water and monitor its quality before it leaves the Site. To address this, a water collection system with a sump area was installed, featuring a well Mayfiower Mine VCP Site Management Plan 16 casing for drawing water samples. Additionally, an inspection port was integrated into the existing outfiow culvert, enabling camera inspections to monitor water fiow as it exits the Site. The sump and extraction well are depicted on the map attached hereto as Exhibit F, Map #1. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Access to the inspection port site should be provided year-round o The inspection port should be inspected for accessibility o The property line sump well casing should be inspected for accessibility Maintenance • Maintain the access road to the inspection port site (other than during winter conditions) • Maintain the well casings for the sump extraction and inspection wells • Test the electrical function of the pump and conflrm availability of discharge piping equipment • 10-year camera inspection of the pipeline to ensure the integrity of the system Restoration and Repairs • As necessary, perform the following tasks: o Maintain the access road to the inspection port site (other than during winter conditions) o Maintain the well casings for the sump extraction and inspection wells J. Legacy Mining Era Pond A legacy man-made mining pond was discovered to be a source of water inflltrating the waste rock repository. The pond was breached and infllled with clay and impervious materials. The outfiow valve and pipeline from the pond was terminated. Any naturally occurring water in the former pond area was directed to the nearby storm drain collection system. The legacy mining era pond is depicted on the map attached hereto as Exhibit D, Map #2. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Verify site is undisturbed and the storm drain system is functional Maintenance • Repair any disturbance of the area Restoration and Repairs • Repair any disturbance of the area Mayfiower Mine VCP Site Management Plan 17 K. Mine Portal Area The mine portal area contains naturally occurring mineralization in both the bedrock and soils. Remediation efforts included the removal of contaminated soils from past operations but were halted at the bedrock face of the portal. The surrounding area was cleared, tested, and documented as a clean soil area. A demarcation fabric was placed over the mine portal opening and covered with soil. The mine portal area is depicted on the map attached hereto as Exhibit F, Map #1. This area is subject to the Environmental Covenant as described above, and a work plan is required to be submitted to DERR for review and approval prior to any disturbance of the portal area. Inspection Checklist • Frequency of inspection – annual • Inspect area for the following: o Inspect to verify site is undisturbed o Inspect to conflrm clean flll or other cover, such as a building or other structure, remains in place to protect the area Maintenance • Maintain appropriate cover of the area Restoration and Repairs • Repair and/or replace any disturbed earthen cap materials or other cover 3.4 Contingency Plan If unforeseen events occur at the Site that would impact the effectiveness of the remedy in the remedial action plan and/or the Remedial Action Report, DERR will be notifled, and a contingency plan will be developed in consultation with DERR. Similarly, if unexpected contamination is encountered at the Site during any work, such as legacy mining operations or impacts, DERR will be notifled, and a contingency plan will be developed in consultation with DERR to address the situation. 3.5 Notification DERR shall be notifled by phone at (801) 536-4100 or in writing to the address noted below prior to any excavation into impacted soils covered by the EC. In addition to the SMP requirements, site activities must comply with appropriate permitting authorities. Project Manager, VCP ID# C090 Voluntary Cleanup/Brownflelds Section Division of Environmental Response and Remediation Utah Department of Environmental Quality P.O. Box 144840 Salt Lake City, Utah 84114-4840 Mayfiower Mine VCP Site Management Plan 18 4. INSPECTION & MAINTENANCE CHECKLISTS A. Annual Inspection Checklist Inspection Item Inspection Result Follow-Up Needed Railroad Grade Lens of Impacted Soils Soil erosion or disturbance ☐ Yes ☐ No Evidence of excavation in immediate area ☐ Yes ☐ No Evidence of soil cap removed or disturbed ☐ Yes ☐ No Glencoe Canyon Sediment Retention Pond Debris impacting grated outlet ☐ Yes ☐ No Minimum freeboard of 2’ from bottom of grated outlet to sediment retention layer ☐ Yes ☐ No Big Dutch Pete Hollow Subsurface Water Cut Off Wall Proper function of surface inlets ☐ Yes ☐ No Proper function of water bars on upgradient mountain slope ☐ Yes ☐ No Collection system is collecting water ☐ Yes ☐ No Water fiowing from pipeline discharge at storm drain detention pond at same volume as inlets ☐ Yes ☐ No Big Dutch Pete Hollow Spring Water Collection and Pipeline Water free fiowing from end of pipeline at same volume as diversion box ☐ Yes ☐ No Damage to collection box ☐ Yes ☐ No Proper function of diversion box ☐ Yes ☐ No Signs of damage in pipeline right-of-way ☐ Yes ☐ No Signs of water escaping collection system ☐ Yes ☐ No Big Dutch Pete Hollow Stormwater Detention Pond Relocation Debris, sediment, or blockages impacting outfiow structure ☐ Yes ☐ No Mayfiower Mine VCP Site Management Plan 19 Inspection Item Inspection Result Follow-Up Needed Mayflower Mine Portal Water Diversion Damage to and/or improper flt of manhole covers ☐ Yes ☐ No Flowing water remains visible via open manhole covers ☐ Yes ☐ No Damage to or signs of leakage from pipeline ☐ Yes ☐ No Signs of damage within the pipeline right-of- way ☐ Yes ☐ No Water fiowing from end of pipeline at volume of at least 0.4-0.6 CFS ☐ Yes ☐ No Wetland Replacement Outfiow free of debris and blockages ☐ Yes ☐ No Water fiowing into wetland area ☐ Yes ☐ No Waste Rock Repository Shrinkage of asphalt around the perimeter of the cap, especially adjacent to concrete curbing and light pole bases ☐ Yes ☐ No Cracks in or deterioration of asphalt ☐ Yes ☐ No Settlement within asphalt area ☐ Yes ☐ No Soil rills or damage to greenspace area ☐ Yes ☐ No Drainage outlet pipes in greenspace cover area functioning properly ☐ Yes ☐ No 50’ lateral buffer remains between Repository boundary and surrounding buildings, unless otherwise approved by DERR ☐ Yes ☐ No Any deep-rooted plants in greenspace cover ☐ Yes ☐ No Storm drains remain free of debris and no signs of stormwater system failure ☐ Yes ☐ No Evidence of unauthorized intrusions into the cover ☐ Yes ☐ No Mayfiower Mine VCP Site Management Plan 20 Inspection Item Inspection Result Follow-Up Needed Piezometers GW-6, GW-8, and GW-9a remain undisturbed and are accessible ☐ Yes ☐ No Property Line Sump and Extraction Well Access to Property Line Sump and Inspection Port site is clear ☐ Yes ☐ No Property Line Sump is functional ☐ Yes ☐ No Inspection Port is functional ☐ Yes ☐ No Legacy Mining Era Pond Site is undisturbed and storm drain system functioning properly ☐ Yes ☐ No Mine Portal Area Site remains undisturbed ☐ Yes ☐ No Conflrm clean flll or other acceptable cover remains in place ☐ Yes ☐ No Any other observations on the Site that could indicate or cause a problem with the remedy Mayfiower Mine VCP Site Management Plan 21 B. Scheduled Maintenance Items Checklist – Beginning date to determine maintenance item frequency is 2023 Maintenance Item Frequency Maintenance Current? Notes Waste Rock Repository Sealing of asphalt cracks Annually ☐ Yes ☐ No Sealing of asphalt surface Every 3 years ☐ Yes ☐ No 2” mill of asphalt and overlay of asphalt surface Every 12 years ☐ Yes ☐ No Mayflower Mine Portal Water Diversion Camera inspection of the pipeline to ensure system integrity Every 10 years ☐ Yes ☐ No Property Line Sump and Inspection Port Camera inspection of the Property Line Sump and Inspection Port Every 10 years ☐ Yes ☐ No Mayfiower Mine VCP Site Management Plan 22 5. REFERENCES Supplemental RAP Activities to Address Water Inflltration and Management (BLX Mayfiower LLC 2025) Remedial Action Plan, Mayfiower Mine VCP Site #C090, Proposed Phase I Development (BARR 2019). Remedial Action Report, Mayfiower Mine VCP Site #C090 (RMEC 2025). Mayfiower Mine VCP Site Management Plan 23 Exhibit A – Site Location Map CLIENT: PROJECT PROFESSIONAL LAND SURVEYING AND CONSULTING 435-640-4200 463 SCENIC HEIGHTS ROAD, FRANCIS, UTAH 84036 DATE STAFF SHEET OF LEGAL DESCRIPTION A parcel of land located in Section 25, Township 2 South, Range 4 East, Salt Lake Base and Meridian, Wasatch County, State of Utah, said parcel of land being more particularly described as follows: BEGINNING AT A POINT, said point being the north quarter corner of Section 25, Township 2 South, Range 4 East, Salt Lake Base and Meridian (Basis of Bearing for the herein described parcel being South 26°11'47" East 5917.16 feet from the North Quarter Corner of Section 25, to the Southeast Corner of Section 25, the North Quarter Corner also being North 89°57'12" West 2633.77 feet from the Northeast Corner of said Section 25, See Record of Survey Maps 2647, 3058 & 3759 on file with the Wasatch County Surveyor's office for said Section 25 retracement and the Mayflower LDP coordinate system projection parameters); and running thence coincident with the section line South 89°57'12" East 373.89 feet to a point on the westerly right of way of US HWY 40; thence coincident with the right of way of US HWY 40 the following twenty-one (21) courses, 1) South 31°31'07" East 76.73 feet to a point on a curve to the left having a radius of 2984.79 feet, of which the radius point bears North 58°28'53" East; thence 2) along the arc of said curve 648.58 feet through a central angle of 12°27'00"; thence 3) South 43°58'07" East 177.72 feet; thence 4) South 38°30'49" East 279.61 feet; thence 5) South 24°58'07" East 218.13 feet; thence 6) South 10°49'13" East 221.70 feet; thence 7) South 46°11'55" East 208.95 feet; thence 8) South 30°58'07" East 232.72 feet to a point on a curve to the right having a radius of 5629.58 feet, of which the radius point bears South 59°01'53" West; thence 9) along the arc of said curve 393.02 feet through a central angle of 04°00'00"; thence 10) South 26°58'07" East 373.69 feet; thence 11) South 08°18'07" West 271.52 feet; thence 12) South 19°15'58" East 206.82 feet; thence 13) South 55°00'19" West 135.40 feet; thence 14) South 76°01'53" West 128.96 feet; thence 15) South 84°32'35" West 202.92 feet; thence 16) North 75°58'07" West 132.05 feet; thence 17) South 14°01'53" West 150.00 feet; thence 18) South 55°13'48" East 141.20 feet; thence 19) North 88°11'09" East 651.65 feet; thence 20) South 18°47'08" East 632.92 feet; thence 21) South 50°47'53" East 453.10 feet to the easterly line of section 25; thence coincident with the boundary of said section 25 the following four 4) courses; 1) South 00°22'16" West 1297.67 feet; thence 2) South 89°17'47" West 2553.71 feet; thence 3) South 89°18'12" West 2553.71 feet; thence 4) North 03°07'30" West 2726.06 feet to the west quarter corner of section 25; thence North 48°06'20” East 1600.94 feet; thence North 54°12'29” East 1349.19 feet; thence North 56°50'10” East 115.29 feet; thence North 6°31'17” East 131.11 feet; thence North 81°14'02” West 41.06 feet; thence North 81°04'41” West 106.07 feet; thence North 0°10'04” East 531.29 feet to the section line; thence coincident with the section line North 88°23'23” East 355.29 feet to the POINT OF BEGINNING. PHASE I VCP PARCEL DESCRIPTION CONTAINS 451.135 ACRES MORE OR LESS Found rebar & cap monument "ALLIANCE ENGR" Found US HWY 40 ROW Monument SURVEYOR'S CERTIFICATE I, Charles Galati, certify that I am a Professional Land Surveyor and that I hold License No. 7248891, as prescribed by the laws of the State of Utah. I further certify that under my direct supervision a survey has been performed on the hereon described property and that to the best of my knowledge this plat is a correct representation of said survey. LOCATED IN SECTION 25, TOWNSHIP 2 SOUTH, RANGE 4 EAST, SALT LAKE BASE AND MERIDIAN RECORD OF SURVEY WASATCH COUNTY, UTAH PHASE 1 VCP AREA BOUNDARY SURVEY NARRATIVE/NOTES 1.Basis of Bearing for this survey is between the found section corner monuments as shown on this plat. 2.Field work for this survey was performed Summer of 2017 through Fall 2022 and is in compliance with generally accepted industry standards for accuracy. 3.The purpose of this survey was to prepare and record a Record of Survey for the boundary of the Phase 1 VCP Area - Revised, of the Mayflower Mine VCP Site #C090 as part of the remediation completion requirements. 4.A Title Report was not provided to the surveyor and no easements were located as part of this survey. The owner of the property should be aware of any items affecting the property that may appear in a title insurance report. The surveyor found no obvious evidence of easements, encroachments or encumbrances on the property surveyed except as shown hereon. 5.County tax maps, recorded deeds, Records of Survey, Nos 2647, and 3058 (all aforementioned documents on file and of record in the Wasatch County Recorder's Office), Map of Remediation Area Figures 1-13 provided by RMEC and physical evidence found in the field were all considered when determining the boundary as shown on this plat. 6.No boundary corner monuments were set as part of this survey. ROW Monuments as indicated hereon have been previously located by this surveyor before construction of the Mayflower Resort and may have since been disturbed or destroyed. 7.This survey supercedes any previous boundary survey performed by this surveyor of the Phase 1 VCP Area. Found Section monument (As-Noted) LEGEND 2 14 2024 MAYFLOWER LDP COORDINATE SYSTEM PROJECTION PARAMETERS PROJECTION = TRANSVERSE MERCATOR DATUM = NAD83(2011) REALIZATION/EPOCH = 2010.0000 FALSE NORTHING = 200,000.0000 FALSE EASTING = 50,000.0000 ORIGIN LATITUDE = 40°37'30.0000" N SCALE REDUCTION = 1.000317000 CENTRAL MERIDIAN = 111°27'30.0000" W PROJECT ELEVATION = 6,700.00 (NAVD88) ZONE UNIT (N/E/U) = U.S. SURVEY FOOT SURVEYOR NOTE All Bearings and Distances recited in Line Tables, or annotated hereon, are expressed in U.S. Survey Feet, projected to an NAVD Height of ~6700 feet, and defined by the NAD83(2011) Epoch 2010.0000 Projection Parameters (aka Mayflower LDP Coordinate System Projection) detailed hereon. This projection was specifically designed to minimize both convergency and scale variation within the Project Area. Refer to Records of Survey Nos. 2647, 3058 and 3759 in the Wasatch County Surveyor's office. Mayfiower Mine VCP Site Management Plan 24 Exhibit B – Greenspace Cover and Hard Surface Cover Mayfiower Mine VCP Site Management Plan 25 Exhibit C – Map #4 from the Remedial Action Report Mayfiower Mine VCP Site Management Plan 26 Exhibit D – Map #2 from the Remedial Action Report Mayflower VCP - Project Overview Map 2 Subsurface Water Cutoff Wall Legacy Mining Pond Final Construction Document BIG DUTCH PETE CANYON Mayfiower Mine VCP Site Management Plan 27 Exhibit E – Map #3 from the Remedial Action Report Mayflower VCP - Project Overview Map 3 Big Dutch Spring and Pipeline Final Construction Document BIG DUTCH PETE CANYON Big Dutch Pete Hollow Spring Pipeline Route Mayfiower Mine VCP Site Management Plan 28 Exhibit F – Map #1 from the Remedial Action Report