Environmental Assessment Cibola Old Channel Restoration

Colorado River Front Works and Levee System, Arizona

Lower Colorado Region

U.S. Department of the Interior Bureau of Reclamation Yuma Area Office Yuma, Arizona December 2018

Mission Statements

The Department of the Interior protects and manages the Nation's natural resources and cultural heritage; provides scientific and other information about those resources; and honors its trust responsibilities or special commitments to American Indians, Alaska Natives, and affiliated island communities.

The mission of the Bureau of Reclamation is to manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public.

Environmental Assessment Cibola Old Channel Restoration

Colorado River Front Works and Levee System, Arizona Lower Colorado Region

prepared by

United States Department of the Interior Bureau of Reclamation Yuma Area Office

U.S. Department of the Interior Bureau of Reclamation Yuma Area Office Yuma, Arizona December 2018

Acronyms and Abbreviations

APE Area of Potential Effect BMPs Best Management Practices CFR Code of Federal Regulations CFS Cubic Feet per Second DO Dissolved Oxygen EA Environmental Assessment ESA Endangered Species Act EO Executive Order EPA Environmental Protection Agency ESA Endangered Species Act ITAs Indian Trust Assets LCR Lower Colorado River MSCP Multi-Species Conservation Program NAAQS National Ambient Air Quality Standards NWR National Wildlife Refuge NEPA National Environmental Policy Act NHPA National Historic Preservation Act NRHP National Register of Historic Places O3 Ozone pH a logarithmic scale used to specify the acidity or basicity of an aqueous solution PVOD Palo Verde Outfall Drain PM10 Particulate Matter that is 10 microns in diameter or less Reclamation Bureau of Reclamation RM River Mile US United States USFWS United States Fish and Wildlife Service USACE United States Army Corps of Engineers

Contents

Page

1.0 Purpose and Need for Proposed Action ...... 1 1.1 Introduction ...... 1 1.2 Location ...... 1 1.3 Background ...... 4 1.4 Purpose and Need ...... 4 1.5 Determinations to be Made ...... 6 2.0 Alternatives Considered ...... 8 2.1 No Action Alternative ...... 8 2.2 Proposed Action ...... 8 2.2.1 Maintenance Activities ...... 10 2.3 Alternatives Considered but Eliminated from Further Review ...... 10 2.3.1 Additional Flows Through High-Levee Pond and Pretty Water .. 10 2.3.2 Dredging ...... 11 3.0 Affected Environment and Environmental Consequences ...... 13 3.1 Land Use ...... 13 3.1.1 Affected Environment ...... 13 3.1.2 Environmental Consequences ...... 13 3.1.3 Management and Mitigation Measures ...... 13 3.2 Air Quality ...... 13 3.2.1 Affected Environment ...... 13 3.2.2 Environmental Consequences ...... 14 3.2.3 Management and Mitigation Measures ...... 14 3.3 Biological Resources ...... 14 3.3.1 Affected Environment ...... 14 3.3.2 Environmental Consequences ...... 19 3.3.3 Management and Mitigation Measures ...... 21 3.4 Cultural Resources ...... 22 3.4.1 Affected Environment ...... 22 3.4.2 Environmental Consequences ...... 22 3.4.3 Management and Mitigation Measures ...... 22 3.5 Indian Trust Assets ...... 23 3.5.1 Affected Environment ...... 23 3.5.2 Environmental Consequences ...... 23 3.5.3 Management and Mitigation Measures ...... 24 3.6 Environmental Justice and Socio-Economic Conditions ...... 24 3.6.1 Affected Environment ...... 24 3.6.2 Environmental Consequences ...... 25 3.6.3 Management and Mitigation Measures ...... 25 3.7 Hazardous Materials or Solid Waste ...... 25 3.7.1 Affected Environment ...... 25 3.7.2 Environmental Consequences ...... 25 3.7.3 Management and Mitigation Measures ...... 26

iii

3.8 Noise ...... 26 3.8.1 Affected Environment ...... 26 3.8.2 Environmental Consequences ...... 26 3.8.3 Management and Mitigation Measures ...... 26 3.9 Water Resources ...... 27 3.9.1 Affected Environment ...... 27 3.9.2 Environmental Consequences ...... 28 3.9.3 Management and Mitigation Measures ...... 28 3.10 Geology, and Soils ...... 29 3.10.1 Affected Environment ...... 29 3.10.2 Environmental Consequences ...... 29 3.10.3 Management and Mitigation Measures ...... 29 3.11 Visual Resources ...... 30 3.11.1 Affected Environment ...... 30 3.11.2 Environmental Consequences ...... 30 3.11.3 Management and Mitigation Measures ...... 30 3.12 Floodplain ...... 30 3.12.1 Affected Environment ...... 30 3.12.2 Environmental Consequences ...... 31 3.12.3 Management and Mitigation Measures ...... 31 3.13 Recreation ...... 31 3.13.1 Affected Environment ...... 31 3.13.2 Environmental Consequences ...... 31 3.13.3 Management and Mitigation Measures ...... 32 3.14 Cumulative Effects of the Proposed Action ...... 32 3.14.1 Impacts by Resource ...... 35 4.0 Consultation, Scoping, and List of Preparers ...... 37 4.1 Agencies Consulted ...... 37 4.2.1 Scoping Letter ...... 37 4.2.2 Public Meeting ...... 37 4.3 List of Preparers ...... 37 4.3.1 Bureau of Reclamation ...... 37 5.0 References ...... 38

1.0 Purpose and Need for Proposed Action

1.1 Introduction

The Bureau of Reclamation (Reclamation) has prepared this environmental assessment (EA) to evaluate potential impacts associated with the proposed Cibola Old Channel Restoration project. This EA was prepared in accordance with the National Environmental Policy Act (NEPA) of 1969 (42 United States Code 4321), the Council on Environmental Quality regulations (40 Code of Federal Regulations (CFR) 1500-1508) for implementing NEPA, and the Department of the Interior’s NEPA Regulations (43 CFR Part 46), and Reclamation Manual NEPA Policy. Reclamation is the lead Federal agency pursuant to NEPA.

1.2 Location

The project area is located within the Cibola National Wildlife Refuge (NWR) at Township 2 South, Range 23 West, Section 18 (United States Geological Survey Cibola Quadrangle, see Figures 1 and 2). The project is located within the Cibola Division of the Lower Colorado River (LCR).

Figure 1. Location Map

Figure 2. Project Area Map

1.3 Background

In 1969, Reclamation constructed a plan known as the Colorado River Channelization, as part of an ongoing program to correct channel deficiencies and other problems in the Palo Verde and Cibola Valley Divisions. In the process of channelizing the river, the old river channel became a side channel/backwater, herein referred to as the Cibola Old Channel. To ensure that the Cibola Old Channel was not isolated from the newly formed Colorado River channel, porous (percolation or permeable) rock structures were placed at the inlet area at River Mile (RM) 96.3 to ensure flow through the Cibola Old Channel. The inlet consists of two structures; the Pretty Water area and the High Levee Pond. The Cibola Old Channel terminates at the Walter’s Camp area at RM 88.4, via an open outlet into the main river channel.

Flows through the Cibola Old Channel were established and maintained for the benefit of fish and wildlife resources. Additionally, the Palo Verde Outfall Drain (PVOD) also provides flows (monthly mean discharge ranges between approximately 387 and 605 cubic feet per second (cfs)) through the channel. The PVOD empties into the Cibola Old Channel about 1.5 miles below (downstream of) High Levee pond. Over time, flows from the PVOD and through the existing structures into the Cibola Old Channel have lost their capacity to move sediment through the backwater. Residents of the Walter’s Camp area have expressed concerns of insufficient water flow through the outlet area to help with flushing out of sediment deposition in the area.

Reclamation has implemented various short-term actions over the past years to help alleviate the problem of sediment accumulation caused by limited flows through the lower section of the Cibola Old Channel by dredging the outlet area in 1998 (Walter’s Camp) and in 2003. Also, in 2003, a wash fan (sediment sandbar) was excavated from the Cibola Old Channel at the upstream end of Walter’s Camp.

1.4 Purpose and Need

The purpose of the Proposed Action is to supplement water flows through the latter 1.5 miles of the Old River Channel to increase water velocity and decrease sedimentation. Decreased water flow and increased sedimentation over the years have resulted in increased shallowness of the lower portion of the Cibola Old Channel. Surface water enters the Cibola Old Channel through two sources: 1) through a pair of permeable rock “inlet” structures on the upstream and downstream side of High Levee Pond at the head of Cibola Old Channel, and 2) through the Palo Verde Outfall Drain, which discharges excess irrigation water from the Palo Verde valley into the Cibola Old Channel approximately 1.5 miles downstream of High Levee Pond.

The High Levee Pond inlet was designed to allow water to seep through the permeable rock structures, thereby limiting sediment from entering and settling in the Cibola Old Channel/Pretty Water backwater area. While the existing inlet structures at High Levee Pond are still functioning, they are not providing sufficient flow from the Colorado River into High Levee Pond and Pretty Water and through the lower portion of the Cibola Old Channel, to assist transporting sediment. This is due to reduced flows from the main channel. Data from the Cibola Gage located downstream from the proposed project area show that average daily flow in the Colorado River dropped from approximately 8,807 cfs in 1987 to 7,677 cfs in 2018, a 12.8% drop in streamflow over a 31 year period. This results in a reduction in flow through High Levee Pond. See Figure 3.

Figure 3. River Gage Data

With the Colorado River inflow into the Cibola Old Channel limited to seepage, the PVOD has become the primary source of flow into the Cibola Old Channel. Historical flow data for the PVOD just upstream of the Cibola Old Channel confluence can be seen in Figure 4.

Figure 4. Flow Data through Palo Verde Outfall Drain

While the PVOD supplies a steady discharge into the Cibola Old Channel (±480 cfs daily mean discharge), it is visually evident that, infiltration and other losses along the ±10-mile length of the Cibola Old Channel has resulted in reduced flows in the lower section of the Cibola Old Channel throughout the year. While discharge measurements have not been conducted in the lower channel, the flow adjacent to Walter’s Camp has been regularly observed by Reclamation to be near stagnant.

The Cibola Old Channel is approximately 10 miles in length. The proposed project’s objectives include improving the environment by providing increased flows through the lower 1.5 mile section of the Cibola Old Channel, maintaining and protecting the existing wetlands in the lower reach by assuring water flow to help support and sustain the aquatic environment.

1.5 Determinations to be Made

This EA will be distributed to appropriate decision-makers within Reclamation for review to determine whether a Finding of No Significant Impact is appropriate. This decision will be based on a determination that all potential impacts are either not significant or can be reduced to not significant levels

6 through the implementation of mitigation measures. If any potential impacts are considered significant and cannot be avoided or reduced to not significant levels, the preparation and processing of an Environmental Impact Statement is required to implement the proposed project.

2.0 Alternatives Considered This chapter describes the alternatives considered for the Cibola Old Channel Restoration project. Alternatives considered include the Proposed Action and the No Action alternatives.

2.1 No Action Alternative

NEPA guidelines require that an EA evaluate the “No Action” alternative in addition to the Proposed Action. The no action alternative provides a basis for comparison of the environmental consequences of the Proposed Action. In this EA, the no action alternative assumes that the Project would not occur and the water flow through the area would remain relatively unchanged and no new facilities would be installed.

Under the No Action alternative, Reclamation would not install pipelines to add flows through the lower portion of the Cibola Old Channel near R.M. C-89.9.

2.2 Proposed Action

The Bureau of Reclamation’s Yuma Area Office would install a pipeline on Cibola National Wildlife Refuge to supplement water flow through 1.5 miles of the lower section of the Cibola Old Channel to increase water flow and maintain aquatic habitat. The new pipeline would allow Reclamation to moderately increase water flow through this section of the Cibola Old Channel, see Figure 6.

The undertaking involves the installation of two 42-inch diameter by 1,180-foot long high-density polyethylene (HDPE) pipes that would be placed in an 18-foot wide trench excavated to an average depth of 6 feet below the existing ground surface. The project is proposed to be constructed during the low water period along the river during the months of December 2018, January 2019, and possibly into February 2019. The length of construction activity is approximately five weeks.

The proposed HDPE pipe invert elevations are designed to sit at an elevation one foot (1-ft) below the 95th Percentile water surface elevation in the Colorado River adjacent to the project site. Gage data and river geometry was used to develop a hydraulic model of the Colorado River, from which a statistical analysis was run on the gage data record. Water surface elevations for the 5th, 50th, 75th, 90th, and 95th Percentile flowrates in the Colorado River were developed. The 95th Percentile flowrate and corresponding water surface elevation indicates that based

upon the historical record, the water surface elevation, or stage, in the Colorado River will be at or above the specified elevation 95% of the time and would only fall below the specified elevation 5% of the time. A separate hydraulic model was used to model the inflow through the proposed pipeline based upon the Colorado River model output and the proposed pipeline geometry. Figure 5 exhibit depicts the modeled pipeline flowrates for corresponding Colorado River Percentile stages.

Figure 5. Hydraulic Modeling

As can be seen in the exhibit, the mean flow average through the pipeline is modeled to be 79.8 cfs. The mean inflow into the Cibola Old Channel from the PVOD is ±480 cfs, as noted above. Discounting any infiltration or losses along the ±10 miles of the Cibola Old Channel, this would be a minimum of a 16.6% average increase in flow through the lower section of the Cibola Old Channel. Given observable losses in the Cibola Old Channel, the actual increase in flowrate in the lower section of the Cibola Old Channel is expected to be larger.

The construction area of the project is a corridor of approximately 200 feet wide by 1,180 feet long (approximately 5 acres). A minimum of 2 feet of cover fill will be placed over the pipes. The pipelines will be covered with grates at the entrance to prevent a human from being sucked in to the pipelines. Backfill material would consist of native materials and gravel base materials. The area affected hydraulically by the project is expected to raise the water level less than one inch

approximately .25 mile upstream and 1.5 miles downstream to the confluence with the Colorado River main channel.

Construction of the buried underground pipe would include ground disturbing activities with heavy equipment. Surface vegetation along the project corridor would be cleared and a trench would be dug to facilitate the installation of the pipeline. The Proposed Action is expected to take approximately 6 weeks to complete.

Existing access roads (levee road and operations/maintenance roadway) will be used to access the project area. One of the access roads would be open always to allow emergency response vehicles and Cibola Refuge personnel and the public access to downstream areas. In addition, staging areas for equipment and refueling will be established within the access roads. The staging area will encompass an approximate area of about 100 by 200 feet (1 acre), it would be located away from the main stem of the river and the Cibola Old Channel.

Equipment expected to be used during construction activities will be: dozers, excavators, crane, haul trucks, water trucks, and service trucks.

2.2.1 Maintenance Activities Once construction activities are completed, Reclamation will perform periodic operation and maintenance activities such as pipeline repair or replacement and clean out of accumulated materials in the pipeline’s inlet and outlet areas if they become plugged with sediment. The HDPE pipes are expected to have a useful life of at least 50 years.

2.3 Alternatives Considered but Eliminated from Further Review

2.3.1 Additional Flows Through High-Levee Pond and Pretty Water This alternative was considered initially but eliminated from further analysis due to the potential direct adverse impacts to High-Levee Pond and Pretty Water Lagoon. Razorback suckers (Xyrauchen texanus) and bonytail (Gila elegans) are stocked in High-Levee Pond and Pretty Water Lagoon contains extensive cattail (Typha domengensis) marsh habitat for Yuma Ridgway’s rails (Rallus obsoletus yumanensis). Additional flows through the Cibola Old Channel near Mitchell’s Camp have a higher potential for water to be lost to evaporation, evapotranspiration, and infiltration and not reach the confluence with the Colorado River (lower section). For the purpose of maintaining habitat, the permeable structures through the levees allowing water through High-Levee Pond are functioning as designed and do not require maintenance or modification at this time. This alternative is unlikely to achieve desired results of the proposed action and has been eliminated from further review.

2.3.2 Dredging The majority of Cibola Old Channel is habitat for many species of fish and wildlife. Large scale dredging would have potential negative effects on existing habitat and would not appreciably change water quality parameters or increase flow through the area. Increasing depth is not a desired output for the project, therefore this activity has been considered but eliminated from further analysis.

Figure 6. Site Plan

3.0 Affected Environment and Environmental Consequences This section describes the existing environmental resources in the project area that may be affected by the Proposed Action and the No Action alternative, if implemented. It also serves as the baseline for the comparisons of alternatives. The following critical elements of the human environment are not present or would not be affected by the alternatives; therefore, they will not be addressed in this EA: Energy Policy, Fire Management, Public Health and Safety, and Travel Management

3.1 Land Use

3.1.1 Affected Environment The proposed project is located on federal land withdrawn for project purposes by Reclamation. The land is currently managed by the United States Fish and Wildlife Service as the Cibola National Wildlife Refuge.

3.1.2 Environmental Consequences No Action – Under this alternative, use and status of the land would not change.

Proposed Action – There would be no change in land use or status. Management of adjacent lands would not be impacted.

3.1.3 Management and Mitigation Measures No mitigation measures are proposed. Reclamation will coordinate with Cibola National Wildlife Refuge staff prior to construction.

3.2 Air Quality

3.2.1 Affected Environment The proposed project is located within La Paz County and outside the nearest PM10 non-attainment area located near Yuma, AZ.

The Clean Air Act, as amended in 1990, requires the Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for wide-spread pollutants from numerous and diverse sources considered harmful to public health and the environment. Imperial County is designated by the EPA as a Moderate Nonattainment Area for the 1997 8-Hour Ozone (O3) NAAQS. PM10 is defined as particulate matter that is 10 micrometers in diameter or smaller. A portion of Imperial County, not including the project area, is designated as a

Serious Nonattainment Area for the PM10 NAAQS. A portion of Yuma County, not including the project area, is designated as a Moderate Nonattainment Area for the PM10 NAAQS. The project areas are designated as being in attainment for all other NAAQS.

3.2.2 Environmental Consequences No Action - Under the No Action Alternative, air quality in the area would not change from its present readings.

Proposed Action – Construction activities associated with the Proposed Action have the potential to release small amounts of ozone precursors such as nitrogen oxides or volatile organic compounds from vehicle and machine exhaust. Ground disturbance associated with the movement of dirt and other dry material has the potential to generate dust, resulting in an increase in PM10 emissions.

3.2.3 Management and Mitigation Measures Best Management Practices (BMPs) would be followed to limit dust and PM10 emissions, including at a minimum: • Vehicle and equipment traffic would be limited to paved or graveled roads as much as possible. • Where equipment traffic, excavation, or demolition is required outside of paved or graveled roads, water or soil binders would be applied to exposed surfaces. • Equipment should be properly maintained to minimize exhaust emissions, and equipment idling would be limited. • Ground disturbing activities would cease temporarily when wind speeds at the site exceed 20 miles per hour.

3.3 Biological Resources

3.3.1 Affected Environment The site where the project is proposed to be located is heavily disturbed by past wildfires. Salt cedar (Tamarix chinensis, consisting of approximately 60 percent cover) is the prominent vegetation type within the project site (see Photos 1 through 3). A small amount of cattail and bulrush (genus Scirpus) is present only along one bank line adjacent to the Cibola Old Channel. Very few riparian trees exist in the area, mostly along the bank of the Colorado River, however a few Gooding’s willow trees may exist within the proposed project site. Upland vegetation common to all areas are palo verde (Cercidium floridum), smoketree (Psorothamnus spinosus), saltcedar, arrowweed (Pluchea sericea), quailbush (Atriplex lentiformis) and some scattered mesquite (Prosopis pubescens) in the upland areas.

Woody riparian vegetation and uplands provide habitat for common mammals such as coyote (Canis latrans), bobcat (Felis rufus), desert cottontail (Sylvilagus

audubonii), several species of rodents and bats, striped skunk (Mephitis mephitis), and raccoon (Procyon lotor) (Anderson and Ohmart 1984). The Colorado River corridor provides important habitat for migratory birds, both upland species and waterfowl, as well as habitat for resident species. Common birds include various egrets, herons, and owls, Gambel’s quail (Callipepla gambelii), white-winged dove (Zenaida asiatica), mourning dove (Zenaida macroura), flycatchers, and woodpeckers. Reptiles and amphibians are represented by several species of lizards, snakes, toads, and frogs, many of which are native to the area. Other species known to occur in the adjacent areas are the desert mule deer (Odocoileus hemionus), great egret (Ardea alba), least bittern (Ixobrychus exilis), and the western burrowing owl (Athene cunicalaria hypugaea).

Federally listed threatened or endangered wildlife species potentially occurring near the project area were identified using information from the United States Fish and Wildlife Service (USFWS) (endangered species list by county) for La Paz County.

There are five federally listed threatened, endangered, or candidate species which may occur near the project area:

1) Razorback sucker - Historically, razorback suckers inhabited the Colorado River and its tributaries from Wyoming to the Gulf of California. Most razorback suckers in the LCR are currently restricted to Lake Mohave, with smaller populations occurring in the Colorado River below Davis Dam, Lake Mead, and Senator Wash Reservoir (Bradford and Vlach 1995). Critical habitat has been designated for the razorback sucker and includes Lake Mead to its full-pool elevation; the river between Hoover Dam and Davis Dam, including Lake Mohave to its full-pool elevation; and the river and 100-year floodplain between Parker Dam and Imperial Dam. Razorback suckers are found in the Palo Verde Division near the A-7 and A-10 backwaters. Based on the Lower Colorado River Native Fishes Database, 15,795 razorback suckers were released downstream of Palo Verde Diversion Dam between 2007 and May 2017 (MSCP 2017). Based on contact records 130 were contacted in 2016, 130 were contacted in 2017 and 78 were encountered in both periods (MSCP 2017). More than 90% of the contacts were recorded in A-10 Upper backwater (MSCP 2017). The closest contact to the project area was near Oxbow Camp bridge (MSCP 2017). No contacts were made in the Cibola Old Channel nor the main channel of the river near Walter’s Camp (MSCP 2017 and personal communication with Brian Kesner). Razorback suckers were stocked some years ago in Three Fingers Lake, but that is fully enclosed, so they cannot access the Cibola Old Channel. Razorback suckers are also in High Levee Pond (USGS 2005). It is unlikely there are any wild populations in the Cibola Old Channel (B. Zaun, USFWS).

2) Bonytail - Bonytail were historically widespread and common throughout tributaries of the Colorado River and other larger rivers, with captures documented from Mexico to Wyoming. However, during the 1950s, bonytail

population abundance began a drastic decline following numerous biotic and abiotic habitat modifications. During the period between 1976-1988, 34 bonytail were captured in Lake Mohave, and some of these fish were incorporated in the establishment of a broodstock; the progeny of which are presently stocked into Lakes Mohave and Havasu as well as a number of UCRB rivers. Very few wild bonytail captures have been documented in recent years and, therefore, little is known about the specific habitat requirements of this unique species (MSCP 2018). Based on the Lower Colorado River Native Fishes Database, 11,696 bonytail were released into the Colorado River below Palo Verde Diversion Dam between 2007 and May 2017 (MSCP 2017). 76 contacts were made outside the release site and none have been located near Walter’s Camp neither in the Cibola Old Channel nor in the main stem of the river.

3) Southwestern willow flycatcher (Empidonax traillii extimus) - Throughout its range, the southwestern willow flycatcher is a riparian obligate, insectivore that breeds in summer along rivers, streams, and other wetlands where dense willow, cottonwood, salt cedar, or other similarly structured riparian vegetation occurs (USFWS 2002). No habitat exists for nesting southwestern willow flycatcher within the project area.

4) Yuma Ridgway’s rail - In the US, the Ridgway’s rail (formerly Yuma clapper rail) is associated primarily with freshwater marshes, with the highest densities of this subspecies occurring in mature stands of dense to moderately dense cattails and bulrushes. In the LCR MSCP planning area, Ridgway’s rail populations are considered regionally significant. Population centers for this subspecies include Imperial Division, Imperial National Wildlife Refuge, Cibola NWR, Mittry Lake, West Pond, Bill Williams River Delta, Topock Gorge, and Topock Marsh (LCR MSCP, 2004b). Minimal habitat exists for Ridgway’s rail within the project area. Vegetation along the Cibola Old Channel consists of linear cattail/bulrush intermixed with arrowweed along the upper banks. October 30, 2018 Marsh Bird Report regarding the Cibola Old Channel, prepared by B. Zaun from USFWS, is herein incorporated by reference (USFWS 2018).

5) Western yellow-billed cuckoo (Coccyzus americanus) - The western yellow- billed cuckoo is listed as threatened under the Endangered Species Act (ESA) and is listed as endangered under California ESA. Western yellow-billed cuckoos require structurally complex riparian habitats with tall trees and a dense woody vegetative understory (Halterman 1991, Hughes 1999). Critical habitat has been proposed for the species however, has not been finalized. The proposed project is within the proposed critical habitat. Most recently, the USFWS has determined that a status review is warranted for the species to determine if delisting is appropriate (USFWS 2018). Proposed critical habitat for yellow-billed cuckoo exists within the project area, however critical elements of that habitat are not found within the area impacted by the project. Habitat exists further north near the Cibola National Wildlife Refuge at the Cibola Valley Conservation Area

16 where cottonwood and willow trees have been planted by Reclamation’s LCR MSCP to mitigate for this species and others.

Photo 1

Photo 2

Photo 3

Water quality analysis can be found in Section 3.9 Water Resources and Appendix B. Main channel concentrations of dissolved oxygen (8.48 and 7.26 mg/L) are considerably higher than levels found in the Cibola Old Channel (3.88 and 4.42). Turbidity was higher in the Cibola Old Channel (9.0 and 7.8 NTU) than the main channel of the river (0 and 0.2 NTU). Conductivity in the Cibola Old Channel (2.11 and 2.14 mS/cm) is approximately twice that of the main channel (1.02 and 1.01 mS/cm). Alkalinity of the Cibola Old Channel (320 and 260 ppm) is higher than the main channel (110 and 144 ppm). Carbamates, chlorophenoxy herbicides, glyphosate, and total phosphorous were analyzed but not detected. Selenium and total nitrogen was detected. Salinity was sampled however the method of testing was not accurate enough to derive any useful data.

3.3.2 Environmental Consequences No Action – Under the No Action Alternative, no pipelines would be installed. There would be no direct impacts to biological resources from the construction of new facilities, however, impacts from low flows would remain.

Proposed Action – The proposed project would have minimal impact to vegetation and wildlife in the project areas. Approximately 5 acres of scattered salt cedar would be impacted and an area of about 50 by 25 feet of cattail/bulrush/reed vegetation would be impacted by the construction of the pipeline along the shoreline of the Cibola Old Channel. The project area was previously impacted by fire and no nesting habitat exists at the site for southwestern willow flycatcher or western yellow-billed cuckoo. Linear cattail and bulrush habitat exists for marsh birds, including Yuma Ridgway’s rails. Ground dwelling small mammals, birds and reptiles may be temporarily impacted by vehicle use and the moving of materials during construction. These impacts are temporary and localized and will be inconsequential once construction of the facilities is completed. No riparian habitat will be disturbed. Some wetland and upland habitat may be impacted; however, wetland vegetation, trees and shrubs will be avoided to the extent practical.

Water quality parameters are shown in Tables 2 and 3 in Section 3.9 and in Appendix B. Lloyd et al. (1987) showed that the productivity of aquatic systems could be reduced by turbid conditions. Increases in turbidity reduced light penetration in lakes and streams which led to decreased quantities of plant material and hence reduced primary production, decreased abundance of fish food organisms (secondary production) and decreased production and abundance of fish. Beneficial impacts to aquatic life could exist by reducing sedimentation and turbidity (which is occurring due to low flows and no scouring of the bottom of the Cibola Old Channel by high flow events and/or freshening flows) by mixing water from the main channel into the Cibola Old Channel. By mixing water of lower turbidity from the main channel of the river into more turbid water in the Cibola Old Channel, turbidity is expected to decrease in the area which should also benefit aquatic life, particularly fish. “The generally accepted minimum

amount of DO that will support a large population of various fishes is from 4 to 5 mg/l. When the DO drops below 3 mg/l, even the hardy fish die. Keep in mind that even though there may be enough DO to keep an adult alive, reproduction may be hampered by the need for higher DO for eggs and immature stages. Depletion in DO can cause major shifts in the kinds of aquatic organisms found in water bodies. Species that cannot tolerate low levels of DO – mayfly nymphs, stonefly nymphs, and beetle larvae – will be replaced by a few kinds of pollution- tolerant organisms, such as worms and fly larvae. Nuisance algae and anaerobic organisms (that live without oxygen) may also become abundant in waters with low levels of DO” (https://www.water-research.net/index.php/dissovled-oxygen- in-water). Mixing water with higher dissolved oxygen from the main channel of the river should result in an increase in dissolved oxygen in the Cibola Old Channel downstream of the proposed outlet. This should be a positive impact for fish and other aquatic life.

No adverse impacts to fish or wildlife are expected due to changes in water quality. Selenium detected in samples collected near the project area (1.0, .98, 1.6, and 1.3 ug/L) are less than concentrations known to begin causing negative affects due to bioaccumulation (greater than 2 ug/L) (USFWS 1987). Nitrogen levels detected in samples collected in the area (.91, .79, .80, and .78 mg/L) are well below acceptable levels for drinking water of 10 mg/L and should have minimal effect on the environment, particularly fish or wildlife, due to the project. Carbamates, chlorophenoxy herbicides, glyphosate, and total phosphorous were analyzed but not detected and therefore will have no effect on the environment due to the proposed action. No other effects to biological resources are anticipated due to other changes in water quality.

Razorbacks and bonytail are stocked in the reach below Palo Verde Diversion Dam near Blythe, California however, the Cibola Old Channel is more than 10 miles long and the project area will impact a very small area of the backwater. As such, it is anticipated that a small number of razorbacks and bonytail could be in the area but would be able to freely move out of the project area to avoid harm. No razorbacks nor bonytail have been detected in the Walter’s Camp area from stocking efforts upstream. There could be a benefit to native endangered fish within Three Fingers Lake should increased water flow in the Cibola Old Channel result in increased flows through the permeable rock berms to Three Fingers Lake. Therefore, impacts of this action are likely discountable and insignificant to these native fish.

Minimal habitat exists within the project area and less than a tenth of an acre of cattail/bulrush marsh habitat used by Yuma Ridgway’s rails will be temporary impacted during installation of the pipelines along the shoreline. Local water elevation increases are expected to be less than one inch which is inconsequential and discountable, regarding impact to these marsh birds. Additionally, the pipeline alignment would serve as a short-term fire break, while the vegetation reestablishes along the project area possibly preventing short term habitat loss in

the unlikely event of a wildfire in the project area. Due to presence of rails detected by surveys near the proposed project, is not unrealistic to assume that rails may be in the area, however this project will be disturbing very little habitat and construction will be outside the breeding season when rails are most susceptible to disturbance. If rails are present and disturbed during this action they will be able to move to areas outside the project area containing habitat, therefore any potential direct or indirect effects will be discountable.

Regarding riparian habitat used by southwestern willow flycatchers and yellow- billed cuckoos, the project area has been highly disturbed by wildfire in recent years, resulting in little to no breeding habitat, and most likely only migrant birds moving through the area transiently. Habitat for these bird is sparse through the area however is any are present and disturbed during this action they will be able to move to areas outside of the project area to other areas containing habitat. Therefore, any potential direct or indirect effects will be discountable. Proposed activities will not occur during the breeding season of either bird, therefore no impacts to breeding are anticipated.

The Proposed Action may affect, but is not likely to adversely affect, the following listed species: Yuma Ridgway’s rail, yellow-billed cuckoo, southwestern willow flycatcher, bonytail, and razorback sucker.

The Proposed Action alternative will not result in adverse modification to designated critical habitat for razorback sucker, since minimal surface water areas will be impacted. Proposed critical habitat for yellow-billed cuckoos has not been finalized, however the habitat elements are not found within the project site, therefore no adverse modification to its habitat is anticipated.

3.3.3 Management and Mitigation Measures Project construction activities will avoid and minimize impacts to vegetation and wildlife to the extent practical. By largely avoiding and minimizing direct impacts to wetland, riparian, and riverine habitats, impacts to listed species will be beneficial, insignificant or discountable. Direct effects will be minimized by carrying out the project during the months of December, January, and possibly extending into February, which is outside the migratory and breeding seasons for listed bird species. As a BMP, Reclamation will wash construction vehicles before working at the site to prevent the spread of invasive species. Trash and food materials will be properly contained within vehicles or closed refuse bins while on site, and will be regularly removed from the construction site for proper disposal. Reclamation has agreed to purchase potted honey mesquites as mitigation for trees lost to construction of the proposed project. Native vegetation will be avoided to the extent practical.

3.4 Cultural Resources

3.4.1 Affected Environment The National Historic Preservation Act (NHPA) establishes national policy for protecting significant cultural resources that are defined as “historic properties” under 36 CFR 60.4. NHPA Section 106 (36 CFR §800) requires that Federal agencies consider and evaluate the effect that Federal projects may have on historic properties under their jurisdiction. The Area of Potential Effect (APE) for this undertaking includes the location noted in Section 2.2 (above).

Reclamation conducted a Class I survey (file and record search) and there are no known cultural resource sites in the APE. Furthermore, the expectation for the discovery of new cultural resources in the project area is very low. The APE is in the historic floodplain of the Colorado River which, prior to Reclamation’s Colorado River channelization project, was subject to severe seasonal flooding. In addition, approximately 90 percent of the APE is in the construction footprint of the channelization project area. Because of the low expectation for the discovery of new cultural recourses and the high amount of previous ground disturbance in the APE, a Class III survey was not conducted.

3.4.2 Environmental Consequences In accordance with 36 CFR Part 800.5 Reclamation has applied the criteria of adverse effect to historic properties subject to the No Action and Proposed Action Alternative to determine if they would directly or indirectly alter any of the characteristics of historic properties that qualify them for inclusion in the National Register of Historic Places (NRHP).

No Action – Under the No Action Alternative, no pipelines would be installed.

Proposed Action – No historic properties are in the APE. The APE is in the historic floodplain of the Colorado River which, prior to Reclamation’s Colorado River channelization project in the area, was subject to severe seasonal flooding. In addition, approximately 90 percent of the APE is in the old construction footprint of the channelization project area. Therefore, Reclamation has made a finding of No Historic Properties Affected for the undertaking. If during any activities associated with this undertaking, any districts, sites, buildings, structures, or objects are discovered, activities will cease in the vicinity of the resource. Reclamation shall ensure that the stipulations of 36 CFR Part 800.13 are satisfied before activities in the vicinity of the previously unidentified property resume.

3.4.3 Management and Mitigation Measures In accordance with 36 CFR part 800.5 Reclamation has applied the criteria of adverse effect to historic properties to determine if the Proposed Action would directly or indirectly alter any of the characteristics of historic properties that

qualify them for inclusion in the NRHP. Based on our finding of no adverse effect, no mitigation measures are proposed.

If during any activities associated with the implementation of the Proposed Action any sites, buildings, structures, or objects not addressed in this assessment are discovered, activities will cease in the vicinity of the resource. Reclamation’s Environmental Group Manager and project archaeologist will be notified immediately. Reclamation shall ensure that the stipulations of 36 CFR Part 800.11 are satisfied before activities near the previously unidentified property resume.

3.5 Indian Trust Assets

3.5.1 Affected Environment Indian Trust Assets (ITAs) are legal interests in property held in trust by the United States for Indian tribes or individuals, or property in which the US is charged by law to protect for Indian tribes or individuals. In accordance with the Indian Trusts Fund Management Reform Act of 1994, as amended, all Department of Interior agencies, including Reclamation, are responsible for protecting ITAs from adverse impacts resulting from their programs and activities. In cooperation with tribes, Federal agencies must inventory and evaluate assets, and mitigate or compensate for adverse impacts to the asset. While most ITAs are located on reservation lands, they may also be located off- reservation. Examples of ITAs include, but are not limited to, land, minerals, rights to hunt, fish, and gather, and water rights.

3.5.2 Environmental Consequences Reclamation departmental policy requires the agency to address potential impacts to ITAs even if impacts are found to be non-significant. The proposed project does not involve Indian Trust Assets.

Trust Lands The Proposed Action is not located on ITA lands. There are no tribal residences and/or facilities within the project area.

Water Rights No tribes inhabit the immediate area where a water right might be impacted.

Hunting, Fishing, and Gathering Rights The Colorado River and its tributaries provide habitat for sensitive fish and wildlife species, especially in the riparian woodlands and marshes. Some members of the tribe still collect a variety of plants, which are eaten as well as used for medicinal and ceremonial purposes, and in traditional craft production (LCR MSCP 2004c).

3.5.2.1 No Action Alternative Under the No Action Alternative, construction of the pipelines would not take place. Therefore, no change to Federal actions will occur that could result in an adverse effect to identified ITAs.

3.5.2.2 Proposed Action Trust Lands The Proposed Action will not interfere with any Trust Lands. The project is not located on Trust Lands and does not prevent the use or management of any tribal or Trust Lands.

Water Rights The Proposed Action will not result in a change to any tribal water right, or to the diversion or delivery of tribal water entitlements.

Hunting, Fishing, and Gathering Rights The Proposed Action will not interfere with any hunting, fishing or gathering rights which could be exercised by any tribe.

3.5.3 Management and Mitigation Measures No mitigation measures are proposed.

3.6 Environmental Justice and Socio-Economic Conditions

3.6.1 Affected Environment Executive Order (EO) 12898 requires Federal agencies to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low- income populations in the US.

Minority populations include all persons identified by the Census of Population and Housing to be of Hispanic or Latino Origin, as well as, non-Hispanic persons who are African American, American Indian and Alaska Native, Native Hawaiian or other Pacific Islander.

Low-income populations are those that fall within the annual statistical poverty thresholds from the Bureau of the Census for the 2010 Census. The definition of poverty is dependent on the size of the family. For example, the poverty threshold for a family of three is $17,374; whereas, $22,314 is the threshold for a family of four (U.S. Census Bureau 2010b). If the total income of a person’s family is less than the threshold appropriate for that family, then the person is considered as being below the poverty level. Information on total population, minority population, and poverty status for La Paz and Riverside Counties and Blythe, California is provided in Table 1.

Table 1 Location Total Percent Percent Population Living Population Minority Below Poverty Level La Paz County, 20,489 39.7 20.2 Arizona Riverside County, 2,189,641 19.3 15.6 California Blythe, California 20,817 40.5 16.1 Source: US Census Bureau 2010a

3.6.2 Environmental Consequences No Action – Under the No Action Alternative, the project will not take place. Therefore, no Federal actions will occur that could result in a disproportionately high and adverse effect on the health or environment of minority or low-income populations.

Proposed Action – Implementation of the Proposed Action Alternatives would not disproportionately affect the minority and impoverished population in the area. Based on the analysis for air quality, water resources, and hazardous materials in this EA, changes resulting from implementing the project will not result in proportionately high and adverse impacts to the environment or to the health of low-income and minority populations.

3.6.3 Management and Mitigation Measures No mitigation measures are proposed for the environmental justice and socioeconomic conditions section.

3.7 Hazardous Materials or Solid Waste

3.7.1 Affected Environment No hazardous materials are currently used or stored anywhere at the proposed structure location sites.

3.7.2 Environmental Consequences No Action – Under this alternative, no ground disturbing activities that may affect hazardous materials in the area or produce waste from construction activities. Therefore, there would be no change to existing conditions.

Proposed Action – Under this alternative, waste petroleum, oils, and lubricants would be generated that would require disposal. Any of the hazardous waste associated with the construction will be disposed of properly as to not pose a further hazard.

3.7.3 Management and Mitigation Measures Mitigation actions designed to limit the potential impact of hazardous materials or solid waste would be implemented according to State and Federal regulations. Other hazardous materials anticipated to be used during construction of the project are small volumes of petroleum hydrocarbons and their derivatives (for example, fuels, oils, lubricants, and solvents) required to operate the equipment used in the construction activities. These materials are those routinely associated with the operation and maintenance of heavy equipment or other support vehicles, including gasoline, diesel fuels, and hydraulic fluids.

• A site specific contingency spill plan should be developed and implemented. The plan should consist of reporting guidelines in the event of a spill, good housekeeping techniques, and employee training in the use of required equipment and proper handling of potentially hazardous materials.

• Hazardous materials used for this project would be contained within vessels engineered for safe storage.

• Areas for refueling of equipment would be chosen to prevent any accidental fuel leakage from contaminating surface water, groundwater, or soils.

3.8 Noise

3.8.1 Affected Environment Noise that currently exists in the area generally comes from river recreational (motor boats), farming operations, farming equipment, and vehicle travel along State Route 78 in California and the levee road in Arizona. Residences in the general vicinity include those in the town of Cibola in Arizona, along with those located at Walters Camp and Mitchells Camp in California.

3.8.2 Environmental Consequences No Action – In the No Action Alternative, current noise levels including noise from river recreation, highway, and farming operations would continue at the present levels.

Proposed Action – The use of equipment during the implementation of the project will slightly increase noise disturbance temporarily in the vicinity where work is occurring. This could affect adjacent areas; however, the project area is isolated from any public sensitive receptors.

3.8.3 Management and Mitigation Measures No mitigation measures are necessary because noise levels would continue to be consistent with current ongoing operations and adjacent recreational activities.

3.9 Water Resources

3.9.1 Affected Environment The Colorado River is the nearest source of surface water in the area. The U.S. Army Corps of Engineers (USACE), under Section 404 of the Clean Water Act, regulates the discharge of dredged, excavated, or fill material in wetlands, streams, rivers, and other US waters. The Colorado River is USACE jurisdictional water identified within the project area.

Water samples were taken from two locations in the Cibola Old Channel and from two locations in the main stem of the Colorado River to compare water quality. The northernmost samples, one from the main stem of river and one from the old Cibola Channel, were taken near the proposed pipeline’s inlet and outlet area, approximately 1.5 miles above Walter’s Camp. The other Cibola Old Channel sample was taken at Walter’s Camp and the second main stem river sample was taken approximately one-half mile below the confluence of the Colorado River and the Cibola Old Channel. Reclamation requested and received a list of water quality parameters to test for from the Cibola National Wildlife Refuge staff. Water samples were composite samples representing a cross-section of the river/channel at each location. See Appendix B, Water Quality Report for specifics regarding protocol, field logs, sample locations, lab results, quality controls, etc. Field analysis was conducted for dissolved oxygen (DO), pH, salinity, conductivity, temperature, alkalinity, and turbidity, see Table 2.

Table 2 Cibola Old Cibola Old River 1 River 2 Channel # 1 Channel # 2 DO (mg/L) 3.88 4.42 8.48 7.26 pH 9.22 9.21 9.54 9.47 Salinity (ppm) <1000 <1000 <1000 <1000 Conductivity (mS/cm) 2.11 2.14 1.02 1.01 Temperature I 30.68 30.64 30.83 31.95 Alkalinity (ppm) 320 260 110 144 Turbidity (NTU) 9.0 7.8 0 0.2

Additionally, laboratory analysis was conducted for selenium, total phosphorus, total nitrogen, carbamates, chlorophenoxy herbicides, and glyphosate, see Table 3.

Table 3 Cibola Old Cibola Old River 1 River 2 Channel # 1 Channel # 2 Carbamates Not Not Not Not Detected Detected Detected Detected Chlorophenoxy Not Not Not Not Herbicides Detected Detected Detected Detected Glyphosate Not Not Not Not Detected Detected Detected Detected Selenium (ug/L) 1.0 0.98 1.6 1.3 Total Phosphorus Not Not Not Not Detected Detected Detected Detected Total Nitrogen (mg/L) 0.91 0.79 0.80 0.78

3.9.2 Environmental Consequences No Action – Implementation of the No Action Alternative would not entail any construction activity; therefore, no impacts to surface water, or jurisdictional waters would occur due to construction.

Proposed Action – The Proposed Action Alternative’s impacts on water resources are anticipated to be minimal, with no changes to water delivery operations, and/or reduction in surface water areas. Increase in water elevation will be less than one inch, affecting approximately ¼ mile above the pipeline outlet to approximately 1.5 miles downstream at the confluence with the main channel. Potential impacts to surface water could include temporary water quality degradation during construction, however measures to reduce sediments moving downstream will be used in compliance with the Clean Water Act. Additional flows in the Cibola Old Channel would help improve dissolved oxygen levels immediately below the pipelines outlet area. Sedimentation and turbidity are expected to decrease slightly due to the increase in velocity from pipeline flows. Effects related to water quality on biological resources are discussed in Section 3.3.2.

Although highly unlikely, spills from construction activities could migrate into surface water conduits or infiltrate the groundwater, contaminating the source. If a spill were to occur, the impacts to water resources could be minimized with immediate response and clean-up procedures.

No construction components of the Proposed Action Alternatives would affect waters of the US, as no fill material will be discharged into the Colorado River.

3.9.3 Management and Mitigation Measures During construction, no refueling equipment should be permitted within 100 feet of the Cibola Old Channel, the Colorado River, or any other surface water conveyance system. Required Clean Water Act Section 404 and 401 permits will

28 be obtained prior to project commencing. Water quality testing will be conducted annually after the project is implemented for a period of 3 years to assess project effects.

3.10 Geology, and Soils

3.10.1 Affected Environment The LCR area of Arizona, Nevada, and California is in the lower portion of the Basin and Range geomorphic province, within the western Sonoran Desert. This area is characterized by numerous mountain ranges that rise abruptly from broad, plain-like valleys or basins. The basins are composed of silt-filled channels and alluvial fans, fan terraces, and floodplains, consisting of Quaternary sand, gravel, and conglomerate. Limited soil horizon development indicates young unstable alluvial and floodplain surfaces of late Holocene age, subject to periodic flooding, sedimentation, and dynamic alteration. The LCR generally consists of narrow stretches confined by resistant bedrock cliffs and bluffs and broad areas lined by low-lying alluvial floodplains. The active floodplain is bounded by steep, active slopes (escarpments), active sand dunes, and washes (arroyos). The floodplain has low relief and includes the stream channel and associated features such as point bars and abandoned channels or meanders. Sand splays, point bars, and meander scrolls are typically underlain by coarse-grained alluvium, whereas broad shallow channels and backswamps are more clay-rich (Parsons et al. 1986).

The soils on the Colorado River floodplain are saline. The salinity is the result of accumulated salts from alluvial deposits and subsequent evaporation of soil moisture. The rainfall is not sufficient to leach these salts below the plant root zone; therefore, a continuing accumulation of salts occurs. These salts are primarily calcium, sodium, magnesium, chloride, and sulfate. An excessive amount of toxic salts in the soil can delay or prevent seed germination, decrease available water capacity, interfere with plant growth, and impede the movement of air and water through the soil.

3.10.2 Environmental Consequences No Action – Under this alternative, there would be no changes to soils. Disturbances would continue as they are currently.

Proposed Action – Implementation of the Proposed Action alternatives would disturb soils during excavation activities, however following project activities natural vegetation regrowth would be expected to occur.

3.10.3 Management and Mitigation Measures No mitigation measures proposed.

3.11 Visual Resources

3.11.1 Affected Environment Visual resources consist of natural and manmade features that give a particular environment its aesthetic qualities. Landscape character is evaluated to assess whether the project will appear compatible with the existing features or would contrast noticeably with the setting and appear out of place. Visual sensitivity includes public values, goals, awareness, and concern regarding visual quality.

Visual resources within the project area generally include open space, agricultural areas, degraded wetland areas, and desert upland habitats located in and near the Colorado River floodplain. Prominent vegetation includes patches of desert scrub, salt cedar, common reed, and cattail. Other visible structures in the area consist of river control structures (levee) and bank line access road.

3.11.2 Environmental Consequences No Action – Under the No Action Alternative, no changes would occur to the sites’ characteristics.

Proposed Action – Implementation of the proposed project alternatives will not significantly impact the visual characteristics of the area.

3.11.3 Management and Mitigation Measures No mitigation measures proposed.

3.12 Floodplain

3.12.1 Affected Environment The Colorado River Floodway Protection Act, Public Law 99-450, was signed into law on October 8, 1986. The Act calls for the establishment of a federally declared floodway from Davis Dam to the Southerly International Boundary between the United States and Mexico. In accordance with Section 5 (a) of the public law, Reclamation developed maps that show the floodplain for the Lower Colorado River. In addition, EO 11988, Floodplain Management, May 24, 1977, requires avoiding or minimizing harm associated with the occupancy or modification of a floodplain. The base floodplain is an area expected to be inundated by floodwaters on the average of once in 100 years.

The Colorado River is also subject to flooding throughout the winter and spring season from rapid snowmelt in the upper Colorado River Watershed. The major flood control structures on the lower Colorado River are the Glen Canyon and Hoover Dams. The two major water storage levels in these reservoirs are regulated in association with the small reservoirs to provide flood protection, year-round water use, and hydro-electric power. In combination with these

storage facilities, Reclamation has developed extensive levee systems along many parts of the river to ensure safe passage of water during periods of high flow.

3.12.2 Environmental Consequences No Action – The no-action alternative would not impact the integrity of the lower Colorado River floodplain.

Proposed Action – Implementation of the Proposed Action alternatives would not impact the integrity of the lower Colorado River floodplain’s flow regime.

3.12.3 Management and Mitigation Measures No mitigation measures proposed.

3.13 Recreation

3.13.1 Affected Environment Recreation exists in the vicinity of the project area. Walter’s Camp, a Bureau of Land Management concession is located near the proposed project. Recreational opportunities that currently exist in the area include: Off Highway Vehicle riding, boating, year-round camping, fishing, hunting, paddle-sports, nature-watching, hiking, and picnicking. http://www.walterscamp.com/activities/.

The project is located on the Cibola National Wildlife Refuge. Recreational activities on the Refuge include wildlife watching, hiking, hunting and angling. https://www.fws.gov/refuge/Cibola/visit/visitor_activities.html.

3.13.2 Environmental Consequences No Action – The no-action alternative would likely lead to a reduction in water related recreational activities, especially boat related activities. There would be no affect to land-based activities. Walter’s Camp area residents have expressed that swimming, fishing and boating conditions have declined over the years due to decreased flow. This trend is expected to continue.

Proposed Action – Implementation of the proposed alternatives would allow for existing recreational activities to persist. There could be a beneficial affect for water related activities, especially swimming, boating and fishing. Reclamation does not expect a large change in recreational use of the area due to the project. Vegetation is expected to quickly grow back in areas that have been cleared due to construction, which would likely prevent any notable additional use. A minor increase in fishing activity could be found at the location where the freshening flows enter the Cibola Old Channel, however it is extremely difficult to predict future use of the area by recreationists. Cibola Refuge staff expects increases in activities which are illegal on the Refuge including overnight camping, litter, fires, and off-road travel due to the project creating areas without vegetation.

3.13.3 Management and Mitigation Measures Reclamation is committed to work with the Refuge staff to mitigate negative affects due to the recreational public being attracted to areas opened by the project. Reclamation is willing to provide barriers or other management solutions to prevent illegal off-road use, illegal campfires, illegal littering and dumping, and illegal overnight camping. Signs indicating that “no overnight camping, no fires, and no illegal OHV use allowed” will be placed near the proposed project site once construction is completed to abate anticipated illegal recreational activities.

3.14 Cumulative Effects of the Proposed Action

Cumulative effect is the impact on the environment that results from the incremental impacts of an action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or nonfederal) or person undertakes such actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 CFR 1508.7). Several former, current and planned projects either located within or in the vicinity of the planning area and having the potential to impact common resources will be addressed in this section.

The Yuma Area Office’s (YAO) Cibola Division Bankline Repairs

Under the Colorado River Front Work and Levee System (CRFWLS) Act of 1946 (as amended) Reclamation has responsibility along the lower Colorado River for flood control. The CRFWLS authorizes Reclamation to improve, stabilize, and maintain the river channel so that it can handle flows resulting from flood control operations and floods of local origin. In the Cibola Division, maintenance activities are continuous along the river rehabilitation flood control structures (e.g. levees and bank lines) to protection Reclamation facilities including adjacent land and property.

YAO’s Palo Verde Division Backwater Maintenance Project

Reclamation conducts maintenance and improvement activities to five backwaters located along the lower Colorado River’s Palo Verde Division, just south of Blythe, California.

1. A-7 backwater located on the Arizona side of the river between RM 120.5 to 117.3. 2. A-10 backwater located on the Arizona side of the river between RM 115.2 to 113.8. 3. C-5 backwater located on the California side of the river between RM 119.0 to 117.3. 4. C-8 backwater located on the California side of the river between RM 114.7 to 113.8.

5. C-10 backwater located on the California side of the river between RM 110.6 to 109.1

Reclamation has various maintenance requirements for the backwater sites mentioned above including: ensuring inlet/outlet structures are functioning properly for the benefit of fish and wildlife purposes. Rehabilitation activities consist of restoring existing inlet and outlet structures to improve water circulation through the backwaters if existing structures are not conveying sufficient flow through the backwaters due to being plugged with sediment.

MSCP’s Three Fingers Lake Conservation Project

Under the LCR MSCP program, Reclamation may restore and create backwater and marsh habitat through the creation of natural channels and aquatic habitats within Three Fingers Lake. MSCP’s Three Fingers Lake Conservation Project is in the preliminary planning stages. The Project would incorporate target criteria by the LCR MSCP planning documents. Overall, the proposed Project would create backwater habitat that would contribute to the Habitat Conservation Plan requirements and the wellbeing of the public at large by preserving and conserving fish, wildlife, plant, and aesthetic amenities.

Walters Camp Wash Fan Removal

Reclamation will conduct a one-time removal of the Walter’s Camp Wash Fan. Wash fan removal is a maintenance activity undertaken by Reclamation under the authority of the CRFWLS for the purposes of controlling floods, improving navigation, and improving the flow of the Colorado River in Arizona, Nevada, and California. Numerous washes drain directly into the lower Colorado River (between Davis and Imperial Dam). Precipitation may cause flash floods in the surrounding watershed that can carry large amounts of alluvial material into the river channel forming wash fans adjacent to and in the river channel. Wash fans are identified for removal by Reclamation when: river flows are forced by the fan into the opposite bank line causing erosion and/or when the main stem of the river is significantly constricting the flow, reducing channel capacity, and causing a navigational hazard. Removal of the wash fan will not prevent future wash fans to develop.

The number of wash fans requiring removal varies from year to year because it is related to the number of significant storm events that generate sufficient rainfall and overland flow conditions to carry sediment to the river from the tributary watershed.

Figure 7. Wash Fan Removal

3.14.1 Impacts by Resource Land Use The Proposed Action Alternative would not change any land uses in the area and/or disrupt any established land configurations, wildlife or recreational areas. Implementation of the Proposed Action Alternative, in conjunction with the other actions is not anticipated to have negative cumulative impacts to land use.

Air Quality Implementation of the Proposed Action and other actions described in section 3.13 may result in increased area emissions associated with construction activities. Due to the mobile nature and short duration of most emission sources, project emissions in combination with future emission sources would not be expected to contribute to an exceedance of an ambient air quality standard. As a result, the Proposed Action, in combination with other foreseeable projects and mitigation requirements, would not produce significant cumulative impacts to air quality and climate conditions.

Biological Resources The Proposed Action Alterative and the above-mentioned projects in section 3.13 have the potential for biological impacts due to short-term habitat loss for sensitive and common wildlife species. However, several of the projects are restoration and enhancement projects that are designed to benefit targeted species and other wildlife that utilize the proposed project site, resulting in a net positive impact over the duration of the proposed project implementation. With incorporation of avoidance, minimization, and mitigation measures, the Proposed Action Alternative, in conjunction with the other actions, is not anticipated to have negative cumulative impacts to biological resources.

Cultural Resources Reclamation has made a finding of no adverse effect to historic properties for the activities associated with the implementation of the Proposed Action. During the implementation phase of projects identified in section 3.13, there is potential for unforeseen cultural resources to be discovered or damaged. Reclamation has established “stop work” procedures that shall be implemented should and unanticipated discovery situation arise. Therefore, the Proposed Action, in conjunction with other projects listed in section 3.13, would not result in significant cumulative impacts on cultural resources.

Indian Trust Assets No Indian Trust Assets were identified near the proposed project area. Therefore, the Proposed Action, in combination with other proposed or on-going projects, would not cause disproportionate cumulative effects on ITAs.

Environmental Justice and Socioeconomic The Proposed Action would have negligible effects on population, housing, and other socioeconomic issues. The Proposed Action would not displace persons or housing, nor would it induce substantial population growth in the area, either directly or indirectly. The types of potential effects identified (e.g., increased noise, and fugitive dust) for the Proposed Action and the other projects would be localized and short-term. The Proposed Action, in combination with other foreseeable projects described in section 3.13, is not expected to have a cumulatively significant impact on socioeconomics and minority or low-income populations.

Hazardous Materials The project site is not located in close proximity to any known or suspected hazardous waste or petroleum waste sites. However, incidental spills of petroleum products could occur during construction activities, and such spills could result in significant impacts to water quality. With the implementation of mitigation measures, the risks of incidental spills would be reduced to less than significant. Other projects described in section 3.13 have hazards/hazardous materials related impacts due to construction activities. However, with anticipated mitigation measures, these risks would be cumulatively less than significant as these impacts are localized and temporary.

Noise The Proposed Action Alternative would require some use of heavy equipment to assist in the placement of the pipelines. However, the project will be short term. Other projects described in section 3.13 would have similar temporary construction noise. The Proposed Action, in conjunction with the other actions, is not anticipated to have long term negative cumulative impacts in the vicinity of the proposed project area.

Water Resources The Proposed Action would have beneficial impacts by improving water circulation through the lower section of the old Cibola channel. The Proposed Action, in conjunction with other proposed or on-going projects described in section 3.13, would not result in cumulatively significant impacts to water resources.

4.0 Consultation, Scoping, and List of Preparers

4.1 Agencies Consulted

An electronic copy of this EA has been posted for public viewing on Reclamation’s Yuma Area Office web site at http://www.usbr.gov/lc/yuma/. Paper copies of the Notice of Availability memorandum and EA were distributed to the following entities:

US Fish and Wildlife Service Bureau of Land Management California Department of Fish and Wildlife AZ Game and Fish Department Quechan Indian Tribe Cocopah Indian Tribe Bureau of Land Management Yuma Audubon Society Colorado River Indian Tribes AZ State Parks State Historic Preservation Office

Consultation with the Arizona State Historic Preservation Office was conducted under Section 106 of the NHPA (36 Part 800) for the undertaking involving federal facilities. Consultation with the USFWS for compliance under the Fish and Wildlife Coordination Act and Section 7 of the Endangered Species Act was initiated with staff from Ecological Services in Phoenix, AZ and concurrence with determinations was received.

4.2.1 Scoping Letter Reclamation prepared and sent a scoping letter to the agencies consulted in Section 4.1 soliciting information regarding the proposed action to assist with the identification of relevant issues. Copies of the letter are available upon request.

4.2.2 Public Meeting Reclamation conducted a public meeting on August 28, 2015 in Blythe, California. Copies of the information presented are available upon request.

4.3 List of Preparers

4.3.1 Bureau of Reclamation Nicholas Heatwole Environmental Protection Specialist Julian DeSantiago Group Manager, Environmental Planning and Compliance James Kangas Archaeologist Jan Miller Civil Engineer Jay Nemeth Supervisor Civil Engineer

5.0 References Anderson, B.W., and R.D. Ohmart 1984 A vegetation management study for the enhancement of wildlife along the lower Colorado River. Final report. Boulder City, NV: Bureau of Reclamation, Lower Colorado Region.

Bradford, R. H., and B. R. Vlach 1995 Razorback sucker habitat assessment indices for the lower Colorado River. (Cooperative Agreement No. 3-FC-34-08243). Prepared for U.S. Bureau of Reclamation, Yuma, AZ.

Halterman, M.D. 1991 Distribution and habitat use of the Yellow-billed Cuckoo (Coccyzus americanus occidentalis) on the Sacramento River, California, 1987-90. Masters’ Thesis California State University, Chico 49 pp.

Hughes, J.M. 1999 Yellow-billed cuckoo ( Coccyzus americanus). The Birds of North America, No. 418 (A. Poole and F. Gill, eds.). The Birds of North America, Inc., Philadelphia, PA.

Lemley, A. Dennis, and Gregory J. Smith 1987. Aquatic Cycling of Selenium: implications for fish and wildlife. U.S. Fish Wildl. Serv., Fish Wildl. Leafl. 12. 10pp.

http://www.dfo-mpo.gc.ca/Library/255660.pdf Lloyd et all DFO 2000. Effects of sediment on fish and their habitat. DFO Pacific Region Habitat Status Report 2000/01.

Lower Colorado River Multi-Species Conservation Program (LCR MSCP) ____. 2004a. Lower Colorado River Multi-Species Conservation Program, Volume III: Final Biological Assessment December 17. Sacramento, CA.

____. 2004b. Lower Colorado River Multi-Species Conservation Program, Volume IV: Final Appendices (Appendix I) December 17. Sacramento, CA.

____. 2004c. Lower Colorado River Multi-Species Conservation Program, Final Programmatic Impact Statement/Environmental Impact Report: Volume I, December 17.

2011 Final Environmental Assessment for the Laguna Division Conservation Area Yuma County, Arizona and Imperial County, California. February.

U.S. Fish and Wildlife Service ___. 2002. Final recovery plan for the southwestern willow flycatcher (Empidonax traillii extimus). Albuquerque, NM: Region 2.

___. 2012. http://www.fws.gov/carlsbad/Tespecies.html

___. 2012. http://www.fws.gov/southwest/es/arizona/Threatened.htm

https://www.fws.gov/refuge/Cibola/visit/visitor_activities.html

https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=B06R

U.S. Geological Survey - https://pubs.usgs.gov/of/2005/1075/report.pdf

http://www.walterscamp.com/activities/

APPENDIX A

CORRESPONDENCE

OFFICIAL FILE CO oYAO RECEIVED DATE NOV 272015 IMH Code ~ O~) Control No. Sc) ~L Fo’der No. 12 ~ Project Name/No.

Cu)4-uvc~t (~e~xiR-Ce≤ S ~ ~2U______‘~7fl~’4f~ ~ ~ PRESERVATION OH9U~ United States Department of the Interior BUREAU OF RECLAMATION Lower Colorado Region Yuma Area Office ~ \Y/~ 7301 Calle Agua Salada ~~—~-1 IN REPLY REFER TO: Yuma, AZ 85364 NOV 0 92015

nr~t n ‘~ni A1~i~ STATE HI~1~IC YAO-7210 LJi.J U LUI _fRESERVAT1ONOFFIC~ ENV-3 .00

CERTIFIED — RETURN RECEIPT REQUESTED (70142120000185137514)

Mr. James Garrison State Historic Preservation Office Arizona State Parks 1300 West Washington Phoenix, AZ 85007

Subject: Consultation Under Section 106 of the National Historic Preservation Act for the Installation of a Pipeline for the Cibola Cut Old Channel Reconstruction Project in La Paz County, Arizona

Dear Mr. Garrison:

The Bureau of Reclamation’s Yuma Area Office is planning to install a pipeline to enhance water flow through the lower section of the old Cibola channel in order to improve water circulation and fish and wildlife resources. The old river channel used to be the main channel in this reach of the Colorado River (see Figure 1). It was by passed in the late 1960’s and early 1970’s when Reclamation channelized the Colorado River to its present course. Channelization of the river in the Palo Verde and Cibola Valley Divisions was part of a program to alleviate the river bed, scouring, and river meander, thereby reducing the sediment load that was being carried downstream to the reservoir behind Imperial Dam. Channelization prevented the inherent danger of the river making a major change during flood flows. The old river channel was developed as a side channel and backwater to create habitat for fish and wildlife. To ensure the old river channel was not isolated from the newly formed channel, porous (permeable) rock structures were placed at the top inlet area to ensure flow would continue through the old channel. Over time, flows through the old river channel have been reduced primarily due to changes in Colorado River hydrology as a result of improved water conservation practices and drought conditions in the watershed. The new pipeline will allow Reclamation to increase water flow through the old channel to improve the ability to flush out sediment deposition and provide fresh water in this section of the old river channel. The project area is located within the Cibola National Wildlife Refuge at Township 2 South, Range 23 West, Section 18 (USGS Cibola Quad) (see Figures 1 and 2).

The undertaking involves the installation of two 42-inch diameter by 1,180-foot long pipes that would be placed in an 18-foot wide trench excavated to an average depth of 6 feet below the existing ground surface. A minimum of 2-feet of cover fill will be placed over the pipe. The project area of potential effect (APE) is a corridor 200 feet wide by 1,180 feet long (approximately 6 acres).

Reclamation conducted a Class I survey (file and record search) and there are no known cultural resource sites in the APE. Furthermore, the expectation for the discovery of new cultural resources in the project area is very low. The APE is located in the historic floodplain of the Colorado River which, prior to Reclamation’s Colorado River channelization project, was subject to severe seasonal flooding. In addition, approximately 90 percent of the APE is located in the construction footprint of the 2 channelization project area (see Figure 3). Because of the low expectation for the discovery of new cultural recourses and the high amount of previous ground disturbance in the APE, a Class III survey was not conducted.

No historic properties are located in the APE. Therefore, Reclamation has made a finding of No Historic Properties Affected for the undertaking. If during the course of any activities associated with this undertaking, any districts, sites, buildings, structures, or objects are discovered, activities will cease in the vicinity of the resource. Reclamation shall ensure that the stipulations of 36 CFR Part 800.13 are satisfied before activities in the vicinity of the previously unidentified property resume.

If you have questions or concerns regarding the undertaking please contact Mr. James Kangas, Archaeologist, at 702-293-8392 orjkangas~usbr.gov within 30 days of receiving this letter.

Sincerely,

Maria Ramirez Area Manager cc: Ms. Elaine Johnson U.S. Fish and Wildlife Service Southwest Arizona Refuge /~~P~1421/’~~ Complex Headquarters ~1 ~J)4/’~~4~li 9300 East 28th Street Yuma, AZ 85365 ‘~~A~2t (w/encls)

Mr. Curt Kessler Refuge Manger Cibola National Wildlife Refuge Arizona State Historic Preservation 6~’fice 66600 Cibola Lake Road Route 2, Box 1 Cibola, AZ 853 28-9002 (w/encls)

LC-263 I (Kangas) (w/o ends)

APPENDIX B

WATER QUALITY MONITORING REPORT Nicklaus Engineering, Inc.  Civil  Survey  Architecture 8(a)  SDB  EDWOSB  Environmental  Geotechnical

August 15, 2018

Bryon Green Environmental Compliance Emergency Management U.S. Department of the Interior Bureau of Reclamation 7301 Calle Agua Salada Yuma, AZ 85364 [email protected]

RE: Bureau of Reclamation Walters Camp River Sampling

Dear Mr. Green, Nicklaus Engineering, Inc. (NEI) is pleased to present this letter documenting the sampling that was conducted on July 25, 2018. NEI collected a total of four (4) composite samples, with two (2) samples from the Old Cibola Canal and Two (2) samples from the Colorado River. Samples were collected in a way to be representative of a cross section of the river. Field analysis was conducted for dissolved oxygen, pH, salinity, conductivity, temperature, alkalinity and turbidity. Field notes are included as Attachment A. Laboratory analysis was conducted for selenium, total phosphorus, total nitrogen, carbamates, chlorophenoxy herbicides and glyphosate. One (1) duplicate sample was also collected for quality control. The resulting analytical is included as Attachment B. Please let me know if you have any questions or concerns.

Sincerely,

______Nick Breshears, EIT Environmental Professional

Nicklaus Engineering, Inc. 1851 W. 24th Street, Suite 101, Yuma, AZ 85364 Ph: (928) 344-8374 Fax: (928) 726-6994 www.neiaw.com

N:\2018\018-0102 Colorado River Sampling at Walters Camp\BOR River Sampling Summary 8-15-2018.docx

Attachment A River Sample Logs Date: 7/25/2018 Time: 10:10 AM Project: BOR River Sampling Job # 018-0102 Sample ID: River #1

Sampler: Nick Breshears Sample coordinates: 33° 15' 10.98" N 114° 40' 10.56" W

Cross Section Information Point 1 Point 2 Point 3 Point 4 Depth Of Water 8.3' 7.6' 7.4' Notes: Samples start from the South East Bank Depth of Pump 4.0' 3.5' 3.5' Purge Log Parameters Time Electrical Dissolved Flow Alkalinity Turbidity Purged Temp(°C) pH Conductivity Salinity Oxygen Comments (Gal/Min) (PPM) (NTU) (Min) (mS/cm) (mg/L) 5 Min 1 30.83 9.54 110 1.02 <1% 0 8.48

Date: 7/25/2018 Time: 11:15 AM Project: BOR River Sampling Job # 018-0102 Sample ID: River #2

Sampler: Nick Breshears Sample coordinates: 33° 13' 40.68" N 114° 40' 36.84" W

Cross Section Information Point 1 Point 2 Point 3 Point 4 Depth Of Water 14' 6.6' 5.4 Notes: Samples start at the west Bank Depth of Pump 7' 3.0' 3.0' Purge Log Parameters Time Flow Alkalinity Electrical Turbidity Dissolved Temp(°C) pH Salinity Comments Purged (Gal/Min) (PPM) Conductivity (NTU) Oxygen 5 Min 1 31.95 9.47 144 1.01 <1% 0.2 7.26 River Sample Logs Date: 7/25/2018 Time:8:20 AM Project: BOR River Sampling Job # 018-0102 Sample ID: Old Cibola Canal #1

Sampler: Nick Breshears Sample coordinates: 33° 15' 19.14" N 114° 40' 26.04" W

Cross Section Information Point 1 Point 2 Point 3 Point 4 Depth Of Water 7.1' 5.9' 5.7' 6.0' Notes: Samples start from the South East Bank Depth of Pump 3.5' 3.0' 3.0' 3.0' Purge Log Parameters Time Electrical Dissolved Flow Alkalinity Turbidity Purged Temp(°C) pH Conductivity Salinity Oxygen Comments (Gal/Min) (PPM) (NTU) (Min) (mS/cm) (mg/L) 5 Min 1 30.68 9.22 320 2.11 <1% 9 3.88

Date: 7/25/2018 Time: 9:11 AM Project: BOR River Sampling Job # 018-0102 Sample ID: Old Cibola Canal #2

Sampler: Nick Breshears Sample coordinates: 33° 14' 41.94" N 114° 41' 22.20" W

Cross Section Information Point 1 Point 2 Point 3 Point 4 Depth Of Water 11.3' 7' 5.5' Notes: Samples start at the west Bank Depth of Pump 5.5' 3.5' 3.5' Purge Log Parameters Time Electrical Dissolved Flow Alkalinity Turbidity Purged Temp(°C) pH Conductivity Salinity Oxygen Comments (Gal/Min) (PPM) (NTU) (Min) (mS/cm) (mg/L) 5 Min 1 30.68 9.21 260 2.14 <1% 7.8 4.42 Image Provided By NEI Environmental

Boundaries are approximate

SAMPLE LOCATIONS BOR BOR Colorado River Walters, Camp 8/15/2018 Attachment B

1 2 3 4 5 ANALYTICAL REPORT 6 TestAmerica Laboratories, Inc. TestAmerica Phoenix 7 4625 East Cotton Ctr Blvd Suite 189 8 Phoenix, AZ 85040 Tel: (602)437-3340 9 TestAmerica Job ID: 550-106698-1 10 TestAmerica Sample Delivery Group: Pit Client Project/Site: 018-103 11 For: 12 Nicklaus Engineering 1851 W 24th Street 13 Yuma, Arizona 85365 14 Attn: Eric Gardner

Authorized for release by: 8/7/2018 10:11:02 PM Rachel Sester, Project Manager I [email protected] Designee for Urvashi Patel, Manager of Project Management (949)261-1022 [email protected]

This report has been electronically signed and authorized by the signatory. Electronic signature is intended to be the legally binding equivalent of a traditionally handwritten signature.

Results relate only to the items tested and the sample(s) as received by the laboratory. Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 1 Project/Site: 018-103 SDG: Pit 2 Table of Contents Cover Page ...... 1 3 Table of Contents ...... 2 4 3 Definitions/Glossary ...... 5 Case Narrative ...... 4 Sample Summary ...... 5 6 Detection Summary ...... 6 7 Client Sample Results ...... 7 8 QC Sample Results ...... 11 QC Association Summary ...... 17 9 Lab Chronicle ...... 20 10 Certification Summary ...... 22 Method Summary ...... 24 11 Chain of Custody ...... 25 12 Receipt Checklists ...... 27 13 14

TestAmerica Phoenix Page 2 of 28 8/7/2018 Definitions/Glossary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Qualifiers 3 General Chemistry 4 Qualifier Qualifier Description E2 Concentration estimated. Analyte exceeded calibration range. Reanalysis not performed due to sample matrix. M1 Matrix spike recovery was high, the associated blank spike recovery was acceptable. 5

Glossary 6

Abbreviation These commonly used abbreviations may or may not be present in this report. 7 ¤ Listed under the "D" column to designate that the result is reported on a dry weight basis %R Percent Recovery 8 CFL Contains Free Liquid CNF Contains No Free Liquid 9 DER Duplicate Error Ratio (normalized absolute difference) Dil Fac Dilution Factor 10 DL Detection Limit (DoD/DOE) DL, RA, RE, IN Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample 11 DLC Decision Level Concentration (Radiochemistry) EDL Estimated Detection Limit (Dioxin) LOD Limit of Detection (DoD/DOE) 12 LOQ Limit of Quantitation (DoD/DOE) MDA Minimum Detectable Activity (Radiochemistry) 13 MDC Minimum Detectable Concentration (Radiochemistry) MDL Method Detection Limit 14 ML Minimum Level (Dioxin) NC Not Calculated ND Not Detected at the reporting limit (or MDL or EDL if shown) PQL Practical Quantitation Limit QC Quality Control RER Relative Error Ratio (Radiochemistry) RL Reporting Limit or Requested Limit (Radiochemistry) RPD Relative Percent Difference, a measure of the relative difference between two points TEF Toxicity Equivalent Factor (Dioxin) TEQ Toxicity Equivalent Quotient (Dioxin)

TestAmerica Phoenix

Page 3 of 28 8/7/2018 Case Narrative 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Job ID: 550-106698-1 3 Laboratory: TestAmerica Phoenix 4 Narrative Job Narrative 5 550-106698-1 6 Comments No additional comments. 7 Receipt The samples were received on 7/26/2018 7:40 AM; the samples arrived in good condition, properly preserved and, where required, on ice. 8 The temperature of the cooler at receipt was 2.3º C. 9 Receipt Exceptions 10 Method(s) 531.1 LL: One or more containers for the following samples were received broken or leaking: Old Cibola Canal #1 (550-106698-1), Old Cibola Canal #2 (550-106698-2), River #1 (550-106698-3), River #3 (550-106698-4) and River #2 (550-106698-5). 11 HPLC/IC No analytical or quality issues were noted, other than those described in the Definitions/Glossary page. 12

Metals 13 No analytical or quality issues were noted, other than those described in the Definitions/Glossary page. 14 General Chemistry No analytical or quality issues were noted, other than those described in the Definitions/Glossary page.

TestAmerica Phoenix Page 4 of 28 8/7/2018 Sample Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 3 Lab Sample ID Client Sample ID Matrix Collected Received 550-106698-1 Old Cibola Canal #1 Water 07/25/18 08:20 07/26/18 07:40 550-106698-2 Old Cibola Canal #2 Water 07/25/18 09:11 07/26/18 07:40 4 550-106698-3 River #1 Water 07/25/18 10:10 07/26/18 07:40 550-106698-4 River #3 Water 07/25/18 10:45 07/26/18 07:40 5 550-106698-5 River #2 Water 07/25/18 11:15 07/26/18 07:40 6 7 8 9 10 11 12 13 14

TestAmerica Phoenix

Page 5 of 28 8/7/2018 Detection Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: Old Cibola Canal #1 Lab Sample ID: 550-106698-1 3 Analyte Result Qualifier RL MDL Unit Dil Fac D Method Prep Type 4 Nitrate as N 0.25 0.10 mg/L 1 300.0 Total/NA Selenium 1.0 0.50 ug/L 1 200.8 LL Total/NA Nitrogen, Kjeldahl 0.66 0.50 mg/L 1 351.2 Total/NA 5 Analyte Result Qualifier RL RL Unit Dil Fac D Method Prep Type Nitrogen, Total 0.91 0.10 mg/L 1 Total Nitrogen Total/NA 6 7 Client Sample ID: Old Cibola Canal #2 Lab Sample ID: 550-106698-2

Analyte Result Qualifier RL MDL Unit Dil Fac D Method Prep Type 8 Nitrate as N 0.23 0.10 mg/L 1 300.0 Total/NA Selenium 0.98 0.50 ug/L 1 200.8 LL Total/NA 9 Nitrogen, Kjeldahl 0.56 0.50 mg/L 1 351.2 Total/NA Analyte Result Qualifier RL RL Unit Dil Fac D Method Prep Type 10 Nitrogen, Total 0.79 0.10 mg/L 1 Total Nitrogen Total/NA 11 Client Sample ID: River #1 Lab Sample ID: 550-106698-3 12 Analyte Result Qualifier RL MDL Unit Dil Fac D Method Prep Type Nitrate as N 0.26 0.10 mg/L 1 300.0 Total/NA 13 Selenium 1.6 0.50 ug/L 1 200.8 LL Total/NA Nitrogen, Kjeldahl 0.54 0.50 mg/L 1 351.2 Total/NA 14 Analyte Result Qualifier RL RL Unit Dil Fac D Method Prep Type Nitrogen, Total 0.80 0.10 mg/L 1 Total Nitrogen Total/NA

Client Sample ID: River #3 Lab Sample ID: 550-106698-4

Analyte Result Qualifier RL MDL Unit Dil Fac D Method Prep Type Nitrate as N 0.26 0.10 mg/L 1 300.0 Total/NA Selenium 1.6 0.50 ug/L 1 200.8 LL Total/NA Nitrogen, Kjeldahl 0.60 0.50 mg/L 1 351.2 Total/NA Analyte Result Qualifier RL RL Unit Dil Fac D Method Prep Type Nitrogen, Total 0.86 0.10 mg/L 1 Total Nitrogen Total/NA

Client Sample ID: River #2 Lab Sample ID: 550-106698-5

Analyte Result Qualifier RL MDL Unit Dil Fac D Method Prep Type Nitrate as N 0.27 0.10 mg/L 1 300.0 Total/NA Selenium 1.3 0.50 ug/L 1 200.8 LL Total/NA Nitrogen, Kjeldahl 0.51 0.50 mg/L 1 351.2 Total/NA Analyte Result Qualifier RL RL Unit Dil Fac D Method Prep Type Nitrogen, Total 0.78 0.10 mg/L 1 Total Nitrogen Total/NA

This Detection Summary does not include radiochemical test results. TestAmerica Phoenix

Page 6 of 28 8/7/2018 Client Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: Old Cibola Canal #1 Lab Sample ID: 550-106698-1 3 Date Collected: 07/25/18 08:20 Matrix: Water Date Received: 07/26/18 07:40 4 Method: 300.0 - Anions, Ion Chromatography Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 5 Nitrate as N 0.25 0.10 mg/L 07/26/18 23:09 1 Nitrite as N ND 0.10 mg/L 07/26/18 23:09 1 6 Method: 531.1 LL - Carbamate Pesticides (HPLC) 7 Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 3-Hydroxycarbofuran ND 2.5 ug/L 07/31/18 00:58 1 8 Aldicarb ND 2.5 ug/L 07/31/18 00:58 1 Aldicarb sulfone ND 2.5 ug/L 07/31/18 00:58 1 Aldicarb sulfoxide ND 2.5 ug/L 07/31/18 00:58 1 9 Carbaryl ND 2.5 ug/L 07/31/18 00:58 1 Carbofuran ND 0.90 ug/L 07/31/18 00:58 1 10 Methiocarb ND 2.5 ug/L 07/31/18 00:58 1 Methomyl ND 2.5 ug/L 07/31/18 00:58 1 11 Oxamyl ND 2.0 ug/L 07/31/18 00:58 1 Propoxur ND 2.5 ug/L 07/31/18 00:58 1 12 Method: 547 LL - Glyphosate (DAI HPLC) 13 Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Glyphosate ND 6.0 ug/L 07/30/18 20:51 1 14 Method: 200.8 LL - Metals (ICP/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Selenium 1.0 0.50 ug/L 07/29/18 10:44 08/01/18 15:41 1

General Chemistry Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl 0.66 0.50 mg/L 07/29/18 15:35 07/31/18 14:36 1 Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1 Analyte Result Qualifier RL RL Unit D Prepared Analyzed Dil Fac Nitrogen, Total 0.91 0.10 mg/L 07/31/18 17:03 1

Client Sample ID: Old Cibola Canal #2 Lab Sample ID: 550-106698-2 Date Collected: 07/25/18 09:11 Matrix: Water Date Received: 07/26/18 07:40

Method: 300.0 - Anions, Ion Chromatography Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrate as N 0.23 0.10 mg/L 07/26/18 23:37 1 Nitrite as N ND 0.10 mg/L 07/26/18 23:37 1

Method: 531.1 LL - Carbamate Pesticides (HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 3-Hydroxycarbofuran ND 2.5 ug/L 07/31/18 01:28 1 Aldicarb ND 2.5 ug/L 07/31/18 01:28 1 Aldicarb sulfone ND 2.5 ug/L 07/31/18 01:28 1 Aldicarb sulfoxide ND 2.5 ug/L 07/31/18 01:28 1 Carbaryl ND 2.5 ug/L 07/31/18 01:28 1 Carbofuran ND 0.90 ug/L 07/31/18 01:28 1 Methiocarb ND 2.5 ug/L 07/31/18 01:28 1 Methomyl ND 2.5 ug/L 07/31/18 01:28 1

TestAmerica Phoenix

Page 7 of 28 8/7/2018 Client Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: Old Cibola Canal #2 Lab Sample ID: 550-106698-2 Date Collected: 07/25/18 09:11 Matrix: Water 3 Date Received: 07/26/18 07:40 4 Method: 531.1 LL - Carbamate Pesticides (HPLC) (Continued) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 5 Oxamyl ND 2.0 ug/L 07/31/18 01:28 1 Propoxur ND 2.5 ug/L 07/31/18 01:28 1 6 Method: 547 LL - Glyphosate (DAI HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 7 Glyphosate ND 6.0 ug/L 07/30/18 21:49 1 8 Method: 200.8 LL - Metals (ICP/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 9 Selenium 0.98 0.50 ug/L 07/29/18 10:44 08/01/18 15:48 1 10 General Chemistry Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl 0.56 0.50 mg/L 07/29/18 15:35 07/31/18 14:39 1 11 Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1 12 Analyte Result Qualifier RL RL Unit D Prepared Analyzed Dil Fac Nitrogen, Total 0.79 0.10 mg/L 07/31/18 17:03 1 13 Client Sample ID: River #1 Lab Sample ID: 550-106698-3 Date Collected: 07/25/18 10:10 Matrix: Water 14 Date Received: 07/26/18 07:40

Method: 300.0 - Anions, Ion Chromatography Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrate as N 0.26 0.10 mg/L 07/27/18 00:04 1 Nitrite as N ND 0.10 mg/L 07/27/18 00:04 1

Method: 531.1 LL - Carbamate Pesticides (HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 3-Hydroxycarbofuran ND 2.5 ug/L 07/31/18 01:58 1 Aldicarb ND 2.5 ug/L 07/31/18 01:58 1 Aldicarb sulfone ND 2.5 ug/L 07/31/18 01:58 1 Aldicarb sulfoxide ND 2.5 ug/L 07/31/18 01:58 1 Carbaryl ND 2.5 ug/L 07/31/18 01:58 1 Carbofuran ND 0.90 ug/L 07/31/18 01:58 1 Methiocarb ND 2.5 ug/L 07/31/18 01:58 1 Methomyl ND 2.5 ug/L 07/31/18 01:58 1 Oxamyl ND 2.0 ug/L 07/31/18 01:58 1 Propoxur ND 2.5 ug/L 07/31/18 01:58 1

Method: 547 LL - Glyphosate (DAI HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Glyphosate ND 6.0 ug/L 07/30/18 22:08 1

Method: 200.8 LL - Metals (ICP/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Selenium 1.6 0.50 ug/L 07/29/18 10:44 08/01/18 15:50 1

General Chemistry Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl 0.54 0.50 mg/L 07/29/18 15:35 07/31/18 14:41 1

TestAmerica Phoenix

Page 8 of 28 8/7/2018 Client Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: River #1 Lab Sample ID: 550-106698-3 Date Collected: 07/25/18 10:10 Matrix: Water 3 Date Received: 07/26/18 07:40 4 General Chemistry (Continued) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 5 Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1 Analyte Result Qualifier RL RL Unit D Prepared Analyzed Dil Fac 6 Nitrogen, Total 0.80 0.10 mg/L 07/31/18 17:03 1 7 Client Sample ID: River #3 Lab Sample ID: 550-106698-4 Date Collected: 07/25/18 10:45 Matrix: Water 8 Date Received: 07/26/18 07:40 9 Method: 300.0 - Anions, Ion Chromatography Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrate as N 0.26 0.10 mg/L 07/27/18 00:32 1 10 Nitrite as N ND 0.10 mg/L 07/27/18 00:32 1 11 Method: 531.1 LL - Carbamate Pesticides (HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 12 3-Hydroxycarbofuran ND 2.5 ug/L 07/31/18 02:28 1 Aldicarb ND 2.5 ug/L 07/31/18 02:28 1 13 Aldicarb sulfone ND 2.5 ug/L 07/31/18 02:28 1 Aldicarb sulfoxide ND 2.5 ug/L 07/31/18 02:28 1 14 Carbaryl ND 2.5 ug/L 07/31/18 02:28 1 Carbofuran ND 0.90 ug/L 07/31/18 02:28 1 Methiocarb ND 2.5 ug/L 07/31/18 02:28 1 Methomyl ND 2.5 ug/L 07/31/18 02:28 1 Oxamyl ND 2.0 ug/L 07/31/18 02:28 1 Propoxur ND 2.5 ug/L 07/31/18 02:28 1

Method: 547 LL - Glyphosate (DAI HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Glyphosate ND 6.0 ug/L 07/30/18 22:27 1

Method: 200.8 LL - Metals (ICP/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Selenium 1.6 0.50 ug/L 07/29/18 10:44 08/01/18 15:52 1

General Chemistry Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl 0.60 0.50 mg/L 07/29/18 15:35 07/31/18 14:44 1 Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1 Analyte Result Qualifier RL RL Unit D Prepared Analyzed Dil Fac Nitrogen, Total 0.86 0.10 mg/L 07/31/18 17:03 1

Client Sample ID: River #2 Lab Sample ID: 550-106698-5 Date Collected: 07/25/18 11:15 Matrix: Water Date Received: 07/26/18 07:40

Method: 300.0 - Anions, Ion Chromatography Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrate as N 0.27 0.10 mg/L 07/27/18 00:59 1 Nitrite as N ND 0.10 mg/L 07/27/18 00:59 1

TestAmerica Phoenix

Page 9 of 28 8/7/2018 Client Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: River #2 Lab Sample ID: 550-106698-5 Date Collected: 07/25/18 11:15 Matrix: Water 3 Date Received: 07/26/18 07:40 4 Method: 531.1 LL - Carbamate Pesticides (HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 5 3-Hydroxycarbofuran ND 2.5 ug/L 07/31/18 02:58 1 Aldicarb ND 2.5 ug/L 07/31/18 02:58 1 6 Aldicarb sulfone ND 2.5 ug/L 07/31/18 02:58 1 Aldicarb sulfoxide ND 2.5 ug/L 07/31/18 02:58 1 7 Carbaryl ND 2.5 ug/L 07/31/18 02:58 1 Carbofuran ND 0.90 ug/L 07/31/18 02:58 1 8 Methiocarb ND 2.5 ug/L 07/31/18 02:58 1 Methomyl ND 2.5 ug/L 07/31/18 02:58 1 Oxamyl ND 2.0 ug/L 07/31/18 02:58 1 9 Propoxur ND 2.5 ug/L 07/31/18 02:58 1 10 Method: 547 LL - Glyphosate (DAI HPLC) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 11 Glyphosate ND 6.0 ug/L 07/30/18 22:46 1 12 Method: 200.8 LL - Metals (ICP/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Selenium 1.3 0.50 ug/L 07/29/18 10:44 08/01/18 15:55 1 13

General Chemistry 14 Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl 0.51 0.50 mg/L 07/29/18 15:35 07/31/18 14:46 1 Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1 Analyte Result Qualifier RL RL Unit D Prepared Analyzed Dil Fac Nitrogen, Total 0.78 0.10 mg/L 07/31/18 17:03 1

TestAmerica Phoenix

Page 10 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: 300.0 - Anions, Ion Chromatography 3 Lab Sample ID: MB 550-152699/2 Client Sample ID: Method Blank 4 Matrix: Water Prep Type: Total/NA Analysis Batch: 152699 MB MB 5 Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrate as N ND 0.10 mg/L 07/26/18 14:56 1 6 Nitrite as N ND 0.10 mg/L 07/26/18 14:56 1 7 Lab Sample ID: LCS 550-152699/5 Client Sample ID: Lab Control Sample Matrix: Water Prep Type: Total/NA 8 Analysis Batch: 152699 Spike LCS LCS %Rec. 9 Analyte Added Result Qualifier Unit D %Rec Limits Nitrate as N 4.00 4.07 mg/L 102 90 - 110 10 Nitrite as N 4.00 4.23 mg/L 106 90 - 110

Lab Sample ID: LCSD 550-152699/6 Client Sample ID: Lab Control Sample Dup 11 Matrix: Water Prep Type: Total/NA Analysis Batch: 152699 12 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit 13 Nitrate as N 4.00 4.08 mg/L 102 90 - 110 0 20 Nitrite as N 4.00 4.23 mg/L 106 90 - 110 0 20 14 Lab Sample ID: 550-106716-B-1 MS Client Sample ID: Matrix Spike Matrix: Water Prep Type: Total/NA Analysis Batch: 152699 Sample Sample Spike MS MS %Rec. Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits Nitrate as N 2.7 4.00 6.80 mg/L 102 80 - 120 Nitrite as N ND 4.00 4.24 mg/L 106 80 - 120

Lab Sample ID: 550-106716-B-1 MSD Client Sample ID: Matrix Spike Duplicate Matrix: Water Prep Type: Total/NA Analysis Batch: 152699 Sample Sample Spike MSD MSD %Rec. RPD Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit Nitrate as N 2.7 4.00 6.80 mg/L 102 80 - 120 0 20 Nitrite as N ND 4.00 4.25 mg/L 106 80 - 120 0 20

Method: 531.1 LL - Carbamate Pesticides (HPLC)

Lab Sample ID: MB 680-533396/11 Client Sample ID: Method Blank Matrix: Water Prep Type: Total/NA Analysis Batch: 533396 MB MB Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 3-Hydroxycarbofuran ND 2.5 ug/L 07/30/18 15:28 1 Aldicarb ND 2.5 ug/L 07/30/18 15:28 1 Aldicarb sulfone ND 2.5 ug/L 07/30/18 15:28 1 Aldicarb sulfoxide ND 2.5 ug/L 07/30/18 15:28 1 Carbaryl ND 2.5 ug/L 07/30/18 15:28 1 Carbofuran ND 0.90 ug/L 07/30/18 15:28 1 Methiocarb ND 2.5 ug/L 07/30/18 15:28 1

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Page 11 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: 531.1 LL - Carbamate Pesticides (HPLC) (Continued) 3 Lab Sample ID: MB 680-533396/11 Client Sample ID: Method Blank Matrix: Water Prep Type: Total/NA 4 Analysis Batch: 533396 MB MB 5 Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Methomyl ND 2.5 ug/L 07/30/18 15:28 1 6 Oxamyl ND 2.0 ug/L 07/30/18 15:28 1 Propoxur ND 2.5 ug/L 07/30/18 15:28 1 7 Lab Sample ID: LCS 680-533396/12 Client Sample ID: Lab Control Sample 8 Matrix: Water Prep Type: Total/NA Analysis Batch: 533396 Spike LCS LCS %Rec. 9 Analyte Added Result Qualifier Unit D %Rec Limits 3-Hydroxycarbofuran 10.0 11.0 ug/L 110 80 - 120 10 Aldicarb 10.0 10.6 ug/L 106 80 - 120 Aldicarb sulfone 10.0 9.82 ug/L 98 80 - 120 11 Aldicarb sulfoxide 10.0 9.62 ug/L 96 80 - 120 Carbaryl 10.0 10.9 ug/L 109 80 - 120 12 Carbofuran 10.0 10.7 ug/L 107 80 - 120 Methiocarb 10.0 10.9 ug/L 109 80 - 120 13 Methomyl 10.0 10.7 ug/L 107 80 - 120 Oxamyl 10.0 10.5 ug/L 105 80 - 120 14 Propoxur 10.0 10.5 ug/L 105 80 - 120

Lab Sample ID: LCSD 680-533396/13 Client Sample ID: Lab Control Sample Dup Matrix: Water Prep Type: Total/NA Analysis Batch: 533396 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit 3-Hydroxycarbofuran 10.0 11.9 ug/L 119 80 - 120 8 20 Aldicarb 10.0 11.3 ug/L 113 80 - 120 6 20 Aldicarb sulfone 10.0 10.8 ug/L 108 80 - 120 10 20 Aldicarb sulfoxide 10.0 10.6 ug/L 106 80 - 120 10 20 Carbaryl 10.0 12.0 ug/L 120 80 - 120 10 20 Carbofuran 10.0 11.2 ug/L 112 80 - 120 4 20 Methiocarb 10.0 10.9 ug/L 109 80 - 120 0 20 Methomyl 10.0 11.5 ug/L 115 80 - 120 7 20 Oxamyl 10.0 11.3 ug/L 113 80 - 120 8 20 Propoxur 10.0 11.6 ug/L 116 80 - 120 10 20

Lab Sample ID: 550-106638-I-1 MS Client Sample ID: Matrix Spike Matrix: Water Prep Type: Total/NA Analysis Batch: 533396 Sample Sample Spike MS MS %Rec. Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits 3-Hydroxycarbofuran ND M2 10.0 10.7 ug/L 107 65 - 135 Aldicarb ND M2 10.0 10.4 ug/L 104 65 - 135 Aldicarb sulfone ND M2 10.0 9.57 ug/L 96 65 - 135 Aldicarb sulfoxide ND M2 10.0 9.21 ug/L 92 65 - 135 Carbaryl ND M2 10.0 10.5 ug/L 105 65 - 135 Carbofuran ND M2 10.0 10.3 ug/L 103 65 - 135 Methiocarb ND M2 10.0 11.1 ug/L 111 65 - 135 Methomyl ND M2 10.0 10.6 ug/L 106 65 - 135

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Page 12 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: 531.1 LL - Carbamate Pesticides (HPLC) (Continued) 3 Lab Sample ID: 550-106638-I-1 MS Client Sample ID: Matrix Spike Matrix: Water Prep Type: Total/NA 4 Analysis Batch: 533396 Sample Sample Spike MS MS %Rec. 5 Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits Oxamyl ND M2 10.0 10.2 ug/L 102 65 - 135 6 Propoxur ND M2 10.0 10.8 ug/L 108 65 - 135 7 Lab Sample ID: 550-106638-I-1 MSD Client Sample ID: Matrix Spike Duplicate Matrix: Water Prep Type: Total/NA 8 Analysis Batch: 533396 Sample Sample Spike MSD MSD %Rec. RPD Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit 9 3-Hydroxycarbofuran ND M2 10.0 11.7 ug/L 117 65 - 135 9 35 Aldicarb ND M2 10.0 11.1 ug/L 111 65 - 135 6 35 10 Aldicarb sulfone ND M2 10.0 10.4 ug/L 104 65 - 135 8 35 Aldicarb sulfoxide ND M2 10.0 10.1 ug/L 101 65 - 135 9 35 11 Carbaryl ND M2 10.0 11.8 ug/L 118 65 - 135 11 35 Carbofuran ND M2 10.0 11.2 ug/L 112 65 - 135 9 35 12 Methiocarb ND M2 10.0 11.1 ug/L 111 65 - 135 0 35 Methomyl ND M2 10.0 11.0 ug/L 110 65 - 135 4 35 13 Oxamyl ND M2 10.0 10.8 ug/L 108 65 - 135 5 35 Propoxur ND M2 10.0 11.5 ug/L 115 65 - 135 5 35 14

Method: 547 LL - Glyphosate (DAI HPLC)

Lab Sample ID: MB 680-533471/2 Client Sample ID: Method Blank Matrix: Water Prep Type: Total/NA Analysis Batch: 533471 MB MB Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Glyphosate ND 6.0 ug/L 07/30/18 14:48 1

Lab Sample ID: LCS 680-533471/3 Client Sample ID: Lab Control Sample Matrix: Water Prep Type: Total/NA Analysis Batch: 533471 Spike LCS LCS %Rec. Analyte Added Result Qualifier Unit D %Rec Limits Glyphosate 200 205 ug/L 102 80 - 120

Lab Sample ID: LCSD 680-533471/4 Client Sample ID: Lab Control Sample Dup Matrix: Water Prep Type: Total/NA Analysis Batch: 533471 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit Glyphosate 200 203 ug/L 101 80 - 120 1 20

Lab Sample ID: 550-106698-1 MS Client Sample ID: Old Cibola Canal #1 Matrix: Water Prep Type: Total/NA Analysis Batch: 533471 Sample Sample Spike MS MS %Rec. Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits Glyphosate ND 200 219 ug/L 110 80 - 120

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Page 13 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: 547 LL - Glyphosate (DAI HPLC) (Continued) 3 Lab Sample ID: 550-106698-1 MSD Client Sample ID: Old Cibola Canal #1 4 Matrix: Water Prep Type: Total/NA Analysis Batch: 533471 Sample Sample Spike MSD MSD %Rec. RPD 5 Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit Glyphosate ND 200 210 ug/L 105 80 - 120 4 20 6

Method: 200.8 LL - Metals (ICP/MS) 7

Lab Sample ID: MB 550-152822/1-A Client Sample ID: Method Blank 8 Matrix: Water Prep Type: Total/NA Analysis Batch: 153094 Prep Batch: 152822 9 MB MB Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac 10 Selenium ND 0.50 ug/L 07/29/18 10:44 08/01/18 15:34 1 11 Lab Sample ID: LCS 550-152822/2-A Client Sample ID: Lab Control Sample Matrix: Water Prep Type: Total/NA Analysis Batch: 153094 Prep Batch: 152822 12 Spike LCS LCS %Rec. Analyte Added Result Qualifier Unit D %Rec Limits 13 Selenium 100 102 ug/L 102 85 - 115 14 Lab Sample ID: LCSD 550-152822/3-A Client Sample ID: Lab Control Sample Dup Matrix: Water Prep Type: Total/NA Analysis Batch: 153094 Prep Batch: 152822 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit Selenium 100 103 ug/L 103 85 - 115 1 20

Lab Sample ID: 550-106698-1 MS Client Sample ID: Old Cibola Canal #1 Matrix: Water Prep Type: Total/NA Analysis Batch: 153094 Prep Batch: 152822 Sample Sample Spike MS MS %Rec. Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits Selenium 1.0 100 108 ug/L 107 70 - 130

Lab Sample ID: 550-106698-1 MSD Client Sample ID: Old Cibola Canal #1 Matrix: Water Prep Type: Total/NA Analysis Batch: 153094 Prep Batch: 152822 Sample Sample Spike MSD MSD %Rec. RPD Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit Selenium 1.0 100 104 ug/L 103 70 - 130 4 20

Method: 351.2 - Nitrogen, Total Kjeldahl

Lab Sample ID: MB 550-152829/35-A Client Sample ID: Method Blank Matrix: Water Prep Type: Total/NA Analysis Batch: 152994 Prep Batch: 152829 MB MB Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Nitrogen, Kjeldahl ND 0.50 mg/L 07/29/18 15:35 07/31/18 14:11 1

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Page 14 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: 351.2 - Nitrogen, Total Kjeldahl (Continued) 3 Lab Sample ID: LCS 550-152829/36-A Client Sample ID: Lab Control Sample 4 Matrix: Water Prep Type: Total/NA Analysis Batch: 152994 Prep Batch: 152829 Spike LCS LCS %Rec. 5 Analyte Added Result Qualifier Unit D %Rec Limits Nitrogen, Kjeldahl 10.0 9.94 mg/L 99 90 - 110 6

Lab Sample ID: LCSD 550-152829/37-A Client Sample ID: Lab Control Sample Dup 7 Matrix: Water Prep Type: Total/NA Analysis Batch: 152994 Prep Batch: 152829 8 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit 9 Nitrogen, Kjeldahl 10.0 10.2 mg/L 102 90 - 110 3 20

Lab Sample ID: 550-106639-B-4-B MS Client Sample ID: Matrix Spike 10 Matrix: Water Prep Type: Total/NA Analysis Batch: 152994 Prep Batch: 152829 11 Sample Sample Spike MS MS %Rec. Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits 12 Nitrogen, Kjeldahl 18 M1 10.0 28.5 E2 mg/L 105 90 - 110 13 Lab Sample ID: 550-106639-B-4-C MSD Client Sample ID: Matrix Spike Duplicate Matrix: Water Prep Type: Total/NA 14 Analysis Batch: 152994 Prep Batch: 152829 Sample Sample Spike MSD MSD %Rec. RPD Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit Nitrogen, Kjeldahl 18 M1 10.0 29.4 E2 M1 mg/L 114 90 - 110 3 20

Method: SM 4500 P E - Phosphorus

Lab Sample ID: MB 550-152757/3-A Client Sample ID: Method Blank Matrix: Water Prep Type: Total/NA Analysis Batch: 153079 Prep Batch: 152757 MB MB Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dil Fac Total Phosphorus ND 0.10 mg/L 07/27/18 13:15 08/01/18 16:37 1

Lab Sample ID: LCS 550-152757/4-A Client Sample ID: Lab Control Sample Matrix: Water Prep Type: Total/NA Analysis Batch: 153079 Prep Batch: 152757 Spike LCS LCS %Rec. Analyte Added Result Qualifier Unit D %Rec Limits Total Phosphorus 0.300 0.317 mg/L 106 90 - 110

Lab Sample ID: LCSD 550-152757/5-A Client Sample ID: Lab Control Sample Dup Matrix: Water Prep Type: Total/NA Analysis Batch: 153079 Prep Batch: 152757 Spike LCSD LCSD %Rec. RPD Analyte Added Result Qualifier Unit D %Rec Limits RPD Limit Total Phosphorus 0.300 0.308 mg/L 103 90 - 110 3 20

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Page 15 of 28 8/7/2018 QC Sample Results 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Method: SM 4500 P E - Phosphorus (Continued) 3 Lab Sample ID: 550-106651-C-1-B MS Client Sample ID: Matrix Spike 4 Matrix: Water Prep Type: Total/NA Analysis Batch: 153079 Prep Batch: 152757 Sample Sample Spike MS MS %Rec. 5 Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits Total Phosphorus ND 0.300 0.399 mg/L 110 80 - 120 6

Lab Sample ID: 550-106651-C-1-C MSD Client Sample ID: Matrix Spike Duplicate 7 Matrix: Water Prep Type: Total/NA Analysis Batch: 153079 Prep Batch: 152757 8 Sample Sample Spike MSD MSD %Rec. RPD Analyte Result Qualifier Added Result Qualifier Unit D %Rec Limits RPD Limit 9 Total Phosphorus ND 0.300 0.396 mg/L 109 80 - 120 1 20 10 11 12 13 14

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Page 16 of 28 8/7/2018 QC Association Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 HPLC/IC 3 Analysis Batch: 152699 4 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 300.0 5 550-106698-2 Old Cibola Canal #2 Total/NA Water 300.0 550-106698-3 River #1 Total/NA Water 300.0 6 550-106698-4 River #3 Total/NA Water 300.0 550-106698-5 River #2 Total/NA Water 300.0 MB 550-152699/2 Method Blank Total/NA Water 300.0 7 LCS 550-152699/5 Lab Control Sample Total/NA Water 300.0 LCSD 550-152699/6 Lab Control Sample Dup Total/NA Water 300.0 8 550-106716-B-1 MS Matrix Spike Total/NA Water 300.0 550-106716-B-1 MSD Matrix Spike Duplicate Total/NA Water 300.0 9 Analysis Batch: 533396 10 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 531.1 LL 11 550-106698-2 Old Cibola Canal #2 Total/NA Water 531.1 LL 550-106698-3 River #1 Total/NA Water 531.1 LL 12 550-106698-4 River #3 Total/NA Water 531.1 LL 550-106698-5 River #2 Total/NA Water 531.1 LL 13 MB 680-533396/11 Method Blank Total/NA Water 531.1 LL LCS 680-533396/12 Lab Control Sample Total/NA Water 531.1 LL 14 LCSD 680-533396/13 Lab Control Sample Dup Total/NA Water 531.1 LL 550-106638-I-1 MS Matrix Spike Total/NA Water 531.1 LL 550-106638-I-1 MSD Matrix Spike Duplicate Total/NA Water 531.1 LL

Analysis Batch: 533471

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 547 LL 550-106698-2 Old Cibola Canal #2 Total/NA Water 547 LL 550-106698-3 River #1 Total/NA Water 547 LL 550-106698-4 River #3 Total/NA Water 547 LL 550-106698-5 River #2 Total/NA Water 547 LL MB 680-533471/2 Method Blank Total/NA Water 547 LL LCS 680-533471/3 Lab Control Sample Total/NA Water 547 LL LCSD 680-533471/4 Lab Control Sample Dup Total/NA Water 547 LL 550-106698-1 MS Old Cibola Canal #1 Total/NA Water 547 LL 550-106698-1 MSD Old Cibola Canal #1 Total/NA Water 547 LL

Metals Prep Batch: 152822

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 200.8 550-106698-2 Old Cibola Canal #2 Total/NA Water 200.8 550-106698-3 River #1 Total/NA Water 200.8 550-106698-4 River #3 Total/NA Water 200.8 550-106698-5 River #2 Total/NA Water 200.8 MB 550-152822/1-A Method Blank Total/NA Water 200.8 LCS 550-152822/2-A Lab Control Sample Total/NA Water 200.8 LCSD 550-152822/3-A Lab Control Sample Dup Total/NA Water 200.8 550-106698-1 MS Old Cibola Canal #1 Total/NA Water 200.8

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Page 17 of 28 8/7/2018 QC Association Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Metals (Continued) 3 Prep Batch: 152822 (Continued) 4 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 MSD Old Cibola Canal #1 Total/NA Water 200.8 5 Analysis Batch: 153094 6 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 200.8 LL 152822 550-106698-2 Old Cibola Canal #2 Total/NA Water 200.8 LL 152822 7 550-106698-3 River #1 Total/NA Water 200.8 LL 152822 550-106698-4 River #3 Total/NA Water 200.8 LL 152822 8 550-106698-5 River #2 Total/NA Water 200.8 LL 152822 MB 550-152822/1-A Method Blank Total/NA Water 200.8 LL 152822 9 LCS 550-152822/2-A Lab Control Sample Total/NA Water 200.8 LL 152822 LCSD 550-152822/3-A Lab Control Sample Dup Total/NA Water 200.8 LL 152822 10 550-106698-1 MS Old Cibola Canal #1 Total/NA Water 200.8 LL 152822 550-106698-1 MSD Old Cibola Canal #1 Total/NA Water 200.8 LL 152822 11

General Chemistry 12 Analysis Batch: 151126 13 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water Total Nitrogen 14 550-106698-2 Old Cibola Canal #2 Total/NA Water Total Nitrogen 550-106698-3 River #1 Total/NA Water Total Nitrogen 550-106698-4 River #3 Total/NA Water Total Nitrogen 550-106698-5 River #2 Total/NA Water Total Nitrogen

Prep Batch: 152757

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water SM 4500 P B 550-106698-2 Old Cibola Canal #2 Total/NA Water SM 4500 P B 550-106698-3 River #1 Total/NA Water SM 4500 P B 550-106698-4 River #3 Total/NA Water SM 4500 P B 550-106698-5 River #2 Total/NA Water SM 4500 P B MB 550-152757/3-A Method Blank Total/NA Water SM 4500 P B LCS 550-152757/4-A Lab Control Sample Total/NA Water SM 4500 P B LCSD 550-152757/5-A Lab Control Sample Dup Total/NA Water SM 4500 P B 550-106651-C-1-B MS Matrix Spike Total/NA Water SM 4500 P B 550-106651-C-1-C MSD Matrix Spike Duplicate Total/NA Water SM 4500 P B

Prep Batch: 152829

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 351.2 550-106698-2 Old Cibola Canal #2 Total/NA Water 351.2 550-106698-3 River #1 Total/NA Water 351.2 550-106698-4 River #3 Total/NA Water 351.2 550-106698-5 River #2 Total/NA Water 351.2 MB 550-152829/35-A Method Blank Total/NA Water 351.2 LCS 550-152829/36-A Lab Control Sample Total/NA Water 351.2 LCSD 550-152829/37-A Lab Control Sample Dup Total/NA Water 351.2 550-106639-B-4-B MS Matrix Spike Total/NA Water 351.2 550-106639-B-4-C MSD Matrix Spike Duplicate Total/NA Water 351.2

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Page 18 of 28 8/7/2018 QC Association Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 General Chemistry (Continued) 3 Analysis Batch: 152994 4 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water 351.2 152829 5 550-106698-2 Old Cibola Canal #2 Total/NA Water 351.2 152829 550-106698-3 River #1 Total/NA Water 351.2 152829 6 550-106698-4 River #3 Total/NA Water 351.2 152829 550-106698-5 River #2 Total/NA Water 351.2 152829 MB 550-152829/35-A Method Blank Total/NA Water 351.2 152829 7 LCS 550-152829/36-A Lab Control Sample Total/NA Water 351.2 152829 LCSD 550-152829/37-A Lab Control Sample Dup Total/NA Water 351.2 152829 8 550-106639-B-4-B MS Matrix Spike Total/NA Water 351.2 152829 550-106639-B-4-C MSD Matrix Spike Duplicate Total/NA Water 351.2 152829 9 Analysis Batch: 153079 10 Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batch 550-106698-1 Old Cibola Canal #1 Total/NA Water SM 4500 P E 152757 11 550-106698-2 Old Cibola Canal #2 Total/NA Water SM 4500 P E 152757 550-106698-3 River #1 Total/NA Water SM 4500 P E 152757 12 550-106698-4 River #3 Total/NA Water SM 4500 P E 152757 550-106698-5 River #2 Total/NA Water SM 4500 P E 152757 13 MB 550-152757/3-A Method Blank Total/NA Water SM 4500 P E 152757 LCS 550-152757/4-A Lab Control Sample Total/NA Water SM 4500 P E 152757 14 LCSD 550-152757/5-A Lab Control Sample Dup Total/NA Water SM 4500 P E 152757 550-106651-C-1-B MS Matrix Spike Total/NA Water SM 4500 P E 152757 550-106651-C-1-C MSD Matrix Spike Duplicate Total/NA Water SM 4500 P E 152757

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Page 19 of 28 8/7/2018 Lab Chronicle 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2

Client Sample ID: Old Cibola Canal #1 Lab Sample ID: 550-106698-1 3 Date Collected: 07/25/18 08:20 Matrix: Water Date Received: 07/26/18 07:40 4 Batch Batch Dilution Batch Prepared 5 Prep Type Type Method Run Factor Number or Analyzed Analyst Lab Total/NA Analysis 300.0 1 152699 07/26/18 23:09 NEL TAL PHX 6 Total/NA Analysis 531.1 LL 1 533396 07/31/18 00:58 UI TAL SAV Total/NA Analysis 547 LL 1 533471 07/30/18 20:51 UI TAL SAV 7 Total/NA Prep 200.8 152822 07/29/18 10:44 EXZ TAL PHX Total/NA Analysis 200.8 LL 1 153094 08/01/18 15:41 TEK TAL PHX 8 Total/NA Prep 351.2 152829 07/29/18 15:35 DGS TAL PHX Total/NA Analysis 351.2 1 152994 07/31/18 14:36 DGS TAL PHX 9 Total/NA Prep SM 4500 P B 152757 07/27/18 13:15 TLN TAL PHX Total/NA Analysis SM 4500 P E 1 153079 08/01/18 16:37 TLN TAL PHX 10 Total/NA Analysis Total Nitrogen 1 151126 07/31/18 17:03 LAS TAL PHX 11 Client Sample ID: Old Cibola Canal #2 Lab Sample ID: 550-106698-2 12 Date Collected: 07/25/18 09:11 Matrix: Water Date Received: 07/26/18 07:40 13 Batch Batch Dilution Batch Prepared Prep Type Type Method Run Factor Number or Analyzed Analyst Lab 14 Total/NA Analysis 300.0 1 152699 07/26/18 23:37 NEL TAL PHX Total/NA Analysis 531.1 LL 1 533396 07/31/18 01:28 UI TAL SAV Total/NA Analysis 547 LL 1 533471 07/30/18 21:49 UI TAL SAV Total/NA Prep 200.8 152822 07/29/18 10:44 EXZ TAL PHX Total/NA Analysis 200.8 LL 1 153094 08/01/18 15:48 TEK TAL PHX Total/NA Prep 351.2 152829 07/29/18 15:35 DGS TAL PHX Total/NA Analysis 351.2 1 152994 07/31/18 14:39 DGS TAL PHX Total/NA Prep SM 4500 P B 152757 07/27/18 13:15 TLN TAL PHX Total/NA Analysis SM 4500 P E 1 153079 08/01/18 16:37 TLN TAL PHX Total/NA Analysis Total Nitrogen 1 151126 07/31/18 17:03 LAS TAL PHX

Client Sample ID: River #1 Lab Sample ID: 550-106698-3 Date Collected: 07/25/18 10:10 Matrix: Water Date Received: 07/26/18 07:40

Batch Batch Dilution Batch Prepared Prep Type Type Method Run Factor Number or Analyzed Analyst Lab Total/NA Analysis 300.0 1 152699 07/27/18 00:04 NEL TAL PHX Total/NA Analysis 531.1 LL 1 533396 07/31/18 01:58 UI TAL SAV Total/NA Analysis 547 LL 1 533471 07/30/18 22:08 UI TAL SAV Total/NA Prep 200.8 152822 07/29/18 10:44 EXZ TAL PHX Total/NA Analysis 200.8 LL 1 153094 08/01/18 15:50 TEK TAL PHX Total/NA Prep 351.2 152829 07/29/18 15:35 DGS TAL PHX Total/NA Analysis 351.2 1 152994 07/31/18 14:41 DGS TAL PHX Total/NA Prep SM 4500 P B 152757 07/27/18 13:15 TLN TAL PHX Total/NA Analysis SM 4500 P E 1 153079 08/01/18 16:37 TLN TAL PHX Total/NA Analysis Total Nitrogen 1 151126 07/31/18 17:03 LAS TAL PHX

TestAmerica Phoenix

Page 20 of 28 8/7/2018 Lab Chronicle 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Client Sample ID: River #3 Lab Sample ID: 550-106698-4 3 Date Collected: 07/25/18 10:45 Matrix: Water Date Received: 07/26/18 07:40 4

Batch Batch Dilution Batch Prepared Prep Type Type Method Run Factor Number or Analyzed Analyst Lab 5 Total/NA Analysis 300.0 1 152699 07/27/18 00:32 NEL TAL PHX Total/NA Analysis 531.1 LL 1 533396 07/31/18 02:28 UI TAL SAV 6 Total/NA Analysis 547 LL 1 533471 07/30/18 22:27 UI TAL SAV 7 Total/NA Prep 200.8 152822 07/29/18 10:44 EXZ TAL PHX Total/NA Analysis 200.8 LL 1 153094 08/01/18 15:52 TEK TAL PHX 8 Total/NA Prep 351.2 152829 07/29/18 15:35 DGS TAL PHX Total/NA Analysis 351.2 1 152994 07/31/18 14:44 DGS TAL PHX 9 Total/NA Prep SM 4500 P B 152757 07/27/18 13:15 TLN TAL PHX Total/NA Analysis SM 4500 P E 1 153079 08/01/18 16:37 TLN TAL PHX 10 Total/NA Analysis Total Nitrogen 1 151126 07/31/18 17:03 LAS TAL PHX 11 Client Sample ID: River #2 Lab Sample ID: 550-106698-5 12 Date Collected: 07/25/18 11:15 Matrix: Water Date Received: 07/26/18 07:40 13 Batch Batch Dilution Batch Prepared Prep Type Type Method Run Factor Number or Analyzed Analyst Lab 14 Total/NA Analysis 300.0 1 152699 07/27/18 00:59 NEL TAL PHX Total/NA Analysis 531.1 LL 1 533396 07/31/18 02:58 UI TAL SAV Total/NA Analysis 547 LL 1 533471 07/30/18 22:46 UI TAL SAV Total/NA Prep 200.8 152822 07/29/18 10:44 EXZ TAL PHX Total/NA Analysis 200.8 LL 1 153094 08/01/18 15:55 TEK TAL PHX Total/NA Prep 351.2 152829 07/29/18 15:35 DGS TAL PHX Total/NA Analysis 351.2 1 152994 07/31/18 14:46 DGS TAL PHX Total/NA Prep SM 4500 P B 152757 07/27/18 13:15 TLN TAL PHX Total/NA Analysis SM 4500 P E 1 153079 08/01/18 16:37 TLN TAL PHX Total/NA Analysis Total Nitrogen 1 151126 07/31/18 17:03 LAS TAL PHX

Laboratory References: TAL PHX = TestAmerica Phoenix, 4625 East Cotton Ctr Blvd, Suite 189, Phoenix, AZ 85040, TEL (602)437-3340 TAL SAV = TestAmerica Savannah, 5102 LaRoche Avenue, Savannah, GA 31404, TEL (912)354-7858

TestAmerica Phoenix

Page 21 of 28 8/7/2018 Accreditation/Certification Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Laboratory: TestAmerica Phoenix Unless otherwise noted, all analytes for this laboratory were covered under each accreditation/certification below. 3

Authority Program EPA Region Identification Number Expiration Date 4 Arizona State Program 9 AZ0728 06-09-19

The following analytes are included in this report, but accreditation/certification is not offered by the governing authority: 5 Analysis Method Prep Method Matrix Analyte Total Nitrogen Water Nitrogen, Total 6 Laboratory: TestAmerica Savannah 7 All accreditations/certifications held by this laboratory are listed. Not all accreditations/certifications are applicable to this report. 8 Authority Program EPA Region Identification Number Expiration Date AFCEE SAVLAB Alabama State Program 4 41450 06-30-18 * 9 Alaska State Program 10 06-30-18 * Alaska (UST) State Program 10 UST-104 09-22-19 10 ANAB DoD ELAP L2463 09-22-19 ANAB ISO/IEC 17025 L2463.01 09-22-19 11 Arizona State Program 9 AZ0808 12-14-18 Arkansas DEQ State Program 6 88-0692 02-01-19 12 California State Program 9 2939 06-30-18 * Colorado State Program 8 N/A 12-31-18 13 Connecticut State Program 1 PH-0161 03-31-19 Florida NELAP 4 E87052 06-30-19 14 GA Dept. of Agriculture State Program 4 N/A 06-12-19 Georgia State Program 4 N/A 06-30-18 * Georgia State Program 4 803 06-30-18 * Guam State Program 9 15-005r 04-17-19 Hawaii State Program 9 N/A 06-30-18 * Illinois NELAP 5 200022 11-30-18 Indiana State Program 5 N/A 06-30-18 * Iowa State Program 7 353 06-30-19 Kentucky (DW) State Program 4 90084 12-31-18 Kentucky (UST) State Program 4 18 06-30-18 * Kentucky (WW) State Program 4 90084 12-31-18 * Louisiana NELAP 6 30690 06-30-18 * Louisiana (DW) NELAP 6 LA160019 12-31-18 Maine State Program 1 GA00006 09-24-18 * Maryland State Program 3 250 12-31-18 Massachusetts State Program 1 M-GA006 06-30-18 * Michigan State Program 5 9925 06-30-18 * Mississippi State Program 4 N/A 06-30-18 * Nebraska State Program 7 TestAmerica-Savannah 06-30-18 * New Jersey NELAP 2 GA769 06-30-18 * New Mexico State Program 6 N/A 06-30-18 * New York NELAP 2 10842 03-31-19 North Carolina (DW) State Program 4 13701 07-31-18 * North Carolina (WW/SW) State Program 4 269 12-31-18 Oklahoma State Program 6 9984 08-31-18 * Pennsylvania NELAP 3 68-00474 06-30-18 * Puerto Rico State Program 2 GA00006 12-31-18 South Carolina State Program 4 98001 06-30-18 * Tennessee State Program 4 TN02961 06-30-19

* Accreditation/Certification renewal pending - accreditation/certification considered valid. TestAmerica Phoenix

Page 22 of 28 8/7/2018 Accreditation/Certification Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 Laboratory: TestAmerica Savannah (Continued) All accreditations/certifications held by this laboratory are listed. Not all accreditations/certifications are applicable to this report. 3

Authority Program EPA Region Identification Number Expiration Date 4 Texas NELAP 6 T104704185-16-9 11-30-18 Texas (DW) State Program 1 T104704185 06-30-19 5 US Fish & Wildlife Federal LE058448-0 07-31-18 * USDA Federal P330-17-00213 06-14-20 * 6 Virginia NELAP 3 460161 06-14-19 Washington State Program 10 C805 06-10-19 7 West Virginia (DW) State Program 3 9950C 12-31-18 West Virginia DEP State Program 3 094 08-13-18 * 8 Wisconsin State Program 5 999819810 08-31-18 * Wyoming State Program 8 8TMS-L 06-30-16 * 9 10 11 12 13 14

* Accreditation/Certification renewal pending - accreditation/certification considered valid. TestAmerica Phoenix

Page 23 of 28 8/7/2018 Method Summary 1 Client: Nicklaus Engineering TestAmerica Job ID: 550-106698-1 Project/Site: 018-103 SDG: Pit 2 3 Method Method Description Protocol Laboratory 300.0 Anions, Ion Chromatography MCAWW TAL PHX 531.1 LL Carbamate Pesticides (HPLC) EPA TAL SAV 4 547 LL Glyphosate (DAI HPLC) EPA TAL SAV 200.8 LL Metals (ICP/MS) EPA TAL PHX 5 351.2 Nitrogen, Total Kjeldahl MCAWW TAL PHX SM 4500 P E Phosphorus SM TAL PHX 6 Total Nitrogen Nitrogen, Total EPA TAL PHX 200.8 Preparation, Total Metals EPA TAL PHX 7 351.2 Nitrogen, Total Kjeldahl MCAWW TAL PHX SM 4500 P B Phosphorous, Total and Ortho SM TAL PHX 8

Protocol References: 9 EPA = US Environmental Protection Agency MCAWW = "Methods For Chemical Analysis Of Water And Wastes", EPA-600/4-79-020, March 1983 And Subsequent Revisions. 10 SM = "Standard Methods For The Examination Of Water And Wastewater" 11 Laboratory References: TAL PHX = TestAmerica Phoenix, 4625 East Cotton Ctr Blvd, Suite 189, Phoenix, AZ 85040, TEL (602)437-3340 12 TAL SAV = TestAmerica Savannah, 5102 LaRoche Avenue, Savannah, GA 31404, TEL (912)354-7858 13 14

TestAmerica Phoenix

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Page 26 of 28 8/7/2018 1 Login Sample Receipt Checklist 2

Client: Nicklaus Engineering Job Number: 550-106698-1 3 SDG Number: Pit 4 Login Number: 106698 List Source: TestAmerica Phoenix List Number: 1 Creator: Stehlin, Marc 5 Question Answer Comment 6 Radioactivity wasn't checked or is

TestAmerica Phoenix Page 27 of 28 8/7/2018 1 Login Sample Receipt Checklist 2

Client: Nicklaus Engineering Job Number: 550-106698-1 3 SDG Number: Pit 4 Login Number: 106698 List Source: TestAmerica Savannah List Number: 2 List Creation: 07/27/18 04:12 PM Creator: Jones, Tyre D 5 Question Answer Comment 6 Radioactivity wasn't checked or is

TestAmerica Phoenix Page 28 of 28 8/7/2018