GENESIS ENERGY LP

See Item 1. “Business,” in addition to the Summary Overview of Mining Operations disclosure below. We also have various operating leases for rental of office space, facilities and field equipment and transportation equipment. See Management’s Discussion and Analysis of Financial Condition and Results of Operations, and Note 5 to our Consolidated Financial Statements in Item 8 for details on our right of use assets and related lease liabilities. Such information is incorporated herein by reference.

Summary Overview of Mining Operations

Information concerning our mining properties in this Annual Report on Form 10-K has been prepared in accordance with the requirements of subpart 1300 of Regulation S-K, which first became applicable to us for the fiscal year ended December 31, 2021 and was applicable until February 28, 2025, the date we sold our Alkali Business (see “Recent Developments” in Item 1. “Business”). These requirements differ significantly from the previously applicable disclosure requirements of SEC Industry Guide 7. Among other differences, subpart 1300 of Regulation S-K requires us to disclose our mineral resources, in addition to our mineral reserves, as of the end of our most recently completed fiscal year for our material mining property.

As used in this Annual Report on Form 10-K, the terms “mineral resource,” “measured mineral resource,” “indicated mineral resource,” “inferred mineral resource,” “mineral reserve,” “proven mineral reserve” and “probable mineral reserve” are defined and used in accordance with subpart 1300 of Regulation S-K. Under subpart 1300 of Regulation S-K, mineral resources may not be classified as “mineral reserves” unless the determination has been made by a qualified person that the mineral resources can be the basis of an economically viable project. You are specifically cautioned not to assume that any part or all of the mineral deposits (including any mineral resources) in these categories will ever be converted into mineral reserves, as defined by the SEC.

You are further cautioned that, except for that portion of mineral resources classified as mineral reserves, mineral resources do not have demonstrated economic value. Inferred mineral resources are estimates based on limited geological evidence and sampling and have too high of a degree of uncertainty as to their existence to apply relevant technical and economic factors likely to influence the prospects of economic extraction in a manner useful for evaluation of economic viability. Estimates of inferred mineral resources may not be converted to mineral reserves. A significant amount of exploration must be completed in order to determine whether an inferred mineral resource may be upgraded to a higher category of mineralization and it cannot be assumed that this will occur. Therefore, you are cautioned not to assume that all or any part of an inferred mineral resource exists, that it can be the basis of an economically viable project, or that it will ever be upgraded to a higher category of mineralization. Likewise, you are cautioned not to assume that all or any part of measured or indicated mineral resources will ever be converted to mineral reserves.

The information that follows is derived, in part, from the technical report summary (“TRS”) prepared by Stantec Consulting Services Inc. (“Stantec”), an external qualified person (“QP”) in compliance with Item 601(b)(96) and subpart 1300 of Regulation S-K. Portions of the following information are based on assumptions, qualifications and procedures that are not fully described herein. Reference should be made to the full text of the TRS that was filed as Exhibit 96.1 as a part of the Annual Report on Form 10-K for the fiscal year ended December 31, 2021 and is incorporated herein by reference. A new TRS was not filed as a part of this Annual Report on Form 10-K because (i) there was not a material change in the mineral reserves or mineral resources from such previously filed TRS and (ii) all material assumptions and information pertaining to the disclosure of our mineral resources and mineral reserves required by paragraphs (d), (e) and (f) of subpart 1302 of Regulation S-K, including material assumptions relating to all modifying factors, price estimates and scientific and technical information (e.g., sampling data, estimation assumptions and methods), were current as of December 31, 2024, as confirmed by Stantec.

Overview of Mining Property and Operations

Our Alkali Business produced natural soda ash, which is processed from trona, a sodium carbonate mineral composed of soda ash (Na 2 CO 3), sodium bicarbonate (NaHCO 3) and water with the chemical formula Na 2 CO 3 NaHCO 3 H 2 O.

Approximately 50% of the world’s natural soda ash capacity is from trona extracted from underground mines and brine (solution) mining in the Green River Basin of southwestern Wyoming. Our trona mining and processing facilities are located in southwestern Wyoming approximately 18 miles west of the city of Green River, Wyoming. The following maps show the location of our mining property, asof December 31, 2024:

Figure 2.1. General Location Map

Figure 2.2. Map of Mining Areas

The Green River trona beds are collectively the largest known deposit of trona and the undisputed largest source of raw material feed for the production of natural soda ash in the world. The trona deposits are the result of very unusual, geological circumstances. Sodium-rich springs are believed to have fed ancient Lake Gosiute, a large, shallow inland lake that reached a maximum extent of over 15,000 square miles around 50 million years ago. In response to repetitive cycles of lake expansion, contraction and evaporation, and changes in temperature and salinity, trona was precipitated in beds of remarkable purity and extent. In addition to trona, the evaporite sodium mineral assemblage includes variable levels of other sodium carbonate minerals as well as halite (NaCl). At least 25 beds of natural trona in the Wilkins Peak Member of the Eocene Green River Formation exceed at least three feet in thickness and are estimated by the U.S. Geological Survey (“USGS”) to contain a cumulative resource of over 100 billion tons of trona. Individual trona beds are numbered in ascending order and trona beds of significance lie at depths between approximately 400 to 2,000 feet. Our current dry mining and brine (solution) mining operations exploit three trona beds, and our reserves are contained in four trona beds.

Genesis has one trona mineral property, located in the Known Sodium Leasing Area in Southwest Wyoming, primarily encompassed by the Westvaco area and the Granger area. Due to differences in geology between these two mine areas, the mineral leases and, ultimately, the trona resources and reserve estimates have been separated into Westvaco contiguous leases, Granger contiguous leases and Granger non-contiguous leases. The table and figures below are summaries of our acreage under each mineral lease type as of December 31, 2024.

Our trona resources and mining operations are held under leases covering 87,637 acres over portions of 23 townships, primarily in two contiguous units informally known as the “Westvaco” and “Granger” blocks. Mineral and mining rights are secured by leases from the Federal government, the State of Wyoming, and Sweetwater. We lease approximately 25,215 acres from the U.S. Government under the Mineral Leasing Act of 1920 (Title 30 §181) which includes trona under its definition of a “solid leasable mineral.” Federal minerals are administered by the U.S. Bureau of Land Management (“BLM”). We lease 40,819 acres from Sweetwater who acquired the mineral rights from Anadarko Land Corporation, a subsidiary of Occidental following Occidental’s August 2019 acquisition of Anadarko Petroleum Corporation, which acquired the ownership from the Union Pacific Resources Group (“UPRG”) in 2000. The lease includes alternate sections of land for 20 miles on either side of the trans-continental railroad, originally granted to UPRG under the Pacific Railroad Act of 1862 and subsequent railroad land grants. We also lease 21,603 acres from the State of Wyoming. Our mineral leases have varying terms. Our private leases are held indefinitely by production, BLM and State Leases expire and are renewed every 10 years. Royalty payments range from 2% to 8% of the sales value of soda ash products. We believe that all of our leases were entered into at market terms.

As of December 31, 2024, our senior secured credit facility was guaranteed by substantially all of our restricted subsidiaries and is secured by liens on a substantial portion of our assets, including our trona leases. Refer to further discussion of our senior secured credit facility in Item 7. “Liquidity and Capital Resources.” As of December 31, 2024, our Alkali senior secured notes were secured by a fifty-year 10% limited term overriding royalty interest in substantially all of the Alkali Business’ trona mineral leases owned by GA ORRI, LLC (“GA ORRI”).

Figure 2.3. Lease Tenure

The table below shows certain key information for leases in the Westvaco contiguous leases, Granger contiguous leases, and Granger non-contiguous leases that are included in the resource and reserve estimates, including lessor, lease term, size, royalty information and expiration date.

Our Westvaco site is a production stage property that mines trona through both dry mining and brine (solution) mining methods.

The location of the Westvaco site and contiguous lease boundary can be found in Figure 2.2. It is located in Sweetwater County, Wyoming, 18 miles west of Green River and is accessible from Interstate 80 (I-80), a four-lane divided highway. I-80 exit 72 is approximately seven miles from the processing plant. The Union Pacific Railroad passes just north of the Westvaco facilities with siding to access the mainline. The two main population centers of Green River, Wyoming and Rock Springs, Wyoming are 18 miles and 30 miles to the east, respectively. Evanston, Wyoming is 66 miles to the west. The area population provides a more than adequate base for staffing the Westvaco facilities, with a pool of talent for management.

The Westvaco site has been in uninterrupted, continuous operation since its start in 1947 by Westvaco Chemical Corporation. Westvaco Chemical Corporation notified Union Pacific in 1946 of its intention to sink a mine shaft and to construct a trona processing plant. A shaft was sunk in 1947 to the top of Bed 17 bringing the first skipload of trona to the surface in late 1947. In the fall of 1948, Westvaco Chemical Corporation was acquired by the Food Machinery Corporation (later known as “FMC”). In 1952, the Westvaco Division of FMC formed the Intermountain Chemical Company as Wyoming’s first trona mining company. In 1953, Intermountain Chemical Company began producing refined soda ash by a sesquicarbonate process through a plant with a 300,000-ton capacity. The Alkali Chemical Division of FMC, including the trona mining and processing operations in the Green River Basin of Wyoming, was acquired by Tronox Alkali in May 2015. In September 2017, we acquired the Westvaco facility from Tronox Alkali and currently operate the facility through Genesis Alkali Wyoming, LP.

Infrastructure on the Westvaco site is very well developed as the facilities have been in operation for over 75 years. The infrastructure consists of sufficient truck and rail loadout facilities, electrical generation and transmission facilities, tailings facilities, product storage facilities, process facilities, natural gas pipelines and distribution facilities and water pipelines, treatment and distribution facilities. The Westvaco site also has ample buildings for offices, labs, change rooms, warehouses and maintenance shops.

Our Granger site is a production stage property that mines trona through brine (solution) mining methods.

The location of the Granger site and contiguous lease boundary can be found in Figure 2.2. The Granger site is located in Sweetwater County, Wyoming and can be accessed by traveling eight miles west of Green River, Wyoming on I-80, then turning north on state highway 372 and traveling about 12 miles to county road 11. The Granger site is accessible to the Union Pacific Railroad by a spur line that connects to the mainline near the town of Granger, Wyoming. The two main population centers of Green River, Wyoming and Rock Springs, Wyoming are 18 miles and 30 miles to the east, respectively. Evanston, Wyoming is 66 miles to the west. The area population provides a more than adequate base for staffing the Granger facilities, with a pool of talent for management.

The Granger mine and processing facility operated as an underground mine from 1976 to 2002. FMC acquired the properties in 1999 by acquiring Tg Soda Ash Inc., originally developed as a unit of Texasgulf and then owned by Elf Atochem. FMC converted the mine and mill to brine (solution) mining in 2005. The Alkali Chemical Division of FMC, including the trona mining and processing operations in the Green River Basin of Wyoming, was acquired by Tronox Alkali in May 2015. In September 2017, we acquired the Granger facility from Tronox Alkali and currently operate the facility through Genesis Alkali Wyoming, LP.

Infrastructure on the Granger site is very well developed as the facilities have operated for over 35 years. The infrastructure consists of sufficient rail loadout facilities, electrical transmission facilities, tailings facilities, product storage facilities, process facilities, natural gas pipelines and distribution facilities and water pipelines, treatment and distribution facilities. The Granger site also has ample buildings for offices, labs, change rooms, warehouses and maintenance shops.

As both the Westvaco site and Granger site have been operating for many years, all permits necessary for the operation of these facilities are in place. The Westvaco site includes approximately 36,000 permitted acres, of which the processing, support facilities and tailings and evaporation ponds cover about 2,900 surface acres. The Granger facility includes about 16,000 permitted acres of which the processing, support facilities, and tailings and evaporation ponds cover about 1,600 surface acres. The WDEQ is the primary issuer of the environmental permits relevant to our operations, including air quality permits, mining and reclamation permits, as well as class III and class V underground injection control permits. With respect to each facility, permits, licenses and approvals are obtained as needed in the normal course of business based on our mine plans and federal, state, provincial and local regulatory provisions regarding mine permitting and licensing. There have been no outstanding violations or orders that would prevent continued operation of the plants and mines. This includes air, land, surface and groundwater, drinking water, wildlife, and waste. As of December 31, 2024, approved reclamation plans were in place along with surety in the amounts of approxi mately $55.5 million for the Westvaco site and $34.5 million for the Granger site.

At our Wyoming property, we use both mechanical and brine mining to mine the trona ore:

•Dry Mining of Trona Ore. We extract trona ore from our Westvaco underground mine by mechanized, continuous mining methods. Our current underground dry mine production is from trona bed 17, a near-horizontal bed approximately 10 feet thick at a depth from the surface of 1,500-1,800 feet. Ore is extracted primarily by our single longwall mining machine from an extensive network of parallel drifts and connecting cross-cuts, known as room-and-pillar mining. Longwall miners shear off successive panels of ore which drops onto a conveyor belt for delivery to the vertical hoisting shafts. Longwall mining provides higher recovery rates leading to extended mine life compared to other dry mining techniques. Development of the “tunnels” necessary to access and ventilate our longwall is through room-and-pillar mining completed primarily by our fleet of borer miners. The ore is conveyed underground to two hoisting operations where it travels about 1,600 feet vertically to the surface and is either taken directly into our processing facilities or stored on two outdoor stockpiles for future consumption.

•Secondary Recovery Brine Mining. We brine (solution) mine trona at both our Westvaco and Granger sites using secondary recovery techniques. Our secondary recovery mining starts with the recovery of water streams from our operations and non-trona solids (“insolubles”) remaining from the processing of dry mined trona. The water and some insolubles are injected through a number of wells into the old dry mine workings at both our Westvaco and Granger sites. The insolubles settle out while the water travels through the old workings, dissolving sodium carbonate and sodium bicarbonate from the trona left behind during previous dry mining. Multiple pumping systems are used to pump the enriched brine to the surface for processing.

Our mineral recovery consists of four processing plants producing soda ash at two surface sites, Westvaco and Granger.

Dry mined and brine mined trona are processed into soda ash at our Westvaco site, located within the boundaries of our Westvaco contiguous lease blocks, involving multiple processing lines, steam generation facilities, evaporation ponds, spare parts warehouses, maintenance shops, and offices for engineering, production, and support staff. Mineral recovery at Westvaco site consists of three plants: the Sesqui plant, the Mono plant and the ELDM plant.

Our Sesqui and Mono plants process dry-mined trona into soda ash. Crushing, dissolution in water, filtration, and crystallization techniques are used to produce the desired final products. The Mono plant consists of two separate processing lines to produce soda ash. Mono I began operation in May 1972, while Mono II was started up in January 1976. In the Mono plant, the ore is calcined with heat, prior to dissolution, to process the trona into soda ash by the removal of water and carbon dioxide. A final calcining step using steam produces a dense soda ash product from the Mono process. The Sesqui plant was the first soda ash plant built and operated at the Westvaco site. In our Sesqui plant, the calcination is performed at the end of the process, producing a light density soda ash that is preferred in applications desiring increased absorptivity. The Sesqui process also has the ability to produce refined sodium sesquicarbonate (which we sell under the names S-Carb® and Sesqui®™) for use as a buffer in animal feed formulations and in cleaning and personal care applications.

Our ELDM plant was constructed in 1995 and started operations in 1996. Our brine based ELDM plant uses the tailings return water as a feed source for soda ash production. Solution mined trona brine is processed into dense soda ash in our ELDM operation. The steps to produce soda ash are similar to the dry mined processes, except the crushing and dissolving steps are eliminated because the trona is already in a water solution as it leaves the mine.

Figure 2.4 Westvaco Surface Production Facilities

The Westvaco site also has a facility producing food, feed, and pharmaceutical grade sodium bicarbonate from a Sesqui plant intermediate product. Fifty percent caustic is produced on the Westvaco site for commercial sale from a Mono plant intermediate product.

The Westvaco site has successfully mined and processed trona ore at a profit for over 75 years. In this time, capital has been expended as appropriate to sustain the operation at the current production and operating cost level. We plan for capital expenditures necessary to replace equipment and facilities over time in order to sustain production and operating costs.

Solution mined trona brine is processed into soda ash at our Granger plant, located within the boundaries of the Granger contiguous lease blocks, and involves multiple processing lines, steam generation facilities, evaporation ponds, spare parts warehouses, maintenance shops, and offices for engineering, production, and support staff. The steps to produce soda ash are similar to the dry mined processes, except the crushing and dissolving steps are eliminated because the trona is already in a water solution as it leaves the mine.

Figure 2.5. Granger Surface Production Facilities

The Granger site has successfully mined and processed trona ore at a profit for over 35 years. In this time, capital has been expended as appropriate to sustain the operation at the current production and operating cost level. In 2023, the Granger Optimization Project reached substantial completion and achieved first production. Capital expenditures are generally for sustaining production and operating costs except for some remaining capital for our Granger Optimization Project.

The total book value of the Westvaco and Granger sites as of December 31, 2024 and December 31, 2023 was approximately $1,657 millionand $1,668 million, respectively.

In many cases, market demand drives annual production so that actual production may be less than plant capacities. The table below shows annual production from our trona property and its four plants for the fiscal years ended December 31, 2024, 2023 and 2022.

In the fourth quarter of 2023, our Granger Optimization Project reached substantial completion and achieved first production and has since ramped up to its estimated, incremental 750,000 tons of annual production capacity in 2024.

Summaries of our mineral resources and reserves for the fiscal years ended December 31, 2024 and 2023 are set forth in the tables below:

(1)Mineral resources are exclusive of mineral reserves, which are summarized in the table below. Mineral resources are not mineral reserves and do not have demonstrated economic viability. There is no certainty that all or any part of the mineral resources will be converted into mineral reserves upon application of modifying factors.

(2)Based on the analysis described in Section 11.3 of the TRS, no economic cutoff grade has been applied to the resource given the long history of uninterrupted trona mining on the property, spatial consistency of the trona content and overall low insoluble and halite content. No elements or compounds from within the beds were identified as having a material impact on the ability to extract trona from the beds via mechanical or brine (solution) mining methods.

(1)Our trona ore reserves are calculated from in-place trona-bearing material that can be economically and legally extracted and processed into commercial products at the time of reserve determination. Our reserves estimates are developed using industry-standard procedures and have been reviewed internally and externally to ensure compliance with subpart 1300 of Regulation S-K.

(2)We use “measured and indicated” resources as the primary basis in determining our proven and probable reserves. We define proven reserves and probable reserves as follows:

a. Proven dry-mining reserves are measured reserves that fall within a 0.5 mile radius from drillhole data points or previously mined areas with a 7.0 feet minimum ore thickness.

b. Probable dry-mining reserves are indicated reserves that fall between 0.5 miles and 1.0 miles from drillhole data points or previously mined areas with a 7.0 feet minimum ore thickness.

c. All brine (solution) mining reserves are designated as probable based on the degree of confidence in the reserve estimate related to uncertainties involving brine flow paths, trona ore surface area available for dissolution, and the inaccuracy of depletion verification methods. They consist of both measured resources falling within a 0.5 mile radius from drillhole data points or previously mined areas and indicated resources that fall between 0.5 miles and 1.0 miles from drillhole data points or previously mined areas. Brine (solution) mining reserves are not limited to a minimum ore thickness, but rather are subjected to a 50 foot halo limit into large blocks of trona adjacent to areas impacted by previous dry mining and adjacent to areas planned for future dry mining.

(3)Estimated dry mining ore reserves include dilution from un-mineralized material within and marginal to the trona ore bed. We exclude support pillars from dry mining reserves, but a portion of the trona contained in the pillars is recovered by brine (solution) mining. We apply a bulk density factor of 133 lb/cu ft for conversion of volumes to mass. Key dry mining parameters include minimum trona ore bed thickness.

(4)Our brine (solution) mining ore reserves are reported on an in-place basis, inclusive of dilution from insoluble material that remains in the ground. The brine (solution) mining reserves are calculated using recovery parameters developed from our 20-plus years of cumulative secondary recovery brine (solution) mining experience. Key factors include the surface area of remaining support pillars and other trona-mineralized surfaces exposed to liquid brines injected into voids created by dry mining, solubility and alkalinity data, and predicted dissolution rates.

(5)Our ore reserves have a minimum trona grade of 66.2% (occurs in Bed 15). The balance of the ore consists of clays, shales, and other impurities.

Total trona reserves for the fiscal year ended December 31, 2024 decreased approximately seven million short tons from fiscal year ended December 31, 2023, representing approximately 0.8% of the total reserves.

Dry mining reserves at year end 2024 are approximately four million short tons, or 0.9%, lower than year end 2023 reserves as a result of dry mine extraction in 2024.

Brine (solution) mining reserves at year end 2024 are approximately three million short tons, or 0.7% lower than year end 2023 reserves as a result of brine (solution) mining extraction in 2024.

Our mineral resource and reserve estimates are based on many factors, including the area and volume covered by our mining rights, assumptions regarding our extraction rates (based upon an expectation of operating the mines on a long-term basis) and the quality of in-place reserves. Stantec reviewed our data at the end of 2024 and 2023 and determined that, other than updating reserves to reflect ore consumption, there has not been any material changes in our mineral resources and reserves since the issuance of the TRS and the TRS can be relied upon in stating 2024 and 2023 reserves. Key assumptions and parameters relating to our mineral resources and reserves at the Westvaco site are discussed in the TRS, and include, among other things, the following:

•The economic analysis of our resources and reserves was prepared based on 2022 dollars with annual inflation at 2.5% which has been applied to revenue, operating costs, and capital spending.

•The production schedule to mine and process the remaining reserves is based on the existing production capacity of the mine and processing plants.

•Bed 15, which lies approximately 35 to 55 feet below bed 17, can be effectively dry mined starting in roughly the year 2071, after the completion of longwall mining in overlying areas of Bed 17.

•Future secondary brine (solution) mining recoveries are similar to those that have been demonstrated thus far in certain areas of our Westvaco mine.

•Prices for bulk soda ash are based on the 2020 USGS price, which was escalated to establish the 2022 price while prices for bag and specialty products were consistent with recent history.

•Cash production costs include dry mining, brine (solution) mining, processing, royalties and production taxes, insurance, and administrative costs. Administrative costs include mine administration and corporate overhead allocations. Other costs include distribution, sales general and administrative, and research and development costs.

•The operating costs are based on our historical averages. Other costs are based on our five-year estimate. Costs are assumed to be similar in the future with annual inflation similar to pricing inflation. Modeled underground dry mining costs include a step change in approximately 50 years when longwall mining is phased out and replaced by borer and continuous mining in Bed 15 and the remaining areas of Bed 17.

•Capital expenditures are generally for sustaining production and operating costs. Sustaining capital expenditures in the future is assumed similar to recent history and short-term projections, with inflation similar to product pricing escalation.

•All leases remain valid throughout the time required to mine the reserves.

•All permits remain valid throughout the life of the operation, and no new laws are enacted that require any extraordinary compliance which would significantly impact production or cost.

•New permits and approved mine plans will be obtained for mining reserves that lie within existing leases, but outside of our current mining permit areas.

•Tailings storage capacity will be developed as necessary over the life of the mine and processing plants.

•Because our Alkali Business is structured as a pass-through entity for income tax purposes, there is no provision for income taxes in the cash flow analysis.

Internal Control Disclosure

The modeling and analysis of our resources and reserves has been developed by our mine personnel and reviewed by several levels of internal management and external consultants, including the QP. The development of such resources and reserves estimates, including related assumptions, was a collaborative effort between the QP and our management. This section summarizes the internal control considerations for our development of estimations, including assumptions, used in resource and reserve analysis and modeling.

When determining resources and reserves, as well as the differences between resources and reserves, management developed specific criteria, each of which must be met to qualify as a resource or reserve, respectively. These criteria, such as demonstration of economic viability, points of reference and grade, are specific and attainable. The QP and our management agree on the reasonableness of the criteria for the purposes of estimating resources and reserves. Calculations using these criteria are reviewed and validated by the QP.

We base our mineral reserve estimates on detailed geological, geotechnical, mine engineering and mineral processing inputs, and financial models developed and reviewed by management and technical staff of our Alkali Business, who possess years of experience directly related to the resources, mining and processing characteristics or financial performance of our operations. Additionally, our management and technical staff includes senior personnel who have remained closely involved with each of our active mining and mineral processing operations.

In preparing our reserve estimates for our Alkali operations at Green River, Wyoming, we follow accepted mining industry practice and are guided by our long-term experience in extraction of trona ore from underground mining and sodium carbonate from brine (solution) mining in the district. Estimates of recoverable reserves for both techniques are routinely reconciled with actual production, and our Alkali ore reserves disclosures comply with subpart 1300 of Regulation S-K.

All estimates require a combination of historical data and key assumptions and parameters. When possible, resources and data from generally accepted industry sources, such as governmental resource agencies, were used to develop these estimations.

Management also assesses risks inherent in mineral resource and reserve estimates, such as the accuracy of geophysical data that is used to support mine planning, identify hazards and inform operations of the presence of mineable deposits. Also, management is aware of risks associated with potential gaps in assessing the completeness of mineral extraction licenses, entitlements or rights, or changes in laws or regulations that could directly impact the ability to assess mineral resources and reserves or impact production levels. Risks inherent in overestimated reserves can impact financial performance when revealed, such as changes in amortizations that are based on life of mine estimates.

Documentation of sample security measures, quality control and assurance (“QAQC”) was not observed by the QP. However, given that there has been successful underground dry mining of Bed 17 and Bed 20 within and nearby the exploration sample sites, it would appear that previous sampling methods, sample security, analysis methods, and internal QAQC measures met the requirements for successful mine planning over the history of the Westvaco site and Granger site mining operations.