HomeMy WebLinkAbout20102826.tiff Varra Companies, Inc.
Office of Special Projects
8120 Gage Street Frederick, Colorado 80516 Telephone(970)353-8310 Fax(970)353-4047
Friday 19 November 2010
To: Jared Ebert, EPS
Colorado Office of Mined Land Reclamation
1313 Sherman Street, #215
Denver, Colorado 80203
From: Varra Companies, Inc. — ce7 p.( - ,,JL
Bradford Janes, Professional Forester
Subject: M-1984-036 Dakolios Pit - Reply to the Colorado Office of Mined Land
Reclamation (Office) Adequacy Review correspondence of 3 November 2010.
Dear Jared:
For greater continuity and ease of reference, we have iterated your comments
by item in a graphical box, with our comments in blue following:
Item #1 Agricultural Area:
1) The Division reviewed your response to the Division's concerns raised during
the second adequacy review in regards to the agricultural area. The Division
does not agree the proposed activities for Areas 1 and 3 were the intent of
the original reclamation plan or Technical Revsion No. 2. Changing the
reclamation plan from a topsoiled and re-vegetated plain to a substantial
equipment/material storage area is a significant change in the post mine land
use designated for the site and would require an amendment to the permit.
The Operator has two options:
A) Revise the submitted map indicating Areas 1 and 3 will be re-soiled and
vegetated. Along with this, please indicate the volume of overburden stored
on site (in cubic yards) to fulfill the reclamation requirement. Please identify
the location of any overburden piles within the permit boundary on the
revised map. The Division may consider a request to reduce the amount of
overburden to be replaced on these areas with proper justification.
At this time the Division estimates it would need approximately 27,430 cubic
yards of topsoil to spread 6 inches of material over Areas 1 and 3. The
Division will increase the financial warranty to account for importation of this
varra Companies, Inc. correspondence to the Colorado Office of Mined Land Reclamation(Office)in reply to 1
Office correspondence of 3 November 2010 --Dakolios Pit—M-1984-036.
Vu,hll(. Kt U i eLO 2010-2826
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Varra Companies, Inc.
Office of Special Projects
8120 Gage Street Frederick, Colorado 80516 Telephone(970)353-8310 Fax(970)353-4047
material unless the operator can demonstrate sufficient topsoil is located
within the Dakolios Pit permit boundary.
B) Withdraw this Technical Revision and submit an amendment to the permit and
update the reclamation plan outlining the intended uses of Areas 1 and 3 and
to address the installation of the clay liners.
As discussed on the 9t1 , Varra Companies, Inc., will provide an
Amendment to address the specific matter of the agricultural fill areas and
the desired uses attending to them. The amendment will be submitted no
later than 21 January 2010, and by this commitment, any consideration for
the same, under this Technical Revision, is withdrawn.
Respective of the northwest pond liner, the leak test is underway, and
anticipated to be completed before year's end. The proper assurances of
this test will be provided to the Division no later than 21 January 2010.
All other aspects of concerns respective of commitment of waters is
addressed in item number 2, below.
Item #2 Clay liner of the Northwest Pond:
2) Prior to approval of this Technical Revision, please submit evidence from the
Office of the State Engineer that the Operator has committed sufficient
shares of water to the SEO to cover the augmentation plan for the northwest
pond.
As previously stated to better assure the Office: 'The operator is blessed with
adequate water to assure the Colorado State Engineer Division of Water
Resources that it has sufficient water to commit, and will, commit to the
complete unlined state of the operations until the basins are lined.'
A letter will be obtained from the State Engineer to assure the Office of this
circumstance. This correspondence will be obtained and submitted to the Office
within those guidelines and timeframes afforded under general correspondence
from the Office of 30 April 2010 pertaining to 'Mining Operations with Exposed
Ground Water.'
Varra Companies, Inc.correspondence to the Colorado Office of Mined Land Reclamation(Office)in reply to 2
Office correspondence of 3 November 2010—Dakolios Pit—M-1984-036.
Varra Companies, Inc.
Office of Special Projects
8120 Gage Street Frederick, Colorado 80516 Telephone(970)353-8310 Fax(970)353-4047
Item #3 Bond Estimate:
3) Based on your response to the items above, the Division will conduct a
financial warranty estimate for the current level of disturbance and adjust the
required financial warranty accordingly.
Acknowledged. It is further understood that warranty considerations may
prove pending in part or in whole at the Discretion of the Office,
respective of the forthcoming Amendment application, per Item #1, above.
Item #4 Ilydrologic Balance:
4) The Division approves the locations of the proposed piezometers. Please
specifically state that groundwater elevations will be monitored on a
quarterly basis until the permit has been released by the Division and commit
to supplying the Division with the results of the measurements in the annual
reclamation report. Please indicate when monitoring will begin.
As requested by the Office, Varra Companies, Inc. affirms that the referenced
groundwater elevations will be monitored on a quarterly basis until the permit
has been released by the Division and commit to supplying the Division with the
results of the measurements in the annual reclamation report.
Monitoring will commence within 30 days of the completion of piezometers. We
anticipate both can be accomplished no later than the scheduled 21 January 2010
Amendment submittal. As with all of our 21 January 2010 commitments, Varra
Companies, Inc. will apply due diligence to those ends, and will not seek an
extension of those commitments from the Office without good cause.
Attachments:
1. Proof of Placement of this material with the Weld
County Clerk to the Board.
Varra Companies, Inc. correspondence to the Colorado Office of Mined Land Reclamation(Office)in reply to 3
Office correspondence of 3 November 2010—Dakolios Pit—M-1984-036.
Varra Companies, Inc.
Office of Special Projects
1431 East 16th Street Greeley,Colorado 80631 Telephone(970)353-8310 Fax(970) 353-4047
Friday 19 November 2010
Weld County Clerk to the Board
915 10i6 Street, 3rd Floor
Greeley, Colorado 80632
Subject: Varra Companies,Inc. — Dakolios Pit— Regular Impact(112) Technical Revision
Application —Permit M1984-036
Materials submitted to the Colorado Division of Reclamation Mining and Safety (CRMS)— Office
of Mined Land Reclamation (OMLR):
• Correspondence of 19 November 2010 and attachments.
ATTACHEMENTS:
• None
Your signature below acknowledges receipt of the above referenced material,as attached. The
material should be added to the above referenced Application,as originally submitted to the Weld
County Clerk to the Board,and made accessible for public review.
Received On 711:3U-t,(.v,.la.t,( / '/ , 2010
By: 0 Cr
Office of the Weld County Clerk to the Board of County Commissioners
cr
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Varra Companies, Inc. DAKOLIOS PIT 1
OMLR Techniial Revision — M1984-036 2 July 2010
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