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Home My WebLink About20140281.tiff Varra Companies, Inc. Office of Special Projects 1431 East I6(11 Street Greeley, Colorado 80631 Telephone(970)353-8310 Fax (970)353-4047 Wednesday 22 January 2014 Weld County Clerk to the Board 1150 O Street Greeley, Colorado 80632 Subject: Varra Companies, Inc.- Varra-Coulson Resource Project- Regular Impact (112) - Permit M-2013-064 Materials submitted to the Colorado Division of Reclamation Mining and Safety (CRMS) - Office of Mined Land Reclamation (MLR): • Correspondence of 21 January 2014 from Varra Companies, Inc. to the Colorado Office of Mined Land Reclamation,with attending attachments. Attachments: I Proof of Placement of this material with the Weld County Clerk to the Board. 2 Proofs of Notification — 7pgs. 3 Correspondence of 10 December 2013 AWES, PLC. 4 Signed 13ackfill Notice — pg. 5 of Exhibit E — Reclamation Plan. 5 h:ntisols & Inceptisols examples. 6 Correspondence of 14 January 201.1 — Flow Technologies. 7 Correspondence of 13 January 201.1 - AWLS, PLC. 8 Signed & Notarized Statements of LJnderstancling & related 16 pgs. 9 Map Revisions: a. Revised Floodway & Rip-Rap 07 January 2014. I). Revised in two pages of 20 January 2014 Exhibit C-1 (A) Exhibit C-1 (B) in. Exhibit C-2 e. Revised Exhibit G of 21 January 2014. 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 0O . 2014 By: Ent O111ce of the Wek y Clerk to the Board of County Commissioners Varra Companies, Inc. Varra-Coulson Resource Project OR 112 Permit Application 8 August 2013 TI btIC nQ,Vte ,7? 3 -O7OJLj C L ', V,2oA“\ 2014-0281 • Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(970) 353-8310 Fax (970)353-4047 Tuesday 21 January 2014 To: Peter Ilays, E.P.S. Colorado Office of Mined Land Reclamation (OMLR. or 'the Office') 1313 Sherman St., #215 Denver, CO 80203 From: Varra Companies, Inc. Bradford Janes, Professional Forester Liaison, Office of Special Projects Subject: Varra-Coulson Resource Project OMLR Permit M-2013-0(i=1 For greater continuity and ease of reference, we have iterated the comments from the OMLR Adequacy Review of 16 December 2013, necessitating a reply according to its respective items, iterated in a graphical box, with our comments in blue following: The Division of Reclamation, Mining and Safety (Division) has reviewed the content of the Varra Companies, Inc. 112c permit application for the Varra- Coulson Resource Project, File No. M-2013-064 and submits the following comments. The Division is required to make an approval or denial decision no later than January 3, 2014 therefore; a response to the following adequacy review concerns should be submitted to the Division as soon as possible. The review consisted of comparing the application content with specific requirements of Rules 1, 3, 6.1, 6.2, 6.4 and 6.5 of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials. Any inadequacies are identified under the respective exhibit heading along with suggested actions to correct them. 1. As required by Rule 1.6.2(d) and 1.6.5(2), please submit proof of publication in a newspaper of general circulation in the locality of the proposed mining operation. 1 The Division received proof of publication in the Greeley Tribune on November 21, 2013. Acknowledged. 2. As required by Rule 1 .6.2(e), please submit proof of the notice to all owners of record of surface and mineral rights of the affected land and the owners of record of all land surface within 200 feet of the boundary of the affected land including all easement holders located on the affected land and within 200 feet of the boundary of the affected land. Proof of notice may be return receipts of a Certified Mailing or by proof of personal service. On November 21. 2013, the Division received proof of notice for the adjacent landowners, structure owners and easement owners from the Applicant. Please provide proof of notice for the following landowners and easement holders: a. Doeringsfeld & Aratas Partnership b. Varra Companies, Inc. c. Jack Allmer d. J.W. Duff Aircraft Company, 575 Crosier Avenue #15, Greeley, CO 80(332 e. Merit Energy Company, 1327 Noel Road, Ste. 1200, Dallas, TX 75240 f. Century Link, 2505 151 Ave., Greeley, CO 80631 — proof of personal service a & I). Varra Companies, Inc.: and as agent for the Aratas Partnership, provided a signed and notarized affidavit of notification, which was included with the other proofs as received by O\ILR on 20 November 2013. We have included a copy with this reply. c. Jack Allmer was sent notifications. Postage was sent 15 October and returned over a month later on 1 1/20/13 as `unclaimed' and 'unable to forward,' as shown in the copy of the envelope, and received by us a day after our submittal to OMER. We have no other address for this individual. d. .I.W. Duff Aircraft Company had multiple addresses. Delivery to 575 Crosier Ave. failed: however, Delivery to (375 Airport Road #36 succeeded, as shown in proofs submitted to OMEN on 20 November, and copied in this submittal. Similar to Jack Allmer, the notice sent to 575 Crosier Ave was sent 15 October and returned over a month later on 11/20/1;3 as `unclaimed' Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 2 Correspondence to Peter Hays 21 January 2014 and 'unable to forward,' as shown in the copy of the envelope, and received by us a day after our submittal to OMLR. I!nlike Allmer, we had an alternative address that was successfully delivered. as stated. Copies are included with this submittal. e. We attempted to deliver to two different addresses for Merit Energy Company. As shown in our proofs provided to the OMLR on 20 November. the notice addressed to 1313 North Denver Ave.. Fort Lupton was returned undelivered and marked 'unable to forward.' Also included with our proofs to the Oi\ILR was attempted delivery to 1327 Noel Road in Dallas. and no green card or envelope was returned. Copies are also included with this submittal. g. Proof of notification to Century Link was provided to the OMLR on 20 November. The proof was originally sent to 12(i80 Weld County Road 58 and returned as undelivered. We called Century Link and hand delivered the notice to Carson Ortega at 2505 1" Avenue in Greely. Mr. Ortega's signature and confirmation of the address and delivery is shown on the green card provided to the OMLR on 20 November. a copy of which is included with this submittal. Please note the box marked 'yes' just. above the 1' Avenue address which states: 'Is delivery address different from Item 1? If yes enter delivery address below.' Mr. Ortega completed the information in the box as shown. Please note that due diligence and every reasonable good faith effort to notify the required interests was made on our behalf. In many instances. where some interests were not known to be within 200 feet of our parcel. but were known to be nearby, we made an attempt to notify. Often multiple addresses were used where they were known to attempt notification. If new information about an address was learned, a second attempt. was made to notify. We trust this information provided in this reply assures the OMLR of that. proper and faithfully executed effort. 3. The Division received comments from the Colorado Division of Water Resources, History Colorado, the Army Corps of Engineers and Mr. Paul Lightsey. The letters are attached for review. Please address the comments noted in the letters and make any changes to the application as necessary. a. Colorado Division of Water Resources: Prior to exposing groundwater, Varra Companies, Inc. will provide the OMLR the following from the Office of the State Engineer: • An approved well permit for the planned basin. Varna Companies, Inc. Coulson Resource Project OM LR M-2013-064 3 Correspondence to Peter Hays 21 January 2014 • An approved Substitute Water Supply Plan. b. History Colorado: With respect to the concerns expressed by Edward Nichols, State I listoric Preservation Officer, if any cultural resource or hui11ai1 remains are discovered during project activities. ` arra Companies. Inc. will comply with C.R.S. 2'1-80 (Part. 13). A cultural inventory is taking place over the property by a professional Archaeologist as part of our efforts to gain authorization from the Army Corps to provide for the relocation of the irrigation ditch segment identified in the permit application text as Canal #3 and on im.ip exhibits as Ditch #3. c. Army Corps of Engineers: The applicant is presently seeking authorization from the Army Corps for the relocation of a segment of the irrigation ditch identified as Greeley Canal #3, and as approved by the Greeley Irrigation Company. A copy of the agreement is included with this submittal. No impacts to wetlands. the referenced irrigation ditch segment, or wetlands in general will occur until authorized by the A.C.E. for the specified activity. Copies of any letters of authorization will be provided to the OMI,R. (l. Paul Lightsey: Please refer to correspondence of 10 December 201:1 from AWES, 1.1,C. 6.4 SPECIFIC EXHIBIT REQUIREMENTS - REGULAR 112 OPERATIONS The following items must be addressed by the Applicant in order to satisfy the requirements of C.R.S. 34-32.5-101 et seq. and the Mineral Rules and Regulations of the Mined Land Reclamation Board: 6.4.3 Exhibit C - Pre-Mining and Mining Plan Maps of Affected Land 4. The red text in the Exhibit C-1(A), C-1(B) and C-2 maps are difficult to read. Please revise the maps to provide for more legible text on the maps. A match line has been established to spit the above referenced neaps and enlarge the scale so the included text can be more readily discerned. The new map exhibits are now in two parts each, as provided with this submittal. 6.4.4 Exhibit D - Mining Plan Van-a Companies, Inc. Coulson Resource Project OMLR M-2013-064 4 Correspondence to Peter Hays 21 January 2014 5. Please confirm the Applicant intends to operate the site continuously or if the Division should consider the site an "intermittent operation" as defined in C.R.S 34-32.5-103(11)(b). Operations will be continuous in that they will not trigger temporary cessation requirements without prior notice by the operator to the OMLR. 6. The Applicant states materials may be conveyed to the adjacent Durham Project for processing and sale. Please include construction and design details for the conveyor structure or commit to submitting a technical revision to the permit in the future to include the conveyor structure in the permit. No conveyor systems will be established without. prior approval from the OMLR 1)y Technical Revision. 7. The Applicant states the method of mining is "presently" dry. Please confirm mining activities have not started at the site and describe all water diversions and impoundments required for the proposed dry mining method. Extraction activities have not commenced. as witnessed by a recent inspection of the location by the OJ\`ILR on 12 December 2013. No extraction activity will occur prior to permit approval, except for that activity allowed as a use by right under state, county, and local laws for the lands as presently zoned. 6.4.5 Exhibit E - Reclamation Plan 8. Please provide a signed copy the backfill notice by Mr. Christopher Varra. A signed backfill notice is included as an addendum to this submittal. 9. Please state if the Applicant intends to use fertilization as part of the Reclamation Plan. If so, please specify types, mixtures, quantities and time of application. Fertilization will not l)e determined until soil testing of replacement soils occurs. Soil will he submitted to the CSt 1 Soils Lab in Ft. Collins, Colorado for a recommendation prior to seeding. The recommendation will he included in the subsequent Annual Report to the OMLR. A generic estimate for the application of fertilizer was provided under Exhibit I. Reclamation Costs. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 5 Correspondence to Peter Hays 21 January 2014 Fertilizer rates can vary dramatically. Until a specific fertilizer recommendation is determined from soil testing of stockpiled soils prior to resoiling activity, a standard agricultural application of NPK can be applied based upon OMLR estimates of fertilizer costs in its proprietary software. In general. fertilization does not occur until AFTER grasses have emerged in order to minimize competition from weeds, and only to the extent indicated by soil tests. A starter fertilizer may be necessary if fertility levels are too low in the native soil, but this is not anticipated, and as a general rule of tha.imb, overall rates when recommended and applied will be comparatively lower for native grasses than for crops. Again, while the application sloes not forecast a need for fertilization or assume specific rates, it does provide for potential application, as identified under Exhibit I_ Reclamation Costs. 10.As required by Rule 6.4.5(1), please state the depth of overburden to be salvaged, where the material will he stockpiled, and the depth to which overburden will replaced during reclamation. "There is no overburden at this location. All extracted earth resources will be used and processed, stockpiled, sold, and transported off-site, with the exception of topsoil necessary to reclaim the affected lands. 1 l.As required by Rule 3.1.9(3), topsoil stockpiles shall be stored in places and configurations to minimize erosion and located in areas where disturbance by ongoing mining operation will be minimized. The Hoard may require immediate planting of annual and/or perennial grasses on topsoil stockpiles for the purpose of stabilization. Please depict on Exhibit C a typical topsoil stockpile location for each field and commit to seeding all stockpiles, if not replaced within 130 days with a temporary vegetative cover. Soils stockpiled and reserved for reclamation, and not otherwise disturbed by accumulation of additional soils or utilization during reclamation, will be stabilized with a vegetative cover established by utilizing the approved seed mixture. The seed mixture utilizes a hybrid cover species that will aid stability until the more native species have opportunity to express themselves. Since there is no rule or regulation specifying immediate stabilization, which is impossible, or a 180 day requirement, which is fiat, the applicant proposes to seed either at the end of the growing season or the onset of the next, once the stockpile has reached stasis. The approximate area and extent of the soil stockpile is shown within the plant and stockpile area on the revised Exhibit C-2: Extraction Plan Map, as Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 6 Correspondence to Peter Hays 2I January 2014 included as an addendum to this submittal. . As can be seen, the soil stockpiles as they encompasses portions of the west and north lot line of the Corral parcel, will function to further limit operational effects to the nearby residence. A typical cross-section will encompass an area nearly 75 feet long, at 3 feet in height with 311: 1V slopes for a total width of 21 feet. The cross-sectional area is sufficient to store the necessary volume of soils needed for reclamation, as detailed under part. 12, below. 12.The Applicant proposes to replace a minimum of 6 inches of topsoil on the reclaimed areas. The NRCS soils report states topsoil depths ranges from 0 to 13 inch in the majority of the South and Middle Fields and the report by AWES, I..I.C dated July 22, 2013 states three to five feet of topsoil is present based on soil borings conducted on the site. Additionally, only approximately 10% of the mined area will require topsoil replacement due to the creation of the clay lined reservoir. Therefore, the Applicant should replace topsoil to a depth at least equal to the existing topsoil depth of three to five feet. Please commit to replacing topsoil to a minimum depth of three to five feet over the reclaimed upland areas. Exhibit C- 1 : Existing Conditions Map. show the two predominant soils within the extraction limits. Both are commonly associated along alluvial pathways and floodplains along the Front Range. Middle Field is dominated by Soil Unit. 10 - Bankarcl Soils, with some overlap of Soil Unit 3 - Aquoil/Aquerat Soils. which essentially covers the balance of South Field. The I3ankard Soils have a Soil Series Description. The Aquoll/Aquent Soils do not. This is an important distinction, since soils lacking a soil profile description are generally considered Entisols, while those with poorly formed profiles may be considered Inceptisols (please refer to attached descriptions of Entisols and lnceptisols). Generally. topsoil is understood to he the A-1. or more generously the upper A profile of a developed soil profile: and otherwise where it exists the Ap or 'plow layer' where it is either absent or in the event where it is shallower than the six inch plow layer, made deeper by cultivation and assigned the Ap designation. In poorly formed soils, there is no distinct soil peckrra and soil depths can vary dramatically every three feet or so. Contrary to the American propensity that more is better, such is seldom the case in soil as it increases in depth from the surface. Commonly, in all soils, but especially in poorly developed soils, the sleeper you go. the less organic matter, the lower the fertility, and the poorer the soil texture, if any. A lack Varra Companies, Inc. Coulson Resource Project OM LR M-2013-064 7 Correspondence to Peter Hays 21 January 2014 of soil texture, organic matter, and overall general fertility of soils decreases with increasing depth. Another factor is overall field capacity, moisture holding and fertility holding capacity. which generally decreases as soil texture tends toward sand and gravel, as in this instance. This can be compounded in irrigated lands by the concentration of salts at lower levels of the soil horizon, where it exists. "I'o capture the entire soliim of such soils is ill advised for purposes of reclamation and a prescription for revegetation failure on drastically disturbed lands. It has been widely understood in such circumstances, as established by over three decades of similar permits in similarly sited locations, to salvage the upper six inches of such soils and set that aside for establishment of grasses. What is commonly absent in the regulation and (-)MLR review is a consideration of rooting depth, which this application volunteers and discusses at some length. The application assures a proper rooting depth of two feel, which is adequate in most instances, even with a restrictive layer. for which at this location there is not. The application under Exhibit 1/.l offers assurances of an additional 18 inches in depth of unconsolidated material to aid in root growth development, or two feet when the replaced soil depth is considered. This depth can be assured for any discovered compacted areas by the use of rippers. Generally. compaction and unconsolidated materials are riot a concern over the un-extracted segments of the site and should be more than adequate to assure unconsolidated depths beyond two feet. and sufficient. to establish grasses, trees and shrubs. As the site will be returned to developed water resources, the establishment of trees and shrubs are not prescribed, only grasses. The ()MLR has a history of approving shallower rooting depths for rock quarries and is essentially absent of this consideration in its regulations, reviews, and absent of any data gathering of the thousands of sites reclaimed and released over its 42 year history. While the applicant commits to a minimum replacement of six inches of soil under an environment of regulatory force: as assured by the larger Ap layer evident over South Field, depths may be greater since material placement by heavy equipment isn't exactly performed with surgical precision. Regardless. the use of the term `topsoil' has specific limitations. Even the definition under Rule 1.1(32) topsoil is described as the material at the surface of the earth which has been so modified and acted upon by physical, chemical, and biological agents that it will support rooted plants necessary to achieve reclamation goals. It is highly improbable that depths beyond 0 inches over poorly developed soil profiles meet even this intent. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 8 Correspondence to Peter Hays 21 January 2014 The °MLR history is replete with the approval and release of similarly sited and equally committed operations whose salvage of the upper six inches of the solunr was sufficient, even in the face of soil profile descriptions where a formed and deeper A or B profile is evident. The C profile has never been considered to our knowledge. There is neither an A (except for the Ap layer created by cultivation) for the I nit 3 soils. There is a 0-4 inch A layer for the Unit 10 soils, underlain by a C profile, and lacking a 13 soil profile horizon. In this instance, a 0-18 inch description for Unit 3 Soils simply means soil may be absent or poorly developed to a depth of 48 inches. The variation is too great to even mat), and soil is often absent as evidenced by exposed sand and gravel at the surface within this area. The lower depths of this soil unit are commonly sand and gravel, which is a recoverable resource, as is the excess soils where it exists, commonly utilized off-site for urban and infrastructure development, for which the economy of this state relies. There is no evidence that increased soil depths will benefit the final reclamation and stability of the location. Since the majority of the area where soils are impacted are within the extraction limits, the operator is more than willing to keep soils in-situ outside of the extraction limits to minimize disruption of the soil structure, texture. percent organic matter and other soil qualities destroyed (luring salvage and stockpiling. This reduces the total soil salvage volume to 3,( 48.20 cu.yds., or a decrease from the 5.307.87± cu.yds. indicated under Exhibit L - Reclamation Costs, of 1659.58 cu.yds. Regardless, adequate area for salvage and placement of soil is maintained within the existing stockpile area shown under Exhibit C-2: Extraction Plan Mat:). 6.4.7 Exhibit G - Water Information 13.The Division's engineering staff reviewed Exhibit G - Water Information. A copy of the review memo from Tim Cazier, P.E. is attached. Acknowledged. Refer to correspondence of 1:3 January 2014 from AWES. LI,C: and correspondence of 14 January 2014 from Flow Technologies. Associated attachments and revised maps are included with this correspondence. 14.Groundwater monitoring well are mentioned in the Dewatering Evaluation Report by AWES, LLC and were observed during the pre-operation Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 9 Correspondence to Peter Hays 21 January 2014 inspection on December 12, 2013. Please indicate the location of the monitoring wells on the Exhibit O map. Refer to correspondence of 13 January 201.1 from AWES. LI,C. 15.Please commit to provide the Division with monthly monitoring well data as part of the annual report for the site. Refer to correspondence of 13 January 2014 from AWLS, Ilk. 16.Please provide proof of monitoring well installation permits from the Office of State Engineer to the Division. Refer to correspondence of 13 January 2011 from AWES, I.I.C. 17.The AWES, LLC report states there are a number of domestic wells located within the area influenced by pumping. Though there is sufficient aquifer thickness to provide good well yields there may he partially penetrating wells that might be affected by mine dewatering. Please provide a mitigation plan with trigger levels for the potential impacts to the surrounding groundwater wells. The Applicant must explain any mitigation measures to be implemented and trigger points which would put mitigation measures into effect. Typically, a trigger point of a 2 feet change from historic ground water levels is acceptable. Refer to correspondence of 13 January 2011 from AWES, LLC. 18.Please state if all the registered alluvial wells within 600 feet were identified based on SEO records and if field inspections were conducted to identify all wells within 600 feet. Refer to correspondence of 13 January 201.1 from AWES. LLC. 19.The Dewatering Evaluation Report by AWES, LLC predicts the cone of depression and radius of influence, the horizontal and vertical extent, for the expected impacts at the Coulson site due to the planned dewatering and dry mining operation in combination with the effects of the dewatering of the Durham site. The Division does not agree with the statement on page 4 of the report that the predicted drawdown at 380 feet is 7.65 feet. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 10 Correspondence to Peter Hays 21 January 2014 Refer to correspondence of 13 January 201-1 from AWES, PLC. Plate 4 Durham Pumping Simulation indicates a current groundwater elevation at MW-4 of 4616 and a current groundwater elevation of 4620 approximately 380 feet south of the southern permit boundary. Plate 5 — Coulson Pumping Simulation indicates a modeled groundwater elevation at MW-4 of 4600 and a modeled groundwater elevation of 4605 approximately 380 feet south of the southern permit boundary. This is a drawdown of 15 to 16feet, not 7.65 feet, which could impact the groundwater wells located near the permit boundary. Refer to correspondence of 13 January 2014 from AWES, LLC. Additionally, the model does not indicate the historic, pre—Durham dewatering, groundwater elevations and potential effects. Please model the potential effects of the proposed dewatering activity from historic groundwater elevations and reevaluate the results of the model from the Durham to Coulson simulations. Refer to correspondence of 13 January 2011 from AWES. LLC. Please provided and explain the mitigation measures to be implemented for the potential impacts to the surrounding groundwater wells and trigger points which would put mitigation measures into effect. Typically, a trigger point of a 2 feet change from historic ground water levels is acceptable. Refer to correspondence of 13 .January 201.1 from AWES. I.I.C. 20.The Shadow/Mounding Analysis by AWES, [PC dated June 27, 2013 does not accurately predict the potential shadowing and mounding effect of the proposed clay liner at the Varra-Coulson site. The Applicant must define or predict the shadow and mounding effect expected for the Coulson site not Varra Pits 110 and 112. If the analysis determines a shadow or mounding effect will occur offsite impacting a groundwater user, the Applicant must explain all mitigation measures to be implemented and trigger points which would put mitigation measures into effect. Typically, a trigger point of a 2 feet change from historic ground water levels is acceptable. The mitigation measures must include a scenario for the installation of a French drain to direct groundwater around the clay liner and restore groundwater levels to the historic elevation in area of groundwater mounding. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 11 Correspondence to Peter Hays 21 January 2014 Refer to correspondence of 13 .January 201 .1 from AWES, I.I.C. 21.Please state if the Applicant is pursuing agreements with the existing well owners within 600 feet of the site. Please provide signed copies of the agreements if available or provide evidence the appropriate notice was provided to the well owners. Refer to correspondence of 13 January 201 .1 from AWES, LLC. 6.4.12 Exhibit L - Reclamation Costs 22.The Division will estimate the cost to reclaim the site based on the information submitted once the Applicant addresses the concerns noted in this letter. The Division will include costs to comply with the Office of the State Engineers requirement for out-of-priority groundwater depletions. The reclamation plan states a 59.30 acre clay lined reservoir will remain as the post mine land use. The Division is required to set the financial warranty at a level which reflects the actual current cost of fulfilling the conditions of the Reclamation Plan per Rule 4.2.1(1). The Division has identified several options for determining the amount of the financial warranty. The Applicant must choose one of the following options to be included in the financial warranty calculation: a. Backfill the pit to two feet above the groundwater level. b. Install a slurry wall or clay liner. c. Provide the Division with documentation from SEC), which demonstrates the Applicant owns a sufficient amount of shares of water to cover the evaporative losses from the exposed groundwater and the said shares have been committed to the SEO should the financial warranty be forfeited and the permit revoked. Prior to exposing groundwater, Varra Companies, Inc. will provide the OINIL.R the following from the Office of the State Engineer: • An approved well permit for the planned basin. • An approved Substitute Water Supply Plan. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 12 Correspondence to Peter Hays 21 January 2014 • Documentation with the Office of the State Engineer demonstrating the applicant owns and has committed sufficient shares of water to cover the evaporative losses from the exposed groundwater anticipated in the OMER permit. Consistent with information provided under Exhibit G Water Information (specifically parts (a) and (4). Varra Companies, Inc. has sufficient water to meet this consideration in lieu of direct financial warranty cost considerations. The Division will calculate the cost to install a clay liner at the site, since the post-mining land use is developed water resource unless otherwise instructed by the Applicant. Please refer to part C.. above. The applicant has sufficient water to cover exposed groundwater, dust suppression, and related groundwater demands, until installation of the clay liner is completed over the extracted basin. 6.4.13 Exhibit M - Other Permits and Licenses 23.Please commit to providing the Division with copies of the approved permits and licenses required for the Varra-Coulson Resource Project. Varra Companies, Inc. will provide proofs of the approved permits and licenses prior to onset of extraction activities not otherwise allowed by law. and consistent with the terms of the approved O 11.R permit. 6.4.18 Exhibit R - Proof of Filing with County Clerk and Recorder 24.Please provided an affidavit or receipt indicating the date on which the revised permit application information required to address this adequacy letter was placed with the Weld County Clerk and Recorder for public review, pursuant to Subparagraph 1.6.2(1)(c). Proof of placement of this correspondence and related attachments and addendums to the Weld County Clerk to the Board is included as an addendum to this submittal. 6.4.19 EXHIBIT S - Permanent Man-made Structures Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 13 Correspondence to Peter Hays 21 January 2014 Where the mining operation will adversely affect the stability of any significant, valuable and permanent man—made structure located within two hundred (200) feet of the affected land, the Applicant may either: a. provide a notarized agreement between the Applicant and the person(s) having an interest in the structure, that the Applicant is to provide compensation for any damage to the structure; or b. where such an agreement cannot he reached, the Applicant shall provide an appropriate engineering evaluation that demonstrates that such structure shall not be damaged by activities occurring at the mining operation; or. c. where such structure is a utility, the Applicant may supply a notarized letter, on utility letterhead, from the owner(s) of the utility that the mining and reclamation activities, as proposed, will have "no negative effect" on their utility. 25.Please provide the Division with signed copies of the notarized structure agreements with all owners of the structures on and within 200 feet of the affected area of the site. As provided in Part h. above, an appropriate engineering evaluation demonstrates that area structures will not be damaged by planned extraction activities. This evaluation is provided in tandem with our efforts to notify and gain agreement with owners of structures consistent with Part a, above. Signed agreements are provided where obtained. Notification of owners of structures occurred consistent with past notification statements made from our recently approved permits. 6.5 Geotechnical Stability Exhibit 26.The Division's engineering staff reviewed the slope stability analysis report included with the Varra—Coulson site dated June 27, 2013. A copy of the review memo from TC Wait is attached. Acknowledged. Refer to correspondence of 13 January 2011 from AWLS, LLC. • Marra Companies, Inc. Coulson Resource Project OMLR M-2013-064 14 Correspondence to Peter Hays 21 January 2014 27.The Applicant states operations will remain 125 feet or greater from residential structures, not otherwise owned or controlled by the Operator. The mining plan map indicates the Operator will mine within 10 feet of the residence owned by Mr. Jesse Corral. Please explain this discrepancy and consider increasing the offset between Mr. Corral residence and the mining disturbance. Extraction activities will occur to within 10 feet of parcel lines, rights—of— way, or easements. The Corral residence, a structure, will not see extraction activities within 125 of the structure, and no closer than 10 feet from the parcel boundary, consistent with setbacks specified by Weld County Code. The specialist may have confused an outbuilding with the residence. 28.The Slope Stability Analysis report prepared by AWES, LLC indicates 17 soil borings were drilled from the ground surface to bedrock at the site. Please provide the Division with copies of the boring logs. Refer to correspondence of 13 .lanuary 201:1 from AWLS, I,1.C. Please be advised the Varra-Coulson Resource Project application may be deemed inadequate, and the application may be denied on January 3, 2014, unless the above mentioned adequacy review items are addressed to the satisfaction of the Division. If more time is needed to complete the reply, the Division can grant an extension to the decision date. This will he clone upon receipt of a written waiver of the Applicant's right to a decision by January 3, 2014 and request for additional time. This must be received no later than the deadline date. On 18 December 2013, the OMLR extended the Decision Date to 2 February 2014. By this submittal, Varra Companies, Inc. requests additional time for the benefit of the OMLR to reply to this submittal. Please extend the Decision Date an additional 30 days beyond 2 February 2014. Attachments: 1 Proof of Placement of this material with the Weld County Clerk to the Board. 2 Proofs of Notification 7pgs. 3 Correspondence of 10 December 2013 - AWES, I.I.C. 4 Signed Hackfill Notice — pg. 5 of Exhibit E Reclamation Plan. 5 Entisols & Inceptisols examples. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 15 Correspondence to Peter Hays 21 January 2014 6 Correspondence of 14 January 2014 — Flow Technologies. 7 Correspondence of 13 January 2014 AWES, EEC. 8 Signed & Notarized Statements of Understanding & related - 16 pgs. 9 Map Revisions: a. Revised Eloodway & Rip-Rap 07 January 2011. b. Revised in two pages of 20 January 2011: Exhibit C-1 (A) Exhibit C-1 (13) Exhibit C-2 c. Revised Exhibit (4 of 21 January 2011. Varra Companies, Inc. Coulson Resource Project OMLR M-2013-064 16 Correspondence to Peter Hays 21 January 2014 Affidavit 1'NO\1' ALL 1'II;v B\ THESE PRESENTS, that I. ( arretn ( '. \';n.ra. \"r,•e•I'resident „i Operations. Varra Companies, Inc.. testily and affirm receipt ofproper noii;l::;iiun as to the Public Notice and any consideration for the stability of our structures tor :lira ('ompanies, Inc.. and as the land manager on hehallol•Deoringslield and Partnership: for OMI.R Permit Application vl-2t)I ;-0)h-1 \urea-Coulson •I•his testimony is EXECLITEI) this I7th day of October. 2_t►I 3. . Garrett C. \''arr:l. Vice-Prl'.`:Ide;}i r )I1erations Varra Companies. Inc. t)F (.'Ol.(•)R,\})O ) SS: COUNTY l Y OF BONDER ) S 'lime foregoing signature was acknowledged heti:we me this _ r_._. day o .....: , 2013. by, the Principal. IN WIIFI•NLSS WI-IC REOF I have affixed by hand 'lnd Notarial Seal the 1la., and year last above written. My commission expires: `-1/ f !. �_ JESSICA HOOVER NOTARY PUBLIC ,vc�t'iry Public OF COLORADO NOTARY ID 20044035571 I My Commission Expires 0cL 4, 2016 i : ,='4!'.... 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I. •, 1.; 1:77:4(4):A `.t �` L:y December 10, 2013 Varra Companies 8120 Gage Street Frederick, Colorado 80516 Attn: Mr. Garrett Varra RE: Well Inspection Record Lightsey Domestic Well Weld County, Colorado AWES No. 1-1-108 Dear Mr. Varra: At the request of Varra Companies, Inc. (Varra) I inspected the domestic well currently owned by Mr. Paul A. Lightsey of Greeley, Colorado. The purpose of the inspection was to document the construction details of the well and respond to concerns presented in a letter dated October 27, 2013, addressed to Mr. Garrett Varra of Varra Companies, Inc. Mr. Lightsey's letter is presented in Attachment A. The well is located approximately 300 feet south of the southern extent of the Varra Coulson gravel quarry mine (DRMS Permit # M-2013-064). The well inspection was conducted on November 26, 2013. Personnel present during the inspection were Mr. Brad Janes, me and Mr. Paul Lightsey. The site location is depicted on Figure 1. The location of the well with respect to Varra mining operations is also depicted on Figure 1. The concern presented by Mr. Lightsey was that the predicted drawdown in the vicinity of his well (based on numerical analyses) would diminish or eliminate the ability of the well and pump to provide irrigation water. Based on my inspection it is my opinion that dewatering associated with the Varra Coulson mine has the potential to reduce or eliminate the ability of the pump, in its current configuration, to generate the required suction lift. If the well is retrofitted with a submersible pump the well has sufficient water column to supply the needs for light irrigation use. The rational for this opinion is provided below. The construction details of the well of interest are as follows: 1. Four-inch diameter, steel casing (assumed) with expanding well seal; 2. Top of well casing approximately 4.5 feet below grade located within a circular concrete vault; 3. Depth to water measured at 7.5 feet below top of casing (TOC); Lighlsey Well Inspection Record Greeley,Colorado I',vv 2 4. Depth to well bottom measured at 47.17 feet below TOC; and S. Pump type—centrifugal suction with drop pipe and foot valve. A numerical groundwater model presented by AWES indicated that drawdown induced from Varra dewatering operations in the vicinity of the well could be on the order of 20 feet. 'The existing depth to water below the suction pump was measured at 7.5 feet below TOC. It is estimated that the maximum practical dynamic suction lift at the well's elevation is on the order of 22-24 feet. Adding the maximum expected drawdown to the measured depth to water yields an elevation that exceeds the pump's practical dynamic suction lift. Assuming worst case, at a 20 water level change there would still he approximately 19.5 feet of water column in the well. The current water volume needs were not indicated but based on past experience light irrigation usage for a seven sprinkler head zone is estimated at 35 gallons per minute. The expected drawdown using twice this volume is calculated at 11 feet, which would leave S to 9 feet of water in the well during pumping. Predicted drawdowns calculations are presented in Attachment B. The well casing appeared to have significant iron carbonate or sulfate scaling at the time of the inspection and well yields may be dramatically lower than calculated volumes. If a new pump installation is required it may be advisable to jet the well prior to the pump installation. If you have any questions regarding this letter or attachments, please contact me at 970-590-3807. Sincerely, AWES, LLC Joby L. Adams, P.G. Principal/Hydrogeologist REFERENCES Raghunath, H. M., 1987. Ground Water. Wiley Eastern Limited, New Delhi, India, pp 231- 232. I o FIGURE 1 - SITE LOCATION MAP . , _�1•• .... 1.11�••t;_.111:4(1. • • n Po4ti :4659 •%.R:..i i �k I it..:1 •ii 4662:.... :•'. ,� i. 4G4'•al' • r: ,� • • •I` MuairipAl I • `-... • : .. i�Ir Pori i6.7EI 9. ?' I.' -+r.. La67.8 Y . r^:� .ir• _-,s,•.. I .'ftl " :)0l��y-.':,,--.-atiy 46,2/ '�' ill'. p 1 I., i Approximate Mine Boundary r —T --• 4 39 •. .I. : • t I.'� I j r::1 ('Cr/'/1,.�, - ,�. -.1 � . /. {•iavel Pltr. ,,,. ' 'r 1'1 I.;• ••a• • •'3•••} j. 4A.i.:ti,•• .•; _ n I Grove • I. .•• y:i_• :. Approximate Well Location • ; ' • • (4.'Y,,r loll r I 'MC ••II0 f 1 •• • 1.4•6•45 .",� : : . • 464 •le•. '41;1r: • ..• •.. ..... • _ ' 1 .44.6.•. : •.� {5 l ''�4tr41 j'4 i► L!f? R' .:la. • I •• • R _ . •1'' Lr 1 •I I;r.ftiv:PION'.< ' I:O I • .1 , 'I •'. n• � • I i ..ii.V.•:-- ,�(ivel})il. oar 46x5 i 4(:i: • • I f•�I Tf.l+•' '.;t, 11/ l.•�: I1 , •. • It.84 •i • /��I A r� '' t. • I, L..... - — -- iY I. • .--•••••••• ......-. \ 46-r...• t" r 46..- ,,.•,,II 1 t,:•- ' ,%;.•- .. ...... }t4fi•,�.. I' ..y F:17•tl • . • `.. • , 46.•O • • • 11. •f i • it .. e:.. -. _ .I e i ,41.I ••. \•• 'I ' 1 I II % I I . I 1.� 1 -- .. 1 ..Il��jiill.I 'i. ---•/:tl .._..,r::i�'lli'i.'. . . I��' I 1 .1. -.�. .I. .I... ATTACHMENT A LIGHTSEY LETTER ATTACHMENT B CALCULATIONS 1 he calculated drawdown for the Lightsey well was estimated by use of the equation: C3 = 1 (Raghunath, 1987) SW 1.4 where: T = transmissivity(2,500 ft2/day—20 feet of saturated thickness x 125' per day) Q = pumping rate(100,800 gpd or 13,477 ft3/day) SW = drawdown in feet(calculated) The efficiency of the well is assumed to be 70%. Thus,the specific capacity is: T x 0.70 = 7500 ft2/day x 0 7 = 1,250 ft2/day 1.4 1.4 SW = 13,477 ft'/day = 10.78 feet 1,250 ft'/day Note:the above calculations assume steady state conditions. I�,xhibit I? Reclamation Plan BACK rill NOTICI Inert fill may be imported or utilized from existing sources, along with processing liue,s and reject material to fill portions of extracted areas the extent and location of which will he field determined during final reclamation in order to advance alternative end-use potentials Ior post extraction development. The estimated total volume of till will not exceed the total volume of material extracted from the location, or as otherwise determined. The date of fill activity will commence at onset of approval of this application, and continue for the life ofthe project, estimated al 30± years. Material will he mixed with on-site processing lines and reject prior to fill to eliminate void spaces, where necessary. The tilled portions ofa given tract will be re-vegetated with the approved seed mix where it meets the conditions described under Exhibit I - Reclamation Plan. All material either extracted on site. or imported to the site, will be handled in such a manner so as to prevent any unauthorized release of pollutants to the surface drainage system. No unauthorized release of pollutants to groundwater shall occur from any materials mined, handled or disposed of within the permit area. I, Christopher L. Varra, hereby attest that the material to be utilized as inert fill in the area described us the Varra-Coulson Resource Project, is clean and inert as defined in Rule 1 . 1(20) of the Rules and Regulations. Chris opher L. Varra, President Varra Companies, Inc. Varna Companies, Inc. Varra-Coulson Resource Project OM1.R 112 Permit Application August 2013 1 >t • , . f � + 7r ery 1 w"d'lb \*1•r0 y /• -41.44 \/rl � `il• S, ,!" c; •,rid _ • • Entisols are soils that show little or no evidence of pedogenic horizon development. Entisols occur in areas of recently deposited parent materials or in areas where erosion or deposition rates are faster than the rate of soil development; such as dunes, steep slopes, and flood plains. They occur in many environments. ENTISOLS MAKE UP ABOUT 16% OF THE WORLD'S ICE-FREE LAND SURFACE. 1ucS 4, T` o „. ,,.. . . ..,,,,.. ,, .., ,.....,.,,..„5..,:.. ,,..,,..,..„,. t. ' .a▪ ZI , .,,..yy -4,:cS • -2: 444:. Lim ' ;ITTi"', h fie, xr" 4 : -,,,,s-C4•-•:'.',1.4.7-t---'. �- .'"MM`. 4. y N d.4,,,,./7":„.„"'„N.:4:::::4 ,..: w ..i `s --i+0. ,j.' • . a5, : .e. - 1 ' a¢ . �,-.. .gyp �; =s v '.. ' ' �` rut s r wi 'Fy�"^[n"W "to f f.. �� ,: t< "'n 4 ;'iy5 r e-y.di t 'r7X .. ,�t ^l✓P ,�';:r-? at r-��lc-"z ,. ••. • - aT rr- F W: .....•,, F>K ✓ A �. i y , - 4. • AJY1 k npKx .„ . v P- .i ; yv �Y in,eptisols are soils of semiarid to humid environnxnis Iliac generally exhibit only moderate degrees of soil weathering and development. Inc eptisols have a wide range in characteristics and occur in a wide variety of c limates. INCH'IISOLS MAKE UP ABOUT 1 7% OF THE WORLDS ICE-FREE LAND SURFACE. f IOW Hydraulics P.O. Box 6100 Breckenridge, CO 80424 Hydrology 970-547-3823 ,echnologies www.flowtechnologies.biz Water Resources MEMORANDUM Date: January 14, 2014 To: Mr. Garrett Varra, Varra Companies, Inc. Mr. Brad Jones, Varra Companies, Inc. From: Mr. Douglas Trieste, Flow Technologies Subject: Response to Mr. Tim Cazier's Colorado DRMS, Memorandum (Varra-Coulson Resource Project, Permit No. M-2010-049; Exhibit G — Water Information, Preliminary Adequacy Review, December 13, 2013 (Re: Coulson Gravel Pit Mine Berm Failure Analysis and Flood Control Mitigation Plan prepared by Flow Technologies and dated September 2, 2013) Comment 3 ".Section 3.2.1, P. 13: The last paragraph of Section 3.2.1 discusses the need to characterize the geotechnical composition for a complete erosion estimate. Please provide a discussion on summarizing what values were used and how they were obtained Ibr the following parameters: a. Representative particle size. b. Percent clay fraction, c. Plasticity index, d. Total unit weight, e. Undrained shear strength, and Critical shear stress. Please also provide some discussion as to how these parameters are related to the credibility factor, Kd. " Representative Particle Size. This value is the representative particle diameter in inches of the soil material on the surface of the downstream face gravel pit berm. The representative particle diameter is used in determining the soil grain roughness, and thereby erosional effective stress, on the soil of the downstream face. This value is used in computations only when the representative particle diameter is greater than 0.05 inches and value is required only when a vegetative surface is being modeled. Because the headcutting/erosion modeling of Coulson Pit did not consider a vegetative slope—rather bare soil for conservativeness — input of representative particle size was not necessary. Percent Clay Fraction. A geotechnical engineering report performed by Terracon Consultants, Inc. (Geotechnical Engineering Report, Coulson and BearsonSM Gravel Pits, Various Locations, Weld County, Colorado, June 17, 2013, Terracon Project No. 21 135012) indicates that percent clay fraction is zero. Page 1 Hydraulics P.O. Box 6100 �10W ... . ...... Breckenridge, CO 80424 Hydrology 970-547-3823 Technologies www.flowtechnologies.biz Water Resources Plasticity Index. This parameter is mentioned in Section 3.2.1 for the purpose of giving a basic description of WinDAM, but was not needed in this analysis. The plasticity index is required only when a vegetative surface is being modeled. Because the erosion modeling of Coulson Pit did not consider a vegetative surface—rather bare soil for conservativeness — input of plasticity index was not necessary. 'total Unit Weight. Total unit weight is the total density of the in-place soil in the berm. A value of 115 lb/113 was input for this analysis. Total unit weight was not available from soil sample data for Coulson Pit. Due to such, the value obtained from soil boring data of a nearby gravel mine (Western Sugar) was assumed applicable to Coulson Pit. This is a reasonable assumption because total unit weight is not a sensitive parameter with respect to final results. Undrained Shear Strength. WinDAM B uses the undrained shear strength approximated by taking one-half of the unconfined compressive strength of the soil material. ASTM D2166 provides a description of the testing methodology to determine the unconfined compressive strength of soil —which is a complex, expensive procedure and beyond the scope of practicality of this study. Due to such, guidance contained in a paper authored by I Janson et el. Il was applied. Hanson's paper includes a table provided by Moore (2) for estimating unconfined compressive strength of soil which was applied for estimating undrained shear strength for the purpose of this analysis. In addition to Moore's procedure, engineering judgment was applied. Because the WinDAM methodology is not an exact science (as with any computer model of natural processes), undrained shear strength values used on other WinDAM analyses (provided as references with the model) were viewed and considered also. Most importantly, due to the uncertainties of estimating undrained shear strength, sensitivity analysis was performed and results indicate that variations within the bounds of reasonable values have minimal effects on the study conclusions for the scenarios evaluated. Based on the above, a value of 200 lb/ft2 was input to WinDAM. Critical Shear Stress. The critical shear stress can be determined from the jet erosion test or some other erosion test (e.g., flume test, hole erosion test, or erosion function apparatus). Those tests would he impractical for the purpose of this study. However per the WinDAM manual, the critical shear stress is usually enough smaller than the applied hydraulic shear stress that it may be taken as zero with minimum error. However, engineering judgment was applied to arrive at a value slightly greater than zero, or 0.1 lb/ft2. It was reasoned that for the event being modeled, the berm would have a high moisture content due to heavy rains preceding the flood event. Also, the berm (upper soil profile) would Development and Characterization of Soil Material Parameters for Embankment Breach, G.J. Hanson, D.M. Temple,S.L. Hunt, R.D.Tejral,Applied Engineering in Agriculture,Vol. 27(4)387-595, 2011. 2 Moore,J.S., Field procedures for the headcut erodibility index. Trans.ASAE (40(2):425-436), 1997. Page 2 f IOW Hydraulics P.O. Box 6100 ... .... Breckenridge, CO 80424 Hydrology 970.547.3823 7cchno(ogies www.flowtechnologies.biz Water Resources be heavily compacted due to months of heavy equipment moving on it. Thus, a critical shear stress of slightly greater than zero (0.1 lb/ft2) was assumed and applied. Provide Some Discussion As To How- These Parameters Are Related To The Erodibility Factor, Kd. Hanson et al. (r) provides guidance for approximate values of Kd relative to compaction and percent clay. Note that representative particle size, plasticity index, total unit weight, undrained shear strength, and critical shear stress are not factors in estimating Kd. A table is presented that lists approximate values of Kd against percent clay, modified compaction, standard compaction, low compaction, and greater or lesser than optimal water content. Because the WinDAM modeling procedure is not an exact science—as with any other model of natural processes—engineering judgment and sensitivity analyses were also performed to estimate Kd. It was assumed that water content during a berm overtopping event would be greater than optimal due to river overbank flooding and heavy' rains. Also, compaction of the berm down to several feet would be considerable due to movement of heavy equipment over months on a daily basis. As stated in sub-section 3.2.2 of the subject document, "because of the many assumptions and uncertainties, values of Kd were applied having two orders of magnitude from 10 for "Weakest" scenario, to 0.1 for "Strongest." Such a range of magnitude was chosen to cover a very large range of head cutting and erosion possibilities due to the many uncertainties of such modeling with the intent that the actual values would fall somewhere within the range of model results." Comment 4 WinDAMB Model Input/Output Data, p.44: Please explain vi'hy, the Maximum Pool Elevation /br the Worse (Kd=l0) case is 096 feel lower than it is far the Best (Kd 1) and Strongest (Kd pit) cases. During the Worse case failure scenario, headcutting and erosion of the berm occurs much sooner, and at a significantly faster rate than for the other scenarios resulting in the berm breach to widen and deepen at an earlier and faster rate. With a wider and deeper breach, discharge will be higher consequently resulting in a lower water surface (pool) over the breach because a higher percentage of the flood inflow is in the breach rather than overtopping the berm. Comment 5 WinDAM B Model Input/Output Data, p.55: Similar to Comment 4, please explain why the Maximum Pool Elevation varies between the four cases analyzed. Similar to Comment 4, the four cases model different berm breach headcutting and erosion rates due to variations in the erosion parameter Kd. With different breach headcutting and erosion rates—and consequent breach initiation time, and varying widening and deepening—the breach discharges will also vary considerably. The maximum pool elevations then become a function of the percentage of discharge in the breach relative to that overtopping the berm. Page 3 t % A.WI S. I I I tit 4( 11111%. 4 4 1t rea4d4 . 1 !!S • January 13, 2014 Mr. Garrett Varra Varra Companies Incorporated 8120 Gage Street Frederick, Colorado 80516 RE: Response to DRMS Comments DRMS Permit M-2013-064 Varra Coulson Mine—Greeley, CO Dear Garrett: I have reviewed the comments provided by the Colorado Division of Reclamation, Mining and Safety (DRMS) in their December 2016, letter to your office. Below are my responses to the comments presented in the letter which are germane to information generated by AWES, LLC. I have also addressed comments provided by Mr. Tim Cazier and Mr. TC Wait as documented in attachments to the letter. 14. The observation wells have been located on Exhibit G. 15. Varra commits to providing water level data as part of its annual report. 16. All required well permits will be provided to DRMS upon reciept. 17. As stated, it appears that all wells located within the areas of greatest predicted drawdown have adequate well depths to sustain continuous pumping for domestic uses. Varra Companies, Inc. (Varra) is already aware that there are wells in the predicted cone of depression where the water table may be depressed by more than two feet. A trigger point can vary in time, space and magnitude and should be related to the unique circumstances at this location and not a predetermined value, such as two feet. Varra will commit to the following protocol in the event of a complaint or letter of concern. a. Notify DRMS within 3 business days of receiving the complaint; b. Contact the well owner within 3 business days to schedule a mutually agreeable time to conduct a well inspection; c. Within one week of conducting the well inspection provide a written response to DRMS and the well owner. If is determined that Varra is not responsible for the complaint the rational for this opinion will be documented to DRMS and the well owner. If it is determined that Varra operations are the 4%4 0 III SI.0 4 4 Hi IA ! l 14 1 4I1!ls. 4 4 ♦4 p, 4 b64 d U / Response to DRMS Comments Varra Coulson Mine Operations Greeley,Colorado Page 2 cause of diminished well use/yield an appropriate remedy will be implemented. This can include but is not limited to providing supplied water, reconfiguration of the well's pump and the drilling of a new well.The timing of mitigation, if required, will be dependent on measures implemented and may involve factors outside of the control of Varra. If a complaint is deemed valid the timing of mitigation will be conveyed to DRMS and the well owner. 18. All registered wells within 600 feet were identified as available from the Colorado Division of Water Resources. Field inspections have not been conducted to verify the presence of registered wells. 19. The drawdown of approximately 16 feet referenced by DRMS (at 380 feet) is accurate. The drawdown referenced in the dewatering report was a model predicted change in the observation well (not the aquifer) at that location. The model was reconstructed and it was observed that the top of the well screen in the model parameters was located in bedrock. The well screen was moved into the coarse alluvium and all simulations were rerun and the predicted drawdown at the observation well was on the order of 14 feet. The calibration graph and model generated groundwater contours are presented as Attachment A. As requested all model calibration runs are presented in Attachment B. Varra recently provided water level data that was not available at the time of model construction. Based on these data it was observed that leakage from the Greeley # 3 Ditch was over estimated. The leakage was approximated based on trial and error runs until good agreement between measured water levels and predicted water levels was achieved. The drawdowns depicted between the River+ Ditch and River+ Ditch + Durham model runs depict the influence of the Durham dewatering. A review of the model runs shows a drawdown of approximately three feet at 1,500 (MW-6)feet south of the mine face. 20. We disagree that the Shadow/Mounding analysis does not reflect predicted effects from the proposed Coulson reclamation. The sites are nearly identical in scale, hydrogeology and liner construction. The use of field data in lieu of model predictions should be given substantial consideration. We did, however, modify the numerical model used for drawdown predictions to simulate a low permeability barrier at the Coulson mine. A barrier wall was constructed in the model around the mine face and a constant head boundary was assigned inside the barrier wall to simulate a full pond.The assumptions used in the model were as follows. • Barrier wall thickness of seven feet with a permeability of 1 x 10.6 cm/s. • The constant head boundary inside the barrier wall was assigned an elevation of 4027 feet. • The barrier wall is fully penetrating. • All simulations were steady state. In order to evaluate the influence of the pond liner, simulations were run showing the hydrology of the site without influences from the Durham mine, Greeley Number 3 Ditch and ,VWI_ 1.1 111 III %l a; A wit i. 11 o l [ 9 loins. 4 i 16 al a Dd£ = M „+..r Response to DRMS Comments Varra Coulson Mine Operations Greeley,Colorado Page 3 the reclaimed Coulson mine. A particle tracking simulation was included to show the groundwater flow lines without external influences. This simulation is presented on Plate A in Attachment C. A second simulation shows the influence of the Coulson barrier wall, presented on Plate B. As can be observed the barrier wall diverts groundwater around the mine with only minor variations in gradient. It should be noted that influences associated with the Durham mine pumping, and recharge from the Greeley # 3 Ditch will totally mask any water table variations created by the barrier wall. There is no information that an offsite groundwater user will be adversely affected to any recommended trigger point. 21. As a condition of its well permit Varra must provide notification letters to well owners within 600 feet of the mine.These notifications will be provided to DBMS. 28. The Hanes Property Preliminary Analysis report, which includes the requested boring logs, is provided as Attachment D. Also included is a cross section, which includes the lithology used for the slope failure analysis. We also have included a slope failure model documenting a flooded mine condition at the mine slope of 1.25H:1V. The safety factor increases from 1.27 under dry mine conditions to just less than 1.4 under flooded conditions. As slope failure modeling for a 3:1 slope would result in very high safety factors we do not see the value in reconstructing the model for these conditions. If you have any questions regarding this letter or attachments, please contact me at 970-590-3807. Sincerely, AWES, LLC Joby L.Adams, P.G. Principal/Hydrogeologist cc: Brad Janes—Varra Companies, Inc. AWL1.1 1 1 u m ♦Idr 4 1 Ur 1. 1 e r 1 1 4 Hint, 4 4 M4 ).14. sk4 ran Fwd ATTACHMENT A Coulson Pumping Influence Analysis u, G, ex thip .. A +n ,s 4 2 83 s.' , ems, 1' + h • .44 t AP T4. tSJr '.I. } '-gy_sulk m «r'M,+sl<.y F .'6 ' ,a ,' iV,i a T _ -��..a4 4 t - .r a s jj P .1777'y 'n • 1. Ia mR M ` s $. a r .�,; -t8th t`3a it�....r xy • s t + ,, °, " 0,'' oogle earth +�� J iA - .His. -tifig • r- .S _ '-' j , ++' ^'mayecv Uate I,Jr L01240'1150(.19"N 11.14'.38403.044W elev X611 tt eye alt 1J9St II O � 0 200'_' .1000 6000 8000 I 000 10668 Date: I'I 3 '014 I I:I I:a9 A1AI Coulson Run - Ricer— Ditch - Durham Farra Coulson Project • Calculated vs. Observed Head : Steady state ■ Layer#1 95%confidence interval • --- 95%interval • • MW-6/A . Observed=4621 93 Calculated=4619 74 • m • • • MW-5/A Observed=4611 62 Calculated=4611 11 MW-3/A Observed=4613 13 Calculated=4608.77 U MW-21A Observed=4811 47 Calculated=4607 42 i • • • • M W-4/A Observed=4613.62 Calculated=4600 10 • 4599.66 460966 4619.66 Observed Head(ft) Num of Data Points 5 Max Residual.-13 522(ft)at MW-4/A Standard Error of the Estimate.2.258(ft) Mm Residual-0.506(ft)at MW-51A Root Mean Squared.6 683(ft) Residual Mean -4 926(ft) Normalized RMS.63.895(%) •Abs. Residual Mean•4 926(ft) Correlation Coefficient•0 708 Project• Varra Coulson Coulson Run Modeller: JL Adams River-f Ditch f- Durham ATTACHMENT B Calibration Runs 2 `Vila- ' �J ,,,,„,4 , ,263 " � z,i ,,,,,,,, .. ._ %.,. . . .... , ....„ y — IY b s I • r r I �� 1 F i • i I 2.,„,, y 3 «M....c u �� • dJ ' .. y .. +r16t to f... ti " + + Lit 'Si}Yx� f % r q' � w � '8+. ml39.„, r t.., ai". } A ,07„„ .., Ry`'�` i x, • ua ^V ws . t ttsi' ' .th zr,AfA a "qita p / kr • 7f s "' '1r- Y /R� � � + " , j �� . '' - 07 , r r.4 �,} + . � �i..}' �� G w: X181 .II _ens*. r 4 a ki. , at .' *" :at,--447, .� 4 g , , �� . r S. r : oo3leear4h 4 e# »..M» ' d am: O ra , E.. agery Date`e/18/2011 4 25'01.1q"N 104'38'38 04'W elev 4622 ft eye alt 1102 ft i. 2000 4000 500C. IOCOO 10668 Date: I_-'b:'n01? 2:?2:01 I'll Initial Calibration - Rix r(i ,I Calculated vs. Observed Head : Steady state ■ Layer#1 95%confidence interval -- 95%interval is I MW-6/A Observed=4620.28 Calculated=4620.66 7(6 • co m n_ e i D o v Ti U Y MW-4/A • Observed=4613.90 Calculated=4613.68 m • MW-3/A Observed=4613.00 Calculated=4613.00 MW-2/A vm Observed=4612.03 Calculated=4611.66 4611.43 4613.43 4615.43 4617 43 4619 43 Observed Head(ft) Num of Data Points 5 Max.Residual 0 38(ft)at MW-6/A Standard Error of the Estimate 0 126(ft) Min. Residual 0(ft)at MW-5/A Root Mean Squared 0.256(ft) Residual Mean -0 043(ft) Normalized RMS 2.957)%1 Abs.Residual Mean 0.195(ft) Correlation Coefficient 0 999 Project. Coulson Modeller E. Adams Initial Calibration- River Only ..c o �n ,1. ` •. tJ;Sx . ily '41,3.4 ,_ - c f f ' / P S waFZ. 41 .., AV'''. � *. '/ • -(4 ° +' < O: - :— 'i'! ta � " 1yR. _ i3e `. • y'4414 f Y 1 . v u'-'•r7 .�"t) «( .!4' 1 ' ,, (3* j d Q iif.G Y - . ss-c A r " .72 M k (.0 •f $r" vii t ifs. _ y I ! : c'6Z3� r sz G ...t...... . , ,...,3-.- - ,,i - , .e...4, ey s AMID •8<t a ry t+ e � a t"". Live ods9 ods. 0 9E _.. Odle 0021 - ob., �' Calculated vs. Observed Head : Steady state 0 Layer#1 95%confidence interval _ 95%interval n MW-6/A Observed=4620 66 Calculated=4625 01 m m re coo v i - I Y � o -a -a U M as m ro MW-4/A Observed=4613 68 Calculated=4615.31 MW-3/A Observed=461300 Calculated=4613.88 • MW-5/A Observed=4611.76 Calculated=4611 71 4611 393 4616 393 4621 393 Observed Head lit) Num of Data Points 5 Max.Residual.4.352(ft)at MW-6/A Standard Error of the Estimate 0 787 ift) Mm Residual-0 052(ft)at MW-5/A Root Mean Squared 2.119((t) Residual Mean 1 417(ft) Normalized RMS 23.543(%) Abs Residual Mean 1.438(ft) Correlation Coefficient 0.999 Project Modeller River + Ditch Calculated vs. Observed Head : Steady state ■ Layer#1 95%confidence interval - 95%interval MW-6/A Observed=4620 66 Calculated=4625 01 •• v I m 3 U N U MW-4/1). o Observed=4613 8B Calculated=4615.31 • MW-3!A Observed=461300 Calculated=461388 MW-2/A Observed=4611 66 Calculated=4611.94 4611.393 4616 393 4621 393 Observed Head(ft) Num of Data Points 5 Max Residual 4 352(ft)at MW-61A Standard Error of the Estimate 0.787(ft) M,n Residual -0 052(ft)at MW-5/A Root Mean Squared.2.119(ft) Residual Mean 1 417(ft) Normalized RMS•23 543(% Abs Residual Mean. 1 438(ft) Correlation Coefficient 0.999 Project !I Modeller River+ Ditch 14 �... ., .., .:, f ., - 251 •a - - _. ..., ..... . „.. _. ..„ ._ tee }) 7 _ � .. ,. • �. ./.. I ~ _ ,.. - •v�+ i� O . . .. . ., . ,.....„ .. .„..„. . .. . . .1::!.'2 _ I • • 1 Kai.. Y f ._ aw"a 1 A.111.•411 I. ' re:„...__ .e. .:,/..: ,•.1 --it-. -t' # t 1� r *t .1 P.te fikt'et) , ar bir;t, r ' 11 ; m11 . t sy`aih, i vlK,i S`�' it r,2 '+t rw "' 4`- g fms� •. �� - y e o� "uhf' , -.- 4ta LS.• t < _, ' , ..� �, t • t R, Fk z,, , le , .� ;� ' • oogle earth ' Ir fir. '. . _ _ ,dY ;t4; Ima9ery;Date'8/18 ill 40°2501.19"N 104°38'38.04'Y! elev 4622 ft eye all 13952 N O z^ar .000 ,oas soon mcun mess Date: 113^_0' I I L 11: 9 ASI Initial Calibration- Ricer -r Ditch -- Durham Varna Coulson Project Calculated vs. Observed Head : Steady state • Layer#1 95%confidence interval ---. 95%Interval • • MW-6/A • Observed=4625.01 Calculated=4621 93 r a• N 0 x v 3 a T U g cc_pp • • • MW-4/A Observed=4615 31 Calculated=4613.62 v MW-2/A cn Observed=4611 94 Calculated=4611 47 4611 195 4616.195 4621 195 Observed Head(ft) Num of Data Points 5 Max.Residual -3.078(ft)at MW-6/A Standard Error of the Estimate 0 535(ft) Min Residue' -0 089(ft)at MW-51A Root Mean Squared 1.62(ft) Residual Mean -1 216(ft) Normalized RMS- 12.182(% Abs Residual Mean 1.216(ft) Correlation Coefficient.0.997 Project• Varra Coulson River+ Ditch+ Durham Modeller JL Adams Calculated vs. Observed Head : Steady state N Layer #1 95%confidence interval 95%interval Ali MW-6/A jl Observed=4625.01 Calculated=4621.93 ul m a � I v 1 j V I m i 2 V 2 a 3 V V to Co MW-4/A Observed=4615 31 Calculated=4613 62 Observed x613.88 Calculated=4613.13 MW-5/A Lc, Observed=4611 71 Calculated=4611.62 4611 195 4616195 4621 195 Observed Head(ft) Num of Data Points 5 Max.Residual -3 078(ft)at MW-6/A Standard Error of the Estimate 0.535(ft) Min Residual-0.089(ft)at MW-5/A Root Mean Squared 1.62(ft) Residual Mean -1 216(ft) Normalized RMS 12 182 % Abs Residual Mean 1 216(ft) Correlation Coefficient 0 99/ Project- Varra Coulson Modeller'. Jl. Adams 'River-l- Ditch a Durham ATTACHMENT C Coulson Barrier Wall Simulations Plate 1 , a: , l:- lil: 4619 .._.. %.�"` - - " d w N ♦--' r.‘"4":' ..-.::4 ww 3 ,E 'A� n' ir:`..1. - t. • t�_si. R*• " 1v tor Q .I� s x 4sssyx �' ss* �� t• Y fi Y 2. 'Si. ,I..4 4. 1. 10116,H 101 . 7Y I ♦ a YJ "A� 4 a fl F`` ' r Y -;;TL- M11 Nd 41.,41.,f4+kl f . la \ lei'.."., i + 3S.oz-u`. .--74:wcft,mi.ilizasany12 40° '01.1 N 1049. :'i 119W PI 4622R _ !fie aft 13951 R . Plate 2 Ik / .. 6111 • ., ' /,: N • ,.'. .. . "-,w • lib` "* r•""er r. . 1 4 . a lkit 14 f woe. ' 44's. , irk b-.., , . - .4,0-4:, 1 z . dl• t INN ' t , t c “.'.. f r, +! 1!:I _ 161 -..,41:: ..1.111:11141:11:1e1 sty` !1{ ,,._ 1 j`I a • f . - i T I ' v 2 * ,. N 3 4 `1'"rill*. • F f f ♦: s 1 ` i • . ` E'♦a. 1 .� 1 � eM1 '� 't r ..Xtlikir: 2.4.'Us). N 104°38',_11.04' d ' 4611 N ife dt 11951 R 0..;. I'nnr<L l ,,,..'It t ..il f l: I_i Al .11I ATTACHMENT D Hanes Property Preliminary Analysis Report Cross Section Flooded Mine Slope Failure Simulation HANES PROPERTY PRELIMINARY ANALYSIS Prepared For: Kauffman & Son,Inc. 808 South County Road 9E Loveland,Colorado 80537 Prepared By: = I'M vire liittieApplegate,Inc. Consullanle fur Land,Mineral and Water 11970 Grant Street.Suite 304,Ocmc,CO 80233 I h13!PHONU: 003)432-6611 FAX:(303)452-2759 April 2000 TA Job#00-153 RESERVE CALCULATIONS Preliminary reserve calculations on the Hants property were obtained using the following assumptions: • The limit of mining was set back from the east and south property boundary by 50 feet, from the top of the ditch by 35 feet and from the river by 100 feet. • The area would be mined using 2H:1 V slopes around the perimeter. • The existing ground elevation is an average of 4615 feet. • Based on the limited site visit, we did not exclude any area due to wetlands. • We used 1.5 tons per cubic yard to calculate the"gross" sand and gravel tonnage. • To account for unmarketable fines, the gross tons are reduced by 8% to obtain the"saleable" product. • Four acres were reserved for the current property owners house and limited corrals for horses and cattle. • Approximate locations of tree buffers were determined from the site visit and an aerial photo • The approximate location of a gas well and associated storage tank was determined from the site visit and an aerial photo. Mining Cell Area—60 acres Overburden Volume—247,300 cubic yards Mining Volume-3,285,300 cubic yards Mining Volume—4,927,950 tons(gross) Saleable Volume—4,533,700 tons It is possible that gravel reserves are deeper in this area than the bore logs indicate. This area is known to have clay lenses and potential reserves at 60 to 70 feet. Holes H-7 and H-14 passed through clay lenses and arc at opposite sides of the property. Re-drilling at a couple of locations may be prudent to verify this. SITE ACCESS This site is bounded on two sides by two-lane asphalt roads. This area is unincorporated Weld County,but is very close to town. It is unknown at this time who is responsible for the road maintenance,Greeley or Weld County. Potential haul mutes could be either directly west on 16°i Street to SH 85,north on Fern Avenue to Highway 263 then west to SH 85,or south on Fero to pick up SH 34 back to SH 85. Using 16i°to the west may be a concern as there arc numerous residential properties between this site and the highway. Additional truck traffic could he a major concern. It is not known if the bridge currently existing over the river on Fern Ave. is sufficiently rated to allow hauling of material in that direction. COUNTY CONCERNS As this site is so very close to the limits of the City of Greeley, any concerns over additional truck traffic, haul mutes,noise and dust impacts to local residents will be carefully considered. At this time we do not know of any local concerns that could potentially stop the project. A trail easement may be required on the area adjacent to the river as there is an existing Master Plan for the Poudre River Trail Project. OTHER CONCERNS As this site is bounded on the north by the Poudre River and has what seems to be an old meander of the river in the north portion, the arca should be examined for potential habitat for the Preble's Meadow Jumping Mouse and any potential Orchid habitat. Based on our site visit, there does not appear to be wetlands on the property, hut this should be verified by a qualified individual. WATER ISSUES Attached is a memo from Steve Nguyen,outlining alternatives for end uses of the site. Richard Raines of our office is researching existing water rights for this site and compiling information on the potential requirements for augmentation. His information will be forwarded as soon as it is available. • 71mttleApplegate,Inc. Consultants for Land,Mineral and Water 1)evclopment Memorandum Date: 4-5-00 TA Job#00-153 To: Pam Acre From: Steve Nguyen v+-3 Subject: • Hanes Property The Hanes Property is located in Section 10,Township 5 N,Range 65 W, east of Greeley near the confluence of the Cache la Poudre and the South Platte Rivers. Due to the location near the confluence,the gravel deposits are much deeper with bedrock estimated at 60-80 feet. Prior to the purchase of this property,there are different end land uses that should be considered. The intent of this letter is to provide a brief understanding of the various end land use alternatives. No evaluation was performed for this site specifically,but the estimates given arc based on past experiences and knowledge of the area. The estimates are merely provided to help understand the potential values and costs associated with each alternative,but are limited by the fact that a detailed evaluation has not been completed for this particular site. There are three end land uses that can he considered with a gravel pit: Alternative A--The gravel pit will be backfilled. This end land use alternative requires no augmentation of evaporative losses. Alternative B—The gravel pit will be left unlined. This end land use alternative requires augmentation of evaporative losses. Alternative C—The gravel pit will be developed into lined storage. This end land use alternative requites creating water storage by lining the gravel pit to segregate the lake from the surrounding groundwater system. Alternative A-Rackflll 1'his is a potential end land use to eliminate any augmentation responsibility. Because the gravel deposits are so deep,however,there most likely is not enough overburden to backfill the entire pit. 11990 Grant Street,Suite 304 • Denver,Colorado 80233 • (303)452-6611 • (Fax)452-2759 Alternative 13 -Augmentation Gravel pit augmentation requires replacements to the river due to evaporation from the unlined lake surface in both the summer and the winter months. Typically,ditch water is used for summer augmentation. This ditch water must be senior and thus have a reliable delivery each year. Winter augmentation can be provided through a lease for temporary replacement,but lined storage is generally needed for long-term winter augmentation. Winter augmentation includes water that is needed for replacement of evaporative losses and water that is required to maintain historic return flows. Evaporative loss for this area is approximately 2.9 acre-faet/acre exposed annually. Return flow obligations are approximately 20%of the total irrigation requirement. For this area, the approximate acquisition cost of senior ditch water that can be used for summer augmentation is approximately$2000-52500 per acre-foot consumptive use. Winter storage for augmentation and maintaining historic return flows is estimated at$1000-$1500 per acre-foot. Note that if the property has senior water rights attached to it,such as Greeley Canal No. 3,then this water can be used for augmentation and the cost of purchasing new water would decrease or be eliminated. However,a change of use would be required on the existing water rights to allow them to be used for augmentation. With this end land use alternative,there is potential value in selling the property as open space or for development An estimated value for open space is$5000 per acre. Weld County zoning ordinances require that any development be located outside the 100-year floodplain. Due to the site being located next to the river,development of this property may not be an option. An estimated range for development value is 520,000-550,000 per acre. Alternative C-Lined Storage There are several factors that influence the value of lined storage: competition in the area, location on the river, and location in relation to filling structures. Having the Greeley Canal No.3 as a potential filling structure adds value to creating storage at this site. In addition, the location of the Hanes Property on the river has exchange potential for several municipalities and may add to the competition for the site. There are costs associated with lining a gravel pit for storage. The two most common methods of lining are a compacted clay liner and a slurry wall. Slurry walls arc typically more expensive. If there are not sufficient on- site clays,however,using a compacted clay liner also becomes very expensive. In almost all cases,the value of storage once a gravel pit is lined far exceeds the cost for the actual liner. Gravel pit storage values have a large range,depending on the factors listed above. Past sales have been from approximately 51000-52600 per acre-foot of storage. Due to the locatiou of this site,the value is most likely on the lower end of this range. Even with the"low end"value,the value of lined storage at this site may exceed the cost to line. It is difficult to evaluate what the true potential is for this site with only a brief analysis. There is potential value of this site as lined storage,but a detailed evaluation would need to be completed to develop a full understanding of this particular site. 11990 Grant Street,Suite 304 • Denver,Colorado 80233 • (303)452-6611 • (Fax)452-2759 I hope the information provided will assist you in the understanding of the possible end land uses. The numbers given should help you see the potential value of lined storage as an alternative and the approximate cost of augmentation if the pit is left unlined. If it is determined that this site will be purchased,it may be beneficial to meet with the City of Greeley to discuss, up front,their potential interest in lined storage at this location. Todd Williams would be the contact at the City of Greeley Water Department if you have any questions,please do not hesitate to call. t 1990 Grant Street,Suite 304 • Denver,Colorado 80233 • (303)452-6611 • (Fax)452-2759 I l IN ) j fro • I - H-ts %` I I • v� I I N-10 'J-1 •11 k •H-14 a� H-13 a1 g I i4v �� z H-' i :1:4-7 3312 H-3 H-4 N-3 II I3 33 ' 3 i tp CI H-1 i H...B I S 33 H-6 :-2 3)- j a9 �� i HANES PROPERTY Lithologic Logs HOLE A-1 O'-0" to 2'-0" Overburdcn/TopSoil;dark brown 2'-0" to 20'-0" Sand&Gravel;tan,medium to coarse grained,gravel to 2" 20'-0" to 32'-0" As Above;fine to medium grained, Gravel to 1" 32'-0" to 41Y-0° Clay;gray TD Composite sample taken from 2'to 32' HOLE H-2 0'-0"to 3'-0" Overburden/TopSoil; dark brown 3'-0"to 6'-0" Sand;tan, fine gained,H2O at 3 ft. 6'-0"to 15'-0" Sand&Gravel;fine to medium grained,gravel ta1 15'-0"to 31'-0" As Above;medium to coarse gained, gravel to 3" 31'-0" to 40'-0" Clay,gray TD Composite sample taken from 3' to 31' HOLE H-3 0'-0"to 1'-0" Overburden/TopSoil;dark brown 1'-0" to 7-0" Sand&Gravel;fine to medium grained,gravel to 3" T-0" to 30'-0" As Above;medium to coarse grained,gravel to 2" 30'-0" to 35'-0" Clay;gray TD Composite sample taken from 1'to 30' HOLE $- 0'-0"to 3'-0" Overburden/TopSoil;black 3'-0"to 4'-0" Silt; tan,very fine gained 4'-0"to 16'-0" Sand; fine to medium gained 18-0"to 36'-0" Sand&Gravel;coarse grained,gavel to 3" 36'-0"to 40'-0" Clay; gray TD Composite sample taken from 4' to 36' HOLE H-5 O'-O"to 2'-0" Overburden/TopSoil;black 2'-0"to 13'-0" Sand&Gravel;coarse grained,abundant gravel to 3" 13'-0"to 20'-0" Sand;coarse grained,trace gavel to 1" 20'-0"to 33'-0" Sand&Gravel; coarse gained,gravel to 3",one 5 " cobble 33'-0"to 40'-0" Clay;gray TD Composite sample taken from 2' to 33' HOLE 11-6 0'-0"to 2'-0" Overburden/TopSoil; black 2'-0" to I0'-0" Sand&Gravel; medium grained,gravel to 2",H2O at 6 ft. 10'-0"to 17-0" As Above; medium grained,gravel to 1" 17'-0"to 29'-0" As Above;medium gained,gravel to 2" 29'-0"to 40'-0" Clay;gray TD Composite sample taken from 2'to 29' HOLE 1.1-7 0'-0"to l'-0" Overburden/TopSoil;black l'-0"to 6-0" Sand;fine grained 6-0" to 20'-0" Sand&Gravel; medium to coarse grained,minor gravel to 1" 20'-0"to 45'-0" As Above 45'-0"to 53'-0" Clay;brown to gray • 53'-0"to 56'-0" Sat/Sand&Gravel;gray fine grained,gravel to 3" 56-0"to 60'-0" Clay;gray TD Composite sample taken from 6 to 45' HOLE H-8 0'-0"to l'-0" Overburden/TopSoil;dark brown 1'-0"to 6-0" Sand;fine grained 6-0"to 16'-0" Sand&Gravel;medium to coarse grained, gravel to 2" 16'-0"to 33'-0" Sand; coarse grained, trace grave!to 1" 33'-0" to 40'-0" Clay;brown 40'-0"to 45'-0" Clay; gray TD Composite sample taken from 6 to 33' HOLE H-9 0'-0"to 2'-0" Overburden/TopSoil;dark brown 2'-0" to T-0" Sand& Gravel;coarse grained, gravel to 2" T-0"to 15'-0" As Above;gravel to 3" 15'-0" to 28'-0" Sand;come grained,trace pea gravel 28'-0" to 33'-0" Sand &Gravel;medium to coarse grained,gravel to 3" 33'-0" to 40'-0". Clay;brown TD • Composite sample taken from 2'to 33' HOLE H-10 0'4'to 3'-0" Overbu rdenfropSoil; dark brown 3'-0" to 5'-0" Silt;tan, very fine grained 5'-0"to 11'-0" Clay;black,some grit and trace of gravel to 2" 11'-0" to 23'-0" Sand&Gravel;medium to coarse grained,gravel to 1" 23'-0" to 3T-0" As Above; gravel to 3",several 4" cobbles 37-0" to 44'-0" Clay; brown TD Composite sample taken from 11'to 37' HOLE H-11 0'-0"to 5'4' Ovesburclen/TopSoil;dark brown 5'-0" to 12'-0" Sated&Gravel;medium grained,gravel to 2" 12'-0" to 13'-0" Clay; brown 13'-0"to 20'-0" Sand&Gravel;medium to coarse grained, gravel to 3" 20'-0" to 29'-0" As Above; abundant gravel to 3" 29'-0"to 35'4' Clay; brown TD Composite sample taken from 5'to 29' HOLE H-12 O'-O" to 4'-0" Overburden/TopSoil;dark brown 4'-0" to 6'-0" Sand; medium to coarse grained 6'-0" to 8'-0" Clay;gray,H2O at 6 R 8'-0" to 10'-0" Sand&Gravel; coarse grained, gravel to 2" 10'-0" to 15'-0" Sand; coarse grained,trace pea gravel 15'-0" to 20'-0 Sand&Gravel;coarse grained,gravel to 3" 20'-0"to 33'-0" As Above;abundant gravel to 3" 33'-0" to 40'-0" Clay;brown to gray TD Composite sample taken from 4'to 33' HOLE H-13 0'-0"to 2'-0" Overburden/fopSoil;black 2'-0"to 13'-0" Sand&Gravel;medinm to coarse grained,gravel to 1" 13'-0" to 20'-0" As Above;abundant gravel to 3" 20'-0" to 30'-0" As Above; gravel to 2" 30'-0"to 40'-0" As Above;abundant gravel to 3",several 5"cobbles 40'-0"to 50'-0" Clay;brown to gray TD Composite sample taken from 2'to 40' HOLE H-14 0'-0"to 3 '-0" Overburden/fopSoil;black 3'-0"to 6'-0" Sand;medium 6'-0"to 20'-0" Sand&Gravel; fine to medium grained,gravel to 2" 20'-0" to 25'-0" As Above;coarse grained,gravel to 2" 25'-0"to 40'-0" As Above,abundant gravel to 3",several 4"cobbles 40'-0" to 47'-0" As Above;no cobbles 4T-0" to 50'-0" Clay,gray 50'-0" to 65'-0" Silt/Sand and Gravel;dirty fine to medium grained, gravel to 2" 65'-0" to 70'-0" Clay;gray TD Composite sample taken from 6' to 47'and 50'to 65' HOLE , H-15 0'-0"to 3'-0" Overburden/TopSoil;dark brown 4 3'-0"to 10'-0" Sand; fine gained 10'-0"to 27'-0" Sand&Gravel;medium gained,gravel to 1" 27'-0" to 42'-0" Silt/Sand;very fine gained,trace pea gravel 42'-0"to 75'-0" Clay;brown to gray TD No Composite sample taken HOLE H-16 0'-0" to 2'4' Overburden/TopSoil;dark brown 2'-0" to S-0" Silt/Sand;very fine gained S'-0"to lO'-0" Sand&Gravel;medium to coarse grained,gravel to 1" 10'-0" to 20'-0" As Above; gravel to 3" 20'-0"to 41'-0" As Above; abundant gravel to 3" 41'-0"to f'-0" As Above;no cobbles 47-0" to 50'-0" Clay;gray TD Composite sample taken from 5'to 41' HOLE H-17 0'-0" to 3'-0" Sand; fine grained 3'-0" to 15'-O" Sand& Gravel; medium to coarse gained,gravel to 1" 15'-0" to 18'-0" Sand; coarse gained 18'-0" to 19'-0" Clay;brown 19'-0" to 23'-0" Sand;coarse grained, trace pea gravel • 23'-0"to 34'-0" Smut&Gravel;coarse grained,gravel to 3" 34'-0"to 40'-0". Clay;brown to gray TD Composite sample taken from 0'to 34' All holes logged by CL Coppage 1 Cross Section Plan View Map A-A' 1 I =1-17 a o` e l �'\ *4. I . I 1 - 11-184. i A to i 1 - - �/ I H-16 14-10 I A I H-1t • g 4i '61 k H-14 I aA :4-13 a0 1 • uo �� ' c C H-! H-12PI 14-S A 33 l • • 4 H-3 as 13 33 36 3o' I A 0 H-t I H •- H-B I 33 O H-6 3s -x 3� S act �� l -i 4 il g I r 2 I Varra Coulson Mine Cross Section AA' 4630 H-7 H-8 +13 H-14 4620 - ? 4610 ? ? ? ? 4600 4590 - 4580 EOB N EOB EOB ? LLJ 4560 7 4550 EOB 4540 4530 500 1000 1500 Distance (ft) Top Soil/Clay Fine Sand Sand & Gravel Clay/Clays tone Problem: Varra Coulson Slope Failure Analysis - FS Min- Bishop = 1.366 12,2+i Soils Cohesion Friction —` — ------ ----- _ _ Angle 1201 Snda��,� 00 33 is 115ImmoClay S00 280 • 110 Pd., r3r�1 Snd 0 0) 31 0 ttt#Mlti i Top Snd 50 0 28 0 . 105 MIME Bedroc• 7 31 0 230 ' 100 Water Tale Critical Surface: 95 90 • • 80 .. • 70 • • 60 •..._. .,. 50 .. . 4s • 40 V 30 20 10 0 •10 -10 0 10 20 10 40 50 60 70 30 90 100 110 120 130 140 17!1 160 170 • iSt aie in Feet, Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick,Colorado 80516 Telephone(303) 666-6657 Fax (303) 666-6743 Friday 11 October 2013 To: Our Neighbor Subject: PUBLIC NOTICES: Varra-Coulson Resource Project-Regular Impact(112) Permit Application M-2013-064 —Required information for Adjacent Landowners. Contact: Garrett C. Varra,Vice President of Operations Varra Companies, Inc. 8120 Gage Street Frederick,Colorado 80516 Dear Neighbor: Two Notices are enclosed for your consideration. The Notices are required as part of permitting our lands for sand and gravel operations. We have enclosed a Notice of our intent to conduct mining operations, and a Notice regarding your structure(s) which may be located within 200 feet of our affected lands. A map shows the approximate location of our project area. A Stability Analysis Report offers evidence our planned operations will not impact your adjacent structures, and is available to you upon request. We hope you will review the included Notifications, and return signed and notarized Statements of Understanding. Naturally, should you have any questions, please feel free to contact me directly at the telephone number above. Thank-you for your time and cooperation. 1 Friday 11 October 2013 To: Adjacent Surface Owner of Record Subject: PUBLIC NOTICE: Varra Companies,Inc. -Varra-Coulson Resource Project-Regular Impact (112) Permit Application M-2013-064. Contact: Varra Companies,Inc 8120 Gage Street Frederick,Colorado 80516 Telephone: 303-666-6657 FAX: 303-666-6743 e-Mail: gvarra@varracompanies.com The following Public Notice will appear in the Greeley,Tribune for four(4) consecutive weeks,commencing Thursday 10 October 2013,as shown below. You have received a copy of this Notice as required by Colorado Mined Land Rules and Regulations. All lands having a valuable mineral resource must be extracted prior to development. All extracted lands must also be reclaimed. These lands will be reclaimed to Developed Water Resources and other mixed uses that will complement the surrounding lands. If you have any questions or concerns,please feel free to contact us as detailed above,and ask for Garrett C.Varra,Vice-President of Operations. Thank-you. PUBLIC NOTICE Varra Companies, Inc.; 8120 Gage Street; Frederick, Colorado 80516; (303) 666-6657, has filed an application for a Regular Impact (112) Construction Materials Operation Reclamation Permit with the Colorado Mined Land Reclamation Board under provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials. The proposed mine is known as the Varra-Coulson Resource Project, and is located at or near Section Ten, Township Five North, Range Sixty-five West; Sixth Prime Meridian. The proposed date of commencement is 1 January 2014, and the proposed date of completion is 1 January 2044. The proposed future use of the land is Developed Water Resources and other mixed uses. Additional Information and tentative decision date may be obtained from the Division of Reclamation, Mining, and Safety: 1313 Sherman Street, Room 215; Denver, Colorado 80203; (303) 866-3567, or at the Weld County Clerk to the Board; 1150 O Street; Greeley, Colorado 80632; or the above named applicant. Comments must be in writing and must be received by the Division of Reclamation, Mining, and Safety by 4:00 P.M. Wednesday 20 November 2013. Please note that under the provisions of C.R.S. 34-32.5-101 et sea. Comments related to noise, truck traffic, hours of operation, visual impacts, effects on property values and other social or economic concerns are issues not subject to this Office's jurisdiction. These subjects, and similar ones, are typically addressed by your local governments, rather than the Division of Reclamation, Mining, and Safety or the Mined Land Reclamation Board. 1 Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax(303)666-6743 Friday 11 October 2013 To: Adjacent Surface Owner of Record Subject: Statement of Understanding regarding significant,valuable and permanent man-made structures located within 200 feet of planned extraction activities for Varra Companies,Inc.-Varra-Coulson Resource Project-Regular Impact(112)Permit Application M-2013-064. Contact: Varra Companies,Inc. 8120 Gage Street Frederick,Colorado 80516 Dear Property Owner: Varra Companies,Inc.(8120 Gage St.,Frederick,CO,80516,Telephone: 303-666-6657),plans to conduct extraction activity over a parcel of land identified as the Varra-Coulson Resource Project,and is located at or near Section 10, Township 5 North,Range 65 West;6th P.M.;Weld County,Colorado. You have received this notice because we believe you are the owner of one or more significant, valuable and permanent man-made structure(s) located within two hundred (200) feet of the planned extraction and related affected land. A qualified man-made structure may include a fence, a residence or out building, a road, utility,or other significant,valuable and permanent man-made structure. As the owner of a qualified man-made structure located within 200 feet of our planned extraction activity,the Colorado Division of Reclamation, Mining and Safety requests we provide evidence of our efforts to protect such structures from injury during the planned extraction activities; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law. Upon request,we will provide you with one copy of our Stability Analysis Report, as included in our permit application with the Colorado Division of Reclamation, Mining and Safety. The report indicates that planned extraction activities arc not expected to adversely impact adjacent qualified man-made structures. Also included is a map showing the approximate area of land affected under our planned extraction activities, our permit area and the relationship to your property. A line showing the approximate extent 200 feet from our permit boundary is shown for your reference. You may review the complete permit application at the Division of Reclamation, Mining, and Safety (1313 Sherman St., Room 215, Denver,CO 80203,Telephone 303-866-3567),or at the Weld County Clerk to the Board(1150 O Street; Greeley, Colorado 80632), or at our corporate headquarters in Frederick, above. Please review the available materials, and if you agree that activities will not impact your qualified structures verify this understanding by your notarized signature, below. Please return it to us in the enclosed self- addressed envelope. Letters not returned to us within ten (10) days of your receipt of this notice will act as evidence of your approval as well. Please submit any objections in writing to our Gage Street Office within 10 days of receipt of this correspondence. If you have any questions or concerns about our planned activities and your structures we want to discuss them with you. You arc encouraged and welcomed to contact us as soon as possible at our Gage Street Office at the telephone number, above. Please ask for Garrett C.Varra,Vice President of Operations. 1 Isr?9!VN7�..'G: " 55 ---;7711 I pp(jN itL- •-.t.' __t•P' 1 _ ` t 'sG • rr.,7S D C7 •,--,.0.•,,,., a65j '^' `is. 3 -.—r 46ae. ' ". •ar.i-;{�•-464? - " y I. i ; .. r Gs ... '$•,•,1,------. $•,,i._ 1 :.: Ry1�S:.�,...��._'�uas�5 Q- :r'f— •-•:, _—..— --_ .. _.....,...1_14...;•5)-__..._ '.;•sasJ ._ _ -.-_ .. ',.iCR9 LI 23 m Z .. ___-? .��'7h e }r. sir .�t.• `� .. ,a9af i r I •cri — •I 1. 11,4 ,�{ .•tt.. rsR.s��• -,.,.„1-..::„1-,44..-.„::.,,I' <-0`33 '� 1! • •. . * t`4LG�-3 .. �. ,�, .. f �s.. is t'H i. ,i .'.'- .�I•' r �E k: LEY a y I' _ l �; `.1•\'Y-7E. `� :z - =�� I 1 r '. . ..,....-;.;..-!,...._÷,_,,,,..,,..„...-, b I-I ' �, .7.)1! I •.4661 ' , ''I a.,:.� t :,. •I. •• .46ad_--,,l--. •r. s6?B .._•.::' I ' ;�'� r-- s 11 � �:.. •.._-_ .�, - "i. . - ',i - ___ :� .....„„„.-:77„,_.4„,„2„2, •x,..• : 3 _ i_�r 1 'Tr. '�^ _ _- 4• ..;,•••;_.-::•,::::::: •c•-...,,, • '-.r;-°"r. 3�..•�..'�. �t66o .. ' �._ •. or a ..._,-•. :•n .r• D "_`*' s 'r, 46a4 '_._iU w _�fu 1, :+;Ps`cfs[_?.I CAC ti _ - y.�. , �''', •?.. f,. m .:ao ,�'•. kg p,, T i � AI _ __iL.Sr fete ,ti ° fz Yi` ' _•__._ 'I l Y:. �/!�t� ..„:.t.,...,•: .- -�_ �'� • f'- }. �lil -` ,.. W _ �.r ..^ •. f \}. _:. ^?'._•.. -_.a-,.•2P =\T .tz \� .r: OO -• `>..:V.. �'� *•�1 1>s. �` ,,. - II. ., •jltnn I ■i �YC�Eh� =- ,7,..•;::•••••.• - '��• Q •:.-.:.�.,4•..•.. S;'�, l ��•9' ` 1 �.'" __. 1 _ _ Varra-Coul son- . - • D ;-.y _ .....-1.::,-, .. i &..., Ia_ r '. ,iii%• .. i.r. '• . .i II{v �'.,j'.4.Isle�':'...HA la d _ Project • •,C-:n. 7~' :I: __ elite 'n • - e4D.� 4Bs..•�' - -- ___ - �',�: is m O N -�` i _,.. .„.,;.._ SFr shv__. .•�.,\ `•'• ,�.�1 I ,`;• I - _ ' D PI D C.°) IF .. - • 'ti t �inG[aMe G7 ≤ —I D ��}ti ,y r ..� "\ r ' '-I�X T�'� \�_a.�4er•� r .• �_-_ 1 __ . " .. •\ i .q i�. -. — `• yt. \'1+.7 •-e. ,►. .;14'BJe.: ;a•• "''!.• • s'•.•• __. •,V6. Z !:•, ^'� +r_ l -" ttl . 3 - ••; Pi. .�._\-�T. :.,��—ic�;4 ,;arrf , • •,,••, , (/ qf ;4 : ! j > � " '�' , ' ri A1,.4 • '964/ 4CY,. r.F_'.h: 1 l' 'ill s { ,r rfI • #a :• .i Y.._ .• . ° `'•ire. 1••le' s rr" ,fit{.F : ----- `• (rJ rs 4 ? :•,•;• '• •' •�06 • 5. • J __. i, .., .• .,. ....._ • _. •r , 1 = • .:>. /. —.IL', if s `'I Y.ailerl 'c, _ T F .; .L 1.,:-; 1--42.--P.1 i ..* .. N '. i; f _, \' ..'-. a ..ice- .•. ,•'J<,•?' . .T. _. PROJECT: Varra—Coulson Project — Parcel Location I DRAWING: Index Map NE/4, Sec. 10, T5N, R65W, 6th PIN,. DEC28 2013 Varna Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303) 666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: I) a Stability Analysis Report pertaining to the proposed Marra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra—Coulson Resource Project— Regular Impact(112)Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project— Regular Impact (112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law.• �.-- /11/V21)- / %/L2 j/ / / 2 - ,2013 Sig nature of Adjacent Landowner d / Date Jfl1 e > !�i � (akieV Print Name l State of Co/G,-0,of o ) ) ss. County of i,c,,e/ ) The foregoing instrument was acknowledged before me this t) day of %0(rbr��y�� 2013,by -F ID 5 1-tj ( for 3. Title Company or Corporation ! i rotary Public AARON LAWSON NOTARY PUBLIC My Commission expires: O/-09- (AI/iv? S FAIL Oh COLORADO -- 2 NOTARY ID 20134000985 MY COMMISSION EXPIRES JANUARY 9,2017 DEC 1 2 2013 Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact (112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra—Coulson Resource Project — Regular Impact(112)Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra- Coulson Resource Project-Regular Impact (112)Penult Application M-2013-064; , Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with stab' hed law. "' C �l� (,�77 �� 77— ve -.; ,2013 Signature of Adjacent Landowner Date L1\6 __ M 320v 9%.A,_ Print Name n State of v(3\uciiAelm ) ) ss. County of C_OeVA ) The foregoing instrument was acknowledged before me this Z2 ma c° day of 1 W e�N..\b-i r , 2013,by Ui+ _A 1iiis yR\Nfav� �-c` ( Cmmurov for Ci)iiiikrS1moV ,ej j jj,,,j 0.2.), ltle Company or Corporation i = si ` "9. i=1 Notary Public SLth Jol \C < 5 _ )t�2U5� e'p i '• �� ti My Commission expires: y��s yfrs '1s',`c`''� ^ 2 Varra Companies, Inc. Office of Special Projects 8120 Uage Street Frederick,Colorado 80516 telephone(303)666-6657 fax(3O3)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: I) a Stability Analysis Report pertaining to the proposal Varra-(:oulson Resource Project - Regular Impact (112) Permit Application M 2013 064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson 12esource Project Regular Impact(112) Permit Application M-2013-064. Upon review of the available materials; - And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within die proposed Varra- Coulson Resource Project- Regular Impact(112) Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law. T� N,,,t �� ---,2013 Signaruhc of Adjacent Landowner\'il Date C3\x,cmt \"\C-am,\CX3C Print Name J Stale of C-O\CCCS.(S J ) ) ss. County of NJ�.-\( -34_ ) 3 he loregoi gjoi un t was a owledged before me this d;iy olI47 __. 2013,by� � r•J t L amr� — Title Colnpany or Corporation �f� Public Notary Public My Commission expires, /0 r TERESA MALLOY 2 Notary Public State of Colorado Varra Companies, Inc. Office of Special Projects 8120 Gape Street Frederick. Colorado 80516 Telephone(303)666-6657 Fax(303) 666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: I) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact (112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra- Coulson Resource Project-Regular Impact (112) Permit Application M-2013-064; 1 Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your struct - as a direct result of our active operations, it will be compensated for, consistent with e abl' ed law �� _ (] mil' 7�/ , s tt5re of Adjacent Landowner Q20l3 /�1-7 14/1"" 4:: >'L/frZ,z/ t Print Name ri State of O10 retAO ) � �� ) ss. County of e-->'—` - ) The foregoing instrument was acknowledged before me this �U day of Ot ( °✓�u, 2013,by ( For ). Title Company or Corporation LINDA HANNA NOTARY PUBLIC Not ublic STATE OF COLORADO M Cornmjssion ex{.�ires IS Z,l 4 17 • My Commission Expires February 15,2014 2 Varra Companies, Inc. Nov 1 3 291 Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax (303) 666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra—Coulson Resource Project — Regular Impact (112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project—Regular Impact (112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law../ SOIL/ X/C/a / // ,2013 Signature of Adjacen Landowner Date WS. 13115 �//gin l/`�5 �e�'e� - Print Name JUDITH MORALES (State of [? /nvri r,(/ ) NOTARY PUBLIC STATE OF COLORADO ,, 'p J ) Ss. NOTARY ID 20034016039 1A/€l County of 1 4 ) MY COMMISSION EXPIRES JUNE 16,2015 The foregoing instrument was acknowledged before me this 1 f day of /WI/toy/bit. 2013,by WIIIvarn VohS anci Iertja Vohs ( for ). Title Company or Corporation 1/1417O N �'nv P lic C' LI Ay Commission expires. (40-(o15 2 Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick. Colorado 80516 Telephone(303) 666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact (112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within die proposed Varra- Coulson Resource Project-Regular Impact (112) Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with establishe a . li /64 ,2013 l Signature cc an downer Date gkuces L. Iv; t ' Print Nameame ^`U�`�� O Aa�Pit State of Cblorc`.dt ) � 1 ss. ys a 1 County of \jA1 t � - The foregoing instrument was acknowledged before me this - 3 day of t b6P 2013,by U i14 i{ �� ( t�iclrel+ for (rii 1 ( 'rn`r u r u,,�� ). Title Company or torpdriation k - e c it L 41_, Notary Public My Commission expires: tic/ .C�14 2 Varra Companies, Inc. NOV 0 4 2n13 Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax 030331666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact (112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project—Regular Impact(112)Permit Application M-2013-064; 1 Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law. rl w Oc- a ( ,2013 Signature of Adjacent Lando6Ivner Date S VIaroln / 0tti9 Print Name J State of CVAokcycv.) ss. County of ) The foregoing instrument was acknowledged before me this s31CJd day of rLQ 2013,by ila9�3C\ t Jd\C-Y>r\ ( Ot A i'\ for Company of Corpo .(\��C k. ) • • �� Py P Notary Pu 1' Z. � jQ.� O My Commission expires:� IX ;QQ 2 STATE.0F.GO Varra Companies, Inc. OCT 2 6 2013 Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project -- Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra—Coulson Resource Project — Regular Impact(112)Permit Application M-2013-064. Upon review of the available materials; • And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project—Regular Impact (112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established law. / 6 ' 25--- ,2013 Signat e of Adjacent Lando\ ner Date c)acirt+ 4 , WttYEc. Print Name State of Cl(7✓ado ) ) ss. County of tAl2.lC\ ) The foregoing instrument was ae nowledged before me this day of G 2013,by JuciA;+L P . ekk ( Ac '6 loguja.w.,,r for /U/4- k)/q ). T e Company or Cor.pza it 1_._ _,-,.`- .-,--7,,,,,:-.- �'4�'ERIKA A. DOTY . •NOTARY PUBLIC Notary Public STATEF IDC20O124OLRADO MY COMMISSION EXPIRES OCTOBER 2A2016 ' My Commission expires. /O/2V/2-O/fO Varra Companies, Inc. OCT 2 4 2013 Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303)666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra- Coulson Resource Project- Regular Impact (112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established-law. sr" �!�i1�� l0 a.7 ,2013 CSigr{ature f Adjacent Landowner Date i/; /r, J ( Print Name CELESTE y6 lair MUG STATE OF COLORADO State of l:VIov7rt utdo ) NOTARY ID 20124027815 -'.+MISSION EXPIRES MAY 0S•2016 ) Ss. County of We VA The foregoing instrument was acknowledged before me this day of a✓lb t2 h 2013,by MICAWA V71.1617 Lot-91i,5 1\OV• Litt ) d Company or Corporation Nota u My Commission expil API PI 2 Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick, Colorado 80516 Telephone(303) 666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra—Coulson Resource Project — Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact(112)Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and pennanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra- Coulson Resource Project-Regular Impact(112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as di c 'tilt of our active operations, it will be compensated for, consistent with establis •w. /C - /2- ,2013 ignatu f dj cent Landowner Date 4, CV4 5P , Print Name •State of Clot ace• ) �?U'A9LT9 �4 ss. < is Count of �r,elcl ) •y 7-C�� t 5 *yvT O•-/ .•'o - 4 The foregoi a instrument was acknowled ed before me this 4,-m�a%+.�:..•i \ .C t�� r ; 2013,by �zy A C c�r �� - (MWa VX'R for Company or Corporation ��C\�\C1C� 1'L\Ca� Arc. Notary Public My Commission expires: ht7a 1 A\ i2(*it 2 Varra Companies, Inc. OCT 2 2 POI Office of Special Projects 8120 Gage Street Frederick,Colorado 80516 Telephone(303)666-6657 Fax (303) 666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below- testifies we have been provided with and opportunity to review: 1) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact(112) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra-Coulson Resource Project - Regular Impact (11.2) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project— Regular Impact(112)Permit Application M-2013-064; 1 Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with established'aw. -/- "4„c-,/,-(/‘ 2 e76-re/3,f/2 9- / ,2013 Signature of Adjacent Landowner Date eall,v D,„,L /7/Jo 1'1 , /27nN'✓N'- n Print Name/ (' tr i-/i-2m 5, te. c.. JESSICAANNE AUSTIN State of (r no d r ) NOTARY PUBLIC CD STATE OF COLORADO �I I p ) ss. NOTARY ID 20134001934 County of al pa Y n I D 1s ) MY COMMISSION EXPIRESJAN.15,2017 The foregoing instrument w s a knowledged before me this 51. day of 0 C-t pJ` V , 2013,by ( o ia9cr for V �- C- ). Title Conipan or Corporation .� -1 P f in-z-ni s, ` G 2— . N ry Public My Commission expires: II p I 5 III 2 Varra Companies, Inc. Office of Special Projects 8120 Gage Street Frederick,Colorado 80516 Telephone(303) 666-6657 Fax (303)666-6743 Statement of Understanding Landowner of Adjacent Structure Statement: Our notarized signature below testifies we have been provided with and opportunity to review: I) a Stability Analysis Report pertaining to the proposed Varra-Coulson Resource Project - Regular Impact (1.12) Permit Application M-2013-064; and, 2) a Map showing the approximate relationship of our property and the potential for any qualified significant, valuable and permanent man-made structure(s), which may occur within 200 feet of lands affected within the proposed Varra—Coulson Resource Project — Regular Impact(112) Permit Application M-2013-064. Upon review of the available materials; And understanding the relationship of any significant, valuable and permanent man-made structures under our ownership and which may stand within 200 feet of lands affected within the proposed Varra— Coulson Resource Project—Regular Impact(112)Permit Application M-2013-064; Further, by our signatures, as notarized below, we concur that planned activities detailed in the application for permit M-2013-064; do not impact our qualified significant, valuable and permanent adjacent man-made structures; and to assure you that in the unlikely event damage occurs to your structures as a direct result of our active operations, it will be compensated for, consistent with establisl d law. ^_---- Or-kbIsig I g ,2013 Signature of Adjacent Landowner Date p� uot�stpr�r - . <a 11>s , 0.0 u_\ o a S 4 Print Name T Q�• ..F" 'o o L• I O T A R c.% State of apt o _a.A.n ) --0: p L i G .'O: JJ � ) ss. %yj�▪ , ,.• O County of / 12\1'5 ) ' tsz- `",oF CO••O�`\ a The foregoing instrument was acknowledged before me this /51-1-§,— day of _ /�__ a 2013,by )&mu Eh,. Gt A.sba ( PR-E- `;A -5,a. forOi, Lsbk) `z_xrm.-v5 Pr-A-\tJ 4 @ttn -P9 S i c ). Title Compaq or Corpbratio i`k-n.-v n v1\\ Notary Public My Commission expires: sari x,2O I ej 2 File contains oversized Maps Originals were sent to planning on 1/28/2014 • Exhibit G - Water Information • Exhibit C-2: Extraction Plan (2 Pages) • Exhibit C-1 (B): Structures Easements and R-O-W (2 Pages) • Exhibit C-1 (A) Existing Conditions (2 Pages) • Floodway and Erosion Mitigation Map • Riprap Typical Section and Profile Please See Original File Hello