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HomeMy WebLinkAbout20153842.tiff Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 Monday 7 December 2015 To : Colorado Office of Mined Land Reclamation (Office) Division of Reclamation Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 RECEIVED From : Varra Companies, Inc. DEC 0 g 20f5 Bradford Janes, Forester WET COUNTY Liaison, Office of Special Projects COMMISSIONERS Subject: Amendment # 1 — Varra Companies, Inc. Western Sugar Reclamation Land Development Project - OMLR Permit # : M-2010-049 --- and follow-up pertaining to prior Office denial of our Technical Revision #4 of 2013 . Submitted with this correspondence, find a complete Amendment Application of one original and four (4) copies, the Amendment Fee of $ 2, 229 .00 (Check #41278), proofs of submittal consistent with and as part of Exhibits Q & R, and related attachments. Following is contextual information pertaining to why and how this 'Amendment' came about subsequent to our efforts to properly obtain approval under an OMLR Technical Revision in 2013 . Portions of the following were originally drafted on Thursday 29 August 2013, but never sent. It seemed appropriate to have these comments on record to establish context for this Amendment submittal : On 13 August 2013, the Office wrote a letter indicating it denied our request for a Technical Revision intended to provide the specifications for lining our completed basins at our Western Sugar project. The stated reason is the need to change the post-mining land use by Amendment to Developed Water Resource. The Applicant never had opportunity to rebuttal the opinions of the Office, nor were the Application Fees refunded. Essentially, our opinion was never considered before the Office made its determination . This submittal attempts to remedy the matter by applying for Amendment, instead of persisting by way of Technical Revision, in regard to our good history and relations with the diverse members of the Office. Still, we think some aspects of the prior submittal, which form this Amendment, as a requirement of process asserted by the Office, needs to be set down for continuity and durability of any subsequent interactions. r-Pabi rZA/aO)t� 199 2015-3842 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 The original determination of the Office ignored Eieverdl references rences within the original permit and attending adequacy review statements that clearly specify Developed Water Resources as part of the mixed use reclamation planned for the site. Further, we had established a practice_ of submitting 'technical Revisions for matters of this kind, as the Applicant has sufficient waters to reclaim these basins in either a lined or an unlined state, and provided the necessary assurances of committed water resources sufficient to support this statement. This condition of abundant water resources, places the Applicant in a situation unique in this industry, and affords us flexibility from which considerations by Technical Revision were considered sufficient prior to this circumstance and opinion of the Office, Regardless, in light of that decision, we have closely examined the statements iivide in the original permit and ai.tencdii7g adequacy review letters that lead us to believe the decision on the part of the Office to deny our Technical Revision ignored the stated intent of the original permit. Furthermore, that decision did injury and harm both to the contract, which is the permit, and to the Applicant who kS; party to that contract, So while the Amendment is now in the nand` of the Office, the circumstances attending to evidence�' and t r �f. the t ;i time t ( se forth benchmark �. . id,�r�c'F, �.:��•� facts ;�>; permit up r t ���. ,. t:� r�r,c-_ �l► _�t.i (c! be set to 1�:�_, c•lamar•k the matter, as follows : Taken from page 1 of the OMLR 'Lined Pit Guide — September 2000:' INTRODUCTION It has become a common practice to reclaim gravel pits to a developed water resource land use through the installation of clay pit liners or slurry walls. The purpose of these installations is to isolate the constructed water storage reservoir from the surrounding ground water system. Please Note : Nothing in the guidelines requires the designation of ` developed Water Resource land use to be either 'Primary' or the 'Singular' use designation. Taken from page 13 of the OMLR 'Lined Pit Guide — September 2000 :' PERMITTING OPTIONS Frequently, the process of permitting a gravel pit and lined reservoir project precedes the design phase making it difficult and costly to prepare and application that will qualify for the regulated construction option and the reduced bond amount. The following list describes permitting mechanisms that may be employed to allow application approval prior to design and specification preparation and preserve the option to post the reduced bond amount available under the regulated construction option. Varra Companies, Inc. Western Sugar Land Development Project 2 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, (:O 80516 Telephone (303) 666-6657 Fax (303) 666-6743 An application could include a general description of the clay liner or slurry wall installation, similar to what would be sufficient under the 100 percent performance bonding option. The application would be approved with a commitment stating that a liner or slurry wall design, specifications, and quality assurance plan would be submitted as a technical revision and the revision would be approved prior to the exposure of ground water in the pit. l ea.)c Note : The uuicleifi icy; provide or the use of a Technical chnical Revision for purpos t, U finalizing liner specifications, USE (as stated in the original permit application): i_ . The lands comprising the Western ;Sugar Project are zoned 1-3 Industrial, and the permit application primary use (check one) reflected this use. The application ` vent on to clarify the mixed use potentials and intent of the planned reclamation under the permit; and included plans to line the resulting basins as resulting part of `Developed Water Resources. ' Additional commentary in Exhibits G and L, respectively, serve to further clarify the intent. From Exhibit E : All affected lands remaining above the anticipated final water level of the basins, and not otherwise occupied by existing or planned mixed uses, will be re-vegetated with the approved seed mixture(s) for general agriculture. Since the existing pasture comprised predominantly of weeds is being replaced predominantly with native grasses, the target for release of revegetated lands is based upon the establishment of a stabilizing cover of predominantly native vegetation whose foliar umbrella equals or exceeds 20 percent of the total area of the ground as measured three inches above the native soil on a square meter basis for typical areas of reclaimed cover achieved within five years subsequent to the completion of all extraction activities. Mixed use(s), other than general agriculture will occur and may include, but are not limited to: the retention of existing structures as desired (e.g., processing facilities and plant(s), concrete batch plant, asphalt batch plants, recycling facilities and related operations, shop, scale-house/ office, and supporting facilities (fuel depots, parking areas, oil and gas facilities access, Varra Companies, Inc. Western Sugar Land Development Project 3 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gate Street Frederick, CO 80516 Telephone (303: 666-6657 Fax (303) 666-6743 etc.) for continued industrial - commercial use (as validated by any co-related and required Weld County Building Permits); the creation of unforeseen future structures, and for the use and development of on-site water resources. Since the area of surrounding lands is a mix of these uses, the site end use will retain these potentials. From Exhibit G : The reclamation plan provides that the pits will be lined after being mined. The lined pits will not require replacement water and will be used for storage. There may be incidental demand for water to establish vegetation on the site after lining is completed. However, the ultimate demand for water will be zero. From Exhibit L: NOTE: The basins resulting from extraction will be reclaimed in an unlined state, since the operator retains sufficient water resources to do so. The basins may be lined or otherwise segregated from the area groundwater as an option to the approved permit, in order to liberate the water otherwise retained to supplement loss from evaporation in the unlined state, Since sufficient water resources exist, the option to line the resulting basins at an unspecified time during the life of the permit is retained under this application and as part of the approved permit. Adequacy Review (as stated over several correspondence from December 2010 to March 2011) Of special note is the Adequacy letter and reply of 23 February 2011 , In this correspondence, any misunderstanding as to custom is intended to be repaired by an invitation by the Office to revise page four of the 112 Application Form to reflect the multiple post mining land uses stated throughout the permit application exhibits. This revision was made and included in the reply, and included 'Developed Water Resources, , as shown in the included attachment of that correspondence, now on file with the Office . Other references relevant to intent are made manifest in the several adequacy correspondence extracted and otherwise made evident., as follows : Varra Companies, Inc. Western Sugar Land Development Project 4 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Cage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 From the 13 December 2010 Adequacy Reply: 18 . The applicant states in Exhibit G - Water Information, that the pits will be lined upon the completion of mining. However, the Reclamation Plan does not provide any details about lining the reservoirs. Please clarify if the reservoirs will be lined or unlined. If they are to be lined, then please provide the Division with design specifications and detailed plan for lining the reservoirs. Since the applicant is blessed with waters sufficient to create unlined basins , for purposes of this submittal, the applicant desires to maintain the option of lining extracted basins to liberate water for other purposes than augmentation. Since this is a method reserved for consideration under a subsequent Technical Revision with the Office , we respectfully request the specifics of construction be addressed at that time , since it does not bear upon current financial or permit performance considerations under the present plan of operations . From the 23 February 2010 Adequacy Reply: 6 . The Applicant has stated a Technical Revision may be submitted to allow for the lining of the pits. The Division considers lined pits to be a developed water resource , which would constitute a significant change from the proposed post-mining land use of industrial/commercial and would require an Amendment rather than a Technical Revision. • The creation of basins within a permit boundary will not in general consume the entire permit or above water elements of extraction activities. It is consistent with the Uses allowed by County governments that developed water resources may occur under Agricultural, Industrial , or Commercial spaces . Yet the Regular Impact Permit form only provides for the selection of one Use . Varra Companies, Inc. Western Sugar Land Development Project 5 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 It is our understanding that the selection should not restrict the establishment of developing the location in a manner that elevates the land to the highest level of Use attainable under its diverse parts. It would appear logical that if the entire permit area cannot be put into a basin that above ground portions will form an alternative , and hence, multiple , Use . To narrow the range of acceptable uses within the framework of acceptable reason and purpose is unnaturally constrained and at odds with the purposes of reclamation. The current understanding of the OMLR, appears to place the operator in a Catch 22 , whereby the above ground portions of the permit will be at odds with the completed basin. If necessary, the applicant will provide a change in the Use requested by the OMLR to that of `Developed Water Resources, ' with the understanding that all above water portions of the reclaimed permit area will revert to the existing Industrial/Commercial designations of Weld County, Colorado without impeding the diverse potential Use of the contained waters. From the 13 March 2011 Adequacy Reply: 1. The Applicant has stated a Technical Revision may be submitted to allow for the lining of the pits. As noted in the Division's previous Adequacy Review Letter, the Division considers lined pits to be a developed water resource, which would constitute a significant change from the proposed post-mining land use of industrial/commercial and would require an Amendment rather than a Technical Revision. The Division understands mine sites may be reclaimed to multiple land uses. However, if the Applicant does not identify `developed water resource' as one of the post-mining land uses, then the Applicant will be required to amend the Reclamation Permit should they decide to line the pits in the future. It is common practice to identify multiple post-mining land uses on the permit application. The Applicant should be familiar with this practice as they have identified multiple post-mining land uses on previously submitted permit applications (copy enclosed). The Applicant may revise page four of the permit application to include multiple post- mining land uses. Varra Companies, Inc. Western Sugar Land Development Project 6 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Ga2e Street Frederick, CO 80516 Telephone (303) 666-6657 Fax (303) 666-6743 We understand now that even though the 112 form states primary use `check one,' that more than one may be checked. The OMLR on- line pdf form only allows for one check. Previously, we've attempted to use text in the body of the permit to clarify multiple use matters, only to discover the OMLR relies upon this page . Historically, a primary use did not exclude other uses detailed by text and reason; it was simply the `primary' use and did not exclude secondary or multiple uses if stated in later application exhibits. As extracted from Exhibit E -- Reclamation Plan: Mixed use(s), other than general agriculture will occur and may include, but are not limited to: the retention of existing structures as desired (e.g., processing facilities and plant(s), concrete batch plant, asphalt batch plants, recycling facilities and related operations, shop, scale- house/office, and supporting facilities (fuel depots, parking areas, oil and gas facilities access, etc.) for continued industrial - commercial use (as validated by any co-related and required Weld County Building Permits); the creation of unforeseen future structures, and for the use and development of on-site water resources. Since the area of surrounding lands is a mix of these uses, the site end use will retain these potentials. Attached is a revised 112 form, page 4, which replaces page 4 of the 112 form originally submitted, which also includes general agriculture as clarification of the above statement. There was an active pivot and former cattle yard within the industrial zoned land as a component of the present land use. Further, since the lands are zoned industrial by Weld County, Colorado, this may be perceived by some as comprising the primary future use as well - but it is simply the current zoned use. The predominant, or primary, future use by area as a result of reclamation of the basins is `Developed Water Resources.' The above ground portions would constitute the other potential end uses, yet all will be contained within the standing zoned industrial use. At its simplest, the reclamation of the above ground portions for release Varra Companies, Inc. Western Sugar Land Development Project 7 OMLR Permit # : M-2010-049 Amendment 7 December 2015 Varra Companies, Inc. OFFICE OF SPECIAL PROJECTS 8120 Gage Street Frederick, CO 80516 'Telephone (303) 666-6657 Fax (303) 666-6743 aims at establishing the approved seed mixture to stabilize the above water portions of the affected lands. From the 14 January 2011 Adequacy Comments from Kate Pickford, and subsequent reply from Joby Adams, Hydrogeologist, C.G.R.S. : 4. The application indicates that the resulting ponds may be lined. If so the applicant must submit data regarding the resulting mounding and shadow effects around the lined ponds and the mitigation measures that it will take to correct these effects if it will result in impacts to surrounding land vegetation and structures. 'A-4 - As presented to the Division on other projects the lining of a pond has little effect on the local hydrology and water level changes that do occur are on the order of a foot or less. Unless continuous monitoring is implemented water level changes at any distance from the pond face are, for all practical purposes, undetectable.' The stated reason by OM1 , R for previous denial of the Technical Revision is that it would constitute a ' proposed change in post- mining land use, ' and hence require an Amendment to the permit, changing the use from `Industrial/Commercial to Developed Water Resource . ' The. correspondence continues stating that, 'significant changes in post- mining land use require public notice per Rule 1 .6 . ' It remains a curiosity to us as in what manner this holds true? In the interim, lies before you our Amendment Application, provided in respect of our differences in this matter in a good faith attempt, in spite of our differences, to cure this matter according to and consistent with the dictates of the Office. The application is submitted in good faith that it fully conforms with the spirit and intent of the Act and its attending regulations respective of the Amendment requirements and process now at play. It should be understood; while Developed Water Resources is now the ' Primary' end use, other mixed uses as stated in the Original Application as Approved/ remain in effect. Thank-you for your understanding and consideration of this submittal . Naturally/ if you need clarification or additional information, please do not hesitate to contact us. cc. Garrett Marra, Vice President Varra Companies, Inc. Varra Companies, Inc. Western Sugar Land Development Project 8 OMLR Permit # : M-2010-049 Amendment 7 December 2015 STATE OF COLOFADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman Si, Room 215 Denver, Colorado 80203 COLORADO Phone: (303) 866-3567 CONSTRUCTION MATERIALS DIVISION OF RECLAMATION FAX: (303) 832-8106 REGULAR (112) OPERATION MINING RECLAMATION PERMIT APPLICATION FORM SAFETY Bill Ritter, Jr. CHECK ONE: ✓ There is a File Number Already Assigned to this Operation Governor Harris D. Sherman P M - - - (Please reference the file number currently assigned to this operatiolplecutive Director New Application (Rule 1 .4.5) _171Amendment Application (Rule 1 .10) Ronald W. Cattalo/ Division Director Conversion Application (Rule 1 . 11) Natural Resource Trustee Permit # M - 2010 - 049 -_ (provide for Amendments and Conversions of existing permits) The application for a Construction Materials Regular 112 Operation Reclamation Permit contains three major parts: (1) the application form; (2) Exhibits A-S, Addendum 1, any sections of Exhibit 6.5 (Geotechnical Stability Exhibit; and (3) the application fee. When you submit your application, be sure to include one (1) complete signed and notarized ORIGINAL and one (1) copy of the completed application form, two (2) copies of Exhibits A-S, Addendum 1, appropriate sections of 6.5 (Geotechnical Stability Exhibit, and a check for the application fee described under Section (4) below. Exhibits should NOT be bound or in a 3-ring binder; maps should be folded to 8 1/2" X 11" or 8 1/2" X 14" size. To expedite processing, please provide the information in the format and order described in this form. GENERAL OPERATION INFORMATION Type or print clearly, in the space provided, ALL information requested below. 1 . Applicant/operator or company name (name to be used on permit): Varra Companies, Inc. 1 . 1 Type of organization (corporation, partnership, etc.): Colorado Corporation 2. Operation name (pit, mine or site name): Western Sugar Reclamation Land Development Project 3. Permitted acreage (new or existing site): 102.87 permitted acres 3.1 Change in acreage (+) - 0 - acres 3.2 Total acreage in Permit area 102.87 acres 4. Fees: 4. 1 New Application $2,696.00 application fee 4.2 New Quarry Application $3,342.00 quarry application 4.4 Amendment Fee $2.229.00 amendment fee 4.5 Conversion to 112 operation (set by statute) $2,696.00 conversion fee 5. Primary commoditie(s) to be mined: sand gravel construction materials earth products 5. 1 Incidental commoditie(s) to be mined: 1 . - lbs/Tons/vr 2. / lbs/Tons/vr 3. / Ibs/Tons/vr 4. / lbs/Tons/yr 5. / lbs/Tons/vr 5.2 Anticipated end use of primary commoditie(s) to be mined: urban infrastructure & development 5.3 Anticipated end use of incidental commoditie(s) to be mined: N/A Office of Office of Mined Land Reclamation Denver • Grand )unction • Durango Active and Inactive Mines _ 2 _ 6. Name of owner of subsurface rights of affected land: Refer to Exhibit O I f 2 or more owners, "refer to Exhibit Out. 7. Name of owner of surface of affected land: Varra Companies, Inc. 8. Type of mining operation: Surface EL Underground 9. Location Information: The center of the area where the majority of mining will occur: COUNTY: Weld PRINCIPAL MERIDIAN (check one): ✓ 6th (Colorado) El 10th (New Mexico) E. Ute SECTION (write number): nine TOWNSHIP (write number and check direction): T five ✓ North I South RANGE (write number and check direction): R sixty-five I I East ✓ West QUARTER SECTION check one): I I Q ( ) QUARTER/QUARTER SECTION (check one): ✓ NE NW SE SW GENERAL DESCRIPTION: (the number of miles and direction from the nearest town and the approximate elevation): immediately east of Greeley, Colorado. Elevation 4,636 feet. 10. Primary Mine Entrance Location (report in either Latitude/Longitude OR UTM): Latitude/Longitude: Example: (N) 39° 44' 12.98" (W) 104° 59' 3.87" Latitude (N): deg 37 min 38 sec 41 . 00 (2 decimal places) Longitude (W): deg 108 min 09 sec 21 . 00 (2 decimal places) OR Example: (N) 39.73691 ° (W) - 104.98449° Latitude (N) (5 decimal places) Longitude(W) (5 decimal places) OR Universal Tranverse Mercator (UTM) Example: 201336.3 E NAD27 Zone 13 4398351 .2 N UTM Datum (specify NAD27, NAD83 or WGS 84) Nad 83 Zone 13 Easting 2230388.85 Northing 396239. 11 - 3 - 11. Correspondence Information: APPLICANT/OPERATOR (name, address, and phone of name to be used on permit) Contact's Name: Christopher L. Varna Title: President Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: ( 303 ) _ 666-6657 Fax Number: ( 303 ) - 666-6743 PERMITTING CONTACT (if different from applicant/operator above) Contact's Name: Bradford Janes Title: Forester Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: f 970 ) _ 353-8310 Fax Number: ( 970 ) - 666-6743 INSPECTION CONTACT Contact's Name: Garrett C. Varra Title: Vice-President of Operations Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: ( 303 ) _ 666-6657 Fax Number: ( 303 ) - 666-6743 CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Zip Code: Telephone Number: ( ) - CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Zip Code: Telephone Number: ( ) - - 4 - 12. Primar future (Post-mining) land use (check one): Cropland(CR) El Pastureland(PL) General Agriculture(GA) n Rangeland(RL) Li Forestry(FR) Wildlife Habitat(WL) _O Residential(RS) El Recreation(RC) Industrial/Commercial(IC) ✓ Developed Water Resources(WR) D Solid Waste Disposal(WD) 13. Primary present land use (check one IMIMINF D_ Cropland(CR) -ONINI Pastureland(PL) -4a General Agriculture(GA) El Rangeland(RL) Forestry(FR) Wildlife Habitat(WL) Residential(RS) Recreation(RC) 1Industrial/Commercial(IC) Developed Water Resources(WR) 14. Method of Mining: Briefly explain mining method (e.g. truck/shovel): Surface extraction and processing of aggregate using heavy equipment such as dozers, front-end loaders, haul trucks, etc. 15. On Site Processing: 171Sit l Crushing/Screening 13. 1 Briefly explain mining method (e.g. truck/shovel): Materials are extracted and removed to screens and crushers for processing into product to be sold for urban infrastructure needs List any designated chemicals or acid-producing materials to be used or stored within permit area: none - all fuels and lubricants will be brought in as needed on mobile equipment and vehicles 16. Description of Amendment or Conversion: If you are amending or converting an existing operation, provide a brief narrative describing the proposed change(s). - 5 - Mans and Exhibits: Two (2) complete, unbound application packages must be submitted. One complete application package consists of a signed application form and the set of maps and exhibits referenced below as Exhibits A-S, Addendum 1 , and the Geotechnical Stability Exhibit. Each exhibit within the application must be presented as a separate section. Begin each exhibit on a new page. Pages should be numbered consecutively for ease of reference. If separate documents are used as appendices, please reference these by name in the exhibit. With each of the two (2) signed application forms, you must submit a corresponding set of the maps and exhibits as described in the following references to Rule 6.4, 6.5, and I .6.2(1 )(b): EXHIBIT A Legal Description EXHIBIT B Index Map EXHIBIT C Pre-Mining and Mining Plan Map(s) of Affected Lands EXHIBIT D Mining Plan EXHIBIT E Reclamation Plan EXHIBIT F Reclamation Plan Map EXHIBIT G Water Information EXHIBIT H Wildlife Information EXHIBIT I Soils Information EXHIBIT J Vegetation Information EXHIBIT K Climate Information EXHIBIT L Reclamation Costs EXHIBIT M Other Permits and Licenses EXHIBIT N Source of Legal Right-To-Enter EXHIBIT O Owners of Record of Affected Land (Surface Area) and Owners of Substance to be Mined EXHIBIT P Municipalities Within Two Miles EXHIBIT Q Proof of Mailing of Notices to County Commissioners and Conservation District EXHIBIT R Proof of Filing with County Clerk or Recorder EXHIBIT S Permanent Man-Made Structures Rule I .6.2(1 )(b) ADDENDUM 1 - Notice Requirements (sample enclosed) Rule 6.5 Geotechnical Stability Exhibit (any required sections) The instructions for preparing Exhibits A-S, Addendum I , and Geotechnical Stability Exhibit are specified under Rule 6.4 and 6.5 and Rule 1 .6.2(1)(b) of the Rules and Regulations. If you have any questions on preparing the Exhibits or content of the information required, or would like to schedule a pre-application meeting you may contact the Office at 303-866-3567. Responsibilities as a Permittee: Upon application approval and permit issuance, this application becomes a legally binding document. Therefore, there are a number of important requirements which you, as a permittee, should fully understand. These requirements are listed below. Please read and initial each requirement, in the space provided, to acknowledge that you understand your obligations. If you do no • understand these obligations then please contact this Office for a full explanation. el 1 . Your obligation to reclaim the site is not limited to the amount of the financial warranty. You assume legal liability for all reasonable expenses which the Board or the Office may incur to reclaim the affected lands associated with your mining operation in the event your permit is revoked and financial warranty is forfeited; _ 6 - elle 2. The Board may suspend or revoke this permit, or assess a civil penalty, upon a finding that the permittee violated the terms or conditions of this permit, the Act, the Mineral Rules and Regulations, or that information contained in the application or your permit misrepresent important material facts; 3. If your mining and reclamation operations affect areas beyond the boundaries of an approved permit (0 boundary, substantial civil penalties, to you as permittee can result; 4. Any modification to the approved mining and reclamation plan from those described in your approved application requires you to submit a permit modification and obtain approval from the Board or Office; d 5. It is your responsibility to notify the Office of any changes in your address or phone number; idJ 6. Upon permit issuance and prior to beginning on-site mining activity, you must post a sign at the entrance of the mine site, which shall be clearly visible from the access road, with the following information (Rule 3 . 1 . 12): a. the name of the operator; b. a statement that a reclamation permit for the operation has been issued by the Colorado Mined Land Reclamation Board; and, c. the permit number. 01) 7. The boundaries of the permit boundary area must be marked by monuments or other markers that are clearly visible and adequate to delineate such boundaries prior to site disturbance. lo4 8. It is a provision of this permit that the operations will be conducted in accordance with the terms and conditions listed in your application, as well as with the provisions of the Act and the Construction Material Rules and Regulations in effect at the time the permit is issued. Cile 9. Annually, on the anniversary date ofpermit issuance, you must submit an annual fee as specified by Statute, and an annual report which includes a map describing the acreage affected and the acreage reclaimed to date (if there are changes from the previous year), any monitoring required by the Reclamation Plan to be submitted annually on the anniversary date of the permit approval. Annual fees are for the previous year a permit is held. For example, a permit with the anniversary date ofJuly 1 , l 995, the annual fee is for the period ofJuly 1 , 1994 through June 30, 1995. Failure to submit your annual fee and report by the permit anniversary date may result in a civil penalty, revocation of your permit, and forfeiture of your financial warranty. It is your responsibility, as the permittee, to continue to pay your annual fee to the Office until the Board releases you from your total reclamation responsibility. 10. For joint venture/partnership operators: the signing representative is authorized to sign this document and a power of attorney (provided by the partner(s)) authorizing the signature of the representative is attached to this application. - 7 - NOTE TO COMMENTORS/OBJECTORS: It is likely there will be additions, changes, and deletions to this document prior to final decision by the Office. Therefore, if you have any comments or concerns you must contact the applicant or the Office prior to the decision date so that you will know what changes may have been made to the application document. The Office is not allowed to consider comments, unless they are written, and received prior to the end of the public comment period. You should contact the applicant for the final date of the public comment period. If you have questions about the Mined Land Reclamation Board and Office's review and decision or appeals process, you may contact the Office at (303) 866-3567. _ 8 _ Certification: As an authorized representative of the applicant, I hereby certify that the operation described has met the minimum requirements of the following terms and conditions: 1 . To the best of my knowledge, all significant, valuable and permanent man-made structure(s) in existence at the time this application is filed, and located within 200 feet of the proposed affected area have been identified in this application (Section 34-32.5-115(4)(e), C.R.S.). 2. No mining operation will be located on lands where such operations are prohibited by law (Section 34-32.5- 115(4)(f), C.R.S.; 3. As the applicant/operator, I do not have any extraction/exploration operations in the State of Colorado currently in violation of the provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials (Section 34-32.5- 120, C.R. S.) as determined through a Board finding. 4. I understand that statements in the application are being made under penalty of perjury and that false statements made herein are punishable as a Class 1 misdemeanor pursuant to Section 18-8-503, C.R.S. This form has been approved by the Mined Land Reclamation Board pursuant to section 34-32.5-112,CR.S., of the Colorado Land Reclamation Act for the Extraction of Construction Materials. Any alteration or modification of this form shall result in voiding any permit issued on the altered or modified form and subject the operator to cease and desist orders and civil penalties for operating without a permit pursuant to section 34-32.5-123, C.R.S. Signed and dated this I CP day of ry ov `en bur 2 O 1 s Vov'c& Compan les., 4 L4i o. If Corporation Attest (Seal) Applicant/Operator or Compan ame Signed: 9 4416%mm. Signed: Cor orate Sec tary or Equivalent Title: President Town/City/County Clerk State of Cokrado ) ) SS. County of WQA4 ) n ' The foregoing instrument was acknowledged before me this � p day of 1 v O V e rh ei Ir , '2-0 I5, by Ch.r i s'apher L. Vav✓o& as Pr4siaevtt of Vat rck COnnpa. A i ts,Dhc. . (3\65\A-r) JESSICA HOOVER NOTARY PUBLIC Nota ublic STATE OF COLORADO NOTARY ID 20044035571 j (�I I My Commission Expires Oct. 4, 2016 My Commission expires: SIGNATURES MUST BE IN BLUE INK You must post sufficient Notices at the location of the proposed mine site to clearly identify the site as the location of a Exhibit A — Legal Description 6.4.1 EXHIBIT A -- Legal Description (1 ) The legal description must identify the affected land , specify affected areas and be adequate to field locate the property. Description shall be by (a), township, range, and section , to at least the nearest quarter-quarter section and (b), location of the main entrance to the site reported as latitude and longitude, or the Universal Transverse Mercator (UTM) Grid as determined from a USGS topographic map. A metes and bounds survey description is acceptable in lieu of township, range, and section. Where available, the street address or lot number(s) shall be given. This information may be available from the County Assessor's Office or U.S. Geological Survey (USGS) maps. (2) The main entrance to the mine site shall be located based on a USGS topographic map showing latitude and longitude or Universal Transverse Mercator (UTM). The operator will need to specify coordinates of latitude and longitude in degrees, minutes and seconds or in decimal degrees to an accuracy of at least five (5) decimal places (e.g. , latitude 37. 12345 N , longitude 104.45678 W). For UTM, the operator will need to specify North American Datum (NAD) 1927, NAD1983, or WGS 84, and the applicable zone, measured in meters. This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit A — Legal Description Legal Description modified on 14 April 2011 : A parcel of land located in part of the NW/4, NE/4 and NE/4,NW/4; Section 9; and a portion of the S/2,S/2; Section 4; all in Township 5 North; Range 65 West; 6th P. M . ; Weld County, Colorado; more specifically beginning from the Northeast corner of Section 9; thence 1 ,317.97 feet S85°03'26"W to the true point of beginning at the Northeast corner of the Parcel and Permit Boundary; then : 1258. 71 feet S00°20'17"E 427 .81 feet S81 ° 14'30"W 187. 76 feet S21 ° 15'32"W 645. 75 feet S62°39'37"\N 254.98 feet S65°08'23"W 670 .46 feet S89°30'06"W, leaving the parcel boundary and forming the West boundary of the permit area on a line running 1652 .92 feet N00°57'02"W (note : this line separates the permit boundary from the remainder of the parcel boundary to the East of this line); and continuing the permit boundary until it reaches the south point of parcel 096104302034 (containing 0. 69 vs. stated 0 .66 acres) where Weld County parcel information is contradicted by the geometry slightly, therefore the line is modified in order to close said parcel along the east boundary of the same (noting that the north and west boundary of the parcel are unchanged by the stated Weld County GIS parcel information) hence 567. 12 feet N10°01 '00"E, then continuing,301 109 .08 feet N89°59'36"E 314.01 feet N00°39'29"W 68.47 feet S77°53'39"E 725 .94 feet N75°07'41 "E 337.80 feet S88°23'21 "E 19.88 feet S01 °00'30"E 342 .79 feet S60°42'25"E 349.71 feet S29°02'36"E 352.91 feet S35°53'24"E, to the true point of beginning, and comprising 102. 18± acres, more or less. The mine entrance is identified on Exhibit C-2 : Extraction Plan Map, and located as identified under NAD 83 Colorado State Plane North Zone — (UTM ZONE 13) : Easting 2231009 .40, Northing 396631 .67 . Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 l•••• • pei P••• -s ‘0 • F• • A1 t.^I I H 1 • .' o • •• • • . • - - 4) •• • W l '• ' z • g Z . • Cd • • ,• :. Del -d I \ O• 7.,' t~ i ` P (1 i I DI) . \ .....i k • w • . z r ,:= Q • I • 0 'i • 111 • • 1/4 - - ___., \ • ' ' ' i I • /s - . .. . iii U * _ rJ I ii •• .,a• 1 • ,t ••r - • `Z �' a • ° .J r -- - • • O I •t• `s��T�s^- rem •a -e.n-- -•.ar-., -- w w.-. !s..+ r• .•••� �.�• • •� �. .•. ( t /1 r r -. •!' • '> • R di • r t t O• Il : HtIH . r Its *C. f 1 II I 4 •0 cil . CJ hi .1., . a . •••••••• • - -.t _ ..C • it-r • c.n . .. 3-1 0t •••• • •• • i N aTil :b.. •• • 1• r.O Gi i 4 . • 1 1 1 ' I L/ • • 1 • • C• r • ( Q- 4 SCALE: 1 Inch = 2,640 feet VARRA COMPANIES, INC. DATE: 8 February 2010 8120 GAGE STREET FREDERICK, COLORADO 80534 REVISION: ,/a S. 4 14 a Exhibit C — Pre-Mining & Mining Plan Map 6.4.3 EXHIBIT C - Pre-mining and Mining Plan Map(s) of Affected Lands One or more maps may be necessary to legibly portray the following information : (a) all adjoining surface owners of record ; (b) the name and location of all creeks, roads, buildings, oil and gas wells and lines, and power and communication lines on the area of affected land and within two hundred (200) feet of all boundaries of such area; (c) the existing topography of the area with contour lines of sufficient detail to portray the direction and rate of slope of the affected land ; (d) the total area to be involved in the operation , including the area to be mined and the area of affected lands (see definition of "Affected Land"); (e) the type of present vegetation covering the affected lands; and (f) in conjunction with Exhibit G - Water Information, Subsection 6.4.7 , if required by the Office, further water resources information will be presented on a map in this section. (g) Show the owner's name, type of structures, and location of all significant, valuable, and permanent man-made structures contained on the area of affected land and within two hundred (200) feet of the affected land . (h) In conjunction with Exhibit I - Soils Information, Subsection 6.4.9, soils information may be presented on a map in this section; (I) Aerial photos, if available, may be included in this section . Adjoining Surface Owners Of Record As Shown On Exhibit C — Pre-Mining & Mining Plan Map (Source: Property Owners from Weld County Assessor Records and Utilities Directly from Utility): Property Number Name & Address 096109100004 Crazybear, Alvis Lee & Neuendorf, Krista Rene 1001 East 16th Street Greeley, Colorado 80631 096109100001 Doeringsfeld & Aratas Partnership do 8120 Gage Street Frederick, Colorado 80516 096109100022 Goddard, Jerry N & Evelyn G 1019 East 16th Street Greeley, Colorado 80631 096109100008 Kinsey, Charles E 096109100009 1433 Birch Avenue Greeley, Colorado 80631 096109100007 Varra, Barbara 1031 East 16th Street Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit C -- Pre-Mining & Mining Plan Map Greeley, Colorado 80631 096109100002 Varra Companies, Inc. 096109100003 8120 Gage Street 096109100023 Frederick, Colorado 80516 096109200012 096109200013 096104000015 096104000016 096104302008 096104302034 Richmark Real Estate Partners 096104302035 5200 W. 20th Street 096109200027 Greeley, Colorado 80631 -3863 096109200005 Briggs Trucking & Equipment Company 11350 Second Street NorthWest Canada, XXT6S 1G2 096109200021 ET&T Pallets, Inc. 096109200023 P.O. Box 63 Kersey, Colorado 80644-0063 096109200011 Galindo, Virginia 615 East 16th Street Greeley, Colorado 80631 096109100010 Goldman, Otoniel M 703 East 16th Street Greeley, Colorado 80631 096109100011 Griego, Alfonso F c/o Charlene Griego P.O. Box 188 Greeley, Colorado 80632 096109100021 Hildred, George W 805 East 16th Street Greeley, Colorado 80631 096109200006 Magdelano, Pete 096109200010 609 East 16th Street Greeley, Colorado 80631 096109200018 Greeley Urban Renewal Authority 096104302032 1100 10th Street, Number 201 096104000061 Greeley, Colorado 80631 096104302009 Ogilvy Irrigation & Land Company ATTN: Steve Cockroft, Ditch Rider 28609 WCR 57.5 Kersey, CO 80644 096104000062 Duggan, Demund J & Loa J — Trust c/o Gerald L Davis, Trustee P.O. Box 340 Windsor, Colorado 80550 Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit C — Pre-Mining & Mining Plan Map 096109100013 Ted Gilliland Revocable Trust 1841 Pinecrest Lane Greeley, Colorado 80631 -5232 And 821 East 16th Street Greeley, Colorado 80631 096109100014 Vega. Santos & Luz Yadira 909 East 16th Street Greeley, Colorado 80631 Other (Utilities, Roads, Name and Address etc) City of Greeley City of Greeley ATTN: City Clerk 1100 10th Street Greeley, Colorado 80631 Merit Energy Merit Energy ATTN: Clay Munger, Operations Manager 1313 North Denver Avenue, Building #3 Fort Lupton, Colorado 80621 Petroleum Development Petroleum Development Corporation Corporation ATTN: Right of Way Dept. 1775 Sherman St., Ste. 3000 Denver, Colorado 80203 Noble Energy Production, Noble Energy Production, Inc. Inc. ATTN: Right of Way Department 1625 Broadway, Ste. 2200 Denver, Colorado 80202 DCP Midstream DCP Midstream ATTN: Right of Way Department 370 17th Street, Ste. 2500 Denver, Colorado 80202 Century Link Century Link Carson Ortega, Engineer III 2505 1st Ave. Greeley, CO 80631 Varra Companies, Inc. Permit M-2010-049 3 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan 6.4.4 EXHIBIT D - Mining Plan The mining plan shall supply the following information , correlated with the affected lands, map(s) and timetables: (a) description of the method(s) of mining to be employed in each stage of the operation as related to any surface disturbance on affected lands ; (b) earthmoving; (c) all water diversions and impoundments ; and (d) the size of area(s) to be worked at any one time. (e) An approximate timetable to describe the mining operation . The timetable is for the purpose of establishing the relationship between mining and reclamation during the different phases of a mining operation . An Operator/Applicant shall not be required to meet specific dates for initiation, or completion of mining in a phase as may be identified in the timetable. This does not exempt an Operator/Applicant from complying with the performance standards of Section 3. 1 . If the operation is intended to be an intermittent operation as defined in Section 34-32 . 5-103(11 )(b), C. R. S. , the Applicant should include in this exhibit a statement that conforms to the provisions of Section 34-32 . 5-103(11 )(b) , C . R . S . Such timetable should include: (i) an estimate of the periods of time which will be required for the various stages or phases of the operation ; (ii) a description of the size and location of each area to be worked during each phase; and (iii) outlining the sequence in which each stage or phase of the operation will be carried out. (Timetables need not be separate and distinct from the mining plan , but may be incorporated therein .) (f) A map (in Exhibit C - Pre-Mining and Mining Plan Maps(s) of Affected Lands, Subsection 6.4. 3) may be used along with a narrative to present the following information: (i) nature, depth and thickness of the deposit to be mined and the thickness and type of overburden to be removed (may be marked "CONFIDENTIAL," pursuant to Paragraph 1 .3(3)); and (ii) nature of the stratum immediately beneath the material to be mined in sedimentary deposits. (g) Identify the primary and secondary commodities to be mined/extracted and describe the intended use; and (h) name and describe the intended use of all expected incidental products to be mined/extracted by the proposed operation. (i) Specify if explosives will be used in conjunction with the mining (or reclamation) . In consultation with the Office, the Applicant must demonstrate pursuant to Subsection 6 . 5(4), Geotechnical Stability Exhibit, that offsite areas will not be adversely affected by blasting . Varra Companies, Inc . Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1( 1). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215; Denver, Colorado; or on-line at http ://mining.state.co. us. There are no planned revisions to this Exhibit. Summary Status of Affected and Unaffected land as of this Amendment (Exhibit C- 1 : Existing Conditions and Exhibit C-2 : Extraction Plan Map) : Of the 128 . 18± Acres of lands comprising the parcel boundary, 25.31± acres of zoned commercial/industrial lands within the City of Greeley are not included in the permit boundary, resulting in total permit area of 102.87± acres remaining in the Weld County 1-3 Industrial Zone District. Of the 102.87± Acres to be permitted the nature of each aspect of the affected lands are as follows: 20.84± Acres of Planned Extraction -- Tract A 12.88± Acres of Planned Extraction — Tract B 29 . 31± Acres of Planned Extraction — Tract C 11 .99± Acres of Planned Extraction — Tract D 75.02± Acres of Planned Extraction — TOTAL Comprised of: 62.81± Acres - Completed basins (within Total Area of Extraction) — total area at anticipated static water level . Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan 12 .21 Acres - requiring resoling and revegetation between the anticipated static water level of the completed basins and the extraction limits And a remainder of: 27.85± Acres - previously affected lands remaining outside of the extraction limits, comprised of: 4.60± Acres - Internal Access Roads 1 . 23± Acres - disturbed by existing above ground oil and gas facilities 22.02± Acres outside area of extraction (extraction limits) requiring revegetation only . NOTE Well : All lands within the 102,87± acre permit area are to be considered as affected lands under C. R.S. 34-32 .5-103( 1) respective of this permit application and any subsequent permit revisions or amendments to the permit as originally approved . Exhibit C- 1 : Existing Conditions and Exhibit C-2: Extraction Plan Map, show the location, extent, and features described above; along with features made obvious in the included aerial image of the permit location and surrounding lands. The maps also show all man made structures located within 200 feet of the permit boundary (i .e. , affected lands); including creeks, roads, buildings, oil and gas wells and lines, and power and communication lines on and within 200 feet of the affected land; as well as all adjoining surface owners of record . A listing of the adjoining surface owner's names and addresses are listed under Exhibit C — Text, correlated with those shown in the aforementioned map. The site lies within the flood plain of the Cache La Poudre River to the north, and overlies bedrock that varies in depth from 20-25± feet along the southwest portion of Tract B, to increasing depths to the north and east averaging 35-40± feet and dropping to a potential depth of 70-80± feet along the Poudre River. Geological conditions are based in part from a Preliminary Feasibility Report for Aggregate Reserves at the Greeley Facility, as prepared by Applegate Group, Inc. in January 2005 for The Western Sugar Cooperative. Accordingly, test bores suggest a mean static ground water level of 8 .0± feet and generally variable from 5± to 13± feet or deeper from the surface. Alluvial groundwater is unconfined and flows east and `slightly toward' the Poudre River. As stated in the report, the underlying bedrock is likely to be a hard grey to sandy brown clay-stone or tightly cemented sandstone consistent with strata of the Laramie Formation or Pierre Shale which outcrop north and west of the site. Bedrock contour maps were utilized to approximate elevations resulting from extraction and corresponding basin depths as shown on the Extraction Plan and Reclamation Plan maps. A bedrock 'mound' is evident in the southwest portion of the map underlying the majority of the designated Tract B. Varra Companies, Inc. Permit M-2010-049 3 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan Method of mining is presently dry, with discharge of waters conducted under an approved Colorado Dept. of Health discharge permit. Extraction utilizes, but is not limited to, diverse heavy equipment; including, backhoes, scrapers, excavators, dozers and related heavy equipment. A grader and water truck maintain access throughout operations. Access is clearly indicated under Exhibit C- 1 : Existing Conditions and Exhibit C-2 : Extraction Plan Map. Primary access is approximately 657 .0± feet east of Ash Avenue behind a commercial- industrial lot owned and controlled by Varra Companies, Inc. The lot itself is flanked on its western boundary by Ash Avenue. Access from the permit boundary will be through the existing lot. The commercial industrial lot is surrounded by other industrial lands and uses when turning from that lot either north or south onto Ash Avenue itself. Wet and/or dry plant processing operations will occur near the eastern permit boundary on previously affected lands comprising the last area of extraction identified as Tract A on Exhibit C-2 : Extraction Plan Map. The specific plant operations will be clarified by a later Technical Revision to the Division, but are generally comprised of portable equipment. A small wash pond may be established within Tract A or an adjacent existing pit, or as otherwise identified in the correlated Technical Revision . Materials may be processed and scaled at the adjacent Durham Project until similar facilities are established within the approved permit boundary. Provisions for a materials processing plant, a concrete and/or asphalt batch plant, and periodic use of recycling facilities and related plant, remain a necessary inclusion to operations under this permit. Any material processing facilities, recycling facilities, recycling plant, or concrete and/or asphalt batch plant locations will be determined and identified in a later Technical Revision to the approved permit, and are mentioned for purposes of establishing these activities as approved uses under this submittal . Additionally, adjacent lands may have asphalt or concrete batch plant operations serviced by the permit, but will occur on adjacent lands under a separate approved municipal permit with the City of Greeley, and such operations and attending stockpiling or other surface disturbances or features should not be considered part of this permit or extraction activities requiring permitting under the Act. Known structures and landowners, including above and below ground utility owners, located on and within 200± ft. of the permit boundary are shown on Exhibit C- 1 : Existing Conditions and Exhibit C-2 : Extraction Plan Map. Exhibit S — provides certification from a registered professional engineer that these structures will not be harmed by planned operations; nor has any evidence of harm evidenced itself over the nearly 60± years of operations at the adjacent Durham Project. A 1600± linear foot standard morphing extraction front is comprised of a 1 . 25H : 1V face along an approximate 800- 1200± linear foot advancing; wall with trailing side slopes up Varra Companies, Inc. Permit M-2010-049 4 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan _ to 400 total linear feet combined along either side of the advancing wall where it serves to define the predetermined boundary of the extraction limits shown on Exhibit C-2 : Extraction Plan Map. Concurrent grading follows immediately behind the trailing side slopes as they occur along the extraction limits. This morphing extraction front, with its advancing wall, trailing side slopes, and concurrent reclamation along the extraction limits is approximate for all active Tracts. The 1600± linear foot total extraction front is 'morphing' in that the total linear feet of the front will not exceed 1600± linear feet, however, the advancing wall and side slopes may deviate from the 'standard' lengths described above. For example: If the advancing wall is only 600± linear feet, trailing side slopes may have a combined length pending finished grading of up to 1 ,000± linear feet. Another example is if the advancing wall is 1,400± linear feet long, there is only 200± linear feet of trailing wall, and operations must be more Johnny on the spot in keeping up with concurrency in this configuration. So the ` morphing of the front generally affects the pace of concurrent reclamation of the trailing wall . Extraction activities will continue to remove aggregate from approximately 15-25± feet along the southwest, to a mean depth of 35-40 . 0± feet at center, with a potential total depth to 70-80± feet along to the Cache La Poudre River. Since anomalous depths greater than 40± feet may occur, any extraction deeper than 40± feet in depth, may be extracted either dry, or wet. If extracted wet, a dredge may be utilized for the removal . Regardless, all final basin (pond) slopes will conform at a minimum to Rule 3 . 1 . 5(7). The general direction of extraction activities over the diverse Tracts is shown on Exhibit C-2 : Extraction Plan Map. Extraction will occur no closer than 10± feet from the permit boundary, man made structures, easements and right-of-ways; except for well heads and above ground oil and gas facilities. Extraction will occur to within 25± feet of well heads and related above ground facilities. Extraction around well heads will be concurrently backfilled to maintain a 100± foot buffer from the balance of extracted lands. At all times, safety will take precedent and over-ride all other conditions in time with a matter of safety or emergency respective to and all aspects of the approved permit. Tracts are used instead of Phases to describe the activities, since each Tract can be accessed concurrently instead of sequentially with the other; and per Exhibit L — Reclamation Costs, accelerated extraction only serves to decrease the overall reclamation liability and accelerate final reclamation and site stabilization of the property as a whole. Therefore, any method that accelerates the above timetable will be utilized, based upon market conditions and the capacities of the operator. Because the permit area is entirely affected and degraded from past uses, the method of extraction functions to effect reclamation first on the most disturbed portions of the parcel; essentially where soil is absent, hence reclaiming previously spoiled lands that Varga Companies, Inc. Permit M-2010-049 5 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit D- Extraction Plan might not otherwise be reclaimed. Essentially, since Tracts A and B are void of soil , Tract B will be extracted first while plant operations are established over Tract A. Extraction will then follow over Tracts C, D, and A. Simultaneous extraction with Tract B in other Tracts may occur by simply providing additional warranty for Standard Extraction Fronts, as previously described above and detailed under Exhibit L — Reclamation Costs. Set up of Plant operations and on-set of extraction activities in Tracts A and B, respectively, will better allow for the use of over the shoulder removal of soil from Tracts C and D to effect the reclamation of the designated affected lands in Tracts A and B. The timetable for extraction, commencing approximately fall to winter 2010; is estimated to take 20± years combined followed by an additional five years to complete reclamation; or a total estimated life of the mine of 25± years; ending approximately winter 2035-36. Varra Companies, Inc. Permit M-2010-049 6 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit E — Reclamation Plan 6.4.5 EXHIBIT E - Reclamation Plan ( 1 ) In preparing the Reclamation Plan , the Operator/Applicant should be specific in terms of addressing such items as final grading (including drainage) , seeding , fertilizing, revegetation (trees, shrubs, etc. ) , and topsoiling . Operators/Applicants are encouraged to allow flexibility in their plans by committing themselves to ranges of numbers (e.g. , 6"-12" of topsoil) rather than specific figures. (2) The Reclamation Plan shall include provisions for, or satisfactory explanation of, all general requirements for the type of reclamation proposed to be implemented by the Operator/Applicant. Reclamation shall be required on all the affected land . The Reclamation Plans shall include: (a) A description of the type(s) of reclamation the Operator/Applicant proposes to achieve in the reclamation of the affected land , why each was chosen, the amount of acreage accorded to each , and a general discussion of methods of reclamation as related to the mechanics of earthmoving ; (b) A comparison of the proposed post-mining land use to other land uses in the vicinity and to adopted state and local land use plans and programs. In those instances where the post-mining land use is for industrial, residential , or commercial purposes and such use is not reasonably assured , a plan for revegetation shall be submitted . Appropriate evidence supporting such reasonable assurance shall be submitted ; (c) A description of how the Reclamation Plan will be implemented to meet each applicable requirement of Section 3. 1 ; (d) Where applicable, plans for topsoil segregation, preservation , and replacement; for stabilization , compaction, and grading of spoil ; and for revegetation . The revegetation plan shall contain a list of the preferred species of grass, legumes, forbs, shrubs or trees to be planted , the method and rates of seeding and planting , the estimated availability of viable seeds in sufficient quantities of the species proposed to be used , and the proposed time of seeding and planting; (e) A plan or schedule indicating how and when reclamation will be implemented . Such plan or schedule shall not be tied to any specific date but shall be tied to implementation or completion of different stages of the mining operation as described in Subparagraph 6.4.4( 1 )(e). The plan or schedule shall include: (i) An estimate of the periods of time which will be required for the various stages or phases of reclamation; (ii) A description of the size and location of each area to be reclaimed during each phase; and (iii) An outline of the sequence in which each stage or phase of reclamation will be carried out. (The schedule need not be separate and distinct from the Reclamation Plan, but may be incorporated therein.) (f) A description of each of the following: Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit E -- Reclamation Plan (i) Final grading - specify maximum anticipated slope gradient or expected ranges thereof; (ii) Seeding - specify types, mixtures, quantities, and expected time(s) of seeding and planting ; (iii) Fertilization - if applicable, specify types , mixtures, quantities and time of application ; (iv) Revegetation - specify types of trees, shrubs, etc. , quantities, size and location; and (v) Topsoiling - specify anticipated minimum depth or range of depths for those areas where topsoil will be replaced . This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011, and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011, are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1( 1) . A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215; Denver, Colorado; or on-line at http:/mining .state.co. us. There are no planned revisions to this Exhibit. This application provides substantial detail of features utilizing aerial photography that is ortho-rectified to approximately 1 .0± percent of surveyed accuracy. This highly accurate and detailed portrayal of the mining and reclamation is visible under Exhibit C- 1 : Existing Conditions and Exhibit C-2 : Extraction Plan Map, and, Exhibit F — Reclamation Map . How reclamation will occur over affected lands is further detailed under Exhibit L — Reclamation Costs. As extraction progresses over planned areas in Tracts A, B, C and D; the resulting 1 .25H : 1V slopes created during extraction will be concurrently modified by pushing the resulting pit bottom with a dozer until the resulting basin slopes conform with Rule Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit E — Reclamation Plan 3 . 1 .5(7). Lands above the anticipated final water level of the basins and within 10 .0± feet below the anticipated final water level of the basins will be graded to 3H : 1V, or flatter. Lands below 10 .0± feet from the anticipated final water level of the basins may approach 2H : 1V. Naturally occurring or previously established slopes may exceed 2H : 1V where not otherwise affected by extraction activities and may not be altered as part of reclamation unless necessary to facilitate the reclamation of affected lands. A Backfill Notice is included with this application as an Addendum at the back of Exhibit E — Reclamation Plan, to facilitate the fill of portions of the extracted lands for final end- use potentials beyond water storage, which may include residential, commercial or industrial structures or uses otherwise approved, now or in the future, by Weld County, Colorado or any subsequent municipality resulting from annexation . The extent and nature of the water storage basin represents the maximum build-out respective of optimal extraction of commercial product and resulting final slopes. All affected lands between the extraction limits and remaining above the anticipated high water mark of the basins will be capped with a minimum of six (6.0±) inches of soil, as supported by Exhibit I & J — Soils and Vegetation Information. Timing and use of soil is detailed further under Exhibit I & J - Soils and Vegetation Information and Exhibit L — Reclamation Costs. Where compacted lands exist, and are to be revegetated, those locations will be ripped prior to re-soil application . There are no known areas of compaction at the time of this application which would require such activity; and ripping remains a contingency of the application . The final land configuration results in four reservoir basins totaling 62.81± surface acres (refer to Exhibit F : Reclamation Map). The balance of unoccupied affected lands above the anticipated static water level will be stabilized where necessary utilizing the seed mixture under Exhibit L - Table L- 1 : Primary/Preferred Re-vegetation Seed Mixture and Costs. Lands not otherwise occupied will be later developed to the highest possible end-use, and will likely comprise a mixed use which may include other agricultural uses as well as light residential, commercial or industrial uses. All affected lands remaining above the anticipated final water level of the basins, and not otherwise occupied by existing or planned mixed uses, will be re-vegetated with the approved seed mixture(s) for general agriculture. Since the existing pasture comprised predominantly of weeds is being replaced predominantly with native grasses, the target for release of revegetated lands is based upon the establishment of a stabilizing cover of predominantly native vegetation whose foliar umbrella equals or exceeds 20 percent of the total area of the ground as measured three inches above the native soil on a square meter basis for typical areas of reclaimed cover achieved within five years subsequent to the completion of all extraction activities. Mixed use(s), other than general agriculture will occur and may include, but are not limited to: the retention of existing structures as desired (e.g . , processing facilities and Varra Companies, Inc. Permit M-2010-049 3 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit E — Reclamation Plan plant(s), concrete batch plant, asphalt batch plants, recycling facilities and related operations, shop, scale-house/office, and supporting facilities (fuel depots, parking areas, oil and gas facilities access, etc. ) for continued industrial - commercial use (as validated by any co-related and required Weld County Building Permits); the creation of unforeseen future structures, and for the use and development of on-site water resources. Since the area of surrounding lands is a mix of these uses, the site end use will retain these potentials. The rate of reclamation activity, including grading, soiling and revegetation will follow concurrently with extraction and the respective timetables identified for extraction under Exhibit D — Extraction Plan. AU timetables are contingent upon market conditions, therefore, a probable range of time is indicated . With extraction activities anticipated to take up to 20 years to complete, reclamation will add an approximately five years to this estimate, bringing the anticipated life of the mine to 25± years, or the year 2035 . A Backfill Notice follows this page, as part of this Exhibit. The use of inert fill will facilitate the timely fill of selected portions of the project area as desired, and related reclamation of affected lands and use of related water resources (refer to Exhibit L — Reclamation Costs). Varra Companies, Inc. Permit M-2010-049 4 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit E — Reclamation Plan BACKFILL NOTICE Inert fill may be imported or utilized from existing sources, along with processing fines and reject material to fill portions of Tracts A, B, C, and D — the extent and location of which will be field determined during final reclamation in order to advance alternative end-use potentials for post extraction development. The estimated total volume of fill 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 of the project, estimated at 25± years. Material will be mixed with on-site processing fines and reject prior to fill to eliminate void spaces, where necessary. The filled portions of a given tract will be re-vegetated with the approved seed mix where it meets the conditions described under Exhibit E — 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. 1, Christopher L. Varra, hereby attest that the material to be utilized as inert fill in the area described as the Western Sugar Reclamation Land Development Project, is clean and inert as defined in Rule 1 . 1 (20) of the Rules and Regulations. Christopher L. Varra, President Varra Companies, Inc. Varra Companies, Inc. Permit M-2010-049 5 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit F — Reclamation Plan Map This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Refer to the Exhibit F : Reclamation Plan Map, for information required under this exhibit. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G — Water Information 6.4.7 EXHIBIT G - Water Information ( 1 ) If the operation is not expected to directly affect surface or groundwater systems, a statement of that expectation shall be submitted. (2) If the operation is expected to directly affect surface or groundwater systems, the Operator/Applicant shall: (a) Locate on the map (in Exhibit C) tributary water courses, wells, springs, stock water ponds, reservoirs, and ditches on the affected land and on adjacent lands where such structures may be affected by the proposed mining operations; (b) Identify all known aquifers; and (c) Submit a brief statement or plan showing how water from de-watering operations or from runoff from disturbed areas, piled material and operating surfaces will be managed to protect against pollution of either surface or groundwater (and, where applicable, control pollution in a manner that is consistent with water quality discharge permits), both during and after the operation . (3) The Operator/Applicant shall provide an estimate of the project water requirements including flow rates and annual volumes for the development, mining and reclamation phases of the project. (4) The Operator/Applicant shall indicate the projected amount from each of the sources of water to supply the project water requirements for the mining operation and reclamation. (5) The Operator/Applicant shall affirmatively state that the Operator/Applicant has acquired (or has applied for) a National Pollutant Discharge Elimination System (NPDES) permit from the Water Quality Control Division at the Colorado Department of Health, if necessary. This Amendment is intended to satisfy the option of lining approved basins. The basins identified in the original Office of Mined Land Reclamation (OMLR) permit are presently approved and bonded for both the lined and unlined state. The permit provides for the option that the basins be lined in order to liberate the waters presently securing the exposed groundwater in the unlined condition. The previous effort to detail the methodology and procedures to line the basins with the approved change in the original permit via a technical revision were later rejected defacto by the Office of Mined Land Reclamation (OMLR), and an Amendment to assure notification of adjacent landowners was mandated instead . This submittal is intended to satisfy that mandate to assure the assure the OMLR that lined basins will comply with state law. To satisfy the concerns of the OMLR, included with this revision is a report on the potential for shadowing and mounding by AWES, LLC of 27 June 2013 . The report concludes : Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G — Water Information '. . .that lining mined gravel pits has almost unmeasurable influences to the surrounding groundwater hydrology and does not change hydraulic gradients beyond the variations that would normally be expected in the geologic settings associated with the operation.` We anticipate the OMLR will concur with this analysis. Once operations near completion of any lined basin, the Colorado Department of Water Resources Office of the State Engineer (OSE) will be contacted and the lined basins will be approved prior to use. The OSE approval letter will be provided to the OMLR as a condition of the permit and satisfaction that the lined basin has met the specifications necessary to pass a liner test as part of the OSE approval process. (1 ) Operations will not adversely affect surface and groundwater systems. The manner and method of extraction is detailed under Exhibit D — Extraction Plan . Anticipated effects on surface flows are anticipated to be minor to none. Essentially, the flood plain covers the property and unless under flood conditions, upland overland flows are generally diverted by existing access roads or grassed drainage channels, or drain internally into existing or planned basins. (2) (a) Please refer to Exhibit C- 1 : Existing Conditions Map. (b) The known aquifer under the site is the stream alluvium . (c) Discharge water will be dissipated with hard surface riprap or established grassed waterways. Other waters are retained by internal pit drainage, directed by vegetated berms or established waterways or through the maintenance or establishment of a stabilizing cover of vegetation, or as otherwise established under an approved Colorado Department of Health stormwater permit and/or stormwater discharge permit. (3) The three components of the project water requirements are water removed with the product, dust control, and evaporation from exposed ground water. Dust will be controlled using truck sprinklers, and the estimated frequency is one load per day. At 2,500 gallons of truck capacity, the annual demand is 2 .80 acre-feet. After the water table is encountered, the water removed with the estimated 800,000 tons of product is 23. 55 acre-feet per year. The estimated net evaporation is 1 .419 feet per year. At the maximum potentially exposed ground water of 62 .81 acres, the annual evaporation is 89. 13 acre-feet. The monthly distribution of these estimates is shown in the following table. The reclamation plan provides that the pits will be lined after being mined . The lined pits will not require replacement water and will be used for storage. There may be incidental demand for water to establish vegetation on the site after lining is completed. However, the ultimate demand for water will be zero. Van-a Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G -- Water Information MONTH PRODUCT DUST NET EVAP USE CONTROL Tons af Trucks af ac af af November 40,000 1 . 18 3 0.23 62.81 5.78 7. 19 December 40,000 1 . 18 31 0.24 62.81 4.97 6.39 January 40,000 1 . 18 31 0.24 62.81 4.78 6.20 February 36,000 1 .06 28 0.21 62.81 6.36 7.63 March 40,000 1 . 18 31 0.24 62.81 7.95 9.37 April 80,000 2.35 30 0.23 62.81 9.69 12.27 May 85,000 2.50 31 0.24 62.81 10.49 13 .23 June 92,000 2.71 30 0.23 62.81 10.77 13 .71 July 93,000 2.74 31 0.24 62.81 8.36 11 .34 August 90,000 2.65 31 0.24 62.81 7.67 10.56 September 85,000 2.50 30 0.23 62.81 6.61 9.34 October 79,000 2.33 31 0.24 62.81 5.70 8.27 Apr-Octj 604,000 17.781 214{ 1 .65 59.29 78.72 TOTAL 800,000 23.561 3651 2.81 89. 13 115.50 (4) Water will be supplied by two sources: shares of the Rural Ditch Company and water decreed in Case No. 01CW274. VCI owns four shares of Rural Ditch Company. From April through October, water use at the site will be replaced to the stream system using the historical consumptive use credits from any of the sources and/or from storage. The monthly distribution of the historical consumptive use is shown in the following table : HISTORICAL CONSUMPTIVE USE All Values in Acre-Feet APR MAY JUN JUL AUG SEP OCT ANN Rural 5.4 23.3 54. 1, 84.3 61 .81 27. 1 9.5 265. 5 Water in excess of this mine's and other VCI obligations will be stored and used to replace the water use from November through March. The storage sites are lined pits described in Case No. 01CW274 decree. Water available under these storage decrees will also be stored and used for VCI operations. The storage facilities are listed in the following table. Those currently lined and approved by the state are 112 and Dakolios. Varra Companies, Inc. Permit M-2010-049 3 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G — Water Information VCI STORAGE FACILITIES (All Values in Acre-Feet) Reservoir Active Capacity, a-f Dead Storage, a-f 112 1,552 0 Dakolios 1,900 0 Von Ohlen 1 ,300 0 Kurtz 4,000 0 Total NOT TO EXCEED 0 7,500 A-F PER YEAR • S i (5) A Colorado Wastewater Discharge Permit System Permit has been applied for with the Colorado Department of Health . Varra Companies, Inc. Permit M-2010-049 4 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 a a1 M % AWES, L LC 7 11 r .414 Fort Collins, Colorado, USA June 27, 2013 Varra Companies 8120 Gage Street Frederick, Colorado 80516 Attn: Mr. Garrett Varra RE : Shadow/Mounding Analysis AWES No. 1-3-1320 Dear Mr. Varra: You have requested that I provide an opinion on possible effects that lining excavated gravel mines can have on local groundwater hydrology - specifically shadow and mounding effects created by the presence of a low permeability barrier. My opinion is that lining active or inactive gravel mines will deflect groundwater around the barrier, but hydraulic gradients changes at any distance away from the barrier will be insignificant. My rational for this opinion is provided below. Varra Companies, Inc., (Varra) has two lined pits used for water storage that were lined in 2003 (Pit 112) and 2010 (Pit 110). The method of lining was compacting several feet of clay and shale bedrock on the side walls of the pits, thus creating a low permeability liner. Varra installed 13 monitoring wells at each of these locations and obtained water levels on a periodic basis. Pit 110 consists of two lined pits and Pit 112 is a single pit. The locations of these pits are depicted on Figure 1. The monitoring well locations are depicted on Plates 1 through 4, which are included in Attachments A and B. In order to evaluate the effects of low permeability liners on the local groundwater hydrology, I used the geo-statistical model Surfer® to evaluate groundwater flow direction and gradients in the vicinity of the pits. I input water level data obtained from the monitoring wells for the months of January and July 2012, at each location. I chose these months to evaluate possible changes that might occur from irrigation returns in the vicinity of the pits. After the model runs were competed, I used a vector analysis to depict variation in gradient and flow direction. Model runs for Pits 112 and 110 are presented in Attachments A and B, respectively. A review of both Attachments show that groundwater is being deflected around the pits, but the changes in gradients are so minor the model also predicts that groundwater will flow through the pits as well — this indicates the liners are competent and that there is little to no hydraulic connection between the aquifer and pond. For graphical purposes, 1 superimposed red lines that represent the primary groundwater flow patterns in the vicinity of the pits. The vector analysis shows very minor changes in hydraulic gradients up and down stream of the pits indicating shadow and mounding are not occurring. AISAWIES 4809 Four Star Court, Fort Collins, CO 80524 970-590-3807 Shadow/Mounding Analysis Varra Gravel Operations Longmont, Colorado Page 2 In July of 2010, I provided Varra with the results of a groundwater model simulation of an impermeable barrier in a uniform flow field. The model results closely approximate actual field conditions as documented from water level data obtained by Varra . That analysis is presented in Attachment C. This analysis indicates that lining mined gravel pits has almost unmeasurable influences to the surrounding groundwater hydrology and does not change hydraulic gradients beyond the variations that would normally be expected in the geologic settings associated with your operations. It is my understanding the Division of Reclamation and Mine Safety has requested technical revisions to your mine permits for the placement of liners at active operations such as Great Western Sugar. Until the pits are completely lined and dewatering is no longer occurring a static analysis cannot be performed, however, the analysis presented should be valid for mines in similar geologic settings. If you have any questions regarding this letter or attachment, please contact me at 970-590-3807. Sincerely, AWES, LLC cz3;1---) Afola Joby L. Adams, P.G. Principal Hydrogeologist sto.AIVES 4809 Four Star Court, Fort Collins, CO 80524 970-590-3807 • A .III% feel . , , • + I J rd�i•�w '4 7- 41%1k ' -4. .a 911' , Cr• i 1 / .,r Jto 0 II 1 44 I400 r -a. Int Wit. I f _ • I i 1 I '~ • j 0 \\I . ` '� �• 1 • • t i i�. 1 ' A y O a. ii, r ++� .. t a _ • fir - - - • t. in ' ' . _ •,� r 1 . Ill Qs -• i> 144 . , • i . . • % • I, •• . . • •• I ' eft a I ! erj) • ' ,•.. .0 IC .... • D . , 4, . . ,.. . . . 1 _, . ,,, , .. .. t ' . • • f A tai . - : 1 II' . 7 ' i . ... , - pp to3 o pr.) goose - .ti fa jrzi.• I A , • i • . . t • • i.i1Q- el alpi „ t.,-; a Ili II( .1. i \ i Illi, . - Nbri...:eirs ,,• r.... . . ts-- , ..11M ... . H • %- -allir0:::.‘ _ ; F 'itIf olaNIP 4 1.0 - -1 . 4 */ • :, • k 1 li • I 1 • .0' Jig i k �. , -. • .� t I 4 ,. - • -. - ' I -0 r ._ -r- -I -- 4 >_veiri-- ' , • ii-g4 „. Ai , . \ 4 . i 4 is 4# (i) WM:Fr1141 _ _ L \ t .. - . : . - . -I • /. 111:cp,4%*„.• • _ )1411/4 I • / ., IIb+So ID T IN- 1,. r _ '..a.: 174i • - I, „We - Cettiviti ei e.,1pp _ . a err _ / 41 4444..44.4....ammtm(\ 1. . A 1 .. St. Sl• • l _ ..P' • I . ilikilL' 14- \ • • Illillialit - ; it I , 4 � .1. I ` cr) ild r. 1 ATTACHMENT A PIT 112 VECTOR ANALYSIS to is) U) U) 10 is) = O o o • 0 0 CO CO N N 0 0 0 O d c5 co O O o c5 o O o O i t ..i.. c 111111. 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CI- N 0.1 a-+ CO a ATTACHMENT B PIT 110 VECTOR ANALYSIS Plate 3 - Pit 110 Vector Analysis L. 3000 ,4 V t ,- ) Pit0•f! , _ GMIM•.009 0 ?Or PI -.A27 f wra +a O psi • N — --,-__.. - T� of .D00 7 0.02201 • '< 04 �,� ' `°'° • 0.02101 0.02001 2500 qiP a,w J • i 'I 1, �� �,�,■.,,,� l ., .7 0.01901 ® OO :it-s: I. 0.01801 t•. ,.6 �o • 0.01701 0.01601 2000 \ 1 ; l 0.01501 P1 0•f: �1 , , , n°' .,;, .:� � ♦ 1. I 0.01401 � 0.01301 � � 0.01201 • +�i� �f1• n �no-fo --•• 0.01101 *itel2.1 011001.0•4010. for 1410t 44047 e ' (,. - . -- 0.01 001 1500 "��..f..,.: -- , f 0.00901 PrFc 0.00801 1 t cc, cJ i 0.00701 — II s 0.00601 �?p I �f O 0.00501 1000 °"°-s S 1.11al3 : - Yx 0 PM ' 0.00401 ,� I 0.00301 c.-)� ! 0.00201 0.00101 1 I Y 500 ! , K .~ �� Gradient ft/ft P 4 �'. its riYF•M?O.ea A \_)fr algi0 0 500 1000 1500 200O 2500 3000 Note - Contour Interval = 1 foot Jan 2012 Water Level Data Plate 4 - Pit 110 Vector Analysis / 3000 F , / >< Pt •P'3 211 t w•.. \\-* 0.023 _ �� 0.022 r r•:> , '' Ca_ --7:----,1 __.s__ 0.021 4 ' � 1 ntto•rl 2500 I "'� NI- � �o° '° ..1> > Q ° c 0.02 �' r�. '''��� • d' 0.019 t • • I. 0.018 ni ‘1 lint" e, — 0.017 luny •4,4 , Wal&Allir - vneteS7 { ��l't% it1tii t0.016 lt 2000 0,10-,: W***.".11141,1 0.015 c.Kuhc. 1t �t`� v� 0.014 ...►tacit I . 0.013 Hp PM 48 0.012 - : � •..� �8 � 0.011 so „ •u•a, awlI,v.1 Saotil �_ - 0.009 SIIIIIipseet;7:na‘s ' Y '„ '4 \ 0.008 't 1 / 111111111. .. 0.007 ` • - 0.006 1000 Flit= 1\ Y 0.005 .. .. � 0.004 ron rrr'E.,oza 0.003 " ► 0.002 ii IV " _ 0.001 500 I br��� ,I q t" `= ",..eA st Gradient ft/ft lak. .ate . 4, ,... .tivaiii- KIP Pm sena tit - • • Y1 0 0 500 1000 1500 2000 2500 3000 Note - Contour Interval = 0. 75 foot Jly 2012 Water Level Data ATTACHMENT C Groundwater Model Analysis July 1 , 2010 Mr. Garrett Varra Varra Companies, Inc. 8120 Gage Street Frederick, Colorado 80203 Re: Water Impoundment Hydrology CGRS No. 1 -135-10807ab Dear Garrett: This letter and attachments address comments presented by Colorado Division of Reclamation, Mining and Safety regarding mounding and shadowing related to water impoundments. Any impoundment or pond that holds water at an elevation above the surrounding water table will have the potential of increasing the water table elevation (mounding) at some distance from the pond, which is determined by the total groundwater-pond head difference. For ponds that are large in areal extent the distance to no influence on the upstream side is usually less than the downstream side as the head difference will be less based on the water table's hydraulic gradient. The influence imposed by the pond can be estimated by one dimensional unconfined flow solutions presented by McWhorter and Sunada, 1977. Numerical models can be used but we have found model results generally agree well with analytical solutions. An example calculation using a one dimensional unconfined flow equation is presented as Attachment A. In most unconfined flow regimes we consider the distance to no influence (or measurable influence) generally to be on the order of 600 feet. For your operations it appears the pond and groundwater head difference is on the order of five feet. Given this scenario at 100 and 300 feet from the pond the resulting mounding would be four and two feet, respectively. We advise that great care be given when constructing water impoundments (lined or unlined) within 100 feet of any subsurface structures. We have evaluated the affects of impermeable barriers on groundwater hydrology by using the analytical model TWODAN. We simulated a uniform flow field using aquifer properties typically associated with sand and gravel deposits. We then simulated an impermeable barrier within the flow field . The results indicate that the groundwater hydrology is modified but only severely in very close proximity to the barrier. Upstream of the barrier the hydraulic gradient will increase and will decrease downstream of the barrier. Hydraulic gradient changes of between one and two feet are observed within 15 feet of the barrier wall but are negligible at any significant distance from the hydraulic structure. A P.O Box 1489 Fort Collins, CO 80522 1 800 -288-2657 F 970 .493 . 7986 www .cgrs.corn IT you nave any questions regarding this letter, please contact me at 970-493- 7780 . Sincerely, CGRS, Inc. Johy L. Adams. P. G. Principal/Hydrogeologist vvater Kesource ruoucations, Littleton, Voioraao, pp 14b-14ö. ATTACHMENT A UNCONFINED FLOW ANALYSIS JprCdubr 'eel '. aruUrale' 'Jrre uiirrerisiurrar rleau ul5[riouUon kunconiinea) h = )hi2 + X1. (H2 - hi`) H Head at no influence (ft) 4808 h Head at point of interest (calculated) LAMA hi Head at retention pond 4$13 X Distance from pond to point of interest (ft) 300 L Distanct to no influence (ft) 600 ATTACHMENT B BARRIER WALL MODEL RESULTS U - 86 ! _ _ 1 \ - 4 8 88 __ - - - - - - - — 90 1 i 4) 88 \92 - Li - - - -- - — - -- - 1 J. _ _ li 92 lis, L gQ, A 6 j___+e__196 98 9 ) 100 -1f -- - - - Approximate Gradient Line in Uniform Flow X span: 0 to 800 Y span: 0 to 800 Impermeable Barrier Solution Varra Companies Exhibit H — Wildlife Information 6.4.8 EXHIBIT H - Wildlife Information ( 1 ) In developing the wildlife information, the Operator/Applicant may wish to contact the local wildlife conservation officer. The Operator/Applicant shall include in this Exhibit, a description of the game and non-game resources on and in the vicinity of the application area, including: (a) a description of the significant wildlife resources on the affected land; (b) seasonal use of the area; (c) the presence and estimated population of threatened or endangered species from either federal or state lists; and (d) a description of the general effect during and after the proposed operation on the existing wildlife of the area, including but not limited to temporary and permanent loss of food and habitat, interference with migratory routes, and the general effect on the wildlife from increased human activity, including noise. (2) The application may be reviewed and commented upon by the State of Colorado Division of Wildlife (DOW). If the DOW has comments, they must be provided prior to the end of the public comment period specified in Subsection 1 .7. 1 (2)(a) to be considered by the Board and Office. This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit I & J — Soils & Vegetation Information 6.4.9 EXHIBIT I - Soils Information ( 1 ) In consultation with the Soil Conservation Service or other qualified person , the Operator/Applicant shall indicate on a map (in Exhibit C) or by a statement, the general type, thickness and distribution of soil over the affected land . Such description will address suitability of topsoil (or other material) for establishment and maintenance ofplant growth. The above information shall satisfy "completeness" requirements for purposes of determination of date of filing. (2) If necessary, at its discretion, the Board may require additional information on soils or other growth media to be stockpiled and used in revegetation to be submitted subsequent to the filing and notification of "completeness" of the application. 6.4.10 EXHIBIT J - Vegetation Information (1 ) The Operator/Applicant shall include in this Exhibit a narrative of the following items: (a) descriptions of present vegetation types, which include quantitative estimates of cover and height for the principal species in each life-form represented (i.e. , trees, tall shrubs, low shrubs, grasses, forbs); (b) the relationship of present vegetation types to soil types, or alternatively, the information may be presented on a map; and (c) estimates of average annual production for hay meadows and croplands, and carrying capacity for range lands on or in the vicinity of the affected land, if the choice of reclamation is for range or agriculture. (2) The Operator/Applicant shall show the relation of the types of vegetation to existing topography on a map in Exhibit C. In providing such information, the Operator/Applicant may want to contact the local Soil Conservation District. This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit I & J — Soils & Vegetation Information shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10 . 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varna Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit K - Climate 6.4.11 EXHIBIT K — Climate Provide a description of the significant climatological factors for the locality. This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit L — Reclamation Costs 6.4.12 EXHIBIT L - Reclamation Costs ( 1 ) All information necessary to calculate the costs of reclamation must be submitted and broken down into the various major phases of reclamation . The information provided by the Operator/Applicant must be sufficient to calculate the cost of reclamation that would be incurred by the state. (2) The Office may request the Operator/Applicant to provide additional, reasonable data to substantiate said Operator/Applicant's estimate of the cost of reclamation for all Affected Lands. SUMMARY OVERVIEW: Summary Status of Affected and Unaffected land as of this Amendment (Exhibit C-1 : Existing Conditions and Exhibit C-2 : Extraction Plan Map) : Of the 128 . 18± Acres of lands comprising the parcel boundary, 25 .31± acres of zoned commercial/industrial lands within the City of Greeley are not included in the permit boundary, resulting in total permit area of 102 .87± acres remaining in the Weld County 1-3 Industrial Zone District. Of the 102.87± Acres to be permitted the nature of each aspect of the affected lands are as follows: 20.84± Acres of Planned Extraction — Tract A 12 .88± Acres of Planned Extraction — Tract B 29.31 ± Acres of Planned Extraction — Tract C 11 .99± Acres of Planned Extraction — Tract D 75.02± Acres of Planned Extraction — TOTAL Comprised of: 62.81 ± Acres - Completed basins (within Total Area of Extraction) - total area at anticipated static water level. 12.21 Acres - requiting resoiling and revegetation between the anticipated static water level of the completed basins and the extraction limits And a remainder of: 27.85± Acres - previously affected lands remaining outside of the extraction limits, comprised of: 4.60± Acres - Internal Access Roads 1 .23± Acres — disturbed by existing above ground oil and gas facilities 22 .02± Acres outside area of extraction (extraction limits) requiting revegetation only . NOTE Well : All lands within the 102 .87± acre permit area are to be considered as affected lands under C.R.S. 34-32. 5- 103( 1) respective of this permit application and any subsequent permit revisions or amendments to the permit as originally approved . Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit L — Reclamation Costs This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of. Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 21. 5 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit M — Other Permits & Licenses 6.4. 13 EXHIBIT M - Other Permits and Licenses A statement identifying which of the following permits, licenses and approvals the Operator/Applicant holds or will be seeking in order to conduct the proposed mining and reclamation operations: effluent discharge permits, air quality emissions permits, radioactive source material licenses, the State Historic Preservation Office clearance, disposal of dredge and fill material (404) permits, permit to construct a dam , well permits, explosives permits, highway access permits, U. S. Forest Service permits, Bureau of Land Management permits, county zoning and land use permits, and city zoning and land use permits. • Colorado Department of Health Storm Water Permit Permit # COG-501526. • Colorado Department of Health Emission Permit Pending Operations — Concrete Batch Plant. • Colorado Department of Health Emission Permit see Fugitive Dust Permit, below — Portable Equipment — Dry Plant • Colorado Department of Health Emission Permit Pending Operations — Wet Plant • Colorado Department of Health Emission Permit Permit # 06WE0781F — Fugitive Dust — Mining Operations and related activities. • Weld County Special Use Permit USR 1760 Approved 27 July 2011 . • Colorado Division of Water Resources Well Permit #75865F . • State Historic Preservation Office clearance Refer to correspondence of 15 March 2010 . • U.S. Department of the Army Corps of Engineers Cleared — Refer to Correspondence of 15 January 2010 . • Planned operations will not utilize or encounter materials, sources, or authorities over related lands and do not require permits for the following : radioactive source materials, construction of a dam, explosives, highway access, U.S. Forest Service, Bureau of Land Management, city zoning or land use. • Note: Any necessary permits for other planned or potential activities, including asphalt batch plants, recycling facilities and operations, etc. , will be acquired prior to on-set of such plants, facilities or operations. All future permits will be submitted to the Division to update this list as necessary. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit N — Source of Legal Right to Enter 6.4.14 EXHIBIT N - Source of Legal Right to Enter The source of the Operator's/Applicant's legal right to enter and initiate a mining operation on the affected land. (Same requirements as Rule 6. 3.7). This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit O — Owner(s) of Record of Affected Land (Surface Area) and Owner(s) of Substance to be Mined 6.4.15 EXHIBIT O - Owner(s) of Record of Affected Land (Surface Area) and Owners of Substance to be Mined The complete list of all owners can be submitted as a list or on a map in Exhibit C . Varra Companies, Inc. 8120 Gage Street Frederick, CO 80516 Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit P -- Municipalities Within Two Miles 6.4.16 EXHIBIT P - Municipalities Within Two Miles A list of any municipality(s) within two miles of the proposed mining operation and address of the general office of each municipality. City of Greeley 1000 Tenth Street Greeley, CO 80631 City of Evans 1100 Thirty-seventh Street Evans, CO 80620-2036 Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit Q — Proof of Amending Materials in previous Notice to the Board of Supervisors — West Greeley Soil Conservation District West Greeley Soil Conservation District Board of Supervisors ATTN: Joyce Wallace, District Manager 4302 West 9" Street Road Greeley, Colorado 80631 Subject: Colorado Division of Reclamation Mining and Safety (DRMS), Office of Mined Land Reclamation (OMLR), Permit M-2010-049 Amendment application for Varra Companies, Inc. — Western Sugar Reclamation Land Development Project. NOTICE TO THE BOARD OF SUPERVISORS WEST GREELEY SOIL CONSERVATION DISTRICT Varra Companies, Inc. (the `Applicant/Operator') has applied for an Amendment to its Regular (112) reclamation permit M-2010-049 from the Colorado Mined Land Reclamation Board (the `Board') to conduct the extraction of construction materials operations in Weld County. The attached information, including the 112 Permit Amendment form and Exhibit B — Index Map, is being provided to notify you of the location and nature of the proposed operation. A copy of Exhibit G — Water Resources Information, contains information pertinent to the purposes of the Amendment. The entire application is on file with the Division of Reclamation, Mining, and Safety (the `Division') and the Weld County Clerk to the Board. The applicant/operator proposes to reclaim the affected land to Developed Water Resources and other mixed uses. Pursuant to Section 34-32.5-116(4)(m), C.R.S., the Board may confer with the local Conservation Districts before approving of the post-mining land use. Accordingly, the Board would appreciate your comments on the proposed operation. Please note that, in order to preserve your right to a hearing before the Board on this application, you must submit written comments on the application within twenty (20) days of the date of last publication of notice pursuant to Section 34-32.5- 112(10), C.R.S. If you would like to discuss the proposed post-mining land use, or any other issue regarding this application, please contact the Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, Colorado 80203, (303) 866-3567. Your signature below acknowledges receipt of the above referenced permit application form. 07d / C Date Received: ,A9St ' ‘/.9U/4141° Oa/ . (epataltittyLdeak Received By: Office of Board of Supervisors -- West Greeley Soil Conservation District. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit Q — Proof of Amending Materials in previous Notice to the Board of County Commissioners Office of the Board of Weld County Commissioners RECEIVED c/o Weld County Clerk to the Board 1150 O Street -- Administration Bldg. P.O. Box 758 WELDGreeley, Colorado 80632 OMMI SIONEPF y COMMISS Subject: Colorado Division of Reclamation Mining and Safety (DRMS) Office of Mined Land Reclamation (OMLR Permit M-2010-049 Amendment application for Varra Companies, Inc. — Western Sugar Reclamation Land Development Project. NOTICE TO THE BOARD of WELD COUNTY COMMISSIONERS Varra Companies, Inc. (the `Applicant/Operator') has applied for an Amendment to its Regular (112) reclamation permit M-2010-049 from the Colorado Mined Land Reclamation Board (the `Board') to conduct the extraction of construction materials operations in Weld County. The attached information, including the 112 Permit Amendment form and Exhibit B — Index Map, is being provided to notify you of the location and nature of the proposed operation. A copy of Exhibit G — Water Resources Information, contains information pertinent to the purposes of the Amendment. The entire application is on file with the Division of Reclamation, Mining, and Safety (the `Division') and the Weld County Clerk to the Board. The applicant/operator proposes to reclaim the affected land to Developed Water Resources and other mixed uses. Pursuant to Section 34-32.5- 116(4)(m), C.R.S., the Board may confer with the local Conservation Districts before approving of the post-mining land use. Accordingly, the Board would appreciate your comments on the proposed operation. Please note that, in order to preserve your right to a hearing before the Board on this application, you must submit written comments on the application within twenty (20) days of the date of last publication of notice pursuant to Section 34-32.5-112(10), C.R.S. If you would like to discuss the proposed post-mining land use, or any other issue regarding this application, please contact the Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, Colorado 80203, (303) 866-3567. Your signature below acknowledges receipt of the above referenced permit application form. Date Received: la _Q2 Received By: 61 0 Weld County Clerk to the Board of W ld County Commissioners Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit R — Proof of Filing with County Clerk and Recorder 6.4. 18 EXHIBIT R - Proof of Filing with County Clerk and Recorder An affidavit or receipt indicating the date on which the application was placed with the local County Clerk and Recorder for public review, pursuant to Subparagraph 1 .6 .2( 1 )(c). Proof of filing with the County Clerk, pursuant to Subparagraph 1 . 6. 2( 1)(c) : Weld County Clerk to the Board 915 10th Street, 3rd Floor Greeley, Colorado 80632 Subject: Colorado Division of Reclamation Mining and Safety (DRMS), Office of Mined Land Reclamation (OMLR) Permit M-2010-049 Amendment application for Varra Companies, Inc. — Western Sugar Reclamation Land Development Project. Your signature below acknowledges receipt of the above referenced permit application . The application will be placed for public inspection and review. The information will be made available to the public until final agency action by the OMLR Board, as defined by C. R.S. 24-4- 105( 14) . Date Received : Received By : Office of Weld County Clerk to the Board Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit S -- Geotechnical Stability 6.4. 19 EXHIBIT S - Permanent Man-made Structures 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 be 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. 6.5 GEOTECHNICAL STABILITY EXHIBIT 1 ) On a site-specific basis, an Applicant shall be required to provide a geotechnical evaluation of all geologic hazards that have the potential to affect any proposed impoundment, slope, embankment, highwall, or waste pile within the affected area . The Applicant may also be required to provide a geotechnical evaluation of all geologic hazards, within or in the vicinity of the affected lands, that may be de-stabilized or exacerbated by mining or reclamation activities. (2) On a site-specific basis, an Applicant shall be required to provide engineering stability analyses for proposed final reclaimed slopes, highwalls , waste piles and embankments. An Applicant may also be required to provide engineering stability analyses for certain slopes configuration as they will occur during operations, including , but not limited to embankments. Information for slope stability analyses may include, but would not be limited to, slope angles and configurations, compaction and density, physical characteristics of earthen materials, pore pressure information , slope height, post-placement use of site, and information on structures or facilities that could be adversely affected by slope failure. (3) Where there is the potential for off-site impacts due to failure of any geologic structure or constructed earthen facility, which may be caused by mining or reclamation activities, the Applicant shall demonstrate through appropriate geotechnical and stability analyses that off-site areas will be protected with appropriate factors of safety incorporated into the analysis. The minimum acceptable safety factors will be subject to approval by the Office, on a case by- case basis, depending upon the degree of certainty of soil or rock strength determinations utilized in the stability analysis, depending upon the consequences associated with a potential failure, and depending upon the potential for seismic activity at each site. Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit S — Geotechnical Stability (4) At sites where blasting is part of the proposed mining or reclamation plan, the Applicant shall demonstrate through appropriate blasting, vibration, geotechnical, and structural engineering analyses, that off-site areas will not be adversely affected by blasting. This Amendment provides construction details for the option of lining completed basins, as described under Exhibit G of this Amendment. These or any other changes to the existing approved permit or related exhibits and correlated documents are either referenced or otherwise identified in green ink only. All reclamation under this Amendment will remain consistent with the original permit, including Developed Water Resources as the primary end use as reflected in correspondence of 13 April 2011 as received by OMLR on 15 April 2011 , and included in the permit as originally approved on 7 July 2011 . All other aspects of the original permit, or prior Technical Revision or Amendment to the original application as approved by the Office of Mined Land Reclamation on 7 July 2011 , are retained under this Amendment. Any exhibit language not shown in green is extracted from the original permit submittal and may appear below for reference and orientation only, consistent with Rule 1 . 10. 1 ( 1 ). A complete copy of the original approved permit, correlated documents, revisions, and amendments can be viewed directly at the Colorado Division of Reclamation Mining & Safety, Office of Mined Land Reclamation, located at 1313 Sherman Street, Room 215 ; Denver, Colorado; or on-line at http://mining.state.co.us. There are no planned revisions to this Exhibit. Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit Q — Proof of Amending Materials in previous Notice to the Board of County Commissioners Office of the Board of Weld County Commissioners c/o Weld County Clerk to the Board 1150 O Street — Administration Bldg. P.O. Box 758 Greeley, Colorado 80632 Subject: Colorado Division of Reclamation Mining and Safety (DRMS) Office of Mined Land Reclamation (OMLR Permit M-2010-049 Amendment application for Varra Companies, Inc. - Western Sugar Reclamation Land Development Project. NOTICE TO THE BOARD of WELD COUNTY COMMISSIONERS Varra Companies, Inc. (the `Applicant/Operator') has applied for an Amendment to its Regular (112) reclamation permit M-2010-049 from the Colorado Mined Land Reclamation Board (the `Board') to conduct the extraction of construction materials operations in Weld County. The attached information, including the 112 Permit Amendment form and Exhibit B — Index Map, is being provided to notify you of the location and nature of the proposed operation. A copy of Exhibit G — Water Resources Information, contains information pertinent to the purposes of the Amendment. The entire application is on file with the Division of Reclamation, Mining, and Safety (the `Division') and the Weld County Clerk to the Board. The applicant/operator proposes to reclaim the affected land to Developed Water Resources and other mixed uses. Pursuant to Section 34-32.5- 116(4)(m), C.R.S., the Board may confer with the local Conservation Districts before approving of the post-mining land use. Accordingly, the Board would appreciate your comments on the proposed operation. Please note that, in order to preserve your right to a hearing before the Board on this application, you must submit written comments on the application within twenty (20) days of the date of last publication of notice pursuant to Section 34-32.5- 112( 10), C.R.S. If you would like to discuss the proposed post-mining land use, or any other issue regarding this application, please contact the Division of Reclamation, Mining, and Safety, 1313 Sherman Street, Room 215, Denver, Colorado 80203, (303) 866-3567. Your signature below acknowledges receipt of the above referenced permit application form. Date Received: Received By: Weld County Clerk to the Board of Weld County Commissioners Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman SL, Room 215 COLORADO Denver, Colorado 80203 Phone: (303) 866-3567 CONSTRUCTION MATERIALS DIVISION OF RECLAMATION FAX: (303) 832-8106 REGULAR (112) OPERATION MINING G RECLAMATION PERMIT APPLICATION FORM — &-- SAFETY Bill Ritter, Jr. Governor CHECK ONE: 0 There is a File Number Already Assigned to this Operation Harris D. Sherman Pe ' M - - (Please reference the file number currently assigned to this operatiog)ecuuve Director is AmendmentApplication R le Ronald W Cat" New Application (Rule 1.4.5) (Rule 1.10) Division Director Conversion Application (Rule L11) Natural Resource Trustee Permit # M - 2010 - 049 - (provide for Amendments and Conversions of existing permits) The application for a Construction Materials Regular 112 Operation Reclamation Permit contains three major parts: (1) the application form; (2) Exhibits A-S, Addendum 1, any sections of Exhibit 6.5 (Geotechnical Stability Exhibit; and (3) the application fee. When you I submit your application, be sure to include one (1) complete signed and notarized ORIGINAL and one (1) copy of the completed application form, two (2) copies of Exhibits A-S, Addendum 1, appropriate sections of 6.5 (Geotechnical Stability Exhibit, and a check for the application fee described under Section (4) below. Exhibits should NOT be bound or in a 3-ring binder; maps should be folded to 8 1/2" X 11" or 8 1/2" X 14" size. To expedite processing, please provide the information in the format and order described in this form. GENERAL OPERATION INFORMATION Type or print clearly, in the space provided, ALL information requested below. 1. Applicant/operator or company name (name to be used on permit): Varra Companies, inc. 1.1 Type of organization (corporation, partnership, etc.): Colorado Corporation 2. Operation name (pit, mine or site name): Western Sugar Reclamation Land Development Project 3. Permitted acreage (new or existing site): 102.87 permitted acres 3.1 Change in acreage (+) - 0 - acres 3.2 Total acreage in Permit area 102.87 acres 4. Fees: 4.1 New Application $2,696.00 application fee 4.2 New Quarry Application $3,342.00 quarry application 4.4 Amendment Fee $2,229.00 amendment fee 4.5 Conversion to 112 operation (set by statute) $2.696.00 conversion fee 5. Primary commoditie(s) to be mined: sand gravel r'nattiest earth products 5.1 Incidental commoditie(s) to be mined: 1 . - lbs/Tons/vr 2. / lbs/Tons/vr 3. / lbs/Tons/vr 4. / lbs/Tans/yr 5. / lbs/Tons/vr 5.2 Anticipated end use of primary commoditie(s) to be mined: urban infrastructure & development 5.3 Anticipated end use of incidental commoditie(s) to be mined: N/A Office of Office of Mined Land Reclamation Denver • Grand Junction • Durango • Active and Inactive Mines - 2 - 6. Name of owner of subsurface rights of affected land: Refer to Exhibit 0 If 2 or more owners, "refer to Exhibit O". 7. Name of owner of surface of affected land: Varra Companies, Inc. 8. Type of mining operation: 7 Surface El Underground 9. Location Information: The center of the area where the majority of mining will occur: COUNTY: Weld PRINCIPAL MERIDIAN (check one): E `' 1 6th (Colorado) Ft 10th (New Mexico) fl Ute SECTION (write number): S nine TOWNSHIP (write number and check direction): T fiveEll North I I South RANGE (write number and check direction): R sixty-five ri East al West QUARTER SECTION (check one): SW QUARTER/QUARTER SECTION (check one): 12 NE N W I SE I I SW GENERAL DESCRIPTION: (the number of miles and direction from the nearest town and the approximate elevation): Immediately east of Greeley, Colorado. Elevation 4,636 feet. 10. Primary Mine Entrance Location (report in either Latitude/Longitude OR UTM): Latitude/Longitude: Example: (N) 39° 44' 12.98" (W) 104° 59' 3.8T Latitude (N): deg 37 min 38 sec 41 . 00 (2 decimal places) Longitude (W): deg 108 min 09 sec 21 . 00 (2 decimal places) OR Example: (N) 39.73691 ° (W) -104.98449° Latitude (N) (5 decimal places) Longitude(W) (5 decimal places) OR Universal Tranverse Mercator (UTM) Example: 201336.3 E NAD27 Zone 13 4398351 .2 N UTM Datum (specify NAD27, NAD83 or WGS 84) Nad 83 Zone 13 Easting 2230388.85 Northing 396239. 11 - 3 - 11 . Correspondence Information: APPLICANT/OPERATOR (name, address, and phone of name to be used on permit) Contact's Name: Christopher L. Varra Title: President Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: ( 303 ) _ 666-6657 Fax Number: ( 303 _ 666-6743 PERMITTING CONTACT (if different from applicant/operator above) Contact's Name: Bradford Janes Title: Forester Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: ( 970 ) _ 353-8310 Fax Number: ( 970 ) _ 666-6743 INSPECTION CONTACT Contact's Name: Garrett C. Varra Title: Vice-President of Operations Company Name: Varra Companies, Inc. Street/P.O. Box: 8120 Gage Street P.O. Box: City: Frederick State: Colorado Zip Code: 80516 Telephone Number: ( 303 ) _ 666-6657 Fax Number: ( 303 is 666-6743 CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Zip Code: Telephone Number: ( ) - CC: STATE OR FEDERAL LANDOWNER (if any) Agency: Street: City: State: Zip Code: Telephone Number: ( ) - - 4 -12. Prima future (Post-mining) land use (check one): Cropland(CR) D Pastureland(PL) General Agriculture(GA) CI Rangeland(RL) El Forestry(FR) Wildlife Habitat(WL) Residential(RS) II Recreation(RC) Industrial/Commercial(IC) ✓ Developed Water Resources(WR) f] Solid Waste Disposal(WD) 13. Primary present land use (check on ,a: Cropland(CR) -es Pastureland(PL) _ - General Agriculture(GA) fa Rangeland(RL) Forestry(FR) _ Wildlife Habitat(WL) Residential(RS)E. Recreation(RC) lndustriaVCommercial(IC) Developed Water Resources(WR) 14. Method of Mining: Briefly explain mining method (e.g. truck/shovel): Surface extraction and processing of aggregate using heavy equipment such as dozers, front-end loaders, haul trucks, etc. 15. On Site Processing: ✓ Crushing/Screening 13. 1 Briefly explain mining method (e.g. truck/shovel): Materials are extracted and removed to screens and crushers for processing into product to be sold for urban infrastructure needs List any designated chemicals or acid-producing materials to be used or stored within permit area: none - all fuels and lubricants will be brought in as needed on mobile equipment and vehicles 16. Description of Amendment or Conversion: If you are amending or converting an existing operation, provide a brief narrative describing the proposed change(s). Provides specific information on the lining of completed basins for our developed water resources, - 5 - Maps and Exhibits: Two (2) complete, unbound application packages must be submitted. One complete application package consists of a signed application form and the set of maps and exhibits referenced below as Exhibits A-S, Addendum I , and the Geotechnical Stability Exhibit. Each exhibit within the application must be presented as a separate section. Begin each exhibit on a new page. Pages should be numbered consecutively for ease of reference. If separate documents are used as appendices, please reference these by name in the exhibit. With each of the two (2) signed application forms, you must submit a corresponding set of the maps and exhibits as described in the following references to Rule 6.4, 6.5, and 1 .6.2(I)(b): EXHIBIT A Legal Description EXHIBIT B Index Map EXHIBIT C Pre-Mining and Mining Plan Map(s) of Affected Lands EXHIBIT D Mining Plan EXHIBIT E Reclamation Plan EXHIBIT F Reclamation Plan Map EXHIBIT G Water Information EXHIBIT H Wildlife Information EXHIBIT I Soils Information EXHIBIT J Vegetation Information EXHIBIT K Climate Information EXHIBIT L Reclamation Costs EXHIBIT M Other Permits and Licenses EXHIBIT N Source of Legal Right-To-Enter EXHIBIT O Owners of Record of Affected Land (Surface Area) and Owners of Substance to be Mined EXHIBIT P Municipalities Within Two Miles EXHIBIT Q Proof of Mailing of Notices to County Commissioners and Conservation District EXHIBIT R Proof of Filing with County Clerk or Recorder EXHIBIT S Permanent Man-Made Structures Rule I .6.2( 1)(b) ADDENDUM 1 - Notice Requirements (sample enclosed) Rule 6.5 Geotechnical Stability Exhibit (any required sections) The instructions for preparing Exhibits A-S, Addendum I, and Geotechnical Stability Exhibit are specified under Rule 6.4 and 6.5 and Rule 1 .6.2(1)(b) of the Rules and Regulations. If you have any questions on preparing the Exhibits or content of the information required, or would like to schedule a pre-application meeting you may contact the Office at 303-866-3567. Responsibilities as a Permittee: Upon application approval and permit issuance, this application becomes a legally binding document. Therefore, there are a number of important requirements which you, as a permittee, should fully understand. These requirements are listed below. Please read and initial each requirement, in the space provided, to acknowledge that you understand your obligations. If you do no understand these obligations then please contact this Office for a full explanation. 1 . Your obligation to reclaim the site is not limited to the amount of the financial warranty. You assume legal liability for all reasonable expenses which the Board or the Office may incur to reclaim the affected lands associated with your mining operation in the event your permit is revoked and financial warranty is forfeited; - 6 - elf 2. The Board may suspend or revoke this permit, or assess a civil penalty, upon a finding that the permittee violated the terms or conditions of this permit, the Act, the Mineral Rules and Regulations, or that information contained in the application or your permit misrepresent important material facts; • 3. If your mining and reclamation operations affect areas beyond the boundaries of an approved permit boundary, substantial civil penalties, to you as permittee can result; 4. Any modification to the approved mining and reclamation plan from those described in your approved 0r application requires you to submit a permit modification and obtain approval from the Board or Office; 5. It is your responsibility to notify the Office of any changes in your address or phone number; idd 6. Upon permit issuance and prior to beginning on-site mining activity, you must post a sign at the entrance of the mine site, which shall be clearly visible from the access road, with the following information (Rule 3. 1 . 12): a. the name of the operator; b. a statement that a reclamation permit for the operation has been issued by the Colorado Mined Land Reclamation Board; and, c. the permit number. eu7. The boundaries of the permit boundary area must be marked by monuments or other markers that are clearly visible and adequate to delineate such boundaries prior to site disturbance. goii 8. It is a provision of this permit that the operations will be conducted in accordance with the terms and conditions listed in your application, as well as with the provisions of the Act and the Construction Material Rules and Regulations in effect at the time the permit is issued. °de 9. Annually, on the anniversary date ofpermit issuance, you must submit an annual fee as specified by Statute, Y P and an annual report which includes a map describing the acreage affected and the acreage reclaimed to date (if there are changes from the previous year), any monitoring required by the Reclamation Plan to be submitted annually on the anniversary date of the permit approval. Annual fees are for the previous year a permit is held. For example, a permit with the anniversary date of July 1 , 1995, the annual fee is for the period of July 1, 1994 through June 30, 1995. Failure to submit your annual fee and report by the permit anniversary date may result in a civil penalty, revocation of your permit, and forfeiture of your financial warranty. It is your responsibility, as the permittee, to continue to pay your annual fee to the Office until the Board releases you from your total reclamation ofresponsibility. • 10. For joint venture/partnership operators: the signing representative is authorized to sign this document and a power of attorney (provided by the partner(s)) authorizing the signature of the representative is attached to this application. - 7 - NOTE TO COMMENTORS/OBJECTORS: It is likely there will be additions, changes, and deletions to this document prior to final decision by the Office. Therefore, if you have any comments or concerns you must contact the applicant or the Office prior to the decision date so that you will know what changes may have been made to the application document. The Office is not allowed to consider comments, unless they are written, and received prior to the end of the public comment period. You should contact the applicant for the final date of the public comment period. If you have questions about the Mined Land Reclamation Board and Office's review and decision or appeals process, you may contact the Office at (303) 866-3567. - 8 - Certification: As an authorized representative of the applicant, I hereby certify that the operation described has met the minimum requirements of the following terms and conditions: 1 . To the best of my knowledge, all significant, valuable and permanent man-made structure(s) in existence at the time this application is filed, and located within 200 feet of the proposed affected area have been identified in this application (Section 34-32.5-115(4)(e), C.R.S.). 2. No mining operation will be located on lands where such operations are prohibited by law (Section 34-32.5- 115(4)(f), C.R.S.; 3. As the applicant/operator, I do not have any extraction/exploration operations in the State of Colorado currently in violation of the provisions of the Colorado Land Reclamation Act for the Extraction of Construction Materials (Section 34-32.5- 120, C.R.S.) as determined through a Board finding. 4. I understand that statements in the application are being made under penalty of perjury and that false statements made herein are punishable as a Class 1 misdemeanor pursuant to Section 18-8-503, C.R.S. This form has been approved by the Mined Land Reclamation Board pursuant to section 34-32.5-112,CR.S., of the Colorado Land Reclamation Act for the Extraction of Construction Materials. Any alteration or modification of this form shall result in voiding any permit issued on the altered or modified form and subject the operator to cease and desist orders and civil penalties for operating without a permit pursuant to section 34-32.5-123, C.R.S. bur Signed and dated this day of `��' ov �� 2 l S Vavv'c COMJDOJ(. ( _'S 1 Teti C . If Corporation Attest (Seal) Applicant/Operator or Compan ame Signed: Signed: Cor orate Sec tary or Equivalent Title: President Town/City/County Clerk State of Co \ orado ) ) ss. Lk) QA4 Countyof ) mow. {�� 11 IV The foregoing instrument was acknowledged before me this I LP day of OU env) & r 2015, by CI i s etbelntr L. Vnv& as Prsiaevtt of VGLr rct Connpa n i es ,Dhf_ . Lra\hp45\Ari JESSICA HOOVER NOTARY PUBLIC Nota ublic STATE OF COLORADO NOTARY ID 20044035571 � l LP My Commission Expires Oct 4, 2016 My Commission expires: J SIGNATURES MUST BE IN BLUE INK You must post sufficient Notices at the location of the proposed mine site to clearly identify the site as the location of a r • ' ; • �y �, I, . • • - In \ . \.0 /n j H to c. . v • It Z . ; • • i .. 7 • O.. • A .." " s \ .°?-4 0 'ci C) r "U 4 - . � , Vi hallii \_ . (16 r . it: II Q • 1 a 1. • • . . . .. ;` • • Or 1 - ' � \ • � _ 1 • v mu. . S •... c - r• I• O 5 t ,f • . ^4 .# • IN a. . ` � y in t r 0 •,� ,r v * •• i• ,�• cs i • '• ill �� • a t •4 -• • ' f-•. . . - ♦ ;-•! L 'r . , _, J • J a• n..., •' • �1 Cl • • I- • • ,l ' �� • _ { . • t CD I) PA I I . • . 0 • w I1 • 0 I CC 6 SCALE: 1 Inch = 2,64(1 feet VARRA COMPANIES, INC. DATE: 8 February 2010 8120 GAGE STREETON-11 a • FREDERICK, COLORADO 80534 REVISION: . k 4 Exhibit G --- Water Information 6.4.7 EXHIBIT G - Water Information ( 1 ) If the operation is not expected to directly affect surface or groundwater systems, a statement of that expectation shall be submitted . (2) If the operation is expected to directly affect surface or groundwater systems, the Operator/Applicant shall: (a) Locate on the map (in Exhibit C) tributary water courses, wells, springs, stock water ponds, reservoirs, and ditches on the affected land and on adjacent lands where such structures may be affected by the proposed mining operations; (b) Identify all known aquifers; and (c) Submit a brief statement or plan showing how water from de-watering operations or from runoff from disturbed areas , piled material and operating surfaces will be managed to protect against pollution of either surface or groundwater (and , where applicable, control pollution in a manner that is consistent with water quality discharge permits), both during and after the operation . (3) The Operator/Applicant shall provide an estimate of the project water requirements including flow rates and annual volumes for the development, mining and reclamation phases of the project. (4) The Operator/Applicant shall indicate the projected amount from each of the sources of water to supply the project water requirements for the mining operation and reclamation . (5) The Operator/Applicant shall affirmatively state that the Operator/Applicant has acquired (or has applied for) a National Pollutant Discharge Elimination System (NPDES) permit from the Water Quality Control Division at the Colorado Department of Health, if necessary. This Amendment is intended to satisfy the option of lining approved basins. The basins identified in the original Office of Mined Land Reclamation (OMLR) permit are presently approved and bonded for both the lined and unlined state. The permit provides for the option that the basins be lined in order to liberate the waters presently securing the exposed groundwater in the unlined condition. The previous effort to detail the methodology and procedures to line the basins with the approved change in the original permit via a technical revision were later rejected defacto by the Office of Mined Land Reclamation (OMLR), and an Amendment to assure notification of adjacent landowners was mandated instead. This submittal is intended to satisfy that mandate to assure the assure the OMLR that lined basins will comply with state law. To satisfy the concerns of the OMLR, included with this revision is a report on the potential for shadowing and mounding by AWES, LLC of 27 June 2013 . The report concludes: Varra Companies, Inc. Permit M-2010-049 1 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G -- Water Information `. . .that lining mined gravel pits has almost unmeasurable influences to the surrounding groundwater hydrology and does not change hydraulic gradients beyond the variations that would normally be expected in the geologic settings associated with the operation.' We anticipate the OMLR will concur with this analysis. Once operations near completion of any lined basin, the Colorado Department of Water Resources Office of the State Engineer (OSE) will be contacted and the lined basins will be approved prior to use. The OSE approval letter will be provided to the OMLR as a condition of the permit and satisfaction that the lined basin has met the specifications necessary to pass a liner test as part of the OSE approval process. ( 1) Operations will not adversely affect surface and groundwater systems. The manner and method of extraction is detailed under Exhibit D — Extraction Plan. Anticipated effects on surface flows are anticipated to be minor to none. Essentially, the flood plain covers the property and unless under flood conditions, upland overland flows are generally diverted by existing access roads or grassed drainage channels, or drain internally into existing or planned basins. (2) (a) Please refer to Exhibit C-1 : Existing Conditions Map. (b) The known aquifer under the site is the stream alluvium . (c) Discharge water will be dissipated with hard surface riprap or established grassed waterways. Other waters are retained by internal pit drainage, directed by vegetated berms or established waterways or through the maintenance or establishment of a stabilizing cover of vegetation, or as otherwise established under an approved Colorado Department of Health stormwater permit and/or stormwater discharge permit. (3) The three components of the project water requirements are water removed with the product, dust control, and evaporation from exposed ground water. Dust will be controlled using truck sprinklers, and the estimated frequency is one load per day. At 2,500 gallons of truck capacity, the annual demand is 2 . 80 acre-feet. After the water table is encountered, the water removed with the estimated 800,000 tons of product is 23. 55 acre-feet per year. The estimated net evaporation is 1 .419 feet per year. At the maximum potentially exposed ground water of 62.81 acres, the annual evaporation is 89 . 13 acre-feet. The monthly distribution of these estimates is shown in the following table. The reclamation plan provides that the pits will be lined after being mined . The lined pits will not require replacement water and will be used for storage. There may be incidental demand for water to establish vegetation on the site after lining is completed . However, the ultimate demand for water will be zero. Varra Companies, Inc. Permit M-2010-049 2 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G -- Water Information MONTH PRODUCT DUST NET EVAP USE CO NTRO L Tons of Trucks af ac af af November 40,000 1 . 18 30 0.23 62.81 5.78 7. 19 December 40/000 1 . 18 31 0.24 62.81 4.97 6.39 January 40,000 1 . 18 31 0.24 62.81 4.78 6.20 February 36,000 1 .06 28 0.21 62.81 6.36 7.63 March 40,000 1 . 18 31 0.24 62.81 7.95 9.37 April 80,000 2.35 30 0.23 62.81 9.69 12.27 May 85,000 2.50 31 0.24 62.81 10.49 13.23 June 92/000 2. 71 30 0.23 62.81 10.77 13.71 July 93,000 2.74 31 0.24 62.81 8.36 11 .34 August 90,000 2.65 31 0.24 62.81 7.67 10.56 September 85,000 2. 50 30 0.23 62.81 6.61 9.34 October 79,000 2.33 31 0.24 62.81 5 .70 8.27 Apr-Oct 604,00O 17.78 2141 1 .65 59.29 78.72 TOTAL 800,000 23.561 3651 2.81 89.13 115.50 (4) Water will be supplied by two sources: shares of the Rural Ditch Company and water decreed in Case No. 01CW274. VCI owns four shares of Rural Ditch Company. From April through October, water use at the site will be replaced to the stream system using the historical consumptive use credits from any of the sources and/or from storage. The monthly distribution of the historical consumptive use is shown in the following table: HISTORICAL CONSUMPTIVE USE All Values in Acre-Feet APR MAY JUN JUL AUG SEP OCT ANN Rural 5.41 23.3 54. 1 84.3 61 .8 27. 1 9.5 265 .5 Water in excess of this mine`s and other VCI obligations will be stored and used to replace the water use from November through March. The storage sites are lined pits described in Case No. 01CW274 decree. Water available under these storage decrees will also be stored and used for VCI operations. The storage facilities are listed in the following table. Those currently lined and approved by the state are 112 and Dakolios. Varra Companies, Inc. Permit M-2010-049 3 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Exhibit G — Water Information VCI STORAGE FACILITIES (All Values in Acre-Feet) Reservoir Active Capacity, a-f Dead Storage, a-f 112 1,552 0 Dakolios 1,900 0 Von Ohlen 1,300 0 Kurtz 4,000 0 Total NOT TO EXCEED 0 7,500 A-F PER YEAR (5) A Colorado Wastewater Discharge Permit System Permit has been applied for with the Colorado Department of Health. Varra Companies, Inc. Permit M-2010-049 4 Western Sugar Reclamation Land Development Project OMLR 112 Permit Amendment 2015 Hello