2013-12-16_REVISION - M2013064

• Permit No: M2013064
• IBM Index Class Name: REVISION
• Doc Date: 12/16/2013
• Doc Name: Permit Application Adequacy review
• From: DRMS
• To: Varra Companies, Inc
• Email Name: PSH
• Media Type: D
• Archive: No

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Varra- Coulson Resource Project
Adequacy Review
11. As required by Rule 3.1.9(3), topsoil stockpiles shall be stored in places and configurations
to minimize erosion and located in areas where disturbance by ongoing mining operation
will be minimized. The Board may require immediate planting of annual and /or perennial
grasses on topsoil stockpiles for the purpose of stabilization. Please depict on Exhibit C a
typical topsoil stockpile location for each field and commit to seeding all stockpiles, if not
replaced within 180 days with a temporary vegetative cover.
12. The Applicant proposes to replace a minimum of 6 inches of topsoil on the reclaimed areas.
The NRCS soils report states topsoil depths ranges from 0 to 48 inch in the majority of the
South and Middle Fields and the report by AWES, LLC dated July 22, 2013 states three to
five feet of topsoil is present based on soil borings conducted on the site. Additionally, only
approximately 10% of the mined area will require topsoil replacement due to the creation
of the clay lined reservoir. Therefore, the Applicant should replace topsoil to a depth at
least equal to the existing topsoil depth of three to five feet. Please commit to replacing
topsoil to a minimum depth of three to five feet over the reclaimed upland areas.
6.4.7 Exhibit G - Water Information
13. The Division's engineering staff reviewed Exhibit G - Water Information. A copy of the
review memo from Tim Cazier, P.E. is attached.
14. Groundwater monitoring well are mentioned in the Dewatering Evaluation Report by AWES,
LLC and were observed during the pre- operation inspection on December 12, 2013. Please
indicate the location of the monitoring wells on the Exhibit G map.
15. Please commit to provide the Division with monthly monitoring well data as part of the
annual report for the site.
16. Please provide proof of monitoring well installation permits from the Office of State
Engineer to the Division.
17. The AWES, LLC report states there are a number of domestic wells located within the area
influenced by pumping. Though there is sufficient aquifer thickness to provide good well
yields there may be partially penetrating wells that might be affected by mine dewatering.
Please provide a mitigation plan with trigger levels for the potential impacts to the
surrounding groundwater wells. The Applicant must explain any mitigation measures to be
implemented and trigger points which would put mitigation measures into effect. Typically,
a trigger point of a 2 feet change from historic ground water levels is acceptable.
18. Please state if all the registered alluvial wells within 600 feet were identified based on SEO
records and if field inspections were conducted to identify all wells within 600 feet.
19. The Dewatering Evaluation Report by AWES, LLC predicts the cone of depression and radius
of influence, the horizontal and vertical extent, for the expected impacts at the Coulson site