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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />STATE OF COLORADO <br />MEMORANDUM <br />To: Peter Hays, Environmental Protection Specialist <br />From: Tim Cazier, P.E., Environmental Protection Specialist <br />Date: December 13, 2013 <br />Re: Varra- Coulson Resource Project, Permit No. M -2010 -049; <br />Exhibit G — Water Information, Preliminary Adequacy Review <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta Pineda <br />Director <br />The Division of Reclamation, Mining and Safety engineering staff (DRMS) have reviewed <br />Exhibit G — Water Information included in the I I 2 application received on September 18, 2013 <br />for the Varra- Coulson Resource Project. <br />The review consisted of comparing the application content with specific requirements of Rule <br />6.4.7 of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for <br />the Extraction of Construction Materials. Any inadequacies are identified below along with <br />suggested actions to correct them. <br />Shadow/Mounding Analysis Letter dated June 27, 2013 from Awes LLC: <br />1. The letter focuses on Pit 112 and Pit 110. Each pit is unique and as these are pits in a <br />different location than the Varra- Coulson pit, the DRMS questions the relevance and purpose <br />of providing this analysis. Please provide a rationale for their inclusion. <br />2. The DRMS questions the validity of the vector analysis in predicting hydraulic gradients <br />when the results show an 8 -foot drop across an open pond. Plate 1 — Pit 112 Vector Analysis <br />(for January 2012) depicts an 8 -foot drop in groundwater elevations (contour 4841 to 4833) <br />across the pit. A similar result is depicted on Plate 2 — Pit Vector Analysis (for July 2012). <br />Please explain the validity of these results. <br />Coulson Gravel Pit Mine Berm Failure Analysis and Flood Control Mitigation Plan dated <br />September 2, 2013 and prepared by Flow Technologies, LLC: <br />3. Section 3.2.1, p. 13: The last paragraph of Section 3.2.1 discusses the need to characterize <br />the geotechnical composition for a complete erosion estimate. Please provide a discussion <br />Office of Office of <br />Mined Land Reclamation Denver , Grand Junction • Durango Active and Inactive Mines <br />