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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 />February 14, 2014 <br />STATE OF COLORADO <br />COLORADO <br />D I V I S I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />John Hickenlooper <br />Governor <br />Bradford Janes <br />Mike King <br />Varra Companies, Inc. Executive Director <br />8120 Gage Street Loretta Pineda <br />Fredrick, Colorado 80516 Director <br />Re: Second Review of Slope Stability Analysis, Varra Companies, Inc., Varra - Coulson <br />Resource Project, File No. M- 2013 -064 <br />The Division of Reclamation, Mining and Safety (Division) staff has reviewed the stability <br />analysis included with the Varra - Coulson Resource Project 112c permit application and the <br />adequacy response from AWES, LLC dated January 13, 2014. <br />The following list describes the information used by the Division as presented in the permit <br />application to evaluate slope stability for the proposed pit: <br />• Excavation will occur no closer than 10 feet from the permit boundary, man -made <br />structures, easements and right -of -ways. <br />• Excavation will occur to within 25 feet of well heads and related above ground facilities. <br />• Extraction of sand and gravel to occur at a 1.25H to 1 slope. <br />• The average depth to claystone bedrock is 40 feet per the mining plan, 45 feet per the <br />stability analysis report and is as deep as 60 feet. <br />• No laboratory strength tests were performed on soils at the site. <br />• The water table is 5 to 10 feet below grade. A static groundwater elevation of 6 feet <br />below the ground surface was used for the analysis. <br />• The site will be dewatered during mining activities. <br />• A clay liner will be constructed at reclamation to create a reservoir. <br />1. Please provide a plan map indicating the critical cross - section locations used for the stability <br />analysis models. <br />2. Please update the stability analysis to include surcharge loads from structures, roads, gas <br />well facilities, topsoil stockpiles and any other appropriate loads. <br />3. The typical soil profile used for the stability analysis indicates; two feet of topsoil, four feet <br />of poorly graded sand, forty -one feet of sand and gravel, a three foot clay lense, fifteen feet <br />of additional sand and gravel and bedrock at 65 feet below the existing grade. The soil <br />profile does not match the typical soil profile presented on Page 3 of Exhibit D — Mining <br />Plan. Please explain this inconsistency and revise the analysis or mining plan accordingly. <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />