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2015-03-30_GENERAL DOCUMENTS - M1999006
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2015-03-30_GENERAL DOCUMENTS - M1999006
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Last modified
8/24/2016 5:58:46 PM
Creation date
3/31/2015 2:15:39 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1999006
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
3/30/2015
Doc Name
Reply to 8/18/2014 Inspection Report
From
Varra Companies, Inc
To
DRMS
Email Name
PSH
Media Type
D
Archive
No
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default/forfeiture by the Operator, that understanding, the purpose and meaning <br />behind it, doesn't end. <br />i. The location of plant processing and stockpiling of product is clearly identified in <br />the approved permit and attending maps. <br />ii. There is no statute or rule to cause the Operator to predict the size of a stockpile, <br />any more than there is a practical or applied means to do so. <br />iii. No other operations in Colorado made known to us are required to meet what is <br />expected as extrapolated by this statement. AU permit making such an estimate <br />would find itself perpetually at risk of violating such a forecast. No one really <br />knows, or can know, how much of what product can be sorted from a deposit in <br />advance of the act of processing. It is folly to attempt to characterize this, and we <br />said as much in the original approved permit. <br />iv. What is known is commonly derived from a combination of exploratory drill logs, <br />geologic maps and reports; but mostly through an applied empirical understanding <br />that comes from experience. <br />Regardless, the deposit, prior to opening it up for extraction, generally defies <br />specificity. This is due to the simple fact that the mix of products can vary <br />dramatically with geological deposition events that are simply too random to be <br />considered predictive. <br />It is why most operations anticipate an area substantial enough to contain the <br />extracted deposit during the process of removing it from its native location, <br />transporting it to crushers and screeners for sorting, and sending the product off <br />site to meet an ever fluctuating and equally unpredictable market. One thing is <br />clear; you cannot make this product magically appear to meet the need. It takes <br />time and anticipation of both existing and potential future markets. So called <br />`large' stockpiles can become `small' too, with comparatively short notice. <br />Again, it's why the permits are designed to be for the `life of the mine.' <br />Finally, squandering product because it offends the sensibilities of some is poor <br />practice, private or public. If the product becomes unavailable, by accident or <br />incompetence by operator or government, it will only serve to increase pressure to <br />open up new lands to meet the need. Affected lands and attending resources need <br />to be fully utilized before they are reclaimed to a `beneficial use.' It should be <br />understood that the purpose of Title 34 is to assure the common good for all <br />Coloradoans, through the conservation of our natural resources; including the <br />conservation of construction materials. Every effort is made to minimize offsite <br />impacts and assure the integrity of our operations and final reclaimed lands with <br />respect to our neighbors and fellow citizens. <br />Second, once processed, the historical removal of all processed material by the <br />market is virtually assured with time. In a default, the operation itself is still a life <br />Varra Companies, Inc. correspondence of 30 March 2015 to the Colorado Office of Mined Land Reclamation in 9 <br />reply to the OMLR Inspection Report of 28 August 2014 — Kurtz Project — M- 1999 -006 <br />
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