2016-05-10_PERMIT FILE - M2010049 (2)

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6.4.4 Exhibit D - Mining Plan 7. The Applicant states there are no planned revisions to the Exhibit D. The amendment application is missing Page 5 of the approved Mining Plan for the Western Sugar Project. Please provide the missing page of the approved Mining Plan. Included with this submittal,please find Page 5 of the Extraction Plan,as requested. Since this is an Amendment application,information previously provided and approved by the Office of Mined Land Reclamation (OMLR) —is not required as part of an Amendment to the approved permit. We have included it as requested as a courtesy. It's available in the original permit as well. 6.4.5 Exhibit E - Reclamation Plan 8. The amendment application description states the application provides specific information on the lining of completed basins for developed water resources. The amendment application does not provide information on how the Applicant intends to line the four open water pits at the Western Sugar Project site. Please provide the specific information on how the Applicant intends to line the ponds and update the Reclamation Plan and Reclamation Plan Map as needed. Lining of basins involves the placement of low permeability compactable fill from on-site geologic materials into the resulting 3 foot by 3 foot or greater keyway;the same keyway used in the discharge of groundwater at the time of extraction.The balance of the basin floors and slopes are also covered and compacted with the same materials until it meets the standards established under the August 1999 State Engineer Guidelines for Lining Criteria. Typical to obtaining approval for the constructed liner, the lined basin must pass a 90 day leak test. Correspondence from the OSE approving the construction of the lined basin will be submitted to the OMLR on receipt, or as part of any request for release of the permit,in part or whole. 6.4.7 Exhibit G-Water Information 9. The Applicant states the report by AWES,LLC dated June 27,2013 is included in the amendment application to satisfy the concerns of the Division for the potential for groundwater mounding and shadowing at the Western Sugar Project site. The Shadow/Mounding Analysis by AWES,LLC dated June 27, 2013 does not accurately predict the potential shadowing and mounding effect of the proposed lined ponds at the Western Sugar site. The Applicant must define or predict the shadow and mounding effect expected for the Western Sugar site not Varra 110 and 112 Pits. Please refer to the specific evaluation of lined ponds at this location by AWES of Fort Collins, dated 16 March 2016,included with this submittal. 3 Varra Companies, Inc. Western Sugar Project OMLR M-2010-049 Correspondence to Peter Hays 9 May 2016