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2009-06-30_PERMIT FILE - M2009018 (8)
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2009-06-30_PERMIT FILE - M2009018 (8)
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Last modified
8/24/2016 3:48:20 PM
Creation date
7/2/2009 1:48:36 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2009018
IBM Index Class Name
PERMIT FILE
Doc Date
6/30/2009
Doc Name
Reply to Preliminary Adequacy Review
From
Varra Companies, Inc.
To
DRMS
Email Name
MAC
Media Type
D
Archive
No
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Varra Companies, Inc. <br />Office of Special Projects <br />8120 Crane Street Frederick. Colorado 80516 Telephone (970) 353-8310 Fax(970)353-4047 <br />areas, leaving only the areas from the extraction limits to the pond edge for revegetation, or <br />essentially, the pond slopes. <br />39. In determining the cost to grade Tract A and C, the Applicant assumes an average push <br />distance of 50 ft. Please explain how this figure was arrived at. <br />It utilized a previous calculation by the Office of 50f feet to estimate a cost we anticipate will be <br />revised by the proprietary software used by the Office to determine its own estimates. The 50-+ <br />feet, was an approximation. Since the slope distance to establish a 3H:1 V slope at 25f feet in <br />height is 80t feet, a 100± foot distance may have been a bit closer. Since the Office may want to <br />use a deeper mean depth or height of the advancing wall, that distance will increase. Since the <br />Office will plug this value into its proprietary software, we will wait for the estimates performed <br />by the Office to determine this value. <br />40. In determining the cost to dewater the pits, the Applicant assumes that 42f acres will <br />need to be dewatered. The Division does not concur with this assumption. The Division <br />calculates the cost of reclamation based off of the point of maximum disturbance. If default <br />were to occur when excavation on Tract A and C is complete, but before final grading had <br />occurred, the total area of both Tracts would have to be dewatered to complete reclamation. <br />Please revise the reclamation estimate accordingly. <br />Since the basins resulting from extraction do not form except over extended number of years, the <br />42f acres for estimating a point of failure can simply be transformed to a basin limit, beyond <br />which will require additional warranty. For example, with a 25± year life estimated for <br />extraction, Tract A may be extracted and reclaimed, qualifying for release before the other two <br />Tracts are completed, or any combination of completion for the Tracts, depending upon market <br />conditions and rate of extraction and concurrent reclamation within the individual tracts. <br />Regardless, the entire 105.44± acres of water will not appear immediately but over time. If the <br />Office is willing, a 42f acre area appears to give sufficient room for extraction without <br />burdening the operation with an assumed cost that all Tracts have been extracted in year one. <br />With time, the warranty can be adjusted. Annual reporting and periodic inspection of the <br />operations by the Office should provide the necessary checks and balance to maintain adequate <br />warranty over the life of the operations. <br />In evaluating the concerns of the office, an error was observed in that only 21.0± acres of water <br />was used in the actual calculations, so the sum total derived for 21.0± acres of water should be <br />doubled from the $ 14,740.31 reported. <br />6.4.13 Exhibit M - Other Permits and Licenses <br />No Office Comment. <br />Varna Companies, Inc. correspondence of 30 June 2009 to the Colorado Office of Mined Land Reclamation 18 <br />(Office) in reply to Office correspondence of 12 May 2009 - Heintzelman Project - M2009-018.
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