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Varra Companies, Inc. <br />Office of Special Projects <br />8120 Gage Street Frederick Colorado 80516 Telephone (970) 353-8310 Fax(970)353-4047 <br />such as this to be addressed through an amendment to the permit. This request cannot be <br />processed through this Technical Revision. The applicant has two choices: <br />a) Withdraw this Technical Revision and submit an amendment application to change the <br />post mine land use to agricultural for the designated areas. If this option is chosen, the <br />Division will allow the operator to submit an amendment application in 90 days. <br />Or, <br />b) The applicant can modify the submitted technical revision to indicate Areas 1 and 3 will <br />be top-soiled and re-vegetated in accordance with the approved plan. If the applicant <br />chooses to do this, there does not appear to be adequate topsoil stockpiled at the site to <br />reclaim these areas. The operator will need to import adequate growth medium and the <br />Division will need to increase the financial warranty to cover the cost to import this <br />material. <br />The Division is correct in this assumption that the farm equipment and agricultural <br />materials stockpile area is designated as Area 3. Pertaining to the change in use; the 1996 <br />Technical Revision Backfill Notice part (e), specifically calls out for the area of fill to <br />revert to A-Agriculture. <br />The use of farm equipment storage is an allowable use in Weld County for Agricultural <br />lands. We respectfully request that the Division agree, with respect to the approved 1996 <br />Technical Revision, that the aims of reclamation for the area in question were properly <br />clarified at that time and that an amendment to the permit to effect the same is un- <br />necessary in this instance. <br />2. Hydrologic Balance: <br />Since the Operator installed the clay liners for the two basins prior to the Division's approval, no <br />analysis has been submitted to the Division in regards to the possible impacts the clay liners may <br />have on the surrounding hydrologic balance specifically for mounding and shadowing affects. <br />Given the sites proximity to the Saint Vrain Creek and the likely direction of the ground water <br />flow, shadowing impacts may be negligible. However, the Division has observed clay liners, <br />slurry walls and backfilled pit excavations impede the flow of ground water ad cause mounding <br />impacts to land adjacent to these nearly impervious basins. Was any ground water elevation <br />monitoring conducted at the site for lands adjacent to the clay liners prior to their construction? <br />Please determine what impact the installation of these clay liners and the backfilling activity may <br />have on the surrounding ground water levels. Determine how ground water levels will be <br />monitored to determine if a mounding problem is occurring and how the Operator will mitigate <br />possible mounding problems. <br />Please refer to correspondence of C.G.R.S., dated 1 July 2010, as included with this submittal. <br />Varra Companies, Inc. correspondence of 18 May to the Colorado Office of Mined Land Reclamation (Office) 2 <br />in reply to Office correspondence of 27 April 2010 - Dakolios Pit - M-1984-036.