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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 />placed in a location within and along the perimeters of Tract A, above the known <br />floodplain. By focusing the majority of our product stockpiling in Tract A, and <br />keeping this area available for product by allowing some soil stockpiling within <br />the floodplain, the operations have served to minimize the need for stockpiling <br />within the floodplain. <br />It should be remembered that Tracts A and B are void of soil resources and will <br />receive soil for reclamation from Tracts C and D in an over the shoulder <br />manner, further minimizing the need for stockpiling soil within the floodplain. <br />Regardless, the flexible handling positioning of materials is generally described <br />to aid the economic viability of operations and avoid the establishment of <br />permits whose standards are too rigid to account for discretion in the field. The <br />specific placement and disposition of soils can be more specifically updated <br />where warranted as part of the Annual Report requirement for approved permits. <br />6.4.12 Exhibit L - Reclamation Costs <br />26. The Applicant will be exposing groundwater during mining operations. <br />Several options are available that will satisfy the Division's bonding <br />requirements for sites with exposed groundwater. The Division requests the <br />Applicant review the options listed below and commit to completing one of the <br />following: <br />a) File a financial warranty that will ensure backfilling of the pit to cover the <br />exposed ground water to a depth of two feet: above the static ground water level <br />or, <br />b) Obtain a court approved augmentation plan prior to exposing ground water <br />or, <br />c) File a financial warranty to cover the cost of installing a clay liner or <br />slurry wall that meets the Division of Water Resources requirements for <br />preventing groundwater exposure or, <br />d) Obtain approval from the Division of Water Resources that acknowledges <br />compliance with the SEO's requirements pursuant to C.R.S. 37-90-137(11). <br />Varra Companies, inc. correspondence to the Colorado Office of Mined Land Reclamation (OMLR) 15 <br />in reply to OMLR correspondence of 4 October 2010 - Western Sugar Reclamation Land Development Project <br />- M-2010-049.