2025-02-26_REVISION - M1994096 - Laserfiche WebLink

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CIVIL RESVURCES, LLC ENGINEERS & PLANNERS February 20, 2025 Colorado Division of Reclamation and Mining Safety Ms.Jocelyn Carter 1313 Sherman Street, Room 215 Denver, CO 80203 RE: Technical Revision—Glacier Rock Mine(Permit M-1996.096), Larimer County, Colorado Dear Ms. Carter: The Glacier Rock Company(the Permittee) submits this Technical Revision in response to Corrective Actions identified during the Division's December 27, 2024 inspection of the Site. The text from the inspection report is reproduced in italics below. PROBLEM#1: The approved mining plan call for working slopes no greater than 3H:1V;the working slopes appeared to be near vertical. The current mine plan needs to be updated and clarified pursuant to C.R.S. 34-32.5-112 (1)(c)(VI). The Operator must provide sufficient information to describe or identify how the Operator intends to conduct the operation. CORRECTIVE ACTIONS: The Operator may bring the slopes back into compliance with the currently approved mining plan of no greater than a 3H:1V gradient and provide photographs to the Division by the corrective action due date. Alternatively, the Operator may submit a Technical Revision, with the required$216 revision fee, to update and clarify the current approved mine plan to reflect existing and proposed activities by the corrective action date. The updated mining plan and map may be included in the Technical Revision application that is to be submitted to address the problem cited for the reclamation plan compliance;only one Technical Revision needs to be submitted. The current iteration of the mining plan was approved on February 28, 2005 when the pit was converted from a 110 to a 112c permit. Section (b) of Exhibit D (Mining Plan) states that "Standard earthmoving equipment will be utilized for grading and contouring of the mine slopes. Slopes are proposed to be a maximum 3:1 gradient for side slopes." The operator contends that the initial intent of this section of the mine plan is to demonstrate that the slopes will be graded and contoured back to a 3V:1H after mining is complete, not that the slopes were going to be maintained at a 3V:1H slope during active mining. The record shows that this was also the Division's understanding of the permit since the approval of CN-1 until this latest inspection. As shown in satellite images of the Site, mining has been performed with near vertical slopes since it's amendment to a 112c permit in 2005. Observations of the near vertical highwall have been made by the Division in previous inspections without identifying a problem with complying with the current iteration of the Mine Plan. During the Division's July 10, 2020 inspection it was noted that, "Pit walls have an average height of 15 feet and near vertical slopes". As part of the corrective actions identified in the 2020 inspection, the Permittee was required to increase bonding for the Site. The bonding increase included, "costs for backfilling the pit wall to 3H:1V slopes..." The Permittee agrees that this section of the mine plan can be interpreted as maintaining a 3V:1H mine slope while active mining, even though this has not been the interpretation by the Permittee or the Division in the past. In order to clarify this section,the Permittee proposes to change Section(b)of Exhibit D to read: 8308 COLORADO BLVD•SUITE 200• FIRESTONE, CO 80504• PHONE: 303.833.1416