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