2025-11-18_REVISION - M1980244 - Laserfiche WebLink

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Physical Address: 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 Mailing Address: DRMS Room 215, 1001 E 62nd Ave, Denver, CO 80216 https://drms.colorado.gov Jared S. Polis, Governor | Dan Gibbs, Executive Director | Michael A. Cunningham, Director November 18, 2025 Bjorn Meyer Cripple Creek & Victor Gold Mining Company P.O. Box 191 Victor, CO 80860 Re: Adequacy Reivew, Technical Revision No. TR153 Cresson Project, Permit No. M-1980-244 Dear Bjorn Meyer, On October 20, 2025, the Division of Reclamation, Mining and Safety received the Technical Revision TR153 application for the VLF2 Phase 3 Stage B.1 Record of Construction Report. Pursuant to Rule 7.3.1(5), no chemicals used in the extractive metallurgical process or toxic or acid-forming materials shall be placed in constructed facilities until the Board or Office accepts the certification of the facility, or phase thereof, that precedes placement. The following comments need to be addressed prior to the DRMS accepting the submitted report: Record of Construction Report 1. Section 3.2.1 - Structure Fill: The report states that no laboratory compaction testing was performed on the structural fill and that density was achieved by placing the material with a method exceeding past method compactions specifications, however, Section 2.2 – Site Grading, states that a CQA monitor observed all subgrade preparation and Structural Fill placement during site grading to verify it met the requirements of the Technical Specifications. Please clarify what the exact approved specifications are for density and compaction of the structural fill and what methods the CQA inspector utilized to ensure those specifications were met. 2. Section 3.2.2 – Soil Liner Fill: The report refers to Tables 7 and 8 for the SLF nuclear density/moisture testing and SLF depth checks respectively and that 102 tests were performed for each and had passing results. Table 7 shows a total of 103 tests with SLF-15-N failing and, it appears, a passing re-test for SLF-15-RT. In the narrative portion of the report, please discuss failed tests, the steps taken to remediate the issues (if necessary), and re-tests. Additionally, please include a footnote in table 7 to define the test number identifier of “RT”. 3. Section 3.4 - Geomembrane Construction Quality Assurance: The report refers to Appendix I for the specific QA results and specifically Appendix I.6 for pressure testing of fusion welds. Beginning on Pg. 2 of the Appendix I.6 table, several failing tests were recorded on multiple days of fusion welds. Please identify what remedial action was taken for welds that failed the pressure test and if those welds were retested. In the narrative portion of the report, please discuss failed tests, the steps taken to remediate the issues (if necessary), and re-tests. Additionally, please include an appropriate annotation in the Remarks column on the Appendix I.6 table to clearly show tracking of failed tests and associated re-tests.