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4- not provide any information about the proposed "Flowable fill" except that it should be a sui[able, low compressibility, inert fill material. CC&V needs to ob[ain DMG approval to use "f]owablz fill" prior to using the material for closure of open laterals. CC&V will commit to: 1) monitor wall deformation, including bench-scale behavior, 2) model re- evaluation whenever new information becomes available that affects the current understanding of rock mass properties and structure and 3) back-analysis to calibrate actual rock mass/wall behavior if sip ificant wall deformations should occur and provide the data to the Division thing (30) days af[er CC&V recorded the da[a. V. 6.4.5 EXHIBIT E -Reclamation Plan A. On page 102 the operator states, "CC&V also envisions that it may become appropriate to adopt landuse plans developed by the current Joint Planning Effort (Cripple Creek, Victor, and teller County with CC&V participation). This planning effort may result in support for landuses that may differ from those currently planned and achieved. Under AM-07, the OMLR/MLRB approved CC&V's request to allow such changes to the reclamation plan to be considered as technical revisions to the permit. 1. Indeed the Division has allowed some items to be submitted as Technical Revisions to facilitate approval. However, the operator or operators were required to waive his or her right to a decision within thirty (30) days and publish in the local newspaper as required under Amendment applications. If an objection is received on or before the end of the comment period, the Technical revision is processed as an amendment. If this is the understanding CC&V has, changes can be submitted as Technical Revisions. An Amendment is defined in the Hazd Rock/Metal Mining Rules and Regulations as a "change in permit or an application which increases, the acreage of the affected land or which has a significant effect upon the approved or proposed reclamation or Environmental Protection Plan." B. Growth Medium As mentioned in Exhibit D, all available growth medium has to be salvaged. The Division will have no objection if the operator temporarily stockpiles these growth mediums in unapproved locations until such time, the operator moves them into the permanent locations. By the operator's own count there will be an excess of 388,900 cubic yards of growth medium. Please explain where [he extra soil will be placed. It is also the understanding of the Division that, included in the financial warranty is ten tons of lime per acre amendment to the growth medium for plant growth in the upper 2 fee[ of topsoil, for the overburden storage areas, in the event the required vegetation cover can not be es[blished. C. On Section 11.3.1 Grading and Ripping, "The graded slopes of overburden storage areas and disturbed areas other than mine walls will be fina{-graded to overall slopes which are generally 2.SH:l .OV or less, unless steeper slopes are required to blend with the surrounding topography or to create irregular land forms with a more natural appearance. The Financial V/arranty for the overburden used a 2.~H:I.OV overall slopes. Any changes to the approved slopes will require a Division approval D. Under .4M-07, the operator had agreed to 1•lace a 6-foot high (minimum) chain link fence installzd around the crest of those portions of the mines where hiehwalls of greater than approxima[el} 30-feet