2019-05-30_PERMIT FILE - M2018051

• Permit No: M2018051
• IBM Index Class Name: PERMIT FILE
• Doc Date: 5/30/2019
• Doc Name: Comment Acknowledgement/Response
• From: Black Mountain Sand
• To: DRMS
• Email Name: PSH
• Media Type: D
• Archive: No

BLACK MOUNTAIN SAND
420 Commerce St. Suite 500, Fort Worth, TX 76102
[phone]
in the Weld County USR application. Additionally, Black Mountain is happy to meet with
the conservation district to discuss their concerns and our best management practices in
detail.
• Morgan County Quality Water District—Objector
• "The applicant should be required to file an application for hard rock mining because
Applicant is proposing to mine for industrial sand, not construction materials"—Black
Mountain has received verbal confirmation from CDRMS personnel that industrial sand is
considered a construction material under Colorado Rules and,therefore, our use of the
construction materials application form is correct.
• "The application does not adequately describe certain aspects of the proposed mining and
processing plan in sufficient detail" (i.e.the process to remove feldspathic sand grains
from the product)—Black Mountain has already conducted testing on samples from the
Lost Creek project area and is confident in the material's ability to be used as a proppant
sand. Additionally,the percentage of feldspar in the deposit is minimized after washing,
scrubbing, and separating. No flotation is required and no "Designated Chemicals" will be
necessary nor are they proposed for use at the site.
• "The Applicant made assumptions and conclusions regarding the impact of the mining,
processing, and reclamation operations on the groundwater without considering the
underlying alluvial aquifer known as the Hay Gulch alluvial aquifer, and did not consider
the adverse impact that the proposed operations might reasonably be expected to have
on the groundwater quality produced from Morgan County Quality Water District's
permitted wells which are located on the adjacent property and which are completed in
the Hay Gulch aquifer" —Black Mountain has met with Morgan County Quality Water
District and discussed in detail their concerns regarding the Hay Gulch Aquifer and
potential water quality impacts. As a result of these discussions, Black Mountain has
redesigned their mine plan and is in the process of amending their mine permit
application to ensure the water quality in the Hay Gulch Aquifer, going so far as to move
their entire mining area and processing facility outside the Hay Gulch aquifer boundary as
well as committing to not mine 30%of their sand reserves,which overlay the Hay Gulch
aquifer. Additional data has been added to the amendment regarding the project's
impacts to groundwater and detail the steps Black Mountain has made and is continuing
to make regarding Morgan County's municipal well field and the surrounding water
quality.
• Bijou Irrigation District and Bijou Irrigation Company—Objector
• A statement that Bijou does not believe sufficient baseline aquifer data collection and
analysis has been done to establish pre-mining baseline aquifer water levels or hydrology
in the proposed mining area—Historic data and extensive hydrology studies that have
been completed on the Lost Creek and Hay Gulch Aquifers are readily available. Two
exploratory drilling programs have also been completed at the site,which provided
supplemental water level data within the project area. The combination of this data was
used to establish a baseline for the project and assist in the development of Black
Mountain's mine plan and proposed well monitoring program.