2019-05-30_PERMIT FILE - M2018051

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4 BLACK MOUNTAIN SAND 420 Commerce St. Suite 500, Fort Worth,TX 76102 (817) 698-9901 • A belief that Black Mountain should be required to monitor the groundwater of the area for at least one (1)full year prior to permit approval - Historic data and extensive hydrology studies have already been completed in the area and have provided significant groundwater data for use in site planning. This data, combined with the additional exploratory drilling completed at the site, will be used as Black Mountain finalizes its proposed well monitoring program,which will be included in the application amendment. • A statement that the project could have significant water quality impacts from both the process water infiltrating into the area and from the potential for hydrocarbon spills from equipment and additional truck traffic in the area—Chemicals in the process water from the plant are inert and will not contribute to water quality degradation. Black Mountain is finalizing its proposed well monitoring program, which will be included in the application amendment. Black Mountain will comply with all regulations regarding potential hydrocarbon spills at the site, including the implementation of a Spill Prevention Control and Countermeasures Plan and a Storm Water Pollution Prevention Plan for the site. These plans require best management practices to be used at the site at all times, providing for protection measures to be employed against spills, and providing cleanup/notification procedures and standards in the case of an accidental spill. • A statement that Bijou is concerned about the management of wind erosion during the mining and reclamation activities—The mine plan and processing plant have both been designed to minimize wind erosion from the project.The onsite dust abatement plan, which will be submitted to Weld County for approval as part of the Use by Special Review application, includes best management practices for reducing wind erosion from stockpiles and active mining areas, as well as at the processing facility. All processing equipment is located within fully enclosed buildings and final product storage will be within fully enclosed silos. Additionally,the mine plan has been developed to use concurrent reclamation activities as an additional means of reducing the potential dust by backfilling and reclaiming areas immediately behind active mining operations. • A statement that the Empire Reservoir is a winter roosting area for bald eagles and Bijou is concerned about the impacts to the bird's habitat during mining and reclamation activities —An initial wildlife survey has already been conducted to identify potential habitat on and near the project site. Black Mountain will comply with all federal regulatory rules of the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act, which includes conducting surveys as needed to identify active nests within the area of impact, developing buffers to mitigate impacts during mining activities, and scheduling vegetation removal, trimming, and grading activities outside peak breeding and roosting seasons whenever possible. • A statement that Bijou is concerned with the operation's impacts to the air quality, noise levels, nighttime lighting, and traffic impacts on the Empire Reservoir—Black Mountain is complying with all air quality regulations, including obtaining all required air permits from the State of Colorado. All processing equipment will be located within fully enclosed buildings with bag houses and filters for vent dust control, negative pressure valves on the silos to reduce dust emissions during filling operations, and an onsite dust abatement plan which includes the use of water trucks for onsite dust suppression of all disturbed areas. Additionally,the mine plan has been developed to use concurrent reclamation activities as