2019-08-29_PERMIT FILE - M2019028 ‎(3)‎

• Permit No: M2019028
• IBM Index Class Name: PERMIT FILE
• Doc Date: 8/29/2019
• Doc Name: Adequacy Review Response
• From: J&T Consulting
• To: DRMS
• Email Name: AME
• Media Type: D
• Archive: No

RE: J-2 Contracting Company-DPG Pit-Permit No. M-2019-028
112(c)Permit Application
Adequacy Review No. 1 Response 8126119
-11-
Please incorporate these recommendations into the proposed mining plan, including
commitments to performing the recommended surveys within the specified timeframes, to
maintaining the recommended buffer zones during the specified timeframes, and to
coordinating with CPW and/or USFWS as necessary.
Response: J-2 Contracting Company commits to incorporating the recommendations
from ERC's Screening Report for Federal and State Listed Threatened and Endangered
Species into the mining plan and commits to performing the recommended surveys
within the specified timeframes, maintaining the recommended buffer zones during the
specified timeframes, and coordinating with CPW and USFWS as necessary.
Exhibit J-Vegetation Information (Rule 6.4.10):
44) The Aquatic Resource Delineation Report prepared by Ecological Resource Consultants,
Inc. (ERC) identifies several aquatic resources within and nearby the proposed affected
land boundary, some of which are likely non-jurisdictional, and others which are likely
considered jurisdictional and subject to Section 404 Clean Water Act. The application
states a request for an Approved Jurisdictional Determination is pending from the U.S.
Army Corps of Engineers Denver Regulatory Office in order to verify jurisdictional status of
all aquatic resources on site. Please commit to not commencing with dewatering activities
at the site until this determination has been received and a copy provided to the Division.
Please be advised, if any of the identified aquatic resources are determined to be
jurisdictional, the submittal of a permit revision may be required to comply with the
requirements of Section 404 Clean Water Act, including demonstration of compliance with
Rule 3.1.6(1) with regard to potential dewatering impacts to the jurisdictional aquatic
resources.
Response: J-2 Contracting Company commits to not commencing with dewatering
activities until ERC's report has been accepted, a determination has been completed by
the Army Corps of Engineers, and a copy has been provided to the DRMS.
Exhibit L- Reclamation Costs (Rule 6.4.12):
45) The operator proposes a phased and cumulative bonding approach, and has provided
estimated costs for each of the five mining phases. However, it is not clear in the
application what specific phases or maximum disturbance the operator wishes to be
bonded for at this time. On the Exhibits C-4 and C-5 Mining Plan Maps, it appears the
operation would have disturbances in multiple phases at the same time, including slurry
wall installation and mining in Phases 1 and 2, access, truck scale, and scale house in
Phase 3, stockpiling and processing in Phases 3 and 4, and settling ponds in Phase 5.
Therefore, the proposed phasing appears to correlate more with the anticipated
excavation sequence rather than the proposed bond scenario. Please specify the
maximum disturbance (in acres) the operation proposes at this time (e.g., slurry wall
installation, mining, stockpiling, processing, equipment/truck storage, stormwater control
features, sediments ponds, scale/scale house, improved or newly created access/haul
roads). Additionally, please specify the type and approximate amount of disturbance (in
acres) to occur in each phase for the proposed maximum disturbance and bond scenario.
Response: The maximum disturbance has been provided in the revised Exhibit L bond
calculations for the Phase 1 mining. An Exhibit L map has also been provided to provide
more detail of the total disturbed area for the phases of mining. We have calculated the
slurry wall costs for the bonding of Phase 1, however J-2 Contracting Company is
q, 305 Denver Avenue-Suite D•Fort Lupton CO 80621 •Ph: 303-857-6222•Fax:[phone]