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4 <br /> Black Mountain Sand Weld LLC ORIGINAL <br /> 500 Main St. Suite 1200, Fort Worth,TX 76102 R EC EVED <br /> (817) 698-9901 <br /> September 12, 2019 <br /> SEP 13 20119 <br /> DIVISION OF RECLAMATION <br /> Peter Hays «INING AND SAFETY <br /> Environmental Protection Specialist <br /> Colorado Division of Reclamation, Mining and Safety <br /> Department of Natural Resources <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> RE: Black Mountain Sand Weld LLC Lost Creek Mine M-2018-051 Construction Materials Regular(112) <br /> Operation Reclamation Permit Application Amendment AM-01 Response to Adequacy Review <br /> Mr. Hays, <br /> Included below is Black Mountain Sand Weld LLC's(Black Mountain) response to the adequacy review letter <br /> received for the above referenced Lost Creek mine permit application amendment AM-01,which was <br /> received on August 27, 2019.As stated in the adequacy review letter,some of the items have already been <br /> completed and therefore, no further response is provided here. <br /> Item 1—Response to Comments <br /> A response to the original comment letters was provided to the division on May 28, 2019. Subsequent <br /> comments received by those same commenters regarding the amendment and Black Mountain's responses <br /> are provided below. <br /> Colorado Division of Water <br /> • A statement that since the operation does not anticipate exposing groundwater, exposure must not <br /> occur&the operation must stay at least 2 feet above the water table throughout operations—Black <br /> Mountain's mine plan has been designed to stay at least 2 feet above the known water table within <br /> each yearly mine block.Additionally,the groundwater monitoring program has been designed to <br /> provide more complete ongoing data at the site prior to operations and continuing throughout the life <br /> of the mine, allowing Black Mountain to further track and refine its water table data throughout mining <br /> operations. <br /> • A statement that prior to the operation of the existing wells for industrial use associated with the mining <br /> operation,the application must obtain new permits from the Ground Water Commission—Black <br /> Mountain is currently in the process of converting the use of water rights from those wells to multiple <br /> use and will provide proof of the transfer when complete.The transfer applications were submitted on <br /> July 26, 2019, comments were provided on August 21,2019,and Black Mountain submitted responses <br /> to those comments on September 9, 2019. <br /> • A statement that any stormwater runoff captured by the operation must be released back into the <br /> stream system within 72 hours and may require a discharge permit—Black Mountain's stormwater <br /> designs for both construction and operations incorporate this requirement. Most of the stormwater will <br /> be directed around the active operations through the strategic use of berms and grading.The minor <br /> amount of stormwater captured by the small settling ponds will be inspected for hydrocarbons and <br />