2019-09-13_PERMIT FILE - M2018051

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4 Black Mountain Sand Weld LLC 500 Main St. Suite 1200, Fort Worth,TX 76102 (817)698-9901 additional response time to react to a release prior to impacting the groundwater table."—The minimum two-foot buffer is a recommendation from the Colorado Division of Water Resources that Black Mountain has adopted and incorporated into its mine plan. Black Mountain's proposed groundwater monitoring program is designed to capture seasonal water quantity changes on both the east and west sides of the project,which is help further define the groundwater table throughout the project's life. Item 4—Response to additional comment letter received from Bijou Irrigation District and Bijou Irrigation Company • "It appears from the amended mining permit application that several monitoring wells would be installed during the"construction phase"for the project.That phase is expected to last from eight to twelve months. In order to get a useful data set about baseline groundwater levels and gradients and water quality conditions,the monitoring wells need to be installed at the beginning of the construction phase and data collected at least twice per month for an entire year before any mining begins."—Black Mountain has already begun moving ahead with the groundwater monitoring program as proposed. We are putting in 9 monitoring wells near both the mining site and the Hay gulch aquifer.As discussed below, Black Mountain will provide proof of permits prior to well installation as well as quarterly sampling results to the state. Regarding the timing of data collection, requiring water quality samples twice a month is overly onerous since the water quality trends in the area don't change that much on a day to day basis, as confirmed by Bijou itself during the June 11th meeting. • "It appears BMS will be relying on the data from these monitoring wells to ensure compliance with this commitment [staying at least two feet above the groundwater table]. Under these circumstances, BMS should be required to collect data from the monitoring wells at least twice per month during the"life of the mine"—Black Mountain's voluntary groundwater monitoring program will comply with all rules and regulations for monitoring wells. • "In Addition, as this data collection is being done to address concerns raised by Bijou' about impacts to its water rights, BMS should be required to share the collected data with Bijou."- Black Mountain has previously agreed multiple times, including during the onsite meeting with Bijou and the conference call with Bijou's hydrology consultant to share data with Bijou. • "Bijou has suggested to BMS that transducers be installed in the monitoring wells to assist with the data collection process, but is not clear about BMS's position on that item."—Black Mountain, after discussions with both Bijou's board and Bijou's hydrology consultant, committed to looking into the cost and process of installed such transducers. At the moment, Black Mountain is moving forward with the groundwater monitoring program as proposed and is still evaluating transducers. • "Recognizing that areas of the mining footprint will be in a state of flux during the mining operations, Bijou believes that BMS should take measurements at the"permanent"areas of the mine site (parking areas, equipment storage areas,fueling locations, etc.)to prevent the introduction of hydrocarbons into the soil.This goal would likely be best achieved by paving these areas. It is not clear to Bijou from the amended permit application what areas of the Lost Creek Mine site would (or might) be paved."—A single groundwater monitoring well is proposed for installation within the "permanent areas" of the plant, as discussed in the permit application and as was discussed with Bijou and their hydrology consultant.Additional wells located within the parking areas, equipment storage areas, or fueling location, etc.would run the risk of being damaged by the equipment moving around the site during