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2019-10-03_REVISION - M2018051
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2019-10-03_REVISION - M2018051
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Entry Properties
Last modified
12/27/2024 1:10:40 PM
Creation date
10/4/2019 8:00:59 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2018051
IBM Index Class Name
REVISION
Doc Date
10/3/2019
Doc Name
Adequacy Review Response #2
From
Black Mountain Sand Weld, LLC
To
DRMS
Type & Sequence
AM1
Email Name
PSH
Media Type
D
Archive
No
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4 <br /> Black Mountain Sand Weld LLC <br /> 500 Main St. Suite 1200, Fort Worth,TX 76102 <br /> (817) 698-9901 <br /> of file,that of the corporate office in Houston. However, as shown in Attachment 1 of the Adequacy <br /> Response Letter, neither notification letter can be verified as delivered to the address.Therefore, Black <br /> Mountain has sent an additional notice to a Bartlesville, OK address, in which we were advised to send <br /> such documentation to from the office manager at ConocoPhillips as a good faith effort at notification. <br /> Item 11— Exhibit C6.1 Map <br /> Confidential Exhibit C6.1-6.2 have been updated to include better coloring and labels per the division's <br /> request. Please see Attachment C for a revised confidential Exhibit C6.1-6.2. <br /> Item 13—Utilities within the Affected Lands <br /> Several utilities were identified as being within the permit boundary during as onsite visit. As a follow-up, <br /> Black Mountain contracted a survey company to identify and mark all known utilities within the entire <br /> permit boundary. All known and identified structures or significant,valuable, and permanent man-made <br /> structures are shown on revised Exhibit C2: Pre-Mining Map, found in Attachment C. Please see Attachment <br /> C for a final map of all located utilities by the survey company. <br /> Item 17—Reclamation Plan <br /> Black Mountain will conduct four(4) quarters of groundwater quality analysis for the complete list of <br /> parameters listed on Tables 1-4 prior to reducing the testing parameters for the life of the mining operations <br /> to parameters listed on Tables 3 and 4 of the Colorado Water Quality Commission's (WQCC) Regulation No. <br /> 41, except that Black Mountain provides the below justification for why certain parameters should not be <br /> tested during this first year: <br /> • Total Coliforms—the project is not proposing to source any groundwater for a domestic water supply <br /> and testing for the presence of co►iforms in groundwater presents a logistical challenge given the test <br /> hold time and the location of the wells. The hold time for coliform testing is only 2 hours.This means <br /> that during each round of testing, water samples would need to be collected from a single well and then <br /> driven directly to the lab to meet this holding time. Sampling 9 wells in this manner will cause a <br /> significant hardship for Black Mountain. As such, Black Mountain does not believe testing for total <br /> coliforms is warranted in the baseline program. <br /> • Asbestos—the site is not in proximity to any large industrial areas or landfills that may contain <br /> significant amounts of buried asbestos product that could be released into the groundwater system. <br /> Additionally, site operations will not emit asbestos containing materials into the environment. As such, <br /> Black Mountain does not believe testing for asbestos is warranted in the baseline program. <br /> • Chlorophenol -chlorophenol groundwater contamination is generally associated with industrial waste <br /> discharges, leaching from landfills, and chlorination of wastewater containing phenols.The site is not <br /> potentially affected by any of these activities. As such, Black Mountain does not believe testing for <br /> chlorophenol is warranted in the baseline program. <br /> • Foaming Agents-Testing for foaming agents is generally recognized as an aesthetic parameter as these <br /> agents can give water an unpleasant appearance that may reduce the desirability of the water for <br /> drinking. The site operations will not introduce any foaming agents to the environment. As such, Black <br /> Mountain does not believe testing for foaming agents is warranted in the baseline program. <br /> • Odor-Testing for odor is generally recognized as an aesthetic parameter as the presence of an odor <br /> may reduce the desirability of the water for drinking. Additionally,judging odor is a subjective issue and <br />
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