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M-2008-080 - Journey Ventures, LLC - Journey Ventures Pit - 112 (c) Application Preliminary Adequacy Review Response <br />March 5, 2009 <br />-3- <br />10. The applicant has stated that the handling of fuel will conform to all local, State, and Federal <br />regulations. The operator must indicate that there is a Spill Prevention Control and <br />Countermeasure (SPCC) plan in place and that the SPCC plan will be implemented prior to <br />storage of fuel or oil products. This can be done by submitting a letter to the Division, on company <br />letterhead, affirmatively stating that the plan has been implemented The operator does not need to <br />submit a SPCC plan to the Division; however, it must be available for review at the facility or the <br />nearest field office during an inspection conducted during normal business hours <br />A letter is attached acknowledging that Journey Ventures, LLC has a SPCC plan in place and <br />will implement it prior to the storage of fuel or oil products at the Journey Ventures Pit. <br />11. The warm water canal located in the southern portion of the permit area lies within areas that will <br />be excavated Please specify how the operator intends to mine through the canal, Will the canal be <br />relocated and if so, at what point would it be relocated? Please reflect any changes on the Mining <br />Plan Map and the Reclamation Map. In addition, state how the operator will ensure that pre- <br />mining flows of the canal are maintained throughout the mining and once mining is complete. <br />The wetland located in the southern portion of the permit will require obtaining an Army Corps <br />of Engineers 404 permit prior to mining Phase 8. We have provided correspondence with the <br />Army Corps of Engineers by having a jurisdictional determination completed on the wetland <br />areas within the property as indicated in their referral letter to you. The plan, at this point, is to <br />mitigate for removal of the wetland by purchasing wetland bank credits however the 404 permit <br />has not been submitted and will not be submitted until mining commences in Phase 7. The <br />wetland would be removed during the mining of Phase 8. The pre-mining flows are going to be <br />measured such that the flows can be recorded prior to exposing ground water, which will begin <br />in Phase 3, to create a base line of data. During mining JV will be dewatering to recharge <br />ditches that eventually outfall to the culvert crossing at the southeastern edge of the wetland. <br />We anticipate the dewatering flows will be equal to or greater than the pre-mining flows <br />currently being intercepted from the groundwater by the wetland. Once mining is complete the <br />edge of the wetland at the culvert crossing will remain and continue to intercept groundwater, if <br />the flow is cutoff a drain will be installed around the perimeter of the slurry wall such that flow <br />would not be cutoff and discharge to the culvert crossing at Weld County Road 51. The drain <br />will also be installed, if required, such that any mounding effect (if mounding occurs) on the <br />west side of the pit would be mitigated. This also holds true for any shadow effect or cutoff of <br />the seasonal groundwater elevations (if a shadow develops) develops that the drain would <br />equalize the elevations back to seasonal levels. JV has installed piezometers around the <br />perimeter of the pit to measure these levels prior to exposing groundwater which is <br />approximately two years from present. The piezometers will continue to be monitored during <br />mining and after the slurry wall is installed. <br />6.4.5 Exhibit E - Reclamation Plan <br />12. The Reclamation Plan states that a perimeter drain will be installed if needed to convey <br />groundwater around the reservoir. The applicant should identify the trigger(s) that will determine <br />if the drain is needed <br />Journey Ventures, LLC agrees that if differences of 18 - 24 inches or greater occur from the <br />seasonal groundwater data gathered from the piezometers prior to dewatering operations <br />during mining, the perimeter drain will be installed after the slurry wall is installed. The data will <br />V 1400 W 122nd Avenue - Suite 120 • Westminster CO 80234 • Ph: 303-457-0735 • Fax: 303-920-0343