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Off -road vehicle traffic and equipment use by RGS and contractor vehicles will be prohibited <br />except in emergency conditions. All roads or disturbed areas used by RGS and contractors will <br />be graveled with an all- weather material <br />Although not anticipated, Road crossings of ephermal, intermittent and perennial drainages will <br />be made perpendicular to flow direction. Where conditions dictate, RGS will properly install <br />temporary culverts at road crossing of perennial drainages to prevent degradation of the stream <br />banks. These culverts will be removed as part of road reclamation, and the disturbed areas will be <br />reclaimed. <br />3) Phased BMP Implementation. The SWMP shall clearly describe the relationship between <br />phases of construction, and the implementation and maintenance of both structural and <br />non - structural stormwater management controls. The SWMP must identify the <br />stormwater management controls to be implemented during the project phases, which <br />can include, but are not limited to, clearing and grubbing; road construction; utility and <br />infrastructure installation; vertical construction; final grading; and final stabilization. <br />RESPONSE: The BMPs discussed in (1) and (2) above will be installed before the start of the <br />construction activities and will be maintained throughout the life of the project. Reclamation work <br />will be conducted as soon as practical after exploration work is completed. <br />4) Materials Handling and Spill Prevention. The SWMP shall clearly describe and locate all <br />practices implemented at the site to minimize impacts from procedures or significant <br />materials (see definitions at Part I.E.) that could contribute pollutants to runoff. Such <br />procedures or significant materials could include: exposed storage of building materials; <br />paints and solvents; fertilizers or chemicals; waste material; and equipment maintenance <br />or fueling procedures. <br />Areas or procedures where potential spills can occur must have spill prevention and <br />response procedures identified in the SWMP. <br />RESPONSE: See above responses in Part I.C.3, Stormwater Management Plan (SWMP) — <br />Contents: Identification of Potential Pollutant Sources. <br />5) Dedicated Concrete or Asphalt Batch Plants. The SWMP shall clearly describe and <br />locate all practices at the site to control stormwater pollution from dedicated concrete <br />batch plants or dedicated asphalt batch plants covered by this certification. <br />RESPONSE: Not applicable. The San Juan Silver Exploration Project does not have a dedicated <br />concrete or asphalt batch plant. <br />6) Vehicle Tracking Control. The SWMP shall clearly describe and locate all practices <br />implemented at the site to control potential sediment discharges from vehicle tracking. <br />Practices must be implemented for all areas of potential vehicle tracking, and can <br />include: minimizing site access; street sweeping or scraping; tracking pads; graveled <br />parking areas; requiring that vehicles stay on paved areas on -site; wash racks; contractor <br />education; and /or sediment control BMPs, etc. <br />RESPONSE: See above response (2) in Part I.C.3, Stormwater Management Plan (SWMP) — <br />Contents: Identification of Potential Pollutant Sources. <br />7) Waste Management and Disposal, Including Concrete Washout. <br />112 East 12 Street P.O. Box 610 Creede, CO 81130 <br />719 - 658 -1080 Fax 719 - 658 -1082 <br />