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achieved; however, other options must remain available to Venture until such time that repair and re- <br /> certification are deemed viable. In the unanticipated event that site closure evolves to be the preferred <br /> alternative,closure and reclamation activities will be undertaken consistent with permit requirements. <br /> 3) Comment No.3-RE: "Various steps(of the plan)must correlate to specific dates or to a general <br /> timeline". <br /> Venture has provided herein(see response to Comment No.2,above)a projected schedule of performance, <br /> by individual task. Venture provides this timeline estimate in good faith; however, we note that specific <br /> findings or determinations at any phase may result in unanticipated impacts to the projected timeline, as <br /> will potential scheduling constraints(i.e.,availability)for specialty contractors,unforeseen weather events, <br /> and/or other factors beyond the control of Venture. Nevertheless, Venture will strive to accomplish all <br /> components of the proposed corrective action plan in a timely and efficient manner. <br /> 4) Comment No.4-RE: "The Division will require the Operator to utilize additional methodologies <br /> (to supplement visual inspection)that are quantifiable...to test the integrity of the liner". <br /> As stated in our May 20,2016 Technical Revision transmittal,Venture will employ additional liner integrity <br /> testing procedures (beyond visual observation), as determined appropriate and dependent on the extent or <br /> degree of damage (if any) observed following removal of the non-approved materials. Methods to be <br /> employed will be limited to non-destructive test procedures, to include vacuum box testing and/or air <br /> channel pressure testing(ASTM D5820),or other test methods as deemed appropriate by the retained liner <br /> installation and repair firm and/or a retained firm with specific expertise in liner system integrity testing. <br /> Absent information pertaining to the visual confirmation of defects,holes,blisters,tears,or damaged welds <br /> (if any) in the liner system, which will only be available subsequent to removal of the non-approved <br /> material,Venture cannot at this time specify the exact procedure or frequency with which such testing will <br /> be employed. However, we envision that this information will be provided within the document to be <br /> entitled"TR-3 Removal Action Plan and Specifications". <br /> 5) Comment No. 5 — RE: "The primary purpose of the monitoring wells is to detect leaks in the <br /> tailings impoundment liner.....In order to demonstrate the wells were properly constructed, <br /> please provide the Division with copies of the Well Construction Reports". <br /> Venture acknowledges that the approved groundwater monitoring plan is established on a"practice-based" <br /> methodology,with such approval granted largely on the basis of the subject(formerly certified)composite <br /> liner system in the tailings impoundment facility. As the Division so states: "Therefore the primary purpose <br /> of the monitoring wells is to detect leaks in the tailing impoundment liner". Venture concurs with this <br /> statement,and is of the opinion that increased monitoring frequency(in the interim)can only be of benefit <br /> to the overall site status and the proposed liner system corrective action. <br /> To date, all groundwater monitoring episodes (inclusive of those subsequent to the date when the liner <br /> system integrity was potentially affected)have resulted in"dry"monitoring wells,wherein no sample was <br /> found to be retrievable. Thus, it is Venture's contention that any time-forward observed presence of <br /> 5 <br />