2016-12-19_REVISION - M1980244 (6)

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4 6.4.20 Exhibit T – Permanent Man-Made Structures 13. The Division received a complaint from the Mollie Kathleen operators citing blasting from another nearby underground operation causing safety issues. The response is not adequate. Pursuant to Rule 6.5(4), at sites where blasting is part of the proposed mining or reclamation plan, the Applicant shall demonstrate through appropriate blasting, vibration, geotechnical, and structural engineering analyses, that off-site areas will not be adversely affected by blasting. Based on the response that underground blasting will be “relatively small”, the Division infers the surface blasting in the North Cresson pit will be much larger and as this pit is closer to the Mollie Kathleen than the proposed underground workings, the blasting analyses demonstration should include both the underground blasting (as cited in the complaint) and the blasting in the North Cresson pit. RESPONSE: Please see response to Comment No. 5 above as well as the information provided in Attachment 2. On September 6th, 2016, Mr. Dave Dehlin, Director, Land for Newmont Corporate and Ms. Lisa Becker, CC&V External Relations Manager met with Dennis Lanning to discuss Mr. Lanning’s comment letter and concerns. Mr. Lanning stated that he primarily wanted his concerns on record when he had the opportunity. Lisa informed Mr. Lanning that CC&V would communicate to DRMS that CC&V has met with him and has addressed his concerns and that he was okay with CC&V moving forward with Amendment 11 activities. As of September 2016, Mr. Lanning is in agreement with this statement. 6.4.21 Exhibit U – Designated Mining Operation Environmental Protection Plan Project Description 24. Page 12-13, fourth paragraph – VLF re-contour. The response is not adequate. A review of the reclamation cost estimate in the response referenced Appendix 11, Vol. IV, p. 54 of 109 does not explicitly indicate cross-contour ripping. The Division is not convinced that cross-contour ripping will sufficiently control erosion on such a long slope. In addition, the response suggests trees will be planted to help control erosion. The 2,000 plus slope lengths identified in the Division’s original comment are on the south and west side of the AGVLF. Drawing CCVSA11-3 (in the reclamation cost estimate) indicates trees will be planted on the north and east slopes, thereby providing no erosion protection for the long slope lengths. Finally, pursuant to Rule 6.4.6(b), portrayal of the proposed final land use for each portion of the affected lands shall be shown on the Reclamation Plan Map (Exhibit F, not Exhibit L). Further review of the AGVLF reclamation plan indicates other aspects that need clarification and/or demonstration that the reclamation goals can be achieved. As the AGVLF has reached full build- out (the Division understands that only active leaching is proposed for the remainder of the AGVLF life), it is imperative to begin addressing the specific details of the AGVLF reclamation heretofore having been presented only in a more conceptual plan. This expands the scope of AM-11 to a level that may not have sufficient time to address within the 365-day limit of the AM-11 review process. As such, the Division will consider a conditional approval of AM-11 (with respect to this comment no. 24) with