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a. First and foremost, why was the Division not notified of this damage to an environmental <br /> protection facility (EPF) on or shortly after April 27th? <br /> The initial response provided in the PAR was incorrect in attributing holes in the <br /> geomembrane liner on the 9850' bench to damage caused by equipment during <br /> header relocation activities. As part of the initial liner investigation, holes were <br /> installed to allow probe placement beneath the liner during resistivity analyses. <br /> These probe locations are not a failure of the liner system,but rather, part of the <br /> overall investigation and recertification process. <br /> b. What was the extent of this small and large hole damage?Please provide a map with your <br /> response narrative. <br /> The repaired areas,including location and dimensions, are identified in appendix <br /> E.9 (attachment 1). <br /> A map of the repair locations is provided in Attachment 2 <br /> c. Please provide documentation the repairs made specifically to the liner damaged by the <br /> header removal were tested and approved in accordance with the approved specifications. <br /> The repaired areas were documented in accordance with the approved <br /> specifications and observed by the certifying engineer as shown in appendix E.9 <br /> (attachment 1). <br /> d. Why was the certification report narrative completed prior to repairs being completed? <br /> The Record of Construction,VLF2 Recertification Report,9750 -9900' Elevations <br /> (Recertification Report)was compiled once all of the new 80 mil LLDPE <br /> geomembrane liner(new geomembrane)was installed and accepted by all the <br /> parties involved (NewFields, CC&V,Ames and Comanco). Final acceptance of the <br /> new geomembrane was completed on July 13,2018. The draft report was issued for <br /> review to CC&V on July 18, 2018. The initial narrative in the draft report did not <br /> include a discussion for repair of holes outside the recertification area (discussed <br /> below) as this work was unknown at the time. <br /> On August 11, 2017, Comanco completed the following repairs on the geomembrane: <br /> • Patching over the existing nine vent holes on the new geomembrane at the crest <br /> of the 9,850' and the 9,900' benches <br /> • Patching over seven holes,located outside the recertification area, along the <br /> 9,850' bench. <br /> The above repairs were included in the Final Recertification Report, dated August <br /> 17,2018, and the documentation can be found in the Field Daily Progress Reports, <br /> report dated August 11, 2018 and in the Appendix E.9 Geomembrane Defect/Repair <br /> Summary table. <br /> As previously discussed in NewFields letter dated October 5,2018,the <br /> Recertification Report's narrative didn't include a discussion of the repairs outside <br /> the recertification area. The information that NewFields initially received from <br />