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NEWMONT <br /> Va,ni nCnt Vli'li'I :rJCr3ULI I <br /> K 4GVLF- L nderdrain Pumpback St-stem, <br /> h. External Storage Pond(ESP). <br /> i. Off liner pregnant and barren solution pipelines, <br /> j. SG VLF VLF? (including the leak detection sistem), <br /> k. VLF? L/nderdrain Pondd, Bulk Emulsion Facility. <br /> 1. Bucklev.-lnnex,Bulk Emulsion FacilitY. <br /> Please include all 12 of these,facilities in Table I-L2. <br /> Newmont Response: <br /> The Rules identify an Environmental Protection Facility(EPF)as. ..."a structure which is identified in the <br /> 'Environmental Protection Plan' as designed, constructed and operated for control or containment of <br /> designated chemicals, uranium, uranium by-products or other radionuclides, acid mine drainage, or toxic <br /> or acid-forming materials that will be exposed or disturbed as a result of mining or reclamation <br /> operations." <br /> As such, the operator is required to identify these facilities within the Environmental Protection Plan <br /> (Exhibit U). While the initial submittal met this requirement, CC&V appreciates DRMS' response. A <br /> number of the facilities identified in DRMS' response may contain or convey designated chemicals. <br /> < However, they exist entirely within another EPF. Therefore, while these facilities offer redundant <br /> protection to the environment, they are not included as stand-alone EPFs. Additionally, DRMS' request to <br /> include Buckley Annex and the Bulk Emulsion Facility as an EPF fails to consider the definition of an <br /> EPF within the Rules, as these facilities do not contain designated chemicals. <br /> Figure U-I has been updated to reflect the current Phase 3 design. Table U-2 has been updated to include <br /> the ADR-1 (as this ties into the VLF liner, but does not exist entirely over the VLF1 liner), the <br /> Enrichment Building, and process pipelines over un-lined areas. There is one small portion of pipelines <br /> over unlined areas, which falls between the VLF 1 and VLF ? liners,just east of the HGM. This is not <br /> shown in Figure U-1 as it is too small to show up on the map. Updated Figure U-1 and Table U-2 are <br /> included in Attachment 4. <br /> DRMS Comment(italics): <br /> 58. Section S.1. The lust .sentence in this section is misleading, Figure G-1 indicates that there are <br /> domestic water wells near the affected land boundary indicating that groundwater is developed in <br /> the area and mal•be developed in the,future. Please remise for accuracy. <br /> Newmont Response: <br /> The last sentence in Exhibit U. Section 8.1 has been updated to, "As noted in Exhibit G, deep-diatreme <br /> groundwater is not developed for use in this area and is not anticipated to be developed for use in the <br /> future considering the overall lack of groundwater. " <br /> DRMS Comment(italics): <br />