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NEWMONT <br /> N4e,vm,,rr Vlir•i roGranr MI <br /> A"Project Deviations" section was already included in the initial CQA outline submittal, as part of <br /> Exhibit U. The section can be found between the"Quality Assurance/Quality Control" and the <br /> "Engineer's Opinion" sections of the CQA outline in Exhibit U. <br /> DBMS Comment(italics): <br /> 62. Section 14 Specification Chan. .4 telephone conversation with CC&V representatives on <br /> 130 2020 brought up a proposed change in the specifications for drain cover fill (D('F). The <br /> Division understands CC&V would like to increase the DI00.from I ';-inch minus to 3- inch minus. <br /> Such changes need to he addressed in: .4) the COA Report Deviations section if not part of the <br /> approved specifications when placed, with a rationale explaining whyit is not detrimental to the <br /> originalli•intended purpose, or B)the specifications in permit revision documents such as Technical <br /> Revisions of Amendments. Pursuant to our telephone calls, this DCF change should be addressed <br /> in the CO.4 Report Deviations section,for any DCF placed prior to approval of a revision related <br /> change. If CC&V wishes to make this a permanent change to the specifications, the Division can <br /> consider it as part of AAA 13 if requested and the appropriate rationale is provided in the response <br /> to this comment. [,'Vote: this applies to all specification changes and significant changes to design <br /> drtnt•ingsj <br /> Newmont Response: <br /> CC&V does w ish to make this a permanent change to the specifications as part of AM-]3, the rationale for <br /> which is detailed in the updated design report. <br /> DBMS Comment(italics): <br /> 63. Section 14. There is no U 4-(>C for the back <br /> fill of the pit. Please explain wiry this section is missing. <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 <br /> result of mining or reclamation operations." <br /> By definition, the EPF is limited to the features that are designed to contain designated chemicals. Rule <br /> 7.3 addresses the requirement of a QA/QC report for EPFs. The backfill is not designed to contain or <br /> convey designated chemicals. therefore it does not meet the definition of an EPF and does not require a <br /> QA/QC report." <br /> DBMS Comment(italics): <br /> 64. Exhibit U- .Section 16 Wildlife Protection. This section.states designated chemicals are contained <br /> in the internal PSSAs at the VLFs, in the ADR Facilities, in the HG:11ill Facility, or in the permitted <br />