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NEWMONT NeNrci M,. ,, _rC r9[I_ <br /> Os4s. <br /> a. Please explain and provide details of the designated chemicals which are contained in the <br /> permitted Overburden .Ytorage .-lreas or revise this section and remove the reference to <br /> O'Us. <br /> b. This section also included information regarding open-top tanks located tit the HG Rlill. <br /> Please revise this section to include the PV,S and its associated open-top tanks. <br /> Newmont Response: <br /> a. This is an error: there are no designated chemicals contained in the Overburden Storage Areas <br /> (OSAs). Please see the revised Environmental Protection Plan in Attachment 4. <br /> b. Please see the revised Environmental Protection Plan in Attachment 4. <br /> DBMS Comment(italics): <br /> 65. Exhibit U-Section 18.1. Events Requiring Reporting includes the requirement to report a scenario <br /> regarding a fciilure or imminent failure of impoundment, embankment, stockpile or VLF slope that <br /> poses potential danger to human health, properh' or the environment. In accordance with Rule <br /> 8.1(a), please revise this scenario to unv.slope instead of'a slope exclusive to a VLF. <br /> Newmont Response: <br /> Section 18.1 of Exhibit U has been updated to require CC&V to notify DRMS of any slope failure that <br /> meets Rule 8.2 (a) requirements. <br /> DRMS Comment(italics): <br /> 66. Exhibit U- Section 18.1. Events Requiring Reporting (as well as Exhibit G — Section 3.3 Phase 3 <br /> PSSA .Monitoring) lists the permit criteria for reporting scenarios of exceedances of permit <br /> conditions. Regarding the High l'olume Solution Collection Svstem (HUS('S), the.4pplicant states <br /> the permit criteria is the average ql the water level monitoring data in the PSS-I.s exceed SO percent <br /> of'the total c•apaciri�of the PSSA in a sustained manner. Please provide details regarding how the <br /> .4pplicant determines what the average water monitoring data is and how the data,from pump levels <br /> vs pond levels is used Please also provide details regarding how the.-lpplicant determines how long <br /> a sustained manner is. <br /> Newmont Response: <br /> CC&V determines the volume of the HVSCS through continual monitoring of the pond levels and the <br /> pump levels within each PSSA. For VLF 1 Phases 1, ?, and mil, and VLF? PSSA, CC&V uses the pond <br /> level well measurement as the contained volume of the PSSA. For Phase 5 the pond level is determined by <br /> calculating the average of the pump levels within the caissons of the PSSA. <br /> Due to several factors, including variability in environmental conditions, a sustained manner will be <br /> determined based on field conditions, controls in place and response efficacy. Generally, a sustained <br /> manner in the context used in Exhibit U, is when typical operational controls fail, or may fail, to reduce <br />