2022-02-09_PERMIT FILE - M2021046 (6)

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DGM Environmental Monitoring QAPP Section 4 QUALITY ASSURANCE PROGRAM PLAN ORGANIZATION AND RESPONSIBILITY The organizational structure of this QA program includes two participant categories. The first category applies to those persons who actively participate in the program through performing QA and/or QC functions and/or the generation of QA/QC documents. The QA/QC functions of the program are maintained by the active participation of the designated QA Officer(s) and other "Key Individuals". Key individuals are assigned to conduct program tasks such as field measurements, sample procurement, sample analysis, and data documentation. They assure the quality of their work product through adherence to accepted QA/QC practices and documented procedures. The designated Quality Assurance Officer (QAO) maintains the overall surveillance of the program, including guidance and direction. The QAO reports the findings and status of the QA/QC program and the determined need for any corrective action or improvement to the General Manager. The second participant category applies to personnel who serve in a review and/or management capacity. Specifically, this second category consists of those individuals who manage various aspects of the Zephyr Gold USA Ltd. DGM's activities and/or supervise the active QA/QC participants, and/or review QA/QC reports. The DGM's General Manager (Site Manager) has overall responsibility for the conduct, direction, and supervision of the environmental programs at the mine. The General Manager is familiar with all aspects of this QAPP and the QA/QC activities conducted at the mine. He reviews results and findings of the monitoring activities and QA/QC reports and in conjunction with QA/QC personnel, takes appropriate administrative action as necessary to insure compliance with this document's requirements. It is expected that most environmental monitoring QA/QC activities are to be conducted and documented by Surface Operations Personnel who in this QAPP are considered Key Individuals. The QAO is also considered a Key Individual. Zephyr Gold reserves the right to assign QAO and/or other Key Individual duties and responsibilities to one or more of its personnel or designated agents, provided that these individuals do not oversee (in a QA capacity) activities that they are directly responsible for supervising. All key individuals must have either completed training related to the tasks they are assigned to perform or have had adequate related experience. Key individuals are required to familiarize themselves with this QAPP document, with the applicable job procedures and documents, and with all inspection, report, and log forms related to their duties. Specialized training may be required for some tasks or projects. Page 4