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1.0 PHASE 1 -SITE PREPARATION <br /> Phase I of Task 1 will address the various site preparation requirements necessary to effectuate <br /> the CAP, to include establishment of interim material relocation area(s), interim management of <br /> the various materials to be removed from the composite liner system, and other measures that <br /> ensure protection of the environment, all of which are to be carried out in general accordance with <br /> the requirements of the Hard Rock/Metal Mining Rules, and more specifically, Sections 3.1.5, <br /> 6.4.21, 7.3, and 6.4.21 thereof, respectively. <br /> At present, there are three types of material(s) present within the designated environmental <br /> protection facility (EPF), otherwise referred to as the tailing storage facility: (1) meteoric <br /> precipitation accumulation — an authorized content component; (2) an estimated +/-140-tons of <br /> tailing materials and entrained water as derived from gravity-only processes—also an authorized <br /> content component; and, (3) waste rock and bank run (natural) weathered rock materials which <br /> were introduced atop the composite liner system, and which are a non-authorized content <br /> component. The latter, placement of non-authorized waste rock (and bank run) materials atop <br /> the composite liner system (see Attachment 1: Site Photographs) has been determined by <br /> DRMS to have potentially compromised liner system integrity, thereby rendering previously- <br /> issued DRMS certification of the subject environmental protection facility(EPF)void, and resulting <br /> in the requirement that VRI develop and implement the subject CAP in order to effectuate EPF <br /> recertification. <br /> In essence,the CAP will incorporate the removal,disposition and/or interim relocation of materials <br /> currently residing within the EPF; inspection and repair of the composite liner system (as <br /> determined necessary and to the extent determined technically and/or economically practicable); <br /> and, recertification of the (repaired) composite liner system component of the EPF. On <br /> completion of the recertification process, it is anticipated that those materials that were subject to <br /> interim relocation would be designated feedstock(s) for future processing (milling) activities once <br /> milling operations are restored. In the event VRI determines that it is non-practicable to restore <br /> the EPF to certifiable status (from either a technical or economic based decision process), those <br /> materials subject to interim relocation would at that time be dealt with in a to-be-determined <br /> manner. Absent current knowledge as to the extent of damage (if any) to the composite liner <br /> system, and therefore the current inability to define the extent and cost associated with any <br /> necessary remedial measures, VRI cannot at this juncture commit to a specific final disposition <br /> method (due to business reasons); however, VRI does acknowledge the responsibility and <br /> reasserts the commitment to carrying out the CAP in accordance with the requirements of the <br /> Colorado Hard Rock/Metal Mining Rules. To that end, the respective components of the CAP will <br /> be carried out as sequentially discussed below. <br /> 1.1 Establish Staging and Stockpile Area <br /> VRI will first establish an internal staging and stockpile area at the higher elevation bench <br /> immediately upgradient of the EPF's concrete barrier wall and the associated (potentially <br /> compromised) Phase 1 composite liner system. This staging/stockpile area, will be graded and <br /> 2 <br />