2020-08-03_REVISION - M1980244 (11)

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ICMC RECERTIFICATION SUMMARY AUDIT REPORT PRINCIPLE 3 – HANDLING AND STORAGE Protect Workers and the Environment during Cyanide Handling and Storage Standard of Practice 3.1: Design and construct unloading, storage and mixing facilities consistent with sound, accepted engineering practices, quality control/quality assurance procedures, spill prevention and spill containment measures. CC&V is: in full compliance with Standard of Practice 3.1 in substantial compliance with not in compliance with Summarize the basis for this finding: The operation is in FULL COMPLIANCE with Standard of Practice 3.1; design and construct unloading, storage and mixing facilities consistent with sound accepted engineering practices, quality control/quality assurance procedures, spill prevention, and spill containment measures. Two new cyanide offloading and storage facilities have been constructed since the 2014 recertification audit, one as part of the construction of the HGM and the other as part of the construction of ADR2. The HGM started operation in 2015 and ADR2 in March 2016. These new facilities were designed and constructed to employ a dissolution system (Cyanco solid to liquid system [SLS]) with a cyanide mixing tank and a cyanide storage tank and corresponding pump and pipe systems, in a similar manner to the existing cyanide offloading and storage facilities at ADR1. The cyanide ISO container (when delivering cyanide) sits on a curbed concrete pad, sloped to drain to a sump located within the reinforced concrete secondary containment of the mixing and storage tanks. The new cyanide offloading and storage facilities at ADR2 and the HGM are designed and constructed in accordance with sound and accepted engineering practices. The auditors reviewed design, as built and QA/QC documentation for the earthworks, tanks foundations, liner installations, and tank and pipe installations of these facilities to verify compliance. Documentation reviewed by the auditors was stamped by professional engineers or project managers from CC&V who oversaw the construction of these facilities. In June 2016, the piping systems of the cyanide offloading facility at ADR1, ADR2, and the HGM were modified to also receive liquid cyanide. These modifications were designed, supplied, and installed by Cyanco, the cyanide supplier. No other modifications have been made to these facilities since the 2014 recertification audit. The auditors observed that these facilities at ADR1 were in good condition and had been regularly maintained. Since January 2017, CC&V has only been receiving liquid cyanide. The cyanide offloading and storage areas at ADR1, ADR2, and the HGM are located away from offices and areas where workers may congregate. The nearest communities (Victor and Cripple Creek) are located approximately two miles from these facilities. No surface water bodies are nearby. The cyanide offloading and storage areas at ADR1, ADR2, and the HGM are all located within the security perimeter of the mine. As indicated in the 2014 recertification audit report, two ISO containers remain on site. These containers are parked next to the PSES Plant within a geomembrane-lined area, also within the security perimeter of the mine. These containers are maintained on site in case of a delivery related contingency and have their valves locked. Only authorized people can access the gated mine entrance areas. The entrance areas are with 24-hour security to restrict public access. In addition, the access point to the secondary containment of the cyanide mixing and storage tanks are chained and locked. Also, all the cyanide high strength distribution lines to the process areas have valves that are properly locked out. The cyanide offloading and storage areas are located outside with adequate ventilation. Cyanide is offloaded on concrete pads, underlain by a linear low-density polyethylene (LLDPE) geomembrane liner at ADR1, ADR2, and the HGM. The offload pads are sloped to drain to the secondary containment of the mixing and storage tanks. CC&V has constructed the secondary containments for all of CC&V Mine Name of Facility __________________________________ Signature of Lead Auditor July 28, 2017 Date July 2017 Report No. 1663584-003-R-Rev0 6