2020-08-07_REVISION - M1980244 (11)

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ICMC RECERTIFICATION SUMMARY AUDIT REPORT the cyanide mixing and storage tanks out of cast in place reinforced concrete. In addition,the secondary containments are underlain by a LLDPE geomembrane liner acting as a tertiary containment system.The secondary containments have a sump with a dedicated automatic pump at the three process areas to return any spilled material collected in the secondary containments to the cyanide storage tanks.The ADR1 geomembrane liner is sloped to VLF1, and the ADR2 and HGM geomembrane liner is sloped to VLF2.The cyanide offload pads and secondary containments provide adequate containment for the recovery of cyanide liquid spills_The auditors observed the cyanide offload pads and secondary containments of the cyanide mixing and storage tanks to be in good condition. CC&V has installed level indicators and high-level alarms to prevent the overfilling of the cyanide mixing and storage tanks at ADR1,ADR2, and the HGM. Interlock system with automatic shut off valves that prevents overfilling of the tanks have been installed at the ADR2 and HGM tanks. No changes or modifications have been made to the ADR1 cyanide mixing and storage tanks since the 2014 recertification audit.The auditors observed screen shots in the control room to verify that the level sensors were working. In addition,the auditors reviewed completed monthly preventative maintenance records for tank level indicators and level alarms for the recertification period_CC&V has also implemented procedures to prevent overfilling.The CC&V reagent operator verifies that the tank levels are low enough to receive the expected delivery. In addition,the cyanide supplier, Cyanco, has remote telemetry monitoring of the cyanide tank levels to track cyanide usage and inventory, allowing them to dispatch cyanide loads when needed.Tank levels before and after cyanide offloading are documented on checklists, as well as on the Cyanco bills of lading. All the cyanide mixing and storage tanks are located apart from foods,animal feeds, acids, strong oxidizers, and explosives;smoking is prohibited and signed accordingly.The cyanide mixing and storage tanks at ADR1,ADR2, and the HGM are located within their own containments. Standard of Practice 3.2: Operate unloading storage and mixing facilities using inspections, preventative maintenance,and contingency plans to prevent or contain releases and control and respond to worker exposures. ® in full compliance with CC&V is: ❑in substantial compliance with Standard of Practice 3.2 ❑not in compliance with Summarize the basis for this finding: The operation is in FULL COMPLIANCE with Standard of Practice 3.2; operate unloading storage and mixing facilities using inspections, preventative maintenance, and contingency plans to prevent or contain releases and control and respond to worker exposures. Cyanide is delivered in fully enclosed steel ISO containers.The liquid cyanide is transferred from the ISO containers to the cyanide mixing and storage tanks.The ISO containers are used only for the delivery(and mixing of the cyanide when the Cyanco SLS process was in use);therefore, no empty cyanide containers require disposal or treatment.The empty ISO containers are returned to Cyanco immediately after the offloading is completed. The Procedures for Cyanide Truck Unloading: Solid Product requires that a triple rinse of the ISO container be conducted once the transfer of the cyanide is completed.The CC&V reagent operator must also inspect the ISO container with the driver to ensure that the load has been completely dissolved.The driver signs and dates a"Certificate of Cleanliness"certifying that the ISO container has been triple rinsed with fresh water. Estimated residue left in trailer is documented on the"NaCN Batch Record"checklist and signed by the driver and the CC&V reagent operator. In the case of the offloading of liquid cyanide,the Procedures for Cyanide Truck Unloading: Liquid Product requires that a general inspection of the ISO container is conducted of the top and sides of the ISO containers to ensure that spillage or leaks have not occurred during the offloading and disconnecting activities.This inspection is documented on the"NaCN Batch Record"checklist and signed by the driver and the CC&V reagent operator.The auditors observed an offload CC&V Mine July 28,2017 Name of Facility SignaWre of Lead Auditor Date July 2017 Gd&r Report No.1663584-003-R-RevO 7 A modates