2020-08-07_REVISION - M1980244 (11)

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ICMC RECERTIFICATION SUMMARY AUDIT REPORT PRINCIPLE 4 — OPERATIONS Manage Cyanide Process Solutions and Waste Streams to Protect Human Health and the Environment Standard of Practice 4.1: Implement management and operating systems designed to protect human health and the environment including contingency planning and inspection and preventative maintenance procedures. ® in full compliance with CC&v is: ❑ in substantial compliance with Standard of Practice 4.1 ❑ not in compliance with Summarize the basis for this finding: The operation is in FULL COMPLIANCE with Standard of Practice 4.1; implement management and operating systems designed to protect human health and the environment including contingency planning and inspection and preventative maintenance procedures. The CC&V operations are currently composed of the HGM,ADR1, VLF1,ADR2,VLF2,the PSES Plant,the External Storage Pond (ESP)and associated concrete and lined secondary containment structures, process solution transfer pipes,valves, and pumps. CC&V has developed and implemented written operating procedures describing the standard of practice necessary for the safe and environmentally sound operation of these cyanide facilities, including the specific measures needed for compliance with the Code and regulatory requirements. The new cyanide facilities constructed since the 2014 recertification audit report include: 1)the HGM that consists of grinding,flotation CIP circuits with final gold recovery to improve gold recovery from some of the site's higher grade ore deposits; 2)ADR2 that consists of reagent grade cyanide mixing and storage facilities,four carbon trains, an acid wash circuit, a carbon strip and regeneration circuit,and an electrowinning circuit and refinery. Barren solution is conveyed to VLF2, 3)VLF2(Phase 1)that added approximately 63 acres of heap leach facilities to the CC&V operations, and 4)the PSES Plant, designed and constructed to improve gold recovery by removing metal precipitate solids in the VLF process solution and allowing a more sustainable and even distribution of barren solution onto the VLF. The procedures include process descriptions,operating tasks, inspections, maintenance and shut down procedures.The procedures have been updated, as needed,to reflect changes in procedures and new cyanide facilities/process during the recertification period.Verification of the written procedures included review of the procedures and plans, as well as interviews. CC&V has various procedures, permit documents,and plans that identify the assumptions on the facility design and also include contingency actions for various scenarios related to cyanide. For example,the Procedure 25 for Water Balance Management describes the parameters required for safe operation of the Process Solution Storage Areas(PSSAs)including their maximum operating levels, action levels, reporting levels and total volume levels.The Permit M 1980 244 for Mine Life Extension 2 includes the design storm events and geotechnical considerations taken into account for the design of the VLF areas and for the water balance. In addition,the Permit M-1980-244 for Mine Life Extension 2 (under Section 14.6)includes procedures for cyanide management in the event of temporary cessation of the mine.These procedures consider circulation of solutions, and monitoring and maintenance of the water balances associated with the VI-Fs. The Discharge Permit Number CO0043648 authorizes discharges from Outfall 005B(from the ESP to Arequa Gulch)to prevent an overflow od the VLF facilities in case of upset conditions only, prior treatment of the WAD cyanide in the ESP.The Discharge Permit provides discharge limitations, including daily maximum and minimum numerical values for WAD cyanide, and monitoring requirements.The operating procedures for the process areas cover the operational requirements for all tanks,valves, pipes, and other equipment with regard to elements such as tonnages, densities, pH, and cyanide concentrations. c CC&V Mine July 28,2017 Name of Faality Signature of lead Audiror Date July 2017 Golder Report No.1663584-003-R-RevO 9 Associates