2020-08-07_REVISION - M1980244 (11)

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ICMC RECERTIFICATION SUMMARY AUDIT REPORT event. Solution from PSSA Phase 1 overflowed into PSSA Phase 2, but no overflow from PSSA Phase 2 into the ESP occurred. Precipitation data have been collected from 3 meteorological stations that represent site conditions(a historic station referred to as the Victor station with a data record from February 1966 through February 1976,a station established by CC&V on site near Bateman Creek with a data record since 1994,and most recently the Rigi station with a data record since 1999). During the recertification period, design assumptions were reviewed based on collected precipitation data in the area. Precipitation data from the historic station at Victor from 1966 through 2012 was used for the 2015 update of the GoldSim model. Precipitation data collected at these three stations is also used for the regular updates of the operational model. Standard of Practice 4.4: Implement measures to protect birds,other wildlife,and livestock from adverse effects of cyanide process solutions. ® in full compliance with CC&V is: ❑ in substantial compliance with Standard of Practice 4.4 ❑ not in compliance with Summarize the basis for this finding: The operation is in FULL COMPLIANCE with Standard of Practice 4.4; implement measures to protect birds, other wildlife, and livestock from adverse effects of cyanide process solutions. CCC&V has implemented measures to control bird,wildlife,and livestock access to process areas. No open waters whether the WAD cyanide concentration is greater than 50 mg/L are present at CC&V operations since all the PSSAs are subsurface per design.There is a small stormwater pond, located on VLF2 downgradient from the HGM building, and a small stormwater trench, located between ADR2 and the toe of VLF2.These two facilities only receive stormwater but have been covered with HPDE bird balls as a preventive measure in case solution would enter these structures during an extreme contingency condition in these process areas.The ESP, located at the southem (downgradient)side of VLF1, is not an operational pond, but process solution would be introduced to this pond during an extreme upset condition at the VLF1 PSSA.This pond only contains enough precipitation/freshwater to help maintain the pond bottom liner. No solution has been stored in this pond during the recertification period.The auditors reviewed analytical results from 2014 to 2016 for the ESP to confirm this. CC&V has installed a fence around most of the property to prevent livestock access.The ESP is completed fenced. CC&V has not experienced significant wildlife mortality during the recertification period.Three wildlife mortalities have occurred at different times during the recertification period and only one of them was related to cyanide during an upset condition.The auditors,therefore, consider each instance to be isolated.CC&V notified CPW of these mortalities as required in the Wildlife Protection Plan.The auditors reviewed the Cintellate report for these mortalities to verify compliance. CC&V uses buried drip emitters to apply leach solution to the tops of the heaps to minimize freezing and ponding. Drip lines on the sides of heaps remain on the slope surface,where the potential for ponding is low due to the steep slopes. Overspray is effectively eliminated with the drip emitters.CC&V has developed procedures for control of ponding on the leach pads.These procedures described corrective measures to be applied to areas of standing process solution,which are defined as a surface area larger than 3 feet by 3 feet. Corrective measures include to level and rip the area as soon as possible,and employing fencing, bird balls, and/or netting where standing process solution cannot be avoided.The auditors did not observe ponding at the time of the site visit to confirm that operating procedures to prevent ponding are being implemented. CC&V Mine j July 28,2017 Name of Faddy Signature of Lead Auditor Date July 2017 Report No.1663584-003-R-RevO 12 ASSOC18tes