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ATTACHMENT A <br /> Page 4 of 9 <br /> concrete berm along the south side of the tanks,but the berm did not fully enclose <br /> the tanks. <br /> 9. The Division also inspected the buildings at the site. At the main <br /> building at the site,the Division observed a rod mill, numerous floatation tanks, <br /> shaker tables, filter presses, and agitator tanks. The mill was not operating during <br /> the inspection,but the Division observed indications that the mill had been <br /> running, including cleanup of spillage from the loader bin, a well-greased mill drum <br /> gear, solution and concentrates within the floatation cells, and sedimentation on the <br /> shaker tables. Cyanide agitator tanks were running during the inspection. <br /> 10. During the Division's inspection of the outside building, staff observed <br /> diesel tanks, generators, scrap metal, and dysfunctional equipment, as well as oil <br /> and fuel spills staining the soil with no secondary containment or spill prevention <br /> employed.There were also two shipping containers on the south side of the building <br /> containing additional equipment,bags of soda ash, and a 55-gallon drum containing <br /> propylene glycol. <br /> 11. A second building to the east of the main building contained ore <br /> stockpiles, an ore sorter, and a conveyor line that went to the main building. <br /> Division staff also observed remnants of supersacks,which indicated shipments of <br /> ore from outside sources. A third building on the east end of the property contained <br /> a kiln,foundry crucibles, and bags of soda ash, which indicated to the Division that <br /> Operator has been smelting metals recovered from the milling process. <br /> 12. The Division's inspection report, dated July 14, 2022, stated that <br /> milling is defined as a Mining Operation under the Act and that based on the <br /> observations made during the July 1, 2022 inspection, the Division had reason to <br /> believe that the Operator was engaged in Mining Operation without first obtaining <br /> a reclamation permit. <br /> 13. The Division also issued a cease-and-desist order at the site because <br /> the use of cyanide, a designated chemical,posed a significant threat to human <br /> health and the environment. The cease-and-desist order prohibits the continued <br /> operation of the mill facility by Operator. <br /> 14. The Division sent a Reason to Believe a Violation Exists and Notice of <br /> Board Hearing letter to the Operator. The letter provided notice regarding the <br /> alleged violations and information about the hearing before the Board, scheduled <br /> for August 17, 2022. <br /> 15. At the hearing, the Division presented testimony regarding the alleged <br /> violations. The Division described the milling facilities at the site,including <br /> Rocky Flats Environmental Solutions,LLC <br /> M-2020.044 <br /> MV 2022-012 3 <br />