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M-1977-410 <br />Technical Revision 10 <br />April 26, 2022 <br />4 <br /> <br />which operated for approximately 3 months Discharged exceedances from the system in the <br />months of July, August and September 2021 proved the system ineffective to treat the mines raw <br />water, despite a guaranteed performance warranty by the OPEL; therefore, GIR removed the <br />system in October 2021. <br />• September 2021 – GIR aggressively pursued alternative treatment vendors, including <br />Environmental Site Solutions, Ensero and Graver; <br />• October 2021 – Graver/MetSorb was selected by GIR to perform bench scale testing which proved <br />successful, and therefore GIR engaged a filtration and metal adsorption pilot design <br />• November 2021 – 11/15 set as startup date for Ensero particulate filtration and Graver/MetSorb <br />metal polishing pilot systems; pre-dating the Service of Notice of Violation/Cease and Desist <br />Order, Number: IO-211130-1 received from CDPHE issued on November 30, 2021 <br />• December 2021 – commissioning and start-up of hybrid treatment system encompassing the <br />approved lime addition and the filtration and adsorption system. The hybrid approach was <br />proposed by GIR to ensure compliance during commissioning and transition between the lime <br />addition and the filtration/adsorption treatment. The approach was discussed with and was <br />approved by DRMS <br />• January 2022 – Pursuant with Service of Notice of Violation/Cease and Desist Order (Number IO- <br />211130-1) from Colorado Department of Public Health and Environment (CDPHE) dated <br />November 30, 2021, GIR retained Black Fox Mining (Patrick Delaney –Level-One Certified Water <br />Treatment) as qualified operator for water system evaluation and automation implementation of <br />treatment system automation for continual operation. <br />• February 2022 – system 100% in compliance according to laboratory tests results of water effluent <br />at outfall permit M1977-410; see Table 3 for 2022 Quarter 1 compliance samples