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• i <br />Releases to Ground Water <br />CC&V operates a VLF monitoring system and ground water monitoring wells to determine if <br />i <br />releases are occurring from its leaching operations such that ground water quality may be <br />impacted. Releases to ground water, should they occur, are generally not rapid or instantaneous, <br />thus providing appropriate time for evaluation and remediation. CC&V is committed to a <br />DRMS regulatory required response to an increase in certain water monitoring parameters that is <br />contained in Amendment No: 8, Volume I, Project Description page 98 and also in Appendix VII <br />of this document. <br />Spill Path Monitoring <br />If a spill or leak has the potential to migrate from the point of occurrence, spill monitoring will <br />be implemented following clean up. Development of the monitoring plan will be determined by'; <br />the nature and extent of the spill and the potential environmental effects created by the spill. Ally <br />monitoring and sampling will be completed under the direction of the Environmental Resources ~ <br />Department. <br />The potential for spills to migrate from the point of occurrence is minimal. These materials will <br />be quickly absorbed into soil material. If a spill of these materials has the potential to migrate to <br />surface water, a berms) will be placed upgradient of the potential point of entry to the water and <br />surface water monitoring will be implemented downstream, if necessary. All monitoring and <br />sampling will be completed under the direction of the Environmental Resources Department. <br />• Spill monitoring equipment is available on site. Soil along the spill pathway will be monitored <br />and decontaminated and/or moved as necessary. If there is a potential for the spill to migrate off,- <br />site, samples will be obtained expeditiously from down-gradient, existing surface and ground <br />water. stations and any. additional water monitoring points deemed appropriate to monitor the <br />potential migration pathways. The spilled material also may be tested to evaluate the <br />effectiveness of mitigation. <br />VIII. Review, Evaluation, and Revision of Response Procedures <br />All exposure and release incidents and accidents shall be evaluated to identify their cause and <br />determine the measures to be implemented designed to prevent their reoccurrence. Such <br />measures may include equipment changes, revised standard operating procedures, or new or <br />enhanced worker training. ~, <br />CC&V shall review and evaluate the CERP annually and after any incident requiring its <br />implementation. Based on these reviews, the CERP shall be revised as necessary to ensure that it <br />remains current and effective. The date of the most recent review shall be noted on the CERP's <br />title page. <br />CC&V shall- conduct mock emergency drills annually to test its response procedures and <br />capabilities. Some of these drills may be specific to cyanide releases while others may simulate i <br />Cyanide Emergency Response Plan September 25, 2006 <br />EMS: AGANA/CCV Doc.# E-012 <br />S:\4010-00055 CC & V 112(d) Permit Application\ERP, SPCC, FMP\Cyanide Emergency Response Plan.doc Revision 03 <br />-12- <br />