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• <br />Leach solutions are applied via drip emitters, which are buried on the top surface <br />of the heaps. Side hill application of process solution is by unburied drip <br />emitter. Physical examination of the VLF did not indicate any ponding. The <br />leach pad installation Group regularly inspects the VLF during every shift to <br />insure no ponding is occurring. The Process Supervisor also tours the pad area <br />regularly to personally inspect the installation and application rates. <br />4.5 Implement measures to protect fish and wildlife from direct and <br />indirect discharges of cyanide process solutions to surface water. <br />The operation is: ^ in full compliance <br />^ in substantial compliance <br />^ not incompliance ...with Standard of Practice 4.5 <br />Discuss the basis for the Finding/Deficiencies Identified: <br />• <br />• <br />No cyanide-related impacts have occurred to downstream surface water as a <br />result of the Cresson Project. The nearest perennial surface water (Cripple <br />Creek) is about 2 miles from the operation. Although Arequa Gulch is <br />immediately downgradient from the VLF and emergency storage pond, direct <br />inspection and monitoring results indicate that it typically contains no flow; the <br />VLF is operated as azero-discharge facility and does not have any indirect <br />discharges to surface water. The State of Colorado has primacy for the National <br />Pollutant Discharge Elimination System (NPDES) from the U.S. Environmental <br />Protection Agency. CC&V currently has authorizations to discharge under the <br />CDPES for the following: <br />• Arequa Gulch <br />• CDPES General Storm Water <br />• Fourmile Creek Springs <br />• Carlton Tunnel <br />These permits include a "No Discharge' limitation from the VLF, except for <br />flows from the ground water drainage system underlying the VLF. The permits <br />also include a net precipitation exemption from the "No Discharge" limitation. <br />Verbal and written notifications are required to the State in order for any <br />discharge from the VLF to qualify for the exemption. The Storm Exemption from <br />Cresson Project <br />Name of Mine <br />~~~~~ G~ <br />~--~" <br />Signature of Lead Auditor <br />10 September 2007 <br />Date <br />Page 17 of 41 <br />