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• <br />3. HANDLING AND STORAGE Protect workers and the environment during <br />cyanide handling and storage. <br />Standards of Practice <br />3.1 Design and construct unloading, storage and mixing facilities consistent <br />with sound, accepted engineering practices and quality control and <br />quality assurance procedures, spill prevention and spill containment <br />measures. <br />The operation is: ^ in full compliance <br />^ in substantial compliance <br />^ not incompliance ...with Standard of Practice 3.1. <br />Discuss the basis for this Finding/Deficiencies Identified: <br />• <br />• <br />Records review indicated awell-documented Quality Assurance/Quality Control <br />(QA/QC) program for the construction and expansion of the ADR and adjacent <br />cyanide unloading and mixing facilities. Suitability of materials, use of acceptable <br />soil compaction techniques, liner installation, and appropriate record-keeping were <br />all confirmed. All unloading, mixing, and storage of cyanide takes place in a <br />dedicated, bermed concrete pad constructed adjacent to the ADR. The potential for <br />seepage to the subsurface is extremely low as the entire area is underlain by a <br />welded-seam HDPE liner system that is sloped to drain towards the pipeline <br />corridor at the toe of the VLF. The conceptual design of the ADR was submitted <br />and approved by the permitting agency, which also received and approved copies <br />of all as-built drawings. Individual ADR design drawings and specifications for <br />both the original construction and expansion phases were approved by a registered <br />professional engineer. <br />The ADR is located within the fenced security perimeter of the project. The <br />nearest habitations are in Victor, in a separate drainage about 1.5 miles to the <br />southeast of the ADR entrance. All ADR drainage is to the pipeline corridor on <br />the perimeter of the VLF and therefore managed as part of the containment <br />features of the VLF design. Any spillage will report to the pregnant solution <br />ponds, from which it can be pumped back to the ADR. In extreme storm events, <br />drainage can be routed to a 22 million gallon external storage pond, from where <br />it can also be pumped back to the ADR. <br />Cripple Creek & Victor <br />Name of Mine <br />~~ <br />Signature of Lead Auditor <br />10 September 2007 <br />Date <br />Page 8 of 38 <br />