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In the event that there is a leak in the double-walled process water pipeline system that is sufficient to breach to the <br />environment, the operators are instructed to STOP operations and isolate the pipeline by closing appropriate valves <br />to prevent continued process stream flow. The pipeline shall then be repaired. The area should be allowed to <br />evaporate any escaped liquid water. Any remaining solid residues shall be collected in buckets, etc. and disposed of <br />in the lined tailings impoundment. To further reduce the potential for pipeline leaks, all lines containing process <br />solution or tailings shall be drained when the site is unmanned. A leak event in this pipeline system is subject to <br />Rule 8 reporting requirements. See Exhibit 8 for reporting procedures <br />For more Best Management Practices, refer to the Stormwater Management Plan included in the appendix of this <br />Exhibit C. <br />6.3.3(2)(b) <br />The processing plant facilities have been described at length in 6.3.3(1)(e) and 6.3.3(1)(m). <br />The processed tailings produced are inorganic, consisting of silica & alumino silicate minerals, which are essentially <br />inert and meet SPLP standards for RCRA metals as shown in the attached lab results for waste stream <br />characterization. This waste is water carried via double walled pipeline to a lined settling impoundment. There is <br />zero water discharge and the water and any leachate is nearly 100% recycled back to the mill as process water. <br />A laboratory analysis of the tailings (solid and liquid constituents) are attached to the end of this Exhibit C to <br />demonstrate the relatively inert qualities and the fact that the tailings quality greatly exceeds ambient and pre- <br />existing conditions. <br />The EPA recognized this, and in the cleanup methodology in their ROD R08-88/019 concerning the waste rock <br />problem in this vicinity: <br />"REPROCESSING ALTERNATIVE: THE REPROCESSING ALTERNATIVE CONSIDERS THE <br />TAILINGS AND WASTE ROCK PILES AS AN ECONOMIC RESOURCE AND RECOVERS THE <br />IM IF,RENT MONETARY VALUE WHILE GENERATING A WASTE WHICH MAY NOT BE <br />DETRIMENTAL TO THE ENVIRONMENT." <br />"REPROCESSING WOULD BE A PERMANENT SOLUTION THAT ELIMINATED COLLAPSE OF <br />THE TAILINGS AND WASTE ROCK PILES. A NEW WASTE TAILINGS IS PRODUCED. <br />LEACHING TESTS SHOW THAT THE NEW TAILINGS CANBE DISPOSED INA MUNICIPAL. <br />LANDFILL. (emphasis added)" <br />Despite this, however, the DRMS has determined that practice based ground water protection be applied to <br />this operation through the implementation of a composite liner system under the Tailings Impoundment. <br />Leachate and solid waste qualities are given in the laboratory analysis at the end of this Exhibit C. Both leachate <br />and solids meet or exceed existing water quality. Leachate quality actually exceeds existing groundwater quality by <br />2-3 orders of magnitude in many cases. Metallurgical and corrosion controls require that the pH of the process <br />water be in the range of 7.5-9. <br />Existing ground water quality is indicated in Wildeman's Water Handbook for Metal Mining, page 10, Table Il, <br />column entitled "Central Zone". On page 13 (of the same), Figure 1 shows the effect of raising the pH of this <br />effluent water to 7-8. The method employed in Venture Resources' processing plant has the identical beneficial <br />effect as shown in this Figure 1. This has also been verified by the Company and is evidenced by the waste stream <br />lab sample results. <br />Page 13 of 37