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OBSERVATIONS <br />PERMIT #: M -1980 -244 <br />INSPECTOR'S INITIALS: BMK <br />INSPECTION DATE: July 14, 2011 <br />1) The Division conducted a monitoring, third quarter water sampling and construction progress inspection of the site on July <br />14, 2011. The site was active at the time of the inspection. Present during the site visit were Lawrence Myers and Mark <br />Vanoni. <br />2) Four split samples were collected from CRMW -3A &B, monitoring and compliance wells, and the under drain discharge <br />both the south and 4 inch pipe for Wad cyanide and Sulfate analysis. The CRMW -3A monitoring and 3B compliance well <br />sulfate reading had been fluctuating the past five years. The last quarter data for sulfate was above the 1080 mg/I. The <br />numeric protection level set in 1998 for compliance well CRMW 3B WAS 1070 mg /I. The permit condition requires CC &V to <br />sample within two weeks with the Division taking a split sample. The permit condition requires CC &V to sample with the <br />Division collecting a split sample within two weeks. The Division and CC &V collected a split sample on 07/14/11. The <br />Division is still waiting for the sulfate results. However, CC &V'S independent lab results indicate a value of 1130 mg/I. This <br />will require another split sample within two weeks of the verification of the results. The Division plans to collect a split <br />sample on 08/02/2011, which will be within the two -week period. Once the results are verified, a Reason to Believe A <br />violation Exists letter will be sent to CC &V for exceeding the sulfate standards for compliance well CRMW -3B. When the <br />Division set numeric protection levels for Squaw Gulch and Wilson Creek (Bateman) in 1998, the data utilized were, from <br />12/7/1993 to 8/8/1994. The Division utilized the Dump Stat program by Robert D. Gibbons. It is consistent with USEPA <br />Subtitle C &D Regulations and ASTM PS 64 -96. An Intra Well prediction Limit and combined Shewart -CUSUM control charts <br />were generated using the oldest eight values for the well. The values considered outliers were not utilized to generate the <br />numeric protection levels. Since the other compliance wells had sulfate readings below the a narrative standard for drinking <br />water, even though not classified, a value of 250 mg /I were set as a protective number. The permit condition as outlined in <br />the Division's letter to CC &V requires the operator to sample within two weeks after receiving the results if the compliance <br />numbers exceeded. On August 2, 2011, the Division collected a split sample from compliance well CRMW -3B63 and <br />CRMW3A -35. If the compliance well results exceed the 1070mg/I sulfate, the Division will send a reason to believe a <br />violation exists letter and bring the matter before the MLRD Board for a hearing. The split samples collected resulted in a <br />reading of 1060mg/I, below the threshold set for the compliance well. Since the Division's result were higher than the <br />operator's results, the next split sample, next quarter will be sent to an independent lab for verification. <br />3) The phase I,II,III,IV and V valley leach facility were inspected. The following readings were collected from the High and Low <br />solution collection pressure transducers. <br />4) Phase! high volume solution collection transducer was recorded at 22.5 # 2 was at 24.5 and # 3 was at 22.2. The low <br />volume solution collection transducer # 1 was recorded at 0.27 and # 2 was at 0.59. The piezomters for the pond were <br />recorded at 37.8 and 34.6. The phase II high volume solution collection transducer # 4 was recorded at 13.4 # 5 was at 13.7 <br />and #6 13.4. The low volume solution collection transducer # 1 was recorded at 0.49 and # 2 was at 0.59. The phase IV high <br />volume solution collection transducer # 7 was recorded at 31.4 #8 was at 30.8 # 9 was at 29.0 and # 10 was at 28.3. The low <br />volume solution collection transducer # 1 was at 15.5 and # 2 was at 17.9 inches of hydrostatic head. The phase V high <br />volume solution collection transducer # 311 was recorded at 13.29 # 312 was recorded at 13.47 # 313 was recorded at <br />13.78 and #314 was at 13.85. The low volume solution collection transducer # 1 was at 15.7 and # 2 was at 17.8 inches of <br />hydrostatic head. <br />5) The phase V leach pad construction area was inspected. Along the south facing pads, drain cover , geomembarne, clay and <br />sub grade preparation was taking place at various portions of the pad. The construction work was being supervised by <br />Amec QA /QC personnel at the time of the inspection. The deployed liners were walked and inspected and found to be in <br />good repair. <br />Page 2 of 4 <br />