2012-02-28_REVISION - M1980244 (84)

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Releases to Ground Water CC &V operates a VLF monitoring system and ground water monitoring wells to determine if releases are occurring from its leaching operations such that ground water quality may be impacted. Releases to ground water, should they occur, are generally not rapid or instantaneous, thus providing appropriate time for evaluation and remediation. CC &V is committed to a DRMS regulatory required response to an increase in certain water monitoring parameters that is contained in Amendment No. 8, Volume I, Project Description page 98 and also in Appendix VII of this document. Spill Path Monitoring If a spill or leak has the potential to migrate from the point of occurrence, spill monitoring will be implemented following clean up. Development of the monitoring plan will be determined by the nature and extent of the spill and the potential environmental effects created by the spill. All monitoring and sampling will be completed under the direction of the Environmental Resources Department. The potential for spills to migrate from the point of occurrence is minimal. These materials will be quickly absorbed into soil material. If a spill of these materials has the potential to migrate to surface water, a berm(s) will be placed upgradient of the potential point of entry to the water and surface water monitoring will be implemented downstream, if necessary. All monitoring and sampling will be completed under the direction of the Environmental Resources Department. Spill monitoring equipment is available on site. Soil along the spill pathway will be monitored and decontaminated and /or moved as necessary. If there is a potential for the spill to migrate off - site, samples will be obtained expeditiously from down- gradient, existing surface and ground water stations and any additional water monitoring points deemed appropriate to monitor the potential migration pathways. The spilled material also may be tested to evaluate the effectiveness of mitigation. VIII. Review, Evaluation, and Revision of Response Procedures All exposure and release incidents and accidents shall be evaluated to identify their cause and determine the measures to be implemented designed to prevent their reoccurrence. Such measures may include equipment changes, revised standard operating procedures, or new or enhanced worker training. CC &V shall review and evaluate the CERP at a minimum of every other year and after any incident requiring its implementation. Based on these reviews, the CERP shall be revised as necessary to ensure that it remains current and effective. The date of the most recent review shall be noted on the CERP's title page. CC &V shall conduct mock emergency drills annually to test its response procedures and capabilities. Some of these drills may be specific to cyanide releases while others may simulate Cyanide Emergency Response Plan EMS: AGANA/CCV Printed Copies are Uncontrolled G:1EMS\Plans \Emergency Response Plans \Cyanide Emergency Response PIan10ERP.doc - 1 - August 17, 2010 Doc.# E -012 Rev 07