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4. OPERATIONS Manage cyanide process solutions and waste streams to protect <br />human health and the environment. <br />Standards of Practice <br />4.1 Implement management and operating systems designed to protect <br />human health and the environment including contingency planning and <br />inspection and preventive maintenance procedures. <br />The operation is: <br />Discuss the basis for the Finding/Deficiencies Identified: <br />The active cyanide facilities at the CC &V operation include the Cyanide Offload and <br />Storage Facility, VLF (Phases I through IV), ADR Plant (Carbon Trains A through D and <br />associated process circuits and tanks), and the External Storage Pond. The VLF is <br />comprised of a synthetic -lined leach pad with multiple Process Solution Storage Areas <br />(PSSAs), i.e., pregnant solution ponds located within the heap. <br />CC &V has developed and implemented management, operating, and contingency plans <br />and procedures, which provide the standard practices necessary for the safe and <br />environmentally sound operation of the cyanide facilities. In addition to the management <br />and operating plans, procedure documents include a wide range of CC &V departmental <br />SOPs. CC &V's Wildlife Protection Plan provides preventative measures for protecting <br />wildlife mine wide. The operating procedures specific to the cyanide facilities are <br />managed as part of CC &V's third -party certified ISO 14001 Environmental Management <br />System (EMS). The EMS includes processes for periodically assessing and improving <br />the effectiveness of all environmental management practices, including management of <br />cyanide. Additionally, following the June 2007 ICMC certification audit, CC &V <br />established a third -party certified OSHAS 18001 Health and Safety Management System. <br />The regulatory operating permits for the VLF and ADR Plant identify the assumptions <br />and parameters on which the facility designs were based. These permits include the <br />Mining and Reclamation Permit, the Discharge Permit for Arequa Gulch and the General <br />Stormwater Permit. The design reports prepared for the VLF and ADR Plant incorporate <br />the regulatory criteria required by these operating permits. <br />CC &V has implemented inspection programs for all process facilities. These programs <br />involve inspections conducted each shift, daily, three times each week, weekly, monthly, <br />quarterly and annually. Principally, the Mining and Reclamation Permit serves as the <br />operating manual for the VLF and process facilities to ensure protection of water quality, <br />and not only establishes operating parameters, but also provides inspection and <br />monitoring requirements. In accordance with the permit, CC &V monitors surface water, <br />Cresson Project <br />Name of Mine <br />• in full compliance <br />❑ in substantial compliance <br />❑ not in compliance...with Standard of Practice 4.1. <br />September 22, 2010 <br />Signature of Lead Auditor Date <br />Page 9 of 36 <br />