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groundwater, leak detection systems, solution collection systems, underdrain systems, <br />and the PSSAs and External Storage Pond. Additionally, Process personnel conduct <br />detailed, routine inspections of the VLF and ADR Plant, including process tanks, <br />secondary containments, pipelines, pumps and valves. The Environmental Department <br />conducts weekly informal inspections of facilities, site wide. Environmental inspections <br />include driving around the active area of the VLF looking for signs of ponding solution, <br />broken/leaking pipes, drip lines and valves, slope stability issues, and observing wildlife, <br />the integrity of fencing and the condition of the liner at the External Storage Pond. The <br />Environmental Department also conducts weekly informal walkthrough inspections of <br />the ADR Plant to identify containment or other issues, annual detailed inspections of the <br />synthetic liner at the External Storage Pond, and quarterly inspections of the entire <br />stormwater management system, including stormwater diversions. All inspections are <br />properly documented and records are retained for a period of three years or more. <br />Agency inspections include monthly inspections by the Colorado Division of <br />Reclamation Mining and Safety (DRMS) in accordance with the Mining and Reclamation <br />Permit, annual inspections by the Water Quality Control Division of the Colorado <br />Department of Public Health and Environment (CDPHE) in accordance with the <br />discharge and stormwater permits, and arbitrary multimedia inspections by the U.S. <br />Environmental Protection Agency (EPA). Agency inspections may occur more <br />frequently, such as during construction activities or as otherwise warranted. <br />In addition to the inspection procedures outlined above, CC &V has implemented a PM <br />program for critical equipment. The PM schedule provides a listing of the equipment <br />along with the planned time for maintenance. The PM system is managed using JD <br />Edwards© (JDE) software, which automatically produces PM work orders on an <br />established schedule. The system identifies future activities for regular preventive <br />maintenance and includes information on the task requirements and completion. <br />CC &V has implemented procedures to identify when process or operating changes <br />increase the potential for environmental impacts and safety risks, respectively. The <br />procedures define the method used to identify environmental aspects and related <br />environmental impacts and provide criteria for determining the relative significance of <br />each associated impact. <br />Contingency plans implemented for the operation include procedures for responding to <br />situations which demonstrate significant changes from previous monitoring results; <br />managing solution levels under varying upset conditions to prevent unintentional <br />releases; destructing cyanide where process solution must be transferred to the External <br />Storage Pond; and for water management, inspections and monitoring during temporary <br />closure or cessation of operations. In addition, CC &V has implemented a comprehensive <br />Emergency Response Plan. <br />The primary power source for the CC &V operation is overhead line power from the local <br />grid. However, CC &V maintains four diesel - powered generators at the ADR Plant as <br />backup power sources, which are sufficient to power all process pumps and equipment <br />Cresson Project <br />Name of Mine <br />September 22, 2010 <br />Signature of Lead Auditor Date <br />Page 10 of 36 <br />