2012-02-28_REVISION - M1980244 (85)

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(i.e., the ADR Plant and VLF remain fully operational during line power outages). CC &V performs routine electrical and mechanical PM inspections on the generators. A below -grade geomembrane liner underlies the entire ADR Plant area, including the cyanide Offload and Storage Facility, and provides tertiary containment for the cyanide facilities. Therefore, if the physical integrity of the concrete becomes compromised temporarily by cracking, the underlying liner would provide competent secondary containment. CC &V Environmental personnel monitor the liner system leak detection sump, located downgradient of the ADR area, weekly. Additionally, CC &V indicated that inspections of the containments (although not fully documented) had been conducted regularly over the three year period between ICMC audits, and that it did not consider the condition of the concrete critical in providing competent secondary containment because of the underlying liner. Nonetheless, CC &V concurs that although the condition of the concrete may not be critical in providing competent secondary containment, maintaining its physical integrity as a best management practice is prudent. During this onsite recertification audit, a number of cracks and areas of spalling were observed within the concrete containment at the Offload and Storage Facility. As a result, CC &V updated its inspection procedures to better document visual inspections of the concrete containments at the Offload and Storage Facility and within the ADR Plant, and provided copies of the updated inspection checklist as evidence. Additionally, CC &V developed a new procedure providing guidance on appropriate visual standards for initiating maintenance or repair on facilities. On July 19, 2010, CC &V repaired the cracks and spalling in the concrete at the Offload and Storage Facility containment and provided photographic evidence demonstrating that the work had been completed. On September 7, 2010, CC &V provided training records as evidence that Process Operators have been properly trained on the updated/new procedures and provided copies of completed inspection forms demonstrating implementation of the procedures. Thus, in determining that the operation was initially in substantial compliance under this Standard of Practice, the auditor considered the redundant, engineered controls and monitoring, and CC &V's good -faith effort to comply with the provisions of the ICMC. Furthermore, no releases or water quality impacts resulted from the damaged concrete and CC &V took prompt action to remedy the circumstances. The auditor subsequently determined the operation to be in full compliance with this Standard once CC &V demonstrated that the concrete containment had been repaired and that measures were taken to prevent reoccurrence of the situation (via the evidence discussed above). As previously mentioned, cyanide pipelines, pumps, and valves are inspected on a routine basis. However, during this onsite audit, precipitated salts were observed on multiple piping locations and a number of pumps, and valves at the Offload and Storage Facility and within the ADR Plant. Because the inspection records over the past three years do not specifically document the occurrence of precipitated salts, the auditor has no means to determine the duration of the deficiency observed while on site, or if it was an isolated incident or programmatic failure. In the auditor's professional judgment, CC &V's routine inspection and maintenance programs, implemented over the past three years Cresson Project Name of Mine September 22, 2010 Signature of Lead Auditor Date Page 11 of 36