2012-02-28_REVISION - M1980244 (85)

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drainage cover fill material. The leak detection and collection system within the PSSAs are continuously monitored and pumped to ensure that less than two feet of hydraulic head is placed on the lower synthetic liner. The entire VLF area is underlain by a leak detection system placed on the graded and prepared subgrade prior to placement of the soil liner. A geomembrane liner connected to the VLF liner system underlies the entire ADR Plant area, including the cyanide Offload and Storage Facility. The liner serves as tertiary containment for the concrete secondary containment facilities provided at the offload and plant. The cyanide Offload and Storage Facility, located adjacent to the ADR Plant building, consists of a curbed, concrete loading apron for staging the delivery trucks /trailers containing the ISO tanks. The concrete apron drains to the adjacent concrete containment area occupying the Cyanide Mix Tank and the Cyanide Storage Tank. CC &V conducts regular inspections and monitoring of the process facilities to ensure that the operating criteria are being met. In addition, regular monitoring of groundwater downgradient of the operation and of leak detection and solution collection systems is conducted to ensure that the facility is functioning as designed and protective of the environment. Groundwater is regulated by DRMS in accordance with the Mining and Reclamation Permit. The regulatory numerical standard for cyanide in groundwater is 0.20 mg /1 WAD cyanide and is based on five quarters of baseline data. CC &V monitors groundwater quality at three compliance points downgradient of the operation and reports results quarterly to DRMS. Quarterly groundwater monitoring data for the period 2007 through 2010 demonstrate that all numeric permit conditions were met over this period. There has been no seepage from the operation that has caused indirect discharges to groundwater; therefore, CC &V is not engaged in remedial activity. 4.7 Provide spill prevention or containment measures for process tanks and pipelines. The operation is: • in full compliance ❑ in substantial compliance ❑ not in compliance...with Standard of Practice 4.7. Discuss the basis for the Finding/Deficiencies Identified: All cyanide storage and process tanks and process pipelines at the Cresson Project are provided with adequately sized concrete and/or synthetic -lined secondary containment. Nonetheless, CC &V has implemented written procedures for cleaning up spills, which include measures for sampling fluid and/or soils after detoxification and removal for confirmation testing. Cresson Project Name of Mine September 22, 2010 Signature of Lead Auditor Date Page 17 of 36