2012-02-28_REVISION - M1980244 (85)

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monitoring and sampling groundwater and surface water quality, and the Environmental Sampling Protocol Guide for CDPHE Permits (discharge permits). The Wildlife Protection Plan provides preventative measures for protecting wildlife mine wide and outlines inspection and reporting procedures. The sampling protocol guides were developed by CC &V personnel using U.S. Environmental Protection Agency (EPA) protocols. The protocols are managed and administered by appropriately qualified persons. CC &V conducts monitoring at frequencies adequate to characterize water quality and wildlife mortalities. The Mining and Reclamation Permit with DRMS and the discharge permits with CDPHE specify monitoring locations and frequencies. The sampling protocols detail the steps for collecting, preserving, and preparing the samples prior to shipment. They also provide shipping and chain of custody procedures. Field sampling conditions for each sampling episode are documented on the Water Sampling Field Data Sheet. Information provided on the form includes the sample number, date, time, type, analysis suite, sampler, field data, and any comments. Field data include water temperature, flow, specific conductance, dissolved oxygen, pH, and the presence of oil and grease. Information on the Sampling Field Data Sheets is also included on the chain -of- custody forms. CC &V maintains an extensive monitoring network at the Cresson Project in accordance with its Mining and Reclamation Permit. Monitoring is conducted by CC &V professional staff and water quality samples are shipped to outside, certified laboratories for analysis. Appropriate QA /QC procedures are used to validate the sample collection and analytical methods. Surface water monitoring is conducted on a quarterly basis at three locations downgradient of the operation. These locations include one station directly downgradient of the VLF on Arequa Gulch, one station downgradient of the operation on Wilson Creek just below the confluence with Bateman Creek, and one station downgradient of the East Cresson Mine Area on Theresa Gulch. In accordance with the Discharge Permit for Arequa Gulch, the outfall for the VLF underdrain system is checked three times per week, and samples are analyzed for cyanide weekly (if flowing). Groundwater quality and depths are monitored on a quarterly basis. Quarterly samples are taken at three Compliance Points located downgradient of the VLF. In addition, regular (at least weekly) monitoring of the leak detection and solution collection systems associated with the VLF is conducted to ensure that the facility is functioning as designed and protective of the environment. CC &V Environmental personnel interviewed during this onsite recertification audit described the wildlife mortality inspection frequency as daily, at minimum. The Environmental Department conducts weekly inspections of facilities, site wide, which include observing the integrity of protective measures and "accumulated" wildlife (i.e., wildlife that is gathering and lingering). In accordance with the Wildlife Protection Plan, CC &V personnel are instructed to contact the Environmental Department when wildlife mortalities are discovered and to document the details of the incident. According to CC &V Environmental personnel interviewed during this onsite recertification audit, no Cresson Project Name of Mine September 22, 2010 Signature of Lead Auditor Date Page 21 of 36