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The operation is: <br />• in full compliance <br />❑ in substantial compliance <br />❑ not in compliance...with Standard of Practice 2.1. <br />Discuss the basis for the Finding/Deficiencies Identified: <br />The contractual relationships between CC &V, CyPlus /Cyanco and between <br />CyPlus /Cyanco and TriMac have not changed since the 2007 audit. All responsibilities <br />for cyanide supply and delivery are contractually assigned to Cyanco, who inherited the <br />CC &V contract as a result of the CyPlus divestiture. Cyanide is delivered in <br />approximately 40,000 lb. batches, in single, dedicated, stainless -steel "ISO" containers. <br />Cyanco leases dedicated specially designed trailers and the ISO containers, which are <br />transported by TriMac under a Cyanco contract. All trailers /containers are designed to <br />meet or exceed DOT standards. <br />All cyanide production and transportation takes place within the continental US. <br />Labeling and packing specifications are controlled as part of bulk loading operations. All <br />labeling is in English and includes the chemical name, hazard (marine pollutant) code, <br />and DOT hazards code [1689 (6)]. <br />Cyanide container /trailer pickup locations and final routing instructions for traveling <br />through the communities closest to the mine are documented on the transporter's bills of <br />lading. Procedures for evaluation and selection of highway routes to the CC &V mine site <br />are controlled by TriMac's own cyanide management practices, which were reported to <br />have been subject to a recent (and successful) ICMC certification audit. This was in <br />response to recent changes in the ICMC, as TriMac had previously been subject to an <br />ICMC- equivalent third -party audit by CyPlus in 2006. Although no SAR indicating <br />ICMC certification status for TriMac was available for review at the time of the audit, <br />communications with ICMI representatives prior to the submittal date of this report <br />indicate that although public announcements were on hold pending receipt of <br />authorization to post the SAR, TriMac has indeed achieved ICMC certification status. <br />No interim loading, storage and unloading occurs during shipment as the containers are <br />transported directly to the solution mixing and offloading area at the Cresson Project. <br />TriMac is responsible for delivering cyanide free on board (FOB) the security gate at the <br />Cresson Project. CC &V takes ownership of the cyanide at the point the cyanide trailer is <br />brought through the main gate. Cyanco was the designer of the mixing facility; Cyanco <br />and CC &V both provide training to the TriMac drivers with respect to spill response and <br />cyanide mixing and transfer operations. <br />Cresson Project <br />Name of Mine <br />September 22, 2010 <br />Signature of Lead Auditor Date <br />Page 5 of 36 <br />