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regeneration process could contain low concentrations of cyanide, and shared a common <br />containment with a hydrochloric acid mix tank. CC &V staff were requested to assess the <br />potential for HCN generation within the impoundment in a worst -case scenario in which <br />the vessel and tank failed simultaneously, and if significant, to provided separate <br />containment for either the vessel or tank. A documented assessment was completed that <br />demonstrates that the potential for HCN generation was not significant. See Section <br />4.7(2). <br />3.2 Operate unloading, storage and mixing facilities using inspections, <br />preventive maintenance and contingency plans to prevent or contain releases <br />and control and respond to worker exposures. <br />The operation is: <br />Discuss the basis for this Finding/Deficiencies Identified: <br />CC &V does not handle empty cyanide containers as cyanide is only purchased and <br />delivered to the site in dedicated, reusable stainless steel ISO containers. After mixing in <br />the ISO container and transfer of the cyanide to the storage tank, the access port on top of <br />the ISO container is opened and a visual inspection made to ensure that all tank contents <br />have been dissolved and transferred; the port is then secured and the tank washed down <br />as necessary prior to being returned to the production facility. During observation of a <br />mixing activity; however, it was observed that tanks were being released for return <br />shipment with small ( <2 gallons) of unmixed residue. CC &V staff members were <br />requested to modify the SOP to permit small amounts of unmixed cyanide residue in the <br />ISO tank interior. <br />Detailed procedures are in place for operation of the SLS system. The two TriMac <br />drivers are primarily responsible for mixing and transfer of cyanide between the ISO <br />container and the storage tank. CC &V personnel provide oversight at the beginning and <br />end of each mix, and monitor tank volumes remotely from the ADR control room. The <br />procedures detail safe operation of valves and couplings, precautionary inspections of all <br />mixing connections for leaks, and for performing a washdown of the ISO tank dome prior <br />to disconnection, inspection of the interior of the container to ensure complete transfer of <br />the reagent, and moving the trailer and tank off the mixing /offloading apron. <br />Cresson Project <br />Name of Mine <br />• in full compliance <br />❑ in substantial compliance <br />❑ not in compliance...with Standard of Practice 3.2. <br />September 22, 2010 <br />Signature of Lead Auditor Date <br />Page 8 of 36 <br />