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Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO USA 80228 Telephone: (303) 980-0540 Fax: (303) 985-2080 www.golder.com OFFICES ACROSS AFRICA, ASIA, AUSTRALIA, EUROPE, NORTH AMERICA AND SOUTH AMERICA CHINO CLOSURE/CLOSEOUT PLAN UPDATE CHINO MINES COMPANY HURLEY, NEW MEXICO Prepared for: New Mexico Environment Department Ground Water Protection & Remediation Bureau Runnells Building 1190 St. Francis Dr. Santa Fe, NM 87503 and Mining and Minerals Division Energy, Minerals and Natural Resources Department Pinon Building 1220 South St. Francis Dr. Santa Fe, NM 87505 Submitted by: Chino Mines Company 210 Cortez Street Hurley, New Mexico 88043 Distribution: 3 Copies, 1 Electronic - Mining and Minerals Division 3 Copies, 1 Electronic - New Mexico Environment Department August 28, 2007 073-80007
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Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO USA 80228 Telephone: (303) 980-0540 Fax: (303) 985-2080 www.golder.com

OFFICES ACROSS AFRICA, ASIA, AUSTRALIA, EUROPE, NORTH AMERICA AND SOUTH AMERICA

CHINO CLOSURE/CLOSEOUT PLAN UPDATE CHINO MINES COMPANY HURLEY, NEW MEXICO

Prepared for:

New Mexico Environment Department Ground Water Protection & Remediation Bureau

Runnells Building 1190 St. Francis Dr. Santa Fe, NM 87503

and

Mining and Minerals Division

Energy, Minerals and Natural Resources Department Pinon Building

1220 South St. Francis Dr. Santa Fe, NM 87505

Submitted by:

Chino Mines Company 210 Cortez Street

Hurley, New Mexico 88043

Distribution: 3 Copies, 1 Electronic - Mining and Minerals Division 3 Copies, 1 Electronic - New Mexico Environment Department August 28, 2007 073-80007

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EXECUTIVE SUMMARY

Chino Mines Company (Chino) is located within a region of New Mexico that has a long history of

mining activities due to significant deposits of porphyry copper. Mining in this region continues to

be a vital part of current global and local economies. Open pit operations at Chino began on a limited

basis around 1910 and continue to the present day. Phelps Dodge has been mining at Chino since

January 1987. Phelps Dodge employs 1,255 people in Grant County, New Mexico, 808 of whom

work directly for Chino Mines Company.

Chino recovers products from the mined ore using two methods of beneficiation: 1) milling and

concentration of ores to produce copper and molybdenum concentrates for smelting and 2) leaching

of ores to recover pregnant leach solution (PLS) that is processed in the solution

extraction/electrowinning (SX/EW) facility to produce pure copper cathodes. The copper recovery

method for a particular ore depends on its grade (percentage of copper) and type of mineralization.

Chino’s current mine plan projects that active mining and mineral processing will continue to 2015.

Once active mining ceases, Chino will continue to leach the stockpiles and operate the SX/EW plant

for a number of years while closure activities are implemented at other areas of the mine.

Golder Associates Inc. (Golder) has prepared this Closure/Closeout Plan (CCP) at the direction of

Chino and it represents a 5-year update of the CCP submitted in 2001 to the New Mexico

Environment Department (NMED) and the Mining and Minerals Division (MMD) of the New

Mexico Energy, Minerals, and Natural Resources Department. Like the original CCP and financial

assurance, this updated plan is a “snap shot in time” that reflects Chino’s current mine plan and

understanding of site conditions. Chino’s CCP will continue to be revised on a five year basis

through out the mine’s active life to reflect changes in mine operations and site conditions. Chino will

prepare an amended CCP at the time of closure that will reflect actual, rather than anticipated,

conditions at the end of active mining.

Over the past decade, a broad range of specialized studies (e.g., groundwater, cover design, slope

stability, revegetation, and water treatment) have been conducted to evaluate the environmental and

economic implications of various closure alternatives. In addition, Chino has gained extensive

practical experience with reclamation techniques through technology transfers associated with the

concurrent reclamation activities at the Tyrone Mine.

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The principal mine facilities and components addressed in this CCP update include applicable

portions of the Santa Rita Open Pit, waste rock and leach ore stockpiles, tailing impoundments,

copper processing facilities, mine operations facilities and ancillary infrastructure. The financial

assurance amount is based upon the following closure scenario:

• closure of stockpiles and tailing impoundments would rely on a combined approach involving source control (soil covers) and complementary surface and subsurface water control measures and water treatment;

• the cover systems would be placed on mining substrates graded to allow stormwater to runoff while reducing percolation and soil loss from erosion;

• the cover systems would be seeded to establish a self-sustaining ecosystem, remove water and stabilize the soils;

• surface water control structures would be designed to convey water in a manner that maintains the integrity of the adjoining soil covers;

• subsurface water control measures would be operated to limit the impacts to groundwater resources.

• the bulk of the mine process solutions would be eliminated by recirculation and evaporation and the remaining solutions would be collected, treated, and prepared for final discharge;

• impacted waters would be treated using a lime neutralization method followed by commingling with tailing process water and make-up groundwater; and

• some existing stormwater reservoirs and other mine process water management facilities would be used to facilitate conveyance of water to the treatment plant during post-closure, while others would be permanently closed.

Chino’s cost estimate in this CCP update is based on the end-of-2007 mine conditions and assumes

the work would be performed by third-party contractors. The estimated capital cost to reclaim the

principal mine facilities is about $200 million. This cost includes reclamation of stockpiles, tailing

impoundments, reservoirs, and other mine areas, and construction of a water treatment system.

Because Chino will continue to integrate closure decisions into mine planning and operational

decisions to promote efficiency in the closure process and reduce the amount of disturbed land, out-

year costs are expected decrease relative to the end-of-year 2007 costs.

Post-closure operations, maintenance, and monitoring costs were estimated for a 100-year period

following completion of the reclamation. The total cost for post-closure is subject to prediction of the

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appropriate economic factors (escalation and discount rate) to be applied during the 100-year

post-closure period. Once these factors are agreed upon, the net present value will be calculated to

determine the cost for financial assurance.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY......................................................................................................ES-1

1.0 INTRODUCTION..............................................................................................................1 1.1 Purpose of Plan ................................................................................................................... 1 1.2 Plan Organization ............................................................................................................... 1 1.3 Regulatory Framework ....................................................................................................... 2

1.3.1 The New Mexico Mining Act and Administrative Rules............................................. 2 1.3.2 New Mexico Water Quality Act and the New Mexico Water Quality Control Commission Regulations........................................................................................................... 5 1.3.3 Office of the State Engineer (OSE) Rules and Regulations Governing the Drilling of Wells and the Appropriation and Use of Ground Water ....................................................... 6 1.3.4 Agency Coordination. .................................................................................................. 6

1.4 Closure Summary ............................................................................................................... 7 1.4.1 History of Mining Activity at Chino ............................................................................ 7 1.4.2 Active Mining and Ore Beneficiation Operations at Chino ......................................... 8 1.4.3 Closure Activities ......................................................................................................... 9

1.5 Description of Updated Plan............................................................................................. 12 1.6 Summary of Financial Assurance ..................................................................................... 13

2.0 EXISTING FACILITIES AND CONDITIONS.............................................................14 2.1 Description of Mining Facilities ....................................................................................... 14

2.1.1 Santa Rita Open Pit .................................................................................................... 15 2.1.2 Waste Rock, Leach and Cover Material Stockpiles ................................................... 15 2.1.3 Maintenance Facilities Area....................................................................................... 18 2.1.4 Solution Extraction/Electrowinning Plant.................................................................. 18 2.1.5 Ivanhoe Concentrator ................................................................................................. 18 2.1.6 Groundhog Mine Area................................................................................................ 19 2.1.7 Hurley Power Plant .................................................................................................... 19 2.1.8 Tailing Impoundments ............................................................................................... 19 2.1.9 Water Management System........................................................................................ 22 2.1.10 Other Ancillary Facilities, Structures, and Systems.................................................. 23

2.2 History of Mining at Chino............................................................................................... 23 2.3 History of Land Ownership .............................................................................................. 24 2.4 Past and Current Land Uses.............................................................................................. 25 2.5 Environmental Setting ...................................................................................................... 25

2.5.1 Topography ................................................................................................................ 25 2.5.2 Geology ...................................................................................................................... 27 2.5.3 Climate ....................................................................................................................... 31 2.5.4 Hydrology................................................................................................................... 31 2.5.5 Soils and Vegetation................................................................................................... 34 2.5.6 Wildlife....................................................................................................................... 35 2.5.7 Material Characteristics.............................................................................................. 36

2.6 Permits and Discharge Plans............................................................................................. 37 2.6.1 Mine Operation Permit............................................................................................... 37 2.6.2 National Pollutant Discharge Elimination System Permit ......................................... 38

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2.6.3 NPDES Multi-sector Stormwater General Permit...................................................... 38 2.6.4 Water Rights............................................................................................................... 38 2.6.5 Air Quality.................................................................................................................. 39 2.6.6 Other Permits.............................................................................................................. 39 2.6.7 Plans of Operation ...................................................................................................... 39 2.6.8 Administrative Order on Consent (AOC)................................................................... 40 2.6.9 Operational Discharge Plans ...................................................................................... 40

3.0 TECHNICAL CONSIDERATIONS FOR RECLAMATION.......................................44 3.1 Reclamation Plan .............................................................................................................. 44 3.2 Units of Reclamation ........................................................................................................ 44

3.2.1 DP-376: Lampbright Leach System ........................................................................... 44 3.2.2 DP-591: Area, SX/EW Plant and Reservoirs 6 and 7 ................................................ 46 3.2.3 DP-459: North Pit Stockpiles, Reservoir 5, and Santa Rita Open Pit ........................ 48 3.2.4 DP-493: Reservoir 3A............................................................................................... 50 3.2.5 DP-526: Whitewater Leach System (Stockpiles and Facilities)................................. 51 3.2.6 DP-213: Ivanhoe Concentrator and Associated Pipelines Areas................................ 55 3.2.7 DP-214: Hurley Operation, Lower Whitewater Creek, Lake One and Older Tailing Impoundments Areas............................................................................................................... 57 3.2.8 DP-484: Tailing Pond 7 Area..................................................................................... 60

4.0 POST-MINING LAND USE DESIGNATION..............................................................62 4.1 Post-Mining Land Use Overview ..................................................................................... 62 4.2 Wildlife Habitat Post-mining Land Use ........................................................................... 63 4.3 Industrial Post-mining Land Use ...................................................................................... 64 4.4 Site-Specific Revegetation Success Guidelines................................................................ 65

4.4.1 Canopy Cover............................................................................................................. 66 4.4.2 Shrub Density ............................................................................................................. 66 4.4.3 Plant Diversity............................................................................................................ 66

5.0 CONDITIONAL STUDIES AND ONGOING RECLAMATION PROJECTS...........68 5.1 Revision 01-1 to Permit GR009RE, Section 8.................................................................. 68 5.2 Supplemental Discharge Permit for Closure DP-1340 ..................................................... 68

5.2.1 Condition 80 – Supplemental Slope Stability Study .................................................. 70 5.2.2 Condition 81 – Comprehensive Cover Performance Evaluation................................ 71 5.2.3 Condition 82 – Cover, Erosion, and Revegetation Test Plot Study ........................... 71 5.2.4 Condition 83 – Hydrologic Study .............................................................................. 72 5.2.5 Condition 84 – Supplemental Leach Ore Stockpile and Waste Rock Stockpile Mass Loading Study................................................................................................................ 73 5.2.6 Condition 86 – Water Treatment System Sustainability Study.................................. 73 5.2.7 Condition 88 – Process Solution Elimination Study .................................................. 73 5.2.8 Condition 89 – Slag Characterization Study .............................................................. 74 5.2.9 Condition 90 – Lake One Area Characterization Study ............................................. 74 5.2.10 Condition 91 – Reservoir and Impoundment Study ................................................... 74 5.2.11 Condition 92 – North Area Groundwater Flow Model .............................................. 74 5.2.12 Condition 93 – Feasibility Study Analysis of Closure Alternatives........................... 75

6.0 RECLAMATION DESIGNS AND POST-CLOSURE MONITORING......................76

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6.1 Facility Characteristics and Classification........................................................................ 76 6.1.1 Tailing Impoundments ............................................................................................... 77 6.1.2 Stockpiles ................................................................................................................... 77 6.1.3 Santa Rita Open Pit .................................................................................................... 77 6.1.4 Reservoirs/Dams ........................................................................................................ 78 6.1.5 Other Disturbed Areas................................................................................................ 78 6.1.6 Ancillary Work........................................................................................................... 79

6.2 Performance Objectives and Reclamation Designs .......................................................... 79 6.2.1 Tailing Impoundments ............................................................................................... 80 6.2.2 Stockpiles ................................................................................................................... 82 6.2.3 Santa Rita Open Pit .................................................................................................... 85 6.2.4 Reservoirs/Dams ........................................................................................................ 85 6.2.5 Disturbed Areas.......................................................................................................... 86 6.2.6 Borrow Areas ............................................................................................................. 86

6.3 Water Management and Treatment................................................................................... 88 6.3.1 Management and Treatment Processes ...................................................................... 88 6.3.2 Evaporation Treatment System and Process Water Elimination................................ 89 6.3.3 Sludge Management ................................................................................................... 90

6.4 Reporting, Post-closure Monitoring and Contingency Plans............................................ 90 6.4.1 Erosion and Drainage Control Structures................................................................... 91 6.4.2 Groundwater and Surface Water Control Facilities ................................................... 91 6.4.3 Revegetation Success Monitoring .............................................................................. 93 6.4.4 Wildlife Monitoring ................................................................................................... 93

7.0 SUMMARY OF CLOSURE/CLOSEOUT PLAN ACTIVITIES..................................94 7.1 Discharge Plan Areas........................................................................................................ 94

7.1.1 DP-376: Lampbright Leach System (Lampbright Stockpiles and Reservoir 8 Areas)94 7.1.2 DP-591: SX/EW and Reservoirs 6 and 7 ................................................................... 96 7.1.3 DP-459: Main Pit, North In-Pit Leach System, and Northeast, North, Northwest, and Lee Hill Waste Rock Piles and Stockpiles and Reservoir 5 ............................................ 97 7.1.4 DP-493: Reservoir 3A................................................................................................ 99 7.1.5 DP-526: Whitewater Leach System (Stockpiles and Facilities Area) ...................... 100 7.1.6 DP-213: Ivanhoe Concentrator and Associated Pipelines........................................ 102 7.1.7 DP-214: Hurley Operation Area, Lake One, Older Tailing Impoundment Area, Axiflo Lake, Lower Whitewater Creek ................................................................................ 103 7.1.8 DP-484: Tailing Pond 7 Area................................................................................... 106

7.2 Additional Mining Facilities not Considered in Other Sections ..................................... 107 7.2.1 Mine Maintenance Facilities .................................................................................... 107 7.2.2 Groundhog Mine Stockpile Area ............................................................................. 108 7.2.3 Groundhog No. 5 Stockpile Reclamation................................................................. 109 7.2.4 South Mine Area Cover Material Borrow Pit........................................................... 110 7.2.5 East Mine Pit Access Road ...................................................................................... 111

8.0 CAPITAL AND OPERATION AND MAINTENANCE COST ESTIMATES.........112 8.1 Capital Cost Estimates .................................................................................................... 112 8.2 Basis of Capital Cost Estimates ...................................................................................... 113 8.3 Operation and Maintenance Cost Estimates ................................................................... 113

8.3.1 Earthwork ................................................................................................................. 113 8.3.2 Water Treatment....................................................................................................... 113

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9.0 CLOSURE SCHEDULE................................................................................................115

10.0 USE OF THIS REPORT................................................................................................115

11.0 REFERENCES...............................................................................................................116

LIST OF TABLES

Table 2-1 Chino Resource Model Geological Code Descriptions Table 2-2 Summary of Reservoirs Table 2-3 Summary of Chino Closure/Closeout-Related Permits Table 2-4 Summary of NMED Discharge Plans Table 4-1 Proposed Interim Seed Mix and Rates for the North Mine Area Table 4-2 Proposed Interim Seed Mix and Rates for the South Mine Area Table 4-3 Functions and Attributes of the Primary Plant Species Table 4-4 Industrial PMLU Designation Table 4-5 Plant Diversity Guidelines Table 6-1 Summary of Tailing Impoundment Footprint Areas Table 6-2 Summary of Stockpile Footprint Areas Table 6-3 Summary of North Mine Area Reservoir Closure/Close-Out Function Table 6-4 Summary of Tailing Impoundment Long-Term Slope Stability Analysis Table 6-5 Summary of Stockpile Long-Term Slope Stability Analysis Table 9-1 Reclamation Schedule

LIST OF FIGURES

Figure 1-1 Location Map Figure 2-1 Chino Mines Facilities Map Figure 2-2 Chino Ore-Processing Operations – Schematic Diagram Figure 2-3 North Mine Area – Stockpiles and Reservoirs Figure 2-4 South Mine Area – Tailing Impoundments Figure 2-5 Water Use and Supply Cycle – Schematic Diagram Figure 2-6 Site Topography Figure 2-7 Groundwater Elevation Map - North Mine Area Figure 2-8 Groundwater Elevation Map – Pipeline Corridor Area Figure 2-9 Groundwater Elevation Map – South Mine Area (2003) Figure 2-10 Vegetation Communities - North Mine Area Figure 2-11 Vegetation Communities – South Mine Area Figure 2-12 Discharge Permit Areas Figure 3-1 DP-376: Lampbright Leach System Area Figure 3-2 DP-591:SW-EX Plant Area Figure 3-3 DP-459: Santa Rita Open Pit Area Figure 3-4 DP-493/526: Whitewater Leach System/Reservoir Area Figure 3-5 DP-213: Ivanhoe Concentrator/Precipitation Plant Area Figure 3-6 DP-214: Hurley Operation Area Figure 3-7 DP-214: Older Tailing Impoundments

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Figure 3-8 DP-484: Tailing Pond 7 Figure 4-1 PMLU and Waiver Area Designations Figure 7-1 DP-376: Lampbright Leach System Closure Activities Figure 7-2 DP-591:SW-EX Plant Closure Activities Figure 7-3 DP-459/493: Whitewater Leach System/Reservoir Closure Activities Figure 7-4 DP-526: Whitewater Leach System Closure Activities Figure 7-5 DP-213: Ivanhoe Concentrator/Precipitation Plant Closure Activities Figure 7-6 DP-214: Older Tailing Impoundment Closure Activities Figure 7-7 DP-484: Tailing Pond 7 Closure Activities Figure 7-8 Mine Maintenance Facilities Closure Activities Figure 7-9 Groundhog Mine Area Closure Activities

LIST OF APPENDICES

Appendix A Reclamation Drawings Appendix B Facility Characteristic Forms Appendix C Earthwork Cost Basis and Estimate Appendix D Water Treatment Cost Basis and Estimate

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LIST OF ACRONYMS

ac-ft/yr acre-feet per year AGP acid generation potential amsl above mean sea level ANP acid neutralization potential AOC Administrative Order on Consent bgs below ground surface BLM Bureau of Land Management CCP Closure/Closeout Plan Chino Chino Mines Company CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CGCS Comprehensive Groundwater Characterization Study COC constituent of concern CQA construction quality assurance DBS&A Daniel B. Stephens & Associates DP Discharge Plan DSM dynamic system modeling EIS Environmental Impact Statement EOY end of year EPA Environmental Protection Agency (U.S.) ETS evaporation treatment system ft amsl feet above mean sea level ft bgs feet below ground surface ft/d feet per day ft2/d square-feet per day ft/ft foot per foot ft3/s cubic feet per second gpm gallons per minute H:V horizontal to vertical (not defined in text) HDPE high-density polyethylene HDS high density sludge IRA interim remedial action IU investigation unit kWh kilowatt-hours lime/HDS lime precipitation and high density sludge M3 M3 Engineering and Technologies mg/L milligrams per liter

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MMD Mining and Mineral Division (New Mexico Energy, Minerals, and Natural Resources Department)

MMD Permit Permit GR009RE issued by the Director of the MMD MWMP meteoric water mobility procedure MWWCA Middle Whitewater Creek Area, also called the Pipeline Corridor Area (PCA) Myd3 million cubic yards NMA North Mine Area NMAC New Mexico Administrative Code NMED New Mexico Environment Department NMMA New Mexico Mining Act NMOSE New Mexico Office of the State Engineer NMWQA New Mexico Water Quality Act NPDES National Pollutant Discharge Elimination System NRCS Natural Resources Conservation Service (U.S., formerly the Soil Conservation

Service) O&M operations and management OPCZ open pit capture zone PCA Pipeline Corridor Area (also referred to as the Middle Whitewater Creek Area or

MWWCA) pH PLS pregnant leach solution PMLU post-mining land use R&LC rhyolite and leached cap SBR8 spring below Reservoir 8 SCS Soil Conservation Service (U.S., now Natural Resources Conservation Service) SMA South Mine Area SPLP synthetic precipitation leaching procedure SWQB Surface Water Quality Bureau (NMED) SX/EW solution extraction-electrowinning TDS total dissolved solids TDRW tailing decant return water USNVC U. S. National Vegetation Classification VOC volatile organic compounds WQCC Water Quality Control Commission (New Mexico Environment Department) yd3 cubic yard

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1.0 INTRODUCTION

Chino Mines Company (Chino) operates an open-pit copper mine, concentrator, and solution

extraction-electrowinning (SX/EW) plant located approximately 10 miles east of Silver City in Grant

County, New Mexico (Figure 1-1). This updated Closure/Closeout Plan (CCP) modifies the 2005

update and presents Chino’s current plan and financial assurance.

1.1 Purpose of Plan

The Chino CCP was updated to fulfill the requirements of the following two permits:

• Supplemental Discharge Plan DP-1340 (DP-1340), issued by the New Mexico Environment Department (NMED) on February 24, 2003 (NMED, 2003); and

• Revision 01-1 to Permit GR009RE (MMD Permit), issued by the Director of the Mining and Minerals Division (MMD) of the New Mexico Energy, Minerals and Natural Resources Department on December 18, 2003 (MMD, 2003).

Condition 1 of DP-1340 requires Chino to submit to NMED an updated closure plan by August 28,

2007, which is 180 days prior to the expiration date of the permit. Section S of the MMD Permit

stipulates that a revised closeout plan be submitted to MMD by April 30, 2008. This CCP supersedes

the February 2005 CCP Update (Chino, 2005), and the End of Year 2001 through 2006 CCP (M3,

2001).

1.2 Plan Organization

This section describes the purpose and scope of the CCP Update and its overall organization.

• Section 1.0 provides an overview of this CCP.

• Section 2.0 describes the current environmental setting of Chino including geology, fauna, flora, history, existing facilities, current disturbances, and discharge permits.

• Section 3.0 describes the facilities, materials characteristics, site-specific hydrologic conditions, and the known and potential impacts to the environment associated with each of the operational discharge permits for Chino.

• Section 4.0 details the proposed post-mining land uses for Chino and the associated requirements for the individual areas.

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• Section 5.0 presents the status of the studies required in the MMD Permit (Section 8.L) (MMD, 2003) and the DP-1340 (Conditions 79 through 93) (NMED, 2003).

• Section 6.0 describes the proposed reclamation and post-closure monitoring plans for the major mine facilities and operational discharge plan (DP) areas.

• Section 7.0 summarizes the current and planned CCP activities.

• Section 8.0 presents a summary of the capital and operation and maintenance cost estimates.

• Section 9.0 presents a closure schedule for the plan

• Section 10.0 lists the references used in preparation of this CCP.

• Appendix A includes the updated drawings that illustrate the CCP.

• Appendix B includes the updated facility characteristic forms.

• Appendix C includes the updated cost estimate for earthwork.

• Appendix D includes the updated cost estimate for water treatment.

1.3 Regulatory Framework

Chino’s mineral extraction and beneficiation activities take place within a complex regulatory

framework. The statutes and regulations that apply to this CCP include, but are not limited to, the

following:

• The New Mexico Mining Act (NMMA) and administrative rules;

• New Mexico Water Quality Act (WQA), and the New Mexico Water Quality Control Commission (WQCC) Regulations; and

• Office of the State Engineer (OSE) rules and regulations governing the drilling of wells and the appropriation and use of ground water.

1.3.1 The New Mexico Mining Act and Administrative Rules

The NMMA, which was enacted by the New Mexico legislature in 1993, requires that closeout plans

be put in place for mines within the state. The legislature established a goal of promoting responsible

utilization and reclamation of lands impacted by mining while also recognizing that mining is vital to

New Mexico. Rules to implement the requirements of the NMMA were promulgated in 1994. The

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program is administered by the Mining and Minerals Division of the New Mexico Department of

Energy and Natural Resources (MMD).

Chino is regulated as an ‘existing mine” under the NMMA because it produced marketable minerals

for a total of at least two years between January 1, 1970 and the effective date of the NMMA. The

closeout plan is the core of an existing mine permit. The MMD’s New Mexico Mining Rules (Rules)

and advisory Closeout Plan Guidelines (Guidelines) provide a foundation for the development of

Closure/Closeout Plans. Subpart 506.A states that “… closeout plans shall be based on site-specific

characteristics and the anticipated life of the mining operation. Site-specific characteristics include,

but are not limited to, disturbances from previous mining operations, past and current mining methods

utilized, geology, hydrology and climatology of the area.” The Guidelines recognize that each site

presents a unique set of circumstances and that many of the mines subject to closure requirements

were largely developed prior to the NMMA without any requirements for reclamation.

The landowner selects the post-mining land use, which must be approved by the Director of the

MMD. Post-mining land uses include, but are not limited to, agricultural (e.g. cropland, grazing land

or forestry), commercial, industrial or ecological uses that would comply with applicable laws and

regulations. Determining future land-use is the first step in deciding how much effort, should be put

into reconstructing lands disturbed by mining and in determining the amount of financial assurance

required for the site.

The “default” reclamation standard is ecological, that is the closure plan must demonstrate the work

to be done to reclaim the permit area “to a condition that allows for the re-establishment of a self-

sustaining ecosystem on the permit area following closure, appropriate for the life zone of the

surrounding areas.” This reclamation standard must be achieved unless the operator can show that it

conflicts with an approved post-mining land use, or can demonstrate that reclamation of an open pit

or waste unit “is not technically or economically feasible or is environmentally unsound.” An

approved existing mine permit applies for the life of the operation.

The MMD’s recommended format for the closeout plan contains the following basic elements:

• Project Description. An introduction that provides a brief history and explanation for the submittal of the closeout plan;

• Site-Specific Characteristics. A discussion of site-specific information;

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• Post-Closure Land Use. A discussion of post-mine land use(s) proposed by the Permittee for the mine site. A justification for each separate proposed land use should be provided;

• Waiver from Self-Sustaining Ecosystem or Post Mining Land Use. The Permittee should identify and provide justification for each area of the mine where a waiver from the self-sustaining ecosystem is requested;

• Description of Closeout Activities. A description of the reclamation; removal of trash, equipment and debris; disposal of wastes; stabilization; monitoring programs to address post-closeout site conditions and safe-guarding work to be performed;

• Environmental Standards Compliance. Information necessary to demonstrate compliance with environmental criteria;

• Closeout Plan Schedule. A schedule providing a timetable for the various stages of closeout work to be performed;

• Closeout Permitting Requirements. A list of all federal and state permits required for the completion of the closeout plan;

• Post-Closeout Map(s). A topographic map of the anticipated surface configuration upon completion of the closeout plan;

• Cost Estimate for Closeout. A cost estimate for the proposed closeout work; and

• Appendices. Any additional information necessary to support the closeout activities.

The NMMA requires that each operator post, prior to obtaining a permit, financial assurance

“sufficient to assure the completion of the performance requirements of the permit, including closure

and reclamation, if the work had to be performed by the director or a third party contractor.” The

financial assurance estimate should reflect the probable difficulty of reclamation or closure and

include, at a minimum, the following costs; mobilization, demobilization, engineering re-design,

profit and overhead, procurement costs, reclamation or close out management and contingencies. The

Act specifies the forms of allowable financial assurance, which include trust funds, guarantees,

collateral and letters of credit. Permittees are also allowed to use mechanisms such as “net present

value” and to accelerate their reclamation work to decrease their financial assurance obligations.

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1.3.2 New Mexico Water Quality Act and the New Mexico Water Quality Control Commission Regulations

The Mining and Environmental Compliance Section of the New Mexico Environment Department

Ground Water Quality Bureau (NMED) conducts all of the permitting, spill response, abatement and

public participation activities for mining facilities in New Mexico in accordance with the WQCC

regulations (20.6.2 NMAC). In addition, the NMED participates in the implementation of the

NMMA regulations by reviewing and commenting on mine permits and closeout plans, coordinating

environmental protection requirements at mine sites with the MMD, and providing determinations

that environmental standards will be met after closure of mining operations.

The Permittee is responsible for providing the necessary information to the NMED to allow the

Secretary to make a determination that the facility’s closeout plan is expected to achieve compliance

with all applicable environmental standards if carried out as described. These environmental

standards related to water quality are:

• Ground water standards under the WQCC regulations. The information for this part of the determination comes from evaluations of potential historic and current mining activity sources of impact to ground water quality. This evaluation process typically includes data from field measurements of discharge and/or leachate quality, ground water monitoring data collected pursuant to operational discharge permits, and modeling.

• Standards for Interstate and Intrastate Streams adopted by the WQCC. New Mexico’s surface water quality standards were developed under the State Water Quality Act and are consistent with the federal Clean Water Act. The Permittee must demonstrate the proposed closeout plan will meet applicable water quality standards under Section 1102, include adequate monitoring and other commitments to demonstrate that the standards will be met and include corrective action procedures that will be implemented in the event that standards are not met.

The NMED requires that the Permittee submit engineered designs for caps; covers; acid rock drainage

controls; and ground water remediation systems that are components of closure; surface water

protection and/or remediation systems that are components of closure; closure specifications for

raffinate ponds, pregnant leachate collection ponds and other impoundments; closure specifications

for pipeline dismantling, removal, and closure in-place; and monitoring well abandonment

procedures. In addition, the closure plan should include a post-closure monitoring plan and a

contingency plan to address a potential exceedance of applicable ground water standards. The NMED

must also review and approve the financial assurance plan.

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1.3.3 Office of the State Engineer (OSE) Rules and Regulations Governing the Drilling of Wells and the Appropriation and Use of Ground Water

Water management in New Mexico is guided by several nearly 100-year-old principles in the New

Mexico Constitution. Under New Mexico water law, all ground and surface waters belong to the

public and are subject to appropriation under the Doctrine of Prior Appropriation, a constitutional

provision that says earlier appropriations have priority over later appropriations. The Office of the

State Engineer (OSE) is charged with administering the state's water resources. The State Engineer

has power over the supervision, measurement, appropriation, and distribution of all surface and

groundwater in New Mexico, including streams and rivers that cross state boundaries. The OSE

issues permits for drilling new wells, including wells used for monitoring and remediation of

impacted ground water.

1.3.4 Agency Coordination.

NMMA permits are umbrella permits that require the operator to have obtained all other necessary

permits and to obtain a determination from the NMED that the permitted mining activities will

achieve compliance with environmental standards. The Act also imposes requirements on all

permitting agencies regulating mining operations to coordinate with each other and to avoid

duplicative and conflicting requirements and permit administration.

The MMD has entered into agreements with the federal Bureau of Land Management (BLM) and the

U.S. Forest Service (USFS) that establish processes for cooperation on mines on federal land. The

State Land Office modified its rules to largely require their lessees to follow the NMMA rules.

NMED and MMD also work closely together with operators to avoid duplicative and conflicting

requirements. For example, if a mining operation has potential groundwater contamination concerns,

the NMED will require that the operator obtain a discharge permit with a “closure plan.” The closure

plan will attempt to ensure a long-term solution to any groundwater pollution concerns.

In these situations mine operators will often submit one plan to both agencies. The agencies will then

negotiate with the operator, and amongst themselves, to establish one set of requirements for the

reclamation of the facility. The agencies will also allow the operator to provide financial assurance

that satisfies both permits. After the plans are approved, the agencies then continue to coordinate on

the implementation of the CCP.

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1.4 Closure Summary

1.4.1 History of Mining Activity at Chino

This region of New Mexico has a long history of mining activities due to significant deposits of

porphyry copper. Mining in this region is a vital part of historical and current global and local

economies. The Chino mine area may be the oldest active mining site in the American Southwest;

Apaches, Spaniards and Mexicans all collected native copper from this area. Underground mining

began in this region in the early 1800’s and continued through the mid-1970s. Open pit operations at

the Santa Rita Pit began on a limited basis around 1910 and continue to the present day. Chino and

its sister mines at Tyrone and Cobre employ 1,255 people in Grant County, New Mexico, 808 of

whom work directly for Chino.

Currently, the Santa Rita Pit covers approximately 1,500 acres and is more than 1,500-feet deep and

1.8 miles in diameter. The uppermost level of the pit is located on the pit’s east side at approximately

6,675 feet amsl and the lowest point is near the south-central Estrella Pit area, at an elevation of

approximately 5,050 feet amsl which is the lowest point for 10 miles. The Lee Hill Pit bottom is at an

elevation of 5,250 feet amsl.

Major stockpiling of rock in the mine area began in approximately 1940 in the South Stockpile Area.

Stockpiling operations expanded to the West and Lampbright Stockpiles in the late 1960s and early

1970s. Materials were first placed in the North Pit Stockpile in 1986. Several smaller stockpiles

(North, Northwest, and Northeast Stockpiles) were also placed north of the pit. Stockpiling of waste

rock and leach materials in the Lee Hill Pit area began in 1998.

The first monitoring wells were installed in the mid 1980s and the first known seep and spring survey

was conducted in 1985 and 1986. This early data indicated that groundwater quality in the pit area

generally did not meet WQCC water quality standards. These exceedances of the WQCC water

quality standards in and near the pit are a result of a combination of natural mineralization, historical

and current mining activity. Naturally mineralized conditions associated with the ore body likely

adversely impacted groundwater in the vicinity of the pit even prior to mining activity.

The stockpiles in the vicinity of the pit were established before modern-day environmental practices

were standardized. Consequently, seepage from these stockpiles provides a current source of

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impacted groundwater. Other current sources of poor-quality inflows to the pit include seepage from

mine operations reservoirs (i.e., Reservoirs 3A, 6, and 7) located around the perimeter of the pit, and

from places where leach solutions have escaped from historical or present leaching operations.

Precipitation and surface runoff along the pit benches, and groundwater that daylights along the

seepage face of the pit is exposed to oxygen and sulfur-bearing minerals resulting in increased acid

generation within the exposed portions of the pit. This latter source of impacted water within the pit is

an unavoidable consequence of open pit mining; there is no practical way of preventing acid

generation within the confines of the Santa Rita open pit.

Regardless of the complexities described above related to water quality and cause-and-effect

relationships, the most critical aspect of the hydrogeologic system is that the open pit is a passive

hydrologic sink, which draws in and contains impacted groundwater from various sources. The open

pit is the ultimate destination of impacted groundwater within the hydrologic sink, and serves as the

single most effective system for extracting impacted groundwater at Chino. NMED has recognized

that the water quality that enters the hydrologic sink is impaired through imposing abatement

requirements under the operational discharge permits and under the closure requirements of DP-1340

including associated financial assurance for closure and post-closure.

1.4.2 Active Mining and Ore Beneficiation Operations at Chino

Chino recovers products from the mined ore using two methods of beneficiation: (1) milling and

concentration of ores to produce copper and molybdenum concentrates for smelting and (2) leaching

of ores to recover pregnant leach solution (PLS) that is processed in the solution

extraction/electrowinning (SX/EW) facility to produce pure copper cathodes. The copper recovery

method for a particular ore depends on its grade (percentage of copper) and type of mineralization.

Optimizing copper recovery from both ore types allows Chino to maximize efficient recovery of the

natural resource.

The mined ore at Chino is directed to leach stockpiles or to the primary crusher where the ore is

crushed into small enough sizes to be placed on a conveyor belt. After the primary crusher Chino uses

large grinding mills to further crush and grind the ore to the consistency of beach sand. Because

nature creates copper in low densities (typically less than 1 percent grade), copper levels must be

increased or "concentrated" to be recovered economically. This is accomplished by the next step,

called flotation. Finely ground ore is mixed with water and reagents creating slurry. When agitated

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and injected with air, froth is created in the slurry and the copper is liberated or "floated" away from

the host rock. The product of this process is dry, gray powder called copper concentrate, which

contains about 30 percent copper. Chino also produces molybdenum concentrate from the same ore.

The copper concentrate is transported off-site to another facility for smelting since Chino

decommissioned its smelter facilities in 2005. The molybdenum concentrate is also processed at

another facility.

The other method of beneficiation used at Chino to recover copper is leaching of ores. Leaching

began in 1963 at the South Stockpile and expanded to the West and Lampbright Stockpiles in 1969

and 1976, respectively. Prior to 1936, leaching was done on a small scale at sites near the edges of

the pit.

Leach stockpiles that are operated at Chino are part of the mine’s SX/EW process. This process

involves leaching stockpiled ore with a weak sulfuric acid solution called raffinate. The resulting

solution, known as PLS, is recovered and then contacted with an organic solution or “extractant” in

the solution extraction (SX) stage. The copper is extracted away from the aqueous phase leaving

behind most of the impurities that were in the leach solution. The raffinate is recycled to the leaching

phase of the process. The copper-bearing organic phase is stripped of its copper by mixing it with

acid, which returns the copper to an aqueous phase. This solution is advanced to the electrowinning

(EW) stage while the organic phase is returned to the extraction phase of the process. During the

electrowinning phase the copper is reduced electrochemically from copper sulfate solution to a

metallic copper cathode.

1.4.3 Closure Activities

MMD and NMED regulations require that existing mines prepare a CCP that reflects anticipated

conditions at the end of active mining and post, prior to obtaining a permit, financial assurance

“sufficient to assure the completion of the performance requirements of the permit, including closure

and reclamation, if the work had to be performed by the director or a third party contractor.” The CCP

is revised on a five year basis through out the mine’s active life to reflect changes in mine operations

and site conditions. An operator would prepare an amended CCP at the time of closure that would

reflect actual, rather than anticipated, conditions at the end of active mining.

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The requirement that the amount of financial assurance be based upon third party costs protects the

state from mine operators that close during the period of the permit without the financial resources to

complete the closure and reclamation requirements of the permit. This regulatory approach is used in

other regulatory programs, such as hazardous waste treatment storage and disposal facility permits.

Financial assurance amounts calculated in this way are unlikely to reflect an operator’s actual costs at

closure because the operator will use its equipment and manpower resources and buying power for

commodities such as diesel and electricity.

While conceptually simple, the mine closure and reclamation process is extremely complex in

practice and the development of this update of Chino’s CCP has required the coordinated efforts of a

diverse group of scientists and engineers. This CCP relies on the application of standard reclamation

principles to Chino’s unique set of conditions. Chino will continue to integrate closure decisions into

mine planning and operational decisions to promote efficiency in the closure process, reduce the

amount of disturbed land and reduce future closure capital and operation and maintenance costs.

Chino also has the option under both MMD and NMED financial assurance regulations to accelerate

its reclamation work, where appropriate, to decrease its financial assurance obligations.

This CCP is the five year update of the plan that was originally submitted to the MMD and NMED in

2001. Like the original 2001 plan and financial assurance, this updated plan is a “snap shot in time”

that reflects Chino’s current mine plan and understanding of site conditions.

To aid Chino in the preparation of this CCP update, environmental scientists and engineers have

performed extensive, site-specific investigations to develop a comprehensive understanding of site

conditions. Over the past decade, a broad range of specialized studies (e.g., groundwater, cover

design, revegetation, slope stability and water treatment) have been conducted to evaluate the

environmental and economic implications of various closure alternatives (Section 5). In addition,

Chino has gained extensive practical experience with reclamation techniques through technology

transfers associated with the concurrent reclamation activities at Tyrone Mine.

Results from these, and other, studies were integrated through a comprehensive feasibility study to

better understand the global implications of various closure alternatives. The Chino Feasibility Study

(DP-1340, Condition 93) involved a collaborative process whereby representatives from Chino, the

NMED, and MMD selected closure alternatives and mechanisms for evaluation. Ultimately, the

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results of the Feasibility Study figured prominently in the closure decisions that are represented in this

plan.

The site conditions assumptions used for this CCP update are not static, however. Monitoring well

data is regularly collected in accordance with the operational discharge permits. Chino is also

performing a number of studies pursuant to conditions in the current version of DP-1340 and under

the Administrative Order on Consent (AOC). The AOC studies address historical impacts to soil,

sediment and surface water. The constant flow of information that results from all this ongoing work

required Chino to establish a cut off date of June 1, 2007 with the agencies relative to new data and

information that would be incorporated into this CCP update. It is likely that the results of the

ongoing studies may alter some of the assumptions used in this CCP update.

The Site Wide Abatement process is proceeding according to 20.6.2.4106 NMAC and Conditions 30

through 33 of DP-1340. The results of this process may influence the CCP. Chino believes that

alternative abatement standards may be necessary for some constituents at one or more locations. The

abatement standards and requirements in 20.6.2.4103(E) will allow Chino to propose alternative

abatement standards upon a demonstration of the following:

• compliance with the standard is not feasible by the maximum use of technology, within the economic capability of the responsible person or there is no reasonable relationship between the economic and social costs and benefits;

• the proposed alternative abatement standard is technically achievable and cost-benefit justifiable; and

• compliance with the proposed alternative standard will not create a present or future hazard to public health or undue damage to property.

The current phase of field work for the Stage 1 abatement investigation started in May 2007 and is

still ongoing. The objectives of Stage 1 are to define site conditions and provide the data necessary to

select and design an effective abatement option. Once Stage 1 is completed the Stage 2 process will

be used, if necessary, to propose alternative abatement standards for NMED’s approval. These

alternative standards would then be used to drive the evaluation of cleanup technologies used at the

time of actual closure.

Chino’s current mine plan projects that active mining will continue for many years. Active mining

means the mining and hauling of ore for beneficiation at the concentrator or on leach stockpiles.

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Chino will continue to leach the stockpiles for a number of years after it has stopped mining and

hauling new ore and the concentrator facility is taken out of service. During this transition period

Chino’s SX/EW plant will continue to recover PLS and process water from the toes of the stockpiles

while closure activities are implemented at other areas of the mine. The SX/EW plant will not close

until leach stockpiles have been drained and the last of the economically viable PLS has been

processed. Once the SX/EW plant closes Chino will fully implement the closure plan.

1.5 Description of Updated Plan

In 1994, Chino submitted a mining operations site assessment and an existing mining operation

permit application. The permit application was approved by the MMD on December 29, 1997. The

following list provides a chronology of the progress leading to this updated CCP:

• Chino submitted a preliminary CCP in December 1997.

• Chino applied for and was granted an extension by the MMD for closeout plan approval until December 31, 1999.

• Chino submitted a revised CCP in 1999. Based in part on this report, Chino secured an interim financial assurance with NMED.

• Also in 1999, Chino applied for and was granted an extension for closeout plan approval until December 31, 2001.

• Chino submitted the End of Year 2001 Through Year 2006 CCP for Chino in March 2001 (M3, 2001).

• DP-1340 was issued by the NMED on February 24, 2003 (NMED, 2003).

• The Permit GR009RE was issued by the MMD on December 18, 2003 (MMD, 2003).

• A CCP Update was submitted to MMD in February 2005 in fulfillment of the requirement in Section 8.T of the MMD Permit.

This 5-year update to the CCP clarifies and revises the closure/closeout conceptual designs presented

in M3 (2001) and Chino (2005) to account for changes in site-specific conditions, incorporate

changes from previous and ongoing reclamation activities, and accommodate the facility changes

projected in the subsequent planning period. This CCP Update also describes fulfillment and status

of the various studies associated with the permit conditions stipulated in the MMD Permit and

DP-1340 (See Section 5.0). It has been prepared to comply with applicable regulations and

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requirements stipulated in the NMMA (NMAC Title 19, Chapter 10, Part 5), New Mexico Water

Quality Act (NMWQA), and the New Mexico Water Quality Control Commission (NMWQCC)

Regulations (NMAC Title 20, Chapter 6, Part 2).

1.6 Summary of Financial Assurance

For financial assurance purposes, the total estimated cost to implement this updated CCP is a capital

cost of $200 million and operations and maintenance cost of $293 million. The estimated costs were

developed consistent with Condition 101 in DP-1340 and Subpart 12 in the New Mexico Mining Act

Rules. Capital costs, operating costs, and maintenance costs associated with third-party

implementation of the CCP, as well as long-term operation and maintenance for a period of

100 years, have been developed for this updated plan (Section 8). The cost estimate includes direct

costs, contingency costs and indirect costs. The EOY-2007 scenario, used to develop the financial

assurance cost estimate, reflects the most conservative cost scenario for closure/closeout in the time

period between 2007 and 2013. This assumption is based on several considerations, but principally

the following:

• Where practical and economic, mining work after year 2007 should incorporate “mining-for-closure” practices to accommodate the reclamation, such as placement of mined materials in stockpiles outside the open pit capture zone (OPCZ) in a manner that reduces the volume of materials that must be moved to achieve post-closure slope configurations.

• Ongoing reclamation activities at the Groundhog Mine Area (currently on hold pending regulatory review), upcoming reclamation activities such as Chino Tailing Reclamation (Golder-URS, 2007), and other accelerated reclamation projects that may be completed between 2007 and 2013, are expected to reduce the overall financial assurance liability at Chino.

• Development of a borrow source near the Lampbright Stockpiles should be completed as part of mining operations and would be expected to reduce the cost of transporting cover material during reclamation in the Lampbright and north pit areas.

• Construction of the in-pit Lee Hill Stockpile and leach facilities will allow stockpile material, which otherwise would have to be placed in stockpiles outside the OPCZ, to be placed within the OPCZ during mining operations,

• Where practical and feasible as part of mining operations, final placement of material on the top surfaces of the stockpiles will be done safely and efficiently drain water off these top surfaces.

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2.0 EXISTING FACILITIES AND CONDITIONS

The following sections describe the Chino mining facilities and operations, ownership history, past

and current land uses, environmental setting (such as topography, geology, hydrology, climate, and

wildlife), and mine material characteristics. In addition, pertinent permits and operational DPs are

summarized.

2.1 Description of Mining Facilities

The general layout of the mine facilities at Chino is presented in Figure 2-1. The ore processing

operations are schematically illustrated in Figure 2-2.

The principal mine facilities and main mine components include:

• Santa Rita Open Pit;

• Waste Rock and Leach Ore Stockpiles;

• Mine Maintenance Facilities;

• SX/EW Plant;

• Ivanhoe Concentrator;

• Groundhog Mine;

• Active Pond 7 and inactive Older Tailing Impoundments;

• Water Management System (including reservoirs); and

• Ancillary Infrastructure.

These facilities are discussed below. For the purposes of CCP Update, the Chino Mine has been

separated into three geographical areas (Figure 2-1):

• The North Mine Area (NMA) (Figure 2-3) includes the Santa Rita Open Pit, waste rock and leach ore stockpiles, maintenance facilities, SX/EW Plant, Ivanhoe Concentrator, and most of the water management system in the area of the Santa Rita Pit.

• The Pipeline Corridor Area (PCA), also referred to as the Middle Whitewater Creek Area (MWWCA) (Figure 2-1), extends from the Ivanhoe Concentrator (in the NMA) to the north end of Lake One and the Hurley Operation Area.

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• The South Mine Area (SMA) (Figure 2-4) includes Lake One, active and inactive Older Tailing Impoundments and the Hurley Operation Area. It encompasses the tract from the north end of Lake One to the confluence of Whitewater Creek with San Vicente Arroyo, approximately 12 miles to the south.

Presently, the mine operates on a three-shift-per-day, seven-day-per-week basis. Rock is fragmented

using conventional drilling and blasting techniques. After blasting, the following materials are loaded

into haul trucks for delivery to the appropriate destination:

• sulfide ore with a copper content above mill cutoff grade is delivered to the primary crusher west of the pit and then to the Ivanhoe Concentrator (Section 2.1.5) for processing;

• leachable ore is delivered to leach stockpiles around the periphery of the pit and to the Lampbright Stockpiles; and

• waste rock (material below leach cut-off grade) is stockpiled in several locations around the pit;

• overburden suitable for cover materials is currently stockpiled on the Upper South Stockpile.

2.1.1 Santa Rita Open Pit

The Santa Rita Open Pit is about 1,500 feet deep, 1.8 miles in diameter, and covers an area of

approximately 1,500 acres. It includes the Lee Hill, Town Site Island, South and East pit areas, and a

number of pregnant leach solution (PLS) booster and pit dewatering collection sumps joined by a

network of pipelines. The uppermost level of the pit rim is on the south side at an elevation of

approximately 6,600 feet above mean sea level (ft amsl), and the lowest level in the pit is near the

south-center of the pit at an elevation of approximately 5,000 ft amsl. The pit was developed in

benches with 50-foot vertical highwalls. The primary crusher is located approximately 3,200 feet

west of the pit at an elevation of 6,200 ft amsl.

2.1.2 Waste Rock, Leach and Cover Material Stockpiles

Several stockpiles are located in and near the Santa Rita Pit. The stockpiles generally fall into three

types: 1) leach stockpiles, which are used to extract copper from oxide ore; 2) waste rock stockpiles,

which are store excavated materials that have little or no copper value in current economic analysis;

and, 3) cover material stockpiles, which are set aside to store overburden suitable for future

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reclamation purposes. The materials comprising the stockpiles are listed in Table 2-1. The following

paragraphs describe the main stockpiles areas at the mine.

Lampbright Stockpiles

The Lampbright Stockpiles are located east of the Santa Rita Open Pit and consist of two leach

segments (Figure 2-3): 1) the Main Lampbright and South Lampbright Stockpiles, and 2) the

Southwest Lampbright Stockpile, a waste rock stockpile. These three stockpiles are adjacent to one

another, built mostly within a tributary valley (Tributary 1) of Lampbright Draw. The tops of the

leach stockpiles are nearly level, sloping less than 5 percent.

The Main Lampbright Stockpile is primarily within the drainage area of Tributary 1 and is bounded

on the north by the North Diversion Channel and on the east by Tributary 2. The South Lampbright

Stockpile is a southward extension of the Main Lampbright Stockpile. The leach stockpiles have

been constructed experimentally in lifts ranging from 20 to 40 ft. The Southwest Lampbright

Stockpile is on the northeast-facing slope of Kneeling Nun Ridge and is a waste rock pile and was

built in 50-foot lifts. PLS and stormwater runoff from the Lampbright Stockpiles is collected in

Reservoir 8 and pumped to the SX/EW Plant for copper recovery.

Prior to 2006 six stormwater detention reservoirs (Ponds 1 through 6) intercepted storm runoff from

Tributary 1, including the Southwest Lampbright Stockpile. These ponds increased runoff storage

capacity and resulted in lower peak flows into Reservoir 8. In 2006, Ponds 1 through 6 were removed

as part of surface water control improvements to the Reservoir 8 area in fulfillment of Condition 10 of

DP-376. Improvement work included the removal of affected soils, regrading of unaffected soils, and

construction of Sediment Basins 1 though 3. Solutions from the sediment ponds are delivered to

Reservoir 8.

Three sumps (Lampbright Sumps 1, 2, and 3) are located along the north side of the Main Lampbright

Stockpile. Sumps 1 and 2 collect seepage and stormwater runoff, which are pumped to Reservoir 7

and used as makeup water at the SX/EW Plant. Sump 3, located along the northeast edge of the

stockpile, is a buried french-drain and vertical sump system designed to intercept impacted

groundwater. The East Lampbright Sump is located on the central eastside of the Main Lampbright

Stockpile. Solutions collected at this sump are pumped to Reservoir 8.

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South, Upper South, and West Stockpiles

The South, Upper South, and West Stockpiles are located south and west of the Santa Rita Open Pit

(Figure 2-3). These South and West Stockpiles are low-grade leach stockpiles. The Upper South

Stockpile is a waste rock stockpile. Stockpiling of low-grade copper ore on the West Stockpile began

in 1969. Mined rock was placed on the South Stockpile as early as 1940. The Upper South Stockpile

contains waste rock and overburden suitable for reclamation. Chino has dedicated the upper lifts of

this Upper South Stockpile for storage of reclamation cover materials.

A number of stormwater and process water collection systems are associated with the South and West

Stockpiles, including:

• Reservoirs 4A and 2 receive stormwater and process water overflow;

• Dam 17 is a stormwater reservoir;

• Reservoir 9 as stormwater reservoir;

• Runoff and seepage containment dams and sumps have been installed along the base of the west side of the West Stockpile (these facilities are on its western side to prevent surface and shallow subsurface flow to Hanover Creek and form an arc from the northwestern corner of the West Stockpile and its west side between the toe and Hanover Creek); and

• PLS from the West and South Stockpiles is collected in collection systems such as the unlined PLS launder, PLS collection pond and/or Reservoirs 2 and 4A. The PLS is transferred to the stainless steel PLS tank and pumped to the Solvent Extraction/Electrowinning (SX/EW) Plant.

Santa Rita Open Pit Stockpiles

Four stockpiles occur within and along the perimeter of the Santa Rita Open Pit and are known as the

North In-Pit Leach, North, Northwest and Northeast Stockpiles (Figure 2-3). The North, Northwest,

and Northeast Stockpiles contain both overburden and waste rock. The North In-Pit Leach Stockpile

contains low-grade ore. PLS from the North In-Pit Leach Stockpile is collected in sumps and pumped

to the SX/EW Plant. Reservoir 5, located north of the North Stockpile and north of Highway 152,

collects stormwater runoff and is used as makeup water for the process water system.

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2.1.3 Maintenance Facilities Area

The Maintenance Facilities Area for mine operations is west of the Santa Rita Open Pit between the

West and South Stockpiles (Figure 2-3). A number of offices and storage facilities are located in this

area, including: mine operations; the assay laboratory; security; the geology, safety, and mine

engineering and planning departments; the vehicle and electrical maintenance shops; the primary

crusher; and the conveyor. Three small retention basins along the southeast side of this area collect

surface water. The surface water flows southwest and is incorporated into the West and South

Stockpile leach systems.

2.1.4 Solution Extraction/Electrowinning Plant

Chino’s SX/EW plant was constructed in 1987 and became operational in 1988 (Figures 2-2 and 2-3).

PLS is the fluid that results from the stockpile leaching operations. The PLS is conveyed to the

SX/EW feed pond via pumps and pipes, where it is processed to extract copper. An organic reagent

is added to the PLS and later an acidic solution is added to strip the copper from the reagent. The

copper in the acidic solution is then electroplated to a copper cathode. The barren copper leach

solution (known as raffinate) is recycled to the top of leach stockpiles. Raffinate is the effluent from

the SX/EW Plant. These process waters are continually recycled through the use of pumps, pipes,

and reservoirs which provide temporary storage for the process waters.

The SX/EW Plant feed pond has a capacity of 1.4 million gallons and is lined with 80-mil high

density polyethylene (HDPE). Recirculated raffinate that leaves the SX/EW Plant is stored in a

900,000 gallon above-ground stainless-steel holding tank. Prior to 1997, the raffinate was stored in a

2.3-million-gallon holding pond lined with 80-mil HDPE located immediately south of the tank. This

lined pond now serves as a standby containment facility in the event that emergency conditions arise

at the raffinate storage tank. Any overflow from the raffinate tank would flow via gravity into this

lined pond.

2.1.5 Ivanhoe Concentrator

The Ivanhoe Concentrator is south of the South Stockpile and produces copper and molybdenum

concentrate slurry from the milled ore (Figure 2-3). The copper and molybdenum concentrates are

shipped to off-site markets. Tailing materials produced from this process are pumped as slurry to the

tailing facilities to the south. Facilities in the area of the Ivanhoe Concentrator include the coarse ore

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storage area, grinding operations, laboratory, concentrate and tailing thickeners, maintenance shop,

guard house, process water tanks, and storage yard. The concentrator currently operates continuously

with two work shifts.

2.1.6 Groundhog Mine Area

The Groundhog Mine Area is an historical mining area approximately one mile northeast of Bayard

and east of San Jose Mountain (Figure 2-1). The site is addressed under the Hanover/Whitewater

Creeks Investigation Units of an NMED Administrative Order on Consent (AOC). The former

facilities and workings associated with the mine occupied the saddle between Bayard Canyon and an

unnamed tributary of Whitewater Creek to the northwest and extended southwest down Bayard

Canyon and southeast into Lucky Bill Canyon. The Groundhog Mine Area is currently comprised of

the Groundhog Stockpile Area and the Groundhog No. 5 site. The Groundhog Stockpile Area was

part of the Groundhog Mine complex, which consisted of four additional shafts and other mine

openings and waste rock piles. The Groundhog No. 5 site is an abandoned mine shaft and an

associated waste rock pile that covers less than two acres. Under the AOC, 99 percent of the

Groundhog Stockpile in Bayard Canyon has been removed to the West Stockpile. The predominantly

limestone stockpile material at the No. 5 site has been regraded and the shaft closed. The Groundhog

Mine Area has been either regraded or removed and is now pending capping followed by

revegetation. Completed and ongoing reclamation activities at the Groundhog Mine Area are

discussed in Section 7.0.

2.1.7 Hurley Power Plant

The Hurley Power Plant is on the south side of the Hurley Operation Area (Figure 2-4). The plant

was constructed in 1911 to provide a reliable source of power to the Hurley Concentrator. The power

plant burned coal until 1946, when it was then converted to natural gas. Currently, the power plant

provides a portion of the electrical power for Chino operations. Power from the public utility

provides the remainder of the electrical needs at Chino.

2.1.8 Tailing Impoundments

The tailing impoundments are located in the SMA and include the inactive Older Tailing

Impoundments, Lake One, Axiflo Lake, and active Tailing Pond 7 (Figure 2-4). Tailing is the

crushed rock residue remaining after the processing of milled ore. Tailing slurry generated during the

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ore concentration process is currently gravity fed by pipeline and deposited by crane-mounted

cyclones on Tailing Pond 7 at the southern end of the tailing facility.

Older Tailing Impoundment Area

The Older Tailing Impoundment Area includes Tailing Ponds 1, 2, B, C, 4, 6E and 6W, along with

Lake One, which historically stored water for the former Hurley Mill and Axiflo Lake, which is

currently used as a process water reservoir. Beginning in 1991 Chino started covering these tailing

impoundments with native soils to reduce wind-blown dust.

Ancillary facilities associated with the older tailing impoundments include:

• A Class D solid waste landfill, Tailing Pond 1 landfarm (closed in 2005), and tailing and reclaim water pipelines. The Class D landfill was operated under the authority of New Mexico solid waste management regulations.

• The Tailing Pond 1 landfarm has been closed according to a closure plan approved by NMED on November 21, 2005. The closure report was approved by NMED on April 28, 2006. The closed landfarm facility occupies less than an acre and on the southern edge of Tailing Pond 1. The landfarm was used to treated non-hazardous hydrocarbon-contaminated soils.

Tailing Ponds 1, 2, B, C, 4, 6E and 6W

Beginning in 1910, tailing generated by the decommissioned Hurley Concentrator, was deposited in a

series of older impoundments (Tailing Ponds 1, 2, B, C, 4, and 6). Starting in 1982 tailing from the

Ivanhoe Concentrator was disposed in Tailing Pond 6 (East and West). The Older Tailing

Impoundments are inactive, with the exception of Tailing Pond 4 and the southern portions of the

Pond 6E and 6W area, which are used for emergency discharges of tailing and stormwater.

Lake One

Lake One was created in 1910 to collect and store water for use in the Hurley Mill. The lake was

created by constructing an earth-fill dam southeast of the Hurley Operation Area. Until 1955 the

water in the lake was used in the milling process. Over time, Lake One gradually filled with

materials from Whitewater Creek and tailing from the milling operations. After 1955 the water in the

lake became unacceptable for use in the mill, due to low pH, and was sent to the thickeners to be

neutralized by excess alkalinity in the tailing. The water was then used to convey tailing to the

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storage facilities, then decanted and pumped back to the mill for use in processing. In 1982 the mill

was shut down.

In 1984 the Whitewater Creek diversion was constructed that diverted water around the eastern side

of Lake One. In 2003 Whitewater Creek was again diverted farther to the east into James Canyon

Reservoir. The overflow from the reservoir is now directed into Bolton Draw, located farther to the

east. The lake is now essentially dry, receiving surface recharge from incident precipitation. Lake

One materials are generally unsaturated, with the exception of the southern end of Lake One where

saturated conditions exist.

Mining and copper recovery of Lake One materials has occurred over the past several years and is

ongoing. The Lake One material is hauled over seven miles to the leaching operations in the NMA.

Chino is authorized to blend leach ore and Lake One material then place it on the South Lampbright

and Main Lampbright leach ore stockpiles. The placement of this Lake One material is permitted for

up to 4,000 tons per day.

Axiflo Lake

Axiflo Lake, located south of Tailing Pond 2, was created in 1919 as a process water reservoir. It was

historically used for the storage of tailing decant water and most recently reclaimed water from Pond

7 and fresh makeup water from the Bolton production wells. Water stored in Axiflo Lake is pumped

to a 750,000 gallon storage tank for treatment. The treated water is then pumped to the Ivanhoe

Concentrator for use in ore processing. Axiflo Lake is now in the decommissioning process for

closure as part of the reclamation of the Older Tailing Impoundments.

Tailing Pond 7

Created in mid-1988, Pond 7 is the only tailing impoundment currently operating. Tailing generated

by the Ivanhoe Concentrator is conveyed through a set of 9-mile long pipelines and deposited in

Pond 7. Pond 7 is permitted to receive discharges from the termination tank, which include: tailing

slurry from the Ivanhoe Concentrator; treated water from the Metals Recovery Unit; stormwater;

untreated domestic wastewater; mine water from Ivanhoe Concentrator; and stormwater from

Reservoir 17. It also receives stormwater runoff from tailing ponds 6E and 6W, which may include

runoff from the other older tailing ponds. It also may receive groundwater from the Interceptor Well

System south of Pond 7. The Interceptor Well System is an attendant facility to Tailing Pond 7 and

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lies along its southern edge. The system consists of 18 wells that are used to intercept groundwater at

the south end of Tailing Pond 7.

The initial design maximum height of the dam is approximately 230 feet at a crest elevation of

5,475 ft amsl. The design capacity of Tailing Pond 7 is 415 million tons with an average existing

exterior slope of 4(H):1(V).

2.1.9 Water Management System

Chino’s water management system provides process make-up water, process solutions, and controls

stormwater. Figure 2-5 illustrates the water supply and use cycle at the mine. The system consists of

the following facilities:

• production wells that supply process water;

• reservoirs for storage of process water, stormwater runoff, and some of the ephemeral flows in the major drainages (i.e., James Canyon fresh water diversion and reservoir);

• Cobre to Chino pipeline;

• various tanks and sumps that collect and store process solutions;

• diversion structures for rerouting natural drainage channels around operational facilities; and

• pipelines and pumping stations for transferring water from one location to another.

Several well fields supply much of the water used to operate the mine. These well fields include

production and dewatering wells and interceptor well systems in the Santa Rita Open Pit Area,

interceptor wells south of Pond 7, and production wells south and east of the tailing impoundments.

Groundwater has also been pumped from underground workings in the Santa Rita Open Pit Area.

In the NMA, several reservoirs serve to control PLS, process solutions, and stormwater runoff,

throughout the mine site (See Figure 2-3). Table 2-2 lists the reservoirs, impoundments, sumps, and

storage tanks in operation at the mine. Chino practices water conservation through the recirculation

of process water and treatment and reuse of municipal wastewater from nearby towns.

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Major diversion channels that are part of the Chino stormwater and stream flow management system

include:

• the North Diversion Channel that routes runoff around the Lampbright Stockpiles to Lampbright Draw.

• the Whitewater Creek diversions in the SMA that include the 1911 diversion around the Older Tailing Impoundment Area, the 1984 diversion around Lake One, the 1988 and 1998 diversions around Tailing Pond 7, and the James Canyon Diversion completed in 2003.

2.1.10 Other Ancillary Facilities, Structures, and Systems

In addition to the major project facilities, structures, and processes identified above, there are a

number of ancillary facilities that support operations at Chino including:

• administrative/office facilities;

• outdoor lighting;

• haul and access roads;

• electrical power transmission lines;

• explosive, fuel, and reagent storage areas;

• drainage, diversion, and sediment control structures;

• fencing and security systems;

• horizontal drains used to manage slope water;

• dust suppression system; and

• various pipelines.

2.2 History of Mining at Chino

Chino is the largest copper mine in New Mexico and among the oldest in the U.S. The Chino (Santa

Rita) copper deposits were known to the Apache Indians prior to Spanish settlement (M3, 2001). The

Spanish learned of the deposits by the 1770s and began development of the Santa Rita copper

deposits in the early 1800s when a land concession for the area was granted to Don Francisco Elguea.

Through most of the 1800s, the mine was leased from Elguea and his heirs, although Apache Indians

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prevented continuous working of the mine. Early mining methods used underground shafts that

followed the larger ore bodies. Mined ore was transported to Mexico.

In 1909 the Chino Copper Company was formed and assumed ownership of the mine. Open-pit

mining operations at Santa Rita began in 1910 and have continued and expanded to the present. In

1911 the Chino Copper Company constructed a mill and concentrator near the Hurley Operation

Area, to which the ore was transported from Santa Rita by rail for flotation processing. Ore that was

not suitable for the flotation process was stockpiled near the pit, and tailing from the concentrator was

deposited east and south of Hurley along Whitewater Creek. Construction of the Hurley Smelter was

completed in 1939. In mid-1982 the Hurley Mill and Concentrator were replaced by a new mill and

concentrator (together called the Ivanhoe Concentrator) located closer to the open pit.

In 1936 Chino Copper Company started leaching operations of the low-grade ore stockpiles near the

open pit. Copper was extracted from the resulting leach solutions at precipitation plants that were

located in Whitewater Creek just upstream from the confluence with Hanover Creek. In 1988 Chino

constructed the SX/EW Plant just east of the open pit and additional leaching activities began in

permitted areas.

2.3 History of Land Ownership

The Chino MMD Permit area consists primarily of private land owned by Chino, along with areas of

federal lands managed by the Bureau of Land Management (BLM).

Except for the Kneeling Nun Area, Chino controls the mineral rights on all BLM land within the mine

permit area through unpatented mining claims.

The ownership of Chino property from the time of the Elguea concession through the present day is

summarized as follows:

• Through most of the 1800s control of the Santa Rita copper deposits was in the hands of Don Francisco Elguea and his heirs.

• In the late 1800s title to the property changed hands twice before the Santa Rita Mining Company purchased the property in 1889.

• The Chino Copper Company was formed in 1909 and assumed control of the property. In the mid-1920s Chino Copper Company merged with Ray

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Consolidated Copper Company and later with Nevada Consolidated Company to form Nevada Consolidates.

• In 1933 Kennecott Copper Corporation purchased Nevada Consolidates and the Santa Rita Mine.

• In the face of declining copper prices, Kennecott Copper Corporation sold a 1/3 interest in the Santa Rita mine to Mitsubishi Corporation in 1980 and the remaining 2/3 interest to Chino, a subsidiary of Phelps Dodge in 1986.

• Phelps Dodge’s Chino completed acquisition of Heisei Minerals Corporation's 1/3 general partnership interest in Chino Mines Company in December 2003. Heisei is a joint venture between Mitsubishi Materials Corporation and Mitsubishi Corporation.

• Freeport-McMorRan Copper & Gold Inc. acquired Phelps Dodge Corporation, including Chino on March 19, 2007.

2.4 Past and Current Land Uses

Mining has been the principal land use and land-based economic support for the area since open-pit

mining began in 1910. Surrounding lands have a variety of uses including residential, commercial,

industrial, grazing, timber, and recreation. Crop production has not been pursued on a large scale in

this area due to the relatively dry climate, varying topography, and poor soil conditions.

2.5 Environmental Setting

This section summarizes various aspects of the mine site, including its topography, geology, climate,

hydrology, soils and vegetation, wildlife, and material characteristics.

2.5.1 Topography

The general topography of the Chino area is depicted on Figure 2-6. Chino operations are located

near the base of the Cobre Mountains within the Pinos Altos Range of southwestern New Mexico.

The topography at Chino ranges from hilly to mountainous in the NMA to relatively flat in the SMA.

The original landscape at the site has been altered as a result of mining activities. Elevations across

the site range from less than 5,200 ft amsl along Whitewater Creek to 7,704 ft amsl approximately

1 mile south of the Kneeling Nun monolith. The topographic setting within the NMA, PCA and

SMA are described in the following sections.

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North Mine Area

The NMA includes the open pit and surrounding terrain along with Whitewater Creek to the north

end of Lake One. Major topographic features of the NMA include the Cobre Mountains and the San

Vicente Basin. Erosion of the plateau surface in the Cobre Mountains southeast of Bayard has left a

series of even-crested, southward-sloping ridges that gradually become low hills. The topographic

high within the NMA is approximately 7,700 ft amsl.

The San Vicente Basin is a broad lowland extending southward from the Mimbres Valley. The basin

terminates against the Big Burro and Little Burro Mountains on the west, the Silver City and Pinos

Altos Ranges on the north, and the Cobre Mountains on the east. The terrain slopes from these

mountains toward San Vicente Arroyo, which runs along the long axis of the basin. The San Vicente

Basin is characterized by numerous arroyos that are tributary to San Vicente Arroyo.

The Mimbres River drains the eastern slopes of the Pinos Altos and Cobre Mountains. San Vicente

Arroyo and Whitewater Creek drain the San Vicente Basin and adjacent slopes between the Big Burro

and Cobre Mountains.

The topography of the NMA consists of ridges and southeast to southwest-trending drainages. Slopes

range from 0 to 5 percent on the ridge tops to more than 65 percent on hillsides. The steeper slopes

are rock outcrops and cliffs associated with the Kneeling Nun Tuff. The natural ground surface

elevation ranges from 6,600 to 7,700 ft amsl.

The Santa Rita Open Pit in the NMA is located at the historical headwaters of Whitewater and Santa

Rita Creeks. Stockpiles of mined material discontinuously cover the pre-mining topography on the

south through western portions of the northern and eastern edges of the pit.

Pipeline Corridor Area

The Pipeline Corridor, which has also been referred to as the Middle Whitewater Creek Area

(MWWCA) (Golder, 2007a), generally encompasses the Whitewater Creek drainage area between the

confluence of Gold Gulch and Whitewater Creek in the north and the town of Hurley in the south, and

the topography is transitional between the NMA and the SMA.

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South Mine Area

The SMA operations lie along the eastern border of San Vicente Basin, approximately 7 miles

southwest of the Santa Rita Pit. Elevations in the immediate vicinity of the SMA operations range

from about 5,600 ft amsl near Hurley to about 5,250 ft amsl immediately south of Tailing Pond 7

(Figure 2-4). The original surface topography was relatively featureless in this area, with the

exception of a number of small incised washes and the channel of Whitewater Creek. The placement

of tailing, which began in 1910, has changed the original topography.

2.5.2 Geology

The Santa Rita ore deposit that has been mined at Chino lies in the southeastern corner of the Central

Mining District (Rose and Baltosser, 1966). Chino lies in the transition zone between the Colorado

Plateau and the Basin and Range physiographic provinces. The following sections describe the

geology of the ore deposits in and around the Santa Rita Open Pit in the NMA and unmineralized

rocks and sediments in the PCA and SMA.

North Mine Area

The Chino or Santa Rita Deposit is a porphyry copper body that includes intrusive and skarn-hosted

copper mineralization (Rose and Baltosser, 1966). Mineralization is associated with a generally

porphyritic composite intrusion varying in composition from granodiorite to quartz monzonite that

has domed surrounding Paleozoic and Cretaceous sedimentary rocks during the early Tertiary. The

sedimentary section was intruded by late Cretaceous quartz diorite sills that predate the main stock

intrusion but are not believed to be associated with mineralization. Post-mineralization, mid-Tertiary

volcanic rocks were extruded over the deposit and included rhyolitic tuffs and basaltic andesite flows.

Sedimentary rocks in the area include Paleozoic sandstone, limestone, dolomite, and shale. The

lower portion of the Cretaceous and all of the Triassic and Jurassic sections are not represented in the

area, presumably because the region was a topographic high during these periods, thus accounting for

the disconformity between the Permian and upper Cretaceous rocks. The upper Cretaceous rocks

include sandstone, siltstone, shale, and minor shaley limestone of the Colorado and Beartooth

Formations.

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Hydrothermal alteration and mineralization is associated with the intrusion of the Santa Rita

composite stock, which has been dated by 40Ar/39Ar methods at between 58.1 and 59 million years

old. The stock intruded at the junction of three sets of faults, including pronounced northwest and

northeast sets and a less prominent easterly set. The stock is elongated in a northwest-southeast

direction. Abundant mineralized fractures show that the stock was intensively fractured and

hydrothermally altered following solidification. Types of non-skarn alteration include potassic,

biotitic, quartz-sericitic, and argillic.

Three ages and compositions of dikes cut the intrusion. Granodiorite is the oldest and occurs as early

apophyses of the stock into the surrounding rocks and as late dikes cutting the stock. Later intrusive

rocks include dikes of quartz monzonite and latite, both of which have been dated by 40Ar/39Ar

methods at about 56 million years old, but cross-cutting relationships show the latite to be the

youngest dike phase. The latite is not mineralized; the quartz monzonite is rarely mineralized, but

usually not to ore grade.

Pennsylvanian and Mississippian sedimentary rocks, primarily limestone, that were invaded by the

magma were completely altered and replaced by calc-silicates and associated contact metasomatic

minerals. Common skarn minerals associated with these rocks include magnetite, pyrite, quartz,

garnet, epidote, actinolite, and chalcopyrite.

Chalcopyrite is the primary hypogene copper mineral in both skarn and unenriched intrusive rocks.

Without secondary chalcocite enrichment, however, little other than the skarns would be of ore grade.

Cretaceous clastic sedimentary rocks and the quartz diorite porphyry sills within surrounding

sedimentary rocks are also secondarily enriched, frequently to ore grade. The upper Paleozoic rocks,

though extensively altered, were typically reactive to descending supergene solutions and,

consequently, not greatly susceptible to secondary enrichment. Oxidation of chalcocite has

commonly resulted in the formation of native copper, cuprite, and chrysocolla and more rarely

azurite, malachite, turquoise, and libethenite (copper phosphate).

Post-mineralization (mid-Tertiary) volcanic rocks overlie the southern and southeastern portions of

the deposit and probably initially overlaid the entire deposit. These rocks include the Sugarlump and

Kneeling Nun Tuffs. The tuffs are overlain, in places, by basaltic andesite lava flows. These

volcanic rocks crop out over a large portion of the area south and east of the Santa Rita Open Pit. The

Sugarlump Tuff is 50 to 100 feet thick and in the mine area is a poorly consolidated, non-welded tuff

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that typically forms slopes. The 400- to 600-foot-thick Kneeling Nun Tuff is a very strong, massive,

welded tuff, easily identified because it is a cliff former in the area south of the mine. Basaltic

andesite flows overlying the tuffs reach a thickness of up to 500 feet, but are typically 200 to 400 feet

in the mine area. These mid-Tertiary units are not mineralized and are only removed during mining

to facilitate access to mineralized material at depth to the north and northwest.

A number of primary fault systems underlie the NMA:

• Hanover Creek Fault, trending north-northeast along Hanover Creek;

• Copper Glance Fault, a series of north-northeast-trending faults crossing upper Whitewater Creek;

• Bayard Fault, trending north-northeast along upper Whitewater Creek north of Bayard; and

• Groundhog Fault, trending northeast from the south end of Bayard along Bayard Canyon.

Pipeline Corridor Area

The Pipeline Corridor Area geology is comprised of a thin veneer alluvium overlying bedrock of

various lithologies (Golder, 2006a). From Bayard south to Lake One, the alluvium is confined to the

immediate Whitewater Creek channel and tributary canyons and is generally between 5 and 20 feet

thick and 500 feet to nearly 3,000 feet wide. Although there are occasional bedrock outcrops along

the sides of the channel, there is generally no seasonal baseflow between Bayard and Lake One. The

rock outcrops in this area consist primarily of the Sugarlump and Kneeling Nun rhyolite tuffs and

other igneous units farther to the north.

South Mine Area

Only Tertiary and Quaternary strata are exposed at the surface of the SMA, although a small outcrop

of limestone, possibly belonging to the Paleozoic Oswaldo Limestone, occurs outside the area, west

of Tailing Pond B (DBS&A, 1995).

Borehole data indicate that Precambrian granite, gneiss, and schist exist in the subsurface at depths

usually greater than 2,500 feet below ground surface (ft bgs). Paleozoic formations also are present

in the subsurface and consist mainly of limestone, dolomite, and subordinate shale and sandstone.

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The Pennsylvanian Oswaldo Limestone is the youngest Paleozoic rock unit in this area. No Mesozoic

sedimentary rocks have been reported in or below the SMA, although a 265-foot thickness of the

Cretaceous Tertiary Hurley Sill (hornblende latite) was penetrated in a borehole located just east of

Whitewater Creek at the latitude of the Hurley Operation Area.

The Hurley Sill and Oswaldo Limestone are unconformably overlain by the mid-Tertiary Rubio Peak

Formation, which in the SMA subsurface typically comprises 200 to 300 feet of conglomerate and

rhyolitic tuff and ash-flow tuff. The Sugarlump Tuff rests on the Rubio Peak Formation and is made

up of approximately 600 feet of rhyolitic to andesitic tuff, mostly occurring as, ash-flows, and

tuffaceous sedimentary rocks. Overlying the Sugarlump Tuff is the Kneeling Nun Tuff, a welded

pink to grayish-pink ash-flow tuff exposed in the hills east of the SMA, where it forms cliffs with a

maximum thickness exceeding 400 feet. Stratigraphically above the Kneeling Nun Tuff and exposed

outside of the SMA are four other mid-Tertiary volcanic or volcaniclastic units.

In the vicinity of the SMA, the Miocene to Pleistocene Gila Conglomerate is inferred to overlie the

Kneeling Nun Tuff and older Tertiary and Paleozoic stratigraphic units. The Gila Conglomerate

thickens to the south where it appears to be over 600 feet thick. It consists mostly of poorly sorted

conglomerate, with local beds of sandstone and mudstone. The unit is usually poorly to moderately

consolidated and poorly cemented in outcrop, becoming increasingly lithified and cemented with

depth.

In the Interceptor Well System immediately south of Tailing Pond 7, the Gila Conglomerate can be

subdivided into upper and lower units, with thicknesses exceeding 300 and 140 feet, respectively.

The lower unit is finer-grained; more consolidated, and contains more volcanic rock clasts than the

upper unit. Between the upper and lower units near the southwest of Tailing Pond 7, there is a basalt

layer up to 75 feet thick and 3,000 feet wide. At the base of the basalt layer is a thin rubble zone of

boulders and gravel. The Gila Conglomerate is overlain by the compositionally similar Quaternary

sediments that are as much as 50 feet thick and consist predominantly of alluvial sand and gravel.

The Quaternary sediments are typically distinguished from the older Gila Conglomerate only by a

lower degree of consolidation and cementation.

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2.5.3 Climate

The climate at Chino is warm and dry, with mean annual precipitation of about 400 mm (16 inches)

and a mean annual temperature near 10oC (50oF). Precipitation falls mainly as rain, but snow may

occur from November to March. Most of the precipitation in the area falls during July through

October in the form of rain during short, intense, thunderstorms. Monthly precipitation is generally

less than an inch each month from March through June, peaks in July and August at between 2 and

3 inches each month, and generally falls to less than 2 inches each month from September through

February. Evaporative demand in this region is high and annual evaporation far exceeds annual

precipitation.

2.5.4 Hydrology

A brief summary of surface water and groundwater hydrology at the mine is provided in the

following paragraphs.

Surface Water

The surface water hydrology of Chino is characterized by ephemeral and intermittent streams that

have peak discharges associated with summer convective storms. This fluvial system drains to the

south and is included in the Mimbres River watershed. The major drainages at Chino include

Whitewater and Hanover creeks and Lampbright Draw (Tributaries 1 and 2) (Figure 2-6).

Whitewater Creek is an intermittent stream and represents the primary trunk stream draining the

NMA and SMA. Hanover Creek is a major tributary to Whitewater Creek, which eventually joins

San Vicente Arroyo south of the mine. The headwaters of Whitewater Creek have been altered by

mining activities, and runoff from the upper part of the watershed is intercepted by Reservoir 3A.

Consequently, Whitewater Creek now originates immediately west of Reservoir 17 and flows

southwest to the SMA.

The lower reaches of Whitewater Creek have been modified in association with the development of

the tailing impoundments. The historical channel of Whitewater Creek flowed in the area now

occupied by portions of Lake One and Tailing Ponds 1, 2, 4, 6, and 7.

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In 1910 Whitewater Creek was dammed to form Lake One and in 1911 diverted to flow east of

Pond 1. Additional changes in channel location were made in 1984, when the creek bed was moved

to the east around Lake One, and in 1988, when the channel was diverted to the east of the planned

site for Pond 7. In 2003 a project was completed to divert Whitewater Creek out of the Lake One

drainage by the construction of an engineered channel cut into the bedrock from Whitewater Creek

north of Razorback Ridge, through James Canyon, and through a bedrock ridge east to Bolton Draw.

The headwaters of the Santa Rita Creek drainage are located northeast of the Santa Rita Open Pit.

Santa Rita Creek historically drained to the southwest, merging with Whitewater Creek and Hanover

Creek. The Santa Rita Open Pit and associated mine facilities now occupy much of the former

drainage. Most of the drainage upstream of Santa Rita Open Pit is collected in Reservoir 5.

Presently, all surface water flow southwest of the Santa Rita Open Pit in the Santa Rita drainage is

contained by reservoirs in the former Precipitation Plant Area. Flows in this drainage are ephemeral,

occurring only in response to storm runoff.

Hanover Creek is an intermittent stream that originates in the Pinos Altos Range north of Chino. In

the vicinity of the NMA, it flows on the west side of the mine in a south-southwesterly direction

between Highway 356 and the West Stockpile, joining Whitewater Creek near the area south of the

Ivanhoe Concentrator.

Lampbright Draw is an intermittent stream draining the eastern portions of the NMA that has also

been altered in its upper reaches by mining activities. Lampbright Draw commences approximately

6 miles east of Santa Rita Open Pit and east of the present Lampbright Stockpiles. Drainages referred

to as Tributaries 1 and 2 occur in the immediate area of the Lampbright Stockpiles. The Main and

South Lampbright Stockpiles occupy the headwaters for the Tributary 1 drainage. The Tributary 2

drainage occurs east of the stockpiles and joins Tributary 1 approximately 1 mile to the south. The

drainage continues to the southeast approximately 2 miles where it joins the main fork of Lampbright

Draw. From this point, Lampbright Draw continues south and southwestward joining Whitewater

Creek near Faywood Station.

Groundwater

Site geologic conditions of the mine site comprise three distinct environments in the NMA, PCA

(MWWCA), and SMA. The PCA is a transitional zone, with physical features distinct from the other

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two areas. These differing physiographic and geologic settings lead to hydrogeologic conditions

within these sub-regions that are also distinct. The following sections present a brief overview of the

overall hydrogeologic conditions at the site. The geology in the mine site area has been divided into

five hydrostratigraphic units based on the rock types and their hydraulic properties (Golder 2007a).

These units are: Alluvium, Gila Conglomerate, Intrusive Plutonic Bedrock, Volcanic Bedrock, and

Sedimentary Bedrock.

North Mine Area

The NMA is dominated by igneous and sedimentary bedrock, with thin unconsolidated deposits

limited to the bottoms of major drainages. The matrix porosity of the bedrock near the mine pit is

typically very low. The overall porosity of the bedrock is low and occurs primarily in the form of

fractures, joints and faults (Golder 2007a). Fractures are the primary conduits for groundwater flow

in the immediate area of the pit. Farther away from the pit, the original matrix porosity of

sedimentary units remains intact, allowing groundwater to flow through sedimentary pore spaces in

addition to fractures and faults and along bedding plans.

As is typical in mountainous terrain of low rock hydraulic conductivity, groundwater levels within

bedrock generally reflect ground surface elevations: groundwater levels are generally higher in the

elevated terrain and generally lower in the drainages and lower elevations. The current configuration

of the water table (uppermost water) within the NMA is shown in Figure 2-7 (Golder 2006b).

Overall, the depths to groundwater range from over 500 ft bgs below the ridges and elevated terrain to

ground surface or near ground surface in the drainage bottoms. Groundwater flows from the ridges

down gradient to discharge areas in the valley bottoms. The presence of the Santa Rita Open Pit in

the NMA has greatly affected the groundwater flow regime. Groundwater elevations near the bottom

of the Santa Rita Open Pit are approximately 1,000 feet lower than the surrounding groundwater

levels. Consequently, the pit acts as a large regional hydraulic sink, drawing groundwater into the pit

from around the circumference of the pit.

Pipeline Corridor Area

The PCA (MWWCA) hydrogeology is comprised of a thin veneer of variably saturated alluvium

confined to the immediate Whitewater Creek channel and tributary canyons. The alluvium has been

deposited on bedrock of various origins. In contrast to the bedrock in the NMA and the bedrock at

depth, the Whitewater Creek alluvium is more permeable by several orders of magnitude, and as

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such, groundwater preferentially flows within the alluvium. Depths to groundwater within the

alluvium in the lower portion of the PCA average about 10 feet (Dames & Moore, 1983). The

hydraulic gradient in the alluvium closely coincides with the gentler gradient of the creek grade and

the groundwater flows along the course of Whitewater Creek toward the SMA. Groundwater

elevations along Whitewater Creek are shown on Figure 2-8.

South Mine Area

The SMA hydrogeologic system is located within a deep channel of semi-consolidated alluvium that

is over 500 feet thick at its southern end (Golder, 2007a). The primary hydrostratigraphic unit of the

SMA is the Gila Conglomerate, which consists of variably cemented clay, silt, sand and gravel.

Quaternary alluvial sediments, which are as much as 50 feet thick, overlie the Gila Conglomerate

along the axis of Whitewater Creek. Stratigraphically beneath the Gila Conglomerate is a series of

east-dipping volcanic bedrock units including the Kneeling Nun Tuff, Sugarlump Tuff and Rubio

Peak Formation and Paleozoic sedimentary formations.

The hydraulic conductivity of the Gila Conglomerate in the SMA ranges from 0.1 to 98 feet per day

(ft/d), with a geometric mean of 8 ft/d (Golder, 2007a). In general, the hydraulic conductivity has

been noted to decrease with depth due to compaction and lithification. The hydraulic conductivities

measured for the other units are discussed in detail in Golder (2007a). The direction of groundwater

flow in the SMA is to the south towards the Pond 7 interceptor well system (Figure 2-9). South of the

Pond 7 interceptor system, groundwater flow is also in a southerly direction.

2.5.5 Soils and Vegetation

The soils in the Chino area were mapped by the U.S. Soil Conservation Service (SCS) (Parnham et al.

1983). The SCS map units were composed primarily of complexes of soil series and miscellaneous

land areas. The dominant soils in the northern portion of the survey area (Luzena and Muzzler series)

are shallow (<50 cm) and fine-textured with moderate to high rock fragment contents. The soils in

the uplands are mostly shallow, although moderately deep (50 to 100 cm) and deep (>100 cm) soils

occur to a minor extent. The soils in the valley bottoms are generally deep, vary considerably in

texture, but tend to be somewhat coarser textured than the upland soils. The soils in the South Mine

Area range from shallow to deep, are generally medium to coarse-textured, calcareous, and overlie

thick alluvial deposits (DBS&A, 1998).

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The distribution of native vegetation around Chino is locally complex and reflects the combined

influences of environmental gradients (soils and climate), disturbance histories (drought, floods, fire,

and predation) and management practices. The major structural characteristics of vegetation are

controlled primarily by the prevailing environment gradients. The vegetation at Chino was classified

using the nomenclature and hierarchical classification of the U. S. National Vegetation Classification

(USNVC) system (Grossman et al., 1998) and mapped at the Alliance level, which represents the

sixth tier in a seven-tiered hierarchy. The vegetation alliances in the area surrounding Chino

(DBS&A, 2000) are listed below. Figures 2.10 and 2.11 show the distribution of the vegetation in the

NMA and SMA, respectively.

Vegetation Map Units in the Chino Survey Area

Name Acreage Elevation Range

(ft amsl) Mixed-Grama Herbaceous Alliance 6,717 5,200-5,750 Mesquite/Mixed Grama Shrubland Alliance 8,858 5,200-5,800 Fluvial Forest and Shrubland Alliance 1,585 5,200-5,600 Alligator juniper-Oak/Grama Woodland Alliance 10,257 5,800-7,700 Alligator juniper-Oak Woodland Alliance 4,456 5,800-7,400 Mountain mahogany Shrubland Alliance 10,038 5,600-7,600 Ponderosa pine-Oak Forest Alliance 1,552 6,000-7,600 Mine Facilities/Urban 10,122 NA

Notes: ft msl = Feet above mean sea level NA = Not applicable

2.5.6 Wildlife

The undisturbed lands that encompass and surround Chino harbor diverse vegetation and wildlife

communities. General habitat types include riparian corridors, rock outcrops and cliffs, foothills,

canyons, mixed woodlands, and grasslands.

Previous studies at Chino have recorded at least 18 mammal, 71 bird, and 5 reptile species. Surveys

to identify federal and state threatened, endangered, and special status wildlife species were

conducted at Chino (Golder, 1998b). The peregrine falcon was the only federally listed endangered

species to be recorded during the 1996 field investigations. Subsequently, this species has been

removed from the federal endangered species list, but is still listed as threatened by the State of New

Mexico. Two other state-listed species, the common ground dove (endangered) and the gray vireo

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(threatened), were also observed. In addition, two species of bats (western small-footed myotis and

fringed myotis) were observed that were listed by the BLM as species of concern and as sensitive

species by the State of New Mexico. The Chihuhuan leopard frog, a federally listed endangered

species, occurs south and east of the NMA in association with Lampbright Draw and its tributaries.

2.5.7 Material Characteristics

The physical and chemical characteristics of the stockpiles, tailing, and borrow materials have been

characterized and described in detail previously (M3, 2001).

Stockpile Materials

Compositional models have been developed for the waste rock and leach stockpiles at Chino (Golder,

1998a and 1999b). This work is based in part on the Chino Resource Model that is used as a

long-term mine planning tool for predicting ore, leach, and waste rock distribution within the pit prior

to mining. This model is based on a large amount of drill hole assay, mineralogical, and geologic

data. The model assigns codes for a number of categories for evaluating environmental impacts, the

most important of which are general geology, mineral population, and alteration. The pertinent codes

for each of these categories are presented in Table 2-1. These codes are used to select samples for the

waste rock characterization program.

A large number of rock samples were collected for baseline studies in support of the mine expansion

environmental impact statement (EIS) and characterization of the Lampbright Stockpiles. The

samples were selected to represent the compositional range of rock types anticipated to be disposed in

a manner that might result in poor-quality seepage. Sample characterization has included whole rock

chemistry, mineralogy (visual description and x-ray diffraction), static acid-base accounting, and a

limited number of kinetic tests.

The results of the geochemical characterization are combined with compositional models for each

stockpile. The composition and spatial distribution of specific rock types is based on mine records.

Tailing Materials

The older tailing impoundments were constructed by the upstream method from perimeter starter

dikes. The tailing impoundments show an internal stratigraphy that grows progressively finer from

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embankment dikes to the decant pond. The impoundment sediments are layered, and there is a

general coarsening-upward stratigraphy near the impoundment embankments.

The major minerals recognized in the tailing by x-ray diffraction analysis were chlorite, quartz,

sericite, magnetite, pyrite, and potassium feldspar. Laboratory analyses of tailing samples indicate

that acid generating potential (AGP) exceeds acid neutralizing potential (ANP). The pore waters in

the older tailing impoundments generally exceed WQCC criteria for boron, manganese, sulfate, and

total dissolved solids (TDS).

Borrow Materials

Based on MMD criteria, soils and soil substitutes have been evaluated to determine their suitability

for supporting native and adapted vegetation (Golder, 2006; DBS&A, 1998; DBS&A, 1999a). The

intent of soil evaluations has been to establish the general character and extent of soils and geologic

materials that could be used to support CCP activities discussed in Sections 6.0 and 7.0. Four classes

of material have been tested: 1) soils and unconsolidated geologic materials, 2) geologic materials

from stockpiles, 3) tailing from the surfaces of the tailing impoundments, and 4) rock from potential

quarry locations. Thus, native surface soils, semi-consolidated geologic materials, and mining

by-products (leached and unleached geologic materials and tailing) were all considered if no inherent

or insurmountable limitations to plant growth were identified.

2.6 Permits and Discharge Plans

Chino currently conducts its mining operations pursuant to numerous state and federal regulations

covering groundwater, surface water, air, solid, and hazardous wastes. Table 2-3 lists major

environmental permits held by Chino for current mining activities. Information regarding those

permits is summarized in the following sections.

2.6.1 Mine Operation Permit

To meet requirements of the NMMA, Chino obtained approval of its existing mining operation permit

from the MMD in December 1997.

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2.6.2 National Pollutant Discharge Elimination System Permit

Chino received a National Pollutant Discharge Elimination System (NPDES) permit from the U.S.

Environmental Protection Agency (EPA) on August 6, 1985, which is renewed every 5 years. The

permit provides for two outfalls: Outfall 001, immediately west of the former Precipitation Plant on

Whitewater Creek, and Outfall 002 at the spillway of Reservoir 8 on Lampbright Draw. These sites

are permitted as zero-discharge outfalls, except in cases of extreme precipitation events, when excess

stormwater may be discharged if it satisfies certain water quality criteria. The most recent permit was

renewed on December 14, 2006.

2.6.3 NPDES Multi-sector Stormwater General Permit

NPDES stormwater general permits cover the mine area, Hurley Operation Area, and associated

facilities. To meet additional requirements, Chino has prepared a Stormwater Pollution Prevention

Plan and an Emergency Response Plan. Chino’s application for coverage is for a multi-sector general

stormwater permit.

2.6.4 Water Rights

Water-right permits for Chino and Cobre Mine are recorded at the New Mexico Office of the State

Engineer (NMOSE) and are administratively associated with the Mimbres Underground Water

Basin. Chino holds both groundwater and surface water rights, whereas Cobre only has groundwater

rights. Water rights for these operations were adjudicated in 1974 according to a legal judgment

known as the Salopek Decree (JSAI, 2006). The adjudication decree establishes the points of

diversion and consumptive use of water from the Rio Mimbres Stream System and Mimbres

Underground Water Basin. The decree also establishes the priority date, place, and purpose of use of

each valid right based upon a hydrographic survey conducted in the early 1970s. Many of these water

rights have been modified by more recent NMOSE permits.

Chino’s current ground-water right totals approximately 25,000 acre-feet per year (ac-ft/yr), of which

6,705 ac-ft/yr were considered perfected (proven by application to a beneficial use) in the Salopek

Decree. Chino has maintained water right permits subject to Proof of Beneficial Use by submitting

requests for time extensions. Chino is close to perfecting most of its ground-water rights (JSAI,

2006). Water rights associated with the Cobre Mining operation permit an average diversion of

2,313 ac-ft/yr, although annual limits can be as high as 3,280 ac-ft/yr.

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Almost all of the water rights within Chino owned lands are designated for industrial, stock, domestic

and municipal use. Industrial use includes manufacturing processes and pollution control related to

mine operations. The NMOSE considers that all water Chino diverts for industrial, stock, domestic,

and municipal uses is completely consumed and accounts for no return-flow credit. The majority of

Cobre’s water rights are for mining, milling, and related mining uses with some designated for stock

and domestic use. Currently, the place and purpose of use for Cobre’s water rights also applies to

Chino operations and property.

The NMOSE requires that a new permit application be filed to change point of diversion for an

existing water right such as replacement of production and pollution control wells. An NMOSE

application to change the point of diversion is subject to public notice and comment.

2.6.5 Air Quality

The New Mexico Air Quality Control regulations and Clean Air Act Title V permit program apply to

the Hurley Operation Area. Air Quality Permit 298-M-3 from NMED regulates the Concentrator

circuit and was last modified on April 28, 1994 to allow an increase in the average amount of ore

processed from 50,000 to 60,000 tons per day. This permit covers particulate emissions and limits

and mandates emission control devices and records of daily and annual production. Air quality

permitting from NMED regulates the SX/EW Plant to allow emissions of volatile organic compounds

(VOCs). Permit renewal is not required unless changes are made in the systems that increase

emissions. The new Title V permit, issued May 23, 2007, covers the Hurley Operation Area and the

NMA.

2.6.6 Other Permits

Chino possesses a radioactive materials license from the NMED for storage and use of density gauges

and x-ray analyzers, and an explosives permit from the federal Bureau of Alcohol, Tobacco and

Firearms for blasting in the Santa Rita Open Pit.

2.6.7 Plans of Operation

Federal BLM Regulations in 43 CFR Subpart 3809 require an approved plan of operations for

activities conducted on public lands that disturb 5 or more acres. To comply with these regulations,

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Chino submitted plans of operations in 1981, 1995, and 1997 and an environmental assessment in

1996.

2.6.8 Administrative Order on Consent (AOC)

An AOC between the NMED and Chino became effective December 23, 1994. The AOC is a

voluntary, yet binding, agreement between Chino and the NMED designed to identify and remediate

effects to the environment that are not addressed under other regulatory frameworks. The AOC is

aimed at evaluating potential risk to human health and the environment from Chino’s historical

mining operations and is designed to be generally consistent with the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA).

The AOC originally identified six investigation units (IUs) within the investigation area: Hanover

Creek, Hurley Soils, Lampbright, Hurley Smelter (now the Hurley Operation Area), Tailing Area

Soils, and Whitewater Creek. After the AOC was finalized, an ecological investigation unit (IU) was

added to address and characterize ecological issues media on a site-wide rather than an individual

geographical unit basis. Investigations began in 1995 and are ongoing.

2.6.9 Operational Discharge Plans

WQCC regulations require a discharge plan (DP) for any discharge of effluent or leachate that has the

potential to impact groundwater quality above regulatory criteria. Chino operates pursuant to eight

operational DPs, which are listed in Table 2-4. The operational DPs are identified in Figure 2-12.

The DPs in the NMA and the primary facilities they govern include:

• DP-213: Ivanhoe Concentrator and Associated Pipelines (these extend to SMA);

• DP-376: Lampbright Leach System;

• DP-459: North In-Pit Leach and North, Northwest and Northeast Waste Rock Stockpiles, Reservoir 5, and the Santa Rita Open Pit;

• DP-493: Reservoir 3A;

• DP-526: Whitewater Leach System;

• DP-591: SX/EW Plant and Reservoirs 6 and 7; and

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• DP-1568 (pending): Lee Hill Leach Stockpile.

The DPs in the SMA and the primary facilities they govern include:

• DP-214: Hurley Operation Area, Lake One, Older Tailing Impoundments, Axiflo Lake, Lower Whitewater Creek; and

• DP-484: Tailing Pond 7.

On March 25, 1998 all Chino DPs were amended by the NMED to incorporate the Comprehensive

Groundwater Characterization Study (CGCS) (Golder, 1999a). The CGCS is a site-wide

investigation designed to provide a comprehensive evaluation of existing groundwater data and to

identify and fill any data gaps. The CGCS has been used to determine the appropriate regulatory

program (DP, AOC, or NMMA) to address further investigation of groundwater contamination and

remediation for both historical and operational sources. More recently, a Stage 1 Site-Wide

Abatement investigation was initiated (Golder, 2006a). The Site-wide Stage 1 Abatement

Investigation entails investigating and delineating the nature and extent of impacted groundwater and

collecting sufficient data to select and design abatement options. This investigation uses results from

other conditional studies being completed under DP-1340.

DP-376 Lampbright Leach System

DP-376 was renewed and modified May 14, 2005 and expires May 14, 2009. DP-376 covers the

Main, South, and Southwest Lampbright Stockpiles, Reservoir 8, and four sumps (Lampbright Sumps

1, 2 and 3, and the East Lampbright Sump), which are along the north side of the Main Lampbright

Stockpile.

DP-591 SX-EW Plant and Reservoirs 6 and 7

DP-591 was renewed and modified on September 1, 2006 and expires September 1, 2011. DP-591 is

in the NMA and includes Reservoirs 6 and 7, which are used to manage process waters at the mine

site. Both reservoirs are used for storage of stormwater and process water overflow during storm

events and receive overflow from Reservoirs 4A and 2. Reservoir 7 receives excess stormwater and

PLS from Reservoir 8.

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DP-459 North In- Pit Leach System and North Pit Area Stockpiles and Reservoir 5

DP-459 was renewed and modified June 15, 2005 and expires June 15, 2010. DP-459 is in the NMA

and includes the Main Pit (Santa Rita Open Pit), North Pit Leach Stockpile; the Northwest, the

Northeast, and the North Waste Rock Stockpiles, and Reservoir 5. Reservoir 5 is north of the North

Stockpile and collects runoff from Santa Rita Creek, north of the mine area.

DP-493 Reservoir 3A

DP-493 was renewed June 28, 2006 and expires June 28, 2011. DP-493 is adjacent to the Santa Rita

Open Pit, and includes Reservoir 3A, which is an integral part of the water supply and management

system for operations at the mine.

DP-526 Whitewater Leach System

DP-526 was renewed and modified October 3, 2006 and expires October 3, 2011. DP-526 includes a

large part of Chino that lies west and southwest of the Santa Rita Open Pit, as well as the West and

South Stockpiles, used for stockpiling both waste and leach-grade ore, and the Upper South Stockpile

dedicated for overburden and cover materials. A number of stormwater and process water collection

systems are associated with the West and South Stockpiles. DP-526 includes a segment of

Whitewater Creek that extends from the former Precipitation Plant to the north end of Lake One by

the Hurley Operation Area. Dams 16 (and associated pump back system) and 17 are in northern

portion of this reach, which includes the active channel of the creek for the purposes of evaluating

groundwater conditions.

DP-213 Ivanhoe Concentrator and Associated Pipelines

DP-213 was renewed and modified June 16, 2005 and expires June 16, 2010. It includes the Ivanhoe

Concentrator and associated pipelines. The DP-213 area is in the NMA but the related pipelines

extend into the SMA.

DP-214 Hurley Operation Area, Lake One Older Tailing, Axiflo Lake, Lower Whitewater Creek

DP-214 was renewed and modified January 9, 2006 and expires January 9, 2011. It includes the

Hurley Operation Area, Older Tailing Impoundments (Tailing Ponds 1, 2, 4, B, C, 6E, and 6W), Lake

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One, Axiflo Lake, and a segment of Whitewater Creek extending from the north end of Lake One to

its confluence with San Vicente Arroyo approximately 12 miles south of Hurley.

DP-484 Tailing Pond 7

DP-484 was renewed and modified January 14, 2005 and expires January 14, 2010. DP-484 includes

Tailing Pond 7, an interceptor well system south of Tailing Pond 7, a segment of the 1988 Whitewater

Creek diversion channel, the tailing termination tank pipeline system. In 1988, under the authority of

DP-214, Whitewater Creek was diverted from its original channel to allow for the construction of

Tailing Pond 7. This diversion channel is along the eastern perimeter of Tailing Pond 7.

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3.0 TECHNICAL CONSIDERATIONS FOR RECLAMATION

The following paragraphs describe the technical considerations for closing mine-related facilities.

These considerations include materials characteristics, site-specific hydrologic conditions and the

known and potential impacts to the environment associated with each of the operational discharge

permits for Chino.

3.1 Reclamation Plan

All Chino facilities are within operational DPs regulated by the NMED Ground Water Quality Bureau

and can be discussed in terms of “units of reclamation.”

3.2 Units of Reclamation

The units of reclamation refer to the individual DPs. The facilities, within these DPs to be closed are

stipulated in each respective operational DP as well the provisions of DP-1340. The potential impacts

are assessed in relationship to applicable regulatory criteria, such as the WQCC standards.

3.2.1 DP-376: Lampbright Leach System

The primary facilities to be closed in DP-376 are the Lampbright Stockpiles, which are east of the

Santa Rita Open Pit and southeast of the SX/EW Plant, and Reservoir 8, which is at the southern foot

of the South Lampbright Stockpile in Tributary 1. The DP-376 is shown on Figure 3-1.

Material Characteristics

DP-376 contains two primary materials, leach-grade ore and waste rock. Both the leach-grade ore

and waste rock range in size from very fine (clay and silt) to large boulders. As the materials are end

dumped and settle at an angle of repose, they form a heterogeneous mass. The tops of the leach

stockpiles are nearly level. Most of these materials are interpreted as having the potential to generate

acid (M3, 2001).

Site-specific Hydrologic Conditions

Lampbright Draw drains the eastern portion of the NMA (Golder, 2007a). Lampbright Draw is dry

throughout most of the year, and flows only during storm events (DBS&A, 1995). Lampbright Draw

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commences approximately 6 miles northeast of Santa Rita Pit, and northeast of the present

Lampbright Stockpiles. The drainage continues to the southeast approximately 2 miles where it joins

the main fork of Lampbright Draw. From this point, Lampbright Draw continues south and

southwestward joining Whitewater Creek near Faywood Station. The Lampbright Stockpiles are

within the Tributary 1 drainage upstream of Reservoir 8, which is used to collect pregnant leach

solution (PLS). The Tributary 2 drainage occurs east of the stockpiles, and joins Tributary 1 about

1 mile to the south.

Figure 2-7 shows the groundwater elevations and interpreted groundwater contours and directions of

groundwater flow in the NMA based on Golder (2007a). Groundwater elevations are highest in the

elevated terrain to the north and south of the pit, and lowest within the pit. Groundwater flow

converges towards the pit from around its perimeter. Vertically, groundwater flow is directed

downward beneath the elevated terrain where it is recharged, and directed upward beneath the Santa

Rita Pit and drainages where it is discharged.

Known and Potential Impacts

In the Lampbright Area, the extent of impacted groundwater is localized (Golder, 2007a). This is

consistent with the groundwater elevation data that show groundwater converging from the east and

west towards Tributary 1. Groundwater also flows vertically upward from below to Tributary 1.

Downstream of Reservoir 8, which is the primary Lampbright PLS containment facility, the

groundwater that reports to Tributary 1 is largely removed via evapotranspiration. Upstream of

Reservoir 8, most of the potentially-impacted groundwater beneath the stockpiles discharges to the

reach of Tributary 1 buried within the footprint (horizontal projection) area of the stockpile. This

water then reports to the downstream toe of the stockpile as surface water, where it is collected and

contained along with PLS.

Groundwater quality has been impacted from south of the South Lampbright Stockpile to Reservoir 8,

the main PLS collection sump (an excavated bedrock sump). The groundwater in this area exceeds

WQCC criteria, primarily for TDS and sulfate.

Groundwater quality approximately 200 feet south of Reservoir 8 is also locally impacted in the area

of the spring below Reservoir 8. Exceedances of WQCC criteria in this area most frequently include

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TDS, sulfate, and manganese. Investigations associated with the Lampbright Stage 1 Abatement

Investigation are ongoing.

Farther to the south, fifteen wells have been installed. Water quality is within WQCC criteria at 13 of

these 15 wells. Additional drilling is scheduled to determine if impacted groundwater extends farther

down gradient from these two wells, and to better determine the groundwater quality conditions of the

area as part of the Site-wide Abatement Task 2 field investigation (in concert with the Lampbright

Abatement program that is also underway).

On the southeast side of the Southwest Lampbright Stockpile, only 1 of the 9 wells, an interceptor

well, currently exceeds WQCC criteria (TDS, sulfate and chloride) (Golder, 2007a). East of the Main

and South Lampbright Stockpiles groundwater quality criteria are met at 6 of the 9 monitoring wells.

There are two localized areas where WQCC criteria have been exceeded. The elevated TDS and

sulfate concentrations at these two areas may be attributed to local conditions, or possibly to local

structures that might convey impacted groundwater to the east from beneath the stockpile. Ongoing

field investigations are evaluating the feasibility of converting some of the impacted wells into

interceptor wells as an accelerated interim abatement action, similar to that successfully undertaken at

the Southwest Lampbright Stockpile.

The relatively poor quality groundwater along the northern flank of the Main Lampbright Stockpile is

largely contained within the Lampbright PLS collection system. The northeast Lampbright Area

requires additional containment where a cluster of wells exceed TDS criterion. A large french drain

and sump (Sump 3) has been installed in this area to collect and contain impacted groundwater. In

addition, as a part of the Lampbright Abatement Program, another sump (Sump 5) is scheduled to be

installed as an expedited interim measure farther to the east.

3.2.2 DP-591: Area, SX/EW Plant and Reservoirs 6 and 7

The primary facilities to be closed in DP-591 are the SX/EW Plant, the PLS feed pond, the raffinate

storage tank and overflow pond, Reservoirs 6 and 7 and associated conveyance systems, and an

interceptor well. The facilities in DP-591 are shown on Figure 3-2.

PLS resulting from the stockpile leaching operations is routed from the stockpiles through pipelines

for storage in the feed pond. Raffinate from the SX/EW Plant is returned to the stockpiles from the

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raffinate tank. Both reservoirs are used for storage of stormwater and excess process water during

storm events.

Material Characteristics

DP-591 contains two primary materials to be characterized, PLS and raffinate. PLS and raffinate are

characterized as a low-pH solution containing elevated levels of metals, TDS, and sulfate. Other

materials used in the PLS processing operation at the SX/EW Plant include kerosene-like organic

reagents, electrolyte solutions, and sulfuric acid.

Site-specific Hydrologic Conditions

The facilities in DP-591 are located within the upper reaches of the Whitewater Creek drainage basin.

Stormwater runoff from most of the undisturbed portions of DP-591 is routed to the North Diversion

Channel, which conveys stormwater to Tributary 2 of Lampbright Draw. A drainage channel south of

the SX/EW Plant Area diverts surface water to the southwest into Reservoir 7. Reservoirs 6 and 7 lie

in the drainages that flank the ridge and plant facilities to the northwest and southwest. Reservoirs 6

and 7 were constructed for storage of storm and process water overflow, but also receive overflow

from Reservoirs 4A and 2, located southwest of the Santa Rita Open Pit. Reservoir 7 also receives

excess stormwater and PLS from Reservoir 8 and water from a production well that was installed to

recover affected groundwater. Other surface water features in the DP-591 area include the PLS feed

pond.

Groundwater in area of the DP-591 facilities occurs in the Colorado Formation (sandstone/shale), the

Beartooth Quartzite (sandstone), and the Syrena Limestone. Depths to groundwater range from just

below 42 feet to approximately 261 feet bgs. Groundwater elevations range from below 6,300 ft amsl

to above 6,600 ft amsl. The elevation of water stored in Reservoirs 6 and 7 is approximately 6,500 ft

amsl; however it appears that the reservoir water elevations are above nearby groundwater elevations.

Groundwater in the majority of the SX/EW Plant Area is within the OPCZ, flowing south and west

towards the pit (Figure 2-7). However, the groundwater in the eastern portion of the plant area may

flow to the south and east toward the Lampbright Leach Facility.

Groundwater encountered in monitoring wells and springs flowing near the SX/EW Plant indicate a

potentially perched groundwater system. This is most likely attributable to the highly stratified nature

of the sedimentary sequence present in this area. Geological review indicates that the sedimentary

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units in the immediate area of the plant dip primarily to the east (Golder, 2006b). A shale layer

within the easterly dipping Beartooth Quartzite may act as a confining layer that could result in

locally perched groundwater to flow perpendicular to the regional groundwater flow direction. Also,

abandoned underground mine workings (Tin Can Mine) appear to act as a horizontal drain for local

groundwater.

Known and Potential Impacts

The SX/EW Area lies within the OPCZ of Santa Rita Pit, and as such, the impacted groundwater in

this area flows into the open-pit sumps where it is available for operational use (Golder, 2007a). The

water quality in the SX/EW Plant Area is generally poor, except to the north where the groundwater

generally meets WQCC criteria. The WQCC criteria are exceeded for several constituents in the

SX/EW Plant Area, including pH, TDS, sulfate, and some metals. Highest concentrations of TDS,

sulfate, and metals and the lowest pH in groundwater occur in the immediate SX/EW Plant Area near

the southern portion of the SX/EW Plant and immediately northeast of Reservoir 7.

The SX/EW Area is the subject of additional investigations as part of ongoing Site-wide Abatement

Task 2 field investigations. This work includes geologic and hydrogeologic mapping, pumping tests,

borehole geophysics, and installation of four additional monitoring wells.

No known impacts to air quality from DP-591 facilities have occurred.

3.2.3 DP-459: North Pit Stockpiles, Reservoir 5, and Santa Rita Open Pit

The primary facilities to be closed in DP-459 are the North In-Pit Leach System, and the North In-Pit

leach and Lee Hill, Northeast, Northwest, and North Stockpiles, and Reservoir 5. The North Pit

Stockpiles include low-grade ore, leach, and waste rock stockpiles. Reservoir 5 collects stormwater

runoff. The Santa Rita Open Pit includes three discrete pit bottom areas (Lee Hill, Estrella, and East

Pit). The facilities in DP-459 are shown on Figure 3-3.

Material Characteristics

The DP-459 area contains two primary materials to be characterized: leach-grade ore and waste rock.

The results of the stockpile characterization studies conducted at Chino indicate that the stockpiles are

primarily composed of granodiorite, skarn, and Cretaceous sediments, which are the predominant

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material types at Chino (M3, 2001). Both the leach-grade ore and waste rock range in particle size

from very fine (clay and silt) to large boulders. When dumped in stockpiles, these materials form a

heterogeneous mass of materials that settle at the approximate angle of repose. The tops of the leach

stockpiles are relatively level and the top perimeters are bermed for safety.

Site-specific Hydrologic Conditions

DP-459 is within an area that was originally part of the Santa Rita Creek drainage system. Most of

the original Santa Rita Creek drainage area has been modified by mining operations. All runoff,

except for that directed to Reservoir 5, flows directly or indirectly into the Santa Rita Open Pit, from

which it is pumped into the Whitewater Leach System (DP-526). Current surface water features

include the North Pit PLS sedimentation basin, the three pit bottoms/sumps, a number of booster

sumps, and Reservoir 5. Reservoir 5 is north of the leach stockpile and collects stormwater runoff

that can be used for mine operations.

Groundwater occurs in both the intrusive formations in the North Pit Stockpile Area and in limestone

to the north and east. Depths to groundwater range from less than 15 ft bgs to greater than 200 ft bgs.

Hydraulic gradients indicate that groundwater flow is toward the Santa Rita Open Pit (Figure 2-7).

Groundwater seeps, downgradient of the leaching operations, also flow toward the pit bottoms.

Groundwater in the Reservoir 5 Area is regionally upgradient of the Santa Rita Open Pit, and as such

all groundwater in this area eventually flows to the pit (Golder, 2007a).

Known and Potential Impacts

The North Pit Leach Facility permitted under DP-459 includes a number of areas or operations with

the potential to affect water, air, or soil and sediment. These include the leach and waste stockpiles,

the various impoundments and sumps, old sediments in the southern portion of Reservoir 5, PLS and

raffinate pipelines, and haul and access roads. Potential constituents of concern (COCs) that may be

released to the environment by DP-459 facilities include metals, sulfate, TDS, low-pH solutions, and

hydrocarbon compounds. No off-site impacts to surface water quality from the North Pit Leach

Stockpile have occurred. Seepage and runoff into the pit have low pHs and may contain elevated

concentrations of metals, sulfate, and TDS.

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Groundwater to the west of Reservoir 5 meets WQCC criteria, as well as the groundwater up-gradient

of Reservoir 6 and southeast of Reservoir 5, located in the tributary drainage to the east. The

Reservoir 5/North Pit Area lies within the OPCZ of Santa Rita Pit, and as such, any impacted

groundwater in this area flows toward and is captured by open-pit sumps where it available for

operational use.

The Reservoir 5 Area is subject to additional investigations as part of the Site-wide Abatement Task 2

field investigation. Work scheduled includes an investigation to determine the extent and thickness of

the stockpile fill (waste rock was placed at this location during the early mining history), surface

geophysics, monitoring well installation and pumping tests.

3.2.4 DP-493: Reservoir 3A

Pursuant to DP-493, the primary facility to be closed in the DP-493 area is Reservoir 3A, an unlined

reservoir with a capacity of 1.2 billion gallons in the former headwaters of Whitewater Creek, south

of the South Stockpile and the Santa Rita Open Pit. As part of the water management system at

Chino, Reservoir 3A is connected through pipelines to facilities covered under a number of other

DPs, including DP-526 and DP-591. The Estrella Pit dewatering project was recently approved by

NMED and water is being pumped to Reservoir 3A, which is shown on Figure 3-4.

Material Characteristics

DP-493 facilities contain no materials to be characterized.

Site-specific Hydrologic Conditions

Reservoir 3A is south of the Santa Rita Open Pit, in the former headwaters of Whitewater Creek,

where it rests upon the Kneeling Nun Tuff and in a portion of the natural drainage. It covers an area

of 50 acres. All surface drainage is toward the reservoir or, for the drainage basin below the dam,

toward the Whitewater Leach System.

Regional groundwater occurs at depths ranging from approximately 110 to 380 ft bgs. The regional

flow direction appears to be north toward the Santa Rita Open Pit along fractures, joints, and faults in

the Kneeling Nun Tuff (Figure 2-8). Recently installed wells south of the reservoir, however, have

added uncertainty to the direction of groundwater flow in the area south of the reservoir. Currently,

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three monitoring wells are installed in the regional groundwater aquifer along the northwest, north,

and northeast sides of the reservoir.

Known and Potential Impacts

The Reservoir 3A Area lies within the OPCZ of Santa Rita Pit, and as such, any impacted

groundwater in this area flows into the open-pit sumps where it is available for operational use

(Golder 2007a). Groundwater south of the pit is in general of good quality, with the exception of a

localized area northwest of Reservoir 3A. Groundwater in this area has historically exceeded WQCC

criteria for TDS, sulfate, and metals, and the pH is generally less than 5.5 (Golder, 2006a). However,

recent data indicate groundwater no longer exceeds the WQCC criterion for TDS, although the pH

remains below 6. Investigation of the potential source of this impacted groundwater was recently

undertaken for the process to renew DP-493. Results of the investigation indicate that the impacted

groundwater was likely associated with a spray evaporation system that was set up around Reservoir

3A. This system operated in the early 1990s following a number of years of above average

precipitation, which led to excess mine process water.

In addition to the area northwest of Reservoir 3A, the southernmost of two wells installed as part of

the DP-493 hydrogeologic investigation exceeds WQCC criteria for TDS and sulfate. This well is

located 1,700 feet south of Reservoir 3A. Additional investigation, however, is scheduled to confirm

this expectation as part of the Site-wide Abatement Task 2 field investigation. This investigation

includes installing an additional monitoring well south of Reservoir 3A and conducting additional

testing to further evaluate the groundwater flow and water quality conditions.

3.2.5 DP-526: Whitewater Leach System (Stockpiles and Facilities)

DP-526 facilities include the West Stockpile, South Stockpile, former Precipitation Plant,

Concentrator, and portions of the Middle White Water Creek Area. DP-526 is shown on Figure 3-4.

The primary facilities to be closed in the DP-526 include:

• the West, South, and Upper South Stockpiles;

• a PLS Pond and the Launder;

• Reservoirs 2 and 4A;

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• Reservoirs 9 and 17;

• other water catchments including Dams 10, 11, 12, 13, 14, 14-1, 14-2, 14-3, 15, 16, 18, 19, and 20;

• process and runoff water pipelines, tanks (PLS tank and 6525 tank), and pumping systems (Old High Head Pump House and South Side Booster);

• the Mine Maintenance and General Offices areas.

The Santa Rita Class D Landfill, which is on top of the West Stockpile, is not included with DP-526,

but will be closed according to NMED Solid Waste Regulations and the permit requirements.

Material Characteristics

In DP-526 there are two primary materials that have been characterized: leach-grade ore and waste

rock. The results of the stockpile characterization studies conducted at Chino indicate that the

stockpiles are primarily composed of granodiorite, skarn, and Cretaceous sediments, which are the

predominant material types at Chino. Detailed information on stockpile characterization is found in

M3 (2001). Both the leach-grade ore and waste rock range in particle size from very fine (clay and

silt) to large boulders. When dumped in stockpiles, these materials form a heterogeneous mass of

materials that settle at the approximate angle of repose. The tops of the leach stockpiles are relatively

level and the top perimeter is bermed for safety.

Site-specific Hydrologic Conditions

The surface water hydrology of DP-526 is dominated by ephemeral stream channels cut into a

relatively high-relief terrain. Open-pit mining and the construction of leach and waste/overburden

stockpiles and water management facilities have had a marked effect on the surface drainage network.

Portions of the headwaters of both Santa Rita and Whitewater Creeks have been cut off, and

additional areas of these former drainages are now buried by stockpiles.

Current heads of Santa Rita and upper Whitewater creeks originate in the mine maintenance facilities

area. These creeks flow between the West and South Stockpiles into the PLS collection tank and

Reservoir 4A, Reservoir 2 or, under extreme conditions, into the new reservoir behind Dam 17.

Stormwater in Hanover Creek flows in its channel on the west side of the West Stockpile and joins

Whitewater Creek just west of Dam 16. The reach of upper Whitewater Creek from the Precipitation

Plant to Lake One has recently been added to DP-526.

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Known and Potential Impacts

When water is present, the water in Hanover Creek has had variable pH and contained elevated

metals, TDS, and sulfate. The increased metals, TDS, and sulfate observed in the creek appear to

correspond to the higher flow regimes, suggesting that they are a result of storm event runoff from

other Chino and other mining properties in the Hanover Creek drainage.

Stormwater runoff and seepage from the West Stockpile are collected by 11 stormwater containment

structures constructed between 1991 and 1996 to prevent runoff from entering Hanover Creek.

Surface water runoff collected behind the structures is pumped back to Reservoirs 4A, 6, and 7. This

containment system also includes some shallow groundwater pump-back systems.

The West Pit Area includes the West Stockpile, the South Stockpile and the corridors along Hanover

and Whitewater Creeks that extend southwest towards Bayard. The extent of impacted groundwater

is generally confined to the following areas:

• Between the stockpiles and the pit on the east side;

• The corridor area between the two stockpiles in the center where PLS and stormwater is collected from both the West and South Stockpiles;

• The Hanover and Whitewater Creek drainages extending some distance down the Whitewater Creek drainage.

The extent of impacted groundwater here is consistent with the groundwater elevation data, indicating

groundwater converges towards:

• The pit from the eastern portions of the stockpiles;

• The corridor between the two stockpiles, and

• The interceptor wells located along the western flank of the West Stockpile and the Hanover and Whitewater Creek drainages.

Impacted groundwater extends south between the Hanover Creek drainage and the West Stockpile,

where a series of monitoring wells and interceptor wells are present (Golder 2007a). WQCC criteria

for several constituents are presently exceeded in this area, including pH, manganese, TDS, sulfate,

and many of the regulated metals. Groundwater quality is also impacted in the corridor area between

the West and South Stockpiles, where stormwater and PLS are being conveyed and collected. The

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data were collected from the newly installed wells for DP-1340 Condition 83 (Golder 2007a).

Previous sampling of wells along the east side of the West Stockpile in a narrow area of disturbance

between the stockpile and the pit indicated that groundwater east of the stockpile is also impacted.

Water quality data from wells located south of the South Stockpile show that impacted groundwater is

not moving south from the stockpile area. However, some of the wells recently sampled for Task 1

Site-wide Abatement Investigation (Golder, 2006a) located along the immediate southern perimeter

of the South Stockpile have shown varied groundwater quality results. This indicates that some

impacted groundwater is locally present at the footprint (horizontal projection) of the stockpile. As a

result, this local area is the subject of additional investigation as part of the Site-wide Abatement Task

2 field investigation.

The extent of impacts to groundwater (both laterally and vertically) along the Hanover and

Whitewater Creek drainages, downstream of the interceptor wells and containment facilities, is

currently scheduled for additional investigation as part of the ongoing Site-wide Abatement Task 2

field investigation. This investigation entails installing approximately 12 monitoring wells along the

Hanover and Whitewater Creek drainages upstream and downstream of the confluence. In addition to

water quality data, groundwater elevation data collected from these wells will help to further

determine the direction of flow and the downstream extent of impacted groundwater.

Water quality data in the PCA, also know as the Middle White Water Creek Area (MWWCA),

includes continuous quarterly data collected since the early 1980s from wells located north of Lake

One, from other older wells of questionable construction, and from relatively new wells installed in

1998 and 2000 (Golder 2007a). The 526-2000-series wells were last sampled in 2001, prior to

reinitiating sampling as part of the Site-wide Abatement Task 1 data collection effort (Golder, 2006a).

These wells are now being sampled quarterly as required by the NMED. Recent data are not

available from a series of wells installed as part of the CGCS.

The shallow wells in the alluvium of Whitewater Creek are generally characterized as poor quality,

exceeding WQCC criteria for TDS and sulfate (Golder 2007a). Most of these shallow alluvial wells

have low pH. In addition, concentrations of the regulated metals exceed WQCC criteria in the low

pH wells. Along the creek channel from Bayard to Lake One, TDS and sulfate concentrations within

the alluvium remain fairly constant. Metals concentrations are more variable and appear directly

linked to pH. An analysis of data collected around the year 2000 suggested that metals concentrations

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in the alluvium decreased downstream along the Whitewater Creek channel (Golder, 2006a).

Additional data is scheduled to be collected as part of the Site-wide Abatement Task 2 field

investigation.

3.2.6 DP-213: Ivanhoe Concentrator and Associated Pipelines Areas

The facilities to be closed in DP-213 are the Ivanhoe Concentrator, the tailing pipelines, the process

water pipe line, the concentrate pipeline, and associated infrastructure. DP-213 is shown on

Figure 3-5.

Material Characteristics

DP-213 contains two primary materials that have been characterized: tailing slurry and clarified

tailing decant return water (TDRW). Tailing and TDRW chemistry have been characterized and

analytical results have been submitted to NMED pursuant to DP-213 requirements. Tailing is the

waste material produced during ore processing activities. In general, the acid-generating potential of

the tailing exceeds its neutralization potential (DBS&A, 1997). However, as tailing slurry, the

material is generally basic (pH greater than 7). Clarified TDRW makes up most of the process water

used in the concentrator. Some constituents (TDS, sulfate, molybdenum, and fluoride) in TDRW are

elevated above WQCC criteria.

Site-specific Hydrologic Conditions

The Ivanhoe Concentrator and associated pipelines are within the Whitewater Creek drainage basin.

Whitewater Creek is an ephemeral stream that flows in the DP-213 area in response to short-duration,

intense precipitation events or at times of significant snowmelt runoff. The other major surface water

feature in the DP-213 area is Bayard Canyon, an ephemeral tributary of Whitewater Creek. No

perennial surface water features are associated with the Ivanhoe Concentrator Area. Any surface

water runoff from the concentrator is contained by Reservoir 2 in Whitewater Creek.

The major hydrogeologic unit in the Ivanhoe Concentrator Area is quartz diorite porphyry. Regional

groundwater flow in this unit is controlled by fractures and flows toward Santa Rita Creek. The depth

to regional groundwater at the concentrator area is approximately 10 to 20 ft bgs (Golder 2007a). The

flow characteristics of the groundwater recharged from the concentrator area are described in Golder

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(2007a). The other major hydrogeologic unit is the alluvial aquifer along Whitewater Creek,

described in the previous section.

Known and Potential Impacts

Potential COCs produced by or used at facilities permitted under DP-213 include metals, sulfate,

TDS, low- or high-pH solutions, and hydrocarbon compounds. Exceedances of surface water quality

criteria in DP-213 have occurred from past pipeline releases. Improved stormwater containment and

new process water spill containment measures prevent releases to surface water.

Groundwater quality along the southern perimeter of the former Precipitation Plant is characterized

by TDS and sulfate concentrations above WQCC criteria. Historical data from groundwater

monitoring wells immediately within the Ivanhoe Concentrator Area indicate several metals, sulfate,

and TDS exceed WQCC criteria. The Whitewater Leach System, described previously, has been

considered a source for the low quality groundwater. Seven monitoring wells located near the

pipelines are also sampled periodically.

Groundwater quality in the Concentrator Area has been poor since at least as early as the first

monitoring wells were installed in the early 1980s. All wells in this area exceed the WQCC criterion

for TDS. Low pH groundwater is more common in the western portion of the area. Metals are

typically elevated in the areas of low pH. A series of interceptor wells that are collecting impacted

groundwater are present in this area. Impacted groundwater along the Whitewater Creek drainage

upstream of its confluence with the Hanover Creek drainage is collected at Reservoirs 4A, 2, and 17.

Dam 16 is the farthest downstream collection system. It intercepts and collects impacted groundwater

seeping downstream through the alluvial sediments to the west of Reservoir 17.

During process plant operations the potential impacts to air quality are from crushing and conveyor

operations and the lime plant associated with the concentrator. Particulate air emissions from these

facilities are subject to an air permit issued by the NMED Air Quality Bureau. There are no known

impacts to soil or sediment from the pipelines or ore processing activities at the concentrator. Several

tailing pipeline spills have occurred. These spills and affected soils and/or sediments have been

mitigated.

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3.2.7 DP-214: Hurley Operation, Lower Whitewater Creek, Lake One and Older Tailing Impoundments Areas

Facilities to be closed in DP-214 include the Older Tailing Impoundment Area, Lake One, the Hurley

Operation Area, Axiflo Lake, associated infrastructure in the Lower Whitewater Creek Area. The

DP-214 features are shown on Figures 3-6 and 3-7.

Material Characteristics

DP-214 primarily contains tailing, the waste material produced during ore processing activities.

Tailing in the older tailing impoundments was produced by operation of the former Hurley

Concentrator.

Laboratory analyses of tailing samples indicate that acid-generating potential exceeds the

neutralization potential in the older tailing impoundments (DBS&A, 1997). Analyses of vadose and

perched water samples from the older tailing impoundments demonstrate that these waters are in most

cases not degraded chemically, relative to the TDRW. The water returned from the tailing

impoundments usually retains a pH greater than 9. The vadose and perched water from the older

tailing impoundments generally exceeds applicable standards only for boron, manganese, sulfate, and

TDS. The boron and manganese are inferred to be from naturally occurring sources.

DP-214 also includes the slag piles in the Hurley Operation Area. These slag piles have been

characterized as required under the Supplemental Discharge Permit for Closure DP-1340, Condition

89 (Golder, 2005). Borehole and test pit samples were analyzed for mineralogical content, particle

size distribution, total metals analysis, acid-base accounting, paste pH and leach tests, including a

modified meteoric water mobility procedure (MWMP) that involved recirculated leaching for

28 days, rather than the standard 24 to 48 hours, and synthetic precipitation leaching procedure

(SPLP). No constituents in the leachate samples from the modified MWMP tests were above WQCC

criteria.

Site-specific Hydrologic Conditions

DP-214 is within the Whitewater Creek drainage basin of the SMA described in the previous sections.

Whitewater Creek is an ephemeral stream that flows in the DP-214 area only in response to

short-duration, intense thunderstorms or during times of major snowmelt runoff. Other surface water

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features in DP-214 include the Axiflo Lake, the lake bed of Lake One, the discharge elimination

system in the Hurley Operation Area, James Canyon and Bolton Draw (ephemeral tributaries to

Whitewater Creek), and an unnamed ephemeral drainage that runs from Hurley Operation Area past

the west sides of Tailing Ponds B and C and joins Whitewater Creek below the mine area.

The SMA hydrogeologic system is located within a deep bedrock channel filled with

variably-consolidated sediments. On the southern end of the SMA, the sediments are as much as 500

feet thick. The primary hydrostratigraphic unit of the SMA is the Gila Conglomerate. Quaternary

alluvial sands and gravels that are as much as 50 feet thick overlie the Gila Conglomerate principally

along the axis of the Whitewater Creek drainage. Data indicate that the hydraulic conductivity of the

Gila Conglomerate varies considerably (Golder 2007a).

The groundwater levels in the SMA range from approximately 60 ft bgs southeast of Hurley, to over

150 ft bgs south of Pond 7 (Golder 2007a). Figure 2-9 shows the current groundwater elevations of

the SMA along with the locations of monitoring wells. Groundwater elevation data used to map

groundwater elevations were primarily collected in 2007. The direction of groundwater flow in the

SMA is to the south towards the Pond 7 interceptor well system. South of the Pond 7 Interceptor

Well System, groundwater flow is also in a southerly direction. The Pond 7 interceptor system

captures groundwater south of Tailing Pond 7. Groundwater in the SMA discharges primarily to the

Pond 7 Interceptor Well System located down gradient of Pond 7. The interceptor well system has

been expanded since the CGCS in order to better capture groundwater, including that along the

southwestern edge of Pond 7. Groundwater in the lower Whitewater Creek Area on the southern end

of the study area discharges to the south as underflow (groundwater flow through the Gila

Conglomerate).

Currently, the most significant hydrogeologic features of the SMA are associated with infiltration of

water from Pond 7 and the operation of the associated Pond 7 Interceptor Well System. The updated

transient simulation of the current groundwater system described in Golder (2007a) indicates that the

Pond 7 interceptor system is capturing most of the impacted groundwater flowing downgradient of

the tailing ponds.

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Known and Potential Impacts

Shallow groundwater quality and known and potential impacts are described in the next sections for

the Lake One and the older tailing impoundment areas.

Lake One Area

Groundwater quality within the immediate Lake One Area exceeds WQCC criteria for TDS and

sulfate, as well as for metals and pH (Golder 2004a). To the west and southwest of Lake One,

shallow groundwater exceeds TDS and sulfate criteria, but pH is neutral in this area and metals

concentrations are low. The poor groundwater quality in the Lake One Area is believed to be, in part,

associated with the operation of Lake One as a reservoir between 1910 and 1984 (Golder, 2003).

Older Tailing Impoundment Area

Groundwater east of the tailing ponds generally exceeds WQCC criteria for TDS and sulfate The

eastern extent of the plume is not well constrained by the available data, however, additional data will

be collected as part of the Site-wide Abatement Task 2 field investigation. TDS-impacted

groundwater is observed primarily along the eastern side of the tailing ponds. Impacted groundwater

is observed in the Gila Conglomerate and apparently also locally in the underlying volcanic bedrock

in places. Shallow groundwater in the Old Tailing Pond Area has pH levels outside of the WQCC

criterion. The high pH data are likely the result of the alkaline seepage from the Older Tailing

Impoundments Area (DBS&A, 1997). Several of the wells are scheduled for evaluation as part of the

Site-wide Abatement Task 2 field investigation to further determine their construction and utility for

use as monitoring wells.

In the area west of the tailing Ponds B and C, shallow groundwater meet all WQCC criteria (with the

exception of manganese in the last couple of sampling events) demonstrating that groundwater in this

area is not impacted (Golder 2007a). Samples of shallow groundwater west of Ponds 1 and 2 exceed

WQCC criteria for TDS and sulfate. Some of the wells located west of Pond 6 are within WQCC

criteria. The two exceptions are shallow wells located along the immediate flank of Pond 7, where

TDS and sulfate exceed the criteria.

Groundwater quality in the central portion of the Older Tailing Impoundment Area, specifically in the

northern part of Pond 4, meets groundwater quality criteria. Groundwater quality at three of the

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four other interior wells monitored is elevated in TDS and sulfate, but meets most of the other water

quality criteria.

3.2.8 DP-484: Tailing Pond 7 Area

The facilities to be closed in DP-484 include Tailing Pond 7, the interceptor well-field, and auxiliary

structures and equipment such as the pipelines and the crane-mounted cyclones. The interceptor well

system lies along the southern edge of Tailing Pond 7. This system consists of 18 wells capture

affected groundwater south of Tailing Pond 7. DP-484 is shown on Figure 3-8.

Material Characteristics

The primary material to be characterized in the DP-484 area is tailing. Tailing is produced during ore

milling and processing. Tailing in Pond 7 was processed by operation of the Ivanhoe Concentrator.

The mineralogy and chemistry of the tailing in the older tailing impoundment areas have been

characterized and analytical results have been submitted to NMED pursuant to DP-213 requirements

(DBS&A, 1997). These materials have similar physical, chemical and mineralogical properties to the

tailing in the Older Tailing Impoundments.

Site-specific Hydrologic Conditions

DP-484 is located within the Whitewater Creek drainage basin of the SMA, which was described in

the previous section and Golder (2007a). Whitewater Creek is an ephemeral stream that flows in the

diversion channel located a short distance east of Tailing Pond 7 and only in response to short-

duration, intense thunderstorms or at times of major snowmelt runoff. Other waters in DP-484

include process water used to transport the tailing, runoff from the south slope of Tailing Pond 6, and

other permitted discharges that accumulate in the Tailing Pond 7 decant pond. Figure 2-9 shows the

current groundwater elevations within the SMA.

Known and Potential Impacts

Groundwater quality in the area east of Pond 7 generally meets WQCC criteria with the exception of

a couple of wells relative to the TDS and sulfate criteria. The Pond 7 Interceptor Well System is

capturing impacted groundwater. Deeper monitoring wells in this area meet WQCC criteria,

demonstrating that the impacted groundwater is being restricted to the upper portions of the Gila

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Conglomerate. Farther to the south, impacted groundwater is restricted to the corridor of the

Whitewater Creek drainage. Groundwater beneath Whitewater Creek has been impacted by historic

releases of poor quality surface water.

Groundwater quality on the west side of Pond 7 is within WQCC criteria (with the exception of

fluoride which may be naturally occurring in this area). Groundwater southwest of Pond 7 is elevated

in TDS and sulfate and additional interceptor wells were installed to provide containment in this

location (Golder 2007a).

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4.0 POST-MINING LAND USE DESIGNATION

Based upon the requirements of the MMD Permit, NMMA Section 69-36-11.6, and Subparts 507.A

and 507.B of the NMMA Rules (MMD, 1996), this section provides the post-mining land use

(PMLU) for the permit area as a whole and specific facilities at Chino. PMLUs are specified in

Section 3.G. of the MMD Permit.

4.1 Post-Mining Land Use Overview

The NMMA Rules define the PMLU as “a beneficial use or multiple uses which will be established

on a permit area after completion of a mining project. The PMLU may involve active management of

the land. The use shall be selected by the owner of the land and approved by the Director [of MMD].

The uses, which may be approved as PMLUs, may include agriculture, commercial or ecological uses

that would ensure compliance with Federal, State or local laws, regulations and standards and which

are feasible.” The proposed PMLUs for each facility were selected on the basis of the site

characteristics and the following guidelines:

• make the PMLU compatible with the surrounding ecosystem and land use;

• use the existing infrastructure and land resources to the extent possible; and

• maintain economic viability for Chino and the surrounding community.

The following PMLUs were selected for Chino:

• A wildlife habitat PMLU is designated for the tailing impoundments, stockpiles and other reclaimed areas.

• An industrial PMLU is designated for the transition of shops and non-process buildings and ancillary facilities from mining to an industrial/commercial complex.

The Santa Rita Open Pit and portions of the NMA have been granted a waiver from the requirements

of achieving a PMLU or self-sustaining ecosystem pursuant to NMMA Rules (19 NMAC 10, Subpart

5.507.B and Section 69-36-11.B.3 of the NMMA. The waiver area is addressed in DP-1340 (NMED,

2003). Figure 4-1 identifies the locations and extents of the proposed PMLU and the pit waiver area

designation for the permit area. The configuration of the mine upon closing will define the final

extent of the PMLU designations and will be adjusted with the 5-year NMED DP renewals.

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Wildlife habitat is the primary PMLU for the majority of the permit area, with an industrial PMLU

designated for the main mine facilities area, including the SX/EW Plant Area, the Mine Maintenance

Facilities Area, and the Ivanhoe Concentrator Area..

The selection of the wildlife habitat PMLU is discussed in the following sections and presents the

rationale Chino used for designating an industrial PMLU for some of the facilities and provides

details regarding the efforts to achieve the PMLU. The vegetation success guidelines that will be

applied to demonstrate reclamation of the mine are also detailed.

4.2 Wildlife Habitat Post-mining Land Use

Of the MMD-approved PMLUs, grazing land and wildlife habitat are the designations most consistent

with the surrounding land uses and ecological potential of the Chino site, excluding the areas

designated as industrial/commercial. Chino selected the wildlife habitat PMLU in deference to a

grazing land designation to preclude long-term grazing management issues. The wildlife PMLU was

selected in recognition that wildlife cannot practically be excluded from the reclaimed areas and that

they would use the area even if a grazing land designation was selected as the PMLU.

Reclamation will result in the development of an early-stage grass/shrub community that will provide

a locally important increase in community-level diversity. Some infrastructure may have a

post-mining wildlife use such as power poles for raptor perches, main roads for land management,

and modified mine openings for use by ringtail cats, bats and other wildlife.

Native vegetation will be established on the reclaimed areas at Chino resulting in increased erosion

protection, direct habitat improvement, and reduced percolation of water into the underlying materials

relative to current conditions. Proposed reclamation seed mixes and seeding rates for the NMA and

SMA at Chino are presented in Tables 4-1 and 4-2, respectively. These species have broad ecological

amplitudes and provide structural diversity.

The proposed seed mix was selected to provide early establishment of ground cover, erosion control,

and diversity in growth forms. The species selected for Chino have been successfully used in mine

reclamation and range improvement projects in many parts of New Mexico. The primary reclamation

seed mix proposed for the wildlife habitat PMLU areas at Chino includes cool- and warm-season

grasses, perennial shrubs, and forbs. Depending on availability, alternate species may be substituted

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for the primary species. The seed mix was designed for application prior to the summer rains.

However, it has proved successful under fall seeding conditions.

Table 4-3 lists some of the major attributes of the vegetation selected for use at Chino. The selected

vegetation will provide: erosion control; promote soil development; and provide forage, seeds, and

cover for small mammals and birds. The seed mix includes a number of valuable, nutritious forage

and browse species that could be used by wildlife.

4.3 Industrial Post-mining Land Use

The industrial PMLU designation of buildings and facilities are summarized in Table 4-4. Those

facilities not designated as the industrial PMLU will be removed or demolished. Demolition,

removal, and/or burial will be accomplished by meeting requirements of the following conditions

specified in MMD (2003):

• Where footings, slabs, walls, pavement, manholes, vaults, stormwater controls, and other foundations are not included in the industrial PMLU, abandoned in place over non-acid-generating material, and not demolished, they will be covered with suitable cover material.

• Covered footings, slabs, walls, pavement, manholes, vaults, stormwater controls and other foundations not included in the industrial PMLU will be revegetated.

• Structures to be covered due to regrading of piles will be demolished and removed.

• All debris will be removed from reaches of Santa Rita and Whitewater Creeks adjacent to or within industrial PMLU areas upon implementation of the closeout plan.

• Chino will demolish and remove the following structures associated with the tailing impoundments: tailing termination tower, tailing area maintenance facility, tailing slurry cyclones, and cranes.

The industrial PMLU will continue the existing type of use; however, the specific industry will

change. The three areas proposed for industrial PMLU have the infrastructure necessary to support

future industrial uses such as electroplating or sand and gravel supply. The buildings are well

maintained and most of the areas have significant shop facilities and warehouse storage capacity. The

Maintenance Facilities Area is accessible by roads and the Ivanhoe Concentrator Area has railroad

access. Electrical power is available in each area, including possible backup power from the existing

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Power Plant. Stormwater runoff from the areas is contained within the on-site reservoir system.

Finally, ample water resources are available due to the water rights that Chino controls and current

infrastructure.

Chino will maintain erosion controls, structures, equipment, and utilities within the industrial PMLU

areas until they are occupied by tenants. Chino proposes to cover and re-seed non-paved areas within

the industrial PMLU areas after mine closure.

4.4 Site-Specific Revegetation Success Guidelines

Section 507.A of the NMMA rules (MMD, 1996) requires that the permit area of an existing mine be

reclaimed to a condition that allows the establishment of a self-sustaining ecosystem appropriate for

the life zone of the surrounding area unless it conflicts with the approved PMLU. Demonstration of

the establishment of a self-sustaining ecosystem is made by comparison of the vegetation on the

reclaimed areas to vegetation attributes on a reference area and/or technical standards (MMD, 1996).

The MMD recognizes that replication of the pre-mining plant communities after mining is not

practical (MMD, 1996). The intent of the reference area characterization is to provide a site-specific,

quantitative basis for determining revegetation success. More importantly, the reference areas

provide an “ecological barometer” that integrates normal climatic variations to aid in the evaluation

of temporal changes or trends in the reclaimed ecosystem. Thus, the reference areas do not represent

model plant communities that will be replicated in detail, but rather local indications of the ecological

potential of the reclaimed plant communities.

The reclamation success guidelines required by the MMD vary depending on the PMLU. Canopy

cover, shrub density, and vegetation diversity are the revegetation success guidelines that are typically

used to judge revegetation success on lands designated as wildlife habitat.

The vegetation success guidelines include numerical standards to address the canopy cover and shrub

density requirements of the NMMA (DBS&A, 1999b). The plant diversity guidelines are addressed

through a technical standard and are complemented by a qualitative assessment of plant colonization

and regeneration to corroborate the establishment of a self-sustaining ecosystem. The approved

guidelines for revegetation success that apply to Chino are discussed in the following sections.

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4.4.1 Canopy Cover

Because of its broad implications for erosion control and ecologically based PMLUs, canopy cover is

one of the primary criteria for determining reclamation success. Chino has a proportional success

guideline for total canopy cover equal to 70 percent of the measured reference area value (DBS&A,

1999b). The proportional standard was determined based on the interpretation of the community

structure and ecological conditions in the reference area. The proportional standard reflects the view

that the typical 12-year bond release period does not allow enough time for full maturation of the

reclaimed plant community relative to the native sites. The numerical standard derived from the

proportional standard will vary over time to account for temporal differences in canopy cover

associated with climatic variations. Thus, the numerical standard may increase or decrease based on

reference area measurements, but the proportional standards will remain fixed.

4.4.2 Shrub Density

Shrubs are important components of many reclaimed landscapes. A proportional success guideline of

60 percent (of the reference area) has been accepted by the MMD for shrub density in the reclaimed

areas (DBS&A, 1999b). The shrub density standard was determined based on the interpretation of

the ecological condition of the reference areas.

4.4.3 Plant Diversity

Species diversity is commonly thought to increase the stability of plant communities. The perceived

enhancement of ecological stability is related to the buffering effect that species with different

ecological amplitudes provide in response to environmental stresses. A technical, rather than

proportional, standard will be proposed for plant diversity.

The plant diversity guidelines for Chino are based on the assumption that site stability is improved by

establishing plants with different ecological amplitudes to buffer seasonal and annual fluctuations in

climate. Chino understands that creating a monoculture on the reclaimed lands is not desirable, while

at the same time, recognizing that the benefits of increased diversity diminish beyond subjective

threshold levels that are defined by the reclamation objectives. Thus, the diversity guideline for

Chino was developed from a functional perspective, whereby site stability and erosion control are

primary performance objectives. In addition, these guidelines were developed in recognition of the

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limitations associated with the sampling and statistical evaluation of plant communities whereby

minor components are often not represented in the monitoring data.

The numerical diversity guidelines for Chino are listed in Table 4-5. To summarize, the diversity

guideline would be met if the reclaimed area contains at least three warm-season grasses and two

shrubs, with individual cover levels of at least 1 percent, and one perennial, cool-season grass with a

minimum cover level of 0.5 percent. For the purposes of this guideline, intermediate-season grasses

such as plains lovegrass are considered the functional equivalent of the more traditionally defined

cool-season grasses. In addition, one non-weedy forb species should occur at a minimum cover level

of at least 0.1 percent to meet the proposed diversity guideline. The forb guideline is unqualified with

respect to seasonality and could include a perennial, biannual, or annual species.

Species diversity on the reclaimed areas is expected to increase with time; however, this process is

likely to be slow. Successful colonization depends on the convergence of a seed source and the

proper weather conditions; however, even with such an ideal convergence, inter-specific competition,

predation, and dispersion mechanisms may limit the establishment of new plants on the reclaimed

area. Because of the strong climatic influence on seed production and plant establishment, the rate of

colonization is expected to be erratic and potentially slow for many species, with the highest rates of

colonization expected to be concentrated in the reclaimed/undisturbed ecotone. Evidence of

colonization will complement the numerical diversity guidelines listed in Table 4-5. No numerical

guideline is proposed for colonization, which would be demonstrated by increases in the number of

species recognized in the reclaimed area. Information on colonization will be collected and reported

to provide evidence of the ability of the reclaimed landscape to support native plants from the

surrounding communities. Secondarily, observations of colonization provide evidence of

regeneration and thus help demonstrate the establishment of a self-sustaining ecosystem required in

the NMMA.

The intent of the colonization standard is to provide evidence of the ability of the reclaimed landscape

to support plants from the surrounding communities. In addition, observations of colonization

provide evidence of regeneration and thus support the demonstration of the establishment of a

self-sustaining ecosystem. No numerical standard is proposed for colonization, which will instead be

demonstrated by increases in the number of species recognized in the reclaimed area. This

information will be obtained from the relative cover data or documented observations along the

margins of the reclaimed areas.

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5.0 CONDITIONAL STUDIES AND ONGOING RECLAMATION PROJECTS

Additional studies were specified in both the MMD permit (MMD, 2003) and in Supplemental

Discharge Permit for Closure DP-1340 (NMED, 2003) to establish the CCP. In several of the cases,

the required work plans for the additional studies in the two permits have been coordinated and

integrated into single documents. In some instances, the studies have also been integrated to meet the

requirements of the permits and support development of the CCP. The following sections provide an

update relative to these studies. A brief description and the status of the conditional studies are

included in the following sections along with summaries of the results as applicable.

5.1 Revision 01-1 to Permit GR009RE, Section 8

The MMD permit requires that several conditional studies be addressed. A brief description and

summary of their status follows:

Condition Description Status D. Tailing Ponds Lake One closeout procedures finalized based on DP-1340 conditions. In Progress D.4b. and E.4b. Wildlife surveys for tailing impoundments and stockpiles. Completed

Cover Test Plot Program work plan and implementation schedule. In Progress Slope stability study work plan and implementation schedule.

In Progress

Affected areas study work plan and implementation schedule were completed to identify areas affected by Chino mining operations in order to determine whether these areas require reclamation. The study provided a review and evaluation of relevant environmental investigations. The study provided a summary of data gaps, which were summarized by affected area and operational DP at the mine site. These gaps are being addressed under the various discharge permits, the AOC investigations and the Stage 1 Abatement process.

Completed

Areas being considered for sludge disposal have been identified and estimates of sludge volumes were presented in February 2004. This information will be updated pending results of the ongoing water treatment feasibility study.

Completed

L. Additional Studies:

Borrow materials investigation work plan and report. In Progress 5.2 Supplemental Discharge Permit for Closure DP-1340

Supplemental Discharge Permit for Closure DP-1340 includes supplemental studies as part of

Conditions 80 though 93. Several of these conditions required work plans and studies as part of the

terms and conditions of the permit. The following is a summary of the status of these efforts. As

applicable, the results of the conditional studies are summarized as follows:

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Condition Description Status 80

Supplemental Slope Stability Study - Perform a supplemental stability study of the waste rock piles and leach ore stockpiles to evaluate their long-term stability after mine closure.

Due Date: Extension Requested

81

Comprehensive Cover Performance Evaluation - Perform a comprehensive cover performance evaluation to evaluate the type and thickness of the proposed cover materials and to further characterize the physical and hydraulic properties of the proposed cover materials for the tailing ponds, waste rock piles, and leach ore stockpiles.

Due Date: Extension Requested Annual Reports Thereafter

82

Cover, Erosion, and Revegetation Test Plot Study - Perform a cover, erosion, and revegetation test plot study to evaluate net infiltration through the store and release cover with differing cover thicknesses, feasibility of construction and construction techniques required during cover placement, erosion rates of covered and uncovered slopes, vegetation success, and upward migration of acid from underlying materials.

Due Date: Annual Reports Start in 2005 Annually Thereafter Until 2011

83 Hydrologic Study - Perform a hydrologic study to evaluate the hydrologic conditions beneath the tailing ponds, waste rock piles, leach ore stockpiles, including the collection of water level and water quality data. The results of this study may be used to support the development of abatement plans at the mine.

Completed

84 Mass Loading Study: Supplemental Leach Ore Stockpile and Waste Rock Stockpile Mass Loading Study - Perform a supplemental leach ore stockpile and waste rock stockpile mass loading study.

Due Date: Extension Requested

85

Sludge Handling Plan - Develop a detailed sludge handling plan and cost estimate to address the locations and design of sludge management areas, volumes and tonnages of sludge generated as part of the water treatment processes, an operational plan, compliance with applicable waste management regulations, and long-term stabilization. Evaluate existing data and develop estimate of sludge generation; develop list of potential sludge deposit areas; Develop conceptual sludge management report.

Pending Water Treatment Feasibility Study Results Annual Progress Reports

86 Water Treatment System Sustainability Study - Preparation of report identifying water sources and water rights, assessing sustainability of water sources, analysis of potential impacts on groundwater, identification of discharge points, and description of proposed beneficial use of discharged water. Provide a schedule for completion of each of the components of this study. Provide annual progress reports on the status of the component studies.

Annual Progress Reports and Final Report Completed

87 Alternative Water Treatment System Design - This condition is contingent on C. 86 (Water Treatment System Sustainability Study) not complying with C.40 (treat all contaminated water to WQCC criteria) and C.41 (Pump and Treat Contaminated Water from the Open Pit).

Condition Not Triggered

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Condition Description Status 88 Process Solution Elimination Study - Evaluate alternatives and

identify environmentally sound and cost-effective methods to treat or eliminate the process solutions following Cessation of Operation or closure.

Completed

89 Slag Characterization Study and Slag Pile Closure Plan - Characterization study to determine potential effects on groundwater and closure plan for slag pile.

Completed

90 Lake One Area Characterization Study - Characterization report addressing the sediments and groundwater in the Lake One Area and analysis of closure alternatives and development of closure plan.

Due Date: Extension Requested

91 Reservoir and Impoundment Study - Determine which of the existing reservoirs, lakes, sumps, or any other pond will be needed during closure and post-closure for water management.

Completed

92 Supplemental Northern Area Groundwater Flow Model - Model and characterize the impacts and potential future impacts to ground water in the Northern Area as a result of Cessation of Operations.

Completed

93 Feasibility Study - A study designed to evaluate closure alternatives for each facility to be closed.

Completed

5.2.1 Condition 80 – Supplemental Slope Stability Study

To fulfill the requirements of Condition 80, an additional study was performed to supplement

previous analyses of the stability of the stockpiles at Chino (Golder, 2007b). In accordance with

Condition 80, Chino is required to “…evaluate the long-term physical stability of Waste Rock Piles

and Leach Ore Stockpiles after closure.” The study evaluated and quantified changes in the

engineering parameters resulting from weathering processes in the piles and was therefore

coordinated with the Condition 84, study of the geochemical processes in the stockpiles. Additional

conditions of this study included the evaluation of all stockpiles, regardless as to whether they are

inside or outside the OPCZ and the identification and evaluation of the extent of landslides, talus and

rubble areas in the vicinity of the stockpiles and their possible effects on stockpile stability.

The factors of safety for stockpiles in a regraded configuration are high and these would not be

expected to experience instability in the long term. Reasonable predictions of stockpile material

strength reductions due to long term weathering of the stockpile material do not indicate that the

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regraded stockpiles would become unstable. Stockpiles that are not planned to be regraded and have

slopes that are near angle-of-repose could become marginally stable if the shear strengths of the

material are further reduced from their estimated fully weathered strength. The slope stability

analysis does not support flattening of slopes to compensate for further strength reduction of the

stockpile material due to weathering. .

5.2.2 Condition 81 – Comprehensive Cover Performance Evaluation

To fulfill of the requirements of Condition 81, Chino is required to “perform a comprehensive cover

performance evaluation to evaluate the type and thickness of the proposed cover materials and to

further characterize the physical and hydraulic properties of the proposed cover materials for the

tailing impoundments, waste rock piles, and leach ore stockpiles.” Efforts to completely fulfill the

requirements of Condition 81 are in progress.

The supplemental material characterization of the Upper South Stockpile (Golder, 2006c) was

prepared in partial fulfillment of the requirements of Condition 81 of DP-1340. This report

emphasized the characterization of rhyolite soil chemical attributes to evaluate the suitability of this

material as a final cover system. Based on the inherent properties of rhyolite, it was considered to be

the best available for cover construction in the NMA. It is anticipated that ongoing and future work

associated with this condition would be completed in accordance with approved work plans (Tetra

Tech, 2003a and 2003b).

5.2.3 Condition 82 – Cover, Erosion, and Revegetation Test Plot Study

To fulfill of the requirements of Condition 82, Chino is required to “Perform a cover, erosion, and

revegetation test plot study to evaluate net infiltration through the store and release cover with

differing cover thicknesses, feasibility of construction and construction techniques required during

cover placement, erosion rates of covered and uncovered slopes, vegetation success, and upward

migration of acid from underlying materials.” Data collection and other work to completely fulfill the

requirements of Condition 82 are in progress. It is anticipated that ongoing and future work

associated with this condition will be completed in accordance with approved work plans (Golder

2006e).

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5.2.4 Condition 83 – Hydrologic Study

To fulfill of the requirements of Condition 83, Chino is required to “Perform a hydrologic study to

evaluate the hydrologic conditions beneath the tailing impoundments, waste rock piles, leach ore

stockpiles, including the collection of water level and water quality data. The results of this study

may be used to support the development of abatement plans at the mine.” The major conclusions

drawn from the Condition 83 hydrologic study include:

North Mine Area

• the estimated of groundwater inflows during operations and following closure has been revised;.

• the location of the surface expression of the OPCZ under current operational conditions has been further refined;

• outside of the OPCZ, the flow paths of impacted groundwater recharged beneath stockpiles and other disturbed areas has been further refined; and

• updated estimates of the quantities of groundwater reporting to the pit, discharging as surface water at the toes of the stockpiles, and leaving the footprint (horizontal projection) areas of the stockpiles outside of the OPCZ .

Middle White Water Creek Area

• the groundwater system of the MWWCA is largely confined to the alluvial channel associated with the Whitewater Creek drainage;

• groundwater in the alluvium has been impacted by historical releases of poor quality surface water; and

• groundwater of the MWWCA currently flows down gradient into the Lake One and SMA and is eventually intercepted by the Tailing Pond 7 interceptor well system.

South Mine Area

• The SMA groundwater system is largely confined to the Gila Conglomerate; and

• Pond 7 Interceptor Well System is containing impacted groundwater associated with current and historical tailing pond operations, and groundwater that was historically impacted by releases of poor quality surface water down Whitewater Creek.

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5.2.5 Condition 84 – Supplemental Leach Ore Stockpile and Waste Rock Stockpile Mass Loading Study

In fulfillment of Condition 84 of DP-1340, Chino is performing a supplemental mass loading study

on leach ore and waste rock stockpiles. Chino reported preliminary study results in the interim report

submitted by EnviroGroup (2006). The study characterized the West, South, and Lampbright

stockpile compositions, evaluated the effects of leaching and weathering on the mine material

properties, modeled stockpile seepage quality, evaluated mass loading to groundwater, and provided

information for slope stability analysis.

5.2.6 Condition 86 – Water Treatment System Sustainability Study

In fulfillment of Condition 86 of DP-1340, Chino prepared a report on water treatment system

sustainability (JSAI, 2006). The study specifically addressed requirements in the condition:

1) identified sources of water and associated water rights for dilution water to be used as part of the

water treatment system; 2) analyzed the sustainability of the water resources proposed for use in

commingling for a period of at least 100 years; 3) assessed the potential impact to groundwater from

land application of the final effluent stream; 4) analyzed the potential impact to ground water from

land application to the commingling water source wells; 5) identified the potential discharge points

for the final effluent stream; and 6) described the proposed beneficial use for the final effluent stream.

5.2.7 Condition 88 – Process Solution Elimination Study

In fulfillment of the requirements of Conditions 33 and study associated with Condition 88, Chino

submitted a work plan to NMED for a process solution elimination study on October 3, 2003. The

findings were presented in a report to NMED on June 25, 2004 (M3, 2004b). The process solution

elimination study evaluated alternatives to identify environmentally sound and cost-effective methods

to treat or eliminate the process solutions following the cessation of mining operations or closure of

Chino. The study evaluated two options for process solution elimination: a recirculation option and a

pit option. Although both options rely on surface and spray evaporation as the means to eliminate

process water, the recirculation option utilizes the existing reservoirs, pumps, and pipeline systems to

hold and evaporate water, while the pit option transfers water to the Pit Lake/Sump for evaporation.

The recirculation option was recommended system to be implemented after operations cease in the

northern area of Chino.

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5.2.8 Condition 89 – Slag Characterization Study

The subject slag pile is located in the Hurley Operations Area. In fulfillment of Condition 89 of

DP-1340, Chino reported the test results on the slag and underlying native materials samples (Golder,

2005 and 2006d). Test results indicate that the slag does not leach constituents above WQCC criteria.

Tests on soil samples and tuff bedrock indicate metals associated with the slag were not leached to the

native materials.

The specific language requires submittal of results with a proposed closure plan and implementation

schedule.

5.2.9 Condition 90 – Lake One Area Characterization Study

In fulfillment of Condition 90 of DP-1340, Chino prepared a characterization study and closure

alternatives analysis (Golder, 2004a). A conceptual site model was developed as the basis of a

quantitative system model. The system model was used to evaluate fourteen closure alternatives,

which included different approaches for source control and groundwater remediation. In January

2005, NMED approved the characterization study and disapproved the closure feasibility study. In

2005, additional field investigations were conducted to address NMED’s comments. These data were

used to update the conceptual and systems models of the site.

5.2.10 Condition 91 – Reservoir and Impoundment Study

In fulfillment of Condition 91 of DP-1340, Chino prepared a report of the reservoirs and

impoundments at Chino (M3, 2004a). The report concludes that Reservoirs 2, 6 and 9 will be closed.

Reservoir 3A and Reservoir 7 will be retained for stormwater collection after reclamation activities

are complete. NMED commented on the report on January 3, 2006 requesting Chino include

Reservoir 8 in the study, among other comments. Chino responded to NMED’s comments on

March 17, 2006. A revised report incorporating NMED and Chino’s responses is pending.

5.2.11 Condition 92 – North Area Groundwater Flow Model

In fulfillment of Condition 92 of DP-1340, Chino prepared a report describing the NMA groundwater

flow model (Golder, 2006b). The study included developing a three-dimensional groundwater flow

model of the NMA and the Santa Rita Open Pit.

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5.2.12 Condition 93 – Feasibility Study Analysis of Closure Alternatives

In fulfillment of Condition 93 of DP-1340, Chino has completed a feasibility study and selected a

proposed course of action based on the results. The results were based on the relative cost and

benefits of selected alternatives (Golder, 2007d). The preferred alternative for closure is the “Partial

Cover Option” identified in the report as Alternative 2.

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6.0 RECLAMATION DESIGNS AND POST-CLOSURE MONITORING

This section presents the conceptual reclamation designs and post-closure monitoring for

closure/closeout of the principal Chino facilities. The reclamation practices proposed herein are

intended to limit future environmental impacts and, to the extent practicable, provide protection of air

and water resources consistent with state and federal laws.

Open-pit mining and recovery of metals is projected to continue at Chino for many years, therefore,

the size and topography of the mining area will change. Leaching and SX/EW recovery of metals is

projected to continue beyond open-pit mining. Therefore, the conceptual reclamation design

approach for closure/closeout has been prepared to consider changing site conditions to the degree

practical. In meetings with the NMED and MMD, a date of June 1, 2007 was established as the latest

date that new information could reasonably be incorporated into this update to the CCP and the

point-in-time for the closure scenario was also established as the EOY-2007. Final designs, technical

specifications, and construction quality assurance plans for each facility will be prepared when

milling, mining, and SX/EW recovery of metals cease or as part of accelerated reclamation activities.

The basic conceptual designs should be applicable to any time period even though quantities and unit

costs may change with time.

The focus of this plan is to develop general concepts and designs for closure of the larger facilities

and to estimate costs. Descriptions of the facilities covered by the reclamation designs and their

evaluation criteria are included in Section 6.1. The performance objectives and reclamation designs

for closure/closeout of the facilities are included in Section 6.2. The water treatment methodology is

outlined in Section 6.3. Section 6.4 contains post-closure monitoring and contingency plans. The

existing and planned closure/closeout activities for Chino according to each of the eight operational

DPs as well as reclamation of mining facilities not addressed in Section 6.0 are discussed in

Section 7.0.

6.1 Facility Characteristics and Classification

To standardize the development of the financial assurance cost estimate, facilities with common

characteristics and mine function have been grouped together. The reclamation plans and facilities

are also grouped by DP in Section 7.0. Thus, reclamation activities for the tailing impoundments,

stockpiles, open pit, reservoirs, disturbed areas, and water treatment are identified as the primary

work break-down level. The following sections provide general descriptions of these facility groups.

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The characteristics of individual tailing impoundments, stockpiles, the open pit, reservoirs, and other

disturbed areas at Chino are summarized on facility characteristics forms (Appendix B). The general

areas of disturbance and associated major facilities to be reclaimed at Chino are summarized in the

following paragraphs.

6.1.1 Tailing Impoundments

The reclamation design for the tailing impoundments (or ponds) considers that a total of 4,229 acres

have been disturbed and will be reclaimed (Table 6-1). The tailing impoundment area includes:

inactive tailing ponds 1, 2, B, C, 4, 6 East (6E), and 6 West (6W); portions of Pond 4 are required to

accommodate operational upset conditions; the southern sector of ponds 6W and 6E are also required

for operations and active tailing pond 7; as well inactive Lake One and Axiflo Lake process water

reservoir. Ponds 4, 6, and 7 are permitted by the NMOSE Bureau of Dam Safety and NMOSE

approval is required to reclaim these impoundments.

Chino is presently implementing plans (Golder-URS, 2007) to reclaim Axiflo Lake and Ponds 1, 2, B,

C, 4, and portions of Ponds 4, 6E, and 6W (Golder-URS, 2007). Portions of Ponds 6E and 6W will

remain open to accommodate operational requirements, but will receive a dust cover to control wind

redistribution of tailing and fugitive dust. Pond 7 is currently receiving tailing and its topography is

expected to change between now and 2013 as its height increases.

6.1.2 Stockpiles

A total of 2,438 acres of stockpile surfaces are targeted for reclamation under this plan (Table 6-2).

This includes all top surfaces and outslopes outside the OPCZ. The stockpile areas to be reclaimed

include top surfaces of all the stockpiles; and the outslopes of the West, South, Main Lampbright,

South Lampbright, Southwest Lampbright and Upper South Stockpiles where they are outside the

OPCZ (Appendix A).

6.1.3 Santa Rita Open Pit

The Santa Rita Open Pit is a single large pit with smaller zones within it. The water that accumulates

in the Santa Rita pit is managed through combined processes of evaporation and pumping. The pit

forms a hydrologic sink capturing groundwater flowing from all directions. Some of the seepage

from the nearby stockpiles is also captured by the pit.

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6.1.4 Reservoirs/Dams

There are 23 named reservoirs/dams in the NMA covering approximately 120 acres. The reservoir

characteristics are summarized in Table 6-3 (M3, 2004a). The plan is to close and reclaim Reservoirs

2, 6 and 9. Reservoirs 3A and 7 will be cleaned out as necessary and retained for stormwater control

purposes. Existing piping may also be used to support water management and the water treatment

infrastructure. The remaining reservoirs/dams will be used to intercept surface water, seeps, or

perched water and direct flows to permanent impoundment or treatment facilities as follows (M3,

2004a):

• seepage handling: Reservoirs 10, 11, 12, 13, 14, 14-1, 14-2, and 14-3 are required to collect long-term seepage from the stockpile (these reservoirs presently collect stormwater runoff and/or seepage from the West Stockpile to prevent those flows from entering Hanover Creek);

• surface runoff: Reservoirs 3A, 4A, 5, 7, 15, 17, and 20 will be designated for post-closure stormwater control;

• water treatment and influent storage: Reservoirs 4A and 20 will provide storage of influent to the NMA water treatment plant; and

• process solution handling: Reservoir 8 will be utilized during the process solution elimination period that will occur immediately following cessation of leaching operations (Leach solutions will be collected from the Lampbright Stockpiles and pumped to the proposed evaporation system located on the top surface of one of the leach stockpiles).

In the SMA, Axiflo Lake is being closed as part of the reclamation of the older tailing impoundments

(Golder-URS, 2007). Pond 4 is permitted for emergency or upset conditions although it is anticipated

the eastern sector of the pond will be closed and reclaimed with the other older tailing impoundments.

Pond 7 and the southern ends of Ponds 6E and 6W are being used for tailing management operations

and will be reclaimed at the end of Pond 7 operations.

6.1.5 Other Disturbed Areas

Slag Pile – Hurley Operations Area

The slag pile will be graded to 2.5(H):1(V) on the outslopes and no less than 0.5 percent on the top

surface, covered with suitable materials, and seeded and mulched to establish vegetation.

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Groundhog Mine Area Reclamation

Reclamation of the Groundhog Mine Stockpile Area is being addressed under the AOC as well as the

NMMA. Planned reclamation activities associated with the Groundhog Mine Area are discussed in

Section 7.2.

Facility Demolition and Contaminated Soil

In the NMA, facility demolition includes approximately 117,200 square feet of buildings and

equipment areas. For cost estimating purposes, it was assumed that approximately 25 percent of the

facility footprint area (or about 5 acres) was impacted to a depth of 12 inches (1,860 cubic yards) and

was assumed to include contaminated soil. This material will be disposed of onsite. Excavations will

be filled with clean cover materials and seeded to establish vegetation. For planning purposes, it was

assumed that fifty percent (50%) of the demolished foundations will be covered with a minimum of

two feet of suitable cover material.

Pipeline Corridor

The pipeline corridor extends from the Ivanhoe Concentrator to the tailing impoundments area.

Reclamation will include excavation and disposal or covering of impacted soil. Obsolete pipelines

will be removed or rinsed and buried in place. Much of the piping will be used for water

management and water treatment infrastructure.

6.1.6 Ancillary Work

Ancillary work includes abandonment of exploration boreholes and fencing of the perimeter of the

mine area.

6.2 Performance Objectives and Reclamation Designs

Performance objectives were developed with the intent of meeting rules and requirements associated

with the WQA, WQCC Regulations and NMMA. This section presents the reclamation designs in

accordance with these objectives. The reclamation designs are depicted in the drawing set provided

in Appendix A. The designs were developed to support the financial assurance cost estimate.

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6.2.1 Tailing Impoundments

Chino’s performance objectives for the top surfaces and outslopes of the tailing impoundments

include establishment of a self-sustaining ecosystem, control of fugitive dust, control of runoff and

erosion, prevention of overtopping, and the reduction in the amount of water that enters the tailing.

The major performance objectives associated with the tailing impoundment toe and hill-slope

perimeters include maintenance of regional groundwater quality and prevention of undercutting

erosion from channel flow, subsurface inflow, and run-on. The following subsections describe the

conceptual-level designs for the reclamation of the tailing impoundments.

Structural Stability of Tailing Dams

The gross stability of the tailing dams with respect to mass failure has been determined to be

adequate, with long-term static factors of safety (FOS) greater than 1.5 and greater than 1.2 for

undrained and post-earthquake loading conditions (Table 6-4). The stability of the tailing dams is

expected to increase under post-closure conditions, as they undergo long-term draindown and

consolidation. Ultimately, the NMOSE is required to review the reclamation plans to determine that

the designs will not negatively affect the safety of the dams in the post-closure period.

Tailing Impoundment Erosion and Drainage Control

The final grade of the top surface will range from 0.5 to 5 percent. Surface water runoff will be

directed to rock-protected aprons at the entrance to stormwater conveyance structures. Channels and

hydraulic structures have been designed to safely convey stormwater from the top surfaces, while

grading and perimeter berms will protect the outslopes from water erosion. Where necessary, energy

dissipation structures will be provided for channel outlets where erosive velocities are predicted to

occur. Final designs will likely be adjusted for local conditions.

The tailing impoundment inter-bench outslopes will be graded to typical slopes of 3H:1V or flatter.

Stormwater will be controlled on the outslopes using conventional terrace channels integrated to

downdrains. Runoff drainage and erosion control for tailing impoundment will be achieved by

stormwater conveyance channels, stable out-slopes, and revegetation.

Run-on control is not a post-closure concern since tailing impoundments have been constructed

completely above grade and the potential for tailing dam undercutting has been addressed by past

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water diversion projects. The need for additional run-on protection of tailing impoundments will be

re-evaluated in the final design.

Temporary erosion control measures will be provided during the construction and early vegetation

establishment periods. These measures may include mulch, straw bales, silt fences, and minor

corrective regrading, as necessary.

Tailing Impoundment Cover and Revegetation

The tailing is highly susceptible to wind and water erosion and a suitable cover is necessary to

prevent dispersion of these materials in the environment. A large portion of the tailing surfaces at

Chino have already been covered with local soils to control fugitive dust.

Finish grading of the tailing and dust cover subgrade will be performed as needed based on

pre-construction surveys. Earth moving equipment such as bulldozers and motor graders will be used

to smooth the surfaces and facilitate access for supplemental cover placement and mulching/seeding

The cover on the tailing impoundments will be a minimum of 24 inches and will be constructed of

Gila Conglomerate and native soils obtained from local borrow areas. The cover design for the

tailing impoundment requires moderate to high amounts of rock fragments at the surface to reduce the

potential for water erosion. Sufficient quantities of borrow for cover materials exist in the SMA near

the tailing impoundments.

Using techniques that have proven to be effective at the nearby Tyrone Mine, revegetation will be

achieved by seeding with a variety of native and adapted grasses, shrubs, and forbs. The revegetation

requirements including planned seed mix for the South Mine Area tailing impoundments were

summarized in Section 4.0. Seed will be applied using appropriate methods, such as drill and/or

broadcast, depending on the final cover and site characteristics. The mulch will be specified as weed

free and will contain a minimum of viable seeds associated with the mulch source (barley or wheat

are proposed). Long-stem mulch will be given preference over shorter materials. Straw or native

grass mulch will be applied at a rate of approximately 2 tons per acre and stabilized by crimping.

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Tailing Impoundment Groundwater Containment

Impacted groundwater, including any tailing decant waters and seepage will be contained using

downgradient interceptor well systems, such as wells, sumps, and pumps, similar to those currently

operating immediately south and southwest of Pond 7. The interceptor systems will be operated

during the post-closure period in a manner similar to the current operation. Water quality will be

monitored to differentiate impacted from non-impacted water. Impacted water will be commingled

with treated water and non-impacted water to produce a discharge quality suitable for a beneficial use

such as crop irrigation.

6.2.2 Stockpiles

The performance objectives for closure of the stockpile facilities include: establishment of a

self-sustaining ecosystem; reduction of infiltration; containment of seeps and sediment; and control of

run-on, runoff, and releases to perched and regional groundwater.

Structural Stability

Existing stockpile outslopes at Chino are composed of clast-dominated run-of-mine rock in various

stages of hydrothermal and supergene alteration, placed through end-dumping at angle of repose with

occasional setbacks resulting in overall slopes that are flatter than angle of repose. The gross stability

of the stockpiles has been determined to be adequate and is expected to remain stable under post-

closure conditions (Table 6-5).

Stockpile Erosion and Drainage Control

Stockpile top surfaces will be graded to direct non-affected water to designated discharge areas. The

stockpile top surfaces will be graded to promote positive drainage to stormwater conveyance channels

with slopes between 0.5 to 5 percent. Surface water runoff will be directed on the graded top surfaces

to rock-protected stormwater conveyance structures. Rock-lined channels, perimeter berms, and

hydraulic structures will be designed to control erosion on the top surfaces and outslopes and safely

convey stormwater for release. The existing berms on the stockpile top perimeters will be improved,

where necessary, and maintained to prevent the concentration of flow onto the outslopes.

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Sediment detention ponds incorporating existing reservoirs will be used to capture eroded soils and

impacted groundwater. Non-impacted top surface water will drain to a discharge area via the existing

stockpile access roads with enhanced ditches.

Energy dissipation structures will be constructed at channel outlets to reduce erosive velocities where

necessary. Where possible, channels will be constructed to incorporate existing topography, grade

controls, and exposed inert bedrock thus, promoting long-term integrity of the structures. The final

design will be adjusted for local conditions.

Run-on is not expected to be a post-closure concern for most of the stockpiles since they have been

constructed completely above grade. However, the Southwest Lampbright and South Stockpiles have

hillslope perimeters that abut the natural topography and will be evaluated for run-on controls. The

need for run-on protection of stockpiles will be more fully evaluated in the final design process.

Temporary erosion control measures will be provided during the construction and early vegetation

establishment periods. These measures include mulch, straw bales, silt fences, and minor corrective

regrading, as necessary. All construction will be in compliance with state regulations for temporary

stormwater control.

Stockpile Cover and Revegetation

Finish grading of the stockpile subgrade will be performed based on pre-construction surveys. Earth

moving equipment such as bulldozers and motor graders will be used to smooth the surfaces and

facilitate access for cover placement and mulching/seeding. Stockpile covers will be placed

according to the following criteria:

Inside Pit Capture Zone Top Surface Cover Thickness 24 inches Outslope Cover Thickness No cover Slope (overall) Existing Outside Pit Capture Zone Top Surface Cover Thickness 24 inches Average Outslope Cover Thickness 24 inches Inter-bench Slopes Stockpile outslopes outside the OPCZ 2.5H:1V Overall Outslope Stockpile overall outslope Approximately 3:1 assuming 15 foot terrace benches

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Covers will be constructed of rhyolite and leached cap (R&LC) material. The Upper South Stockpile

and South Pit Area have been identified as borrow sources for cover material. The stockpile is

represented by a heterogeneous mixture of R&LC that occur in zones related to the dumping

sequence. The leached cap material tested to ensure its suitability prior to Upper South Stockpile

delivery. The chemical and physical properties of this material indicate few inherent limitations for

use as cover materials (Golder, 2006e).

Once vegetation is established, the R&LC cover will reduce the amount of water entering the

underlying waste rock and leach stockpiles. The suitability of the R&LC as cover material to reduce

water entry into the stockpiles and support a self-sustaining ecosystem is being studied to fulfill the

requirements of Conditions 81 and 82 of DP-1340.

Placement and operational grading of waste rock and leach ore during the mining operations results in

nearly level top surfaces with only minor irregularities. Thus, only finish grading is required to

achieve 0.5 to 5 percent slopes planned on the top surfaces to facilitate cover placement and/or

stormwater controls.

Substantial grading is planned for the stockpile outslopes located outside the OPCZ. Terraced

benches will be constructed to limit slope lengths and control erosion. These benches will be

constructed with inter-bench outslope angles of 2.5(H):1(V) and slope lengths no greater than about

175 feet.

Revegetation of the top surfaces and outslopes located outside the pit capture zone will be achieved

by seeding with a variety of native and adapted grasses, shrubs, and forbs. The planned seed mix for

the North Mine Area stockpiles was discussed in Section 4.0. The seed will be applied using an

appropriate method (such as drill or broadcast) depending on the cover and site characteristics.

This CCP assumes drill and/or broadcast seeding into a roughened seedbed bed. Straw or native grass

mulch will be applied at a rate of approximately 2 tons per acre and stabilized by crimping. The

mulch will be specified as weed-free and contain a minimum of viable seeds associated with the

mulch source (barley or wheat). Long-stem mulch will be used when possible.

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Stockpile Surface Water, Groundwater, and Sediment Containment

The existing and planned reservoirs, dams, berms, sumps, collector pipes, and pump-back systems

will be integrated into a new overall system to reduce releases to surface water, perched water, and

groundwater.

6.2.3 Santa Rita Open Pit

The performance objectives for the open pit facility subgroups are centered on run-on control, safety,

operational access, and groundwater control. Chino received a waiver from the requirements of

achieving a PMLU or SSE for the Santa Rita Open Pit pursuant to Section 3.H of the MMD Permit.

The performance objectives for the pit crest perimeter are to control run-on and public access. A

water diversion and vehicle exclusion berm will be constructed around the circumference of the Santa

Rita Open Pit will achieve these goals. The berm, constructed from local rock and soils, will be a

minimum of 10 feet wide and 5 to 10 feet high with sideslopes angled at 1.5(H):1(V). Site access will

be controlled at the mine property line by new and existing fences and security staff.

The performance objective for the open pit sideslopes is to capture non-impacted water flows

resulting from precipitation above the oxide/sulfide mineralization interface and to maintain access

for operation and maintenance. Pit walls are sufficiently stable that a specific conceptual design is

not needed. Any materials eroded from these slopes will be contained within the pit.

The performance objectives for the pit floor areas are to maintain the hydraulic sink for capture and

removal of impacted water. Impacted water will be captured in pit floor sumps then pumped to the

water treatment facility.

6.2.4 Reservoirs/Dams

The performance objectives for reservoir/dam facilities are to retain or convey process, decant, and

surface water. The reservoir and dam facilities are planned to be the last features to be closed

following the establishment of vegetation and site stabilization on the other facilities. Reservoirs that

serve PMLU functions or are associated with the stockpile toe perimeter control systems that will be

permanent parts of the reclamation system and will be maintained throughout the post-closure period.

The disposition of specific facilities with respect to closure/closeout is discussed in Section 7.0.

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Closure and reclamation of reservoir and dam structures will involve grading to achieve drainage

followed by revegetation. Where non-acid-generating materials exist, a minimum of 24 inches of

suitable cover material will be provided in the areas to be reclaimed. Synthetic liners in Reservoirs

10, 11, 14, and 14-1 will be removed, disposed of and completely covered with 24-inches of suitable

material. Any existing non-deleterious, non-compacted rooting material may be used as part of final

cover. Revegetation will be accomplished using a seed mix similar to that planned for the NMA.

6.2.5 Disturbed Areas

Performance objectives for disturbed areas include creation of a self-sustaining ecosystem and

erosion control. Reclamation of the disturbed areas will be accomplished by removing or burying

utility and structure foundations, pipelines, power lines, and buildings, reclamation will include

providing erosion protection, drainage control and revegetation. Compacted soils in areas such as

roads will be loosened by ripping. Where possible, the ripping and grading of compacted areas will

be accomplished during near-closure operational phases.

The necessity for removing utility structures will be determined on a site-specific basis. Buildings

will either be demolished or converted to an alternative industrial use. Where footings, slabs, walls,

pavement, manholes, vaults, stormwater controls and other foundations are not included in the

Industrial PMLU and are removed, these foundations will be abandoned in place and covered with

24 inches of suitable cover material.

The temporary erosion and drainage control practices will include rough grading and installation of

water bars, minor diversions, sediment containment structures, mulching, straw bales, and silt fences.

The need for these practices will be evaluated on a site-specific basis at closure. Depending on the

geographic location, the sites will be seeded using either the NMA or SMA seed mixes.

6.2.6 Borrow Areas

North Mine Area

The leached cap and rhyolite overburden contained in and scheduled for delivery to the Upper South

Stockpile represent the best available cover materials in the NMA. The use of overburden and waste

rock as a reclamation media is a common practice at surface mines in New Mexico and other western

states regulated under various State and Federal programs. Chino believes this practice was

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recognized by the MMD in the development of the MMD Closeout Guidelines for Existing Mines,

which indicates that “Soils to be used for reclamation may include: soils salvaged and stockpiled prior

to disturbance; in place soils such as waste/overburden materials, or soil taken from borrow areas.”

The use of waste rock and overburden as cover materials is a standard of practice for many existing

mines because the pre-mining soils are typically shallow and soil salvaging was not a component of

historic operations.

Leached cap and rhyolite overburden are the only practical sources of cover material at Chino that

occur in sufficient quantities to achieve reclamation of the NMA. Analyses of these materials

indicates that they are moderately coarse- to medium textured with moderate to high rock fragment

contents and few inherent chemical limitations (Golder, 2006c). Based on investigations made in

2006, about 6 million to 7 million yd3 of readily available cover materials are stockpiled on the Upper

South Stockpile. An additional 50 to 70 million tons of suitable materials are projected for mining in

the near future. Chino has implemented a testing and materials handling plan to identify and

segregate materials suitable to use for the cover. These materials are currently placed on the Upper

South Stockpile and plans are being considered for the strategic development of additional

reclamation stockpiles in the future.

For the NMA, about 7 million yd3 of cover materials will be required to cover the acres scheduled for

reclamation under this plan. The combined resources in the Upper South Stockpile and overburden

from the South Pit Area are will exceed this cover requirement. At closure, the Upper South

Stockpile will be partially consumed and remaining material will then be reclaimed in accordance

with the performance objectives in Section 6.2.2.

South Mine Area

The best available cover material in the SMA is the Gila Conglomerate Formation and associated

soils. Investigations have determined that about 220 million yd3 of cover material occur within the

MMD permit area in the SMA (Golder-URS, 2007).

For the SMA in this plan, approximately 12.5 million yd3 of materials will be required in this plan to

cover the impoundment areas identified for reclamation, including Pond 7 and the Lake One Area.

An additional 300 thousand yd3 is required to cover the slag pile in the Hurley Operations Area. The

borrow areas around the tailing impoundments, which are identified in more detail in the Construction

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Design and Quality Assurance Plan (Golder-URS, 2007), will yield more than 10 million yd3 of

material.

Reclamation Design

The top surface of the Upper South Stockpile in the NMA, which will be only partially consumed,

will be reclaimed using methods similar to those described for the other stockpiles top surfaces within

the OPCZ. The cover material borrow areas in the SMA will have sideslopes no greater than

3(H):1(V) as a result of the specified excavation plan. The borrow areas will be ripped where

required and revegetated with the seed mix proposed for the SMA.

Soil Salvaging

Where feasible in the NMA, Chino will salvage all suitable topsoils and cover material as mining

expands into undisturbed areas. These materials will be stored on Upper South Stockpile or future

cover material stockpiles.

6.3 Water Management and Treatment

Impacted and non-impacted waters will be managed and impacted waters will be treated to meet

regulatory criteria for discharge at closure. The principal objective of the water management and

treatment is to meet regulatory criteria for the discharges.

6.3.1 Management and Treatment Processes

The principal elements of the water management and treatment plan include:

• long-term collection of impacted water from NMA sources;

• short-term collection and elimination of process waters through an evaporation treatment system (ETS) early in the closure period;

• conveyance of impacted waters from Cobre Mine to the NMA facilities;

• conveyance of treated water from the NMA treatment facility to the SMA;

• commingling of the NMA water treatment effluent, treated Lake One water, tailing interceptor well water and SMA production well water; and

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• discharge of final treated and commingled effluents.

Water treatment will involve lime precipitation and high density sludge (lime/HDS) processes using

two treatment plants as follows:

• a lime precipitation high density sludge (lime/HDS) process for a variety of source waters in the NMA; and

• a lime/HDS plant in the Hurley Operation Area for treatment of Lake One water.

The treated effluents from the NMA and Hurley Operation Area lime/HDS plants would then be

commingled with tailing interceptor well and SMA make-up water in a mixing pond prior to

discharge.

6.3.2 Evaporation Treatment System and Process Water Elimination

Integral with the site-wide water treatment system, is development and operation of an ETS in the

NMA. The ETS will collect and evaporate process-related waters on one of the leach stockpiles and

would begin operations at closure and operate in parallel to the water treatment system in the NMA.

Process water elimination is assumed for financial assurance purposes to be completed after 5 years,

although a longer time frame may be necessary. The sources of water that will be collected and

routed to the ETS during this period include:

• pit and reservoir waters;

• pregnant leach solution (PLS) draindown;

• leached stockpile seepage; and

• runoff from uncovered leached stockpile outslopes and pit walls within the OPCZ.

It is anticipated that beginning in year 6, or when the ETS has shut down and process waters have

been reduced significantly or eliminated, the remaining flows would be fed to the water treatment

system.

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For purposes of the CCP Update, it is assumed that lime treatment of the Lake One water will be

included with the Commingling alternative. Golder has estimated the quantities and qualities of the

flows to the NMA water treatment system (Golder 2007a).

6.3.3 Sludge Management

Condition 85 of DP-1340 requires Chino to develop a detailed Sludge Management Plan. So far, the

first three tasks have been completed and include a schedule, estimate of volumes and mass of sludge,

and a list of potential disposal locations (Chino, 2004b and 2004c). A final evaluation and selection

of a preferred location is in progress and will be based largely on the water treatment scenario.

A detailed analysis and cost estimate for a sludge disposal facility at Tyrone has been completed

(GVR, 2004) and was used as the basis to estimate sludge management capital and operating costs at

Chino. The capital costs included a storage and load-out bunker adjacent to the water treatment

facility and the disposal cells. The disposal cells include construction of stormwater diversion

channels and final closure. The Tyrone facility costs are used as the basis with scaling of the Chino

project to account for the projected sludge volumes to be produced by the lime/HDS treatment

facilities at the NMA and Lake One.

6.4 Reporting, Post-closure Monitoring and Contingency Plans

All the closure and post-closure groundwater, surface water, seep, spring, interceptor system, tailing

draindown, and piezometer monitoring data will be reported quarterly under the applicable Chino

Operational Discharge Permits and in accordance with Condition 63 of the Supplemental Discharge

Permit DP-1340 (NMED, 2003). As specified under Condition 64, Chino will submit to NMED

quarterly reports on or before January 15, April 15, July 15, and October 15 of each year. Chino will

also prepare two potentiometric maps annually that include data from all monitoring wells, extraction

wells, piezometers, seeps, and springs in both the SMA and NMA in accordance with Condition 65 in

DP-1340.

Chino will submit annual reports to MMD beginning in Year Two of the test plot study in accordance

with Condition L.1.d of the MMD Permit (MMD, 2003). The MMD guidelines require monitoring of

revegetation during the bonding period to evaluate revegetation success, and WQCC Regulation

3107.A.11 requires the development of post-closure monitoring and contingency plans that are

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consistent with the terms and conditions of the applicable DP. The following sections summarize the

general approach that will used to meet these requirements.

6.4.1 Erosion and Drainage Control Structures

The reclaimed lands, including those in the industrial PMLU areas will be visually inspected for signs

of excessive erosion, and significant erosion features will be mitigated to prevent future degradation

of the site in accordance with Condition 67 (DP-1340 permit condition requiring maintenance on all

reclaimed areas). Based on the monitoring of revegetation and erosion required in Conditions 58

(DP-1340 permit condition requiring closure and post-closure monitoring of vegetation) and 59

(DP-1340 permit condition requiring inspection of closed lands for signs of excessive erosion and

mitigation), Chino will provide recommendations for maintenance work in quarterly monitoring

reports, including a schedule for completion of the work.

As specified in Condition 68 (DP-1340 permit condition requiring inspection and maintenance of all

closure components that may affect groundwater quality), Chino will routinely inspect and maintain

all drainage channels, diversion structures, retention impoundments, and auxiliary erosion control

features in accordance with professionally recognized standards such as Natural Resources

Conservation Service. Post-construction/reclamation inspection schedules will be developed to

include provisions for periodic (annual or semi-annual) and extreme event monitoring as appropriate

for individual facilities. Chino will report evidence of excessive erosion and/or structural failures to

the appropriate agencies (MMD, NMED, or NMOSE) in a timely manner. A written report detailing

the nature and extent of the problem and a corrective action plan will be developed within 75 days

after the problem is identified.

6.4.2 Groundwater and Surface Water Control Facilities

In accord with Condition 66 (DP-1340 permit condition requiring inspections and monitoring of

seepage interceptor systems), Chino will perform quarterly inspections and annual evaluations of all

seepage interceptor systems, including the Pond 7 Seepage Interceptor System and groundwater

remediation systems, and perform necessary maintenance. Monitoring of site water quality will be

accomplished through sampling and analysis of potentially impacted water at site locations.

Groundwater quality will be monitored throughout the post-closure period. The intent of the

groundwater monitoring is to evaluate the effectiveness of the reclamation and groundwater

containment systems and demonstrate compliance with applicable regulations and standards. The

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monitoring schedule, analytical requirements, location, and construction specifications for the

monitoring wells will be determined in consultation with NMED. The analytical results will be

reported to the NMED on a semi-annual basis.

A contingency plan for closure components and emergency response plan for surface impoundments

were prepared and submitted as required by DP-1340 Conditions 75 and 78 (Chino, 2003 and 2004a).

The contingency plan addresses failure of any component of the closure plan that may result in

exceedances of WQCC criteria and will be developed on a site-specific basis consistent with the

protocols established for WQCC Regulation 1203 (notification of discharge). Accordingly, Chino

will verify potential exceedances, report exceedances to NMED within 24 hours of confirmation,

prepare a corrective action plan for mitigation within 75 days, and implement mitigative measures

within a reasonable period of time. The corrective action plan will be developed and implemented in

collaboration with NMED.

Surface water quality will be monitored to determine the effectiveness of the reclamation.

Post-closure surface water monitoring locations and schedules will be established in consultation with

NMED. Chino proposes to monitor water quality in Reservoirs 5, 8, 4A, and 17; and on the major

streams draining the permit area such as Lampbright Draw and Whitewater and Hanover Creeks. The

water samples will be analyzed to determine total suspended sediment and dissolved constituents

required to demonstrate compliance with applicable standards. The results of the surface water

quality monitoring will be reported to the NMED Surface Water Quality Bureau (SWQB). A

corrective action plan will be developed and submitted to the NMED SWQB and MMD if data

indicate degradation of water quality has occurred.

Samples will be collected quarterly at groundwater monitoring well locations. Samples will also be

collected quarterly at surface water collection points. Sample collection will be done in house or

under contract by an independent environmental engineering firm.

Collected samples will be shipped to an independent analytical laboratory for analysis of COCs. A

report will be prepared to document the sampling and analysis for review and recording by site

management and review by regulatory authorities.

The water treatment plant will be on a continuous schedule of sampling and recording for operational

control. Automatic samplers will be employed to collect composite samples of influent and effluent

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streams. Each month, one composite sample of water treatment plant influent and one composite

sample of water treatment plant effluent will be shipped to an independent analytical laboratory for

analysis of COCs. A report will be prepared to document the sampling and analysis for review and

recording by site management and review by regulatory authorities.

6.4.3 Revegetation Success Monitoring

The reclaimed areas will be monitored periodically after the final grading and the initial establishment

of vegetation on the reclaimed lands. Chino will conduct qualitative vegetation monitoring of

re-seeded areas during the third year after seeding. A determination of the success of the vegetation

establishment will be made within 3 growing seasons. Quantitative monitoring will be performed at

the sixth year after planting and then again for 2 consecutive years prior to bond release.

Revegetation monitoring will include canopy cover, plant diversity, and woody stem density as

discussed in Section 4.4 and specified in Condition N.2 of the MMD Permit.

6.4.4 Wildlife Monitoring

Pursuant to Section 8.N.3 of the MMD Permit, Golder submitted a wildlife monitoring plan for

post-closure of the Chino Mine dated December 29, 2004 (Golder, 2004c). This plan was

conditionally approved by the MMD and New Mexico Department of Game and Fish on February 15,

2006. The monitoring plan provides a description of the proposed reclamation plan as it applies to

wildlife and wildlife habitat, an overview of the existing species and wildlife habitat within the

vicinity of the Chino Mine, and the proposed methods for deer pellet group counts and bird diversity

surveys.

Results will be evaluated to determine wildlife use trends during re-establishment of a self-sustaining

ecosystem. The results of the surveys will not be a condition of, or given consideration with regard

to, financial assurance bond release.

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7.0 SUMMARY OF CLOSURE/CLOSEOUT PLAN ACTIVITIES

This section summarizes the existing and planned closure/closeout activities for Chino according to

each of the eight operational DPs as well as reclamation of mining facilities not addressed in

Section 6.0.

7.1 Discharge Plan Areas

The DPs are described in Section 2.6.9. Environmental considerations are discussed in Section 3.2.

The following paragraphs describe the specific facilities to be closed within each of the operational

DPs. Mining facilities that are outside these areas are discussed in Section 7.2.

7.1.1 DP-376: Lampbright Leach System (Lampbright Stockpiles and Reservoir 8 Areas)

Mining Facilities to be Closed

Mining facilities to be closed in the DP-376 area include (Figure 7-1):

• the Lampbright Stockpiles and the associated disturbed areas;

• selected seepage/runoff collection sumps and impoundments along the north side of the Main Lampbright Stockpile; and

• various pipelines for raffinate, PLS, and groundwater, except those that may be used in a post-closure water management system.

The reclaimed area of the combined Lampbright Stockpiles and associated disturbed areas are

provided in Table 6-2 and their characteristics are included in Appendix B. Reservoir 8 will be part

of the post-closure sediment and surface water management system. The few auxiliary structures in

the DP-376 area will be removed and salvaged upon closure.

Existing Closure Components

Closure activities and related engineering controls implemented to date in the DP-376 area include:

• construction and maintenance of stockpile top surface perimeter berms;

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• installation, operation, and maintenance of existing toe control systems, including the process water interceptor system along the north and east sides of the Main Lampbright Stockpile and the groundwater extraction system;

• diversion of excess surface water runoff from undisturbed terrain north of the Main Lampbright Stockpile along the North Diversion Channel into Tributary 2; and

• diversion of stormwater runoff south of the Lampbright Stockpiles into a number of impoundments in Tributary 1 to reduce peak flows into Reservoir 8.

Planned Closure/Closeout Activities

The closure/closeout activities planned for the DP-376 area consist of:

• removing remaining debris and solid waste and dispose of it in an approved manner;

• flushing the raffinate and PLS pipelines with water to remove residual solutions;

• grading the stockpile top surfaces as necessary to support placement of the cover and provide drainage;

• grading stockpile outslopes to approximately 2.5H:1V;

• cover the top surfaces with 24 inches of cover material;

• constructing hydraulic structures as necessary to direct excess water off of the covered top surfaces;

• constructing run-on controls on the west side of the Southwest Lampbright Stockpile and the disturbed area associated with the Lampbright Stockpile;

• constructing terraced benches at interbench slopes of 2.5H:1V with reach lengths of approximately 175 feet.

• constructing benches approximately 15 feet wide, sloped 0.5 percent toward the interior portion of the outslope face immediately above it, with a longitudinal slope of no greater than 5 percent;

• constructing drainage systems to control erosion of the stockpile outslopes and segregate non-affected and most potentially affected runoff;

• providing facilities to discharge non-affected stockpile runoff;

• providing hydraulic structures to direct affected water to a site-wide water treatment facility;

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• grading the disturbed area associated with the stockpiles to provide drainage;

• covering disturbances not identified specifically as a mine unit or borrow area with 24 inches of cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

7.1.2 DP-591: SX/EW and Reservoirs 6 and 7

Mining Facilities to be Closed

The SX/EW Plant area, Reservoir 6 and Reservoir 7 are shown in Figure 7-2. Several of the SX/EW

Plant and associated facilities will be maintained for use as one of the industrial PMLUs. Existing

pipelines, tanks, impoundments, and other facilities will be left in place and maintained by Chino.

Reservoir 7 is expected to serve as a stormwater impoundment whereas Reservoir 6 will be closed.

Existing Closure Components

Closure activities and related engineering controls implemented to date in the DP-591 area include:

• installed and operated interceptor well system;

• installed and maintained stormwater management controls, including the North Diversion Channel and the raffinate overflow impoundment; and

• use of process water storage and Reservoir 7 for stormwater management.

Planned Closure/Closeout Activities

Planned site-specific closure/closeout activities for the DP-591 area consist of:

• draining and grading Reservoir 6 to provide drainage;

• removing or remediate affected sediments and cover with 24 inches of cover material;

• seeding covered and disturbed areas to re-establish vegetation; and

• draining Reservoir 7 and removing and disposal of impacted sediments;

• covering Reservoir 7 with 24 inches of suitable cover material, and use it as a sediment/stormwater control feature for the industrial PMLU area;

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• In the immediate SX/EW Plant area:

• demolishing the old Raffinate Pond, PLS Feed Pond, Wash Rack, and temporary storage structures;

• flushing the PLS, raffinate, and other pipelines with water to remove accumulated sediment;

• removing all debris and visually affected soil at or near the surface;

• disposing of debris or affected soil in an approved manner;

• collecting confirmation samples from areas where soils were removed;

• covering unpaved areas with nominally 24 inches of suitable cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

7.1.3 DP-459: Main Pit, North In-Pit Leach System, and Northeast, North, Northwest, and Lee Hill Waste Rock Piles and Stockpiles and Reservoir 5

Mining Facilities to be Closed

Mining facilities to be closed at the DP-459 area include (Figure 7-3):

• the North Pit Stockpile and associated disturbed areas;

• Northwest, Lee Hill, and Northeast Stockpiles;

• the Santa Rita Open Pit (Main Pit); and

• pipelines and related facilities for raffinate, PLS, and stormwater/groundwater, except those that may be used in the post-closure water management system.

The footprint areas (horizontal projections) of the North In-Pit Leach, Northwest, North and

Northeast Stockpiles are included in Table 6-2. The footprint (horizontal projection) of the Santa Rita

Open Pit is also shown in Table 6-2. The few ancillary structures in the DP-459 area will be removed

and salvaged upon closure. All of these existing stockpiles are within the OPCZ. Chino has received

a waiver from the MMD for these facilities relative to achieving a PMLU or self-sustaining

ecosystem.

Existing Closure Components

Closure activities and related engineering controls implemented to date at the DP-459 area include:

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• stockpile top surface perimeter berms;

• installed, operated, and maintained toe control systems for the stockpiles, including the process water collection system along the south side of the north leach portion of the North Stockpile and the pit dewatering system; and

• surface water runoff diversions in upper Santa Rita Creek to Reservoir 5.

Planned Closure/Closeout Activities

The closure/closeout activities planned for the DP-459 area consist of the following:

For the stockpiles:

• removing remaining debris or solid waste and dispose of it in an approved manner;

• flushing the raffinate and PLS pipelines with water to remove residual solutions;

• grading the stockpile top surfaces as necessary to support placement of the cover and provide appropriate drainage;

• covering stockpile top surfaces with 24 inches of cover material;

• constructing hydraulic structures where needed to direct runoff from the covered top surfaces;

• providing hydraulic structures to direct impacted water to the NMA water treatment facility; and

• providing facilities to discharge non-impacted stockpile runoff.

For the Santa Rita Open Pit:

• constructing a 10-ft wide berm five feet high to control run-on;

• constructing a 6-ft high continuous chain-link security fence around the pit crest perimeter to control access;

• providing and/or maintain hydraulic systems on the pit floor to capture and transfer impacted water to the site-wide water treatment facility; and

• providing interceptor wells to control groundwater.

For miscellaneous pipelines not incorporated in the post-closure water management system:

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• flushing the raffinate and PLS pipelines with water;

• salvaging or burying pipelines with 24 inches of suitable cover material; and

• seed covered areas to re-establish vegetation.

7.1.4 DP-493: Reservoir 3A

Mining Facilities to be Closed

Reservoir 3A will be used for stormwater collection as part of the post-closure surface water control

system (Figure 7-3). Mining facilities to be closed at the DP-493 area include miscellaneous

pipelines for raffinate, except those that may be used in the post-closure water management system or

for stormwater control.

Existing Closure Components

Engineering controls implemented to date in the DP-493 area that may have a post-closure purpose

include periodic pumping of Well 3A-5 to remove impacted groundwater.

Planned Closure/Closeout Activities

The closure/closeout activities planned for the DP-493 area consist of:

• flushing the pipelines with water to remove residual solutions;

• salvaging or burying redundant pipelines with 24 inches of cover;

• pumping the remaining water in Reservoir 3A to an approved discharge point or allow the water to evaporate;

• removing and disposing of impacted sediments, and covering the reservoir area and associated disturbed areas with 24 inches of suitable cover material;

• seeding covered and disturbed areas to re-establish vegetation; and

• using the reservoir for stormwater control during the post-closure period.

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7.1.5 DP-526: Whitewater Leach System (Stockpiles and Facilities Area)

Mining Facilities to be Closed

Mining facilities to be closed at the DP-526 area include (Figure 7-4):

• the West and South Stockpiles and associated disturbed areas;

• Reservoir 2 and associated disturbed areas; and

• pipelines and related facilities used for raffinate, PLS, and stormwater, except those that may be used in the post-closure water management system.

Reservoirs 4A and 17 and the impoundments, catchment structures, and sumps at the toes of the West

and South Stockpiles will be maintained as part of the post-closure water management system.

Existing Closure Components

Closure activities and related engineering controls implemented to date in the DP-526 area include:

• stockpile top surface perimeter berms;

• installed, operated, and maintained toe control systems, including the sediment, stormwater, seepage, and groundwater interceptor systems along the west side of the West and South Stockpiles,

• PLS collection systems and sand traps;

• Diversions of stormwater runoff into Reservoir 4A; and

• water management of utilizing Reservoir 17 and alluvial groundwater interceptor systems (Dam 16) along upper Whitewater Creek

• stockpiling suitable cover materials in the Upper South Stockpile.

Planned Closure/Closeout Activities

The closure/closeout activities planned for the entire West and South Stockpiles, except the Upper

South Stockpile, consist of:

• removing remaining debris and solid waste and dispose of it in an approved manner;

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• flushing the raffinate and PLS pipelines with water to remove residual solutions;

• grading stockpile outslopes (those located outside the pit capture zone) down to an average interbench slope of 2.5H:1V;

• extending the toe interceptor system to outside the regraded West Stockpile toe limits along Hanover Creek;

• grading the stockpile top surfaces to 0.5 percent to support placement of the cover and provide drainage;

• covering top surfaces and regraded outslopes located outside the OPCZ (including the haul roads, unused pipelines, and berms) with 24 inches of suitable cover material;.

• and covering the outslopes with 24 inches of suitable cover material;

• constructing hydraulic structures as necessary to direct excess water off of the covered top surfaces;

• providing drainage systems to control erosion of the stockpile outslopes and maximizes the segregation of non-impacted and potentially impacted runoff;

• providing additional channels, sumps, wells, pumps, and pipelines to direct impacted water to a site-wide water treatment facility;

• providing facilities to discharge non-impacted stockpile runoff;

• grading the Upper South Stockpile, which will be partly consumed for use as cover material, to a slope of 2.5H:1V during material removal; and

• seeding covered and disturbed areas to re-establish vegetation.

For Reservoir 2 and associated disturbed areas:

• draining and grading Reservoir 2 to provide drainage;

• removing or mitigating any impacted sediments and cover with 24 inches of cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

Reservoir 4A will be used for stormwater and sediment control and storage of solutions collected

from the Whitewater Stockpile toe control and groundwater interceptor systems and Reservoir 17 will

be maintained for emergency stormwater control (M3, 2004a).

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7.1.6 DP-213: Ivanhoe Concentrator and Associated Pipelines

Mining Facilities to be Closed

Mining facilities to be closed in the DP-213 area include the tailing and concentrate pipelines

(Figure 7-5). The Ivanhoe Concentrator and its associated facilities will be maintained for use as an

industrial PMLU area. Some process water pipelines will be maintained as part of the post-closure

water management system.

Existing Closure Components

Closure activities and related engineering controls implemented to date at the DP-213 area include

stormwater management facilities at the Ivanhoe Concentrator Area and the tailing pipeline spill

management systems. These closure components and controls are discussed in Section 3.2.6.

Planned Closure/Closeout Activities

The planned site-specific closure/closeout activities for the DP-213 area consist of:

• demolishing the Waste Oil Pad, Hoist House and Head Frame, and Wet Cycle Crush Plant;

• removing the Portable Storage Shed;

• flushing the tailing and concentrate pipelines with water to remove accumulated sediment.;

• salvaging or burying pipelines;

• maintaining culverts;

• placing 24 inches of suitable cover over the pipeline corridor;

• removing all debris and visually affected soil at or near the surface from the concentrator area and covering with 24 inches of cover;

• disposing of debris and affected soil in an approved manner;

• covering unpaved areas with nominally 24 inches of suitable cover;

• seeding covered and disturbed areas to re-establish vegetation.

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The NMA water treatment facility is planned within DP-213 adjacent to the Ivanhoe Concentrator.

Pipelines transporting affected water will originate in most of the NMA DP areas. Existing sumps,

pumps, and pipelines will be used as appropriate.

Facilities to be installed include:

• degriting basin;

• water treatment plant feed reservoir;

• chemical precipitation water treatment plant;

• sludge impoundment for water treatment solid effluent; and

• reservoir or tanks to mix water; and

• existing reservoirs will used as appropriate.

7.1.7 DP-214: Hurley Operation Area, Lake One, Older Tailing Impoundment Area, Axiflo Lake, Lower Whitewater Creek

Mining Facilities to be Closed

Mining facilities to be closed at the DP-214 area include (Figure 7-6):

• Older Tailing Impoundment Area consisting of Ponds 1, 2, B, C, 4, 6E, 6W ;

• Lake One;

• Axiflo Lake; and

• Hurley Operation Area.

Existing Closure Components

Closure activities and related engineering controls implemented to date at the DP-214 area include:

• stormwater controls in Hurley Operation Area;

• dust cover capping in the Older Tailing Impoundment Area;

• Lower Whitewater Creek diversion in 1998;

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• James Canyon Diversion.

• closure of the hydrocarbon landfarm at Pond 1.

The hydrocarbon landfarm at Tailing Pond 1 was closed in late 2005 according to the closure plan

provided in M3 (2001). Chino submitted a closure report (Telesto, 2006b) to NMED documenting

fulfillment of closure requirements. NMED approved the closure report in April 2006.

A closure/closeout plan for Lake One is being developed in fulfillment with Condition 90 of

DP-1340.

As described in Section 6.1.1, Chino is presently implementing plans (Golder-URS, 2007) to close

and reclaim Axiflo Lake and Tailing Ponds 1, 2, B1, B2, C, 6 East (6E), and 6 West (6W).

Implementation plans are also being designed for the east sector of Tailing Pond 4.

Chino ceased operations at the Hurley Smelter complex in the Hurley Operation Area and has

completed resource recovery, structure removal and has developed a reclamation plan as required in

Condition 26 of DP-1340 and Operational DP-214. The plan is being implemented according to the

accelerated reclamation schedule.

Planned Closure/Closeout Activities

Older Tailing Impoundment Area

Chino has developed a Construction Quality Assurance (CQA) Plan to reclaim most of the inactive

Older Tailing Impoundment Area and associated facilities (Golder-URS, 2007). The reclaimed area

will encompass approximately 1,400 acres and include the surface and outslopes of Ponds 1, 2, B1,

B2, C, Axiflo Lake, and all except the southern ends of Pond 6E and 6W Appendix A). Plans are

currently being developed for the east sector of Pond 4. The areas not being closed to support ongoing

active operations include:

• the western sector of Tailing Pond 4 (required for active tailing management operations);

• the south end of Ponds 6E and 6W that contain infrastructure and lay down areas required for operating Pond 7; and

• utility corridors required for the continued operation of Pond 7.

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The planned reclamation incorporates the following approach:

• relocating existing utilities that are not located in utility corridors to utility corridors compatible with both the closure and post-closure objectives;

• removing remaining debris and solid waste, and dispose of it in an approved manner;

• flushing pipelines, active at the time of closure, that do not have a post-closure purpose with water to remove accumulated sediment in accordance with Condition 29 of DP-1340;

• grading outslopes to remove existing erosion channels;

• covering the tailing impoundment outslopes and top surfaces, including the slurry pipelines, with 24 inches of suitable cover material;

• placement of a temporary dust cover (approximately 4 to 6 inches thick) on the south end of Ponds 6E and 6W;

• grading the exterior and interior slopes of all the tailing impoundments to slopes no steeper than 3H:1V (slopes that already meet this requirement will not be graded);

• grading top surfaces to between 0.5 and 5 percent to convey stormwater to hydraulic structures;

• constructing hydraulic structures to direct runoff from the tailing impoundment surfaces;

• applying armoring and construct channels on the tailing impoundment outslopes to reduce erosion and control runoff; and

• seeding covered and disturbed areas to re-establish vegetation.

Lake One Area

• grading the surface to support placement of the final cover and provide drainage;

• covering the site with 24 inches of suitable cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

Hurley Operation Area

• cover the site with a maximum of 36 inches of suitable soil,

• grading the surface to 0.5 percent or greater;

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• creating side interbench slopes at an angle of 3H:1V; and

• constructing drainage channels to control erosion and manage runoff.

7.1.8 DP-484: Tailing Pond 7 Area

Mining Facilities to be Closed

Mining facilities to be closed at the DP-484 area include (Figure 7-7):

• Tailing Pond 7;

• the tailing termination tower;

• pipelines for tailing slurry and groundwater; and

• auxiliary structures and equipment (buildings and crane-mounted cyclones).

Tailing Pond 7 has a footprint (horizontal projection) of 1,560 acres. The auxiliary structures in the

DP-484 area will be removed and salvaged upon closure.

Existing Closure Components

• operation of the Tailing Pond 7 Interceptor Well System;

• operation of the Tailing Pond 7 seepage collection sump;

• Whitewater Creek diversion; and

• dust cover capping program for the Tailing Pond 7 outslopes.

Planned Closure/Closeout Activities

• removing remaining debris and solid waste, and disposal in an approved manner;

• flushing pipelines, active at the time of closure, that do not have a post-closure purpose with water to remove accumulated sediment in accordance with Condition 29 of DP-1340;

• flushing pipelines, active at the time of closure, that do not have a post-closure purpose with water to remove accumulated sediment in accordance with Condition 29 of DP-1340;

• grading the tailing surfaces as necessary to support placement of the cover and provide appropriate drainage;

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• grading outslopes to remove erosion channels;

• regrading tailing outslopes to an interbench angle no steeper than 3H:1V;

• covering top surfaces and outslopes with 24 inches of suitable cover material (slopes that already meet this requirement will not regraded);

• grading top surfaces to between 0.5 and 5 percent to convey stormwater to spillways and channels;

• covering the disturbed area, including slurry pipelines, associated with the tailing impoundments with 24 inches of suitable cover material;

• constructing spillways and downchutes as necessary to direct excess water off of the tailing impoundment surfaces; and

• seeding covered and disturbed areas to re-establish vegetation.

Additional closure/closeout activities planned for the DP-484 area consist of:

• demolishing and burying the tailing termination tower; and

• removing the crane-mounted tailing slurry cyclones and the tailing area maintenance facility.

7.2 Additional Mining Facilities not Considered in Other Sections

The Mine Maintenance Facilities, Groundhog Mine Area, and SMA Cover Borrow Pit are not

regulated by a specific DP, except where required by DP-1340 or the MMD Permit. The

closure/closeout activities for these facilities are discussed in the following paragraphs.

7.2.1 Mine Maintenance Facilities

Figure 7-8 illustrates the CCP components within the Mine Maintenance Facilities Area. The Mine

Maintenance Facilities Area is one of the proposed industrial PMLU areas and covers approximately

80 acres.

Mining Facilities to be Closed

• auxiliary structures in the Mine Maintenance Facilities Area not designated for post-closure use will be removed and salvaged upon closure.

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Existing Closure Components

• stormwater runoff diversions from paved areas to existing sediment/stormwater control impoundments.

Planned Closure/Closeout Activities

• demolishing structures and facilities including the Wash Shop rack and concrete pad, Maintenance Shop, storage lean-to, storage shed, Primary Crusher, Wash Shop wastewater sump, and Shop Fast fuel hoses and pumps;

• removing all debris and visually affected soil at or near the surface in unpaved areas;

• disposing of debris or affected soil in an approved manner;

• collecting confirmation samples from areas where soils were removed;

• reclaiming the large truck wash rack area with clean soil;

• covering unpaved areas with 24 inches of suitable cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

7.2.2 Groundhog Mine Stockpile Area

Reclamation and remediation of the Groundhog Mine Stockpile Area is ongoing and being addressed

under the AOC as well as the NMMA. An interim remedial action (IRA) plan was submitted to

NMED on April 28, 2003 and approved by NMED November 18, 2003 with concurrence from

MMD. The IRA included all stockpiles associated with the Groundhog Mine, except for Groundhog

No. 5 Stockpile (Section 7.2.3). The IRA included removal of stockpile materials, soil cover and

revegetation on areas excavated to bedrock, removal of building foundation materials adjacent to the

stockpiles, closure of mine shafts, diversion of stormwater run-on, and containment of impacted

stormwater. Figure 7-9 shows the closure/close-out activities within the Groundhog Mine Stockpile

Area.

Completed Closure Components:

• constructed stormwater diversion channels;.

• drainfield installed at the headwall to contain shallow seepage from the stockpiles;

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• seepage and runoff collected at the headwall are pumped to Dam 17;

• stockpile material and foundations removed; and

• impacted stormwater pumped from a containment pond and a headwall sump to Dam 17.

Planned Closure/Closeout Activities:

• seeding covered and disturbed areas to re-establish vegetation;

• evaluating, plugging, and abandoning the mine openings;

• constructing additional surface water channels to divert unimpacted stormwater run-on, around and over reclaimed areas; and

• containing surface water by the headwall structure and pump to Dam 17 until vegetation has stablized and runoff meets requirements of the NPDES Permit.

7.2.3 Groundhog No. 5 Stockpile Reclamation

The Addendum to Proposal for Financial Assurance, Section 4 dated September 23, 2003 and

Condition 8.P of the MMD Permit identifies an accelerated reclamation schedule for the Groundhog

No. 5 Stockpile. The Groundhog No. 5 site has been investigated (Golder, 2001, 2005b and 2007e)

and is being reclaimed consistent with a long-term strategy for closure/closeout of the Chino and the

standards prescribed in the AOC agreement and the NMMA Rules. Figure 7-9 shows the

closure/close-out activities within the Groundhog No. 5 Stockpile.

An Interim Remedial Action (IRA) plan (Engineers Inc., 2005) was prepared pursuant to the

requirements for an IRA under the AOC to meet the standards for existing mines under the NMMA

Rules. The IRA consisted of regrading the stockpile, removing structures, covering the mine shaft

opening and constructing drainage controls.

Completed Closure Components:

• head frame and other structures removed; and

• stockpile regraded.

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Planned Closure/Closeout Activities:

• covering stockpile with soil cover from local borrow area;

• seeding covered and disturbed areas to re-establish vegetation; and

• upgrading riprap-lined surface water channels and settling ponds to route stormwater flows to toe of stockpile.

Further progress on the closure of the stockpile is waiting on the submittal of a draft supplemental

characterization investigation of the regraded stockpile, with results indicating the stockpile materials

are not acid generating and do not leach contaminants above WQCC criteria. The draft results

conclude that this stockpile is not a source of contaminants to surface water or groundwater.

In February 2006, Chino submitted a Construction Quality Assurance and Reclamation Completion

Plan (Telesto, 2006a) to MMD and NMED to fulfill the requirement listed in Permit Condition E.2.a.,

which includes a new cover design. Reclamation of the stockpile is pending a Record of Decision for

the Hanover/Whitewater Creek Investigation Unit, which is a delineated as part of the AOC.

7.2.4 South Mine Area Cover Material Borrow Pit

Mining Facilities to be Closed

• borrow pit for cover material located outside current DP areas (Figure 7-6).

Existing Closure Components

• There are no existing closure components in the area of the proposed borrow pit that have not been identified in specific operational DP areas.

Planned Closure/Closeout Activities

• grading of sources used as borrow for cover;

• installing stormwater controls with slopes not steeper than 3H:1V;

• ripping the pit bottoms and slopes to depths of 24 inches;.

• seeding covered and disturbed areas to re-establish vegetation; and

• if practical, incorporate the borrow pit into the post-closure water management system.

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7.2.5 East Mine Pit Access Road

Mining Facilities to be Closed

• the portion(s) of the access road between the Santa Rita and South Pit east and southeast of the Santa Rita Pit outside the OPCZ (Figure 7-3).

Existing Closure Components

• the portion of the access road area outside the OPCZ.

Planned Closure/Closeout Activities

• ripping the road to depth of 24 inches;

• grading for stormwater control;

• covering with 24 inches of suitable cover material; and

• seeding covered and disturbed areas to re-establish vegetation.

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8.0 CAPITAL AND OPERATION AND MAINTENANCE COST ESTIMATES

This section provides a brief description of the capital cost estimate portion of the financial assurance.

Cost estimates are budgetary and for the purpose of determining the value of the financial assurance

performance bond.

8.1 Capital Cost Estimates

The cost estimate has been prepared in accordance with standard engineering practice and is

supported with data from various references (Appendices C and D). The capital costs for closure are

summarized as follows:

CAPITAL COST SUMMARY

Item Amount Total Earthwork Tailing Impoundments $50,261,000

Stockpiles $114,959,000 Santa Rita Open Pit $1,691,000 Reservoirs $1,153,000 Other Disturbed Areas $6,546,000 Abandon exploration holes and perimeter fencing $1,700,000

Earthwork Subtotal $176,311,000

Water Treatment

NMA Water Treatment Facility $9,829,000

Evaporative Treatment System $6,036,000

Lake One Water Treatment Facility $723,000

Effluent Commingling System $4,119,000

Water Collection and Conveyance $1,923,000

Sludge Disposal Facility $1,438,000

Water Treatment Subtotal $24,068,000

TOTAL CAPITAL COST $200,379,000

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8.2 Basis of Capital Cost Estimates

Capital cost estimate details for earthwork, including quantity takeoffs, calculations, and supporting

documentation are provided in Appendix C. The capital costs associated with water management and

treatment are provided in Appendix D.

8.3 Operation and Maintenance Cost Estimates

The Operation and Maintenance (O&M) cost estimate details and supporting documentation are

provided for earthwork in Appendix C and water treatment in Appendix D.

8.3.1 Earthwork

O&M costs are allocated over time periods of years 1 to 20, years 21 to 40, and years 41 to 100 as the

requirements for O&M change as follows:

• Years 1 to 20: erosion control will be will be required 30 days per year with monthly road maintenance.

• Years 21 to 40: erosion control work will be reduced to 24 days per year with bi-monthly road maintenance.

• Years 41 to 100: erosion control will be required 13 days per year with quarterly road maintenance.

Annual O&M costs (current year dollars) for closure are summarized as follows:

Earthwork Annual O&M Cost Summary

Period (years) Wildlife

Monitoring Road Maintenance Erosion Control Total

(Current Year $) 1 to 20 $5,000 $158,740 $160,530 $9,053,637

21 to 40 $5,000 $79,370 $128,424 $5,941,220

41 to 100 $5,000 $39,685 $80,265 $10,465,832

8.3.2 Water Treatment

Annual O&M costs are allocated over time periods of years 1 to 5, years 6 to 10, 11 to 15, 16 to 25,

26 to 32, 33 to 40, and 41 to 100 as the requirements for O&M change. Annual O&M cost for the

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Lake One Lime/HDS Plant, Commingling System and Water Collection/Conveyance are assumed to

remain constant throughout the O&M life. Annual O&M estimated costs for out-year steps and sum

total (100-year) O&M are summarized below. Annual O&M costs for operation of the ETS are

included for years 1 to 5 only. The ETS will be shut down when process solutions are eliminated,

projected to occur at year 5. The O&M of the water treatment plant includes cost for labor,

equipment replacement, utilities, chemical reagents, and testing and are included in Appendix D.

Estimate of Annual Operating Cost in Out-Year Steps

Year

NMA Lime/HDS

Plant

Evaporative Treatment

System

Lake One Lime/HDS

Plant Commingling

System

Water Collection / Conveyance

Sludge Disposal

Annual Total

1 $2,083,000 $709,200 $132,000 $223,200 $129,000 $130,000 $3,406,4005 3,605,000 250,400 132,000 223,200 129,000 296,000 4,635,600

10 3,588,000 132,000 223,200 129,000 294,000 4,366,20015 3,110,000 132,000 223,200 129,000 246,000 3,758,20025 2,339,000 132,000 223,200 129,000 164,000 2,987,20032 1,860,000 132,000 223,200 129,000 112,000 2,456,20040 1,600,000 132,000 223,200 129,000 84,000 2,168,200

Estimate of Total Operating Costs

Period (years)

NMA Lime/HDS

Plant

Evaporative Treatment

System

Lake One Lime/HDS

Plant Commingling

System

Water Collection / Conveyance

Sludge Disposal Total

1 to 5 $10,415,000 $1,711,000 $660,000 $1,116,000 $645,000 $650,000 $15,197,0006 to 10 18,025,000 - 660,000 1,116,000 645,000 1,480,000 21,926,00011 to 15 17,940,000 - 660,000 1,116,000 645,000 1,470,000 21,831,00016 to 25 31,100,000 - 1,320,000 2,232,000 1,290,000 2,460,000 38,402,00026 to 32 16,373,000 - 924,000 1,562,400 903,000 1,148,000 20,910,40033 to 40 14,880,000 - 1,056,000 1,785,600 1,032,000 896,000 19,649,60041to 100 96,000,000 - 7,920,000 13,392,000 7,740,000 5,040,000 130,092,000TOTAL $204,733,000 $1,711,000 $13,200,000 $22,320,000 $12,900,000 $13,144,000 $268,008,000

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9.0 CLOSURE SCHEDULE

An update to the reclamation schedule is required pursuant to DP-1340 and MMD Permit. Table 9-1

presents the anticipated schedule for implementation of closure activities based on best available

information. The proposed schedule summarizes Chino’s understanding of the existing near-term

commitments and longer-term projections. More specifically, the schedule is based on the following

considerations

• ongoing projects and previous schedule commitments;

• practical phasing of the reclamation projects to account for water management, water treatment and the anticipated labor, equipment and other resources that would be necessary to complete these projects based on current conditions;

• sequential closure of facilities in a phased cost efficient manner (i.e., tailing impoundment closures as milling operations cease followed by waste rock pile closures as mining operations cease and finally closure of the leaching facilities following process water elimination); and

• the total annual acreages that would be reclaimed over this period.

Ultimately, Chino reserves the right to modify the proposed reclamation schedule to respond to

unforeseen changes in mine operations and advancements in reclamation practices.

For clarity, the financial assurance cost estimate and the proposed reclamation schedule are explicitly

linked. Chino expects that the planned closure of the facilities represented by the proposed schedule

will be conducted in a more cost efficient manner than that reflected in the financial assurance cost

estimate, which is predicated on the unlikely condition of forfeiture. As indicated earlier,

implementation of the mine for closure concepts is expected to result in more efficient reclamation

than might be considered in a forfeiture scenario.

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10.0 USE OF THIS REPORT

Golder has compiled this Closure/Closeout Plan (CCP) to present Chino’s 5-year update of the CCP

to the New Mexico Environment Department (NMED) and the Mining and Minerals Division

(MMD) of the New Mexico Energy, Minerals, and Natural Resources Department. The Chino CCP

was updated to fulfill the applicable requirements of the following two permits:

• Supplemental Discharge Plan DP-1340 (DP-1340), issued by the NMED on February 24, 2003 (NMED, 2003); and

• Revision 01-1 to Permit GR009RE (MMD Permit), issued by the MMD of the New Mexico Energy, Minerals and Natural Resources Department on December 18, 2003 (MMD, 2003).

Please contact the undersigned with any questions or comments on the information contained in this

report.

Respectfully submitted, GOLDER ASSOCIATES INC. Robert Newcomer Brent R. Bronson, P.E. Project Manager Project Director Associate Principal

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11.0 REFERENCES

Chino Mines Company (Chino), 2003. Contingency Plan for Chino Mines Closure Components and Emergency Response Plan for Surface Impoundments. October 21, 2003.

Chino, 2004a. Emergency Response and Contingency Plan. Revised. April 2004.

Chino, 2004b. Chino Mines Company -P-1340, Condition 85, Detailed Sludge Handling Plan Study, Annual Progress Report. February 24, 2004.

Chino, 2004c. Chino Mines Company - DP-1340, Condition 85, Detailed Sludge Handling Plan Study, Task 3. April 23, 2004.

Chino, 2005. Chino Closure/Closeout Update, Chino Mine, New Mexico. February 2005.

Dames & Moore, 1983. Ground water monitoring study, Chino Mill near Hurley, New Mexico. Prepared for Kennecott Minerals Company. Dames & Moore Job No. 1375-042-06. Salt Lake City, Utah. January 19, 1983.

DBS&A, 1997. Phase 1 Investigation – Chino Mines Company – Older Tailing Source Areas. June 12, 1997.

DBS&A, 1998. Borrow Materials Investigation and Soil Suitability Assessment. Prepared for Chino Mines Company, Hurley, New Mexico.

DBS&A, 1999a. Preliminary Open Pit and Stockpile Waiver Justification, Santa Rita Open Pit – Task 2: Evaluation of Measures to Meet Applicable Regulations and Standards. January 31, 1999.

DBS&A, 1999b. Cover Design Study Status Report, Chino Mine. Prepared for Chino Mines Company, Hurley, New Mexico.

DBS&A, 2000. Comprehensive vegetation survey of the Chino Mine, Grant County, New Mexico. Prepared for Chino Mines Company. June 5, 2000.

Engineers Inc., 2005. Interim Remedial Action Groundhog No. 5 Stockpile and Shaft Closure Plan Hanover and Whitewater Creeks Investigation Unit. January 18, 2005.

EnviroGroup Limited, 2006. Supplemental Leach Ore Stockpile and Waste Rock Stockpile Mass Loading Study, Final Report for DP-1340, Condition 84, Chino Mine. May 31, 2006.

Gary Van Riper Consulting (GVR). 2004. Preliminary Sludge Handling Plan and Cost Estimate DP-1341 Condition 86. Prepared for Phelps Dodge Tyrone, Inc. October 22, 2004.

Golder Associates Inc. (Golder), 1998a. Waste Rock Characterization – Chino Mine. Prepared for Chino Mines Company, Hurley, New Mexico.

Golder, 1998b. An Assessment of Wildlife Communities in the Chino Mine Proposed Action Area.

Golder, 1999a. Comprehensive Groundwater Characterization Study – Phase 3 Report, Volumes 1 & 2 – Chino Mines Company. January 1999.

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Golder, 1999b. Stockpile Characterization – Chino Mines Company. May 25, 1999.

Golder, 2001. Interim Remedial Action, Groundhog Mine Stockpile, Site Investigation Report, Hanover and Whitewater Creek Investigation Units. Prepared for Chino Mines Company, Hurley, New Mexico.

Golder, 2003. Lake One Field Investigation Work Plan. Prepared for Chino Mines Company. May 1, 2003.

Golder, 2004a. Lake One Area Closure Plan, Characterization Study and Closure Alternatives Analysis. February 19, 2004.

Golder, 2004b. Chino Mines – Site-wide Stage 1 Abatement Plan. April 22, 2004.

Golder, 2004c. Wildlife Monitoring Plan for Post Closure of the Chino Mine. December 29, 2004.

Golder, 2005a. Technical Memorandum. Geochemical Testing of Chino Slag Samples. October 13, 2005.

Golder 2005b. Interim Remedial Action, Groundhog No. 5 Stockpile, Site Investigation Report, Hanover and Whitewater Creek Investigation Units. Prepared for Chino Mines Company, Hurley, New Mexico.

Golder, 2006a. Chino Mines Company–Site-wide Stage 1 Abatement Interim Report. September 15, 2006.

Golder, 2006b. Report on North Mine Area Groundwater Flow Model: Chino Mine, New Mexico. January 13, 2005

Golder, 2006c. Supplemental Materials Characterization Upper South Stockpile DP-1340 Condition 81. April 27, 2006.

Golder, 2006d. Technical Memorandum. Phase 2 Geochemical Testing of Chino Slag Samples. October 6, 2006.

Golder, 2007a. Chino Mines Company, DP-1340 Condition 83 – Hydrologic Study, Final Report. June 2007.

Golder, 2007b. Preliminary Draft, Supplemental Stability Analysis of Waste Rock Piles and Leach Ore Stockpiles, Final Report for DP-1340, Condition 80, Chino Mine. April, 2007.

Golder, 2007c. DP-1340 Condition 93 Feasibility Study. February, 2007.

Golder, 2007d Report on Long-term Quality and Quantity Estimates, Chino Mines Water Treatment Feasibility Study.

Golder, 2007e. Interim Remedial Action Groundhog No. 5 Stockpile Site Investigation Report Addendum, Hanover and Whitewater Creeks Investigation Units. Prepared for Chino Mines Company.

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Golder-URS, 2007. Construction Design Quality Assurance Plan, Chino Tailing Reclamation, Chino Mine. January 12, 2007.

Grossman, D.H., D. Faber-Langendoen, A.W. Weakley, M. Anderson, P. Bourgeron, R. Crawford, K. Goodin, S. Landaal, K. Metzler, K.D. Patterson, M. Pyne, M. Reid, and L. Sneddon. 1998. International classification of ecological communities: Terrestrial vegetation of the United States. Volume I. The National Vegetation Classification System: Development, status, and applications. The Nature Conservancy, Arlington, Virginia.

John Shomaker & Associates, Inc. (JSAI), 2006. Report on Water Treatment Sustainabiliyt, Chino Mines Company, DP-1340, Condition 86. February 2006.

M3 Engineering and Technology Corporation (M3), 2001. End of Year 2001 through Year 2006 Closure/Closeout Plan, Chino Mines. March 17, 2001.

M3, 2004a. Reservoir and Impoundment Study for Chino Mines Company. Prepared for Chino Mines Co., March 2004.

M3, 2004b. Process Solution Elimination Study. Prepared for Chino Mines Co., June 2004.

Mining and Minerals Division (MMD) of the New Mexico Energy, Minerals, and Natural Resources Department, 1996. Closeout Plan Guidelines for Existing Mines. MMDMining Act Reclamation Bureau, Santa Fe, New Mexico. April 30, 1996.

MMD, 2003. Permit revision 01-1 to Permit No. GR009RE Chino Mine Existing Mining Operation. Issued December 18, 2003.

New Mexico Environment Department (NMED), 2003. Supplemental Discharge Permit for Closure, Chino Mines Company, DP-1340. Issued February 24, 2003.

Parnham, T.L., R.. Paetzold, and C.E. Souders. 1983. Soil Survey of Grant County, New Mexico, Central and Southern Parts. USDA-Soil Conservation Service, U.S. Gov. Print. Office Washington DC.

Rose, A.W. and W.W. Baltosser. 1966. The Porphyry Copper Deposit at Santa Rita, New Mexico. in Geology of the Porphyry Copper Deposits Southwestern North America edited by Titley, S.R. and C.L. Hicks. University of Arizona Press, Tucson, Arizona. p. 205-220.

Telesto Solutions, Inc. (Telesto), 2006a. Groundhog No. 5 Stockpile Construction Quality Assurance and Reclamation Completion Plan. February 2006.

Telesto, 2006b. Hydrocarbon Landfill Closure Report, Tailings Pond 1. February 2006.

Tetra Tech EM Inc. (Tetra Tech), 2003a. Comprehensive Cover Performance Evaluation, DP-1340 Condition 81 Work Plan. October 23, 2003.

Tetra Tech, 2003b. Cover, Erosion, and Revegetation Test Plot Study, DP-1340 Condition 82 Work Plan. October 23, 2003.

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TABLES

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FIGURES

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APPENDIX A

RECLAMATION DRAWINGS

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APPENDIX B

FACILITY CHARACTERISTIC FORMS

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APPENDIX C

EARTHWORK COST BASIS AND ESTIMATE

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APPENDIX D

WATER TREATMENT COST BASIS AND ESTIMATE


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