ATTACHMENT 5 Rosemont Area-Wide Fate and Transport and DIA Summary Tetra Tech August 31, 2010

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1 ATTACHMENT 5 Rosemont Area-Wide Fate and Transport and DIA Summary Tetra Tech August 31, 2010 F:\Rosemont APP\August 2010 Response Letter\Sept 7 Tetra Tech-revised Response Letters\Final ADEQ Response Letter version_fixed all.doc

2 Tucson Office 3031 West Ina Road Tucson, AZ Tel Fax Technical Memorandum To: Kathy Arnold From: David Krizek Company: Rosemont Copper Company Date: August 31, 2010 Re: CC: Rosemont Area-Wide Fate and Transport and DIA Summary M. Williamson, A. Hudson, M. Gabora, K. Thompson (Tetra Tech); G. O Brien (Engineering Analytics) Doc #: 243/ Introduction Tetra Tech prepared a regional groundwater model as summarized in a Technical Memorandum titled Rosemont Groundwater Flow Model Summary (Tetra Tech, 2010a). Modeling efforts indicate that a terminal pit lake will form in the Open Pit following the cessation of active dewatering operations. A particle tracking analysis was then performed to determine the capture zone of the pit. A capture zone that encompassed all of the mine facilities would ensure that any potential contaminants would flow into the pit lake and there would be no impact to the surrounding groundwater. The results of this particle tracking analysis are presented in Attachment A in a Technical Memorandum titled Rosemont Area-Wide Fate and Transport and DIA Assessment (Tetra Tech, 2010b). Particle tracking indicates that the majority of the Project facilities will be within the capture zone of the pit. A comparison of potential discharges from facilities outside the capture zone to local groundwater was made, indicating that the groundwater quality would not be affected. Therefore, area-wide fate and transport modeling was not required. The proposed extent of the DIA would then be coincident with the Pollutant Management Area (PMA). An assessment of potential seepage volumes and quality from APP-regulated facilities was prepared as part of this analysis. This information is provided for reference in Attachment B in a Technical Memorandum titled Potential Sources Volumes and Chemical Makeup for Area-Wide Fate and Transport Modeling Rosemont Copper Project (Tetra Tech, 2010c). This information is in response to the April 14, 2010 Comprehensive Request for Additional Information from the Arizona Department of Environmental Quality (ADEQ) to Rosemont Copper Company (Rosemont) as part of the APP application submitted to ADEQ in February 2009 (Tetra Tech, 2009). Specifically, this Technical Memorandum and attachments answer the following:

3 HYDROGEOLOGIC DEFICIENCIES Item no. 1 on pages 1 and 2 of 18. The application and supporting documents identify a number of reports that are either pending or completed, but do not appear to have been submitted for review. The following documents are necessary to continue the review of the application. They are identified by title, with the location if the reference indicated in parentheses: Fate and Transport Analysis (Application, Table 7.41) Item no. 8 on pages 3 and 4 of 18. Section 9.2 of the Application indicates that a quantitative groundwater flow model and fate and transport modeling are currently in progress. Section 1.0 of the application indicates that a detailed groundwater flow model, a pit lake geochemical model, and updated facility infiltration and seepage models will be submitted. Section 4.13 of the Application indicates that studies regarding quantities of groundwater withdrawal from the pit are also underway. Please submit the results of these studies and modeling efforts to address the following components of the hydrologic study required in rule. R18-9-A202(A)(8)(b)(x): Any changes in the water quality expected because of the discharge. R18-9-A202(A)(8)(b)(xii): A map of the facilities discharge impact area (Refinement of current delineation, as necessary). R18-9-A202(A)(8)(b)(xiii): The criteria and methodologies used to determine the discharge impact area. ENGINEERING DEFICIENCIES Item no. 20 on page 11 of 18. PW Pond Leak Detection System (p. 2-9) A fate and transport analysis is not required for the PWTS Pond because the facility has been designed to be non-discharging. Pursuant to A.R.S , PWTS will be treated as a discharging facility under the Aquifer Protection Program (APP). Therefore, please summit a fate and transport analysis for the facility. Item no. 23 on page 11 of 18. Settling Basin (p. 3-5) It is stated that a fate and transport analysis is not required for the Settling Basin because the facility will only be used on a temporary basis during process upset conditions. Pursuant to A.R.S , Settling Basin will be treated as a discharging facility under the Aquifer Protection Program (APP). Therefore, please submit a fate and transport analysis for the facility. 2

4 REFERENCES Tetra Tech (2009). Aquifer Protection Permit (APP) Application. Prepared for Rosemont Copper Company. Report Dated February Tetra Tech, Krizek, D. (2010a). Rosemont Groundwater Flow Model Summary. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum dated August 31, Tetra Tech, Thompson, K. (2010b). Rosemont Area-Wide Fate and Transport and DIA Assessment. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum dated August 31, Tetra Tech, Krizek, D. (2010c). Potential Source Volumes and Chemical Makeup for Area-Wide Fate and Transport Modeling Rosemont Copper Project. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum Dated August 23,

5 ATTACHMENT A TECHNICAL MEMORANDUM ROSEMONT AREA-WIDE FATE AND TRANSPORT AND DIA ASSESSMENT

6 Tucson Office 3031 West Ina Road Tucson, AZ Tel Fax Technical Memorandum To: Kathy Arnold From: Keith Thompson Company: Rosemont Copper Company Date: August 31, 2010 Re: CC: Rosemont Area-Wide Fate and Transport and DIA Assessment D. Krizek, M. Gabora, A. Hudson (Tetra Tech), G. O Brien (Engineering Analytics), M. Williamson (Geochemical Solutions) Doc#: 242/ INTRODUCTION The proposed Rosemont Copper Project (Project) is located on the east side of the Santa Rita Mountains, approximately 30 miles southeast of Tucson, Arizona in Pima County. The Arizona Department of Environmental Quality (ADEQ) requires that a Discharge Impact Area (DIA) analysis be included as part of their Aquifer Protection Permit (APP) application for the Project. Delineation of a DIA is required if mining operations are determined to have the potential for increasing the concentration(s) of groundwater quality constituents above background conditions. The Arizona Revised Statutes (A.R.S ) define discharge impact area as the potential areal extent of pollutant migration, as projected on the land surface, as the result of a discharge from a facility. This Technical Memorandum documents the results of the DIA analysis, which was based on Tetra Tech s regional groundwater flow models (Tetra Tech, 2010c, 2010d, 2010e). Tetra Tech s groundwater flow modeling team constructed regional groundwater flow models of the Rosemont Copper Project (Project) area to assess the potential impacts to water resources resulting from the Project. The regional finite-difference models cover an area of 475 square miles and consist of a grid of 205 rows by 169 columns by 20 layers. The regional models represent pre-mining steady state conditions, active mining conditions, and post-closure conditions. Documentation of the construction and calibration of these models and results of the predictive simulations of the mining and post-closure phases are provided in Tetra Tech (2010c, 2010d, 2010e). 2.0 ANALYSIS APPROACH A step-wise approach was undertaken for analyzing and defining the DIA. The capture zone of the pit was determined by using particle-tracking simulations. A capture zone that encompassed all of the mine facilities would ensure that any potential contaminants would flow into the pit lake and there would be no impact to the surrounding groundwater. However, if the capture zone did not encompass all of the mine facilities, there would be the potential for groundwater from beneath the facilities to flow down-gradient. Comparison of the chemical quality of mine-induced recharge water and background groundwater was necessary to determine whether the potential for impacting down-gradient groundwater quality existed. If there was the potential to negatively 1

7 impact down-gradient groundwater quality, fate and transport modeling would be used to predict the impacted area. 3.0 HYDROGEOLOGIC CONDITIONS Dewatering of the open pit mine will lower groundwater levels in the pit area. When pit dewatering is discontinued after the 22 years of active mining, the pit will naturally refill with groundwater, surface-water runoff, and precipitation, and a lake will form within the pit. High evaporation rates will create a terminal hydraulic sink, and surrounding groundwater will continually flow into the pit lake. A groundwater divide will form due to the pit lake level being lower than the surrounding water table. A capture zone will be created with groundwater inside the capture zone flowing into the pit and groundwater outside the capture zone flowing past or away from the pit. Mine operations will locally alter recharge to the groundwater system. The pre-mining recharge from precipitation in the waste rock and dry-stack tailings areas will be replaced by water that drains from the tailings following their placement (AMEC, 2009; Tetra Tech, 2010a) and infiltration in flow-through drains (Tetra Tech, 2010b). Upstream runoff will be channeled beneath the waste rock and tailings in a system of flow-through drains or detained in ponds adjacent to the upstream side of the waste rock area (Tetra Tech, 2010b). Other potential smaller-volume, mining-related recharge sources are described more completely in a Technical Memorandum titled Potential Source Volumes and Chemical Makeup for Area-Wide Fate and Transport Modeling Rosemont Copper Project (Tetra Tech, 2010f). The potential sources with flow rates greater than zero are listed in Table 1 and shown on Figure 1. Table 1. Potential Mining-Related Sources of Groundwater Recharge Source Name Dry Stack Tailings Facility Flow-Through Drains Process Water Temporary Storage Pond Primary Settling Basin Raffinate Pond PLS Pond Heap Leach Pad (Phase 1) Heap Leach Pad (Phase 2) Pond PCA-2 Latitude (UTM NAD 83 Northing - ft) 31 50' 18.52" (11,556,944.78) 31 50' 18.52" (11,556,944.78) 31 50' 9.80" (11,556,056.78) 31 50' 23.78" (11,557,468.36) 31 50' 15.09" (11,556,589.72) 31 49' 32.20" (11,552,261.31) 31 49' 23.93" (11,551,418.85) 31 49' 23.93" (11,551,418.85) 31 48' " (11,546,700) ac-ft/yr = acre-feet per year Longitude (UTM NAD 83 Easting - ft) ' 51.40" (1,723,940.74) ' 51.40" (1,723,940.74) ' 27.39" (1,720,839.83) ' 28.51" (1,720,739.47) ' 35.99" (1,720,096.29) ' 12.44" (1,722,137.55) ' 48.37" (1,719,041.03) ' 48.37" (1,719,041.03) ' " (1,716,700) Period of Recharge (Years) Water Source Draindown Starting year 1, permanent Runoff Infiltration Rate ac-ft/yr maximum ac-ft/yr 1 10 Leakage ac-ft/yr 1 22 Leakage ac-ft/yr 1 10 Leakage ac-ft/yr 1 10 Leakage ac-ft/yr 1 10 Leakage ac-ft/yr Draindown Starting year 1, permanent Runoff Infiltration ac-ft/yr maximum ac-ft/yr 2

8 The chemical quality of water from the mine-related groundwater recharge sources may be different from that of the pre-mining recharge and the background groundwater quality. A determination of whether the recharge from these sources would be captured by the pit or flow away from the Project area, and potentially impact groundwater quality in the adjacent area, was necessary. Tetra Tech developed particle-tracking simulations from the regional groundwater flow models to assess the potential for recharge from the mining-related recharge sources to flow down-gradient. 4.0 PARTICLE-TRACKING SIMULATIONS Particle tracking was used to determine the extent of the pit-lake capture zone and whether mine-induced recharge is predicted to flow away from the pit lake and down gradient from the Project area. Particle-tracking was completed on the mining phase and post-closure phase groundwater flow models. The flow models, as described in greater detail in the Technical Memorandum titled Groundwater Flow Model Construction and Calibration (Tetra Tech, 2010d), used the MODFLOW-SURFACT code and various MODFLOW packages to simulate pit dewatering during the mining phase and the interaction between the pit lake and the groundwater system in the post-closure phase. The flow models simulated the Project-related alterations to groundwater recharge in the Project area, incorporating the recharge from the drystack tailings drain down and infiltration from the flow-through drain system. Pre-mining recharge due to precipitation and runoff in the dry-stack tailings and waste rock storage areas was removed in the post-closure model. For the particle-tracking application discussed in this Technical Memorandum, the MODPATH code (Pollock, 1994) as modified by HydroGeoLogic (2010) to be compatible with MODFLOW- SURFACT was used for this analysis. MODPATH uses the output from MODFLOW-SURFACT to compute three-dimensional flow paths for imaginary particles of water moving through the simulated groundwater flow system. The cell-by-cell flows computed in MODFLOW-SURFACT during each time step of the model are used in MODPATH to calculate the movement of the particles within and between the finite-difference model grid cells for each time step of the simulation. The MODPATH output shows the pathlines followed by each particle throughout the simulation. 4.1 Particle-Tracking Model Input Parameters The aquifer property input parameters, starting heads, hydraulic stresses and model stress periods used in the MODPATH-SURFACT simulations were unchanged from those used in the MODFLOW-SURFACT models. MODPATH-SURFACT is simply a particle-tracking application that uses the output from MODFLOW-SURFACT as its input. The selection and application of those parameters were described in detail in Tetra Tech technical memoranda (Tetra Tech, 2010c, 2010d). The particle tracking model requires one additional aquifer property, effective porosity, which was not necessary in the other model simulations. Effective porosity affects the groundwater velocity and therefore the travel times of contaminants within the aquifer, but it does not affect the paths traveled by the contaminants. Effective porosities of the lithologies present within the model domain typically range from less than one (1) percent to a few percent for limestone and some metamorphic rocks, to as much as 40 percent for unconsolidated sediments (Walton, 1988; Weight and Sonderegger, 2001). An effective porosity of 0.01 (1 percent) was assigned as representative of the hydrogeologic units in the model. This relatively low effective porosity results in higher groundwater velocities and thus places an upper bound on calculated groundwater travel distances for the 1,000-year simulation period. 3

9 4.2 Particle Starting Locations The starting locations and starting times for each particle are provided as input to MODPATH- SURFACT. For this modeling task, it was necessary to track the particle paths through both the mining phase and the post-closure phase. The initial particle starting locations were specified for the mining-phase model, and their final locations at the end of the mining phase were imported as the post-closure phase starting particle locations. The starting locations for the 61 particles assigned to the mining-phase model are listed in Table 2. Particle No. Model Layer UTM Northing (ft) Table 2. Particle Starting Locations UTM Easting (ft) Particle No. Model Layer UTM Northing (ft) UTM Easting (ft) ,546,713 1,716, ,557,152 1,721, ,549,877 1,716, ,557,352 1,722, ,549,500 1,716, ,557,552 1,722, ,549,123 1,717, ,557,752 1,723, ,548,746 1,718, ,557,951 1,724, ,548,369 1,719, ,558,151 1,724, ,547,992 1,720, ,558,351 1,725, ,547,615 1,720, ,558,551 1,725, ,547,238 1,721, ,558,751 1,726, ,546,861 1,722, ,558,951 1,726, ,546,484 1,723, ,559,157 1,720, ,554,016 1,719, ,559,302 1,721, ,553,813 1,720, ,559,448 1,721, ,553,610 1,720, ,559,594 1,722, ,553,407 1,721, ,559,739 1,723, ,553,204 1,721, ,559,885 1,723, ,553,002 1,722, ,560,031 1,724, ,552,799 1,722, ,560,176 1,724, ,552,596 1,723, ,560,322 1,725, ,552,393 1,723, ,560,468 1,725, ,552,190 1,724, ,550,314 1,721, ,555,764 1,721, ,550,177 1,721, ,555,572 1,721, ,550,040 1,722, ,555,381 1,722, ,549,903 1,722, ,555,189 1,722, ,549,765 1,722, ,554,998 1,723, ,549,628 1,723, ,554,807 1,724, ,549,491 1,723, ,554,615 1,724, ,549,354 1,723, ,554,424 1,725, ,549,217 1,724, ,554,233 1,725, ,549,080 1,724, ,554,041 1,726, The particles in the mining-phase simulation were placed in lines forming cross sections through the waste rock and dry-stack tailings areas, where the potential recharge sources will be located. Due to open pit dewatering, the water table dropped below some model cells, which caused the cells to become inactive for the remainder of the particle-tracking simulation. Particles were therefore placed vertically in the uppermost cells that remained active throughout the simulations, either at the water table or at the top of the uppermost model layer that 4

10 remained at least partially saturated throughout the mining-phase simulation. This resulted in some particles being placed below the initial, pre-mining water table, which was necessary to allow tracking of the movement of those particles throughout the simulation. 4.3 Particle Tracking Simulation Results Particle-tracking simulation results are illustrated on Figures 2 and 3, which show the combined particle tracks for the mining and post-closure phases on a local scale (Figure 2) and a regional scale (Figure 3). Figure 2 includes the locations of the various Project-related recharge sources listed in Table 1 and shows the boundary of the mine pit s groundwater capture zone in the area that includes the Project-related recharge sources. The capture zone exists on all sides of the open pit, but only the part of the capture zone on the down-gradient side of the open pit, where the potential Project-related recharge sources will be located, is relevant to this analysis. The particle tracks and capture zone boundary were used to differentiate the Project-related recharge sources lying within the capture zone from those outside the capture zone. Recharge originating from sources within the capture zone will flow into the mine pit or the post-closure pit lake and therefore will not have the potential to impact groundwater quality outside the capture zone. Conversely, water originating from sources outside the capture zone ultimately will flow into areas beyond the Project site, and therefore may have the potential to affect groundwater quality beyond the Project site. The pit capture zone includes all of the Project-related recharge sources except for portions of the dry-stack tailings area and portions of the flow-through drain system (Figure 2). The Process Water Temporary Storage (PWTS) Pond, Primary Settling Basin, Raffinate Pond, PLS Pond, Pond PCA-2, and Heap Leach Pad are completely contained within the pit capture zone, and any water from those facilities will flow into the mine pit or pit lake. Therefore, only the portions of the dry-stack tailings area and the flow-through drain system lying outside the pit capture zone have the potential to affect the down-gradient groundwater quality. Recharge entering the groundwater system from the Project facilities outside the pit capture zone travels generally to the north and northwest down-gradient of the Project area (Figure 3). Variations in aquifer properties and hydraulic gradients north of the Project area result in a slight spreading of the particle tracks. 5.0 GROUNDWATER QUALITY EVALUATION The particle-tracking simulation results indicated that groundwater beneath portions of the drystack tailings is expected to migrate off site. It is therefore necessary to determine background groundwater quality so that it can be used as a basis for determining whether the potential exists for the Project-related recharge sources to impact down-gradient groundwater quality. If the recharge sources are predicted to increase the concentration(s) of groundwater quality constituents above the background concentrations, delineation of a DIA is required. 5.1 Background Groundwater Quality Groundwater samples collected within and immediately adjacent to the particle tracks area outside of the pit capture zone were evaluated to determine the background groundwater quality in that area. Data were available for 50 water-quality analyses of groundwater samples collected from 11 wells and one spring in that area (Errol L. Montgomery & Associates, 2009). The locations of the wells and spring are shown on Figure 4, and a summary of the analytical data is 5

11 presented in Table 3. Data from the wells and spring within and immediately adjacent to the particle tracks area outside of the pit capture zone were included because those data best represent the background groundwater quality in the potentially-affected area. Groundwater quality varies over the Project area and over the groundwater flow model domain. A statistical evaluation of the water-quality data within the predicted flow paths provides a representation of the natural variability. Understanding the natural water-quality variability forms a basis for subsequent evaluation of potential impacts. The standard deviation provides a measure of background water quality variability. The mean and the 95 percent upper confidence limit (95% UCL) on the mean provide measures of the central tendency or representative water quality and therefore are appropriate to use for comparison of background and recharge source water qualities. Both the mean and 95% UCL will fall within the range of expected natural groundwater quality variability. Table 3. Summary of Background Groundwater Quality Data Parameter Maximum Minimum Mean Standard Deviation 95% Upper Confidence Limit Calcium, mg/l Magnesium, mg/l Sodium, mg/l Potassium, mg/l Bicarbonate, mg/l Carbonate, mg/l Total Alkalinity as CaCO 3, mg/l Chloride, mg/l Sulfate, mg/l Nitrate + Nitrite as Nitrogen, mg/l Fluoride, mg/l Hardness as CaCO 3, mg/l Total Dissolved Solids, mg/l ph (Lab), std. units Arsenic, mg/l Barium, mg/l Molybdenum, mg/l Selenium, mg/l mg/l = milligrams per liter Background groundwater quality was calculated using data for samples from wells G-35, HC-4A, HC-4B, HV-1, HV-2, P-899, RP-2A, RP-2B, RP-2C, RP-3A, RP-3B and Sycamore Spring. 6.0 FACILITIES AREA RECHARGE WATER QUALITY Groundwater system recharge within and immediately adjacent to the area of the particle tracks outside the pit capture zone will be a mixture of draindown water from the dry-stack tailings and water infiltrating from the flow-through drains outside the capture zone. The overall quality of the recharge will be proportionate to the quality of the individual sources and their respective rates. The drain-down rate from the entire dry-stack tailings will reach a maximum of ac-ft/yr during years 18 through 22 of mine operations (AMEC, 2009). Approximately 74 percent of the dry-stack tailings area is outside of the predicted capture zone, and the maximum recharge rate from that part of the dry-stack tailings area will be approximately ac-ft/yr (Table 4). After 6

12 mine closure, anticipated in year 22, the recharge rate will continually decrease until reaching zero in approximately 500 years. The average recharge rate due to infiltration from the flow-through drain system will total ac-ft/yr and will not change over time based on average annual precipitation (Tetra Tech, 2010a). Based on the lengths of the various drain segments outside the pit capture zone and the infiltration rates through those segments (Tetra Tech, 2010a), the infiltration rate from the portion of the flow-through drain system outside the capture zone will average ac-ft/yr. The predicted water quality for groundwater recharge from the dry-stack tailings draindown and flow-through drain system infiltration (Tetra Tech, 2010f) is shown in Table 4 as the combined recharge from the tailings and drains. The parameter concentrations presented in Table 4 for the combined recharge from the tailings and drains are the maximum anticipated concentrations calculated using the maximum rate from the dry-stack tailings. Following year 22, as the drystack tailings draindown rate decreases and comprises less of the total recharge, the quality of the recharge from the tailings and drains will improve from that shown in Table 4. Table 4. Summary of Water Quality Data for Project-Related Sources and Background Groundwater Parameter Recharge from Dry-Stack Tailings Draindown Recharge from Flow-Through Drains Infiltration Combined Recharge from Tailings and Drains Background Groundwater Mean 95% UCL Rate, ac-ft/yr max max Calcium, mg/l Magnesium, mg/l Sodium, mg/l Potassium, mg/l Bicarbonate, mg/l Carbonate, mg/l Total Alkalinity as CaCO 3, mg/l Chloride, mg/l Sulfate, mg/l Nitrate + Nitrite as Nitrogen, mg/l Fluoride, mg/l Hardness as CaCO 3, mg/l Total Dissolved Solids, mg/l ph (Lab), std. units Arsenic, mg/l ND Barium, mg/l Molybdenum, mg/l ND Selenium, mg/l ND ac-ft/yr = acre-feet per year mg/l = milligrams per liter UCL = upper confidence limit ND = not detected For comparison, the mean and 95% UCL for the mean background groundwater quality are also shown in Table 4. The anticipated concentrations of magnesium, potassium, sulfate, fluoride, total dissolved solids, molybdenum and selenium (shown in bold in Table 4) in the dry-stack 7

13 tailings draindown water are greater than those in the background groundwater, but none of the concentrations in the water infiltrating from the flow-through drains exceeds the mean concentrations in the background groundwater. The good quality and much larger rate of recharge from the flow-through drains result in the anticipated quality of the combined recharge within the dry-stack tailings area outside the pit capture zone being better than the background groundwater quality for all analyzed parameters. 7.0 CONCLUSIONS The particle tracking model results show that pit dewatering during mining and evaporation from the pit lake that forms after mine closure will create a groundwater capture zone extending approximately ¾ to 1¼ miles east, northeast, and southeast of the margin of the open pit (Figure 2). The groundwater capture zone will include all of the Project-related recharge sources except for portions of the dry-stack tailings area and portions of the flow-through drain system. The groundwater within the capture zone will flow into the pit or pit lake. Therefore, the sources within the capture zone do not have the potential to impact down-gradient groundwater quality outside the Project area. The particle-tracking simulations show that groundwater originating from Project-related sources outside the capture zone will flow generally north and northwest beyond the Project area (Figures 2 and 3). Project-related recharge sources outside the pit capture zone have the potential to impact down-gradient groundwater quality. The anticipated quality of the combined recharge from the dry-stack tailings and flow-through drain system is better than the background groundwater quality for all analyzed parameters (Table 4). Consequently, the Project-related recharge sources are not predicted to impact the down-gradient groundwater quality. The DIA is therefore appropriately established coincident with the Pollutant Management Area. Since the down gradient water quality was not predicted to be altered due to the mine-related recharge, fate and transport modeling was not necessary for this DIA analysis. The overall conclusion of the particle-tracking simulations and water-quality evaluation is that no potential recharge sources related to the Project will negatively impact groundwater quality away from the facility boundary. 8

14 REFERENCES AMEC Earth & Environmental, Inc. (2009). Dry Stack Tailings Storage Facility, Final Design Report. Prepared for Rosemont Copper Company. Report dated April 15, Errol L. Montgomery & Associates (2009) Results of Phase 2 Hydrogeologic Investigation and Monitoring Program Rosemont Project, Pima County, Arizona. Report to Rosemont Copper Company. Report dated February 26, HydroGeoLogic, Inc. (2010). MODFLOW-SURFACT Software (Version 3.0). Herndon, Virginia, HydroGeoLogic, Inc. 548 pp. Pollock, D.W. (1994). User s Guide for MODPATH/MODPATH-PLOT, Version 3: A particle tracking post-processing package for MODFLOW, the U. S. Geological Survey finitedifference ground-water flow model. U. S. Geological Survey Open-File Report Tetra Tech (2010a). Infiltration, Seepage, Fate, and Transport Modeling Report Revision 1. Prepared for Rosemont Copper Company. Report Dated August Tetra Tech (2010b). Rosemont Infiltration Analysis (revised). Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum Dated April 5, Tetra Tech (2010c). Hydraulic Property Estimates. Prepared for Rosemont Copper Company. Technical Memorandum Dated July 9, 2010 Tetra Tech (2010d). Groundwater Flow Model Construction and Calibration. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum Dated July 26, Tetra Tech (2010e). Predictive Groundwater Flow Modeling Results. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum Dated July 30, Tetra Tech (2010f), Potential Source Volumes and Chemical Makeup for Area-Wide Fate and Transport Modeling Rosemont Copper Project. Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical Memorandum Dated August 23, Walton, W.C. (1988) Practical Aspects of Ground Water Modeling Third Edition. Worthington, Ohio: National Water Well Association. 587 pp. Weight, W.D. and J.L. Sonderegger (2001) Manual of Applied Field Hydrogeology. New Your: McGraw-Hill. 608 pp. 9

15 FIGURES

16 N2/N3 FLOW-THROUGH DRAINS N. Main N1 DRY-STACK TAILINGS S. Main S1 S1C S2 WASTE ROCK STORAGE AREA POND PCA-2 Path File Name.ppt P:and \ Figure 1 Source Locations.ppt STORMWATER POND PCA mile SCALE (Approx.) Project No February August Figure 1 Project-Related Potential Sources of Groundwater Recharge

17 FLOW-THROUGH DRAINS N2/N3 N1 N. Main DRY-STACK TAILINGS S1C S1 S. Main S2 Path P: and \ File Name - Figure.ppt 2 - Post-minng rechg_particle tracks + GW capture zone bndy - mine area.ppt STORMWATER POND PCA-2 0 Project No. SCALE (Approx.) mile WASTE ROCK STORAGE AREA Particle Track with Travel Times (years) 200 Boundary of Mine Pit Groundwater Capture Zone February August Figure 2 Post-Mining Particle Tracks and Open Pit Groundwater Capture Zone Boundary in Project Area

18 Path P: and \ File Name - Figure.ppt 3 - Post-minng rechg_particle tracks + GW capture zone bndy.ppt 0 1 mile SCALE (Approx.) Project No Quartz-Porphyry Dike (Flow Boundary) Particle Track with Travel Times (years) 200 Boundary of Mine Pit Groundwater Capture Zone February August Figure 3 Post-Mining Particle Tracks and Open Pit Groundwater Capture Zone Boundary

19 Path and File Name.ppt Project No. Dry-Stack Tailings and Waste Rock Facilities Particle Tracks Boundary Capture Zone Boundary Figure 4 Background Groundwater Quality Wells and Spring February 2007

20 ATTACHMENT B TECHNICAL MEMORANDUM POTENTIAL SOURCE VOLUMES AND CHEMICAL MAKEUP FOR AREA-WIDE FATE AND TRANSPORT MODELING ROSEMONT COPPER COMPANY

21 Tucson Office 3031 West Ina Road Tucson, AZ Tel Fax Technical Memorandum To: Kathy Arnold From: David Krizek Company: Rosemont Copper Company Date: August 23, 2010 Re: CC: Potential Source Volumes and Chemical Makeup for Area-Wide Fate and Transport Modeling Rosemont Copper Project M. Williamson, A. Hudson, M. Gabora, K. Thompson (Tetra Tech); G. O Brien (Engineering Analytics) Doc #: 226/ Introduction This Technical Memorandum provides estimated source volumes and chemical makeup for the following facilities for use, as needed, in the area-wide fate and transport modeling work associated with the Rosemont Copper Project (Project) in Pima County, Arizona: PW Pond (portion of the PWTS Pond) Settling Basin Raffinate Pond PLS Pond Heap Leach Pad Dry Stack Tailings Facility Waste Rock Storage Area Information is also provided herein, if needed, on static leach testing on the run-of-mine (ROM) drain rock materials anticipated for construction of the flow-through drains. 2.0 Facility Locations Except for the flow-through drains, Table 1 below lists the coordinates of the facilities listed in Section 1.0. Facility coordinates were based on the Technical Memorandum titled Rosemont APP-Regulated Facility Locations dated August 18, 2010 (Tetra Tech, 2010a). Table 1 shows

22 all the APP-regulated facilities associated with the Project. Facility locations are as of July Coordinates of the large facilities are at the approximate center of the facility. Figures 04B and 05B from the August 18, 2010 Technical Memorandum are provided in Attachment 1. Table 1 Updated Location of APP Regulated Facilities Facility Name Facility Type (A.R.S (B)) Latitude (UTM NAD 83 Northing - ft) Longitude (UTM NAD 83 Easting - ft) Cadastral T R S General Permit Facilities (not included in Area-wide APP) Coarse Ore Stockpile Intermediate Ore Stockpile 31 50' 24.91" (11,557,577.22) ' 56.31" (1,718,342.14) 18S 16E 30 Temporary Run-of- Mine (ROM) Ore Stockpiles Intermediate Ore Stockpile 31 49' 57.59" (11,554,817.82) ' 52.69" (1,718,660.91) 18S 16E 30 Sewage Treatment Facilities Septic Tanks and Leach Fields Various locations in Plant Site Various locations in Plant Site 18S 16E 30 Dry Stack Tailings Facilities Process Water Temporary Storage Pond (TS Pond) Primary Settling Basin Raffinate Pond Heap Leach Pad PLS Pond Stormwater Pond Open Pit Waste Rock Storage Area Waste Management Area Tailings Non- Stormwater Pond Non- Stormwater Pond Process Solution Pond Heap Leach Pad Process Solution Pond Non- Stormwater Pond Open Pit Mine Waste Rock Dump Solid Waste Facility Area-wide APP Facilities 31 50' 18.52" (11,556,944.78) 31 50' 9.80" (11,556,056.78) 31 50' 23.78" (11,557,468.36) 31 50' 15.09" (11,556,589.72) 31 49' 23.93" (11,551,418.85) 31 49' 32.20" (11,552,261.31) 31 49' 35.98" (11,552,644.27) 31 49' 56.84" (11,554,736.44) 31 48' 56.20" (11,548,622.88) 31 50' 34.13" (11,558,506.91) ' 51.40" (1,723,940.74) ' 27.39" (1,720,839.83) ' 28.51" (1,720,739.47) ' 35.99" (1,720,096.29) ' 48.37" (1,719,041.03) ' 12.44" (1,722,137.55) ' 9.32" (1,722,406.21) ' 22.91" (1,716,054.54) ' 26.22" (1,720,958.50) ' 4.04" (1,717,673.68) 18S 16E 29 18S 16E 30 18S 16E 30 18S 16E 30 18S 16E 31, 32 18S 16E 32 18S 16E 32 18S 18S 19S 16E, 15E 16E 16E 30, 31 25, 36 31, 32 05, 06 18S 16E 30 Note: Partial sections may not be shown for Dry Stack Tailings Facility and Waste Rock Storage Area. 2

23 3.0 Pond and Heap Leach Pad Leakage Estimates Estimated potential leakage rates (annualized) for the ponds are listed below during operations and at closure. The estimated chemical constituents in the facility seepage are provided in Section 7.0. PW Pond - Assumes a double-lined system with leak collection and removal system (LCRS). With this LCRS system, a maximum head of 1.5 feet is assumed on the lower liner. A rate of 0.11 gallons per day (gpd) was calculated based on the Technical Memorandum titled Rosemont Copper BADCT Analysis for the PWTS Ponds dated May 4, 2009 (Tetra Tech, 2009c). Assuming a constant leakage rate of 0.11 gpd, the annualized volume is about 40 gallons per year. It is assumed that the PW Pond would be removed from service at the end of operations, i.e., at area-wide closure. In the February 2009 aquifer protection permit (APP) application (Tetra Tech, 2009a), fate and transport modeling of this facility was not planned. However, in the April 14, 2010 Comprehensive Request for Additional Information from the Arizona Department of Environmental Quality (ADEQ) to Rosemont Copper Company (Rosemont) on April 14, 2010 (ADEQ, 2010), fate and transport modeling of the PW Portion of the PWTS Pond was requested (item no. 20 on page 11 of 18). The PW Pond will typically receive direct precipitation, stormwater runoff from the Dry Stack Tailings, process water, tailings decant from the Settling Basin, and stormwater runoff from plant area. Therefore, the chemical makeup of the potential seepage from the PW Pond was assumed to be represented by leachate from the dry stack tailings material as indicated in Table 2 in Section 7.0. This leachate quality is documented in an updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2001c). This revision will replace the Infiltration, Seepage, and Fate and Transport Report prepared in February 2010 (Tetra Tech 2010b). Settling Basin As indicated in the February 2009 APP application, fate and transport modeling for this facility was not planned. However, as indicated under item no. 23 on page of the 11 of 18 in the April 14, 2010 letter from ADEQ (ADEQ, 2010), fate and transport modeling was requested. The original liner design for this facility was comprised of a geosynthetic clay liner system with a coarse rock cover. This design, however, will now be replaced with an HDPE liner on a geosynthetic clay liner (GCL). An estimated leakage rate for this facility was based on similar comparative calculations prepared for the Stormwater Pond illustrated in the Technical Memorandum titled Rosemont Heap Leach Facilities Permit Design Liner Leakage Calculations dated April 27, 2009 (Tetra Tech, 2009b). Based on this analysis, and an assumed maximum hydraulic head of 36 feet and one (1) two (2)-millimeter diameter hole per acre, the anticipated leakage through the basin liner would be about gpd. Therefore, the estimated annual leakage is assumed to be about 6,700 gallons per year at 60 days per year of service. It is also assumed that the Settling Basin would be removed from service at the end of operations. 3

24 The chemical makeup of the potential seepage from the Settling Basin was assumed represented by leachate from the dry stack tailings material as indicated in Table 2 in Section 7.0. Raffinate Pond - Assumes a double-lined system with leak collection and removal system (LCRS). With this LCRS system, a maximum head of 1.5 feet is assumed on the lower liner. A rate of 0.11 gpd was calculated based on the Technical Memorandum titled Rosemont Copper BADCT Analysis for the Rosemont Heap Leach Facilities Permit Design Liner Leakage Calculations dated April 27, 2009 (Tetra Tech, 2009b). Assuming a constant leakage rate of 0.11 gpd, the annualized volume is about 40 gallons per year. It is assumed that the Raffinate Pond would be removed from service on or before Year 10 of operations. Since the Raffinate Pond receives process solution from the solvent-extractionelectrowinning (SX-EW) process, the chemical makeup of potential seepage from the pond was assumed to be conservatively represented by the seepage without treatment solution chemistry from the heap as indicated in Table 3 in Section 7.0. The table and information is documented in an updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2010c). This revision will replace the Infiltration, Seepage, and Fate and Transport Report prepared in February 2010 (Tetra Tech, 2010b). PLS Pond The PLS Pond will include a double-lined system with leak collection and removal system (LCRS). With this LCRS system, a maximum head of 1.5 feet is assumed on the lower liner. A rate of 0.11 gpd was calculated based on the Technical Memorandum titled Rosemont Copper BADCT Analysis for the Rosemont Heap Leach Facilities Permit Design Liner Leakage Calculations dated April 27, 2009 (Tetra Tech, 2009b). Assuming a constant leakage rate of 0.11 gpd, the annualized volume is about 40 gallons per year. It is assumed that the PLS Pond would be removed from service on or before Year 10 of operations The chemical makeup of potential seepage from the PLS Pond was assumed to be represented by the seepage without treatment solution chemistry from the heap as indicated in Table 3 in Section 7.0 documented in the updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2010c). Heap Leach Pile/Pad Based on the Technical Memorandum titled Rosemont Heap Leach Facilities Permit Design Liner Leakage Calculations dated April 27, 2009 (Tetra Tech, 2009b), the assumed leakage rate using an average hydraulic head of two (2) feet and one (1) two (2) millimeter hole per acre, the calculated leakage rate is gpd. Assuming a constant leakage rate 56.4 gpd, the annualized volume would be about 20,600 gallons per year during operations. It is assumed that any potential leakage through the pad liner would discontinue after Year 10 of operations. The chemical makeup of potential seepage through the pad liner was assumed to be similar to drain-down in seepage without treatment from the heap as indicated in Table 5 in Section

25 After Year 10 of operations, following about three (3) years of active drain-down solution management, the PLS Pond and Stormwater Pond may be converted to Treatment Basins should drain-down continue. It is assumed herein that at the cessation of active drain-down management (assumed to be Year 10 of operations), the ponds would be converted and a maximum assumed rate of ten (10) gallons per minute (gpm) would be treated based on the drain-down curve (Illustration 5.21) provided in the updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2010c) (see drain-down curve and associated table in Attachment 2). To be conservative, the drain-down curve was continued until the starting rate of ten (10) gpm was less than 0.5 gpm, which occurs about 115 years following closure of the Heap Leach Facility. The drain-down table and curve are provided in Attachment 2. The drain-down curve starts at the end of the leaching period (Year 7 of operations). The chemical makeup of seepage through the Treatment Basins is provided as seepage through engineered biological system in Table 3 in Section 7.0. For completeness, the following ponds are not planned for fate and transport modeling: Stormwater Pond The liner system planned for the Stormwater Pond is highdensity, polyethylene (HDPE) underlain with GCL. Under normal operating conditions, this pond will be dry. Therefore, a potential leakage rate has not been applied to this facility. TS Pond The liner system planned for the TS Pond portion of the PWTS Pond is a HDPE liner underlain with GCL. Under normal operating conditions, this pond will be dry. Therefore, a potential leakage rate has not been applied to this portion of the PWTS Pond. 4.0 Dry Stack Tailings Facility AMEC Earth & Environmental, Inc (AMEC) predicted a maximum seepage from the Dry Stack Tailings Facility of 8.4 gpm. Drain-down from the dry stack tailings is anticipated to reach zero about 500 years following closure per Figures 6.7 and 6.8 developed by AMEC in the Rosemont Copper Company Dry Stack Tailings Storage Facility Final Design Report (AMEC, 2009) (see AMEC Figures 6.7 and 6.8 in Attachment 3). Table 4 in Section 7.0 provides the anticipated water quality of the seepage water from the Dry Stack Tailings Facility. Information on seepage from the dry stack has been developed as part of an updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2010c). 5.0 Waste Rock Storage Area Seepage is not anticipated to develop from meteoric precipitation infiltrating into the Waste Rock Storage Area. However, for completeness, a fate and transport analysis was performed as part of the updated Infiltration, Seepage, and Fate and Transport Report Revision 1 (Tetra Tech, 2010c). However, should seepage develop from the facility, the anticipated chemical makeup 5

26 would be as illustrated in Table 4 provided in Section 7.0. This information is provided for informational purposes only. 6.0 Flow-Through Drains Table 7 in Section 7.0 provides the results of Synthetic Precipitation Leaching Procedure (SPLP) test results performed on the planned run-of-mine (ROM) drain rock materials designated for construction of the flow-through drains: Escabrosa and Glance. Of the total material requirements associated with the flow-through drains, the anticipated percentages are about 14 percent Escabrosa and 86 percent Glance. Since the larger portion of the material is the Glance, the chemical makeup of the flow-through drains is most conservatively represented by the Concha/Glance SPLP leachate results represented in Table 5 in Section Chemical Compositions Table 2 provides the chemical makeup of drain-down seepage through Dry Stack Tailings Facility. Those metals not included in Table 2 (aluminum, arsenic, antimony, beryllium, cadmium, chromium, iron, lead, nickel, silver, thallium, and zinc) were not reported above the detection limit in any of the tailings samples analyzed. This information was derived from Table 6.9 in the updated Infiltration, Seepage, and Fate and Transport Modeling Report Revision 1 (Tetra Tech, 2010c). This seepage quality was also assumed representative of potential seepage from PW Pond and the Settling Basin. Table 2 Dry Stack Tailings Facility Seepage Parameters Units Tailings ph 5.87 Pe mg/l 14.7 Total Alkalinity (as CaCO 3 ) mg/l Total Dissolved Solids mg/l 810 Percent error mg/l 2.77 Barium mg/l Carbon mg/l Calcium mg/l 188 Chlorine mg/l 3.98 Fluorine mg/l 2.37 Potassium mg/l 9.35 Magnesium mg/l Molybdenum mg/l Sodium mg/l 26.5 Nitrite + Nitrate as N mg/l

27 Table 2 Dry Stack Tailings Facility Seepage Parameters Units Tailings Selenium mg/l Sulfur mg/l 559 Table 3 provides the chemical makeup of drain-down seepage through the heap leach pile with and without treatment. This information was derived from Table 6.8 in the updated Infiltration, Seepage, and Fate and Transport Modeling Report Revision 1 (Tetra Tech, 2010c). The seepage without treatment was assumed representative of potential seepage through the Heap Leach Pad, PLS Pond, and Raffinate Pond liners during operations. Table 3 Heap Leach Facility Seepage Parameter Seepage Without Treatment Seepage Through Engineered Biological System Seepage Through Crushed Limestone milligrams per liter (mg/l) ph pe Total Alkalinity (as CaCO 3 ) Total Dissolved Solids Percent error Silver Aluminum Arsenic Barium Carbon Calcium Cadmium Chlorine Chromium Copper Fluorine

28 Table 3 Heap Leach Facility Seepage Parameter Seepage Without Treatment Seepage Through Engineered Biological System Seepage Through Crushed Limestone milligrams per liter (mg/l) Iron Potassium Magnesium Manganese Molybdenum Sodium Nickel Nitrite + Nitrate as N Oxygen Lead Sulfur (Sulfate + Sulfide) Selenium Zinc Table 4 itemizes the chemical makeup of potential seepage from the Waste Rock Storage Area. This information was derived from Table 6.7 of the updated Infiltration, Seepage, and Fate and Transport Modeling Report Revision 1 (Tetra Tech, 2010c). Table 4 Waste Rock Storage Area Seepage Parameter Waste Rock Seepage (mg/l) ph 7.73 pe (oxidation potential) 12.9 Total Alkalinity (as CaCO 3 ) 35.9 Total Dissolved Solids 2216 Percent error 0.06 Aluminum Arsenic