Flambeau Mine On-Site Surface Water Monitoring Program (See Appendix I for maps with site locations)

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1 Flambeau Mine On-Site Surface Water Monitoring Program (See Appendix I for maps with site locations) Controlling Document and Specifications COC Stipulation Monitoring Plan (Dec 2007) Frequency: Spring/Fall, starting Fall 2007 Parameters: Cu Zn ph (field) Fe Sulfate Conduct (field) Mn Hardness Flow (field) Last Required Sampling: Spring acre Biofilter Management Plan (Jan 2007) Frequency: Spring (Apr) / Fall (Sep), starting Spring 2007 Parameters: Cu ph Conduct Zn Hardness Last Required Sampling: Fall 2009 or until biofilter stable Copper Park Work Plan (Fall 2008) Frequency: Spring 2008 only, with water samples collected in May and/or June 2008 Parameters 8 : Conduct (lab) Hardness (tot) Cu (tot/dis) ph (lab) Fe (tot/dis)) Zn (tot/dis) Mn (tot/dis) Sulfate (unfilt) Stream C Drainage System Stream B Drainage System 1 Stream A Drainage System Stream C 0.9-acre in Industrial Stormwater Runoff Man-made Channel B (Outfall 002) 1.7-acre close to river Stream A 8.5-acre Mitigation Wetland C2 2 C3 C4 4 C5 3 C6 C7 C8 BF (Inlet) BF C2 (Outlet) Indust. 6 Copper Park Lane 7 B1 Outlet to Channel B A1 Outlet to Stream A

2 Controlling Document and Specifications Monitoring Plan for Intermittent Stream C (Aug/Sep 2004) 5 Frequency: Quarterly, starting Sep 2004 Parameters: Cu (tot) ph (field) Zn (tot) Sulfate Hardness (tot) Temp (field) Last required sampling: Sep acre Biofilter Management Plan : Does Not Exist 8.5-acre Mitigation Wetland Surface Water Monitoring Plan : Does Not Exist Revised Reclamation Plan (January 1998) Long-Term Care and Maintenance (1998-???) Flambeau Mine Permit: Mine Permit Conditions: Part 4 (Monitoring Plan Approval), pp (Jan 1991) Mining Permit Application for the Flambeau Project: Section 10 (Long-Term Care/Maint), pp (1989) Stream C Drainage System Stream B Drainage System 1 Stream A Drainage System Stream C 0.9-acre in Industrial Stormwater Runoff Man-made Channel B (Outfall 002) 1.7-acre close to river Stream A 8.5-acre Mitigation Wetland C2 2 C3 C4 4 C5 3 C6 C7 C8 BF (Inlet) BF C2 (Outlet) No such plan was ever incorporated into the monitoring requirements. No comprehensive plan was ever incorporated into the monitoring requirements. This is the plan that called for the creation of the 0.9 and 1.7-acre wetland/biofilters (they were not part of the original reclamation plan), the rerouting of surface water drainage (creation of swales), and moving the prescribed location of the mitigation wetland. No provisions were included, however, for monitoring surface water quality in Stream C, Man-Made Channel B, Stream A, the mitigation wetland or the two wetland/biofilters. See CD for a copy of the revised plan proposed by FMC in January 1998 and CD for WDNR s final decision. No provisions for monitoring Stream C during the Long-Term Care and Maintenance phase of the project were incorporated into the Mining Permit Application, the Flambeau Mine Permit or the Updated Monitoring Plan, but these are the parameters that FMC has voluntarily been monitoring in the Flambeau River on a semi-annual basis since 2000: ph (field) Cond (field) Cu Zn Hardness Fe (1999+) Mn (1999+) Sulfate (1999+) Indust. 6 Copper Park Lane 7 B1 Outlet to Channel B A1 Outlet to Stream A Updated Monitoring Plan (Jul 91)

3 Construction and Operational Phase ( ) Flambeau Mine Permit: Mine Permit Conditions: Part 4 (Monitoring Plan Approval), pp (Jan 1991) See footnote # 6 for modification procedure 6 Mining Permit Application for the Flambeau Project: Section 7 (Construction and Operation Phase Monitoring Plan), pp (1989) Updated Monitoring Plan (Jul 91) 1. No provisions for monitoring Stream C during the Construction and Operational phase of the project were incorporated into the Mining Permit Application, the Flambeau Mine Permit or the Updated Monitoring Plan, but these are the parameters that FMC routinely reported on a quarterly basis for the Flambeau River : Al Cu Hg Sulfides (1993+) Hardness As Cr (tot or +3) Ni TDS ph (field) Be Cr (+6) Se TSS Conduct (field) Cd Pb Ag Zn Note: For whatever reason, the following parameters were NOT tested in the Flambeau River during this time period: Fe Mn Sulfate 2. During the Construction and Operational phase of the project, discharges were monitored at several different outfalls (see WPDES permit issued in 1991 and revised WPDES permit issued in 1996): -Outfall 001 (1991 WPDES permit: wastewater treatment plant effluent) -Outfall 002 (1991 WPDES permit: settling pond effluent) -Outfall 003 (1991 WPDES permit: 1) water from open pit before the exposure of Type II waste rock; 2) runoff from the Type I waste rock storage area (low sulfur), and 3) runoff from other areas that did not contact either the high sulfur waste rock or the ore) -Outfall 004 (added in 1996 WPDES permit to cover the possible discharge of water from interception wells surrounding the main pit for purposes of wetland flow augmentation. )

4 The FMC Monitoring activities listed below were not specifically required per the terms of the Mining Permit Application, Mine Permit, Updated Monitoring Plan or Reclamation Plan. Apparently either WDNR required the monitoring through a different mechanism, or FMC did it voluntarily. Date Parameter Nov 1999 Nov 2000 Apr 2001 Jun 2001 Jun 2002 Alkalinity ph (lab) As ph (field) Ba Se Cd Ag Cr TDS Cu TSS Pb Conduct (field) Mn Temp (field) Hg Oil & Grease O 2, diss (field) 1999/2000 Water Elev 1999/2000 Conduct (lab) Alkalinity ph (lab) As ph (field) Ba Se Cd Ag Cr TDS Cu TSS Pb Conduct (field) Mn Conduct (lab) Hg Temp (field) Oil & Grease Alkalinity ph (lab) As ph (field) Ba Se Cd Ag Cr TDS Cu TSS Pb Conduct (lab) Mn Conduct (field) Hg Temp (field) Oil & Grease Stream C Drainage System Stream B Drainage System 1 Stream A Drainage System Stream C 0.9-acre in Industrial Stormwater Runoff Man-made Channel B (Outfall 002) 1.7-acre close to river Stream A 8.5-acre Mitigation Wetland C2 2 C3 C4 4 C5 3 C6 C7 C8 BF (Inlet) BF C2 (Outlet) Indust. 6 Copper Park Lane 7 B1 Outlet to Channel B A1 Outlet to Stream A

5 WDNR-imposed and/or FMC voluntary monitoring (cont.) Date Parameter May Alkalinity ph (lab) 2003 As ph (field) Ba Se Cd Ag Cr TDS Cu TSS Pb Conduct (lab) Mn Conduct (field) Hg Temp (field) Oil & Grease (C2 not tested for full Jun Apr 2004 Jun 2005 panel) Cu Conduct (lab) Mn Conduct (field) ph (lab) Temp (field) Stream C Drainage System Stream B Drainage System 1 Stream A Drainage System Stream C 0.9-acre in Industrial Stormwater Runoff Man-made Channel B (Outfall 002) 1.7-acre close to river Stream A 8.5-acre Mitigation Wetland C2 2 C3 C4 4 C5 3 C6 C7 C8 BF (Inlet) BF C2 (Outlet) Indust. 6 Copper Park Lane 7 B1 Outlet to Channel B ph (field) Conduct (lab) Mn Conduct (field) ph (lab) Cu ph (field) Temp (field) Conduct (lab) Mn Conduct (field) ph (lab) Cu ph (field) 1. Stream B is put in quotation marks because the stream was destroyed when the mine pit was excavated. A man-made channel was constructed about 100 yards upstream of the original Stream B discharge point to the Flambeau River, and it was used to convey water from the mine s unlined settling ponds to the Flambeau River during the mining years (Outfall 002 in the Flambeau Mine Permit, regulated under WPDES permit during the mining years). If you go to streams (creeks) at reclaimed Flambeau Mine site, pollution of in the index to Roscoe s book, you will find a number of entries leading you to more information about Stream B. 2. The assumption made here is that C2 is a monitoring site located in Wetland 6B, adjacent to the SOUTH side of the railspur EAST of Highway 27. Even though this monitoring site has not been labeled as such on the attached maps, the FMC 2003 Annual Report makes reference to a sample collected at this physical location. In addition, C3 has clearly been identified by FMC as the sampling site on the NORTH side of the railspur EAST of Highway 27. Absent any other information regarding where site C2 is located, it would make sense to assume that C2 is the site referenced in the 2003 report. A1 Outlet to Stream A

6 3. C5 was originally proposed to be located SOUTH of Copper Park Lane (as shown in Figure 2 of FMC s Aug 2004 Proposed Monitoring Plan for Intermittent Stream C (See CD ). Before any samples were collected, however, the location was changed to that shown in Figure 2 of FMC s Oct 2005 report entitled Stream C 2005 Analysis of Collected Data (attached). The new location was selected to be upstream of the two culverts on the north side of Copper Park Lane, as long as backwater conditions do not exist upstream of the culverts (see CD , CD and CD ). 4. C4 was originally proposed to be located approximately 750 feet north of C3, on the east side of Highway 27 (as shown in Figure 2 of FMC s Aug 2004 Proposed Monitoring Plan for Intermittent Stream C (See CD ). It was meant to serve as a control site, as explained in the report. Apparently due to dry conditions, FMC was not able to collect any samples from this location in fall 2004, and with the April 2005 sampling attempt the location was changed to that shown in Figure 2 of FMC s Oct 2005 report entitled Stream C 2005 Analysis of Collected Data. (attached). The new site was located in an unnamed intermittent stream, just before its confluence with Stream C. 5. Note: A biological assessment of Stream C in Fall 2004 and Spring 2005 was also included as part of this plan. In addition, provisions were included for collecting and analyzing six sediment samples from the 0.9-acre biofilter. in the Industrial. The plan was modified in Sep 2004 to include surface water sampling C7 and C8. 6. Stormwater runoff was collected at two different locations in the Industrial in the fall of In Spring 2005 five more sampling were added. See Figure 2 in FMC s Oct 2005 report entitled Stream C 2005 Analysis of Collected Data for site locations (attached). 7. See Figure 1 and Figure 3 in FMC s 2008 Monitoring Results and Copper Park Lane Work Plan (October 14, 2008) for sampling site locations (attached). 8. Not all samples were tested for all parameters.

7 Appendix I 1. First figure is Figure 6 from COC Stipulation Monitoring Plan, December Second figure is Figure 2 from Stream C 2005 Analysis of Collected Data, (Foth & Van Dyke), October 24, Third figure is Figure 1 from 2008 Monitoring Results and Copper Park Work Plan, (Foth), October 14, Fourth figure is Figure 3 from 2008 Monitoring Results and Copper Park Work Plan, (Foth), October 14, 2008

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