Information Request 11

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1 Information Request 11 Information Request Responses to Information Request 11 Response to Information Request 11a Response to Information Request 11b

2 Federal Review Panel Information Request 11 IR 11 Pit Dewatering Rates References: EIS, Section EIS Appendix A (Preliminary Pit Slope Design) EIS Appendix A-C (Numerical Hydrogeologic Analysis) Related Comments: CEAR # 272 (Natural Resources Canada) Rationale: The Proponent has performed both 2D cross-sectional and 3D numerical groundwater flow modeling analyses to determine dewatering requirements for the proposed 545 m deep pit and the effects of this dewatering on Fish Lake (Appendix A). According to Natural Resources Canada (NRCan) these modeling exercises represent Fish Lake as a constant-head boundary condition in which the lake level is fixed at an elevation of 1457 m. In NRCan s view, this numerical representation of Fish Lake implicitly assumes that there is an infinite amount of recharge water available with which to maintain the level of the lake during pit dewatering and post-closure infilling. Because the level of Fish Lake is fixed a-priori at the pre-mining elevation, the Proponent s numerical groundwater flow analyses are, in the view of NRCan, incapable of predicting whether or not this level will change in response to pit dewatering. The Panel would like to better understand the opposing views of NRCan and Taseko on these matters. Information Requested: The Panel requests that the Taseko: a. Undertake, and report on, additional 3D numerical groundwater flow modeling aimed at determining the amount of recharge required to maintain the pre-mining water level in Fish Lake during all phases of the project. b. Compare this amount to the amount of flow supplementation proposed for Fish Lake. For this analysis, the 3D numerical groundwater flow model should be revised to incorporate a more refined representation of hydrostratigraphic units between the proposed pit and Fish Lake, including the more permeable bedrock above the gypsum line and the overlying thick-inter-stratified overburden deposits between Fish Lake and the proposed pit. 11-1

3 Response to Information Request 11a Information Request #11a Undertake, and report on, additional 3D numerical groundwater flow modeling aimed at determining the amount of recharge required to maintain the pre-mining water level in Fish Lake during all phases of the project. Response Summary The Fish Lake system has been shown to be a surface-water controlled system under predevelopment conditions. A comparison of the surface and groundwater base flows indicates that groundwater inflow into the lake represents about 2% of the total lake inflow on an average annual basis. Reductions in groundwater base flow to Fish Lake, as well as induced lakebed seepage due to the development of the open pit are predicted to total 53 m 3 /day, which equates to 11% of the baseline average annual groundwater base flows and 0.24% of the baseline average annual surface water inflows to Fish Lake. Based on the water management plan for the project, Fish Lake will continue to be a surfacewater controlled system. Reductions in groundwater base flow to Fish Lake, as well as induced lakebed seepage due to the development of the open pit, are not considered to have an effect on maintaining pre-mining water levels in Fish Lake. Discussion In the 3D numerical groundwater flow model, Fish Lake is represented as a river boundary with a constant head of 1457 masl and a river bed conductance of 10 m 2 /d per day for the grid cells representing the Lake. Top of model (Layer 1) elevation for cells representing Fish Lake was assigned using updated 2011 bathymetery provided by Triton Environmental (Triton 2011). The 3D numerical groundwater model is run in 6 month stress periods representing the nonrecharge (Winter) and recharge (Summer) seasons. The Fish Lake level is held constant at 1457 masl through both these seasons based on the results of lake level (Knight Piésold 2012a Appendix A-A of 2012 EIS) modelling. The baseline watershed model predicts that the average annual surface water input to Fish Lake is on the order of 250 L/s (21,600 m 3 /d) (KP 2012b, Table 6 Appendix B-A of 2012 EIS) with 414 L/s (35,800 m 3 /d) average in the summer months of May October and 87 L/s (7516 m 3 /d) average in the winter months of November April. Comparatively, the groundwater base flow into Fish Lake predicted by the 3D numerical model is 470 m 3 /d (average annual) with 446 m 3 /d in the Summer (recharge) months and 493 m 3 /day in the Winter (nonrecharge) months. A comparison of the surface and groundwater base flows indicates that groundwater inflow into the lake represents about 2% of the total lake inflow on an average 11-2

4 Response to Information Request 11a annual basis. Seasonally, the groundwater contribution ranges from as low as 1% in the summer months to up to 7% in the winter months. The pre-development, and post-development water balance for Fish Lake is described below. Figure 4.1 from Appendix A-B of the 2012 EIS reproduced here as Figure 11A-1 can be used for reference when reviewing various project sub-catchment areas. 1) Operationally, non-contact water will be directed towards the inlets of Fish Lake from several areas, including: sub-catchments F (i.e. the remaining baseline Fish Lake catchment), sub-catchments E (i.e. the areas east and south of the TSF), and the recirculated water from the outlet of Fish Lake. The annual water volume requirement for the inlets of Fish Lake during this time period is approximately 10.8 Mm 3, based on the requirement to maintain flows for fish habitat in those inlets. The monthly flows for the inlets have been identified in the following Table (reproduced from Appendix A-B of the 2012 EIS): Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Monthly Flow (m 3 /s) ) Starting in Closure Phase II, sub-catchment E1 will no longer supply non-contact water to Fish Lake, but will instead be directed to Wasp Lake. Sub-catchment E will flow towards the TSF pond. Excess flows from the TSF will be directed to the inlets of Fish Lake. The required annual volume for the inlets of Fish Lake remain the same for the Closure and Post-Closure phases. 3) While the catchment area that collects non-contact water to be directed to Fish Lake is less than the pre-development condition (51 km 2 vs 68 km 2 ), additional non-contact water is pumped from the outlet of Fish Lake to the inlets. As stated earlier, the required annual flows for the Fish Lake inlets during operations, closure and post-closure is approximately 10.8 Mm 3 (i.e. 340 L/s). This new requirement for Fish Lake flows is greater than the total pre-development Fish Lake outflows, which were identified above as 250 L/s. In effect, the flows reporting to Fish Lake during these time periods is greater than during the pre-development time period. 4) As discussed above, and stated as part of the response to IR10a, the combined reduced base flow to Fish Lake and increased lakebed seepage is approximately 53 m 3 /day (i.e. 11-3

5 Response to Information Request 11a less than 1 L/s). Compared to the surface water inflows for Fish Lake, the groundwater reductions are not considered to have a meaningful effect on the water level of Fish Lake. As the Fish Lake water balance is dominated by surface water inputs, and since catchment cutoff will be mitigated with inlet re-circulation and with outlet control, BGC believes that the constant head representation used in the 3D model is both accurate and reasonable. 11-4

6 Response to Information Request 11a References Taseko Mines Limited (2012). New Prosperity Gold-Copper Mine Project Environmental Impact Statement. Knight Piesold Ltd. 2012a. Taseko Mines Limited New Prosperity Gold-Copper Project, Lake Level Fluctuation Predictions for Fish Lake, Ref No. VA /25-A.01. Report submitted to Taseko Mines Limited July 31, Knight Piesold Ltd. 2012b. Taseko Mines Limited New Prosperity Gold-Copper Project, Baseline Watershed Model for New Prosperity Project, Ref No. VA Report submitted to Taseko Mines Limited. August 10,

7 FIGURE 11A-1

8 Response to Information Request 11b Information Request #11b Compare the amount (from IR11a) to the amount of flow supplementation proposed for Fish Lake. For this analysis, the 3D numerical groundwater flow model should be revised to incorporate a more refined representation of hydrostratigraphic units between the proposed pit and Fish Lake, including the more permeable bedrock above the gypsum line and the overlying thick-inter-stratified overburden deposits between Fish Lake and the proposed pit. Response Summary Reductions in groundwater base flow to Fish Lake, as well as induced lakebed seepage due to the development of the open pit are predicted to total 19,000 m 3 /yr (53 m 3 /day). The baseline inflow to Fish Lake is 7.8 Mm 3 /yr The average annual inflow to Fish Lake during operations totals 10.8 Mm 3 /yr, resulting from 6.6 Mm 3 /yr of recirculated flow and 4.2 Mm 3 due to all upstream catchment areas that report to the lake. The amount of flow supplementation required is based on the flow required to achieve fish habitat goals and exceeds that required to maintain lake levels by more than two orders of magnitude. As part of the 2009 EA for the Prosperity project, BGC (BGC 2009b CEAR#1269 from the 2009/10 EIS) conducted a careful review of the pit outline and the hydrogeologic data above and below the gypsum line. Following this review, BGC determined that gypsum dissolution did not have a marked effect on bulk hydraulic conductivity of the fractured rock mass when compared to the parameter assignment used in the 3D model over the depth range potentially affected by gypsum dissolution. Neither of these data reviews supported a refined representation of the hydrogeology in-between Fish Lake and the Open Pit. It remains our opinion that a refined modelling effort is neither warranted, nor will it significantly change results pertaining to the interaction between the Open Pit and Fish Lake. Discussion Flow Supplementation The amount of flow supplementation required is based on the flow required to achieve fish habitat goals and exceeds that required to make up changes in lake groundwater flows by more than two orders of magnitude. Flow supplemental to Fish Lake totals 10.8 Mm3/yr, resulting from 6.6 Mm3/yr of recirculated flow and 4.2 Mm3 due to all upstream catchment areas that report to the lake. 11-6

9 Response to Information Request 11b The pre-development, and post-development water balance for Fish Lake is described below. Figure 4.1 from Appendix A-B of the 2012 EIS reproduced here as Figure 11A-1 can be used for reference when reviewing various project sub-catchment areas. 1) Operationally, non-contact water will be directed towards the inlets of Fish Lake from several areas, including: sub-catchments F (i.e. the remaining baseline Fish Lake catchment), sub-catchments E (i.e. the areas east and south of the TSF), and the recirculated water from the outlet of Fish Lake. The annual water volume requirement for the inlets of Fish Lake during this time period is approximately 10.8 Mm 3, based on the requirement to maintain flows for fish habitat in those inlets. The monthly flows for the inlets have been identified in the following Table (reproduced from Appendix A-B of the 2012 EIS): Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Monthly Flow (m 3 /s) ) Starting in Closure Phase II, sub-catchment E1 will no longer supply non-contact water to Fish Lake, but will instead be directed to Wasp Lake. Sub-catchment E will flow towards the TSF pond. Excess flows from the TSF will be directed to the inlets of Fish Lake. The required annual volume for the inlets of Fish Lake remain the same for the Closure and Post-Closure phases. 3) While the catchment area that collects non-contact water to be directed to Fish Lake is less than the pre-development condition (51 km 2 vs 68 km 2 ), additional non-contact water is pumped from the outlet of Fish Lake to the inlets. As stated earlier, the required annual flows for the Fish Lake inlets during operations, closure and post-closure is approximately 10.8 Mm 3 (i.e. 340 L/s). This new requirement for Fish Lake flows is greater than the total pre-development Fish Lake outflows, which were identified above as 250 L/s. In effect, the flows reporting to Fish Lake during these time periods is greater than during the pre-development time period. Hydrostratigraphic Units between the Lake and the Pit In addition to the description of hydrogeologic conditions between Fish Lake and the Open Pit described in response to IR2, the following summary has been prepared detailing the scale and purpose of 2D versus 3D modelling. This description is provided to assist the Panel in understanding why the gypsum line is important for one model and not the other. 11-7

10 Response to Information Request 11b Purpose of 2D Modelling Knight Piésold (KP 2012c Appendix A of the 2012 EIS) conducted 2D SEEP/W modelling to assess the interaction between Fish Lake and the open pit. The overall purpose of this work was to predict pit wall stability and assess the effectiveness of the proposed dewatering system. These analyses represented Fish Lake as both a constant ponding water pressure and a constant head boundary and found that the inflow estimates were the same for both boundary condition representations. These results also indicated that slope depressurization in the form of horizontal drains and dewatering wells would be required to maintain acceptable pit wall stability. As the scale of this analysis is limited to the interaction between the open pit and Fish Lake, watershed scale impacts were instead evaluated with the 3D numerical groundwater flow model. Purpose of 3D Modelling The conceptual dewatering system deemed necessary by the 2D modeling (KP 2012c Appendix A of the 2012 EIS) was implemented into the 3D numerical groundwater model using drain boundaries. The base-case 3D numerical model predicted that groundwater extraction from dewatering wells would increase from m 3 /d throughout project operations (BGC 2012a Appendix A-C of the 2012 EIS). A comparison of the 2D model and 3D predicted inflows to the open pit and the pit dewatering system concluded reasonable agreement between the two models (BGC 2012a Appendix A-C of the 2012 EIS). The overall purpose of the 3D groundwater flow modelling was to assess the impacts of open pit development to the groundwater system at the scale of the watershed, necessitating a simplification in the geological representation. In the 3D model, the hydrogeological representation between the open pit and Fish Lake has been simplified to: 15 to 30 m of glacial till with K = 5.0E-08 m/s underlain by, m of bedrock with K = 2.0E-07 m/s underlain by, 100 m of bedrock with K = 8.0 x 10-8 m/s to 200 m underlain by, 1200 m of bedrock with K = 4.0 x 10-9 m/s. As part of the 2009 EA for the Prosperity project, BGC (BGC 2009b CEAR#1269 from the 2009/10 EIS) conducted a careful review of the pit outline and the hydrogeologic data above and below the gypsum line. Following this review, BGC determined that gypsum dissolution did not have a marked effect on bulk hydraulic conductivity of the fractured rock mass when compared to the parameter assignment used in the 3D model over the depth range potentially affected by gypsum dissolution. Neither of these data reviews supported a refined representation of the hydrogeology in-between Fish Lake and the Open Pit. It remains our opinion that a 11-8

11 Response to Information Request 11b refined modelling effort is neither warranted, nor will it significantly change results pertaining to the interaction between the Open Pit and Fish Lake. 11-9

12 Response to Information Request 11b References Taseko Mines Limited (2012). New Prosperity Gold-Copper Mine Project Environmental Impact Statement

July 31, 2012

July 31, 2012 www.knightpiesold.com July 31, 212 Mr. Scott Jones Vice President Engineering Taseko Mines Limited 15th Floor, 14 West Georgia Street Vancouver, BC V6E 4H8 File No.:VA11-266/25-A.1 Cont. No.:VA12-743 Dear

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