REVISED 2019 MINING/ LAND RECLAMATION PLAN AND PLAN OF OPERATIONS

FORT CADY PROJECT NEWBERRY SPRINGS, CALIFORNIA

San Bernardino County No. 94M-04 Bureau of Land Management Nos. CACA33044; CAMC 20175

CA MINE ID # 91-36-0124

Prepared for:

San Bernardino County Land Use Services Department 385 N. Arrowhead Avenue, 1st Floor San Bernardino, CA 92415

and

Bureau of Land Management Barstow Field Office 2601 Barstow Road Barstow, CA 92311

Prepared by:

FORT CADY CALIFORNIA CORPORATION 16195 Siskiyou, Suite 210 Apple Valley, CA 92307

MAY 1993 REVISED APRIL 2019

Approved by County of San Bernardino - July 10, 1994 Approved by BLM Barstow – December 30, 1994

Revised 2019 Plans Fort Cady Project

Table of Contents List of Tables ...... 4 List of Figures ...... 5 Appendices ...... 5 Glossary of Terms ...... 6 I. Revised 2019 Mining Plan & Plan of Operations ...... 8 A. Request for Revisions - 2019 ...... 8 B. BLM Requirements ...... 11 C. Summary of EIS/EIR Findings and Revised Plan...... 11 1.0 Mining Operations ...... 16 1.1 Background ...... 16 1.1.1 Summary of 1993 Plan ...... 16 1.1.2 Current Description of the Project ...... 19 1.1.3 Summary of Technology ...... 21 1.1.4 Ore Reserves ...... 22 1.1.5 Land Holdings Status ...... 23 1.2 Project Development ...... 25 1.2.1 Mine Site Approval and Reclamation Plan ...... 25 1.2.2 Waste Discharge Permit ...... 25 1.2.3 Air Quality Permit ...... 25 1.2.4 Hazardous Waste and Toxic Control ...... 25 1.2.5 Office of Building and Safety – Building Permit ...... 26 1.2.6 Groundwater Quality ...... 26 1.2.7 Hydrogeology ...... 26 1.3 Commercial Plant Operations ...... 27 1.3.1 Applied Technology...... 27 1.3.2 In-Site Mining ...... 28 2.0 Ore Processing Method ...... 33 2.1 Introduction ...... 33 2.2 Well Field Facilities ...... 35 2.2.1 Well Field Layout ...... 35 2.2.2 Mining Sequence ...... 35

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2.2.3 Well Field Construction ...... 37 2.2.4 Well Completion Details ...... 38 2.2.5 Well Monitoring ...... 41 2.2.6 Well Field Corrective Actions ...... 42 2.2.7 Plugging and Abandonment Plan ...... 43 2.3 Boric Acid Processing Plant ...... 43 3.4 Solvent Extraction ...... 45 3.4.1 Solvent Extraction and Crystallization ...... 45 2.4.2 Gypsum Production and Acid Regeneration ...... 46 2.5 Sulfate of Potash ...... 47 2.6 Processing Facilities ...... 47 2.7 Product Loading and Shipping ...... 48 2.8 Cogeneration and Ancillary Facilities ...... 50 2.9 Process and Storage Tanks ...... 50 2.10 Railroad Spur, Natural Gas Pipeline and Access Roads ...... 51 3.0 Mine Waste ...... 52 3.1 Recovery Process ...... 52 3.2 In-process Solutions ...... 52 3.3 Gypsum Storage Facility ...... 52 3.4 Other Wastes ...... 54 4.0 Water Supply ...... 55 5.0 Erosion and Sediment Control ...... 58 II. Land Reclamation Plan - 2019 ...... 59 1.0 Introduction ...... 59 1.1 Land Use ...... 59 1.2 Visibility ...... 60 1.3 Vegetation ...... 60 1.4 Wildlife ...... 61 2.0 Reclamation ...... 61 2.1 Pre-Construction Surveys ...... 61 2.2 Construction Phase ...... 62 2.3 Operations ...... 62 2.4 Orebody/Well-field Closure ...... 62

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2.5 Final Reclamation ...... 63 3.0 Revegetation ...... 63 4.0 Clean-up ...... 63 5.0 Post-Reclamation and Future Mining ...... 64 6.0 Slopes ...... 64 7.0 Gypsum Storage Facility ...... 64 8.0 Soils ...... 64 9.0 Drainage and Erosion Control...... 64 10.0 Public Safety ...... 64 11.0 Monitoring and Maintenanc3e ...... 65 12.0 Reclamation Assurance ...... 65 III. Geology ...... 66 1.0 Regional Geology ...... 66 2.0 Local Geology ...... 68 3.0 Project Area Geology ...... 69 3.1 Cross Sections ...... 70 3.2 Lithology ...... 73 4.0 Proposed Mitigation ...... 75 IV. Hydrology and Hydrogeology ...... 75 1.0 Climate ...... 75 1.1 Regional Meteorological Conditions ...... 75 1.2 Local Meteorological Conditions ...... 76 2.0 Surface Water Hydrology ...... 76 3.0 Flood Hazard ...... 79 4.0 Regional Groundwater Hydrogeology ...... 79 4.1 Local Hydrogeology ...... 80 4.2 Project area Hydrogeology ...... 81 5.0 Groundwater Quality ...... 83 5.1 Project area Water Quality ...... 84

List of Tables Table B-1 PoO Information 11 Table C-1 Potential Environmental Impacts 12 Table 2-1 Acres Disturbed and Right-of-Way Information for the Project Site 34

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Table 2-2 Plant and Equipment Description 48 Table 3-1 Waste Characterization Results of Gypsum 53 Table 3-2 Anticipated Project Waste Types 54 Table 4-1 Groundwater Quality Analyses 56

List of Figures Figure ES-1 2019 Mine Plan Revisions (aerial) 14 Figure ES-2 Approved 1994 Mining Plot Plan with 2019 Revision 15 Figure I.1-1 Regional Location Map 17 Figure I.1-2 Project area 18 Figure I.1-3 Land Ownership within the Project area Boundary 24 Figure I.1-4 Fort Cady Project area with Ore Body 30 Figure I.1-5 Ore Body Dimensions 31 Figure I.1-6 Ore Body and Historic and Existing Wells 32 Figure I.1-7 Boric Acid Solubility Curve Versus Temperature 33 Figure I.2-1 Typical Well Field Push/Pull Sequence 36 Figure I.2-2 Schematic of the Proposed Well Field 37 Figure I.2-3 Proposed Well Design 40 Figure I.2-4 Airlifting from a Production Well 41 Figure I.2-5 Process Flow Design 44 Figure I.2-6 Gypsum Storage Facility (Conceptual) 49 Figure I.4-1 Water Well Locations 57 Figure III.3-1 Cross Section with General Lithology 65 Figure III.3-2 Cross Section Showing Lithology & Faults Resulting in Containment 66 Figure III.3-3 Project Area Lithology 68 Figure IV.2-1 Troy Lake Watershed 73 Figure IV.4-1 In-Situ Test Wells 77 Figure IV.5-1 Piper Diagram 79 Figure IV.5-2 Stable Isotopes vs. Meteoric Water Line 80

Appendices Appendix A - Mining Claims and Property Information Appendix B - Fault B Program Technical Report Appendix C - Approved County Mining/Reclamation Plan (94M-04) and BLM Approval Appendix D - Drawings of 1994 Stamped Approved Mining Plot Plan, Reclamation Plot Plan, and Cross Sections Appendix E - Full Size 2019 Revised Mining Plot Plan and Reclamation Plot Plan Appendix F - USFWS Biological Opinion (1-6-92-F-54) October 1992 Appendix G - Ore Reserve Estimation for the Fort Cady Project. RESPEC. Appendix H - Resource Estimation for the Fort Cady Project, L. Fourie. Appendix I - Approved Revegetation Plan (1995) Appendix J - Facilities Locations, stamped by a California Licensed Land Surveyor. Appendix K - 2018 Biological Survey and 1997 Desert Tortoise Land Transfer

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Glossary of Terms Abbreviation Definition amsl above mean sea level AOR Area of Review APBL American Pacific Borate & Lithium AWWA American Water Works Association BA boric acid Bgs below ground surface BLM US Bureau of Land Management CDWR California Department of Water Resources CEQA California Environmental Quality Act cm/sec centimeters per second (cm/sec) CPVC Chlorinated Polyvinyl Chloride DEHS San Bernardino County Division of Environmental Health Services Duval Duval Corporation DXF file Drawing Interchange Format File EIR Environmental Impact Report (California lead) EIS Environmental Impact Statement (BLM lead) FACE Financial Assurance Cost Estimate FCCC Fort Cady California Corporation FCMC Fort Cady Mineral Corporation FRP fiberglass pipe Ft Foot or feet gpm Gallons per minute HCl Hydrochloric acid HDPE High Density Polyethylene plastic HQ 3.78-inch diameter core hole JORC Australian Joint Ore Reserves Committee Km Kilometres LOM Life of Mine LUSD San Bernardino County Land Use Services Department mD millidarcies mg/l milligrams per liter MSME Mountain States Mineral Enterprises Inc. Mt Million tons NAD 83 North American Datum 83 is a unified horizontal or geometric datum providing a spatial reference for mapping purposes NEPA National Environmental Policy Act P&A plugging and abandonment

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Revised 2019 Plans Fort Cady Project pH numeric scale to specify the acidity or alkalinity of an aqueous solution PLS pregnant leach solution psi Pounds per square inch of pressure PVC Polyvinyl chloride ROD The 1994 Record of Decision for the Fort Cady Project issued after the EIS/EIR evaluations SCE ROW Southern California Edison Right-of-way SDWA Safe Drinking Water Act SMARA State of California Mining and Reclamation SOP Sulphate of Potash SP SP SWiPS Standard Wireline Packer System TDS Total Dissolved Solids tpy tons per year UIC Permit Underground Injection Control Class III Area Permit USDW underground source of drinking water USEPA United States Environmental Protection Agency UTM Universal Transverse Mercator coordinate system for mapping XRD analysis X-ray diffraction analysis

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I. Revised 2019 Mining Plan & Plan of Operations

A. Request for Revisions - 2019 Development and pilot plant testing have been conducted since the 1970s at the Fort Cady Project. An initial Mine Site and Reclamation Plan for the Pilot Plant was approved by the County in 1982 with a revision approved in 1987. The first Plan of Operations (Original Plan) was submitted in April 1990 and subsequently updated by the preparation of the 1993 Plan (referred to in this 2019 Revised Plan as the “Plan”). The 1993 Plan and the 1993 EIS/EIR were approved by the BLM and County in 1994.

Fort Cady California Corporation (FCCC) purchased the Fort Cady Project in the spring of 2017. Since that date, FCCC has been reviewing, evaluating, validating and updating existing reports for the Fort Cady Project (“Project”). The findings have verified that the Project is economically feasible. Therefore, FCCC is in the process of obtaining or updating all necessary environmental permits and has started the detailed design process.

This proposed 2019 Revised Plan (“2019 Revised Plan” or “Revised Plan”) details the changes from the 1993 Plan of Operations/Mining & Reclamation Plan (Plan) (Appendix C) and the 1993 Environmental Impact Statement (EIS)/Environmental Impact Report (EIR), approved by the United States Bureau of Land Management (BLM) and County of San Bernardino (County) in 1994 (Appendix C). The content of the 2019 Plan of Operations/Mining & Reclamation Plan (2019 Plan) has been updated to: be consistent with other permit submittals; incorporate advances in technology; and, address changes in regulations. Additionally, a number of the proposed Project modifications are directly in response to mitigation conditions imposed by the 1993 Plan (Condition), including: Condition 75 regarding use of recycled water to “provide the opportunity for a reduction of total water consumption during operational activities”; Condition 97 that “the area of disturbance be confined to the smallest practical area”; and Condition 118 requiring “reduction of [desert tortoise] habitat fragmentation caused by installation of above- ground pipelines shall be accomplished in several ways”. The format of the 2019 Plan utilizes the same or similar format and headings as in the 1993 Plan where possible.

During the review process, FCCC identified several desirable modifications to the existing approved 1993 Plan. In accordance with BLM mining regulations (43 Code of Federal Regulations (CFR) 3809) and County Development Code Chapter 88.03 that incorporates the California Surface Mining and Reclamation Act of 1975 (SMARA) and environmental review through NEPA and CEQA, FCCC is submitting the proposed modifications to the BLM and County for review, comment and approval. Figure I.ES-1 shows the locations of the facility layout approved in the EIS/EIR, along with the new facility layout on a recent aerial. Figure I.ES-2 provides the locations of the facility layout approved in the EIS/EIR, along with the new facility layout showing the general geology and faults (full-size in Appendix E) as well as a close-up of the facilities stamped by a State of California Professional Land Surveyor. The full stamped map is located in Appendix J. Discussions of the pilot plant in the 1993 Plan have been deleted from the 2019 Plan.

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1. Construction of Approved Rail Spur: The approved proposed plant location in Section 30, T8N, R6E, appears to be located for ease of access to rail. FCCC does not believe that obtaining a permit to construct a rail spur across National Trails Highway Route 66 is viable. FCCC is pursuing transportation alternatives, which may include constructing a rail head at a convenient location near the facility. However, the use of rail is not anticipated for the first several years of operation and product will be shipped by truck. If a different rail spur is planned, the County and BLM will be notified for their review and approval.

2. Change of Plant Location: With the removal of the rail spur constraints, the location of the processing plant in Section 30, T8N, R6E, is no longer preferable. To minimize potential environmental impacts and interaction with the off-roading public, FCCC proposes to move the plant to the northwest quarter of Section 25, T8N, R5E onto fee simple lands owned by FCCC. a. All processing facilities will be on private lands, minimizing the impacts to BLM lands, concentrating project facilities in one location, and reducing conflicts with off-road activities. b. All processing facilities will be shielded from Route 66 and I-40 by low lying hills to the north of Section 25. c. The pipeline distribution requirements from the ore body to the plant will be significantly reduced, minimizing environmental impacts, habitat fragmentation, and interactions with the off-roading public. d. The distance to transport gypsum to the Gypsum Storage Facility would be significantly reduced.

3. Gypsum Storage Facility: The EIS/EIR labeled the Gypsum Storage Facility (GSF) as a tailings impoundment. Gypsum was to be slurried via pipeline to the facility for storage and drying, with a dam not to exceed 30 feet and a plastic liner on the inner dam face. See Section 2.3 for a detailed description. a. FCCC is proposing to dewater the gypsum within the processing plant to enhance water recycling and allow for more efficient re-use of water. Therefore, the gypsum will not be delivered to the GSF by slurry line, but by either off-road truck and/or conveyor. b. Note that gypsum is a by-product of the boric acid production process and is a product, not a waste. Therefore, the term “tailings” is not applicable. c. FCCC anticipates that demand for gypsum will vary on a seasonal basis. The GSF is intended to hold gypsum prior to shipment; therefore, FCCC proposes to modify the facility design. As the facility will be holding dewatered gypsum in a solid form instead of a liquified form, a dam and a liner will not be required. The facility is being designed to include a series of 6-foot berms per Condition 105 to provide more gently sloped sides to reduce tortoise entrapment or drowning and to channel stormwater to a down-gradient stormwater recovery pond. The 6-foot berms will be designed by a California Civil Engineer to meet earthquake standards, as well.

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d. Utilizing the new design will eliminate the need for a dam permit and allow easier access to load and unload gypsum and maintain the facility.

4. Sulfate of Potash Plant: The EIS/EIR includes importing Hydrochloric Acid (HCl) in addition to the regeneration of HCl prior to reinjection into the ore body. FCCC is proposing to construct a Sulfate of Potash (SOP) plant within the footprint of the processing plant. The SOP is generated in a Mannheim furnace-based production plant yielding up to 40,000 tons per year (tpy) of potassium sulfate (SOP) through the high-temperature reaction of potassium chloride (aka KCl or muriate of potash [MOP]) with sulfuric acid. Off-gas from the high-temperature process is rich in HCl gas, which is scrubbed with process water to produce a by-product stream of aqueous HCl which will be used in the wellfield or sold as product. SOP is a specialty agricultural additive in limited supply and will be sold off-site as a product.

5. Make-Up Water Sources: Previous operators were able to identify a source of make-up water to the southwest of the ore body, on the west side of the Pisgah Fault and west of the Hector Mine. In 2017, FCCC conducted an exploration program, which included wells to the east of Fault B. Those wells, the first known wells east of Fault B, both encountered significant quantities of water. In 2018, FCCC implemented the Fault B Program (Program) in part to assess the viability of the Fault B East aquifer for supplying the Project’s water. The Program confirmed that: Fault B is a confining fault; the aquifer is of a different origin from the Pisgah Fault West aquifer and the mineral formation water; and, that a pumping rate of up to 500 gallons per minute (gpm) can be sustained for more than 20 years without impacts to regional domestic, agricultural, industrial or ecological waters. FCCC proposes to utilize the new water source in combination with the approved source. Water available from the two aquifers will be 600 gpm.

6. Rights of Way: a. Power: There is power currently servicing the existing pilot plant facility. Additional power is not needed at this time. b. Gas: FCCC is in conversations with operators of the natural gas pipelines immediately to the north of the Project. Upon reaching an agreement for natural gas, FCCC will work with the supplier and BLM to obtain a Gas Right-of-Way, preferably along the existing Power ROW. c. Water: All water pipelines are or will be located within the Project Boundary. No additional water pipeline rights-of-way will be required. d. Roads: The existing facilities are accessed by turning south from Route 66 to County Road 20795 (Hector Road). The Project access road turns east from the County Road, approximately 1.5 miles south of Route 66. The relocation of the processing plant onto private lands will allow FCCC to use existing roads, as well as minimize traffic along Route 66 since the Hector Road and I-40 interchange is located just 0.5 mile west on Route 66.

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7. Extension of the Plan Expiration Date: This 2019 Plan update requests a 25-year extension of the 1994 approved expiration date of April 24, 2024 to April 24, 2049. This re-initiate the original life of mine to 30 years. With an annual production rate of 90,000 tpy or 2.7 million tons (Mt) for the life of mine. It is estimated that the ore reserves are over 100 Mt.

B. BLM Requirements The Bureau of Land Management’s (BLM) Surface Management Handbook, H-3809-1 (3809) provides the requirements for submitting a Plan of Operations (PoO), 43 CFR § 3809.401(b), which requirements specific information to be included in the PoO. A specific format is not required. This 2019 Revised Plan includes the application information:

Table B – 1: PoO Information Contact Information Section I.1.2 List of Unpatented Mining Claims Appendix A Other Federal, State or Local Authorizations Section I.1.2 Project Maps Throughout Plan and Appendices Operating Plans Section I.2.0 Reclamation Plan Section II Schedule of Operations 24/7/365 Monitoring Plans Section I.2.2.6 Interim Management Plans Not included in this Plan Reclamation Cost Estimate Summarized in Section II

The 3809 Handbook, Section 4.6, discusses the requirements for modifications to an existing approved Plan of Operations, also found at 43 CFR §§ 3809.430 – 434 and 3809.580. Section 4.6.3.1 states “BLM will accept a minor modification without formal approval if the modification is consistent with the approved Plan of Operations and does not constitute a substantive change from the activity analyzed in the NEPA document.” FCCC believes that the requested modifications are consistent with the approved Plan of Operations and do not constitute a substantive change for the activities analyzed in the 1993 EIS/EIR documents. FCCC provides a summary of the EIS/EIR findings in the Section below.

C. Summary of EIS/EIR Findings and Revised Plan The planned revisions to the approved 1994 Plan will decrease the approved areas of disturbance. This Revision does not request an increase in boric acid production but does request an additional product stream to reduce the quantities of HCl required to be delivered to the site. Removing rail service in early years of operation will slightly increase initial truck traffic but will significantly reduce traffic on Route 66. With the addition of trucking SOP and HCl shipments for commercial sales, truck traffic will not exceed an estimated 50 trucks per day or 3 – 4 trucks/hour based on 16 hours/day (two shifts). The following information is from Table 1 of the Final EIS/EIR document.

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Table C-1: Potential Environmental Impacts and Proposed Mitigation Measures for the Preferred Alternative Impacts Residual Potential impacts due to request Revision Impacts Geology Not significant Unchanged Hydrology Significant See B.1. below Climate and Air Quality Not significant Unchanged Noise Not significant Unchanged Biological Resources Not significant FCCC will continue to comply with Desert Tortoise management requirements Land Use/Recreation Potentially See B.1. below Significant Visual Resources Not Significant See B.1. below Transportation Not significant See B.1. below Cultural Resources Not Significant See B.1. below Paleontological Resources Not Significant Unchanged Socioeconomics Not Significant Unchanged Erosion Not significant Unchanged

B.1. Changes to Potential Impacts 1. The EIS/EIR discussed the impacts of using make-up water wells west of the Pisgah Fault. While there were no close water wells, there were public wells approximately 7-miles downgradient. 2. Modifying the source of make-up water to an aquifer with abundant water and non-users will minimize the potential impacts to public wells. 3. Changing the gypsum deposition method from slurry to truck/conveyor will optimize the re-use of in-plant water. 4. Changing the design of the gypsum storage facility from a dam to a series of 6-foot berms will reduce risks and increase safety. 5. FCCC’s Dust Control Plan has been authorized by MDAQMD. FCCC will follow the authorized plan to manage and potential fugitive emissions from “drier” gypsum storage facility. 6. The addition of the SOP plant will allow on-site generation of HCl for the wellfield. While the SOP plant is a new potential source air emissions; however, changes in technology of allowed the entire process to be permitted as a Class II – minor source of emission. 7. Air pollutant emissions from plant facilities, on-site equipment, and vehicle traffic will be substantially reduced due to current strict emissions control requirements. 8. Re-location of the plant site and removing construction of a rail spur and roads to the east will reduce land disturbance and pipeline lengths thereby reducing desert tortoise impacts and minimize interactions with the recreation vehicles. 9. These proposed design and operational improvements are responsive to the required Conditions and mitigation measures imposed in the 1993 Plan and will reduce impacts to air quality, ground water, and biological, cultural, and visual resources.

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B.2. Positive Environmental Benefits

FCCC believes that the requested revisions not only make good business sense but have a net positive impact to the environment.

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Figure I.ES-1: 2019 Mine Plan Revisions with Aerial (see Appendix D for full size version)

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Figure I.ES-2: Approved 1994 Mining Plot Plan with 2019 Revision (see Appendix E for full size version)

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1.0 Mining Operations

1.1 Background

1.1.1 Summary of 1993 Plan The 1993 Plan of Operations/Mining & Reclamation Plan (Plan) (Appendix C) and the associated 1993 EIS/EIR, was approved by the County in July 1994 and the BLM in December 1994. The stamped approved 1994 Mining Plot Plan and Reclamation Plot are included as full-size drawings in Appendix E (Drawings). The 1993 Mining and Land Reclamation Plan (1993 Plan) was prepared to describe the components of the Mine Plan and the procedures to be implemented to reclaim the disturbed areas associated with the proposed Fort Cady California Minerals Corporation (FCMC) Solution Mining Project. The 1993 Plan was prepared in accordance with Federal, State and County requirements. The 1993 Plan was compiled using the U.S. Department of the Interior Bureau of Land Management (BLM) Manual Handbook H-3042-1 “Solid Minerals Reclamation Handbook” (April 8, 1992), the California Department of Conservation, Division of Mines and Geology “Surface Mining and Reclamation Act of 1975 Public Resources Code 2710- 2795”, “Article 9, Reclamation Standards 3700-3713” (January 15, 1993), the “Reclamation Bond Calculation/Evaluation Guide (September, 1989), the Financial Assurance Guidelines” (August 13, 1992), and the San Bernardino County “Mining and Land Reclamation Plan Application Forms and Information” (July 1, 1991).

Many sections in the 1993 Plan were included as direct quotations from the FCMC Solution Mining Project Administrative Draft Environmental Impact Statement/Environmental Impact Report (Draft EIS/EIR) prepared for FCMC by Dames & Moore in March 1993. Several of those sections are retained within this 2019 Revised Plan.

The Fort Cady Project is located in San Bernardino County near Pisgah Crater, approximately 40 miles east of Barstow and 17 miles east of Newberry Springs, California. The site is about two and one-half miles south of Interstate 40 (I-40 )(see Figure I.1-1). The Project area consists of approximately 6,500 acres. Land holdings are discussed in more detail in Section 1.1.5.

“FCMC is proposing to construct and operate a borate production mine and processing facility with the capacity of producing 90,000 tons of borate product per year. This project would include a 273-acre ore body well field, a 10-acre processing facility, a 16-acre gypsum deposition area, and 43.5 acres of ancillary services, a process water supply well network, a railway spur, a natural gas pipeline, access roads, and electric lines and facilities. The project would involve the in-situ mining process, which would involve injecting a weak acid solution into the borate ore body to extract the borate product. The mineral would be processed in an on-site plant, and the final borate product, and the by-product, gypsum, would be sold to various markets.” Plan, § 1.1.1.

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Figure I.1-1: Regional Location Map

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Figure I.1-2: Project area

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1.1.2 Current Description of the Project This section of the 2019 Revised Plan contains a description of Fort Cady California Corporation’s ownership, history of the Project, technology of the mining process, ore reserves, and land holding status for the Project area. Section 1.2 of the report describes the Project development activities that led to FCCC’s decision to proceed with commercial operations. Section 1.3 provides a description of the in-situ solution mining operations. Sections 2 through 5 provide further updated information on the proposed Project, including a discussion of mine wastes, the ore processing method, water data, and erosion and sedimentation control. Sections II through IV discuss reclamation, geology, hydrology and hydrogeology. No explosive devices will be used in this mining operation; therefore, this plan does not address blasting issues. The text in the Appendices provides further details of the in-situ mining and processing stages.

Ore Body Location The Fort Cady colemanite ore body is currently approximately 606 acres underlying private and public lands on portions of Sections 25, 26 and 27 of T8N, R5E, in San Bernardino County, California. The ore body is located in the central portion of the Project area and is bounded to the west and to the east by two faults. The Pisgah fault, one of the major northwest-trending faults of the Mojave block, crosses the Project area approximately one-half to one mile southwest of the ore body. Fault B, a smaller fault associated with Pisgah Fault, is a north-south trending fault, which runs along the eastern portion of the Project area.

While an open pit hectorite mine is located immediately to the west-southwest of the Fort Cady Project, there are no residences within 7-miles of the Project. The closest publicly listed water well is also located approximately 7-miles west of the Project.

Ownership Fort Cady California Corporation (FCCC) purchased the Fort Cady Project from Fort Cady Mineral Corporation in the spring of 2017. The following is pertinent information required by SMARA:

Owner & Operator: Fort Cady California Corporation 16195 Siskiyou, Suite 210 Apple Valley, CA 92307 Contact – Cindi Byrns, Environmental Manager 702-927-3795 [email protected]

Representative: Cindi Byrns, Environmental Manager 702-927-3795 [email protected]

EIN: 82-3117298

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Owner of surface and mineral rights: FCCC holds land title for approximately 4,409 acres in or adjacent to the approved Project area under fee simple patented or privately held lands; surface areas privately owned with mineral rights held by the State of California; unpatented claims recorded and held by FCCC; and unpatented claims leased from Elementis Specialties, Inc. (operator of the adjacent Hector Mine). A listing of all claims if available in Appendix A

General County Plan Designation: Resource Conservation (RC) General BLM Plan Designation: Moderate Use

Project/Lease Area: The Project area is in portions of the following sections containing approximately 4,409 acres more or less: • Township 8 North (T8N), Range 5 East (R5E), SBBM, in San Bernardino County, California; Portions of Sections 22, 23, 24, 25, 26, 27, 34, 35, and 36

• T8N, R6E, SBBM; Portions of Sections 19, 20, 29, 30, and 31

Area to be Reclaimed: 343 acres of proposed surface disturbance

Estimated Operating Life: 30 years (or until April 24, 2049)

Estimated Mining Termination Date: April 24, 2044

Estimated Reclamation Completion: April 24, 2049

Reclaimed End Use: Open space

Fort Cady Project History Discovery of the Fort Cady borate deposit occurred in 1964 when Congdon and Carey Minerals Exploration Company found several zones of colemanite, a calcium borate mineral as part of an evaporite sequence, located between 1,330 feet to 1,570 feet below ground surface (bgs) in Section 26, TSN, R5E. (1993 Plan).

In September 1977, Duval Corporation (Duval) initiated land acquisition and exploration activities near Hector, California. By March 1981, Duval had completed 34 exploration holes. After evaluation of the exploration holes, Duval considered several mining methods; subsequent studies and tests performed by Duval indicated that in-situ mining technology was feasible. Duval commenced limited testing and pilot-scale solution mining operations in June 1981.

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Mountain States Mineral Enterprises Inc. (MSME) purchased the project from Duval in 1984 and in 1986, drilled additional wells and conducted an additional series of tests. MSME eventually sold the project to Fort Cady Mineral Corporation (FCMC) in 1989. FCMC began the permitting process, which resulted in a 1994 Record of Decision (ROD) from the BLM and an approved Mining and Reclamation Plan from San Bernardino County, the California Lead Agency.

Market conditions were such that the project was not constructed and was sold several times before being acquired by American Pacific Borate & Lithium (APBL) in March 2017. APBL is listed on the Australian Stock Exchange and conducts business in the US as Fort Cady California Corporation (FCCC).

There is significant commercial demand for borate products, such as boric acid (BA), colemanite and borax. BA is used in the manufacture of numerous industrial products including glass, fiberglass, fire retardants, insecticides, ceramics, and detergents. The operation will also produce gypsum, Sulphate of Potash (SOP), hydrochloric acid (HCl), and metal salts used in de-icing as byproducts. Preliminary market research indicates that the gypsum is marketable to local cement or soil conditioning industries and SOP, which is used as a fertilizer, is marketable to local agriculture operations. The SOP will generate HCl, for use either in the well field or for resale.

1.1.3 Summary of Technology Solution Mining In-situ leaching technology was developed commercially in the 1970s and involves the injection of a leachate through a permeable formation in the ground for selective dissolution of the ore mineral of interest in the ore body. The solution is subsequently recovered to surface for processing to produce a saleable product.

The technology has several technical, economic, and environmental advantages over other mining practices, including the following:

1. Lower capital costs (no earth-moving or ore-handling equipment),

2. Lower fixed and overall operating costs.

3. Flexibility of operation for selective mining (unlike open-pit operation, where all ore and waste must be removed, and underground operations, to a lesser extent).

4. Minimal discharge of solids, liquid, and gaseous effluent.

FCCC proposes to extract borate through the injection of a weak acid, such as hydrochloric, sulfuric and/or carbonic acid solution into the colemanite ore body, approximately 1,300 to 1,500 feet bgs. A chemical reaction between the acid and the ore forms boric acid. The boric acid pregnant leach solution (PLS) will be extracted by pumping or air-lifting to surface and then will be piped to the plant for further processing.

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The ore body is currently approximately 606 acres underlying private and public lands; it remains un-delineated to the southeast and may be expanded in the future. The well field will ultimately be comprised of approximately 250 to 500 wells, depending on recoveries from the ore body. The well field will result in approximately 273 acres of surface disturbance. Each well will be capable of both injection and recovery. Due to the low permeability of the ore body, FCCC will initially operate new wells using a “push and pull” method. The leach solution will be injected into a well and allowed to remain in the formation for an average period of 4 to 12 hours, or until the chemical reaction has reached equilibrium. The PLS will be recovered and pumped to either a solvent extraction facility, a colemanite facility, or a borax facility. FCCC is evaluating inclusion of some or all of these processes in the Fort Cady Project. Lithium occurs in the ore body and lithium production is also under evaluation.

Once the permeability within the ore body is increased, the injection solution may be recovered from a nearby well using a variety of well configurations as discussed in Section 3.2. At any one time, approximately one third of the wells will be in injection mode, one third in reaction mode, and the remaining third in recovery mode. Due to the natural variabilities in the evaporite deposit, well configurations and numbers will be modified as needed to maximize recoveries.

The boric acid PLS will be pumped from the well field at a rate to adequately feed the process plant. The general processing steps are:

• Clarification of the PLS • Solvent extraction to purify BA and increase BA concentration • Evaporative crystallization to generate pure BA crystals • BA crystal dewatering and drying • Regeneration of the weak raffinate by sulfuric acid to precipitate calcium and strontium, producing hydrochloric acid (HCl) • Dewatering and storage of the gypsum product for sale • Zero liquid discharge (ZLD) circuit for solids removal.

The on-site processing facilities will produce the following products to be sold and transported off-site in these approximate annual amounts based on the approved 90,000-ton boric acid production:

• Boric acid - 90,000 tons • Gypsum – 86,000 tons • SOP (potash used as fertilizer) – 40,000 tons • Hydrochloric acid – based upon well field requirements • Specialty Salts – based upon minerals recovered from the PLS

1.1.4 Ore Reserves RESPEC estimated the reserves in the January 2019 report (RESPEC, 2019):

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Ore in Tons: 11 million tons At Grade 5% B2O3 in Tons: 2.98 million tons

1.1.5 Land Holdings Status FCCC holds land title for approximately 4,409 acres, as follows: 240 acres of private lands, owned by FCCC; 269 acres of which the surface is owned by FCCC and the mineral rights are held by the State of California; 2,380 acres of unpatented claims on BLM lands, recorded and held by FCCC; and 1,520 unpatented claims leased from Elementis Specialties, Inc. (operator of the adjacent Hector Mine). The current status of land ownership in the Project area is shown on Figure I.1-3.

Private Property with Mineral Rights owned by FCCC FCCC owns two parcels totaling 240 acres: Parcel 0529-251-01: (1) NW ¼ of Section 25, T8N), R5E (160 acres); and (2) Parcel 0529-251-03: North ½ of the NE ¼ of the Section 36, T8N, R5E, SBBM (80 acres).

Private Property (Surface Ownership) with Mineral Rights owned by the State of California Parcel number 0529-251-04 totaling 269 acres is private property with exclusive rights to any surface use held by FCCC in perpetuity. The exclusive mineral rights are held or reserved by the State of California through the California State Lands Commission (SLC). FCCC has applied for a mineral prospecting permit and/or a mineral extraction lease with the SLC.

Unpatented Claims Recorded and Maintained By FCCC FCCC currently holds 2,380 acres of unpatented claims on BLM managed lands (see Appendix A for the complete list). FCCC holds the exclusive right of exploration, development and production of any mineral and related surface use and mining privilege contingent upon conducting annual assessment work or paying an annual assessment fee.

Unpatented Claims Leased from Elementis Specialties Inc. FCCC leases 1,520 acres of unpatented claims from Elementis Specialties, Inc. per a “Mineral Lease Agreement” (Agreement) made by and between FCCC and Elementis. The Agreement grants FCCC, the Lessee, the right to explore and mine the Property as described in the Agreement “for all purposes reasonably incident to exploring for, mining by solution mining, and any other mining method, surface or subsurface, subject to the Owner’s approval, reasonably exercised, extracting, milling, refining, stockpiling, storing, processing, removing, and marketing therefrom all borate and lithium minerals, and the products thereof subject to the exceptions in the Agreement.”

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Figure I.1-3: Land Ownership within the Project area

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1.2 Project Development 1.2.1 Mine Site Approval and Reclamation Plan Development and pilot plant testing have been conducted since the 1970s at the Fort Cady Project. An initial Mine Site and Reclamation Plan for the Pilot Plant was approved by the County in 1982 with a revision approved in 1987. The first Plan of Operations (Original Plan) was submitted in April 1990 and subsequently updated by the preparation of the 1993 Plan (referred to in this 2019 Revised Plan as the “Plan”). The 1993 Plan and the 1993 EIS/EIR were approved by the BLM and County in 1994.

1.2.2 Waste Discharge Permit FCCC currently has an active Waste Discharge Permit, 6-88-63, to construct and operate a Pilot Plant.

In March 2019, FCCC submitted an application to the Lahontan Regional Water Quality Control Board (LRWQCB) under California Code of Regulations (CCR), Title 27, Division 2, Subdivision 1, Chapter 7, Subchapter 1. Mining Waste Management, §§ 22470 - 22510 for a new waste discharge permit or exemption, as appropriate, to construct and operate the 90,000 tpy Project.

1.2.3 Air Quality Permit FCCC received authorization for a Dust Control Plan from the Mojave Desert Air Quality Management District (MDAQMD) in August 2018.

FCCC submitted a permit application in December 2018, also to the MDAQMD, for a 90,000 tpy boric acid plant. The application is for a minor source, covering the processing plant which includes the following processes: solvent extraction, borate purification/crystallization, sulfate of potash, gypsum, acid regeneration, and cogeneration. More detailed information on the processing facilities is available in Section 3.

1.2.4 Hazardous Waste and Toxic Control In accordance with CCR 27 §20220, FCCC will generate the following non-hazardous wastes: domestic garbage and maintenance generated used motor oil, greases and solvents. The domestic garbage will be collected in five-yard dumpster(s) and removed off-site by a contractor at least once per week. The garbage will be transported to the Barstow landfill. Used oils, greases and solvents will be generated by maintenance related activities. While not RCRA hazardous wastes, used petroleum hydrocarbons are California Hazardous Wastes and will be managed in accordance with CCR22 Division 4.5.

FCCC will comply with Plan Conditions 47 and 48 to prepare a Business Plan detailing plans for emergency release of hazardous materials or waste. The Hazardous Materials Division of the San Bernardino County Fire Department is designated as the Certified Unified Program Agency or "CUPA" to focus the management of specific environmental programs at the local government level. FCCC will prepare or update its Business Emergency/Contingency Plan to include operations for the site as described. The Business Plan includes a hazardous materials inventory

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Revised 2019 Plans Fort Cady Project and Spill Prevention Control and Countermeasure Plan (SPCC), if required, to ensure that on-site materials are stored appropriately and contained, in the event of an uncontrolled release, utilizing Best Management Practices (BMPs). Fuel storage specifications apply to all above ground fuel containers and tanks.

1.2.5 Office of Building and Safety – Building Permit FCCC will comply with Conditions 33, 34, and 49 with respect to obtaining building permits for structures on-site.

1.2.6 Groundwater Quality This Section provides a summary of the groundwater quality in the Project area. More detailed information is available in Section IV of this Plan. Groundwater quality in the Project area does not meet California Drinking Water Standards for Total Dissolved Solids (TDS) or several metals. The LRWQCB determined the groundwater in the Project site is inferior for domestic purposes due to TDS and fluoride concentrations exceeding drinking water standards (6-88-63). Analysis of formation water extracted from the ore zone, indicates that the water is highly saline, with TDS concentration averages of 32,000 milligrams per liter (mg/l), significantly higher than the recommended California drinking water standard of 1,000 mg/l.

Groundwater in the Project area does not currently serve as a source of drinking water and, in view of its high TDS and metals content, depth to water, and low permeability, cannot now and will not in the future serve as an “underground source of drinking water” (USDW) as that term is defined in 40 CFR §144.3.

As part of the 2018 Fault B Program, FCCC evaluated groundwater quality from wells in and around the Project area. The groundwater within the mineralized area is different from the groundwater west of Pisgah Fault or east of Fault B. These data are presented in Sections I.2.0, Section IV and Appendix B.

1.2.7 Hydrogeology This Section provides a summary of the groundwater quality in the Project area. More detailed information is available in Section IV of this Plan.

The central portion of the Project area, where the ore body is located, is hydrologically confined. A block of clays and mudstones makes up much of the central Project area and encloses the colemanite ore body lens from above and below. The mudstone generally has low porosity and permeability, and thus low hydraulic conductivity. Notably, evaluation of the hydraulic properties of the ore body determined that the permeability of the formation is very low, ranging between 1.35 x 10-9 centimeters per second (cm/sec) and 2.9 x 10-10 cm/sec. Wells completed within the ore body have been observed to require months to re-equilibrate following injection or pumping.

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The faults on the east and west sides of the ore body also provide a barrier to groundwater movement. As discussed in more detail Section 2.0, the groundwater levels on opposite sides of the Pisgah Fault differ by 100 feet or more. The groundwater on opposite sides of Fault B differ by approximately 17 feet. The observed differences are due to the presence of clayey gouge in the fault zones forming a relatively impermeable barrier to groundwater movement, as well as significant facies changes created by the offset across the faults. The groundwater quality east of Fault B, west of Pisgah Fault and in the ore body are significantly different, as seen on the Piper Plots and Stable Isotope Plot in Section 2.0. Accordingly, the groundwater in the mineralized zone of the Project area is confined on all sides of the ore body.

The Fort Cady Project area and mineral deposit is ideally situated for solution mining. Given the Project’s isolated area and the absence of residences, public water wells, and USDWs, as well as the very poor water quality within the Project’s mineral zone, there is no beneficial use other than solution mining for the mineral deposit area. The ore body is buried deep within a geologic block that is bounded to the west and to the east by the Pisgah and Fault B faults, respectively. The ore body is confined from above and below by low permeability mudstones. The Fort Cady Project will not have any adverse impact on USDWs.

1.3 Commercial Plant Operations

1.3.1 Applied Technology In-situ mining of the colemanite deposit is feasible for the following reasons:

• The ore body is enveloped in impermeable clays; • The ore formation is saturated with mineralized groundwater; • The calcite content of the ore is low; • Minerals, other than colemanite and calcite in the deposit are relatively insoluble; and • Colemanite is the most permeable component in the formation.

The in-situ solution mining technology has advantages in terms of environmental and final reclamation planning:

• Solution mining by the cyclic process of regeneration and recycling of hydrochloric acid from calcium chloride does not create waste products. Only borate product and gypsum, which is chemically inert, is produced from the processing pregnant leach solution from the wells; • In-situ mining precludes the need for surface disposal of mill tailings or development waste rock; • The extent of environmental disturbance both physically and visually is much less as compared with the traditional mining methods of open-pit or underground-mining methods; and • Solution mining does not require mine shaft sealing or reclamation of an underground mine.

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The leaching of the colemanite in the ore body is characterized by the following equation:

[2CaO • 3B2O3 • 5H2O] + 4HCl + 2H2O → 6H3BO3 + 2CaCl2 colemanite + hydrochloric acid + water → boric acid + calcium chloride

The process design consists of supplying heat to the injection solution in order to improve the reaction kinetics of the leaching process. Figure I.1-7 shows the boric acid solubility curve versus temperature.

1.3.2 In-Site Mining As discussed in Section 2.0, the Fort Cady Project ore body is highly favourable for in-situ solution mining for several reasons:

1. The ore body is located deep, and below water tables; 2. The ore body is confined vertically by impermeable layers; 3. The ore body and its confining layers are weak in structural strengths and easily rubblized; and 4. The faults in the area further confine the ore zone for in-situ leaching.

The outline of the colemanite ore body is based upon exploration work completed by previous owner/operators and verified by L. Fourie, P. Geo. (Fourie, 2018). Figure I.1-4 presents the underlying ore body, EIS/EIR Project Boundary and the proposed well locations. The Ore Body, as currently defined, consists of 606 acres of ore body underlying both private and public lands. The middle point of the Ore Body is Longitude -116.417 and Latitude 34.752. Dimensions of the ore body are presented in Figure I.1-5. Figure I.1-6 provides a close-up view of the existing wells used to define the ore body.

The Fort Cady ore zone is at approximately 1,300 to 1,500 ft bgs and ranges between 65 ft – 262 ft thick. For the production of 90,000 tons per year (tpy) boric acid, approximately 1.03 million tons (Mt) of ore will be dissolved at a 70% extraction rate. FCCC plans to operate all wells in the well field in a similar manner and from a centralized injection and extraction piping system.

Well field Operating Parameters: The well field will be in continuous operation. At any point in time, recycled or make-up water with less than five percent acid will be injected to approximately 1/3 of the wells, approximately 1/3 of the wells will be resting while dissolution is occurring at depth, and Pregnant Leach Solution (PLS) will be recovered out of the remaining wells. The entirety of the well field can be shut in should the need arise.

a. Average daily rate and volume to be injected: The average daily rate of injection for each well is 25 gpm. The volume will vary with time as leaching occurs. b. Maximum daily rate and volume to be injected: The maximum daily rate of injection is anticipated to be 75 gpm. The volume will vary with time as leaching occurs.

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c. Average and maximum injection pressure: Average injection pressure is anticipated to be 150 psi. The maximum injection pressure is anticipated to be 300 psi. FCCC will operate all wells in its well field below the well-head fracture pressure of 356 psi. See Attachment I for additional information on fracture pressures. d. Nature of annulus fluid: the annular space between the casing and geology will be cemented from top of ore body to surface. The fluid in the annular space between the tubing and casing will either be a weak acid solution (injection solution) or boric acid (pregnant leach solution). e. Injection solution: the injection solution will be a weak acid solution (<5% HCl and 95% recycled process water and/or make-up water). FCCC may also concentrate boric acid solutions by recirculating heated PLS back into the well. f. Pregnant Leach Solution: PLS is the product of a chemical reaction between the injected weak acid and the alkaline elements in the colemanite ore body forming a boric acid solution. g. Extraction: PLS will be extracted by airlift or pumping and surface pumping then processed to produce boric acid, colemanite and/or borax.

The amount of HCl injected determines the reaction, and thus is one of the key control variables for the mining process. Amount of HCl in the injection solution must be optimized to make adequate reactions with colemanite, while not being excessive in concentration as not to react with anhydrites, primarily CaSO4, and other minerals within the ore zone.

The return PLS from the mine is where sampling and measurements will be conducted to test the effectiveness of the reaction. Acid concentration measurements via titration for boric acid and HCl, and pH measurements are good initial indicators for effectiveness of reaction.

The pH of a sample of solution withdrawn from the well would be tested, and if it is found to be low (i.e., the solution is still too acidic), the injection solution would be left in the well for a longer period. Once the chemical reaction is determined to have reached equilibrium, the boron-rich solution would be recovered by use of airlifts and surface pumps and pumped to the processing plant. With this mode of operation, approximately one-third of the wells would be in the injection mode, one-third in the reaction mode, and the remaining one-third in the recovery mode. The mode of each well will be inter-changeable. Over time, as resources are exhausted in specific localities, new wells will be drilled to replace those that are depleted.

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Figure I.1-4 – Area Map with Ore Body

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Figure I.1-5: Approximate Ore Body Dimensions

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Figure I.1-6: Ore Body and Historic and Known Wells

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Figure I.1-7 Boric Acid Solubility Curve Versus Temperature

2.0 Ore Processing Method

2.1 Introduction The total area of disturbance resulting from the mining operation would consist of approximately 340 acres, a reduction of approximately 2 acres from the 1993 Plan. Significantly, the Revised Plan reduces rights-of-way disturbance by another 44 acres. The acreage of the Project site is presented in Table 2-1 and is described in more detail in Section 2-10.

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Table 2-1: Acres to be Disturbed and Right-of-Way Length Width of Acres To of ROW Acres of Facility Be ROW (In feet) ROW Disturbed (in feet)1 Well Field 273 N.A. N.A. N.A. Process Plant 10 N.A. N.A. N.A. Gypsum Storage Facility 16 N.A. N.A. N.A. Electrical Transmission Line 0 2 N.A. N.A. N.A. (existing) Water Pipeline (western areas) 15.6 N.A. N.A. N.A. Water Pipeline (PW-1, 2 to plant)8 2.9 N.A. N.A. N.A. Railroad Spur 7.6 3 10,560 25 29.2 Natural Gas Pipeline 0 4 10,560 25 5.9 Access Roads #1 13.4 5 N.A. N.A. N.A. #26 N.A N.A. N.A. N.A. #37 1.5 N.A. N.A. N.A. TOTAL ACRES TOTAL

TO BE ROW 35.1 340.0 DISTURBED: ACRES: 1 Several of the facilities would not require rights-of-way, either because they would be placed on private land or because they are not the type of facility to which rights-of-way apply. No ROW is required for support facilities to be run by the operator for the Project and therefore, are considered as part of the Plan of Operations. These are designated by “N.A.,” (not applicable), in the table above. 2 The existing electrical transmission line extends approximately 3 miles from Route 66 south and east to the process plant, therefore, no additional land disturbance would result. 3 Only 25 feet of the 100-foot wide railroad right-of-way would be disturbed, hence, the disparity between the total right-of-way acreage versus the total disturbed acreage. The railroad spur will not be developed for the current approved 90,000-ton operations. 4 The right-of-way for the natural gas pipeline would occur within the existing Power Line right-of-way; therefore, no additional land disturbance would result. 5 Roads and pipelines within the Project Boundary are part of the process and no ROW is required. Access Road #1 will not be constructed as part of this Revised Plan. 6 Access Road #2 is no longer needed with re-location of the process plant. 7 Roads and pipelines within the Project Boundary are part of the process and no ROW is required. Access Road #3 will not be constructed as part of this Plan. 8 Proposed water line from PW-1 and 2 to the re-located process plant is approx. 1.2 miles (or 2.9 acres); 0.7 miles on BLM managed lands or 1.7 acres and 0.5 miles or 1.2 acres on FCCC land. No ROW is required as the water wells and pipelines are support facilities to be run by the operator for the project and therefore, are considered as part of the Plan of Operations.

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2.2 Well Field Facilities The Fort Cady Project ore body is highly favourable for in-situ solution mining for several reasons:

1. The ore body is located deep, and below water tables; 2. The ore body is confined vertically by impermeable layers; 3. The ore body and its confining layers are weak in structural strengths and easily rubblized; and 4. The faults in the area further confine the ore zone for in-situ leaching.

2.2.1 Well Field Layout There are various ways of developing the well field for in-situ leaching, including “push-pull”, where wells function as both injection and recovery wells; line drive; and multiple spot patterns.

In addition to the vertical pattern options, horizontal drilling and directional drilling for well development is also an option for the Fort Cady ore body. The mine well field development and the pattern will ultimately depend upon recovery and cost benefit analysis of various patterns and options. Directional drilling may be utilized to allow multiple completions from one borehole.

Due to low permeabilities, the Fort Cady well field is planned to be operated initially in a "push and pull" mode, until wells naturally connect. At that time, separate injection and recovery wells can be utilized. When this occurs, one of the well field patterns will be used, converting the push- pull wells into separate production and recovery wells as required, to optimize the operation.

The schematic of the proposed well field with well locations and piping layout are presented in Figure I.2-2. High Density Polyethylene (HDPE) plastic has been selected as the material of construction for the surface piping. Project experience has shown that HDPE is resistant to the harsh desert climate for periods of time greater than 10 years. HDPE is also very acid resistant and can withstand higher temperatures than equivalent PVC without loss of working life. The primary injection and recovery trunklines will be identical 8” HDPE pipe and the secondary distribution piping will be 2” HDPE pipe. HDPE is also very flexible, thus eliminating a large number of 90-degree and 45-degree elbows.

2.2.2 Mining Sequence The ore body well field will encompass approximately 273 acres of disturbed lands, providing sufficient area capable of supporting the estimated 250 to 500 wells required over LOM. Well flow rates are estimated to be 75 gpm during the PLS recovery phase. To accommodate well field planning and mine scheduling, it is estimated that net recovery flow rates are 25 gpm to reflect that each well is only in recovery mode for one-third of the time. Based on well recovery flow rates and PLS boric acid head grade (typically 3.0-5.0% H3BO3), of which normally <0.5% H3BO3 is re-injected, each well will produce approximately 1,700 tons of BA per year with an estimated life of 8 years. It is anticipated that five wells will be constructed during the first year of operations. The next years’ wells will be included in the annual budget. The U.S. Environmental Protection Agency (EPA) is the regulatory authority for the in-situ injection well field operations, as discussed

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Revised 2019 Plans Fort Cady Project in the next section. Accordingly, it will hold the bond for that part of Project operations. The well field bonding cost estimate will therefore be reported to EPA annually. For the remainder of Project operations, the San Bernardino County Land Use Services Department (LUSD) is the State of California Mining and Reclamation (SMARA) lead agency and holds the Financial Assurance Cost Estimate (FACE), which is also updated annually.

Infrastructure will be developed in sequence with the well field and will consist of main trunk lines and branch lines.

Figure I.2-1: Typical Well Field Push/Pull Sequence

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Figure I.2-2: Schematic of the Proposed Well Field

2.2.3 Well Field Construction All Class III injection wells are permitted through the EPA's Underground Injection Control (UIC) program regulated under Title 40 of the Code of Federal Regulations Parts 144 - 146. The Safe Drinking Water Act (SDWA) establishes requirements and provisions for the UIC program. FCCC has applied for a Class III Area UIC permit for the injection well field operations. All injection wells will be designed, drilled, constructed, operated, monitored, and closed in accordance with the UIC Permit. The Class III Area permit authorizes the construction, operations and closures of all injection wells. The EPA will hold the bond for all Class III wells.

Wells are anticipated to be located on a 200 - 250 feet spacing interval. The average depth will be 1,500 feet, to the bottom of the ore zone. Wells will be drilled using conventional rotary technology, although core rigs may be used to obtain ore for additional testing. Hole orientation and caliper surveys will be conducted to ensure the borehole does not deviate greater than 18- inches per 100 vertical feet.

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The basic well design utilizes a 12¼-inch hole, using conventional rotary technology, drilled completely through the ore body. A large diameter hole is necessary to accommodate 7-inch fiberglass (FRP) casing. The FRP will be slotted (perforated) through the ore zone, or a combination of solid and slotted sections, and solid to surface.

The PLS will be either pumped or air-lifted to surface. Hydrochloric acid is corrosive and, thus submersible pumps currently cannot be used. Unless a compatible pump can be identified, airlift will be the main means of recovery from the well. Air-lifting injects compressed air within the recovery line which provides up flow of the PLS to the surface. Compressed air is injected through an air tube, forcing PLS up through either the PLS tubing or annular space to the surface, where surface pumps with internally robust parts will then take the PLS to the processing plant.

The well casing thus must be adequately sized to fit pipelines for recovery (~4” diameter), and air (~2”). The casing is then extended to a pre-selected depth above the ore body, or down to a specified depth within the ore body with perforations in the casing, with double cement baskets on the bottom joint of casing and five centralisers located at intervals along the length of the casing. The casing is then cemented to the surface. After the cement has set, the well is re-entered, and a string of drill pipe is run to the bottom. A combination of air and foam is used to clean the casing and open-hole interval after development.

Perforated well casing at critical sections, with the use of packers at predetermined depths, will control the leaching zone within the ore body to optimize recovery. FCCC plans to evaluate horizontal directional drilling for future developments but will implement operations using vertical wells.

2.2.4 Well Completion Details Water and monitor wells will be completed in compliance with guidance set forth in California Department of Water Resources Bulletin 74-90 and the requirements of the County. Each borehole will be drilled using mud rotary and/or air drilling methods.

Once the borehole has been drilled, wireline geophysical testing will be completed. Wireline geophysics will include, at a minimum, Gamma Ray, Induction and Caliper logs. Once the survey has been completed, the borehole will be conditioned for well installation.

Well materials will be American Water Works Association (AWWA) compliant for the proposed size and depth of each well. Well screen and blank casing will be installed in segments. Each joint will be positioned in place with double lifting collars in alignment with pre-welded tabs. Each joint will be welded or installed in accordance with AWWA specifications by a qualified person. Each respective casing joint (screen or blank casing) will be installed in sequence per the proposed well diagram or as directed by field personal based on the geology drilled.

Once the well casing has been installed in the borehole, tremie pipe will be installed alongside the casing and annular materials will be pumped through tremie pipe from the bottom of the hole to

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Revised 2019 Plans Fort Cady Project eliminate potential for bridging of materials. Well stabilizer or gravel pack will be installed by tremie to within 1 foot above the well screen. The depth of the gravel pack will be periodically checked with tag line to ensure the correct depth is reached. A layer of coated bentonite pellets will be installed by tremie pipe and the depth tagged. Per the well diagram, a cement bentonite slurry and sanitary cement seal will be installed. The seal will be installed by pumping the grout through the tremie pipe (positive displacement) to avoid bridging. The depth of the bentonite cement grout annular backfill will be inspected via tag line to verify the depth of sanitary seal. This activity is expected to occur in the presence of the County inspector. Once verified, the cement sanitary seal will be installed via tremie pipe until cement has reached the surface and the County well inspector is satisfied with the quality of the seal. See Figure I.2.3 for typical proposed well design.

Well heads will be constructed of fiberglass (FRP) for its corrosion resistance and structural strength. In general, exterior well-head parts will be identical for both injection and recovery wells. Airlifts with air de-aerating tanks (foam knock-out tanks) will be used to recover the pregnant borate solution from the ore body. The airlift piping depth will be set at varying depths. Airlifting allows for solution mining without exposing pump internal parts to the acidic solution from the ore body.

Airlifting works with air injection into the well casing, forcing the PLS up to be recovered at surface level. The PLS exits out of the well into a foam knockout tank and is then pumped to the plant (Figure I.2.4).

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Figure I.2-3: Proposed Well Design

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Figure I.2-4: Airlifting from a Well

2.2.5 Well Monitoring In compliance with 40 CFR §§144.33, 148.28(b) & (g)(3), FCCC has submitted a monitoring plan to EPA for all injection/recovery wells as part of its Class III Area UIC permit application.

Due to the low permeability of the ore body and confining layers, it is not anticipated that solution mining fluids will extend beyond the ore body. The following monitoring measures are stipulated to provide additional assurance, as required by Condition 75:

1. Monitoring of piezometric levels within the mining area and vicinity. 2. The hydraulic gradient in the ore zone will be evaluated either by installing a grouted in vibrating wire piezometer, or similar method. 3. Monitoring well(s) will be installed in a down-gradient direction from the ore zone and monitored periodically to assess changes in formation water chemistry, if any, to evaluate any changes that may result from migration of mining process solution. 4. Make-up Water Wells located west of the Pisgah fault will be periodically analyzed for chemical changes, if any, which might indicate migration of the mining process solutions from the mining area. 5. Following completion of mining activities, extraction wells will be pumped until low-pH fluids have been removed and fluids of normal pH are produced.

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a. Groundwater monitoring will include: 1. Obtaining groundwater levels from wells that are not being actively used for boric acid production but have not been closed due to potential future use. 2. If applicable, water levels will be used to assess changes to flow gradients. 3. A down-gradient monitor well will be installed prior to beginning production. The well will be located down-gradient from the first leaching zone but east of the Pisgah fault. The well location will be approved by BLM and San Bernardino County. 4. Well MWW-1 will be sampled at least quarterly for the first year and then annually thereafter. Although it is not anticipated that mining solutions have the potential to cross the Pisgah fault, this well is located immediately west of the fault and will detect any changes due to solution mining. At a minimum, samples will be analyzed for pH, conductivity, TDS, and boron. b. Both formal and informal routine inspections will be conducted of all surface piping and well heads. Inspections will look for leaks or other evidence of potential problems. Observations of potential problems will immediately be reported to a member of management and the area in question will be shut-down and repaired, or permanently removed from service as applicable. c. A subsidence benchmark survey grid has been established and approved by the BLM. The benchmark survey will be conducted annually to measure any subsidence due to solution mining activities.

2.2.6 Well Field Corrective Actions The following corrective actions are in line with 40 CFR 144.55 for Class III Area wells:

1. There are no USDWs near the colemanite ore body that can be affected by solution mining. 2. The colemanite ore body is located within a low permeability evaporite sequence, which is encapsulated by lower permeability mudstones and claystones. 3. The colemanite ore body is further isolated from potential USDWs by two (2) confining faults, the Pisgah Fault and Fault B. 4. San Bernardino County Division of Environmental Health Services (DEHS) is the Lead Agency for California Department of Water Resources (CDWR). DEHS issues permits for drilling and abandoning water wells and monitoring wells. FCCC follows the CDWR and DEHS regulations regarding both completion and plugging and abandoning these types of wells, including all future updates or modifications. 5. San Bernardino County Land Use Services Department (LUSD) is the State of California Mining and Reclamation (SMARA) lead agency. The County approved the Mining and Land Reclamation Plan for the Fort Cady Project in 1994. LUSD conducts routine inspections of the facility and holds the Financial Assurance Cost Estimate (FACE), which is updated annually. FCCC follows conditions of acceptance for the Mining and Land Reclamation Permit, including maintenance and closure of wells.

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6. If a water or monitoring well failure does occur, FCCC will close the well in accordance with the County and State requirements. If a production well failure occurs, FCCC will close the well in accordance with its UIC Area permit requirements. 7. Testing by previous owner/operators indicated a formation fracture pressure of 354 pounds per square inch (psi). FCCC has not identified any documents indicating any historic wells were operated in excess of this fracture pressure. FCCC will not operate any well above 300 psi to ensure that fractures do not occur in the ore body due to overpressure. (Reed & Associates, 1981).

2.2.7 Plugging and Abandonment Plan FCCC will conduct water and monitoring well plugging and abandonment (P&A) in accordance with the statutory requirement set forth in California Department of Water Resources Bulletin 74- 90; and the requirements of San Bernardino County. Including Condition of Approval No. 31. FCCC will P & A production wells in accordance with its UIC Area permit requirements.

Following P&A activities, surface reclamation and restoration will be undertaken to match the existing landscape in accordance with the Surface Mining and Reclamation Act (SMARA) requirements (California Code of Regulations, Title 14, Division 2, Chapter 8, Subchapter 1).

2.3 Boric Acid Processing Plant The beneficiation of ore is any process that improves (benefits) the economic value of the ore by removing the gangue minerals, which results in a higher-grade product (concentrate) and a waste stream. [40CFR 261.4(b)(7)].

The Fort Cady Project processing facilities will all be located on privately owned land, on the northwest quarter of Section 25, T8N, R5E. Only the well field will be located on BLM lands. The following steps convert the PLS, pumped from the wells, into saleable products.

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Figure I.2-5: Conceptual Process Flow Diagram

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3.4 Solvent Extraction

3.4.1 Solvent Extraction and Crystallization The boric acid PLS will be pumped from the well field at a rate to adequately feed the process. The general processing steps are:

• Clarification of the Pregnant Leach Solution (PLS) • Solvent extraction to purify BA and increase BA concentration • Evaporative crystallization to generate pure BA crystals • BA crystal dewatering and drying • Regeneration of the weak raffinate by sulfuric acid to precipitate calcium and strontium, producing hydrochloric acid (HCl) • Dewatering and storage of the gypsum product for sale • Zero liquid discharge (ZLD) circuit for solids removal. • Sale of products, including: o BA o Gypsum o SOP o HCl

Figure I.2-5 shows the conceptual flow diagram for the process plant.

The Solvent Extraction (SX) process upgrades the PLS from the boric acid from the well field to approximately 8% boric acid while rejecting non-BA materials, including chlorides. PLS pumped from the well field is first clarified and then filtered through a multimedia filter bed to remove insoluble materials. In the SX circuit, the PLS flows through the following steps: 1. Solvent extraction circuit (SX) 2. Washing circuit (scrubber) 3. Stripping circuit

In the SX Circuit, the boric acid is readily and preferentially extracted using a solvent, such as iso- octanol and kerosene. The solvents selected are specific to BA and are unable to extract non-boric acid anionic or cationic metals allowing them to flow through for subsequent capture.

After SX, the boric acid solution is scrubbed to remove any remaining unwanted elements or remaining acids. The stripping circuit then separates the solvents from the BA. The stripped solution is held in a tank to allow separation of the solvents from the water. The selected solvents are immiscible, meaning they do not commingle with water and have a specific gravity (SG) of less than 1, so they float at the top of the tank. The solvents are skimmed from the top of the tank for reuse in the SX circuit. Recycle water is drawn from the bottom of the tank for use as injection

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Revised 2019 Plans Fort Cady Project solution. This process prevents solvents from being injected into the well field. Approximately 85% of the process water is recycled as injection solution.

The BA solution then moves to the crystallizers, where the boric acid is crystallized, dried and loaded for shipment. Gypsum and metal salts are recovered from the non-BA solution, processed as described in the next section, and sold as product.

The ZLD circuit is designed to extract solids out of the recycle stream, thus eliminating a need for tailings or other waste disposal alternatives. The crystallizer and the filter belt process the in- process streams to extract out the solids. The solids will be placed in the GSF and sold as product.

2.4.2 Gypsum Production and Acid Regeneration When the BA flows to the crystallizer from the solvent extraction circuit, the non-BA solution is directed to the gypsum and regeneration circuits. The regeneration circuit precipitates calcium and strontium as sulfates while generating hydrochloric acid.

Approximately 4% of the non-boric acid (raffinate) stream will be directed to re-generation. The raffinate liquor is reacted with sulfuric acid to precipitate gypsum (calcium sulfate) and strontium sulfate while regenerating hydrochloric acid for return to the well field.

To minimize water losses, precipitated gypsum will be thickened then filtered through a pressure filter to produce a 75-80% solid cake suitable for dry stacking. A small amount of lime will be added to this filter cake to ensure neutralization of the filter cake. The dry stacked gypsum will not lose water to the ground, water loss will be primarily through evaporation. Gypsum’s propensity to hold water will also minimize windblown losses.

The GSF will encompass up to 16 acres of land. The area is of sufficient size to store more than 12-months of product but is anticipated to generally have a low inventory. The GSF design includes a set of 6-foot-high diversion berms to channel the contact runoff water (stormwater) through a notch and into the stormwater retention pond (see Figure I.2-7). The pond is designed to handle the 100-year, 24-hour storm event and includes an access ramp to clean out any accumulated sediment, if needed. Waters collected in the lined pond will be piped to the process facility for use as make-up water.

While the footprint (16 acres) and location of the GSF remains unchanged from the 1993 Plan, FCCC has modified the design of the GSF to maximize storage capacity and facilitate product management. The facility will utilize a series of six-foot berms, rather than a dam and spillway, to route stormwater to a down-gradient pond. There will be no dam. This design is safer, is more conducive to efficient gypsum storage, and is responsive to Condition 105 for desert tortoise protection. The down-gradient pond will be designed to retain water to be pumped to the plant for use a make-up water.

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As a process component, detailed designs for the GSF will be submitted to San Bernardino County for their review and approval. The substrate will be grubbed and compacted prior to deposition of gypsum. The bottom five (5) feet of gypsum will be compacted to prevent liquefaction in case of an earthquake.

2.5 Sulfate of Potash The sulfate of potash (SOP) facility will be located within the footprint of the 10-acres processing plant facility approved in the 1993 Plans. The boric acid processing facility is complemented by a Mannheim furnace-based production plant yielding up to 40,000 tpy of potassium sulfate (SOP) through the high-temperature reaction of potassium chloride (aka KCl or muriate of potash (MOP)) with sulfuric acid (SA). Off-gas from the high-temperature process is rich in hydrochloric acid (HCl) gas, which is scrubbed with process water to produce a by-product stream of aqueous HCl that will be used in the well field or sold as a commercial product.

2.6 Processing Facilities The processing plant will be modular, such that production expansions can occur by simple additions of equipment with the same basic arrangement. The plant arrangement consists of discrete process areas, connected via pipelines. The facility civil design will incorporate the existing structures to the maximum amount practicable and will incorporate stormwater designs, routing upgradient stormwater around the facility and capturing stormwater falling within the facility for use as make-up water.

All facilities processing chemicals will have cement foundations with lips to prevent spills or releases to the environment. All spilled materials will be cleaned up as soon as practicable and reused in the process if possible. Any materials which cannot be reused will be analysed for hazardous waste characteristics and disposed of at an appropriate facility. Additionally, the maintenance shop will be on a cement foundation with containment.

Support buildings, such as the office building, operator control rooms, lab and quality control building, and other areas for employees, will be in modular facilities. Modular facilities will be located on graded gravel topped areas.

FCCC is beginning the detailed engineering process. Table 2-2 from the 1993 Plan provides information on the types, dimensions and amount of equipment. FCCC will provide the County and BLM with updated equipment information at the end of detailed engineering.

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Table 2-2 - Plant Facilities and Equipment Equipment Description Approx. Approximate Size Number Acid regeneration tanks 5 10’ dia x 10 H Belt filters 2 120 square feet Filter repulp tank 2 6’ dia x 6’ H Plate and frame filters 2 48” x 48” 45 chambers Thickener 1 35’ dia 6’ H Thickener over flow tank 1 12’ dia 12’ H Thickener under flow tank 1 6’ dia 6’ H Gypsum neutralization tank 2 6’ dia 6’ H Injection tank 4 29’ dia 20’ H Regenerated solution tank 1 22’ dia 22’ H Hydrochloric acid storage tank 2 16’ dia 33’ H Sulfuric acid storage tank 2 16’ dia 33’ H Lime make up tank 1 12’ dia 12’ H

2.7 Product Loading and Shipping Solid boric acid will either be packaged into bags or supersacks for transport. Gypsum will be loaded into trucks directly from the GSF. Liquids, such as any hydrochloric acid available for commercial sale will be transported by truck.

Loadout for delivery and shipment, as well as the parking lot will be paved.

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Figure I.2-6: Conceptual Gypsum Storage Facility

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2.8 Cogeneration and Ancillary Facilities “The primary source of electricity would be an on-site cogeneration facility; however, Southern California Edison Company (SCE) would provide back-up electrical supply. Electrical power will be available at all times to power the water supply pumps. Because the process requires both electrical energy and heat, a cogeneration facility would be located in the main process plant. This facility would be made up of a four-kilowatt (kW) natural gas-fired turbine generator equipped with a waste hear recovery boiler, which would utilize the hot exhaust gases created during the burning of the natural gas. The waste heat recovery boiler would also be equipped with additional natural gas burners to increase steam capacity when necessary.” Plan § 3.8.

“A natural gas-powered conventional generator set will be used in conjunction with the turbine to absorb the shifts in electrical demand. In addition, utility interconnection facilities would be provided to permit acceptance of power from SCE as needed, and the possible sale of surplus power to the utility in return.” Id.

As contemplated by the 1993 Plan, a transmission line was extended to the pilot plant. The existing 3-mile electrical transmission line extends from Route 66 south and east to the substation located at the process plant. “This line is above-ground on standard pole anti-perching configuration.” Id.

“Other ancillary items would include a main electrical substation and transformer area, a process and fire water storage area, and a natural gas station with meter. Process storage tanks would contain the fire protection and general process water supply, complete with pumps and various piping systems to deliver the water.” Id. The powerline right-of-way contemplated by the 1993 Plan is not currently required.

“Since process water is unsuitable for drinking purposes, up to approximately 150 gallons per day of bottled drinking water would be imported. Alternately, potable water may be purified from process water using purification procedures. Sanitary sewage from the offices and process plant washroom areas, approximately 50 gallons per person per day, would be directed to a septic tank and tile bed system. The septic tank and tile bed system would be located adjacent to the northwest corner of the process building and would be approximately 100 feet x 200 feet in size.” Id.

2.9 Process and Storage Tanks Table 3-2 lists the process and storage tanks required for the approved operations. There are no changes in this section between the 1993 Plan and this Revised Plan. “A process water surge tank would contain non-potable water for use at the process plant. This tank would be 40 feet high and 40 feet in diameter and would be equipped with two centrifugal pumps.” Plan § 3.9.

“The majority of the process tanks (e.g., the solvent extraction loading cells, dissolving tanks, etc.) would be located at the process plant. Areas containing tanks would be located at both ends of the process plant on cement pads enclosed by cement berms. These bermed areas would be designed to contain process spill or storm water falling within the bermed area. Each bermed area would

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Revised 2019 Plans Fort Cady Project contain a below-grade sump equipped with a high-capacity pump and pipe manifold system capable of delivering the collected fluid to the desired location.” Id.

“Storage tanks would be located near the process plant in non-permeable, berm-enclosed containment areas. These areas would be capable of holding 1.5 times the volume of the largest tank enclosed within them.” Id.

2.10 Railroad Spur, Natural Gas Pipeline and Access Roads The railroad spur will not be developed for the current approved 90,000 tpy operations.

As the railspur will not be constructed as indicated in the 1993 Plan, and the plant location will be moved onto private lands, the natural gas pipeline will be moved to align with the existing power lines.

Access to the plant will now be using existing roads.

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3.0 Mine Waste

3.1 Recovery Process Solution mining by the cyclic process of regeneration of hydrochloric acid from calcium chloride does not create waste products. Only borate product, chemically inert gypsum and limited salts are produced. There will be no overburden, waste rock or materials, or waste and tailings from processing.

There are no existing or proposed hazardous waste storage or waste treatment facilities within the Project area. All facilities processing chemicals will have cement foundations with lips to prevent spills or releases to the environment. All spilled materials will be cleaned up as soon as practicable and reused in the process if possible. Any materials which cannot be reused will be analysed for hazardous waste characteristics and disposed of at an appropriate facility. Additionally, the maintenance shop will be on a cement foundation with containment.

As discussed in Section 3 below, the Zero-Liquid-Discharge (ZLD) circuit is designed to extract solids out of the recycle stream, thus eliminating a need for tailings or other waste disposal alternatives. The crystallizer and the filter belt process the in-process streams to extract out the solids. The solids will be placed in the GSF and sold as product.

3.2 In-process Solutions The pregnant liquor (PLS) contains a solution of borate product, sodium and calcium chloride, and a residual amount of hydrochloric acid. At the plant, it will be processed in fiberglass process equipment using construction materials that are compatible with the chemical constituents of the solutions. This process does not generate waste.

3.3 Gypsum Storage Facility The following language is from WDR 6-95-30 regarding the ore body and gypsum storage facilities:

“Since the project involves a subsurface beneficiation process, the materials injected to the subsurface Project area are not considered a waste. The subsurface Project area and surface gypsum deposition area are unclassified and do not constitute classified waste management units. The project will result in temporary degradation of groundwater quality in the subsurface Project area but does not require a designation of beneficial uses because the aquifer quality will be restored after the termination of the project. If beneficial uses do become redesignated, then it may not be necessary to restore the aquifer quality to pre-project levels. The injection fluid does not constitute a waste unless it migrates from the subsurface Project area boundary or remains in the subsurface Project area after completion of the project. The wetted gypsum to be deposited in the unlined gypsum deposition storage area constitutes a by- product for sale and is not regulated herein as a waste pursuant to Chapter 15 (discharges of Waste to Land), Title 23, California Code of Regulations. The unlined gypsum storage pond is not regulated for water quality effects because groundwater has not been encountered between

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the ground surface and the poor-quality subsurface Project area aquifer in the vicinity of the proposed pond. If ground water is encountered between the subsurface Project area and ground surface during the life of the project, then regulation of the gypsum storage pond will be re-evaluated. Such re-evaluation could result in a requirement to line the pond.” (WDR 6- 95-30, page 4, item 11.)

The gypsum reporting to the GSF is characterized by the following analytical information. The results are from samples collected in March 2019 from the gypsum evaporation ponds authorized under 6-88-103. While the gypsum is a product and not a waste, the material is not hazardous.

Table 3-1: Waste Characterization Results of Gypsum Metal TTLC Mar 2019 STLC Mar 2019 TCLP Mar 2019 Allowable TTLC Allowable STLC Levels TCLP Results Levels Results Levels Results (mg/l) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Antimony 500 ND 15 ND - Arsenic 500 8.4 8 0.2 5 ND Barium 10,000 6.1 100 ND 100 ND Beryllium 75 ND 0.75 ND - Cadmium 100 ND 1 ND 1 ND Chromium 2,500 ND 5 ND 5 ND Cobalt 8,000 ND 80 ND - Copper 2,500 7.6 25 0.5 - Lead 1,000 ND 5 ND 5 ND Mercury 20 ND 0.2 ND 0.2 ND Molybdenum 3,500 1.1 350 ND - Nickel 2,000 3.4 20 ND - Selenium 100 6.5 1 ND - Silver 500 6.2 5 ND 5 ND Thallium 700 ND 7 ND - Vanadium 2,400 ND 24 ND - Zinc 5,000 3.2 250 0.4 -

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3.4 Other Wastes Generation of other wastes is unchanged from the approved Plan “Wastes generated by the operation of the process plant would include domestic garbage and used engine oil, grease, and solvents. Domestic garbage would be collected in a three to five-yard dumpster on site and removed off-site by a contractor as needed to the Barstow landfill. Oil (including that from the cogeneration facility), grease, and solvents would be removed from the Project site to an approved recycling depot and hazardous waste facility. No hazardous wastes are generated by the process operation other than waste oil resulting from changing lubricating oil from the cogeneration unit. This waste oil would be hauled by a licensed recycler for recycle.” Plan § 2.4.

Per Condition 47, FCCC will prepare a Business Emergency/Contingency Plan to include operations for the site as described and submit said Plan(s) to the Hazardous Materials Division of the San Bernardino County Fire Department, designated as the CUPA for the County. The Business Plan includes a hazardous materials inventory and Spill Prevention Control and Countermeasure Plan (SPCC) to ensure that on site materials are stored appropriately and contained in the event of an uncontrolled release utilizing Best Management Practices (BMPs). Fuel storage specifications apply to all above ground fuel containers.

Table 3-2: Anticipated Project Waste Types (Dames & Moore, 1993) Waste Type Source Material Disposal Procedure Domestic waste Paper, plastic, glass, San Bernardino County Foods Landfill Barstow Industrial Concrete, plastic/fiberglass San Bernardino County (non-hazardous) pipe Landfill Barstow

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4.0 Water Supply

“Approximately 150,000 gallons per day (or 0.46-acre feet per day, for a total of approximately 161-acre feet per year) of process water would be required for the proposed action in order to wash the gypsum produced, and for use in cooling, fire protection, and various sanitary uses.” Plan § 4.0. The process water will be pumped from wells west of the Pisgah Fault (Wells MWW- 1 and MWW-2) and east of Fault B (Wells PW-1 and PW-2). The chemical analysis of water from these wells is shown in Table 4-1.

All water and monitor wells will be permitted, operated and closed in compliance with San Bernardino County Department of Environmental Services (DEHS) regulations. Those wells will be bonded for closure and the bond held by the County.

Figure I.4-1 shows the location of all water supply wells within the Project Boundary. Make-up water wells west of the Pisgah Fault were approved in the EIS/EIR for up to 100 gpm for the life of the Project. With the completion of the Fault B Program, a new aquifer has been identified, which can provide up to 500 gpm water for more than 20 years without impacts to regional domestic, agricultural, industrial or ecological waters. Although it varies from the EIS/EIR, FCCC proposes to use water from either PW-1 or PW-2 in addition to MWW-1 and MWW-2, as needed. The distance between PW-1 and the re-located process plant is approximately one mile. The Fault B Program clearly identified that the aquifer east of Fault B and west of Pisgah Fault are of different origins. Additionally, there are no known wells located in the aquifer east of Fault B. Please refer to Appendix B for a detailed water supply assessment for Wells PW-1 and 2.

“The above-ground main water delivery line would have a diameter of three inches, and the above-ground delivery lines from the individual water wells to this main delivery line would be three inches or less in diameter, depending upon the yield of the individual wells. The distance from the farthest well to the process plant would be approximately eight miles.” Plan § 4.0.

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Table 4-1: Groundwater Quality Analyses

Ft. Cady Groundwater Laboratory Analytical Results Analyte MCL 1807 1829 MWW-1 MWW-S1 PW-2 SMT-93-2 TW-1 Alkalinity, Bicarbonate (As CaCO3) mg/L - 120 270 98 74 245 360 658 Alkalinity, Carbonate (As CaCO3) mg/L - ND 250 ND 8 ND 46 ND Alkalinity, Hydroxide (As CaCO3) mg/L - ND ND ND ND ND ND ND Alkalinity, Total (As CaCO3) mg/L - 120 520 98 82 245 410 658 Aluminum mg/L 1 ND ND ND ND ND ND ND Antimony mg/L 0.006 ND ND ND ND ND ND ND Arsenic mg/L 0.01 0.099 0.02 0.054 0.078 0.048 0.15 0.011 Barium mg/L 1 0.02 ND 0.02 0.02 0.088 ND 0.055 Beryllium mg/L 0.004 ND ND ND ND ND ND ND Boron mg/L - 3.2 12 12 13 6.7 150 5.5 Cadmium mg/L 0.005 ND ND ND ND ND ND ND Calcium mg/L - 20 6.6 51 28 120 140 32 Chloride mg/L 250 180 4600 62 69 400 2400 440 Chromium mg/L 0.05 0.012 0.02 0.046 0.063 ND ND ND Copper mg/L 1 0.01 0.02 0.004 0.002 ND ND ND Fluoride mg/L 2 7.7 ND 1.2 0.5 2 14 4 Iron mg/L 0.3 0.3 61 4.9 80 56 ND 27 Kjeldahl, Nitrogen mg/L - 0.2 7.9 ND 0.1 5.8 0.3 8.2 Lead mg/L 0.015 ND ND ND ND ND ND ND Lithium mg/L - 0.4 1 ND ND ND 3 ND Magnesium mg/L - 2 ND 5 3 16 12 4.1 Manganese mg/L 0.05 0.003 0.43 0.1 0.6 0.78 0.07 0.24 Mercury mg/L 0.002 0.0002 0.0001 0.0002 0.0001 ND 0.0001 ND Nickel mg/L 0.1 ND 0.01 0.004 0.002 0.013 0.01 ND Nitrate as N mg/L 10 1.7 ND ND ND ND ND ND Nitrite as N mg/L 1 ND ND ND ND ND ND ND Nitrogen, Nitrate-Nitrite mg/L - ND ND 6.8 ND ND ND ND Nitrogen, Total mg/L 10 1.9 7.9 ND ND 5.8 ND 8.2 pH SI 6.5-8.5 7.73 9.17 7.79 8.39 7.65 8.38 7.76 Potassium mg/L - 6 36 3 3 34 23 11 Selenium mg/L 0.05 ND 0.08 ND ND 0.029 0.07 0.026 Silver mg/L 0.1 ND ND ND ND ND ND ND Sodium mg/L - 340 3000 430 490 970 3800 1100 Sulfate mg/L 250 370 76 940 970 1500 6100 870 Thallium mg/L 0.002 ND ND ND ND ND ND ND Total Dissolved Solids mg/L 500 1000 7900 1500 1400 3100 12000 2900 Tungsten mg/L - 0.075 ND ND ND 0.021 ND ND Zinc mg/L 5 0.12 0.8 0.24 ND ND ND ND

-ND: Less than Laboratory Detection Limit (DL); See Laboratory Reports for Individual DLs MCL: The more stringent value between Federal and California Drinking Water Standards Pink shading indicates MCL exceedance

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Figure I.4-1: Water Well Locations

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5.0 Erosion and Sediment Control

FCCC submitted a request to waive the requirements for a General Industry Stormwater Permit; a State of California Professional Engineer prepared and submitted a Notice of Non-applicability. A request to waive the construction stormwater requirements was also submitted to the LRWQCB. Although a waiver was requested, FCCC will incorporate Best Management Practices (BMPs) and a Spill Prevention Control and Countermeasure Plan (SPCC), if required, throughout the construction and operation of the mining and processing activities. During removal of plant equipment, tanks, and other facilities, any fuel or oil spills, or other contaminants will be cleaned up immediately per the SPCC plan. After reclamation, there will be no contamination sources remaining on-site. FCCC will also comply with Conditions 11, 12, 15, 27, 73, 77, 122, and 131.

Wind and water erosion and sedimentation will be controlled by several methods. Reclamation will emphasize grading practices that enhance the natural reestablishment of native vegetation. The disturbed areas of the site will be graded to eliminate rills and gullies. These areas will be regraded and imprinted to create non-uniform, rough surfaces in order to decrease wind velocities, increase seed and fines deposition and improve moisture collection. Materials (vegetative debris and rocks) that remain from the initial grading of Project-related linear features, the gypsum deposition area, and the process plant will be redistributed in a non-uniform manner designed to decrease wind and water erosion and create habitat conducive to plant reestablishment. Snow fencing may also be used to create wind breaks. Seeding of native perennial species will also enhance site recovery and reduce erosion potential. Additional measures, such as the incorporation of growth enhancers or the installation of erosion control fabrics, may be required to control erosion.

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II. Land Reclamation Plan - 2019

1.0 Introduction

In-situ solution mining provides many environmental and subsequent reclamation advantages compared to conventional open pit or underground mining operations. The proposed solution mine operation will not produce open pits, overburden dumps, mill tailings, or process wastes.

The proposed project will result in approximately 342.5 acres of disturbance, including portions of the 273- acre orebody well field with 500 wells located on the ore body, a 10-acre plant site, a 16-acre gypsum storage facility, and up to 43.5 acres of ancillary services, including a process water supply well network, a natural gas pipeline, access roads, and electric lines and facilities.

1.1 Land Use The project is located approximately 17 miles east of Newberry Springs and two and one-half miles south of Interstate 40 (I-40). Land uses adjacent to the site include the following:

North: Open space, I-40 two and one-half miles north, and BNSF rail-line four miles north.

East: Open space, SCE high-voltage transmission lines and corridors, Pisgah Crater two miles east, and 29 Palms Marine Corps Base one mile southeast.

South: Elementis’ open pit hectorite mine adjacent to the site and Rodman and Lava Mountains four miles south.

West: Elementis’ Hector Mine, County access road and open space.

Federal Land Use Since the 1994 project approval, the BLM has approved a comprehensive Land Use Plan Amendment (LUP or LUPA) to the California Desert Conservation Area (CDCA) Plan as part of the Desert Renewable Energy Conservation Plan (DRECP) (September 2016).

“The LUPA includes plan decisions necessary to adopt a conservation strategy and a streamlined process for the permitting of renewable energy and transmission development on BLM-managed lands, while integrating other uses and resources. This is achieved through the designation of land use allocations for Ecological and Cultural Conservation, Recreation, and Development, and adopting Conservation and Management Actions (CMAs) for resources throughout the LUPA Decision Area.” (LUPA pg. 11) The Ft. Cady Project area is not within any designated areas for conservation or recreation nor areas designated for streamlined or incentivized renewable energy development. The public lands in the project area are within General Public Lands or “Unallocated Lands” administered by the BLM; this has not changed.

The Revised Plan is in conformance with the BLM’s CDCA Plan and the LUPA because it is consistent with the following LUP decision(s) (objectives, terms, and conditions), FCCC holds an existing authorized plan of operation, and it meets the performance standards of the 43 CFR 3809 regulations as applicable.

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The Revised Plan is in conformance with the LUPA, Section II.4.1.5 (DRECP), which describes the goals and objectives of the DRECP regarding mineral resources: “Support the national need for a reliable and sustainable domestic mineral and energy supply. Support responsible mining and energy development operations necessary for California’s infrastructure, commerce and economic well-being.”. (Page 78). Under DRECP Section II.4.2.1.7, minerals lands and existing mining development relevant to the proposed action are characterized in following manner:

“LUPA-MIN-2: Existing Mineral/Energy Operations Existing authorized mineral/energy operations, including existing authorizations, modifications, extensions and amendments and their required terms and conditions, are designated as an allowable use within all BLM lands in the LUPA Decision Area, and unpatented mining claims subject to valid existing rights. Amendments and expansions authorized after the signing of the DRECP LUPA ROD are subject to applicable CMAs, including ground disturbance caps within Ecological and Cultural Conservation Areas, subject to valid existing rights, subject to governing laws and regulations.”

“LUPA-MIN-4: Access to Existing Operations • Established designated, approved, or authorized access routes to the aforementioned existing authorized operations and areas will be designated as allowable uses. • Access routes to Plans of Operations and Notices approved under 43 CFR 3809 will be granted subject to valid existing rights listed in 43 CFR 3809.100.”

“LUPA-MIN-6: New or expanded mineral operations will be evaluated on a case-by-case basis, and authorizations are subject to LUPA requirements, and the governing laws and regulations.”

County Land Use Planning and Policy The original 1994 Plan was approved by the County of San Bernardino. The General Land Use designation of Resource Conservation (RC) has not changed and revisions to an approved action are allowable per Condition of Approval #4.

The project site has been the center for exploration, pilot scale solution mining, and pilot plant testing for the recovery or borates since 1964. A brief history of these activities is discussed in Section 1.1.2 of the Mining Plan. The locality is isolated with no nearby permanent residential or commercial development. Recreation in the area is limited due to inaccessibility and existing mining operations.

1.2 Visibility The 2019 Plan Revision relocates the plant site approximately one-mile west adjacent to the ore body. This location is on the south side of a low set of hills that limits any future views of the site from I-40.

1.3 Vegetation Creosote bush shrub is the primary vegetative type in the project area. Two major community types, white bursage (Ambrosia dumosa) and creosote bush (Larrea tridentate) occur on the proposed project site. Other plants include bladder sage (Salazaria Mexicana), cheesebush (Hymenoclea salsola), beavertail cactus (Opuntia basilaris), Anderson thornbush (Lycium andersonii), and Mojave yucca (Yucca schidigera). The Draft EIS/EIR contains a complete list of plant species observed during field surveys conducted in 1989 and 1990 (Dames & Moore, 1993). A study was conducted for the project area by HDR in October 2018. HDR did not identify any special-status plant species listed by the California Natural

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Diversity Database, the Barstow BLM Wildlife Biologist, or identified in near-by (4 to 20 miles) solar projects. As copy of the 2018 HDR report is available in Appendix K.

1.4 Wildlife “The fauna associated with creosote bush scrub are adapted to desert scrub habitat with little cover and xeric conditions. Fish and amphibians are rare due to the scarce nature of surface water. Reptilian fauna, in contrast, are much more common and diverse. Special species of snakes occur in the project area, which are significant predators of the small mammals found in the area. Lizards are also expected on or near the project area. The desert tortoise (Gopherus agassezii), is also a year-round resident of the area.”

“A wide variety of avian species may be found on or near the project area. Many breed in the area and are year-round residents, while others are seasonally abundant.” The Draft EIS/EIR contains a complete list of wildlife species observed during field surveys conducted in 1989, 1990, and 1991 (see Section 3.5 of the FCMC Solution Mining Project Draft EIS/EIR for more information). (Dames & Moore, 1993).

“Based on literature review and reconnaissance field surveys, nine sensitive wildlife species are known or have the potential to occur in the project area. Of those, two are Federally-listed species (the desert tortoise and peregrine falcon). The desert tortoise is also State-listed as threatened, and the peregrine falcon is State- listed as endangered. A separate Biological Assessment for the desert tortoise was submitted to USFWS as part of the Section 7 consultation required by the Endangered Species Act, as amended” (see USFWS Biological Opinion, Appendix F). Additionally, to offset any project related impacts to Desert Tortoises, 348.25-acres of Desert Tortoise Habitat was granted to BLM on January 15, 1997.

“Seven additional sensitive species are known, or have the potential, to occur in the project area. One lizard, two birds, and four mammals are Federal candidates and/or state-protected species, including the prairie falcon, LeConte’s thrasher, the desert kit fox, Nelson’s bighorn sheep, the California leaf-nosed bat, the spotted bat, and the common chuckwalla.”

During the October 2018 field survey conducted by HDR, Desert Tortoises were identified; however, no additional special-status species were identified. Both the BLM and County have Desert Tortoise requirements in their approvals and permits.

2.0 Reclamation

2.1 Pre-Construction Surveys A pre-construction baseline vegetation survey will be conducted within the disturbed area prior to construction to evaluate community characteristics and structure. The survey will be conducted during peak flowering and fruiting periods to ensure correct species identification. The information will be essential to refinement of proposed revegetation prescriptions and to set realistic performance standards.

Diversity (species richness) and density of perennial vegetation for each community type proposed for disturbance are the currently accepted measurements of vegetation structure in the Mojave Desert. Cover is not considered to be an accurate measure of revegetation success. For many desert perennials, years may be required for above-ground biomass (canopy cover) to equal and exceed below-ground biomass.

Two major community types, white bursage (Ambrosia dumosa) and creosote bush (Larrea tridentate) occur on the project site. Two permanent “control” plots will be located, one in each community, outside

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proposed areas of disturbance. These plots will be representative of vegetation occurring in areas proposed for construction and constitute “control” plots, by which reclaimed areas can be compared. Prior to actual reclamation, the undisturbed “control” plots will be resurveyed to evaluate changes in vegetative composition that may have occurred since project inception.

The exact location of the “control” plots will be determined following construction staking. Plots will be 100 yards squared, with grids on 10-yard intervals. At each intersection, a circular plot, two yards squared, will be measured. Sample size will be sufficient to produce at least an 80 percent confidence interval, for each grid sampled.

2.2 Construction Phase The proposed solution mine operation will cause relatively little grading and associated soil disturbance. Open pits, overburden dumps, tailings and mine waste, all frequently associated with large mining operations, will not occur as part of this project.

Significant surface disturbance and earth moving will be restricted to the gypsum storage facility (16 acres) and the processing plant (10 acres). Removal of a limited amount of vegetation will be required within the well field (273 acres). Disturbance of vegetation is also anticipated as a result of construction of the new roads and a freshwater pipeline.

2.3 Operations The process plants, GSF, utility lines, railroad spurs (if developed) and access roads will remain active for the duration of the mine operation (approximately 30 years per this Plan). It is expected that a market for the by-product gypsum will be developed and that gypsum will be continuously exported.

2.4 Orebody/Well-field Closure FCCC will conduct water and monitoring well plugging and abandonment (P&A) in accordance with the statutory requirement set forth in California Department of Water Resources Bulletin 74-90; and the requirements of San Bernardino County including Condition of Approval No. 31.

All Class III injection wells are permitted through the EPA's Underground Injection Control (UIC) program regulated under Title 40 of the Code of Federal Regulations Parts 144 - 146. The Safe Drinking Water Act (SDWA) establishes requirements and provisions for the UIC program. FCCC has applied for a Class III Area UIC permit for the injection well field operations. All injection wells will be designed, drilled, constructed, operated, monitored, and closed in accordance with the UIC Permit. The Class III Area permit authorizes the construction, operations and closures of all injection wells. The EPA will hold the bond for all Class III wells.

Through the EPA’s UIC program and permitting, FCCC will prepare a P&A Plan in accordance with 40 CFR §144.28(c)(2), 144.52 and 146.10. In general, the requirements for P&A of production wells are to plug in a manner to prevent movement of fluid out of the injection zone and into or between USDWs. Regardless of the type of well, (i.e. push/pull, injection to recovery, or directional), FCCC will remove all tubing from the well prior to plugging. FCCC will set a cement basket immediately above the perforated casing to avoid cementing the formation. Cement will then be pumped to surface using a tremie pipe to ensure that cement is consistent from the top of formation to surface. FCCC will submit a plugging and abandonment report within 60 days after the well is plugged using the most current EPA Form 7520-14.

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Generally, wells will not be proposed for P&A until the end of life cycle, including injection, reaction, and extraction phases. Following P&A activities, surface reclamation and restoration will be undertaken to match the existing landscape in accordance with this approved Reclamation Plan.

2.5 Final Reclamation Final reclamation will emphasize grading practices that enhance the natural reestablishment of native vegetation. Regrading will create non-uniform, rough surfaces to decrease wind velocities, increase seed and fines deposition, and improve moisture collection.

Following the removal of all structures and equipment from the site, all remaining active wells will be plugged, as described above., unless directed otherwise. All areas that initially required excavation will be returned to their original grade and will conform with the surrounding topography.

All compacted soils will be ripped at a minimum depth of eight inches, in two perpendicular passes, on slopes less than 3:1. Ripping depth will be determined by evaluating the depth and quality of subsoil at the site. All areas to be revegetated will also be imprinted on slopes less than 3:1. Use of an imprinting device creates a rough soil surface that allows development of microsites conducive to seedling establishment.

Remaining materials (vegetative debris and rocks) resulting from initial grading shall be non-uniformly redistributed, perpendicular to the prevailing wind, where feasible, following final grading and imprinting. This material will serve to trap soil particles, wind-borne seed, and soil moisture. Snow fencing, or other suitable material, may also be used as a wind break and to direct wind-born deposition.

3.0 Revegetation

In 1995, FCCC prepared a Revegetation/Habitat Restoration Plan approved by the BLM and County (see Appendix I). This Revegetation Plan includes a list of plant species identified on-site for various areas to be developed; a planned seed; erosion control methods; and monitoring and maintenance procedures.

Revegetation objectives are to provide immediate and long-term site stability through the reestablishment of a self-perpetuating, native plant community that allows for natural plant succession. The use of soil amendments (including fertilizers), mulches or tackifiers, is not anticipated.

Following final grading and imprinting, disturbed areas will be seeded with an appropriate mix at a rate developed from data obtained from vegetation survey(s). It is expected that the mix(s) will include the co- dominant species of creosote and bursage. Both species produce seed that can be established by broadcast seeding. The mix will also be determined by the ability of species to become established from seed and to reduce visual contrasts with the surrounding landscape. If possible, seeds will be lightly covered with soil.

Given the anticipated life of the mining operation (approximately 30 years), the assumption can be made that desired species will be commercially available, and seeding specifications will be adjusted, if necessary, in accordance with the best available technology at the time of final reclamation.

4.0 Clean-up

All structures, solution and process water wells, equipment, pipelines and tanks will be dismantled. Salvageable items will be offered for sale and removed from the site following termination of operations.

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All nonsalvageable material will be properly disposed at an approved landfill site. Cleanup will take place throughout the production phase and as facilities are closed.

5.0 Post-Reclamation and Future Mining

The reclaimed site will be reclaimed as open space and will appear similar to preexisting conditions. Original contours will be reestablished where possible. Post-reclamation land use will not be in conflict with adjacent land uses. No future mining of colemanite is anticipated on the present site following mine closure.

6.0 Slopes

There will be no slopes excavated for the operations.

7.0 Gypsum Storage Facility

If any gypsum remains in the deposition area, it will be covered with material from the diversion berms. Regrading will proceed to remove the berms, backfilling the storage area as needed and returning it to a contour in conformation with surrounding topography. Soils will then be tested for nutrients, and if they are found to be deficient, soil amendments may be used in this area to enhance the reestablishment of vegetation. The revegetation will proceed as described above.

8.0 Soils

The soil throughout the northern part of the project area of the Daggett-Tonopah-Bitterspring association, which range from gravelly, sandy loam to sand, are largely covered with desert pavement. Thick, medium- textured vesicular crusts and subsurface horizons with clay accumulations typically underlie the surface rock cover. In the alluvial areas Anthony-Cajon-Arizo association soils occur, typically ranging from sandy loam to gravelly sand.

9.0 Drainage and Erosion Control

No significant changes in runoff patterns are anticipated. Wind and water erosion will be controlled through regrading, which will create non-uniform, rough surfaces to decrease wind velocities, increase seed and fines deposition, and improve moisture collection. In addition, erosion will be further controlled by imprinting and seeding disturbed areas.

In the event that any rill or gully erosion occurs, addition measures, such as the incorporation of growth enhancers or the installation of erosion control rock berms or reseeding may be required to control erosion.

10.0 Public Safety

Since the proposed solution mine operation will not produce open pits, overburden dumps, mill tailings, nor process wastes and mine-related facilities will either be removed and disturbed land reclaimed and revegetated, no public hazards are anticipated. Therefore, posted warning signs will not be needed.

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11.0 Monitoring and Maintenanc3e

Baseline monitoring during project construction and implementation will include the following.

a. Hydrology of the formation containing the ore reserves. b. Water quality of the formation water within the ore body. c. Water quality and quantities of process ore body. d. Quality and quantities of leachate, pregnant and process solutions. e. Climatological data from nearby locations.

Evaluations will continue throughout the life of the mine to enhance the success of reclamation and revegetation activities. The mine will maintain contact with other similar mines, research facilities and government agencies to ensure awareness of state-of-the-art techniques and methodologies. It will be the responsibility of the mine to stay current with and update these specifications as needed.

Once reclamation activities begin, annual evaluations of reclamation success will be submitted to the lead agency. These reports will also include analysis of other appropriate documents from related projects. Since plant establishment in desert communities can be extremely slow, it is unrealistic to expect total reestablishment of vegetative diversity and density after 10 years. Based on previous research, the following performance goals will be achieved 10 years following closure: density of 21 percent of “control” (survey plots or adjacent undisturbed plant communities), and diversity of 15 percent of “control”. The operator will also show that the vegetation has been self- sustaining for two years.

Periodic maintenance, such as reseeding with selected species, regrading to eliminate rills or gullies, weed control, and application or installation of soil stabilizers may be required to control erosion and achieve revegetation standards. No other maintenance of vegetation is anticipated.

FCCC is required under SMARA to submit an annual report on forms provided by the California Department of Conservation - Division of Mine Reclamation. SMARA (Section 2774(b)) requires the lead agency (County) to conduct an annual inspection of the mining operation. It is expected that the BLM will conduct periodic inspections of the site.

12.0 Reclamation Assurance

FCCC has provided the County and BLM a financial insurance cost estimate and financial assurance mechanism in a form of a secured certificate of deposit in the amount of $294,426.10 to assure reclamation of the site. FCCC will increase the posted reclamation assurance as needed in an amount sufficient to pay for the cost of reclamation as the site is developed. The reclamation assurance shall be reviewed by the County annually as required by the SMARA.

All Class III injection wells are permitted through the EPA's UIC program regulated under Title 40 of the Code of Federal Regulations Parts 144 - 146. All injection wells will be designed, drilled, constructed, operated, monitored, and closed in accordance with the UIC Permit. The Class III Area permit authorizes the construction, operations and closures of all injection wells. The EPA will hold the bond for all Class III wells. Following injection well closure activities, surface reclamation and restoration will be undertaken and financial assurance costs for this activity will be include in the County’s FACE and financial assurance mechanism.

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III. Geology

1.0 Regional Geology

“Regional geologic information in this report was compiled, unless otherwise indicated, from Dibblee (1980a, 1980b). The Project area is located in the Barstow Trough of the central Mojave. The Mojave comprises a structural entity commonly referred to as the Mojave block, and is bounded on the southwest by the San Andreas fault zone and the Transverse Ranges, on the north by the Garlock fault zone, and on the east by the Death Valley and Granite Mountain faults. The central Mojave region is made up of a number of relatively low mountain ranges separated by intervening basins which are floored primarily by alluvium. The central Mojave area is cut by numerous faults of various orientations, but which predominantly trend to the northwest.” Id.

“The oldest rocks exposed in the central Mojave area are Precambrian in age and consist primarily of gneissic metamorphic and granitic igneous rocks. The Precambrian rocks are severely deformed and are presumed to underlie younger rock units throughout the central Mojave. Paleozoic and younger sedimentary and volcanic rocks were subsequently deposited above the Precambrian units. During the Mesozoic, older crustal rocks were intruded by predominantly granitic igneous plutons which underlie much of the central Mojave area. Subsequent uplift and erosion have removed much of the rock units overlying the plutonic rocks, leaving isolated granitic remnants exposed in the area. The batholithic and older rocks were subsequently uplifted, eroded, and overlain by later Cenozoic and recent alluvial sediments.” Id.

“A dominant feature of the region is the Barstow Trough, which is a structural depression extending northwesterly from Barstow toward Randsburg and east-southeasterly toward Bristol. The Barstow Through is characterized by thick successions of Cenozoic sediments, including borate-bearing lacustrine deposits, with abundant volcanism along the trough flanks (Gardner, 1980). The northwest-southeast trending trough initially formed during Oligocene through Miocene times. As the basin was filled with sediments and the adjacent highland areas were reduced by erosion, the areas receiving sediments expanded, and playa lakes, characterized by fine-grained clastic and evaporitic chemical deposition, formed in the low areas at the center of the basins. The Barstow Formation, which is found at the surface in the Mud Hills area north of Barstow, comprises the bulk of the Miocene (roughly 13 to 19 million years old) sediments in that area, where its measured thickness is about 1,000 feet (Woodburne, et a., 1990). The Barstow Formation in the Mud Hills area is made up of conglomeratic basal and marginal units, interfingering with marginal and lacustrine sands, muds, and limestones (algal in some cases). Interbedded volcanic ash units, often water-laid and/or zeolitized, occur throughout the unit. Depositional relationships indicate that at least local tectonic activity continued through at least the end of Barstow Formation deposition.” Id.

“Volcanism periodically accompanied faulting in the region and was generally more extensive at the beginning of the Cenozoic. Aerially, volcanism was more intense in the Barstow Trough area,

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where it accompanied development of the structural basin. Volcanics are frequently found intercalated with sediments in the Barstow Trough area (Subsurface Surveys, Inc., 1990).” (Id.)

“Subsequent tectonic disruption of the area during Pleistocene times resulted in elevation of the present topographically high areas and resulted in filling in of former basin areas with coarser- grained clastic sediments. Accumulation of alluvium has continued in low areas to the present. Cenozoic sediments in the central Mojave area are relatively undeformed, although there is local deformation in the vicinity of the northwest-trending faults.” Id.

“The Project area is located in the south-central portion of the wedge-shaped Mojave block, a structural block bounded by the San Andreas fault zone to the southwest and the Garlock fault zone to the northwest. The eastern tectonic boundary of the Mojave block is vague and poorly defined; however, it is generally represented by an alignment of valleys extending southeastward from Death Valley. Along this alignment, the Death Valley fault zone, evident north of the Garlock fault zone, may extend as a concealed fault southeastward an unknown distance (Dibblee, 1980).” Id.

“Recent and historical seismicity and the presence of numerous active and potentially active northwest-trending right-lateral, strike-slip faults provides evidence that the Mojave block is tectonically active. The primary driving force for this activity is believed to be associated with transform motion between two major crustal plates, the Pacific and North American plates. The plate motion is thought to be accommodated across a broad zone of California, both east and west of the northwest-trending, right-lateral, strike-slip San Andreas fault system which represents the principal surface manifestation of the zone of plate interaction and is the dominant seismotectonic element of California. Major faults within the Mojave block generally parallel the San Andreas. The northeast to east-west trending generally left-lateral Garlock fault zone is considered active despite the apparent lack of historic seismic activity clearly attributable to this fault.” Id.

“Major northwest-trending fault zones of the Mojave block include the Helendale, Lockhart- Lenwood, Camprock-Emerson-Homestead Valley-Johnson Valley, Blackwater-Calico-West Calico-Hidalgo, Pisgah-Bullion, and Ludlow Faults. Although the dominant displacement on fault zones appears to be right-slip, some faults, such as the Pisgah, have significant vertical displacements (Dibblee. 1980a). A regional gravity survey was performed by Subsurface Surveys, Inc. (1990) for the Mojave Water Agency in the west and central Mojave area, ending just west of the Project area. The results of that survey indicated that, to a rough approximation, the gravity contours may be viewed qualitatively as structural contours on the bedrock in the area. Evidence for normal, reverse, and strike-slip faulting was found, although upthrown and downthrown relationships across strike-slip faults were commonly observed to change along the fault trends. Offsets of up to 3 to 4 miles (on the Harper Lake-Waterman Fault) were observed, although offsets of roughly 2 to 2.5 miles, as inferred for the Calico-Newberry Fault, were typical. The majority of these faults evaluated by the California Department of Conservation Division of Mines and Geology (CDMG) under the Alquist-Priolo Special Studies Zones Act as part of the Mojave Desert study region (except for the Ludlow Fault, which was outside the study area), are considered to

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be Holocene-active (Hart, et al., 1987). The 1992 Landers earthquake indicates that these faults are capable of generating large earthquakes.” Id.

“Several east-west trending faults are present in the northeastern and southern portions of the Mojave block. These active or potentially active faults are generally considered to be high-angle left-slip faults associated with the Garlock fault zone. Several small north-south trending faults are also located within the Mojave block, generally adjacent to, and probably associated with, the large northwest-trending fault zones. Most of these faults do not show evidence of Quaternary displacement (Bortugno, 1986); however, a few have demonstrated historic seismicity, including the Manix and Galway Lake Faults (1947 and 1975, respectively). The 1947 Manix earthquake reportedly had a magnitude of 6.2 (Wesnousky, 1986).” Id.

Figure I.1-4 shows the regional geology and major structures.

2.0 Local Geology

“Strata ranging in age from probable Pliocene through Recent in age are exposed at the surface within the Project area. Exposures of fine-grained lacustrine sediments and tuffs, possibly Pliocene in age, are found throughout the Project area. Younger alluvium occurs in washes and overlying the older lacustrine sediments. Recent olivine basalt flows occur in the central and eastern portions of the Project area, and along the northern boundary of the western portion of the Project area.” Id.

“Two major geologic features in the Project area are the Pisgah Fault, which transects the southwest portion of the Project area, trending in the northwesterly direction, and the lava flows from Pisgah Crater. The Pisgah Fault is believed to be one of the many through-going northwest- trending strike-slip faults which are found in the region and exhibits substantial vertical separation in the Project area, with the eastern side of the fault upthrown at least 700 feet relative to the western side of the fault. A second fault, designated Fault B, is a north-south trending fault in the northeastern portion of the Project area which also exhibits at least 700 feet of vertical separation. A block of fine-grained lacustrine sediments between the two faults has been raised relative to the coarser-grained alluvial sediments to the east and west. The central portion of the Project area is covered by Recent Olivine basalt flows from Pisgah Crater, which is located approximately two miles east of the site. The basalt flows roughly parallel to the fault immediately north of the west part of the Project area. The Project area east of the Pisgah Fault and west of Fault B lies within an area of thick fine-grained, predominantly lacustrine mudstones which appear to have been uplifted a minimum of 700 feet along both faults, forming an uplifted block of lacustrine sediments that appear to be floored by an andesitic lava flow.” Id.

“Boring logs have consistently demonstrated the presence of a clay layer beneath the evaporite/ mudstone body that surrounds and encloses the ore body. The lower clay layer appears to be underlain by volcanic sand and andesitic volcanic rock.” Id.

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“Based on exploratory drilling logs provided by FCMC, the ore body is elongate in shape and trends northwesterly. The eastern margin of the ore body appears to be roughly linear, paralleling the Pisgah Fault which lies approximately one mile to the west. Based on the similarity of the trend, it appears possible that lacustrine sedimentation in the ore body area was controlled by a structural element paralleling the Pisgah Fault.” Id.

“The ore body consists of variable amounts of calcium borate (colemanite) within the mudstone matrix. X-ray diffraction analysis of the ore body mineralogy indicated the presence of the evaporite minerals anhydrite, colemanite, celestite, and calcite. The mineralogy of the detrital sediments included quartz, illite, feldspars, and clinoptilolite, a zeolite mineral (Rooke, 1982).” Id.

Duval contracted with Core Laboratories in 1981 to conduct testing on ore body core. The results were reviewed and analyzed by Mr. Ed Reed. (Reed & Associates letter report, 1981). The results indicate that initial permeability of the ore body varies from 1.35 x 10-9 to 2.9 x 10-10 cm/s. After in-lab leaching, the permeability increased to 7.7 x 10-6 cm/s.

During the 2018 Fault B Program, FCCC verified that there are 400 feet of vertical separation across Fault B. The west side of the fault is up-thrown relative to the east side. (CRW, 2018).

3.0 Project Area Geology

The colemanite ore body is situated within a thick area of fine-grained, predominantly lacustrine (lake bed) mudstones, east of the Pisgah Fault and west of Fault B. The central Project area has been uplifted along both faults, forming an uplifted block. Test borings emplaced through the ore body show the presence of claystone at the base and around the evaporite/mudstone ore body. Exploration drilling in the Project area indicate that the ore body lies between approximately 1,300 and 1,500 feet bgs. The ore body consists of variable amounts of calcium borate (colemanite) within a mudstone matrix. (Norman, 1987, Section 6.3).

The underlying ore body is elongated in shape and trends north-westerly, extending over an area of about 606 acres. Beds within the colemanite deposit strike roughly N45W and dip about 5° - 10° or less to the southwest.

The western boundary of the ore body roughly parallels the Pisgah Fault which lies approximately one-mile to the west. This western ore boundary was considered by Duval geologists to be controlled by a facies change to boron-poor, carbonate-rich lake beds as a result of syn- depositional faulting. The northeast and northwest boundaries of the deposit are controlled by facies changes to more clastic material, reducing both the overall evaporite content and the concentration of boron within the evaporites. The southeast end of the deposit is open-ended, requiring additional drilling to define the south-eastern limits of borate deposition. (Norman, 1987, Section 6.2.2).

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The boron is believed to have been sourced from thermal waters that flowed from hot springs in the region during times of active volcanism. These hot springs vented into the Hector Basin that contained a large desert lake. Borates were precipitated as the thermal waters entered the lake and cooled or as the lake waters evaporated and became saturated with boron. Colemanite, being the least soluble would have evaporated on the receding margin of the lake. The evaporite-rich sequence forms a consistent zone in which the borate-rich colemanite zone transgresses higher in the section relative to stratigraphic marker beds. (Norman, 1987, Section 6.5).

3.1 Cross Sections Figure III.3.1 presents a cross section showing the location and depths of representative existing wells within the Project mineralized area. Due to the large number of proposed wells, they are not all depicted on the cross section, but are within the ore zone at approximately 1,300 to 1,500 ft bgs. The cross section also includes geology from interpretation of geologic logs from wells and infers geology where no drilling or ground geophysical data exists. (Norman, 1987).

Figure III.3.2 presents a cross-section showing representative wells adjacent to the Project area. These wells are located west of the Pisgah Fault and east of Fault B. The cross section shows the lithology, depth to water in wells and the expected projection of the faults that encapsulate the colemanite ore body. The results of hydraulic testing across Fault B indicate that the fault exhibits characteristics of a no flow, or limited flow boundary. (CWR, 2019). The faults and the ore body are of low permeability. As indicated by offsets in lithology, significant variations in flow, and water quality interaction with aquifers located east of Fault B and west of the Pisgah Fault.

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Figure III.3-1: Cross Section with General Lithology

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Figure III.3-2: Cross Section Showing Lithology and Faults Resulting in Containment

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3.2 Lithology Duval geologists defined the Project area lithological sequence as part of their drilling program (Figure III.3-4). (Norman, 1987, Section 6.2.2). Four major units have been identified:

Unit 1: Characterised by a 500 to 600-foot-thick sequence of red-brown mudstones with minor sandstone, zeolitized tuff, limestone, and rarely hectorite clay beds. Unit 1 is intersected immediately below the alluvium and surface basaltic lavas. Unit 2: A green-grey mudstone that contains minor anhydrite, limestone, and zeolitized tuffs. Unit 2 has a similar thickness (300-500 ft) as the overlying Unit 1. Unit 2 is interpreted as lake beds. Unit 3: A 250 to 500 foot-thick evaporite section which consists of rhythmic laminations of anhydrite, clay, calcite, and gypsum. Thin beds of air fall tuff were also intercepted which provide time continuous markers for interpretation of the sedimentation history. These tuffs have variably been altered to zeolites or clays. Unit 3 contains the colemanite deposit. Anhydrite is the dominant evaporite mineral, and the ore deposit itself is made up mostly of an intergrowth of anhydrite, colemanite, celestite, and calcite with minor amounts of gypsum and howlite. Unit 4: Characterised by clastic sediments made up of red and grey-green mudstones and siltstones, with locally abundant anhydrite and limestone. The unit is approximately 150 feet thick and rests directly on the irregular surface of andesitic lava flows. Where historic drill holes intersect this boundary, it has been noted that an intervening sandstone or conglomerate composed mostly of coarse volcanic debris is usually present. Most drill holes did not extend to this depth.

X-ray diffraction (XRD) analysis of the ore body mineralogy indicated the presence of the evaporite minerals anhydrite, colemanite, celestite, and calcite. (Norman, 1987, Sections 6.3 and 6.4) The mineralogy of the detrital sediments included quartz, illite, feldspars, and the zeolite clinoptilolite. The deposit underlies massive clay beds that encapsulate the evaporite ore body on all sides as well as above and below the deposit. This enclosed setting makes the deposit an ideal candidate for in-situ mining technology affording excellent containment of the leachate solution. (Norman, 1987, Sections 6.3 and 6.4).

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Figure III.3-3: Project Area Lithology

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4.0 Proposed Mitigation

Potential geologic impacts associated with the construction and operation of the proposed Project include the modification of topography and drainage patterns, an increased susceptibility to erosion, and subsidence as a result of mining operations and groundwater extraction. Seismic impacts related to the proposed Project include the potential for induced seismicity by injection and/or subsidence and for surface rupture due to induced seismicity and/or subsidence. Per the Final 1993 EIS/EIR, potential impacts related to the modification of topography and drainage patterns are not significant and do not require mitigation. The potential for induced seismicity is expected to be low, and mitigation is not considered to be necessary. In addition, the Project will be designed and constructed to withstand ground motions of non-Project induced seismic activity. Impacts related to erosion will be mitigated during construction, operation and closure of the project by implementing soil stabilization methods and by reclaiming the disturbed areas, as required by a number of the Conditions, including: 11, 12, 27, 73, 77 and 131.

IV. Hydrology and Hydrogeology

All text in italics in this section IV is taken entirely from the 1993 Land Reclamation Plan (attached as Appendix C). 1.0 Climate

1.1 Regional Meteorological Conditions “The Project area is located in the Mojave Valley of the Mojave Desert in the southeast portion of California. The regional climate of this area is typically hot and dry in summer with cool, dry winters. These conditions result from the influence of the migrating semi-permanent pacific high- pressure cell which lies in the eastern portion of the Pacific Ocean. During summer months, the pacific high-pressure cell increases in intensity due to the heating of the land and begins migrating northward. This deflects any incoming storms from the Pacific Ocean to the north. During winter months as temperatures decrease, the high moves southward allowing pacific northwest storms to occasionally permeate the southeast desert region. The typical coastal maritime weather of California rarely affects areas east of the coastal mountain range. Occasionally in the summer months, warm, most tropical air masses move northward from the gulf regions of Mexico and California producing light scattered showers throughout the central desert and mountains.”

“The predominant factor influencing atmospheric air movement in the Mojave Desert region is the prevailing westerly winds created by the pacific high-pressure cell. Northwesterly winds are pronounced in the summer months due to the diurnal temperature fluctuations of the land, enhancing the effects of the high-pressure cell. During winter months, westerly winds dominate, usually at a lower mean average speed than summer.”

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1.2 Local Meteorological Conditions “Local meteorological conditions are mainly influenced by the surrounding topography. The Project area in the Mojave Valley is located between two mountain ranges, the Cady Mountains to the north and the Lava Bed Mountains to the south. The valley floor is at an elevation of 2,100 feet, while the elevations of surrounding mountains range up to 4,400 feet. This type of topographical situation is indicative of high winds through the valley generated by the compaction of an air mass between the mountain ranges.”

“Daggett Airport located approximately 28 miles to the west, recorded wind direction and wind speed from the years 1955 to 1964. The mean average wind speed during this observation period was recorded at 9.8 knots [11.3 miles per hour (mph)]. The highest mean wind speed is recorded at 15.1 knots (17.4 mph). The lowest mean wind speed was recorded at 6.7 knots (7.7 mph). Wind direction occurs from the west-northwest the majority of the time. Edwards Air Force Base (Edwards) is located approximately 42 miles west of Daggett Airport and has also recorded wind data for the years 1986 to 1970. Edwards is mainly on a dry lake bed featuring miles of flat lands, and experiences lower wind speeds relative to the Project area. The mean average wind speed at Edwards was 8.77 mph. Wind direction occurs most frequently from the west-southwest. The highest mean average wind speed was recorded at 11.48 mph from the west-southwest.”

“Precipitation data for the Project area are most closely represented by Daggett Airport, Barstow, and Victorville meteorological stations. Barstow is located approximately 35 miles east of the project site, while Victorville lies approximately 53 miles to the southwest. Precipitation varies with altitude and is influenced by the local mountain ranges. In general, annual precipitation on the valley floor ranges from 3.6 inches (Daggett) to 5.4 inches (Victorville) per year. Precipitation is highly variable from year to year and is dependent on the pacific high-pressure cell. Occasional violent thunderstorms cause much localized runoff, filling local washes and washing out local roads. More subdued thunderstorms are more frequent.”

“Meteorological stations at Barstow, Daggett, and Victorville were used to characterize the monthly average temperature of the Project area. The warmest temperatures are experienced in July and the coolest in January. Diurnal temperature ranges (defined as the difference between the daily maximum and minimum temperature) are large, up to 30ºF to 40ºF, due to the efficient heating and cooling of the land surface under generally clear skies. Temperatures frequently exceed 100ºF during summer and occasionally dip below 32ºF during winter. The highest relative humidities are recorded during winter nights due to the low temperatures, whereas the driest conditions (due to excessively hot temperatures) occur during spring and summer afternoons.”

2.0 Surface Water Hydrology

“The Project area is located in a southeast projection of the Barstow Valley, approximately 35 miles east of Barstow, and approximately two miles south of the local valley surface drainage axis. Drainage within this valley generally follows the topographic gradients toward the valley

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axis and then flows roughly westward to the northwestward into the Barstow Valley to the northwest in the vicinity of Troy Lake.”

“The western portion of the Project area encompasses part of the northeast-directed drainage from the Rodman and Lava Bed Mountains, which are located south and southwest of the Project area. This drainage is diverted for the most part to the northwest and into a drainage that parallels the south margin of the basalt flows that cover the southern portion of the Project area. It is probable that some of this drainage moves beneath the basalt flow and empties into a second drainage that runs along the north margin of the basalt flow. The south slopes of the low hills in the north-central portion of the Project area also drain generally southward to southwestward into the wash that runs along the north flow margin. The area covered with basalt in the south- central portion of the Project area also drains into these two washes. The washes that parallel the basalt flow in the western Project area drain to the northwest, eventually emptying the valley axis drainage approximately two miles northwest of the Project area. The other principal drainage encompasses the eastern portion of the Project area. Drainage from this area generally empties northward to northwestward into a wash which joins the valley axis drainage north of the Project area.”

“Surface water within the Project area is limited to ephemeral flow in the washes described above and a number of smaller subordinate washes and to ephemeral ponded water in several low areas in the central portion of the Project area. No-flow conditions were observed in the Project area drainages during hydrologic investigations conducted in November 1991. No-flow conditions are expected to exist within the Project area for most of the year, with flow occurring only during and immediately following periods of heavy precipitation. Ponding of water was observed in several small closed depressions in the central part of the Project area in November 1991, most likely due to recent precipitation. Evidence of recent ponding of water was also observed along the drainage at the north margin of the basalt flow in the west-central portion of the Project area. Pooling of water is expected to be dependent upon the amount of precipitation, the evaporation rate, and the permeability of the subsurface materials. Areas of ephemeral ponded water within the Project area appear to be limited to areas where low-permeability clay soils are exposed at the surface.”

FCCC submitted a California PE stamped Notice of Non-Applicability (NONA) report with the LRWQCB in March 2019. The PE found that water generally does not leave the property, but if it should, it would flow into Troy Lake (Figure IV.3). The Project area is a closed basin, meaning that there is no connection with Waters of the US.

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Figure IV.2.1: Troy Lake Watershed

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3.0 Flood Hazard

“The drainages located within the Project area are all relatively minor drainages. As described above, the western portion of the Project area intercepts drainage from the north flanks of the Rodman and Lava Bed Mountains to the south and southwest of the Project area. The remaining two drainages are more local, draining the lava flow area and the low hills in the central and eastern portions of the Project area.”

“Flash flooding and sheet flow during periods of intense precipitation are common flood hazards throughout the Mojave Desert area. The drainage south of the lava flow, in the western portion of the Project area, has the highest potential for this type of flooding, due to the relatively large catchment area in the mountains to the south and southwest. There appears to be a relatively low potential for severe flooding elsewhere within the Project area, due to the small areas encompassed by the drainages in those areas.”

“Ponding of water in low areas along the Pisgah fault is also likely to occur during periods of heavy precipitation, due to the disruption of drainage patterns that is the result of movement along the fault.”

4.0 Regional Groundwater Hydrogeology

“The Project area is situated within the central Mojave, lying in part within an area of structurally uplifted fine-grained lacustrine (lake bed) sediments that are not generally considered to be water bearing, due to low permeabilities of the sediments. The central portion of the Project area lies within this uplifted block, which is bounded on the west and east by active faults. The western portion of the Project area lies within the southeastern end of a basin designated by the Mojave Water Agency as the Newberry groundwater basin. The eastern jurisdictional boundary of the Mojave Water Agency borders the Project area on the west. The Newberry basin is bounded by the Cady Mountains and the Pisgah fault on the east, the Manix fault on the north, the Calico- Newberry fault and the Newberry Mountains on the west, and the Lava Bed and Rodman Mountains on the south. The easternmost portion of the Project area is underlain by predominantly coarse-grained alluvium, which is separated by a fault from the block of fine-grained sediments comprising the central Project area.”

“Sediments in regional basin aquifers are predominantly composed of continental alluvial and lacustrine clastic sediments. Except in lacustrine clay and evaporite deposits, grain sizes are generally sand size or larger, although the sediments are not generally well sorted except where locally reworked by streams and rivers. Decomposition of feldspars present in the dominantly arkosic sediments produces diagenetic clays which act to reduce porosity and permeability. Permeabilities thus vary widely throughout the region, with the highest values found in Recent river and large stream deposits and the lowest values in recent river and large stream deposits and the lowest values in lacustrine (lake bed) clay deposits.”

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“Regionally, the near-surface aquifer is unconfined over most of the central Mojave area (Subsurface Surveys, Inc., 1990). The presence of some perched water tables has been demonstrated, generally in connection with local Pleistocene clay lake deposits that hold water near the surface. The lacustrine clays reportedly serve as confining layers for deeper aquifers throughout much of the western Newberry basin (CM Engineering Associates, Inc., 1982). Where faults provide barriers to groundwater flow, water may also come to the surface locally.”

“The depth to groundwater in the central Mojave area varies from near surface in perched groundwater areas associated with some lake beds to over 500 feet below ground surface (bgs) adjacent to bedrock areas at basin margins (Subsurface Surveys, Inc., 1990). In the Newberry basin, groundwater depths from roughly 50 feet to over 200 feet have been reported, with depths to groundwater generally increasing southward with distance from the Mojave River.”

“In general, groundwater flow within the central and southern Newberry basin is directed from the principal basin recharge area, the Mojave River channel, toward the south and southeast (Subsurface Surveys, Inc., 1990). Very limited groundwater elevation data are available for the southeast portion of the Newberry basin, and thus groundwater flow directions in this area are not known.”

“Fault gouge, which has developed along area faults, reportedly tends to produce effective barriers to groundwater movement. These barriers are believed to be better developed in basin sediments than in bedrock in the region (Subsurface Surveys, Inc., 1990). There is good evidence that the Calico-Newberry fault, for instance, acts as a barrier to groundwater flow, presumably due to the presence of fault gouge. Similar impediments associated with the Helendale and Lockhart faults have been documented (Subsurface Surveys, Inc. 1990).”

“The groundwater stored in the central Mojave basins is not entirely usable. Specific yields reportedly vary from 15 percent for better aquifers to 3 percent or less for lacustrine clays. The average specific yield is believed to be about 10 percent (Subsurface Surveys, Inc., 1990). In addition, much of the deeper water is unusable due to the high concentration of total dissolved solids, fluorine, and boron, particularly water contained in the deeper, semi-stagnant, closed subbasins and water associated with buried evaporites (Subsurface Surveys, Inc., 1990). Many sources consider the Pliocene and older sediments to be essentially non-waterbearing, due to porosity reduction by compaction and cementation (diagenesis) (Subsurface Surveys, Inc., 1990).”

“Recharge in the region is believed to occur principally from the Mojave River and smaller tributaries. Local rainfall ranges from approximately 10 inches per year in the mountains to less than 4 inches per year in the lower valleys. The amount of recharge resulting from infiltration of precipitation from the ground surface is not known.”

4.1 Local Hydrogeology The central portion of the Project area, where the ore body is located, is hydrologically confined. A block of claystones and mudstones makes up much of the central Project area and encloses the

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colemanite ore body lens from above and below. The mudstone generally has low porosity and permeability, and thus low hydraulic conductivity. Notably, evaluation of the hydraulic properties of the ore body determined that the permeability of the formation is very low, ranging between 1.35 x 10-9 centimeters per second (cm/sec) and 2.9 x 10-10 cm/sec. Wells completed within the ore body have been observed to require months to re-equilibrate following injection or pumping.

The faults on the east and west sides of the ore body also provide a barrier to groundwater movement. As discussed in more detail Section IV.5.2 the groundwater levels on opposite sides of the Pisgah Fault differ by 100 feet or more. The groundwater on opposite sides of Fault B differ by approximately 17 feet. The observed differences are due to the presence of clayey gouge in the fault zones forming a relatively impermeable barrier to groundwater movement, as well as significant facies changes created by the offset across the faults. The groundwater quality east of Fault B, west of Pisgah Fault and in the ore body are significantly different, as seen on the Piper Plots and Stable Isotope Plot in Section IV.5.2. Accordingly, the groundwater in the mineralized zone of the Project area is confined on all sides of the ore body.

The Fort Cady Project area and mineral deposit is ideally situated for solution mining. Given the Project’s isolated area and the absence of residences, public water wells, and USDWs, as well as the very poor water quality within the Project’s mineral zone, there is no beneficial use other than solution mining for the mineral deposit area. The ore body is buried deep within a geologic block that is bounded to the west and to the east by the Pisgah and Fault B faults, respectively. The ore body is confined from above and below by low permeability mudstones. The Fort Cady Project will not have any adverse impact on USDWs.

4.2 Project area Hydrogeology Water level measurements from seven (7) test wells in the central Project area collected in February 1990, ranged from 145 to 345 feet bgs. These seven wells are spaced with ½-mile radius. Because these wells were not completed to equal depths, the variations observed in the depth to ground water may be an indication of poor hydraulic communication between intervals. (Simon Hydro-Search, 1993, Section 3.2.1), or an indication of vertical hydraulic gradients between lithologies within the ore body.

The current assessment of the regional and local potentiometric surface of the Project area indicates depth to groundwater within the Project area is greater than 1,740 feet above mean sea level (amsl). Depth to groundwater east of Fault B is approximately 355 feet bgs, or 1,730 feet amsl. Depth to water west of Fault B is approximately 395 feet bgs, or 1,713 feet amsl. Depth to groundwater west and north of the Project area, outside the Project area is approximately 1,760 feet amsl. Depth to groundwater west of the Pisgah Fault is at an elevation of approximately 1,780 feet amsl.

The results of the 2018 Fault B Program indicate groundwater flow east of the Project area is influenced by the fault. Fault B exhibits no flow boundary characteristics including differentiation in water levels between PW-2 and TW-1. PW-2, east of Fault B, and TW-1, west of Fault B, exhibit

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an offset in groundwater elevation of approximately 17 feet over a linear distance of approximately 1,000 feet. (CWR, 2019).

The results of groundwater testing indicate the presence of highly permeable materials in the vicinity of PW-1 and PW-2, with hydraulic conductivity (K) ranging between 6 to 7 feet/day.

The elevations of groundwater within and adjacent to the Project area suggest strong anisotropy in the vicinity of faults and the ore body. The results of the 2018 Fault B Program further validates the conceptual model of the ore body being encapsulated by faults and lithologies of low permeability with no indication of connectivity to regional aquifers and provides validation of the assessment completed by which suggests that groundwater is only present in very small quantities and is of very poor chemical quality in the vicinity of the ore body, where the nearest groundwater of adequate volume is located approximately 10 miles northeast of the Project area. (CRW, 2018)

The hydraulic properties of the ore body are summarized in the In-Situ Inc. Report Fort Cady Injection Test, 1990. (In-situ, 1990). The In-Situ report indicates the presence of hydraulic barriers to both vertical and horizontal fluid movement within the ore body, based on the results of injection testing in P-1, P-2, P-4 and SMT wells (Figure IV.4). The In-Situ testing indicate the lithology of the ore body is of low permeability, with hydraulic conductivity of approximately 0.008 feet/day, and transmissivity of approximately 6.8 gpd/ft. The results of the recent TW-1 testing indicate the screened lithology west of Fault B is also of very low permeability, with hydraulic conductivity of about 0.0001 feet/day, which is very similar to the permeability of the ore body. The permeability and water quality of TW-1, west of Fault B, further validates the In-Situ Inc, 1990, assessment of hydraulic barriers in the vicinity of the ore body.

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Figure IV.4.1: In-site Test Wells

5.0 Groundwater Quality

Groundwater quality in the Project area does not meet California Drinking Water Standards for TDS or several metals. The Lahontan Regional Water Quality Control Board (LRWQCB) determined the groundwater in the Project site is inferior for domestic purposes due to TDS and fluoride concentrations exceeding drinking water standards (6-95-30). Analysis of formation water extracted from the ore zone, indicates that the water is highly saline, with TDS concentrations averages 32,000 milligrams per liter (mg/l), significantly higher than the recommended California drinking water standard of 1,000 mg/l.

Groundwater in the Project area does not currently serve as a source of drinking water and, in view of its high TDS and metals content, depth to water, and low permeability, cannot now and will not in the future serve as an “underground source of drinking water” (USDW) as that term is defined in 40 CFR §144.3.

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FCCC evaluated groundwater quality from wells in and around the Project area. The groundwater within the mineralized area is different from the groundwater west of Pisgah Fault or east of Fault B. In summary:

• There are no drinking water supply wells within the Project area based on available public records and verified by FCCC’s on the ground field reconnaissance. • There are no public water systems within the Project area. • There are no existing or proposed hazardous waste storage or waste treatment facilities within the Project area.

5.1 Project area Water Quality Figure IV.5-1 presents a Piper Diagram for water quality within and adjacent to the Project area. Figure IV.5-2 presents an assessment of oxygen 18 and deuterium isotopes analysed from groundwater samples collected during the 2018 Fault B Program. The results are plotted against the Nevada meteoric water line. (Welch and Others, 1997).

In the Piper Plot and Isotope vs. Meteoric Water Line were prepared from water quality analyses (Table I.4-1) from wells west of Pisgah Fault, including samples from MWW-1, MWW-S1 (an an open hole located south of MWW-1), were compared to water quality east of Fault B (PW-2) and water quality of the ore body at SMT 93-2. A water quality sample from TW-1, located west of Fault B, and two (2) wells (Well 1829 and Well 1807) both located more than 6 miles west of the Project area, were also evaluated. Well 1829 is located approximately 6.9 miles to the northwest from the center of the ore body and Well 1807 is located approximately 6.5 miles west of the center of the ore body.

The Piper Diagram and assessment of Stable Isotopes demonstrate the following:

1. Groundwater entrained in clays between the Pisgah Fault and Fault B appears to be of a different origin than groundwater east and west of the faults. These present two very distinct water quality affinities, suggesting each system is recharged differently and the waters are not directly connected. 2. Groundwater from water bearing sands and gravels east of Fault B and west of Pisgah Fault are SO4 rich, above 70%, where all other groundwater quality evaluated is SO4 poor, below 70%. 3. All groundwater within and adjacent to the Project area does not meet primary or secondary drinking water standards. Water quality from wells within the ore body exceeds maximum contaminant levels for multiple constituents and does not meet any beneficial use criteria other than mineral extraction. Water quality east of Fault B at PW-2, and west of the Pisgah Fault appear to meet criteria typical for industrial beneficial use but may require treatment to reduce concentrations of undesired constituents.

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Figure IV.5-1: Piper Diagram

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Figure IV.5-2: Stable Isotopes vs. Meteoric Water Line

Global Meteoric Water Line (GMWL) Equation: δ2H = 8.13δ18O+10.8 (Rozanski et al., 1993) Nevada Meteoric Water Line (NMWL) Equation: δ2H = 6.98δ18O-10.6 (Welch and others, 1997) Units: Per mil (‰) in reference to Vienna Standard Mean Ocean Water (VSMOW)

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