SRK Consulting (US) Inc. Suite 520 - 1250 Lamoille Highway Elko, NV 89801

T: 775.753.4151 F: 775.753.4152

[email protected] www.srk.com

Memo

To: Kevin Hurrell Date: May 23, 2018 Company: Bureau of Land Management, BMDO From: Carrie A. Schultz Copy to: Val Sawyer, SRK Project #: 465900.090 Subject: Prospect Mountain Project – Water Resources Report

1 Introduction Gullsil, LLC (Gullsil) is proposing to conduct mineral exploration and underground mining activities on patented and unpatented mining claims in the Eureka Mining District, located about 3.5 miles southwest of the town of Eureka in Eureka County, Nevada. The proposed Prospect Mountain Project (Project) would be located on public land administered by the U.S. Bureau of Land Management (BLM) Battle Mountain District and on private land controlled by Gullsil as shown on Figure 1. Gullsil submitted to the BLM and Nevada Division of Environmental Protection (NDEP) Bureau of Mining Regulation and Reclamation a plan of operations entitled the Prospect Mountain Project Plan of Operations and Reclamation Permit Application (NVN-092893) referred to herein as the Plan (SRK 2017a). The claim block, shown on Figure 1, has been used as the Assessment Area for soils. 1.1 Existing and Authorized Operations Gullsil is presently authorized by the BLM to conduct mineral exploration activities on the Fourth of July claims under a Notice (NVN-094784) as shown on Figure 2. Up to seven drill hole locations and about 3,300 feet of new/bladed 12-foot wide drill roads have been identified for exploratory drilling on claims administered by the BLM in Section 34 of Township (T) 19 North (N), Range (R) 53 East (E) and Section 3 of T18N, R53E. Additionally 3,900 feet of the running surface of an existing access road on public land were maintained within the existing disturbance width. Table 1-1: Presents a summary of authorized disturbance. Table 1-1: Summary of Authorized Disturbance

Disturbance Type Dimension (feet) Acres (Public) Drill Site Within drill/access road disturbance 0.0 Drill Road 12 x 3,300 0.9 Access Road 1.0 Total 1.9

Gullsil plans to conduct similar exploration activities on patented claims controlled by Gullsil under this notice; the total disturbance on patented and public land would not exceed 4.5 acres. Existing and authorized operations are described in greater detail in the Plan. 1.2 Proposed Action Gullsil is proposing exploration and underground mining. Gold and silver as well as other economically viable mineral resource exploration would be conducted using both surface and underground techniques to estimate the in-situ mineral resources and reserves. Gullsil would also develop the Diamond, Berryman, and MacIntosh tunnels to modern standards and mine oxide resources. Activities proposed under the Proposed Action are described in the Plan. The proposed disturbance is shown on Figure 3 and includes: • Construction of surface exploration roads, drill sites, and sumps;

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• RC and core drilling using truck- and track-mounted equipment with support vehicles; • Reopening and upgrading to current standards the existing underground workings at the Diamond, Berryman, and MacIntosh tunnels; • A cemented rock fill plant with a crusher and screening plant and a cement silo; • Drilling geotechnical boreholes for siting assessment of future potential mine facilities; • Collecting drill hole and ore samples for metallurgical testing and geochemical characterization; • Construction of a contained ore transfer stockpile pad; • Construction of two waste rock disposal areas; • Construction of ancillary support facilities (e.g., vehicle parking areas, equipment laydown yards, office space, worker change room, assay laboratory, underground explosives storage, etc.); • Construction of infrastructure (e.g., developing Einar Spring, water pipelines, water storage, hydrocarbon storage, connection to grid power, haul roads, monitoring wells, fencing, communications, and security); • Construction of growth media stockpiles; • Upgrading existing access/haul roads and constructing new roads; • Installing a solar array as a secondary power source; • Establishing stormwater controls; and • Incorporating authorized notice-level disturbance of 1.9 acres on public land. Gullsil estimates that about 83 acres of public and private land would be disturbed under the Proposed Action. Table 1-2 presents the surface disturbance estimates, and Figure 3 presents the proposed disturbance. Table 1-2: Summary of Authorized and Proposed Disturbance

Authorized (acres) Proposed (acres) Total (acres) Component Public Private Total Public Private Total Public Private Total Drill Site 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Drill Road1 0.9 0.0 0.9 -0.9 0.0 -0.9 0.0 0.0 0.0 Exploration Area 0.0 0.0 0.0 3.2 23.0 26.2 3.2 23.0 26.2 Access Road1 1.0 0.0 1.0 -1.0 0.0 -1.0 0.0 0.0 0.0 Haul Roads 0.0 0.0 0.0 12.1 0.8 12.9 12.1 0.8 12.9 Rock Disposal Areas 0.0 0.0 0.0 11.3 0.0 11.3 11.3 0.0 11.3 Ore Transfer Pad 0.0 0.0 0.0 2.3 0.0 2.3 2.3 0.0 2.3 Ancillary2 0.0 0.0 0.0 21.0 1.0 22.0 24.1 1.0 25.1 GMS 0.0 0.0 0.0 0.5 0.0 0.5 0.5 0.0 0.5 Portal 0.0 0.0 0.0 1.9 1.3 3.2 1.9 1.3 3.2 Yard 0.0 0.0 0.0 1.2 0.0 1.2 1.2 0.0 1.2 Total 1.9 0.0 1.9 51.6 26.1 77.7 56.6 26.1 82.7

1 0.9 acres of authorized notice-level Drill Road would be incorporated into the proposed Exploration Area, and 1.0 acres of authorized notice-level Access Road would be incorporated into the proposed Haul Road and Portal disturbance areas. 2 Includes laydown areas, solar arrays, parking and fuel storage areas, stormwater controls, fencing, growth media stockpiles, well pads, spring development, power lines, and septic system.

1.2.1 Surface Exploration Overland travel would be used for Project activities, where possible, to minimize the need for new road construction. New roads would be constructed utilizing standard cut and fill techniques to a running width of up to 16 feet. The depth of cut would be kept to a minimum, and growth media removed during construction

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 3 would be stockpiled as the fill slope to be used during reclamation. Road construction within drainages would be avoided whenever possible. When drainages must be crossed with a road, Best Management Practices (BMPs) established by the NDEP Handbook of Best Management Practices (NDEP 2008), would be followed to minimize surface disturbance and erosion potential. Culverts would generally not be installed in exploration roads but would be used as needed. Roads would be constructed with a Cat D-7 dozer or equivalent and would occur intermittently throughout the life of the Project. Specific road locations would be determined in the field based on geologic information collected during the exploration program. Maintenance of exploration roads would include minor seasonal grading as needed. Erosion controls would be monitored in the spring and fall. Road maintenance would consist of smoothing rutted surfaces and holes on existing access and drill roads. Maintenance of existing roads would be conducted only on an as-needed basis. New drill site disturbance would be kept to the minimum necessary for safe access and a safe working area for equipment and crews. Surface disturbance would vary based on the slope of the terrain where the sites are constructed. Sumps, typically one per drill site, would be constructed, as necessary. A laydown yard would be located within the drilling area as needed. The surface exploration program would consist of drilling bore holes utilizing track- or truck-mounted RC and core drill rigs and support equipment. Cuttings not bagged and removed during sample collection or remaining in the sumps would be used as a source of backfill and placed back down the borehole. Holes would be both vertical and angled with average drill depths of 1,500 feet bgs. More than one drill hole may be drilled from each site. Gullsil anticipates that up to 300 holes would be drilled during the Project including holes approved under Notice NVN-094784 and exploration drilling on patented. No more than four holes would be open at any one time. Water or non-toxic drilling fluids may be utilized, as necessary, during drilling. Gullsil would obtain water from the proposed Prospect wells 1, 2, and 3 and Einar Spring and/or Eureka County, pending arrangements, or other legal water sources. Sediment traps and sumps would be incorporated into each drill site to collect drill cuttings and manage drill water. The mixture of drill cuttings and drill water from the drilling operation would be managed in the sediment traps. The drill cuttings would be settled and remain in the sediment traps. A maximum of four drill rigs (both RC and core) are expected to be in operation at the Project area at any time. Each drill crew includes approximately three contract personnel, plus a Gullsil-employed geologist. Up to 24 individuals may be working at any time on the Project. Drilling activities would continue for up to 24 hours per day for some drill rigs. 1.2.2 Underground Exploration and Mining Gullsil proposes to conduct underground exploration and mining activities using the Diamond, Berryman, and MacIntosh tunnels to access existing workings. The extent of the remaining mineral resources would be assessed, and ore and waste rock samples would be collected for geochemical and metallurgical testing. The rock quality would be evaluated for potential future underground development and mining. Underground activities would use conventional underground equipment as shown in Table 1-3 or other equipment as required. All underground excavations would remain above the existing groundwater table; dewatering activities would therefore not be necessary for the Proposed Action. An experienced underground mining contractor would be responsible for bringing the existing underground workings up to current standards to meet MSHA requirements. Table 1-3: Proposed Mining Equipment

Surface Equipment Surface Equipment Loaders D-7 or equivalent Dozer1 Truck Motor Grader1 Drill Jumbo Skytrak 8042 or equivalent Fork Lift Slushers Sandvik LH410 or equivalent Front End Loader Underground Refuge Stations Water Truck

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Surface Equipment Surface Equipment Personnel Tractor Supply Truck Rock Bolter Crew Vans Jackleg Drills Light Vehicles (diesel pickups) (4) Longhole Drills Generators (1 + Backup) Fork Lift Fuel Tanks (under 10,000 gallons) Backhoe 420D or equivalent Excavator Articulated Rear Dump Trucks Cement Backfill Batch Plant Powder (Explosive-Delivery) Truck RC/Core Drill Rigs2 Portable Water Tank 1This equipment would be contracted and used on an as-needed basis. 2 Two of the drill rigs are authorized Each of the tunnels would be increased from approximately six feet high and four feet wide to approximately 18 feet high by 18 feet wide to accommodate the equipment, piping, and ventilation ducting; drifts would be approximately the same dimensions. The blast holes would be loaded with a mix of ammonium nitrate and fuel oil. After blasting, the shot rock would be mucked using load-haul-dump machines and underground haul trucks. Once the workings are sufficiently deep, an underground explosive day-storage area would be established. Renovating the tunnels and underground work would produce an estimated 360,000 tons of waste rock that would be placed either in existing drifts and/or on the proposed rock disposal areas. This facility is further described below. Gullsil expects mining would initially start at a low rate and eventually ramp up to a rate of 1,000 tons per day over the life of the Project. The existing Berryman and MacIntosh tunnels would be used to connect the underground workings with the surface for an escape-way. One or both tunnels would be upgraded to modern standards and to meet MSHA requirements for underground escape-ways. The tunnels would include design for ventilation fans. In addition to the tunnels, the underground work would require drill station development and test stope areas. Underground drill stations would be installed as needed for close-spaced fan-drilling into the potential ore zones using underground RC and core drills. Ground control during renovation of the tunnels, drifts, drill stations, and test areas would consist of rock bolts, chain link fencing, shotcrete, steel sets, or other appropriate ground control methods typical of Nevada underground operations. Ground conditions would be variable, but Gullsil anticipates that many areas would be competent and require less support. In selected areas of drill-defined ore, test stope mining may be done. The stoping method would be determined by the character (strength, fracture density, etc.) of the host and waste rock. Areas selected for test mining would be representative of the various types of rock quality conditions within the potential ore zones, and several areas may be targeted. Ground control in stope areas may require the use of cemented rock fill (CRF). If CRF is necessary, a silo would be located on the tunnel pad to provide cement that would be mixed with crushed waste rock to create cemented backfill. Amounts of cement that may be needed are presently unknown and would be dependent upon the nature of the waste rock that would be used as cemented rock fill, amount needed, etc. Initially, the CRF plant would be located on the surface. Rock would be trucked from the underground to the surface where it would be crushed, blended with cement, and transported back to the underground workings for placement. The CRF plant would be moved underground as mining progresses. The tunnel entrance would be secured for public safety and to prevent unauthorized access. Waste rock and ore would be collected and staged in an underground muck bay(s). The waste rock would generally remain in the muck bay(s); ore would be placed on the ore stockpile for subsequent offsite metallurgical testing and processing. Waste rock would be removed to the surface and placed on the rock disposal areas.

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1.2.3 Ore Transfer Stockpile Pad and Ore Transportation Ore would be transported from the tunnel entrance to the ore transfer stockpile pad during the underground mining. The proposed ore transfer stockpile pad would hold approximately 20,000 tons of ore obtained from underground workings and would measure about 110 feet by 230 feet. The area where ore will be stored and loaded into trucks within the ore transfer stockpile pad (the ore storage area) would be constructed with a 12-inch thick low-permeability soil layer. This soil layer would be constructed using compacted clay or bentonite amended soil with a permeability of less than 1×10-6 cm/sec. Stormwater runoff from the ore storage area would be collected in a stormwater sump on the north end of the ore transfer pad constructed with a single layer of 80-mil high-density polyethylene (HDPE) geomembrane liner. The contiguous stormwater sump and ore storage area are designed to collect and fully contain precipitation from the 100-year, 24-hour storm event which is equivalent to approximately 133,000 gallons. The non-contact portion of the ore transfer stockpile pad would be managed by segregating runoff into a sediment trap to the south. Specifications would be included in the site water pollution control permit. Stormwater collected in the sump would be accessible to a water truck for removal. This water would be used for operations or evaporated and would not remain exposed in the sump for long periods to reduce mosquito breeding habitat. The ore transfer stockpile pad would also be designed to control and divert runon and allow access by equipment to load highway trucks for transport to an offsite mill. The ore would remain in the transfer stockpile pad temporarily until transported offsite for metallurgical testing and processing. As part of the mining and exploration activities, Gullsil proposes to ship ore-grade material offsite for testing and processing. The ore would be transported using highway haul trucks in approximately 35-ton loads. The ore would be transported to suitable processing facilities. Two potential processing facilities could be accessed by traveling east along Highway 50 toward Fallon, NV or Virginia City, NV for one-way distances of 180 and 240 miles, respectively. The offsite mill that receives the ore would be permitted under a Nevada water pollution control permit that has received the necessary authorizations to toll mill the ore. 1.2.4 Rock Disposal Areas Although the majority of waste rock encountered during the test mining would remain underground, about 360,000 tons would be transported to the surface for storage in the two rock disposal areas. The rock disposal areas would be engineered structures constructed in accordance with an approved water pollution control permit. Geotechnical drilling and/or trenching may be performed in the footprint of the rock disposal areas to assess the geotechnical characteristics of the foundation. The existing rock disposal area would be incorporated into the proposed north rock disposal area. Prior to construction of both rock disposal areas, the foundations would be cleared and grubbed of vegetation; growth media would be salvaged where available and stored in growth media stockpiles. The waste rock is expected to be net neutralizing and not generate acid or mobilize metal(loid)s as discussed below. The rock disposal areas would be up to 125 feet above the natural ground surface with a crest elevation of about 7,875 feet above mean sea level (amsl) on the north rock disposal area and 7,950 on the south rock disposal area. The side slopes would be constructed at the angle of repose and reclaimed to 2.5 horizontal to vertical. Stormwater and snow melt contacting the rock disposal areas would be collected in down-gradient sumps and allowed to evaporate. Up-gradient stormwater would be diverted through diversion channels around the tunnel area and allowed to flow into natural drainages. 1.2.5 Growth Media Stockpiles Growth media would be salvaged where possible and stockpiled for subsequent use in reclamation. These piles would be in place for varying lengths of time and would be seeded with an interim seed mixture and protected from run-on and run-off until final placement. Small woody debris accumulated through stripping would be incorporated within the growth media stockpiles. Trees removed during activities would be harvested as firewood and made available for use by Eureka residents. Gullsil would obtain a wood cutting permit from the BLM for trees removed from public land.

1.2.6 Infrastructure Gullsil would develop the necessary infrastructure to support both the surface and underground activities. Where possible, Gullsil would renovate existing structures for use. These facilities would include:

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• Hydrocarbon storage for gasoline, diesel fuel, oils and greases; • A septic system for the change room and office trailer; • Line power and an emergency generator; • Site access roads and truck scales; • A communication system; • Security such as fencing; • Developing Einar Spring and Prospect wells 1, 2, and 3 as water sources, and construct storage tanks, a potable water system, and associated piping; • Monitoring wells; • Stormwater controls; and • A solar array. Hydrocarbon Storage Small quantities of gasoline, diesel fuel, oils, and greases would be stored in a contained area for use in exploration and mining activities. The tanks would be located in secondary containment that would hold 110 percent of the largest volume tank and if out of doors, additional capacity to hold the 100-year, 24-hour storm event. The floor of the containment would be sealed to prevent spills from entering cracks or permeating the concrete and being released to the environment. Table 1-4 provides an estimated inventory of the materials that may be used. Spill control is discussed below. Table 1-4: Estimated Hydrocarbon and Reagent Volumes and Shipments

Amount/ Approximate Anticipated Hydrocarbons and Reagents Storage (gallon) Delivery consumption Trucks/ Month (gallon) per day (gallon) Off-road Diesel Fuel 6,000 4,500 4 600 Automatic Transmission Fluid 55 55 - 1 Engine Oil 500 250 - 20 Hydraulic Fluid 1,000 250 - 100 Gear Oil (50W) 500 250 - 25 Gear Oil (90W) 500 250 - 10 Cat FD01 Lube 500 250 - 25 Drill Oil (ISO VG 100-150) 500 250 - 20 Antifreeze 110 55 - 1 Used Oil 1,500 1,500 4 200 Used Antifreeze 55 55 - 1 Ammonium Nitrate 50,000 pounds 44,000 pounds 1 1,000 pounds 2 - 500-gallon Propane 500 variable variable tanks

Fresh Water Supply, Potable Water, and Septic System Fresh water would be supplied from one or more various sources. Water may be trucked to the site from Eureka or other legal water sources as needed and stored in tanks at the tunnel pad(s). One of three production wells may be constructed to pump up to 500 gallons per minute (gpm) of fresh water to the fresh water storage tanks as shown on Figure 4. This water would be used for drilling and dust control, and as a potable water supply. An underground pipeline would be constructed between the water sources and tanks

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 7 to meet modern standards. Gullsil presently owns or controls water rights as shown in Table 1-5. Proposed water use would be covered by Gullsil’s water rights. Table 1-5: Water Rights Owned by Gullsil

Div. Rate Div. Rate Point of Diversion Application Manner of Application Status Description No. Use (cubic feet per (gallons per second) day) Heard Well 194901 Forfeited Irrigation 2.7 1,745,056

Prospect Well 3 Ready for Action - Mining & 85651 2.7 1,745,056 (proposed) Protested Milling

83915 Permitted 0.22 142,190 Mining & Einar Spring Milling V108802 Vested

Mining & Prospect Well 1 V108812 Vested Milling 0.472 305,062 Mining & Prospect Well 2 V108822 Vested Milling 1 Court decision pending 2 Proofs submitted to the Nevada Division of Water Resources and under review The potable water delivery system would be designed, constructed, and operated as required. Water would gravity feed or be pumped to a storage tank near the office trailer and then into a potable water treatment system and distributed for use. A septic system and leach field would be installed near the office trailer in accordance with state and local regulations. Biosolids would be pumped as necessary by a licensed septic waste hauler and transported to a licensed repository. Portable toilets would be used as needed. The drilling, installation, and abandonment of supply wells would be conducted by a licensed Nevada well driller, as specified in NAC 534.358 et seq as discussed below. Develop Einar Spring Einar Spring, shown on Figure 3, supplied drinking water to the historic town of Prospect below the Diamond Tunnel. Gullsil plans to assess the potential for this spring to be a water source by developing the spring. The Nevada Division of Water Resources (NDWR) has granted Gullsil a surface water right (Permit No. 83915) for 0.22 cubic feet per second or 3.31 acre-feet annually. Pending NDWR review, these rights would be converted to vested water rights. A spring box is currently in place at Einar Spring together with an unused underground water pipeline. No surface water expression is present. Development would generally entail removing vegetation from the surrounding area, excavating a trench to locate the impervious layer, constructing a rock reservoir, and constructing a new collection box. The spring water would be stored in a tank, which would feed the potable water treatment. Figure 4 shows the conceptual spring development. An underground water pipeline would be constructed generally following the alignment of the existing and unused water line. Electrical Power Electrical power would be supplied to the site via the existing Mt. Wheeler Power Co. three-phase power line that crosses the Project Area. Mt. Wheeler Power Co. would install a step-down transformer as needed. An on-site solar power array would be constructed above the Diamond Tunnel area to augment the line power and reduce the carbon footprint. The solar array would consist of ground-mounted panels measuring approximately eight feet by six feet each. The panels would be angled to the south with their highest points located approximately ten feet above the ground surface. The array would be located within an approximate four-acre area; a power line would connect the solar array to the Diamond Tunnel area substation.

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Communication Facilities Communication facilities would include a tower and on-site repeaters as needed. These systems would be powered by either propane, line power, solar, or wind. These facilities would support an on-site radio system, communications with outside systems, internet, and cell phones for the safety of employees, contractors, and regulators. Security Swing gates with locks, fences, and signs would be used to exclude the public from the active mining area as shown on Figure 3. Access to the Prospect Mountain communicate site facilities would remain open. Access to the tunnels would be controlled by the installation of two locking gate panels. Blasting supplies and explosives would be stored underground in accordance with MSHA regulations (30 CFR § 57.6000 et seq.) and U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives regulations (27 CFR § 555 et seq.). During reclamation, a secure barrier such as a locked gate would be installed over the tunnel entrances of private ground to prevent unauthorized access. Stormwater Control Structures Existing stormwater control structures would be maintained or re-established, on an as needed basis, as described below: • Roads would receive periodic inspections for maintenance; • Stormwater generated above the tunnel entrances would be routed around the top of the cut slope and into the nearest natural drainage; • Stormwater generated above the ore transfer stockpile would be routed around the stockpile pad and into the nearest natural drainage; and • Stormwater falling on the ore transfer stockpile pad would be routed to an earthen sump or a tank located adjacent to the ore transfer stockpile pad.

1.2.7 Ancillary Support Facilities Gullsil would develop the ancillary facilities to support both the surface and underground activities. These facilities would include: • An equipment and materials laydown area; • Ancillary use areas including yards; • Employee and visitor parking; • An office trailer; • Maintenance shop; • An employee change room; • Assay laboratory; and • Explosive storage magazines in compliance with MSHA and Bureau of Alcohol, Tobacco, Firearms, and Explosives requirements. The assay laboratory would perform both fire and atomic absorption assays to determine gold and silver content of the material excavated from the underground workings. Used cupels would be analyzed to determine the appropriate means of disposal. Atomic absorption residues would also be analyzed, and the appropriate means of disposal would be identified. 1.2.8 Project Schedule Project activities would continue for about ten years with reclamation work beginning in Year 11. Monitoring and maintenance would continue until Year 16.

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1.2.9 Environmental Protection Measures All Gullsil environmental protection measures are described in the Plan. Those environmental protection measures specific to water resources are included in this report. Solid and Hazardous Materials No hazardous or toxic waste, waste oil, or lubricants would be disposed of on public or private lands. Trash and other debris would be contained on the work site and then hauled to an approved offsite landfill facility. Burial and/or burning of trash and other debris on public lands would not be performed without specific authorization and permits from the BLM and other appropriate agencies. Gullsil has prepared an Emergency Response and Spill Control Plan intended to provide adequate on-site control and clean up materials and instruct on-site personnel in spill prevention and clean-up methods. Oil, noxious fluids, fuels, and chemicals spilled onto the ground or water would be cleaned up immediately. After clean-up, the oil, noxious fluids, fuels, and/or chemicals and any contaminated materials would be removed from the site and disposed of at an approved disposal facility. In the event hazardous or regulated material, such as diesel fuel and/or lubricants, is spilled, Gullsil would take measures to control the spill, and the NDEP and BLM would be notified as per NDEP regulations, and the spill control plan. Petroleum contaminated soils resulting from fuel and lubricant spills would be removed and disposed of at an approved offsite location. Hazardous materials employed at the site would include diesel fuel and various lubricants. All fuel and lubricants would be temporarily stored in a secondary containment area. Fuel and lubricant tanks would be transported to an approved offsite facility for recycling for final disposal. Erosion and Sediment Control Best management practices would be utilized to minimize the surface disturbance and erosion potential. Haul and area access roads would receive periodic inspections for maintenance issues. Maintenance of the access and haul roads may include limited scraping or blading and re-establishment of safety berms, and stormwater swale and ditch upkeep when necessary. Gullsil would conduct erosion control monitoring during the spring and fall and opportunistically during major precipitation events to monitor the effectiveness of the erosion controls. During winter months, snow removal would be conducted using a snow plow mounted on an over-the- highway dump truck. Snow would be piled over the side of the safety berms on the access and haul roads or would be stacked in wide, flat areas near the access roads, drill sites, and laydown yards. Snow would not be stacked or piled in areas where spring runoff could cause sediment loading in nearby streams, ephemeral drainages, or result in damage to access and haul roads. If necessary, snow removal equipment would be utilized to remove snow from areas where spring runoff could potentially contribute to sediment loading in nearby streams and ephemeral drainages. Sediment control structures include, but are not be limited to, fabric and/or hay bale filter fences, siltation or filter berms, and down-gradient drainage ditches to prevent unnecessary or undue degradation. Sediment traps and sumps would be incorporated into each drill site to collect drill cuttings and manage drill water. Drill Hole Plugging Mineral exploration, development, and condemnation drill holes as well as monitoring, production, and dewatering wells subject to the NDWR regulations would be abandoned in accordance with applicable rules and regulations (NAC 534.4371). Boreholes and production wells would be sealed to prevent cross contamination between aquifers, and the required shallow seal would be placed to prevent contamination by surface access. Those bore holes that intercept underground workings would be abandoned in stages. Initially, a bridge plug would be installed in the hole to be abandoned by the drillers at a level above where the bore hole intercepts the underground working. A cement cap would be placed in the hole above the bridge plug and allowed to set in order to form a secure seal. After the cement cap is set, abandonment fluid would be placed in the bore hole in accordance with the Nevada Administrative Code.

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Waste Rock Management Waste rock would be placed on the rock disposal areas during operations. No special handling or management of the waste rock material is proposed. Sediment control structures would be placed below each rock disposal area to minimize impacts to surface water from sediment. Monitoring Gullsil would monitor the proposed activities to identify and/or prevent impacts to surface and ground water resources. Monitoring of surface and ground water resources would be performed in accordance with the water pollution control permit and the stormwater pollution prevention plan. As required by the water pollution control permit, Gullsil would monitor water levels and collect water quality samples in accordance with Environmental Protection Agency (EPA) standard operating procedures and chain-of-custody requirements. Samples would be analyzed by a Nevada-certified laboratory for NDEP Profile I constituents at a minimum using recognized EPA analytical methods. Reporting content and frequency would be performed in accordance with the water pollution control permit conditions. In the event that analytical or other monitoring results indicate an exceedance of the Profile I or other stipulated reference values, Gullsil would immediately re-sample to verify the result as well as report the exceedance according to permit reporting requirements. Gullsil would coordinate with the BLM and the NDEP as to the corrective actions that would need to be instituted. Spills will be reported and remediated as described above. Reclamation Gullsil has presented a reclamation plan within the Plan which includes procedures to prevent unnecessary and undue degradation, earthworks, revegetation, underground working security, waste disposal, and post- mining land use. The reclamation plan has been prepared in accordance with BLM and NDEP regulations and requirements in 43 Code of Federal Regulations 3809 and Nevada Administrative Code 519A. 1.3 No Action Alternative The objective of the No Action Alternative is to describe the environmental consequences that would result if the Proposed Action were not implemented. The No Action alternative forms the baseline from which the impacts of all other alternatives can be measured. Under the No Action Alternative, the Proposed Action would not be approved by the BLM, and no exploration or mining activities would be carried out other than those activities that are authorized. 1.4 Alternatives Considered but Eliminated from Detailed Analysis No other alternatives have been considered for this Project. 1.5 Cumulative Effects Cumulative impacts are the sum of all impacts resulting from past, present (including the Proposed Action), and reasonably foreseeable future actions (RFFAs). The purpose of the cumulative analysis is to evaluate the Proposed Action and No Action Alternatives contributions to the cumulative environment. The cumulative effect study area (CESA) is summarized in Table 1-6 and is shown on Figure 5. Table 1-6: Cumulative Effects Study Area

USFS- BLM-managed Private CESA Name CESA Description managed Total Acreage Acreage Acreage Acreage Diamond Valley Water CESA Hydrographic Sub- 417,887 0 60,770 478,656 Basin

1.5.1 Past and Present Action Disturbance acreages associated with Past and Present Actions which have been assigned an area under the BLM’s Land and Mineral Legacy Rehost 2000 System (LR2000) system (BLM 2017) or which were

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 11 mapped using aerial photography or GIS data have been collected and summarized in Table 1-7. Relevant past and present action categories are discussed in the following sections. Table 1-7: Past and Present Action Disturbance/Use Area Summary

Type of Activity1 Acres within the Water CESA Mineral Materials 88 Mining and Exploration - Surface Management Plan 9,052 Mining and Exploration - Surface Management Notice 10 ROW - Roads and Other 6,163 ROW - Power Facilities 13,280 ROW- TeleComm Facilities 2,747 ROW - Pipelines 6 ROW - Water Facilities 401 Land Sale 1,730 R&PP 150 Municipal Areas 382 Irrigated Agriculture 38,470 Wildfire 21,870 Total 94,349 1Not all disturbance acreages may be located within the CESA Mineral Exploration, Mining, and Mineral Materials On the basis of the LR2000 database (which records lands and mineral actions) a variety of mineral exploration, mining, and mineral material sites exist within the CESA. These range from small notice-level exploration operations to operating mines with permitted surface management plans. The largest authorized operation is the Mount Hope Mine operated by General Moly (NVN-082096); this mine is not yet in production. The next largest operation is the Ruby Hill Mine (NVN-067762). Rights-of-Way The LR2000 database was used to query the various types of rights-of-way (ROWs) that have been applied for or approved in the CESA. Existing ROWs include the following: roads and highways; power facilities, telecommunication facilities, pipelines, and other water facilities. Many ROWs are linear features which may not be located entirely within each CESA. For the purposes of this assessment, disturbance areas assigned to each ROW have been calculated as occurring entirely within the CESA. Some of the more significant linear ROWs which occur within the CESAs include Highway 50 and State Route 278. Land Sales and Transfers Land sales and transfers within the CESA include lands sold, transferred, and lands acquired under the Recreation and Public Purposes Act (R&PP). When lands are sold or transferred to either private individuals or to other administrative entities, the activities which occur on them are no longer required to comply with regulations applicable to BLM-managed land. Municipal Areas The only substantial municipal area within the CESA for which disturbance areas have been calculated is the town of Eureka. The town of Eureka contain homes, businesses, municipal buildings, roads, and utilities. Irrigated Agriculture Most of the irrigated agricultural areas within the CESA are focused within the southern end of Diamond Valley. Crops in the valley consist mainly of alfalfa and hay. Irrigated agricultural areas as mapped using aerial imagery are shown in Table 1-7.

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Wildland Fires Areas burned during wildfires within the CESA between 1900 and 2012 have been mapped and calculated as disturbance in Table 1-7. Many of the areas burned years ago and would have become revegetated by this time, either through seeding or through the natural reestablishment of native vegetation. The post-burn vegetation may be different than the previously existing vegetation. Dispersed Recreation Developed recreational opportunities are relatively sparse in this part of Nevada and tend to be limited to off- highway vehicle/all-terrain vehicle use, dirt bike riding, hunting/shooting, and camping. Other recreational activities may include mountain biking, horseback riding, sightseeing, historical touring, outdoor photography, nature study, pine-nut gathering, wildlife viewing, and rock collecting. Recreational activities are focused within areas managed by the U.S. Forest Service as part of the Humboldt-Toiyabe National Forest. Road-trip style tourism occurs along Highway 50 which results in Eureka as a destination focused on historical sightseeing. Recreation within and around Eureka may result in the use of hotels, restaurants, and other services offered by the community. Other Activities Other activities which occur within the area include transportation, livestock grazing, wild horses use, wildlife use, and wildlife habitat improvement projects. Geothermal leases and phosphate exploration leases are present within the CESA but have not been include in Table 1-7 since the associated disturbance areas are generally quite small. 1.5.2 Reasonably Foreseeable Future Actions Disturbance acreages associated with RFFAs which have been assigned an area under the LR2000 system (BLM 2017) have been collected and summarized in Table 1-8. Table 1-8: RFFA Disturbance Summaries

Type of Activity1 Acres within the Air and Water CESA Mineral Materials 0 Mining and Exploration - Surface Management Plan 164 Mining and Exploration - Surface Management Notice 5 ROW - Roads and Other 0 ROW - Power Facilities 70 ROW- TeleComm Facilities 0 ROW - Pipelines 0 ROW - Water Facilities 0 Oil and Gas Exploration 50 Land Sale 192 R&PP 80 Total 561 1Not all disturbance acreages may be located within the CESA Grazing, recreation, transportation, and wildlife use are expected to continue at current levels. Fires and fire suppression activities are expected to continue to occur in the region.

2 Affected Environment The claim block (Assessment Area) has been used for the analysis boundary for water resources.

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2.1 Groundwater Resources The Assessment Area is located in the southern end of Diamond Valley, approximately 3.5 miles southwest of Eureka, Nevada. Diamond Valley is an intermountain valley, with an area of approximately 735 square miles, and is bounded on the east by the Diamond Mountains and on the west by the Sulphur Spring Range, Whistler Mountain, and the Mountain Boy Range. The southern boundary is formed by the Fish Creek Range, and the northern boundary by the Diamond Hills. The groundwater system in the Assessment Area is part of the regional Diamond Valley Hydrographic Basin 153. Numerous hydrogeological investigations have been conducted within the Diamond Valley Hydrographic Basin for the nearby Ruby Hill Mine (BLM 2005) and the Mount Hope Mine (BLM 2012). These investigations have defined the hydrogeologic and geochemical conditions within the Diamond Valley Hydrographic Basin and beneath the Ruby Hill Mine area. The following text from the Final Supplemental Environmental Impact Statement for the Ruby Hill Mine Expansion – East Archimedes Project (BLM 2005) summarizes groundwater conditions in the Project vicinity. Groundwater recharge, storage, and flow depend on geological conditions. Diamond Valley, groundwater occurs in both alluvium and bedrock aquifers. In the alluvium, groundwater recharge, flow, storage, and discharge are controlled by the permeability of the unconsolidated sediments. In the bedrock, porosity, permeability, and structure (i.e., faults and fractures) control the recharge, flow, storage, and discharge of groundwater. The Prospect Peak area has been mined along with the Ruby Hill Mine since the late 1800s. The underground workings at the Diamond Tunnel and Silver Connor Tunnel consist of four shafts with the No. 4 shaft excavated to about the 1,350-foot level bgs. Based on historical literature, the workings were never dewatered and continue to be dry to the present day (SRK 2017). The No. 4 shaft was excavated to find the roots of the oxide ore structures, and the 1,350-foot level was the lowest development of record. Figure 6 shows the interpolated groundwater level in the vicinity with respect to the existing underground workings. Three drill holes, HRH-1724, HRH-1725, and HRH-1726 were drilled by Homestake Mining Company of California in 2001. HRH-1724 was drilled on the Diamond Mine dump near the Diamond Tunnel to a total depth of 1,100 feet bgs and did not encounter water (EPAR 2001a). HRH-1725 was drilled to a depth of 2,100 feet in New York Canyon. The standing water level was noted during a deviation survey at 1,178 feet bgs (EPAR 2001b). HRH-1726 was drilled to a depth of 1,503 feet bgs on a ridgetop south of the Diamond Tunnel and did not encounter water (EPAR 2001c). Figure 6 presents the locations of these three drill holes. Based on the public data, the groundwater level is anticipated to be at least 1,100 feet bgs and deeper in the vicinity of the Diamond Tunnel. 2.2 Surface Water Resources including Wetlands and Riparian Areas Diamond Valley is a closed hydrographic basin except for inflow through Devil’s Gate, a topographic low point between Whistler Mountain and the Mountain Boy Range. Devil’s Gate permits surface and subsurface inflow from Antelope, Kobeh, and Monitor valleys (BLM 2012). Surface water flows in the Prospect Mountain area are ephemeral and are dependent on seasonal precipitation. Surface drainages contain water only during storms or intense snowmelt. The average annual precipitation in Eureka, Nevada is 11.83 inches and occurs mainly as winter snow and locally intense summer thunderstorms. Precipitation from the nearby SnoTel site at Diamond Peak has recorded an average annual precipitation of 21.54 inches from 1984 to 2016, which is likely more representative of the conditions for the Project area. The northeastern and eastern faces of Prospect Mountain drain into Fish Creek Valley. The western faces of Prospect Mountain drain into Spring Valley. Einar Spring is the only surface water feature located within the Project Area although actual surface water expression is not present. Einar Spring had partially supplied domestic water to the town of Prospect at the base of Prospect Mountain in New York Canyon (Surveyor General 1899). Within a two-mile buffer of the Assessment Area, there are 15 historical springs as shown on Figure 7. No wetland or riparian features are associated with Einar Spring or other areas within the Assessment Area. The jurisdictional determination survey has been completed and the report is in preparation. Based on nearby previous determinations, waters of the U.S. are not expected to be located within the Assessment Area.

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 14

2.3 Water Quality and Geochemistry No groundwater quality information is available for the Assessment Area. Groundwater quality sampling conducted in 2004 found that groundwater in the Ruby Hill Mine area was mainly calcium bicarbonate water with total dissolved solid (TDS) values below 400 milligrams per liter (mg/L). Groundwater from the pumping of well PW-1, in the Ruby Hill Pit, was within Nevada reference values for all constituents. Groundwater from wells to the north of the Ruby Hill Mine was within Nevada reference values for all Nevada Profile II constituents and was characterized by a pH in the range of 7.5 to 7.8 and TDS of 400 mg/L or less. It also was calcium bicarbonate water. Groundwater quality in the carbonate bedrock of the mine site was within Nevada drinking and stock water standards for most constituents, arsenic in the mine area being the only exception with values up to 0.84 mg/L (BLM 2005).

3 Environmental Consequences Effect Intensity Level Definitions Negligible: Effects to the aquatic resources would not result in detectable effects. Chemical, physical, or biological changes to water quality would not be detectable. Hydrology of the area would not be affected, or impacts would not be measurable. Impacts to the hydrologic regime would be slight and short-term. Minor: Effects to aquatic resources would result in detectable effects. These changes would be temporary and the resource would return to pre-impact condition within a few days. Chemical, physical, or biological changes to water quality would be detectable, but would be within historical baseline or desired water quality conditions. Impacts on hydrology, such as an increase or decrease in surface water or groundwater flow, would be detectable. If mitigation were needed to offset adverse effects, it would be relatively simple to implement. Moderate: Effects to aquatic resources would result in detectable effects; these changes would not be permanent, and the resource would rebound to pre-impact conditions after one season. Chemical, physical, or biological changes to water quality would be detectable, but historical baseline or desired water quality conditions would only be temporarily altered. Impacts on hydrology would be readily apparent. Mitigation would probably be necessary to offset adverse effects. Major: Effects to aquatic resources would result in detectable effects which would likely result in long-term to permanent changes. In extreme cases, species may be extirpated due to loss of habitat. Chemical, physical, and biological changes to water quality would represent a major degradation from historical baseline water quality conditions. Alternations could be long-term. Impacts on hydrology would be readily apparent and would substantially change the hydrologic regime over the area. Duration Definitions Short-term: One day or less for water quality; one year or less for aquatic resources. Long-term: Greater than one day for water quality; greater than one year for aquatic resources. Context Definitions Localized: A single seep, spring, wetland, or tributary for surface water resources or within the hydrographic unit for groundwater resources. Regional: Aquatic and water resources covering several seeps, springs, wetlands and tributaries for surface water resources or across more than one hydrographic unit for groundwater resources. 3.1 Proposed Action 3.1.1 Groundwater Resources The underground workings are not anticipated to encounter groundwater based on information obtained about the water table elevation and the historically dry workings. Negligible impacts to groundwater resources are expected to occur as a result of underground exploration or mining give the environmental protection measures. Groundwater resources would be impacted through permitted water use related to the Proposed Action. The anticipated water use of 500 gpm would be taken from the Diamond Valley Hydrographic Basin. Some of the water used would be lost through evaporation during dust control and drilling, while the rest is expected to infiltrate back into the hydrographic basin’s recharge area. Actual recharge of the hydrographic basin would

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 15 be minimal during the life of the Project while impacts related to the actual withdrawal of water would be short-term, lasting for the duration of the Project. Einar Spring is the only surface water feature located within the Assessment Area and is the closest spring to the Prospect wells, although no actual surface expression of water is present. The anticipated water use of 500 gpm is within Gullsil’s water rights and is equivalent to approximately 807acre feet per year (AFY). The Diamond Valley hydrographic basin has an underground usage total of approximately 133,605 AFY (NDWR 2017). Gullsil’s water usage would constitute approximately 0.6 percent of the Diamond Valley underground water usage total. While groundwater pumping may affect Einar Spring, it would not change the presence of surface water at the site. Impacts to groundwater related to water use would be long-term, minor, and localized. 3.1.2 Surface Water Resources including Wetlands and Riparian Areas Surface water resources could be impacted from land clearing and the resulting increased sedimentation to drainages during snow melt and precipitation events. Gullsil’s Project design and environmental protection measures would minimize these impacts. The impacts would be minor, localized, and long-term, lasting until reclamation has been completed and revegetation success established. 3.1.3 Water Quality and Geochemistry A waste rock and ore characterization program was conducted by SRK Consulting (U.S.), Inc. (SRK). SRK collected 16 samples from the underground workings in the Diamond Tunnel area that are representative of waste rock and ore that would be mined. Based on the geology observed in the underground workings and geologic modeling, the main lithologies that would be encountered during expansion of the underground workings consist of Hamburg Dolomite and Dunderberg Shale. All of the waste rock and ore that would be encountered during the tunnel-widening activities would consist of oxidized material (SRK 2016). Gullsil does not plan to mine sulfidic material as part of the Proposed Action. The sampling and testing completed to date has been limited to static geochemical characterization. Static testing methods are designed to address the bulk geochemical characteristics of the samples, and to assess the potential of the waste rock and ore to generate acid and/or leach metals in drainage. Static testing (i.e., acid base accounting, net acid generation, and meteoric water mobility procedure) provides an approximation of acid generation and trace metal release potential, which is used to determine where more comprehensive kinetic testing is warranted. The results of the static geochemical test work demonstrated that the Prospect Mountain waste rock and ore material is net neutralizing and presents a low risk for acid rock drainage and metals release. Sulfide sulfur was below analytical detection limits in all samples tested and the carbonate nature of the sedimentary host rocks results in a significant excess of neutralizing (buffering) capacity. All of the 16 samples submitted for characterization testing were classified as non-acid generating materials based on the BLM and NDEP criteria, and kinetic testing is not required to address any uncertainties with the acid base accounting testing. The paste pH was also moderately alkaline, demonstrating a low level of short-term reactivity and indicating there are no soluble acid sulfate salts from prior oxidation on the material surfaces (SRK 2016). The excess of neutralizing capacity indicates that net acid conditions are unlikely to develop at Prospect Mountain, and the potential for metal leaching from the waste rock and stockpiled ore would be low. However, a few metal (loid)s are likely to be mobile under the circum-neutral to moderately alkaline conditions, particularly from the ore. Meteoric water mobility procedure tests provided an indication of the elements that may be released during meteoric rinsing of the ore and waste rock at concentrations above NDEP Profile II reference values. Constituents that were leached from the ore at concentrations greater than the NDEP reference values consist of aluminum, antimony, arsenic, iron, lead, manganese, mercury, and nitrate. Ore would be temporarily stockpiled on a contained lined pad authorized under the water pollution control permit prior to being shipped offsite for processing. The pad would be constructed to contain runoff from the stockpile generated from direct precipitation. Therefore, the amount of meteoric rinsing of the ore would be limited by the short duration of exposure to the environment (SRK 2017b), and runoff generated from the ore transfer pad would be utilized in underground operations. The majority of constituents were leached at concentrations less than the NDEP reference values for the waste rock samples. A few exceptions include arsenic that was leached from the dolomite samples and to a lesser extent mercury and antimony that were leached from one or more of the dolomite samples. In general, the dolomite waste rock samples showed higher levels of metal(loid) release than the shale material, which can be, related to the close proximity of the dolomite samples to gold mineralization. The only constituent consistently leached from the dolomite is arsenic. Antimony and mercury were leached from one sample of

CAS/VS 465900_090_ProspectMtn_WaterRep_CAS_20180524 May 2018 SRK Consulting Page 16 dolomite waste rock with slightly higher gold mineralization in comparison to the other dolomite samples (SRK 2016). The shale samples are located further away from the mineralized zone and therefore, show lower metal release overall in comparison to the dolomite ore and waste rock. One of the shale samples showed a potential to leach magnesium and sulfate above NDEP reference values. This sample may have been contaminated with shotcrete used during rehabilitation of the tunnel entrance and is not representative of the waste rock that would be removed from the tunnel during exploration activities (SRK 2016). Given the above modelling results, impacts to water quality and geochemistry would be minor, long-term, and localized. 3.2 No Action Alternatives Under the No Action Alternative, negligible impacts to water resources, water quality, or riparian areas would occur beyond those resulting from the authorized activities. 3.3 Cumulative The Water CESA includes the Diamond Valley Hydrographic sub-basin as shown on Figure 5 and encompasses approximately 478,656 acres. Past and present mining, exploration, and irrigation activities have the potential to impact groundwater through groundwater removal, use, and the potential contamination of groundwater resources through the creation of pit lakes (if present), and wells. Groundwater quality may also be impacted from mine waste rock, leaching, and spills. The two largest industrial sites would be the permitted Ruby Hill Mine and the Mount Hope Mine. Disturbed land within the CESA has the potential to impact surface water quality through sedimentation and runoff. Surface disturbance within the CESA is estimated to be 15 percent of the CESA, not including burned areas which are assumed to be revegetated. Transportation within the CESA has the potential to impact surface waters and ground water due to possibility of hazardous material, fuel, and oil spills or leaks. Agricultural activities often involve the use of chemical and fertilizers which can either run off and impact surface waters or infiltrate to impact groundwater. Approximately eight percent of the CESA is occupied by irrigated land. RFFAs which could impact water quality include mining, exploration, ROW construction, and maintenance, grazing, and dispersed recreation. Quantifiable RFFA disturbance acres have been estimated at less than one percent of the CESA. 3.3.1 Proposed Action The Proposed Action has the potential to impact surface and ground water resulting from water use, drilling, waste rock and ore placement, and disturbance. The Proposed Action would result in changes to water quantity resulting from ground water use. The cumulative impacts resulting from this water use would be minor and localized within the context of the Diamond Valley Hydrographic Basin. The Proposed Action may also contribute incrementally to surface water impacts resulting from sedimentation from disturbed areas. Because the proposed disturbance area is less than one percent of the CESA, these cumulative impacts would be minor. 3.3.2 No Action Alternative Impacts to surface water and groundwater quality and quantity resulting from previously permitted authorizations would continue to occur under the No Action Alternative. Cumulative impacts from previously authorized activities would be the same as previously authorized.

4 References Bureau of Land Management (BLM). 2005. Ruby Hill Mine Expansion – East Archimedes Project. Final Supplemental Environmental Impact Statement. NVN-067762, NV063-EIS04-34. July 2005.

Bureau of Land Management (BLM). 2012. Mount Hope Project Final Environmental Impact Statement. October 2012.

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Bureau of Land Management (BLM). 2017. Land and Mineral Legacy Rehost 2000 System – LR2000. https://www.blm.gov/lr2000/, Accessed January 11, 2017. European American Resources, Inc. (EPAR). 2001a. Drilling Log for HRH-1724. 2001. European American Resources, Inc. (EPAR). 2001b. Drilling Log for HRH-1725. 2001. European American Resources, Inc. (EPAR). 2001c. Drilling Log for HRH-1726. 2001. Nevada Division of Environmental Protection (NDEP). 2008. Nevada Contractors’ Field Guide for Construction Site Best Management Practices, 2008. Natural Resource Conservation Service (NRCS). 2015. Web Soil Survey. Accessed 2015. Nevada Division of Water Resources (NDWR). 2017. Hydrographic Summary: Diamond Valley. Accessed November 2017. http://water.nv.gov/DisplayHydrographicGeneralReport.aspx SRK Consulting (U.S.), Inc. (SRK). 2016. Prospect Mountain Geochemical Characterization Summary, memorandum to A. Erickson (Gullsil) from A. Prestia (SRK), April 19, 2016. SRK Consulting (U.S.), Inc. (SRK). 2017a. Prospect Mountain Project Plan of Operations and Reclamation Permit Application (NVN-092893). Report Prepared for Gullsil, LLC. October 2016 updated April 2017. SRK Consulting (U.S.), Inc. (SRK). 2017b. Water Pollution Control Permit Application for Facility Using Physical Separation Methods, March 24, 2017. Surveyor General. 1899. State of Nevada Biennial Report of the Surveyor General and State Land Register. 1899.

Attachments: Figure 1: Project Area and Assessment Area Figure 2: Existing and Authorized Disturbance Figure 3: Proposed Action Figure 4: Spring Development Figure 5: Water CESA Figure 6: Regional Water Levels Figure 7: Surface Water Features

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DRAWING TITLE: PROJECT AREA AND PROSPECT MOUNTAIN PROJECT ASSESSMENT AREA NAD 1983 UTM Zone 11N WATER ISSUED FOR: RESOURCE REPORT DESIGN: BVB DRAWN: BVB REVIEWED: VS DRAWING NO. FIGURE 1 REVISION NO. SCALE: 1 inch = 2,000 feet DATE: 4/25/2018 RESOURCE REPORT SRK JOB NO. FILE: WTR_465900_090_Fig01_Project_Area_BVB_20180425.mxd 465900.090 B PATH: G:\Sites\Prospect_Mountain\Gullsil\465900_090_Prospect_EA\Revision_B\WTR_465900_090_Fig01_Project_Area_BVB_20180425.mxd Basemap Source: USDA-FSA-APFO Aerial Photography Field Office 29 28 27 26

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DRAWING TITLE: WATER CESA PROSPECT MOUNTAIN PROJECT NAD 1983 UTM Zone 11N WATER ISSUED FOR: RESOURCE REPORT DESIGN: BVB DRAWN: BVB REVIEWED: VS DRAWING NO. FIGURE 5 REVISION NO. SCALE: 1 inch = 52,800 feet DATE: 4/25/2018 RESOURCE REPORT SRK JOB NO. FILE: WTR_465900_090_Fig05_CESA_BVB_20180425.mxd 465900.090 B PATH: G:\Sites\Prospect_Mountain\Gullsil\465900_090_Prospect_EA\Revision_B\WTR_465900_090_Fig05_CESA_BVB_20180425.mxd Basemap Source: Copyright:© 2014 Esri N CLAIM BOUNDARY A° APPROXIMATE UNDERGROUND No. 4 SHAFT WORKINGS DRY TO 1354' bgs GROUND ELEVATION: 8485'

PROSPECT MOUNTAIN PROJECT BOUNDARY A' HRH 1724 DRY TO 1100' bgs GROUND ELEVATION: 7925' FAD SHAFT STATIC WATER LEVEL: 2240' bgs EUREKA CONSOLIDATED GROUND ELEVATION: 6892' STATIC WATER LEVEL: 2500' bgs HRH 1725 WATER ELEVATION: 4652' GROUND ELEVATION: 7054' FEET STATIC WATER LEVEL: 1178' bgs HRH 1726 WATER ELEVATION: 4554' GROUND ELEVATION: 7806' DRY TO 1503' bgs GROUND ELEVATION: 7821' 0 1200 WATER ELEVATION: 6628'

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WTR_465900_090-Fig6_RegionalWaterLevels_RevB_LEB.dwg 45900.090 B 13 14 13 18 17 16 15 18

24 19 19 20 21 22 !. 23 24 !. !. 19N 19N D i a m o n d ¤£50 52E 19N 53E 54E V a l l e y 25 25 30 30 29 28 27 26 !. %2 !. !. !.

d a o R n o y n %2!. 36 a /" C 31 rk 31 32 33 34 o 35 36 Y %2 w e N

%2 /" /" %2 /" /" %2 Einar Spring 01 Lucky Josephine 01 05 04 03 02 %2 %2Springs 06 Spring %2 %2 %2 S t e v e n s B a s i n %2 %2 %2 12 12 /" 07 08 09 10 11 %2 07

Murray Spring 18N %2 18N 52E 18N 53E 54E 13 13 18 17 16 15 14 18 %2 L i t t l e %2 A n t e l o p e S m o k y V a l l e y V a l l e y

24 24 19 20 21 22 23 !. 19 Note: Spring locations Feet collected from BLM 2012, BLM GNIS, USGS Topo, and NAIP 2015. 0 5,000 ±25 30 29 28 27 26 25 30

EXPLANATION %2 Spring /" Drill Hole Access Road (County Road) 2 Mile Buffer !. Well (NDWR) Drainage Proposed Project Area Section Hydrographic Sub-Basin Assessment Area Township

DRAWING TITLE: SURFACE WATER PROSPECT MOUNTAIN PROJECT FEATURES NAD 1983 UTM Zone 11N WATER ISSUED FOR: RESOURCE REPORT DESIGN: BVB DRAWN: BVB REVIEWED: VS DRAWING NO. FIGURE 7 REVISION NO. SCALE: 1 inch = 5,000 feet DATE: 4/25/2018 RESOURCE REPORT SRK JOB NO. FILE: WTR_465900_090_Fig07_Surface_Water_BVB_20180425.mxd 465900.090 B PATH: G:\Sites\Prospect_Mountain\Gullsil\465900_090_Prospect_EA\Revision_B\WTR_465900_090_Fig07_Surface_Water_BVB_20180425.mxd Basemap Source: USDA-FSA-APFO Aerial Photography Field Office