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Supplemental Plan for Groundwater Monitoring

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Supplemental Plan for Groundwater Monitoring SUPPLEMENTAL PLAN FOR GROUNDWATER MONITORING CASTLE MOUNTAIN MINE CC19. 1006 February 2019 PREPARED FOR Castle Mountain Venture 911 American Pacific Dr., Suite 190 Henderson, NV 89014 PREPARED BY Geo‐Logic Associates 6155 E. Indian School Rd., Suite 200 Scottsdale, AZ 85251 (480) 659‐7131 Supplemental Plan for Groundwater Monitoring Castle Mountain Mine TABLE OF CONTENTS EXECUTIVE SUMMARY ............................................................................................................IV 1.0 PURPOSE AND OBJECTIVES .......................................................................................... 1 2.0 HISTORICAL PERMIT MONITORING (GROUNDWATER AND PIUTE SPRINGS) ................. 1 2.1 Groundwater Level Measurements ........................................................................ 2 2.2 Spring Flow Measurements .................................................................................... 2 2.3 1990 Plan Monitoring Response Actions ................................................................ 3 3.0 POTENTIAL IMPACTS FROM PROPOSED MINING .......................................................... 4 4.0 PROPOSED REPLACEMENT MONITORING WELL NETWORK .......................................... 5 4.1 Monitoring Well Locations ...................................................................................... 5 4.2 Monitoring Frequency and Reporting Schedule ..................................................... 6 5.0 REFERENCES ................................................................................................................. 7 CC19.1006 | Supplemental Plan for Groundwater Monitoring i February 2019 Supplemental Plan for Groundwater Monitoring Castle Mountain Mine TABLES Table 1 Coordinate Locations of Proposed Monitor Wells Table 2 Proposed Monitor Well Network FIGURES Figure 1 Location Map Figure 2 Historic Mining Infrastructure Figure 3 Location Map of Key Monitor, Production, and Property Boundaries Figure 4 Measured Groundwater Levels in Downgradient Monitor Wells Figure 5 Measured Flows at Piute Spring Figure 6 Location of Abandoned, Existing, and Planned Monitor Wells and Existing Production Wells (Zoomed Out) Figure 7 Location of Abandoned, Existing, and Planned Monitor Wells and Existing Production Wells (Zoomed In) APPENDICES Appendix A Well Construction Diagrams and Lithologic Logs CC19.1006 | Supplemental Plan for Groundwater Monitoring ii February 2019 Supplemental Plan for Groundwater Monitoring Castle Mountain Mine SIGNATURE PAGE R. Douglas Bartlett, PG, CHG Clear Creek Associates (Subsidiary of GLA) CC19.1006 | Supplemental Plan for Groundwater Monitoring iii February 2019 EXECUTIVE SUMMARY This Supplemental Groundwater Monitoring Plan (“Supplemental Plan”) was prepared to address current groundwater conditions and monitoring provisions at Castle Mountain Venture’s (“CMV”) Castle Mountain Mine (“CMM”) in eastern San Bernardino County, California. Groundwater monitoring at CMM was formalized in 1990 by the report, “Castle Mountain Project Plan for Ground Water Monitoring and Contingency Water Supply to Piute Spring, August 1990”, and which will be further referenced in this report as the “1990 Plan”. This update is intended to support approved mining activities at CMM and is required owing to past abandonment of several prior groundwater monitoring wells that were sealed during mine reclamation activities from 2004 to 2010. This report does not replace the 1990 Plan, which is still in effect, but serves as a supplemental report to the 1990 Plan to account for completed reclamation at the CMM site, and also to recognize altered regional land use planning and federal land management (e.g. The Mojave National Preserve, and Castle Mountains National Monument). To date, the approximately 20 years of data gathered at CMM, pursuant to protocol established in the 1990 Plan, have shown there has been no regional impact to the Lanfair water basin or Piute Springs from the operation at CMM. This Supplemental Plan maintains a correspondingly protective monitoring plan as established in the 1990 Plan but through the use of replacement groundwater monitoring wells. These replacement wells have been located as close as possible to the original monitoring well locations from 1990; however there are now federal land management constraints which prevent replacement at the exact same geographic locations. For instance, 1990 monitoring wells W-37, W-38, and PS-2 were all located inside the borders of the Mojave National Preserve, and it is unlikely that approval from the National Park Service (“NPS”) would be granted for the re-drilling of these three past monitoring wells. Mining was authorized at CMM in 1990 by the County of San Bernardino (“County”) Conditional Use Permit (“CUP”) and the Bureau of Land Management (“BLM”) Record of Decision (“ROD”). The BLM and County authorized an expanded mine plan in 1998 and the latter again in 2013. While this Supplemental Plan does not materially alter the monitoring procedures and protective nature established by the 1990 Plan, actual water use at CMM has declined since the 1990 Plan was established. The BLM and County in 1990 authorized an annual average use of 725 acre-ft of water from the West Well Field, however, the 1998 authorizations for expanded mining lowered the expected annual average water use to 625 acre-ft. Historical monitoring results for that project demonstrated that mine activities had limited impacts to groundwater levels near the mine and no impacts to groundwater levels at distance from the site or at Piute Spring. The impact of mine pumping was evaluated as part of the 1990 Plan and again as part of the 1998 mine modification of the Environmental Statement/Environmental Impact Report (EIS/EIR). The 1998 authorization for expansion included pumping in the West Well Field and from an east well field near the JSLA (or Lesley Ann) pit with total estimated groundwater extraction of 2,420 acre- feet. As a component of the 1997 EIS/EIR analysis, a 1996 report by Terracon (Influence of Mine Pit Pumping on the Alluvial Aquifer of Lanfair Valley, July 1996) evaluated the impact from mine pit pumping on the Lanfair Valley alluvial aquifer system. The Terracon evaluation indicated that CC19.1006 | Supplemental Plan for Groundwater Monitoring iv February 2019 Supplemental Plan for Groundwater Monitoring Castle Mountain Mine removal of 2,420 acre-feet over 15 years from the mine pit area would result in an area of impact with a radius of 1 to 1.5 miles in diameter and would not impact Lanfair Valley alluvial aquifer system to any measureable degree. The current Mine Plan makes no change to the total volume of pumping which was estimated and analyzed by the 1996 Terracon report; therefore, potential impacts would not be expected to exceed the impacts analyzed and incorporated in the 1998 mine expansion authorization. The amount of groundwater withdrawal throughout the mine plan equates to less than 0.2 percent of the total amount of groundwater estimated to be contained in the upper 100 feet of Lanfair Valley alluvium as estimated by Terracon (1996). Five groundwater monitor wells are proposed in this Supplemental Plan to monitor changes in groundwater levels that may be induced by future CMM pumping, same as in the 1990 Plan. Three of the wells (2017-1MW, 2017-2MW, and 2017-3MW) were installed adjacent to the planned heap leach pad and have been monitored quarterly since they were constructed in 2017. Two additional monitoring wells, 2019-1MW and 2019-2MW, are planned for construction in 2019. All five wells are located downgradient of CMM’s authorized West Well Field, and are favorably positioned to provide an indication of the magnitude of groundwater elevation changes that may occur over time in areas south and southeast of the mine in Lanfair Valley. CMV plans to conduct quarterly groundwater level monitoring at each of the five wells. These data will be evaluated in relation to estimates of groundwater impacts described in the 1990 Plan and the 1996 Terracon report. CC19.1006 | Supplemental Plan for Groundwater Monitoring v February 2019 Supplemental Plan for Groundwater Monitoring Castle Mountain Mine 1.0 PURPOSE AND OBJECTIVES This Supplemental Plan for Groundwater Monitoring identifies measures that CMV will take to evaluate potential impacts to groundwater resources near the Castle Mountain Mine (CMM) in eastern San Bernardino County, California (Figure 1). During earlier operations (1990 to 2001), CMV (Viceroy), developed a groundwater monitoring plan to assess groundwater within Lanfair Valley south of the mine and at Piute Spring approximately 15 miles southeast of the CMM well field (the West Well Field). This document is provided as a supplement to the original monitoring plan, “Castle Mountain Project, Plan for Ground Water Monitoring and Contingency Water Supply to Piute Spring” which was prepared for Viceroy by The Mark Group (1990). That plan is herein referred to as the “1990 Plan.” Piute Spring is considered a critical ecological resource in the area. Like the 1990 Plan, this Supplemental Plan has been developed to assure that mining operations at CMM do not negatively affect Piute Spring. Mining and leaching activities were conducted at CMM by Viceroy from 1991 to 2005, after which time land reclamation became the focus during a period of depressed market price for gold (Figure 2). Mineral exploration and development activities were renewed by 2013 at CMM and have continued to the present day. A number of groundwater
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