19
Arizona Business Unit 5255 E. Williams Circle, Suite 1065 Tucson, Arizona 85711-7407 tel 520-495-3500 Hudbayminerals.com Beyond POC Water Monitoring Plan As Required By: Mitigation Measure FS-GW-02 October 2018 Prepared by: Rosemont Copper Company

Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

  • Upload
    others

  • View
    0

  • Download
    0

Embed Size (px)

Citation preview

Page 1: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Arizona Business Unit 5255 E. Williams Circle, Suite 1065 Tucson, Arizona 85711-7407 tel 520-495-3500 Hudbayminerals.com

Beyond POC Water Monitoring Plan As Required By: Mitigation Measure FS-GW-02

October 2018

Prepared by:

Rosemont Copper Company

Page 2: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page i

Monitoring and Reporting Schedule

Task Schedule Purpose/Description/

Timing

Pre-Mining Period/

Construction Phase 1

Operations Phase

Closure2

AN Q A SA A SA A

Field investigation of accessibility and usability of listed well sites

To review and finalize proposed monitoring locations, access, and well conditions

X

Monitor wells for water levels; monitor springs for flow conditions

To obtain pre-mining flow conditions and water quality data

X

Collect groundwater and spring water quality samples

To obtain pre-mining groundwater levels and water quality data

X

Monitor springs for flow conditions; collect spring water samples

Assess for potential impacts from mining operations/ other sources

X X

Monitor groundwater levels; collect groundwater samples

Assess for potential impacts from mining operations/ other sources

X X

Reporting To Forest Service X X X

AN = As Needed; Q = Quarterly; SA = Semi-annually; A = Annually; 1 - Includes Pre-Construction Period; 2 - Monitoring in Post-Closure Period to be determined.

Revision Log

Revision Number

Revision Lead

Purpose of Revision Revision

Date

1 Rosemont Based on Forest Service review of June 2017 MPO submittal. March 2018

2 Rosemont Based on Forest Service review of March 2018 MPO submittal. June 2018

3 Rosemont Added Data Management Language per FS October

2018

Page 3: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page ii

Table of Contents 1.0  PLAN OBJECTIVE AND DESCRIPTION ............................................................................. 1 

1.1  PLAN OBJECTIVE ........................................................................................................ 1 

1.2  PLAN DESCRIPTION .................................................................................................... 2 

2.0  MONITORING AND REPORTING ........................................................................................ 3 

2.1  MONITORING ................................................................................................................ 3 

2.1.1  MONITORING DATA ................................................................................................. 3 

2.1.2  MONITORING POINT ............................................................................................... 3 

2.1.3  WATER QUALITY SAMPLING PROCEDURES ....................................................... 3 

2.1.4  SPRING MEASUREMENT LOCATIONS AND PHOTOPOINTS .............................. 4 

2.1.5  SPRING FLOW MONITORING ................................................................................. 4 

2.1.6  RIPARIAN VEGETATION .......................................................................................... 5 

2.1.7  OVERALL CONDITIONS OF THE MONITORING LOCATION ................................ 5 

2.1.8  MISCELLANEOUS SITE INFORMATION ................................................................. 5 

2.1.9  MONITORING FREQUENCY ................................................................................... 6 

2.1.10  SPRING MONITORING EVALUATION ..................................................................... 6 

2.1.11  ANALYTICAL PARAMETERS ................................................................................... 6 

2.1.12  WATER QUALITY THRESHOLDS ............................................................................ 7 

2.2  REPORTING .................................................................................................................. 7 

3.0  CLOSURE AND BOND RELEASE ....................................................................................... 9 

3.1  INTERIM CLOSURE ...................................................................................................... 9 

3.2  FINAL CLOSURE .......................................................................................................... 9 

3.3  BOND RELEASE ........................................................................................................... 9 

4.0  DATA MANAGEMENT ........................................................................................................ 10 

5.0  REFERENCES .................................................................................................................... 11 

Page 4: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page iii

Table Table 1 List of Wells and Springs to be Monitored Under FS-GW-02

Figure Figure 1 Location of Wells and Springs to be Monitored Under FS-GW-02

Page 5: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 1

1.0 PLAN OBJECTIVE AND DESCRIPTION

This Beyond POC Water Monitoring Plan (Plan) was developed by Rosemont Copper Company (Rosemont) in response to the mitigation and monitoring measure (Mitigation Measure) requirement of the U.S. Forest Service’s (USFS, Forest Service) Coronado National Forest (Coronado) Final Environmental Impact Statement (FEIS; USFS, 2013) for the Rosemont Copper Project (Project). The Mitigation Measure requirement is specified as “FS-GW-02: Water quality monitoring beyond point-of-compliance wells” on pages B-17 through B-19 in Appendix B of the FEIS. Corrections to any of the mitigation measures listed in Appendix B are provided in an Errata to the FEIS (USFS, 2017a). The Record of Decision (ROD; USFS, 2017b) for the Rosemont Project also lists the required mitigation measures.

Monitoring for Mitigation Measure FS-GW-02 will begin in the Pre-Mining Period following approval of the Mine Plan of Operations (MPO). Monitoring will continue through the Operations Phase, through the Final Reclamation and Closure Phase (Closure Phase), and into the Post-Closure Period.

1.1 PLAN OBJECTIVE

The objective of Mitigation Measure FS-GW-02 is to:

To determine in situ changes in the quality of the Coronado National Forest groundwater resources, beyond the capture zone of the mine pit, potentially triggered by groundwater drawdown.

Other Forest Service mitigation measures and/or permits/requirements/certifications associated with monitoring groundwater and surface water changes (levels, flows/quantity, quality) due to Project activities include:

FS-BR-05: Construction, management, and maintenance of water features to reduce potential impacts to wildlife and livestock from reduced flow in seeps, springs, surface water, and groundwater. This mitigation measure requires water level monitoring and managing/constructing water features, if needed, for Chiricahua leopard frog and jaguar habitats (see pages B-32 and B-33 in Appendix B of the FEIS);

FS-BR-22: Constructing and maintaining an on-site weather station plus automated stormwater/surface water/groundwater monitoring stations in washes downstream of the Project for the purpose of determining impacts from pit dewatering and changes to surface water features. This mitigation measure proposes monitoring of shallow and deep wells at select locations, such as in Barrel and Davidson Canyon washes. Automated stormwater sampling is also part of this mitigation measure along with the monitoring of geomorphic changes within Davidson Canyon wash (see pages B-48 through B-50 in Appendix B of the FEIS);

FS-BR-27: Periodic validation and rerunning of groundwater model throughout life of mine. This mitigation measure also requires quarterly water level monitoring at well locations located on the Project site and in surrounding areas. The installation of a new monitoring well is also required (see pages B-53 through B-55 in Appendix B of the FEIS);

FS-SSR-02: Spring, seep, and constructed/enhanced waters monitoring. This mitigation measure requires spring and seep flow/quantity monitoring at select springs located on and in surrounding areas of the Project site to measure the effects of groundwater drawdown and to determine if decreased water levels are due to mine activities (see pages B-26 and B-27 in Appendix B of the FEIS);

OA-GW-06: Groundwater quality and groundwater level monitoring required under the aquifer protection permit (APP). This mitigation measure refers to monitoring requirements associated with point-of-compliance (POC) wells under APP No. P-106100 (see pages B-87

Page 6: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 2

and B-88 in Appendix B of the FEIS); and

The Clean Water Act (CWA) Section 401 certification requires a Surface Water Mitigation Plan (MPO Volume IV-s). Modeling and monitoring results will be used to mitigate for potential surface water flow volume reductions from the Project site and to track downstream conditions, i.e., sediment changes, water quality, etc.

In addition, Rosemont has developed a Water Programs Quality Assurance Project Plan (QAPP; MPO Volume II-ff), which is intended to meet the “Sampling & Analysis Plan” requirements under Mitigation Measure FS-GW-02. The QAPP describes and includes the following:

Water level measurement and water sample collection procedures;

Quality assurance protocols;

Sample handling and reporting requirements;

Analyte lists for each monitoring program; and

Criteria and process for data verification.

Tables A-5 and C-2 in the QAPP (MPO Volume II-ff) list the parameters that will be analyzed in the groundwater and spring samples, respectively, under Mitigation Measure FS-GW-02.

1.2 PLAN DESCRIPTION

The remainder of this Plan includes the following sections:

Section 2.0: Monitoring and Reporting;

Section 3.0: Closure and Bond Release;

Section 4.0: Data Management; and

Section 5.0: References.

Due to concerns of potential impacts from groundwater pumping (dewatering) in the open pit during mining operations, the Forest Service developed a list of proposed wells/piezometers/ boreholes and springs that the agency would like to see monitored for water levels and water quality on a periodic basis. The mitigation measure states that “up to 10 springs and up to 16 wells” are to be monitored and specifically lists 14 existing wells, piezometers, and boreholes and 10 springs that will be monitored. The mitigation measure also proposes that one (1) new well be drilled at a mutually-agreed upon location. These wells/piezometers/boreholes and springs were selected primarily on their location, which provide circumferential coverage of the area beyond the Project footprint. Groundwater levels and water quality will be monitored at the downgradient perimeter of the Project by a number of POC wells in accordance with the APP. Mitigation Measure FS-GW-02 requires monitoring of groundwater levels and water quality in wells, and springs, located beyond the footprint of the mine for the purpose of assessing potential impacts related to dewatering the open pit.

Page 7: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 3

2.0 MONITORING AND REPORTING

Monitoring and reporting components for Mitigation Measure FS-GW-02 are listed below.

2.1 MONITORING

The following subsections describe the monitoring data to be collected:

2.1.1 Monitoring Data

The following data will be collected, as appropriate, from each specific well, piezometer, borehole, and spring selected by the Forest Service:

Depth-to-groundwater measurements from wells;

Flow condition data (presence/absence of water) from springs;

Water quality samples from wells and springs;

Measurement location and photopoints;

Overall condition of the monitoring location;

Riparian vegetation; and

Miscellaneous site information.

2.1.2 Monitoring Point

As stated in Section 1.2, the Mitigation Measure FS-GW-02 proposes that “up to 10 springs and up to 16 wells” be monitored. The mitigation measure specifically lists 14 existing wells, piezometers, and boreholes and 10 springs that are to be monitored. The mitigation measure also proposes that one (1) new well be drilled at a mutually-agreed upon location near Lopez Pass. Table 1 presents the potential list of wells/piezometers/boreholes and springs the Forest Service to be monitored under FS-GW-02. These monitoring wells/piezometers/boreholes and springs were selected due primarily to their location, which provide circumferential coverage of the area beyond the perimeter of the Project footprint. Figure 1 shows the locations of the wells/piezometers/boreholes and springs selected for monitoring under Mitigation Measure FS-GW-02.

Thirteen of the 14 existing wells listed by the Forest Service have had groundwater levels measured on a quarterly basis for at least two years, and four of the 14 wells have been sampled for water quality on a quarterly basis for at least two years under a voluntary baseline monitoring program. All ten (10) springs proposed by the Forest Service have been voluntarily monitored for flow conditions for at least two years.

Based on a meeting with the Forest Service on April 18, 2013, the location for the new well will be near Lopez Pass, approximately 1.6 miles north of the center of the Open Pit, at an approximate elevation of 5,600 feet above mean sea level. Depth to groundwater and other hydrologic conditions at this approximate location are unknown at this point in time, and therefore, no construction details can be proposed or discussed.

2.1.3 Water Quality Sampling Procedures

Detailed procedures for groundwater and spring water sample collection, well purging, decontamination of sampling equipment, and sample documentation are provided in the QAPP (MPO Volume II-ff). Groundwater and spring water quality samples will be collected in accordance with the procedures, methods, and considerations described in Rosemont’s QAPP (MPO Volume II-ff).

Page 8: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 4

In general, prior to collecting a water quality sample at each well, the static water level will first be measured and recorded. Wells may be purged using the standard three-borehole volume method, the low-flow method, or disposable, passive sampling bags. If purging results in a well going dry, the well will be allowed to recover to 80% of the original borehole volume, or for 24 hours, whichever is shorter, prior to sampling. If, after 24 hours, there is not sufficient water for sampling, the well will be recorded as “dry” for the monitoring event.

Water samples will be collected from springs only if there is sufficient water flowing from the spring. Water samples will not be collected from ponded or pooled areas, or tanks. Flow conditions at each spring/seep will be described in detail, and include photographic documentation, prior to sample collection, if sampling is possible.

2.1.4 Spring Measurement Locations and Photopoints

Each spring location selected for monitoring under this Plan will have a designated measurement location. The designated measurement location will be clearly described in a record, marked on a detailed map (i.e., a U.S. Geological Survey topographic map), photographed, and its coordinates surveyed with a global positioning system (GPS) unit. This will ensure consistent, reliable, and reproducible data. For locations with clearly visible flow conditions, measurement locations will be established without interfering with the spring function.

At least one photopoint (viewpoint) will be established for photographing the spring. Each location will be marked (using a stake, flagging, or other identifying marks), and recorded (GPS coordinate). This photopoint will be used during subsequent monitoring events. Updated photographs will be taken at each monitoring event.

2.1.5 Spring Flow Monitoring

Based on previous voluntary spring monitoring, conditions recorded at the monitoring locations ranged from:

Dry

Moist soil

Ponded water

Flowing

These same descriptive terms will be used to define spring discharge under this Plan. If flow is measurable – from source - an estimated flow rate will be provided in gallons per minute (gpm). If possible, discharge will be measured by recording the length of time required to fill a container of a known volume, including the use of a mechanical flow meter. Other methods, such as the use of a small weir, and/or electronic field flow meter, will be investigated during ongoing field monitoring. An example Spring Flow Monitoring Form is provided in Appendix I of the QAPP (MPO Volume II-ff).

Automated flow monitoring equipment may be installed at the following locations if such equipment will not interfere with the functioning of the spring or its cultural significance:

Sycamore Spring

Questa Spring

Deering Spring

A design for installing the automated equipment at these locations will be prepared once the feasibility of doing so is assessed. The equipment and method for installation will be provided to the Forest Service for review. It is envisioned that within 6-months of MPO approval, the Forest Service, in collaboration with Rosemont, would make a field assessment of the potential spring sites and determine the feasibility of automated monitoring. Once a general agreement is made as to the

Page 9: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 5

selected sites, preliminary designs will be prepared by Rosemont along with an assessment of site access requirements by the Forest Service. This process, including collaboration on preliminary designs, is also anticipated to take 6-months. Detailed design, and the time to the start of construction, would take an additional 6-months. Non-automated monitoring would continue during this time period at the selected locations.

2.1.6 Riparian Vegetation

In addition to monitoring the presence/absence of flow from the springs, one of the primary criterions used for determining the presence of regional, shallow groundwater is the existence of extensive and well-established riparian vegetation in the immediate vicinity of a spring. Riparian vegetation requires groundwater to be within their maximum root depth and can persist when there is no visible discharge (e.g., dry surface conditions).

In addition to the presence/absence of water, each monitoring event will include an evaluation of the vegetation surrounding the monitoring location, as changes in the extent of riparian vegetation could be an indicator of changing groundwater discharge. Vegetation conditions near some of the selected springs were previously documented in WestLand Resources, Inc. (Westland; 2012). Vegetation monitoring will consist of describing and documenting (with photographs) the existing vegetation at each spring/seep location. The extent, density, diversity, and vitality of vegetation at each location will be documented and mapped. Photopoint monitoring will be used to provide reliable and accurate record of the changes as they occur. However, it must be taken into consideration that vegetation will vary naturally throughout the year – not only in relation to the seasonal responses but also to other factors such cattle grazing, wildlife use, or drought.

Vegetation transects will be performed every three (3) years at Helvetia, Locust, Sycamore, Questa, Deering and Mulberry Springs, starting in the Pre-Mining Period. These six (6) springs were identified because they provide hydroriparian and mesoriparian habitats. Transects will be performed using the line-intercept method (Caratti, 2006) to determine total vegetative volume and species richness of woody and wetland riparian vegetation. With the exception of the Helvetia and Mulberry Springs, each site will consist of two (2), 20 meter transects established along both edges of the spring channel, delimited by upstream and downstream monuments. The Helvetia and Mulberry sites will consist of an additional transect of the same dimensions, positioned down the center of the spring. The additional transect will cover riparian vegetation that occurs throughout the channel at these two locations. GPS coordinates will be recorded at the start and end points of each transect. Example Riparian Vegetation Monitoring Forms are provided in Appendix B of the Spring Flow Monitoring Plan (MPO Volume ll-y).

2.1.7 Overall Conditions of the Monitoring Location

Should a well or designated discharge measurement point for a specific spring become inaccessible over time, Rosemont will clearly describe the current situation in the sample record, along with a description of the condition of the former discharge measurement point, photographs, and a description and photograph of the replacement discharge measurement point.

2.1.8 Miscellaneous Site Information

Other information that will be collected and recorded at each monitoring location, as appropriate, includes:

A description of the substrate composition, i.e., fines, sands, gravel, etc.;

Land ownership, i.e., Coronado National Forest, private land, Rosemont private land, etc.; and

Access to the well or spring – the ease at which the public could visit a monitored location will be described and recorded, i.e., access only by cross-country hiking, site accessed by trail hike, site accessed by walking less than one (1) mile, or site is immediately adjacent to a

Page 10: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 6

road.

2.1.9 Monitoring Frequency

Groundwater level measurements, flow condition assessments, and water quality sampling of wells and flowing springs will be conducted quarterly during the Pre-Mining Period and through the Construction Phase. During the Operations Phase and into the Closure Period, spring flow monitoring and spring water quality sampling under FS-GW-02 will be conducted semi-annually (every six months). It is anticipated that spring monitoring will be completed during the first (January through March) and third (July through September) quarters when semi-annual monitoring is conducted. These quarters have shown the highest potential to record the presence of flows. The monitoring frequency of groundwater levels and groundwater quality sampling under this Mitigation Measure will be reduced to annually during the Operations Phase and into the closure period.

As noted in Section 2.1.6, transects will be taken every three (3) years, starting in the Pre-Mining Period. It is anticipated that transect monitoring would be completed during the first quarter of the monitoring year (i.e., January through March).

2.1.10 Spring Monitoring Evaluation

During the course of this monitoring program, the data collected by Rosemont will be assessed in order to determine if the Plan objectives are being met, including an assessment of which locations should be monitored.

Springs that exist solely due to precipitation events, that is, not connected to the regional aquifer or associated with a perched water zone, will not provide any useful data regarding regional groundwater drawdown. Only springs supported by the regional groundwater flow system that produce hydroriparian and mesoriparian habitats will be useful for monitoring groundwater drawdown due to Open Pit dewatering. Therefore, after periodic assessments and discussions with the Forest Service, those springs that are determined to flow only in response to storm events or be connected to perched water zones may be dropped from the monitoring list associated with this Plan (Table 1).

Springs that are dry over a period of two (2) years may also be removed from the list. Previous work by WestLand (2012) and Tetra Tech (2010) will be used in the assessment. Additionally, accessibility of the monitoring locations and worker safety will also be a factor that will be evaluated over the course of this program.

In the event that a given spring source location (Table 1) is consistently dry over a two (2) year period but water is present nearby that is likely being fed by the spring, the spring location may be updated to more accurately reflect field conditions.

Recommendations on eliminating monitoring locations or other adjustments to the monitoring components would be made in the annual report and discussed with the Forest Service prior to implementing any changes.

2.1.11 Analytical Parameters

Table A-5 in Appendix A and Table C-2 in Appendix C of Rosemont’s QAPP (MPO Volume II-ff) list the parameters that will be analyzed in the groundwater and spring samples, respectively. The parameters listed in Tables A-5 and C-2 were selected to provide an overall chemical characterization of each water source and include major ions, nitrate and nitrite, various total and dissolved metals, and on an annually basis, radiochemicals, carbon disulfide, and stable isotopes (hydrogen and oxygen). Field indicator parameters (i.e., pH, specific conductance, and temperature) will be taken at both the wells and the springs and recorded on a field sample collection data form. In addition, dissolved oxygen (DO) will be measured and recorded at the springs.

Water samples will be submitted to an analytical laboratory for analysis of various parameters, including indicator parameters (i.e., pH and conductivity), major ions, dissolved and total metals, and

Page 11: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 7

radiochemicals. The analytical laboratory will be licensed by the Arizona Department of Health Services, Laboratory Licensure Division, for each parameter they are analyzing and reporting. Example water quality sample collection forms are provided in Appendix I of the QAPP (MPO Volume II-ff)

2.1.12 Water Quality Thresholds

Water quality data received from the analytical laboratory will first undergo a data verification process, as described in Section 3.4 of the QAPP (MPO Volume II-ff), where Rosemont will review and assess the sampling and analyses protocols to ensure that the samples and data are reliable, accurate, and representative. Water quality results will then be compared to appropriate water quality thresholds.

As a note, no numeric alert levels will be established under this monitoring program. However, for reporting purposes, thresholds will be set using the last twelve quarterly samples prior to initiation of dewatering activities. A threshold will be set for a 95% confidence interval for the 0.99 quantile of the distribution, by adding the standard deviation times 3.747 to the mean for each analyte at each sample location. The threshold will then be compared to the sample result at that location. If two (2) consecutive quarterly samples exceed a threshold, then Rosemont will evaluate the trends, water elevations, and possible cause of the water quality change and provide a report to the Forest Service. Rosemont understands that the Forest Service may choose to define alternative thresholds internally for the purposes of assessing water quality results and identifying issues requiring further investigation.

Statistical methods and trend analysis will be used to evaluate the groundwater levels, flow conditions, and water quality. Graphs for groundwater levels versus time and select water quality concentrations versus time will be prepared from the available data and assessed for trends.

All 10 springs monitored under FS-GW-02 are located in or near, and discharge to, ephemeral washes. All but one of the springs (Questa), discharges to an unlisted ephemeral wash. In addition to the thresholds discussed above, Questa Spring water quality will be compared to the applicable surface water quality standards. Arizona SWQSs for washes and streams are based on designated use standards. Questa Spring discharges to the uppermost stretch of Davison Canyon Wash; the applicable SWQSs for Davidson Canyon Wash, and hence, Questa Spring, are:

Aquatic and Wildlife (ephemeral) (A&We)

Partial Body Contact (PBC)

Agricultural Livestock Watering (AgL)

2.2 REPORTING

Reporting on Mitigation Measure FS-GW-02 to the Forest Service will be performed annually. Each report will include the following:

General discussion of previous year’s monitoring/overall conditions;

Tabulations and/or graphs of current and historic water level data for each well/piezometer/borehole;

Tabulation of current and historic flow conditions for each spring;

Discussion of well construction for listed wells, including screened intervals, casing diameter, and casing materials;

General discussion of dry wells and wells with submerged screens;

General description of vegetation of immediate area of each spring;

Page 12: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 8

Summary data tables, as well as copies of the laboratory analytical reports (which include chain of custody forms), and

Any associated figures, maps, graphs, and/or trends analyses.

Other information such as field notes, instrument calibration records, and other sample collection information will be maintained on site and made available upon request.

Long-term groundwater level trends, as well as water quality and spring flow conditions, will be evaluated, summarized in the report, and discussed with the Forest Service on periodic basis. Any concerns regarding developing trends will be addressed with the Forest Service at that time. If necessary, mitigative actions will be evaluated and developed in response to those concerns and will be specific to each monitoring point.

Page 13: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 9

3.0 CLOSURE AND BOND RELEASE This section addresses closure activities associated with this Plan as well as the approach for funding of those activities and bond release of those funds. If bonding is set for one year or less (i.e., simply completing testwork or finalizing reporting) no bond release is proposed. For longer periods, the bonding terms and application for bond release, as well as the mechanism for that release, are included.

3.1 INTERIM CLOSURE

There is no interim closure activities associated with this measure.

3.2 FINAL CLOSURE

There is no final closure activities associated with this measure. However, monitoring and reporting associated with this measure will continue for at least five (5) years post-mining. The costs for this work have been estimated from previous monitoring and are included in the Reclamation and Closure Plan (MPO Volume II-a).

3.3 BOND RELEASE

Bond release for this Mitigation Measure will occur when the monitoring and reporting planned for the closure period is concluded.

Page 14: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 10

4.0 DATA MANAGEMENT

Rosemont currently maintains data in various formats including logbooks, electronic logbooks, spreadsheets, hardcopy and database formats. Rosemont will collaborate with the Forest Service to ensure that the reporting format used will satisfy reporting requirements and that Forest Service concurs with the format prior to the first reporting deadline. It is Rosemont’s intent that, ultimately, a robust database will be used to house all data collected for the various monitoring programs. Numeric data ultimately will be stored in a database and spatial data will be maintained in an ESRI database.

Depending upon the type of data to be reported, Rosemont will develop custom reports displaying required information in table or figure format. Electronic submittals will be provided in pdf format to provide a permanent record of the submittal and “raw” data will be maintained on-site for review by the Forest Service. If the Forest Service requests numeric data, it may include information such as cumulative results documenting the monitoring history and include baseline data for the resource.

Electronic submittals will be made on the reporting period specified. Reports will be submitted in hardcopy form with a duplicate electronic pdf file of the report. Delivery of the electronic files will depend upon the size of the file and will either be made via email, via a CD/DVD or thumb drive, or via a website set up and maintained for delivery of files to the Forest Service. Details regarding access will need to be worked out so transmittals can take place seamlessly.

Page 15: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Beyond POC Water Monitoring Plan, Rev. 3 Page 11

5.0 REFERENCES

Caratti, J.F., 2006. Line Intercept (LI). In: Lutes, D.C. (ed.), FIREMON: Fire Effects Monitoring and Inventory System. Rocky Mountain Research Station, Natural Resources Research Center, Fort Collins, CO.

Tetra Tech, 2010. Davidson Canyon Hydrogeologic Conceptual Model and Assessment of Spring Impacts, Rosemont Copper Project. Consultant report prepared for Rosemont Copper Company. July 2010.

USFS, 2013. Final Environmental Impact Statement for Rosemont Copper Project, Appendix B Mitigation and Monitoring Plan. December 2013.

2017a. Errata – Rosemont Copper Project Final Environmental Impact Statement. April 26, 2017.

2017b. Record of Decision – Rosemont Copper Project and Amendment of the Coronado Land and Resource Management Plan. June 2017.

WestLand, 2012. Rosemont Copper Project: Seeps and Springs Survey, 2011-2012. Consultant

report prepared for Rosemont Copper Company. July 11, 2012.

Page 16: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

TABLE

Page 17: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

Table 1 - List of Wells and Springs to Be Monitored Under FS-GW-02

Monitoring Point ID Cadastral Location Latitude / Longitude

Wells

HC-4A (D-18-16) 20dbc1 31° 51’ 06.39”N / 110° 43’ 47.96”W

HC-4B (D-18-16) 20dbc2 31° 51’ 06.16”N / 110° 43’ 48.19”W

RP-2B (D-18-16) 28aba2 31° 50’ 49.11”N / 110° 42’ 35.18”W

RP-2C (D-18-16) 28aba3 31° 50’ 49.40”N / 110° 42’ 35.11”W

HC-5A (D-18-16) 30bab1 31° 50’ 48.80”N / 110° 44’ 58.75”W

HC-5B (D-18-16) 30bab2 31° 50’ 48.54”N / 110° 44’ 58.56”W

RP-5 (D-19-16) 06cca 31° 48’ 21.95”N / 110° 45’ 10.93”W

HC-1A (D-19-16) 01bab1 31° 48’ 59.47”N / 110° 46’ 02.60”W

HC-1B (D-19-16) 01bab2 31° 48’ 59.17”N / 110° 46’ 02.56”W

DH-1445 (D-18-15) 35abc 31° 49’ 49.93”N / 110° 46’ 54.56”W

DH-1541 (D-19-16) 04dbb 31° 48’ 36.32”N / 110° 42’ 41.26”W

P-899 (D-18-16) 29bbd 31° 50’ 38.51”N / 110° 44’ 11.10”W

C-1; AR-2065 (D-18-16) 30bda 31° 50’ 32.58”N / 110° 44’ 51.67”W

HC-6 (D-19-15) 01aac 31° 48’ 57.26”N / 110° 45’ 31.26”W New well (near Lopez Pass)1 (D-18-15) 24add 31° 51’ 16.57”N / 110° 45’ 27.14”W

Springs2

Deering Spring (D-19-15)1dbd 31° 48’ 31.82”N / 110° 45’ 40.61”W

Rosemont Spring (D-18-16)32bbc 31° 49’ 39.40”N / 110° 44’ 14.16”W

Lower Mulberry Spring (D-18-16)9dbb 31° 52’ 37.33”N / 110° 42’ 32.25”W

Mulberry Spring (D-18-16)9abc 31° 53’ 14.44”N / 110° 42’ 43.44”W

Questa Spring (D-18-16)27ddd 31° 50’ 01.67”N / 110° 41’ 18.71”W

Sycamore Spring (D-18-15)12dba 31° 52’ 55.51”N / 110° 45’ 37.19”W

MC-2 Spring (D-18-16)19ccd 31° 50’ 54.68”N / 110° 44’ 57.17”W

Fig Tree Spring (D-18-16)19abb 31° 51’ 38.96”N / 110° 44’ 48.37”W

Helvetia Spring (D-18-15)14dba 31° 52’ 04.53”N / 110° 46’ 39.82”W

McCleary Dam (D-18-16)29bda 31° 50’ 34.93”N / 110° 43’ 53.83”W 1 Proposed location for new well.

2 As identified in WestLand Resources, Inc. 2012. Rosemont Copper Project: Seeps and Springs Survey 2011-2012. Spring flow monitoring also conducted under Mitigation Measure FS-SSR-02.

Page 18: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

FIGURE

Page 19: Beyond POC Water Monitoring Plan - Rosemont Copper · Beyond POC Water Monitoring Plan, Rev. 3 Page 2 and B-88 in Appendix B of the FEIS); and The Clean Water Act (CWA) Section 401

[[

[ [ [ [ [[ [ [ [

[

[[

[[

[

[

[

[[

[

[[

[

[[

[[

[

[

[

[

[[[[[

[

[

[[

[[

[

[[

[[

[[

[[

[[

[[

[

[[

[

[ [

[ [[ [

[[

[

[

[

[

[

[

[ [[

[

[[

[[

[[[

[

[

[[

[

[

[[[[

[

[

[[

[[

[

[[

[

[[

[[

[

[

[

[[

[

[[

[ [ [[ [ !A

!A!A

!A

!A

!A

!A!A

!A

E

E

E

E

E

E

E

E

E

E

@A@A

@A

@A@A

@A

@A

@A

@A@A

@A

@A

@A@A

/

POC#9

POC#2POC#1

POC #8 POC #7

POC #6

POC #5

POC #4

POC #3

RP-5

HC-6HC-1BHC-1A

HC-5BHC-5AP-899

RP-2CRP-2B

HC-4B HC-4A

DH-1541

DH-1445

MC-2 Spring

C-1; AR-2065

Questa Spring

Deering Spring

Mulberry Spring

Fig Tree Spring

Sycamore Spring

Helvetia Spring

Lower Mulberry Spring

New Well (near Lopez Pass)

Rosemont Spring (until buried)

Project:

County:

PRJ:

State:

Date:

Pima

Beyond POC Water Monitoring Plan

ArizonaNAD83 UTM 12 Meters 3/13/2018

Source:

Legend/ New Well (General

Area)E Spring@A Well

!AProposed POCWells

Landform Footprint

Pit Outline

Plant Site Facilities

[ [ Security Fence

[[[

[ [ Perimeter Fence

State Highway 83

Land OwnershipPrivateUSFSStateBLM

ArcGIS Map Service Server

I

2,800 0 2,8001,400

Feet

1:50,000

Figure 1. Well and Spring Monitoring Locations

SR 83

Landform

SR 83

Open Pit

PlantSite