[PDF] - SWVP-019242 SI bAR/QNA TLT1C IN IX INL zi85 ut lb wi reict PDF Document

SLIDE 1

From Loretta

Ford corn

Sent

Thursday

July 29 2010 310 PM

To Richard

Mendolia

Carrolette Winstead

Nancy Rurnrill

Subject PowerPoint

Presentation

Attachments

Questions

under consideration

regarding Florence July

21

2010.pdf

Hello

all

have

some information

to

share with you Here

is the PowerPoint

presentation

we gave

to the Town

f Florence

couple weeks ago

Many

f the

slides were geared

towards answering questions

that

the Town

had sent to

us in advance

The

email bounced

back to me because

the powerpoint

file

is 53 mbytes

Does

ADEQ

have an ftp

site for sharing

large

files Or we can use one

f our ftp sites

Ive also attached the

list

f Questions

that

the Town

sent and

the Answers we provided Sincerely

Loretta

Notice Regarding Transmission This

message

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nly

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and confidential

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r copying
f

this communication

is

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in

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604-684-6365

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Please note

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the presence

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by any virus transmitted by this email Thank

you

SWVP-019242

SLIDE 2

TLT1C

SI

bAR/QNA

IN

IX INL

ut lb

wi

reict

zi85

COPDL

PROJ BC

Questions under consideration

regarding Florence AZ Copper Project Relative to the General Plan Amendment and Land Use

GPA questions specific to submittal What

is the

rganic

solvent

utilized

in

the SX plant ShelISol D70 petroleum

distillate

LIX 984N reagent copper

extractant What

will be developed as part

f the

Project

in

regards to developed soluble material

waste whether

it

be

in

the injection/recovery process

r retained

in the groundwater

Surplus

water pumped

ut
f the ore zone

at the Florence

Copper

Project

this

is required

to

maintain

hydraulic control

f injected

solution will be sent to double-lined

water

impoundments

Once

water

in these

impoundments has evaporated sediment will remain at

the bottom

f the pond

This sediment will be transported to

approved

ff-site

landfills

for

safe and

permanent storage Sediment

is the only

waste

material

produced from

the

in-situ

copper

recovery

ISCR process At closure

the ore zone will be rinsed with freshwater to

remove any

residual solution

until

the

groundwater meets water quality standards As such

there will be no waste material left

in the ore zone

Monitoring

wells do not

ensure that

no migration

f process

solution

r other

groundwater contamination

ccurs

it merely

identifies

what contaminants

exist if tested

for so how

is migration

prevented

The key to preventing migration

f process

solutions during

ISCR activities

is to pump

more

water out

f recovery

wells than

is injected

in injection wells

creating localized

drawing

in of

water from

the aquifer Process solutions are thereby confined within

this area of hydraulic

control Injection and recovery wells at the Florence

Copper

Project will have instrumentation that automatically detects and records

changes

in water chemistry

If there

is

change

in

water chemistry

that triggers monitoring criteria series

f actions
ccur

to respond to and correct the change including

immediately

ceasing

injection of process solution

There are

number of contingency plans

in place

should something

unpredictable

ccur

If target

constituents are detected in monitoring wells

ther

wells located up gradient can recover

groundwater

to keep constituents

from moving

to or past the monitoring wells As further

contingency monitoring wells

can be turned into recovery wells for pumping groundwater Multiple and

redundant

layers

f prevention

and control will be

in place

at the Florence

Copper

Project to ensure that solutions do not migrate off-site The natural

groundwater

flow

regime

at the site may very at different levels

below ground

elevations verify statement that

flow regime

at the

project

site

is from the

southeast to the

northwest

It

is opined that

groundwater

subflows enter the

Gila

River and flow directions

in

the

upper and lower

aquifers

differ

SWVP-019243

SLIDE 3

Flow direction

in the various

aquifers can change

ver

time and

is influenced

by pumping from

ther

wells

such as for irrigation

in

nearby field

The area of the aquifer that Curis will use

for ISCR

perations

is not generally

used for irrigation and

thus follows the natural gradient

towards

the northwest and

away from

the Gila River The project

site

is within

the Designated

Management Area

f the Town
f Florence

and hence wastewater

should

be regulated

by the Town

if needed

It

is also noted

that along with the

proposed

WWTP

there are proposed wells to be

utilized

for Merrill

Ranch and Anthem

at Merrill

Ranch development This item

is not addressed

specifically The

Florence

Copper

Project currently has an on-site wastewater

treatment

facility

with septic tank and leach

field

request

for permit transfer has been submitted

to ADEQ and

is in

process at this time

Emergency

services related to this project include

Town

f Florences Emergency

Response

Plans

and Multi-Jurisdictional Multi-Hazard Mitigation

Plan hence

the

ability

f emergency

services are yet

unknown

in response

to potential

emergency situations

at

the Project

site

This item should be revisited with

emergency

services

personnel

Agreed

During planning for both the

ISCR

production test and full commercial

ISCR

perations

emergency preparedness and response

will be thoroughly studied in close consultation with

Town

f Florence

personnel

The proposed

General Plan Amendment may affect

the

ability

to sustain

water

quality and quantity

demands of near

future residents

pending alterations

that

may exist for water quality and

quantity that have been

planned and funded

This item should be revisted

Water used

in the ISCR process

at the Florence

Copper

Project will be recycled That said

approximately

10 to 20% more water will be pumped

ut of the aquifer

than

is recycled

back into

it through

the injection wells This

is

permit condition

that

is required

to maintain hydraulic control

f all injected

solutions The 10 to 20

f surplus

water to be consumed by

ISCR

perations

amounts

to about 1300 acre feet

per year

This is

less

intensive

water

use

than agricultural development

n

the same land base

In

addition the aquifer that hosts the Florence

Copper

Project

rebody

is not generally

used for potable water

Potable

water used by

the Town

f Florence

is

within the upper aquifer

This

upper

aquifer

is separated from

the aquifer that hosts the orebody

by 20 40 foot natural

clay layer This clay layer prevents

mixing of the two

aquifers As such neither

water quality nor water quantity for current

r

future

Town

f Florence

domestic uses

will be affected

by the

Florence

Copper

Project CURlS

RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019244

SLIDE 4

Hydrology Are the

influences

f underground

mining on

hydrology to reduce the protective layer of the aeration

zone

raise

r lower

the water

level

in

light

f water

level

data

noted

by ADWR alter hydraulic gradients causing

changes

in

flow direction and speed

alter

natural retention

features and

create turbid ground

water due

to rock fracturing

To clarify

there will be no

underground mining

at the Florence

Copper

Project Curis proposes to recover

copper by injecting low pH

solution into the orebody and then

pumping

it out via

recovery wells

nce

copper

minerals have dissolved into solution

Pumping

will draw

water from

injection wells to recovery wells and

prevent the movement

f process

solutions

ff-site

The area of groundwater affected by

this process

is restricted

to the project well field

Surrounding groundwater

will continue to flow around the orebody in

northwest

direction Hydrofracturing

will not be undertaken at the Florence

Copper

Project

Are discontinuities

such as faults

and fracturing encountered

more frequently

with the injection/recovery

system

Consequently when

fracture flow

ccurs

does

it make it much

more

difficult

in underground

metals

mining to predict where

and

when

hydrologic impacts will occur

To clarify

there will be no

underground mining

at the Florence

Copper

Project The orebody

is

highly fractured

by nature which

is idealfor

the

in-situ

copper

recovery

ISCR process

The existing Underground Injection Control

UIC permit issued by the

EPA

prohibits hydrofracturing

f the orebody

at this site This means that no new fracturing will be allowed during the injection and recovery

process

Injected

fluids are expected

to flow along naturally

ccurring

fractures

in the orebody

from

injection wells to recovery wells The faults that

exist

at the site are actually

fault zones

that consist

f

number of parallelfractures

in fairly

close proximity to

ne

another

These fault zones do have higher hydraulic conductivity

than the surrounding

less fractured

rock

The location and extent

f the fault zones have

been thoroughly studied by previous

site owners

and Curis intends to add to this knowledge

base

Wells will be located so that they avoid

fault zones

The EPA UIC permit requires that hydraulic control

f injected

fluids is maintained

at all times

by creating and

sustaining localized hydraulic gradient that

draws

the injected

fluids to the

recovery wells

The water willflow

along the naturalfractures from

the injection wells to the recovery wells

but not beyond Are water-table

drawdown

predictions generally

based

n

the

assumption that

geologic materials transmit

water equally

in all

directions

isotropic and

that they are the same

ver

great distance

homogenous

Could

formations as structural

features

such as faults

and fractures control

magnify

and

extend drawdown

in

selected directions Curis

water table drawdown

predictions will be based

n

actual geological characteristics that include naturally

ccurring

variation anisotropic and heterogeneous On broad scale geologicalfeatures

will affect

drawdown

predictions

however

Curis UIC

permit requires

that

water drawdown

is managed

very

tightly in the injection

area Drawdown

effects

in the injection area will not extend more than

few tens of feet

in any direction outside

the injection

area regardless

f broader sub-regional

heterogeneity and

anisotropy

CURlS RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019245

SLIDE 5

Hydrology

Ground Water

Is ground

water quantity

affected by depletion

f the aquifer

when

recovery

and rinsing from mining drains and lowers the water table To what extent

in volume

The aquifer

in which

the Florence

Copper

Project

rebody

is located is deeper

than the aquifer generally

used for potable water

Most of the water used in the

ISCR process will be recycled

with

some

10 to 20 comprising surplus

water required

to maintain hydraulic control This 10 20

water surplus

will amount to about

1300

acre-feet

f water consumed by the project

each

year

r about

300 acre-feet

less than would

be consumed if two

alfalfa crops

were grown each year in the permitted ISCR

production area

f slightly

more than

200

acres

Can ground

water depletion

ccur
ver

large area and

impact

larger aquifers

by draining

water from the surrounding

aquifer into the cavity

If so what is the

extent

To clarify

no underground cavity will be formed at the

Florence

Copper

Project

In situ

copper

recovery

ISCR

will not create cone

f depression

as

is

typically

found

at mine

sites

that have

pen

pits

r underground

workings Pumping

required to maintain hydraulic control will cause

small

localized cone

f depression

similar to that

f

typical irrigation well

Is there

typically

direct relationship between the depth

f mining and

its relation

to the resulting

static

water level

In general

will water

levels

decline

more

as the

mine goes deeper Will water

levels

also decline

relative

to the location

f the

mine

both

horizontally and

vertically relative

to recharge/discharge

sources

To clarify

there will be no

underground mining

at the Florence

Copper

Project

Water

will be

pumped from

the ore zone at rate

slightly

higher

than the rate

at which

it

is injected

in order

to maintain hydraulic control The 20 40 foot natural clay layer below the

upper

aquifer prevents

water movement both up

and

down

Therefore the pumping that

is occurring

in the

rebody

will not change the

water level

in the upper

aquifer Do factors that affect

ground water quality

at

the

mine

include flow paths that

result

in movement

f surface

water to ground water geochemistry

and geochemical barriers

Surface

water precipitation

at the Florence

Copper

Project enters the

ground and

replenishes the near surface aquifer The natural clay layer below

this

upper

aquifer prevents

downward movement

f groundwater

into the ore zone The orebody does have geochemical characteristics that are naturally reflected

in the chemistry

f the

water

in the ore zone There

are no known

geochemical barriers in the orebody

r vicinity

Can ground

water

seeping

into the mine

contact fresh rock surfaces

may contain

reactive and soluble minerals lead to the formation of acid generation and metals

contamination

To clarify

there will be no

underground mining

at the Florence

Copper

Project As such

water

will not seep into underground

workings nor produce

acid rock

drainage Furthermore

the CURlS

RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019246

SLIDE 6

groundwater

chemistry

in the ore zone must

be returned to state

and federal

standards

following

ISCR operations

With

sustained

withdrawal

f ground

water

at

rate

significantly

greater

than the

natural recharge

rate

could impacts

happen

ver

large area and

ver

many years

About 1300

acre feet

per year of groundwater

will be removed

from

the deep aquifer

Not

nly

is the volume

removed small but this

deeper

aquifer

is not used for irrigation

r potable

water

in the immediate

project

area

Once

ISCR

perations

are complete and

groundwater

in the ore

zone

is returned

to pre-development levels the flow regime will return to pre-development conditions Thus the projects effect

n groundwater

will be local minor and

temporary How

is the surrounding

water and

soil stabilized

during and after injection/recovery The removal of copper minerals at the Florence

Copper

Project will occur at the molecular level

When

the copper enters solution and

is pumped

to surface

groundwater

takes the place

f the

removed copper

minerals within the ore zone

Therefore

there will be no soil

instability caving

r slumping at surface

Will

the

mining

activities

destabilize

r remove
ther

naturally occurring

contaminants

in

the

local soils and/or aquifer ISCR

perations

at the Florence

Copper

Project will dissolve certain

elements present

in the

re

zone

in addition

to cop per These

elements will be

transported with surplus

water to approved

double-lined

water impoundments

Once

water in these impoundments

is

evaporated

the remaining sediments will be removed and transported

for safe permanent

storage

in an approved

ff-site

facility

What

methods

are

in

place to ensure there

is no

leaching

f copper
ther

heavy

metals and radionuclides into the Town drinking

water supply

All elements present in the ore zone at the Florence

Copper

Project will be managed

by

hydraulic control

Any elements that

dissolve into solution during the

ISCR process will be

recovered along

with excess

water and

transported to approved double-lined

water impoundments for safe storage

Once the water in these impoundments

is evaporated

the

remaining sediments

will be removed and transported

for safe permanent

ff-site

storage What methods

are

in

place to avoid mixing

f Town

existing and future

recharge

waters

and the mine

waters

Recharge water for

Town

f Florence

wells comes

from precipitation

and from

ther

groundwater

sources located upgradient

f the Towns

wells from the south

east

The

Florence

Copper

site

is located

down

gradient

f

Town

f Florence

wells

In addition

Town

f

Florence wells

draw water from

the upper aquifer the Florence

Copper

Project will draw

water from much deeper

and hydrologic

ally distinct

aquifer The two aquifers are separated by 20 40 foot thick clay layer that prevents

them from mixing CURlS RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019247

SLIDE 7

What

are the

measures

that will

be taken

to ensure the native

water after mining

is brought

back to

its natural

stable non-corrosive

state

After

ISCR

perations

are complete

freshwater

will be injected to rinse all solutions

ut of the
re zone

This rinsing water will be recovered and

pumped

to approved double-lined

water

impoundments

This process will continue

until groundwater

quality

in the ISCR

production

area meets

strict

State and Federal

standards for background water quality levels What

is the

extent

f the

cone

f depression

There will be

no cone

f depression

in the water table

Pumping

at the Florence

Copper

Project will occur

in an

isolated

zone far below

the near surface aquifer The vast majority

f water

used

in this process will be re-used

Hydrology Surface

Water

Do factors that affect the

impact mines

n

surface

water include

nature and thickness

f strata

between

the surface water

body and mine workings

geological features and structural discontinuities stress distribution and

water hydraulics

To clarify

there will be no

underground workings at the

Florence

Copper

Project Please

re

phrase question

Can surface flows be affected by water table changes caused

by injection/recovery

and mine

dewatering

relative

to the

sequencing

f injection/recovery

flows

To clarify

there will be no

underground workings at the

Florence

Copper

Project Please

re

phrase question Could

spring

seepage and stream flows be reduced

as

result

f ground

water depletion

in

an adjacent

unmined

aquifer due to depressurization

f dewatering
f the

mined

area

ISCR

does not deplete groundwater

as

is

typically

seen at open

pit and underground

mines

Most of the water used for in-situ

copper

recovery

is reused

There will be surplus

f about

1300

acre feet

f water per year pumped
ut
f the

deep aquifer where the

rebody

is located

Could underground mining by changing

in the

volume

f ground

water inflow

to surface

water

have

an

effect

n

its

chemical

balance

To clarify

there will be no

underground workings at the

Florence

Copper

Project Please

re

phrase question

CURlS RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019248

SLIDE 8

Could mining

impacts that alter flow

regimes affect

the timing and amount of surface

runoff

All of the water to be used in the ISCR process

is groundwater

that

does not recharge to surface The

Florence

Copper

Project will have no effects

n surface

runoff

Could upstream

local

flows and

downstream

flows both

n

and

ff the mine

site be

affected

by underground mining-caused

hydrologic

impacts

To clarify

there will be no

underground workings at the

Florence

Copper

Project

About 1300

acre feet

f water

will be pumped

ut of the deep

aquifer

where

the

rebody

is located

each

year

This

deep aquifer has no

connection to surface

water Could changes

in

surface

water quantity

and timing change the frequency magnitude and duration

f flood

events

and natural baseline flow

conditions

The aquifer

in which

the Florence

Copper

Project

re body

is located is deeper

than the near

surface aquifer

most

affected

by flood events

This near surface aquifer

is separated from

the aquifer that hosts the Florence

Copper

Project

rebody

by 20-40 foot

thick natural clay layer that prevents

water from flowing

up and down As such

ISCR activities will have

no effect

n

the frequency

magnitude and

duration

f flood

events

r natural

baseline

flow conditions

Is

it the intent

to divert any washes

from the

facility

and any water waste

impoundments

Curis

is currently working to assess

the presence

f washes

at

its project

site

and has not yet

determined what measures may

be required

for storm runoff How does

the extraction

f metals

from

rock influenced

by water quality and

flow affect the geologic structure

verlying

the

mining areas

and resulting surface impacts The removal of copper minerals

ccurs

at the molecular level

When

the copper enters solution and

is pumped

to the surface

groundwater

takes the place

f the

removed copper

minerals within the ore zone As result the overlying rock and

soil will not cave

r subside

Hydrology Mitigation

Measures

Because

it

is not

possible to incorporate

all the factors in

the design

f

protective layer would mitigations that use buffer

zones

likely be

ineffective

in

preventing impacts to aquifers

r watersheds

in which

underground mining

is proposed

To clarify

there will be no

underground workings at the

Florence

Copper

Project Please

re

phrase question

In

rder

to be effective should

seal

designs be

site-specific performance-based and

address

geomechanical and hydro geological considerations CURlS RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019249

SLIDE 9

The UIC permit issued by the EPA specifies well seal design that

is based

n

site specific

geology

It is

performance based system These

permit requirements

include identification

f

specific

geologic units and establishes the acceptable

methods for sealing each

well through

r

into those geologic units Once

constructed

each well must pass pressure test before injection begins pass periodic well seal inspection and undergo pressure tests every five

years

If any wellfails any one

f these

steps

it will not go into service until it has been

repaired

r replaced

and successfully passes these tests

In

sensitive

r highly

valued areas

where

impacts to hydrology are either not allowed

r undesirable

based

n

an

appreciation that irreplaceable

ground water and

surface

water

resources

must be

protected

from mining impacts

could

banning mining activities from those

areas

be the

nly

protective

recourse

even

if

it

results

in the

loss

f the mineral

deposit

It has been

conclusively

demonstrated

in the past that ISCR

and

associated

methods for

protecting

water quality and

availability

hydraulic control

work effectively at

this site

Curis intends to demonstrate

this again

with

its

ISCR

production test

Hydrology

Time

Effects Does the permeability and

ther

factors affecting particular flow

system largely dictate

time

effects

Has the time effect

n

springs and

streams controlled by shallow

flow

systems been

shown to range

from

hours to days Does the time effect

n

deep flow

systems generally

run from decades to hundreds

f years

The aquifer to be used for ISCR at the

Florence

Copper

Project

has

hydraulic conductivity

f

about

ft per day This is considerably

lower than the upper

aquifer

which has

hydraulic conductivity

f 40ft per day

This deep aquifer

is separated from

the upper aquifer

by 20 40

foot natural clay layer There will be no effect

n

the Gila River because

it

is located

up gradient

f the project

site plus

the

river

is not connected

to the deep aquifer

Subsidence

Rock

Strength

Reduction

Impacts to Hydrology

Does

mining subsidence rock

strength

reduction

induce

fissuring

in

verlying

and

surrounding

strata influence hydrologic

systems

in ways

that

cause

changes

to both

water quality

and

quantity

There will be

no subsidence

in the Florence

Copper

Project

area because

there will be no

underground workings or rock

removed

Could

rock strength reduction-caused

fracturing

f overlying

strata enhance

vertical

flow

and

could lead to drainage

f overlying

aquifers

Could

permeability increase

when

fractures reach the ground

surface

lead to increased

ground water

recharge

and

near surface

water near depletion

To clarify

there will be no

underground workings at the

Florence

Copper

Project Please

re

phrase question

CURlS RESOURCES ARIZONA INC

1575

Hunt Highway Florence

Arizona 85132

USA

florencecopperproj ect.com

SWVP-019250

SLIDE 10

Are surface

and near-surface

soils and unconsolidated

materials

an

important factor

relative

to hydrologic impacts

because

they affect the exchange

f surface

water and ground

water

From

general hydrologic perspective the answer to this question

is yes

At the Florence Copper

Project

site specifically

the upper aquifer

is separated from

the deep aquifer that hosts the orebody

by 20 40 foot natural

clay layer that prevents

exchange

f water

Could ground water

drainage gradients be altered by disturbance

f the

strata around mine

areas Could

rocks

become

weakened

by saturation

and erosion patterns and thus

change

This question

appears

to be related to open

pit mining

which

is not planned

for the Florence Copper

Project

site

Please re-phrase

question Where

surface water

is present

may

it migrate

more

easily

to fractures and fissures

in

the strata and into the mineral area and possibly induce rock strength

reduction

There will be

no underground

workings at the

Florence

Copper

Project

for surface water to flow into

Rock strength reductions will not occur Could

rock strength reduction

cause the formation

f open

cracks fissures

r

pits which if

connected either directly

r indirectly

to surface

water lead to

partial

r complete

loss

f water that

is drained

to lower strata or mine workings There will be no underground

workings or open

pit

at the Florence

Copper

Project for surface

water to flow into Could ground water

be

affected

by rock

strength reduction

by lowering

f ground

water

levels

changes

in flow

rates and impacts to water quality Rock strength reductions are not associated with

ISCR

and will not occur at the

Florence

Copper

Project

Could dewatering

result

in

the formation of

cavities

and

result

in subsidence

as the hydro geological properties

f the

associated

strata are changed The

Florence

Copper

Project

site will not be dewatered as

result of ISCR

activities

It appears

that the subsurface

may

involve

sedimentary

rock

and fractured

rock

hence alteration

f

rocks

may

ccur

thus reducing rock strength

i.e

sulfide

re due to

Faster movement

f water throughout

fractured strata

Water

diversion

in

strata Alter water quality

by changes

in

chemical reactions

and reaction rates with minerals

r

strata CURlS RESOURCES ARIZONA INC

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SWVP-019251

SLIDE 11

Creates channels that did not

exist

before and

may

contact fresh rock surface that contain reactive

and soluble

minerals notwithstanding

groundwater

itself may be unstable

resulting

in dissolution/precipitation

reactions that change

ground water quality

Please

Comment

There will be

no underground

workings

pen

pits or block caving

at the Florence

Copper

Project

site

The copper minerals to be removed will dissolve from

rock surfaces

and be

replaced with

groundwater

within the

re zone

resulting

in no slumping

caving

subsidence

r
ther

surface

changes Subsidence

Rock

Strength

Reduction

Mitigation

Could

rock strength

damage

be controlled

by alteration

in mining techniques

post-mining stabilization architectural and structural

design

and comprehensive

planning

Do any

f these

measures entirely

prevent reduction

f rock

strength

To clarify

there will be no

underground workings at the

Florence

Copper

Project Stabilization to increase rock strength will not be necessary

Subsidence

Rock

Strength

Reduction

Reclamation

Is there

any statutory requirement requiring reclamation

f subsurface

areas

impacted

by mining

Is there

evidence

that subsided

areas

at least

in

part cannot

effectively be reclaimed and that reclamation

verall may be problematic

To clarify

there will be no

underground workings at the

Florence

Copper

Project

Subsidence

will not occur

Waste

Considerations

Will

wastes generated

be classified as Technologically

Enhanced Naturally

Occurring Radioactive Materials

TENORM

wastes and

will they require special handling

permits

Waste material

in water impoundments

at the Florence

Copper

Project will likely meet the definition

f TENORM because

it may contain

naturally

ccurring

radionuclides at higher concentrations

than those

that

exist in the orebody

from which

the radionuclides

were

removed

Information

btained from

Curis

proposed

ISCR

production test will be used to

determine TENORM

concentrations

in waste

materials and to estimate

maximum

likely

concentrations

f radionuclides

in the

water impoundments

after

ISCR

perations

finish When

ISCR

perations

are complete

contained water will evaporate from

the

water impoundments

The remaining sediment will be removed and transported to an approved

ff-site facility

for

safe and

permanent

disposal Special handling

requirements may apply depending

n

the

composition

f these

waste

materials CURlS

RESOURCES ARIZONA INC

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SLIDE 12

How do you respond

to

an EPA Report

that leaching

perations

and SX/EW

procedures

and recycling raffinate

may extract

and

concentrate soluble radioactive

materials

Specifically

data indicates that the

PLS

produced from

this

project contains very high

levels

f radionuclides

and that

they are leachable

This was done

based upon

data

produced

in

1996 and hence after the APP

permit

but before EPA

402-R-99-002

Technical Report

n TENORM

in

the Southwestern

Copper

Belt

f Arizona

The low levels

f radionuclides

that are expected to be encountered at the Florence

Copper

Project will be managed

by ensuring

they are collected

in solution

neutralized and

piped to

highly-en

gineered

double-lined

water impoundment where

they will ultimately precipitate into solid form

salt

as water evaporates

Water impoundments

at the Florence

Copper

Project will have multiple and

redundant

safety features to ensure they

cannot leak and

will be

monitored

n

daily basis Land

Use Considerations

Will

there

be any restrictions

n

the use of this area

r contiguous

areas during

r after mining

For

example will

it

be suitable

for residential

use rather than

farming

as

riginally

intended

Will

it be

suitable

for recharge

The

Florence

Copper

Project will be an industrial site such that there will be access

restrictions

during

perations

to ensure the health and safety

f the public

and employees Following

ISCR

perations

and closure the site can be rezoned for several types

f potential

uses

such as residential

recreational agriculture

r other

The

ISCR

production

zone

will be rinsed with

freshwater

until

State and Federal

water quality standards

are met As such the

site will be

suitable

for recharge

In

the SX/EW

perations

are there

any reagent

tanks

If so what

There are seven reagents that will be used at the Florence

Copper

Project

Some are

liquids

that will be stored

in tanks

thers

are

solids

that will be stored

in 45

gallon

drums

r bags

The

reagents are

FC1100

surfactant guar gum cathode

smoother

sodium

bicarbonate

r

sodium

hydroxide

aka

baking soda cobalt

sulfate protects anodes L1X984N

r similar

extractant

ShelISol

D70 or similar dilutes

the extractant and sulfuric acid dissolves

copper

in ore

General What

is the pumping

rate for the injection and recovery

wells During the

ISCR

production test solution will be injected at about 120

gpm

and

recovered at about

140 gpm

During operations about

1300

acre feet

per year of groundwater

will be

consumed

CURlS RESOURCES ARIZONA INC

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SLIDE 13

Will

there

be any Dam

Safety Permits

required

Depending

n final engineering

designs to be included in Curis significant APP application

dam

safety permits

may

be required

for the proposed water impoundments

The existing water

impoundment

n

the Florence

Copper

Project

site

is exempt

from dam

safety permit

requirements because

the height

f the berm

is

less

than six feet

Will

any hazardous waste be

hauled

from the site

The

Florence

Copper

Project will produce

minimal amounts

f hazardous

waste

It is expected

that

it will operate under

regulations

for small

quantity

generators What

is the

APP boundary See attached figure

Will

there

be

need

for 404

permits

Curis

is currently working to determine

if

404

permit will be

required

What

ther

metals are released during

exposure

to

sulfuric

acid under various

time temperature

and acid-concentration

conditions Laboratory

column tests were performed

n

Florence

Copper

Project

re samples

by BHP

to

study the

ability

f the
re to release

copper These

tests

were

also used to determine

which

ther

elements were

likely

to enter solution during the in-situ

copper

recovery

process

The test solution

was analyzed for 45 elements

Of these elements 28 were

detected

above the

method detection

limit of the lab equipment

aluminum

antimony

arsenic

barium

beryllium

calcium

cobalt

copper iron lead magnesium

manganese

nickel

potassium selenium

sodium strontium

tin vanadium

zinc gross alpha gross beta three isotopes

f uranium

and three isotopes

f radium

The 28 elements were present

in

wide range

f concentrations

All

elements that

enter solution at the Florence

Copper

Project will either be extracted as

elemental copper

r sent

to double-lined

water impoundments

and eventually

form sediments

Once the water

in these

impoundments has evaporated sediments

will be removed and transported to an approved

ff-site

facility

for safe and permanent

disposal

What

type

f studies

have been

r will

be

undertaken

to determine the reaction

between

the

acidic

raffinate and

rocks in-place

and

BHP performed

extensive laboratory-based metallurgical test work to determine how the ore

would

react with the raffinate Curis plans to

drill

core

samples from

the BHP

test site

to further

study the geochemical

reactions that

ccurred

the reactions with leach

field

remediations

This was not studied

by BHP

in the past

but Curis plans

to do so CURlS

RESOURCES ARIZONA INC

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Arizona 85132

USA

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SWVP-019254

SLIDE 14

Is the

injection

/recovery process

conducted

at ambient temperatures

There will be

no heating

r cooling
f solutions

at the Florence

Copper

Project This ISCR

is

basically

chemical

weathering

thus

changing

the

makeup

f the

parent rock

through

chemical reactions recognizing that

water

can

dissolve

most

minerals that hold rock

together

ur

concern

is related

to contaminant transport so what

contaminants

are foreseen and have

they been modeled based

upon the hydraulic controls

as related to the time effects

f the

chemical reaction

produced

BHP

retained Brown and CaIdwell to develop fate and transport

groundwater models

during the 1990s Curis has retained Brown and CaIdwell to update these

models and

re-evaluate the

chemical reactions

that will occur

in the orebody

and groundwater

flow patterns Under

its

permit conditions

Curis will be required to monitor

groundwater quality for 30

years after closure

such that

these

models

will extend substantially

into the future

Environmental Considerations What

type

f notication

will be provided to the public

if any exceedance

f any permit

condition that

may cause or

result

in imminent

and substantial endangerment to the public

r environment

Curis

approach

is to prevent any endangerment

to the public

r environment

Should an

uncontrollable catastrophe

ccur

the public fire department police and regulatory agencies

would be contacted immediately

to ensure public safety

What

restoration well

plugging

and

temporary

closure functions

were

previously

completed

at

the

site

BHP plugged and permanently

closed exploration

drill

holes within 500 ft of

its

ISCR

production test

What

geological

formation related

radiochemicals will

be

encountered

Radium

uranium and radon What

process related waste/organics will be produced Raffin ate at the Florence

Copper

Project will contain

rganic

substances used in the SX/EW

plant that help remove dissolved

copper from solution

What

is the

action/reporting

if the

injection

fluid

exceeds

the recovered

amount

in

periodic

time frame or

loss

f hydraulic

gradient

is encountered

to the Town

f Florence

Ditto for spillage and

discharge

f hazardous

waste/

material

Following

loss

f hydraulic

control

for 24 hrs Curis

is required

to

adjust flow rates inspect and repair surface

facilities

and

monitoring devices

as needed initiate pressure

testing of wells

if

CURlS RESOURCES ARIZONA INC

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USA

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SWVP-019255

SLIDE 15

problem cannot

be corrected

through

inspections and repairs Following

loss

f hydraulic

controlfor 48 hrs Curis

is required

to cease

injection of solution

in affected

area

inspect and repair associated

facilities

increase recovery rates

until

verage

is eliminated

Groundwater

effects are important how are exceedances reported to the Town

f

Florence

in

regards to Aquifer Quality Limits or Alert Levels

Water quality data

is submitted

to ADEQ and EPA quarterly These reports are also available to the public

although

they

were not sent

directly

to the Town

f Florence

in the past

Does hazardous waste generation include any radiochemicals

from the effects

f the

injection/recovery

perations

Radiochemicals

are subject to different regulatory

system than are hazardous wastes

There will be some radiochemical

salts

present

in the sediment in the water impoundments

at the Florence

Copper

Project following closure

Depending

n their concentration

special handling

requirements may

be necessary

What

waste from the

electrowinning process are encountered and

how

are they

disposed

Typical

waste products from an SX/EW

plant

Electrolyte

bleed

this stream MAY be first sent to an

extraction

stage to recover copper

in which case it would

be part

f and

add to the raffinate

stream leaving

the SX

facility

Backwash solution

from

electrolyte filters

water impoundments

Brine from

RO plant

if one

is

in the design

water impoundments

Lead

sludge

from

cleaning the EW

cells

trucked to approved

hazardous waste

disposal

facility Organic/clay sludge

from

cleaning the organic solution and also from the filter backwash

most

likely

be collected

in 45

gallon

drums and

trucked to an approved

ff-

site

disposal

facility

for safe permanent storage

procedure

included various

ponds

to store water

sulfuric

acid

raffinate and caustic

soda

as such

what

remains

There

is one

water impoundment

at the site which was

used by BHP

during its production test There are storage tanks adjacent to the water impoundment for sulfuric acid raffinate and caustic

soda

that are currently empty CURlS

RESOURCES ARIZONA INC

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Arizona 85132

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SLIDE 16

Permits What

is the

water quality

baseline data

noted

in

Part

II

Section

f the

UIC Permit Reference the appropriate section/document The water quality baseline refers to data collected

for the purpose

f providing

basis for the establishment

f alert levels

and aquifer

water quality limits Some data had been

collected before the APP and UIC permit applications

were submitted by BHP

in January 1996

and were included

in Volume

II of the application

Additional

data were

collected and

submitted

thereafter and an extensive report

was submitted

n September

15 1998

Information

in that

report was

evaluated by ADEQ

and formed the basis of the current

alert levels

and aquifer quality limits which were incorporated into 2001 APP amendment

What

ther

agent

may

be

used

during the process to restore the

zone to

drinking

water standards

It has been

demonstrated

that rinsing with freshwater

is sufficient

to return the groundwater to drinking

water standards following

ISCR operations There

are other

agents such

as

bicarbonate

that could be added to the injection/recovery

zone should challenges develop

in

ther

parts

f the orebody

Document that

the EPA has

reviewed

this

permit every

five

years since initial approval

When BHP

sold the property to Merrill Mining the 5-year well integrity testing did not occur Curis will ha ye each

f the BHP

test

wells inspected

in 2010

Has not there

be any changes

in the

levels

f MCLs

that warrant

revisiting

the Alert Levels and

AQL

Levels

for water

Curis application to amend the APP and UIC permit will include report with

recommendations for modifying and adding to

as appropriate the alert

levels

and aquifer quality

limits in the

permits

That report will include

review of existing MCLs

Previously

it was

alluded to that there was

an

active

permit

for the mine

yet the

letter

to USEPA

in

regards to the subject

f Application

to Amend

APP No 101704

clearly

states ADEQ approves the Significant

APP amendment

so what

is the

current status

f permits

particularly the

UIC

and APP The current APP and UIC permits were transferred to Florence Copper

when

it acquired

the property

from BHP

The APP includes provision recognizing that the facility

is in temporary

cessation and that

nothing may be

done to increase closure cost without first amending the

permit

Curis Arizona has submitted an application to amend the APP and UIC for transferring the permit to Curis Arizona and for authorizing the

installation

and

peration
f an ISCR

production test Information

gained from

the operation

f this production

test

will be used in the application

for significant APP amendment

and for an amendment to the UIC permit Both applications will request and

support

authorization

f commercial operations

The application

process requires that the public

be

given

pportunity

to review and comment on the applications CURlS

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Arizona 85132

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SWVP-019257

SLIDE 17

What process amendments

are needed to reactivate existing permits

Some permits

require

company name

change

Others are more complex For example the applications

for transferring

the APP and the UIC permit to Curis Arizona required

updated

closure and post-closure cost estimates and related financial

assurance for existing facilities and

the proposed test facility The applications

for authorizing commercial

perations

will require revised closure and post-closure cost estimates and related

financial assurance for the entire facility and complete

review

and

expansion as appropriate

f information

used to support existing and proposed

conditions

f the permits

State Mineral Leases has expiration

dates what

is being

done

in

regards to this permit The State Mineral lease was transferred to Curis on February 24 2010 and expires December

13 2013

Curis will apply to renew the lease prior to expiration

Additional Questions

from Other Sources

Sulfate Concentrations

in Test Well

Block

When

did the sulfate concentrations

drop below

750 milligrams per liter mgL

December 15 1999

BHP Copper performed daily sulfate analyses

during injection from

November

1997

through February 12 1998

and during the initial rinsing from February 13 1998

through June 30 2001

When

did the sulfate concentrations

drop below

250 mgL Sometime between July 2001 and December 29 2003

The

precise

date

is not known

because no samples were

collected

between

July 2001 and December 29 2003

General

Water Quality

Are there any constituents

in groundwater

at

the

Site

that naturally

ccur

above the Arizona Aquifer Water Quality

Standards AWQS

Nitrate concentrations above the

WQS

have been reported

in groundwater

collected

from

wells

in the Florence

Copper

Project

area

Because nitrates are above the

WQS

in the area

and are not used

in the ISCR

process the Aquifer

Protection

Permit does not include

either an Alert Level

r an Aquifer

Quality Limit for nitrate Nitrate concentrations above the

WQS

have been reported

in groundwater

collected

from wells

at the project

site

during baseline

sampling from

1995

through mid-1997

and during compliance

monitoring from

late 1997 to the present

time

High

levels

f nitrate

exceeding

WQS

ccur

more frequently

in Point

f Compliance

POC

wells screened

in the Upper Basin

Fill

Unit than in POC wells screened

in the Lower Basin

CURlS RESOURCES ARIZONA INC

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SLIDE 18

Fill Unit

Only one exceedance

is known

to have

ccurred

in the Oxide Zone

where

the ore

body

is located

and that

ccurred

during the baseline

sampling period

few

water samples contained naturally

elevated

levels

f trace

elements antimony

cadmium

and

thallium

gross alpha and

total radium

during the collection

f baseline

data between

1995 and 1997

in the

POC wells but no verified exceedance

f

trace

element or

radiochemical

WQS has occurred

in

POC well

since compliance

monitoring began

in late 1997

Questions are recorded verbatim from compiled

list from the Town

f

Florence

CURlS RESOURCES ARIZONA INC

1575

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USA

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