materials management plan

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

Materials Management Plan As Required By: Mitigation Measure FS-HM-01

Hazardous Materials Containment and Management

October 2018

Prepared by:

Rosemont Copper Company

Materials Management Plan, Rev. 3 Page i

Monitoring and Reporting Schedule

Task Schedule Purpose/Description/

Timing

Pre-Mining Period/

Construction Phase

Active Mining Phase/

Operations Phase

Closure Phase 1

AN A AN A AN A

Inspections of containment and materials management

To ensure compliance with applicable regulations and MPO

x x x

Monitoring of blasting and explosives management

To ensure compliance with applicable regulations and MPO

x x x

Reporting

To Forest Service

Monitoring and Inspection results

x x x

AN = As Needed; A = Annually; 1 = Closure Phase = Final Reclamation and Closure Phase; MPO = Mine Plan of Operations

Revision Log

Revision Number

Revision Lead

Purpose of Revision Revision

Date

1 Rosemont Updated plan date from original June 2017 MPO submittal, added revision number.

March 2018

2 Rosemont Based on Forest Service review of June 2017 and March 2018 MPO submittals.

June 2018

3 Rosemont Added Data Management Language per FS October

2018

Materials Management Plan, Rev. 3 Page ii

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

1.1 PLAN OBJECTIVES ...................................................................................................... 1

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

2.0 HAZARDOUS MATERIALS MANAGEMENT....................................................................... 4

2.1 BLASTING MATERIALS ................................................................................................ 4

2.1.1 REGULATIONS ......................................................................................................... 4

2.1.2 MANAGEMENT AND HANDLING PROCEDURES .................................................. 5

2.1.2.1 LICENSE/PERMITS ......................................................................................... 5

2.1.2.2 TRANSPORTATION OF EXPLOSIVES ........................................................... 5

2.1.2.3 MAGAZINE CONSTRUCTION ........................................................................ 5

2.1.2.4 EXPLOSIVES AND BLASTING-CONSTRUCTION ......................................... 5

2.1.2.5 EXPLOSIVES AND BLASTING-PRODUCTION .............................................. 5

2.1.2.6 BLASTING MATERIALS SPILL PREVENTION PROCEDURES .................... 6

2.1.3 MONITORING ........................................................................................................... 6

2.1.4 RECORDS ................................................................................................................ 6

2.2 PETROLEUM MATERIALS ........................................................................................... 7

2.2.1 REGULATIONS ......................................................................................................... 7

2.2.2 MANAGEMENT AND HANDLING PROCEDURES .................................................. 7

2.2.2.1 PETROLEUM MANAGEMENT AND STORAGE ............................................. 7

2.2.2.2 PETROLEUM HANDLING ............................................................................... 8

2.2.2.3 PETROLEUM SPILL PREVENTION PROCEDURES ................................... 10

2.2.2.4 PETROLEUM SPILL RESPONSE PROCEDURES ...................................... 10

2.2.3 MONITORING ......................................................................................................... 11

2.2.4 RECORDS .............................................................................................................. 12

2.3 REFRIGERANTS/FREON ........................................................................................... 13

2.3.1 REGULATIONS ....................................................................................................... 13

2.3.2 MANAGEMENT AND HANDLING PROCEDURES ................................................ 13

2.3.2.1 REFRIGERANT MANAGEMENT ................................................................... 13

2.3.2.2 REFRIGERANT HANDLING AND TRANSFERS .......................................... 15

2.3.2.3 REFRIGERANT LEAK PREVENTION AND RESPONSE PROCEDURES ... 16

2.3.3 MONITORING ......................................................................................................... 17

2.3.4 RECORDS .............................................................................................................. 17

2.4 LABORATORY ............................................................................................................. 17

2.4.1 REGULATIONS ....................................................................................................... 17


Materials Management Plan, Rev. 3 Page iii

2.4.2.1 LABORATORY CHEMICAL MANAGEMENT ................................................. 17

2.4.2.2 LABORATORY CHEMICAL HANDLING AND STORAGE ............................. 18

2.4.2.3 LABORATORY CHEMICAL SPILL PREVENTION AND

RESPONSE PROCEDURES ......................................................................... 19

2.4.3 MONITORING ......................................................................................................... 19

2.4.4 RECORDS .............................................................................................................. 20

2.5 CLEANING FLUIDS ..................................................................................................... 20

2.5.1 REGULATIONS ....................................................................................................... 20


2.5.2.1 CLEANING FLUIDS MANAGEMENT ............................................................ 20

2.5.2.2 CLEANING FLUIDS HANDLING ................................................................... 20

2.5.2.3 CLEANING FLUIDS SPILL PREVENTION AND RESPONSE

PROCEDURES .............................................................................................. 21

2.5.3 MONITORING AND RECORDS ............................................................................. 21

2.6 COMPRESSED GASES .............................................................................................. 21

2.6.1 REGULATIONS ....................................................................................................... 21


2.6.2.1 COMPRESSED GASES MANAGEMENT ..................................................... 21

2.6.2.2 COMPRESSED GASES HANDLING AND STORAGE ................................. 22

2.6.3 MONITORING ......................................................................................................... 23

2.6.4 RECORDS .............................................................................................................. 23

3.0 WASTE MANAGEMENT ..................................................................................................... 24

3.1 HAZARDOUS WASTE ................................................................................................. 24

3.1.1 REGULATIONS ....................................................................................................... 24

3.1.2 HAZARDOUS WASTE MANAGEMENT ................................................................. 25

3.1.2.1 WASTE PROFILES ........................................................................................ 27

3.1.2.2 HAZARDOUS WASTE ACCUMULATION AND STORAGE

PROCEDURES .............................................................................................. 27

3.1.2.3 HAZARDOUS WASTE PRE-TRANSPORT ................................................... 28

3.1.2.4 LAND DISPOSAL RESTRICTIONS ............................................................... 28

3.1.2.5 HAZARDOUS WASTE EMERGENCY PREPAREDNESS AND

PREVENTION ................................................................................................ 29

3.1.2.6 HAZARDOUS WASTE CONTINGENCY PLAN AND

EMERGENCY PROCEDURES ...................................................................... 30

3.1.3 MONITORING ......................................................................................................... 31

3.1.4 RECORDS .............................................................................................................. 31

3.2 UNIVERSAL WASTE ................................................................................................... 33

Materials Management Plan, Rev. 3 Page iv

3.2.1 REGULATIONS ....................................................................................................... 33

3.2.2 ACCUMULATION AND MANAGEMENT PROCEDURES ...................................... 34

3.2.2.1 UNIVERSAL WASTE MANAGEMENT AND STORAGE ............................... 34

3.2.2.2 LAMPS ........................................................................................................... 34

3.2.2.3 WASTE BATTERIES HANDLING .................................................................. 34

3.2.2.4 PESTICIDES .................................................................................................. 35

3.2.2.5 MERCURY-CONTAINING EQUIPMENT ....................................................... 35

3.2.3 MONITORING ......................................................................................................... 36

3.2.4 RECORDS .............................................................................................................. 36

3.3 USED OIL/OIL FILTERS .............................................................................................. 36

3.3.1 REGULATIONS ....................................................................................................... 37


3.3.2.1 USED OIL MANAGEMENT AND STORAGE ................................................. 37

3.3.2.2 USED OIL HANDLING ................................................................................... 38

3.3.2.3 USED OIL FILTERS MANAGEMENT, HANDLING AND STORAGE ............. 38

3.3.2.4 USED OIL SPILL PREVENTION PROCEDURES ......................................... 39

3.3.2.5 USED OIL SPILL RESPONSE PROCEDURES ............................................ 39

3.3.3 MONITORING ......................................................................................................... 39

3.3.4 RECORDS .............................................................................................................. 40

3.4 SPENT TIRES (LARGE AND SMALL) ........................................................................ 40

3.4.1 REGULATIONS ....................................................................................................... 40


3.4.2.1 LARGE TIRE MANAGEMENT, HANDLING AND DISPOSAL ....................... 41

3.4.2.2 SMALL TIRE MANAGEMENT, HANDLING AND DISPOSAL ........................ 42

3.4.3 MONITORING ......................................................................................................... 42

3.4.4 RECORDS .............................................................................................................. 42

3.5 SOLID WASTE/GENERAL TRASH ............................................................................. 42

3.5.1 REGULATIONS ....................................................................................................... 43

3.5.2 SOLID WASTE/GENERAL TRASH MANAGEMENT AND HANDLING ................. 44

3.5.3 MONITORING ......................................................................................................... 44

3.5.4 RECORDS .............................................................................................................. 44

3.6 SEPTIC WASTE .......................................................................................................... 44

3.6.1 REGULATIONS ....................................................................................................... 45

3.6.2 SEPTIC MANAGEMENT PROCEDURES .............................................................. 45

3.6.3 MONITORING ......................................................................................................... 45

3.6.4 RECORDS .............................................................................................................. 45

3.7 NON-MUNICIPAL SOLID WASTE LANDFILL WASTE ............................................... 46

Materials Management Plan, Rev. 3 Page v

3.7.1 REGULATIONS ....................................................................................................... 46


3.7.2.1 LANDFILL MANAGEMENT ............................................................................ 46

3.7.3 MONITORING ......................................................................................................... 47

3.7.4 RECORDS .............................................................................................................. 48

3.8 SPECIAL WASTE ........................................................................................................ 48

3.8.1 REGULATIONS ....................................................................................................... 48

3.8.2 PETROLEUM CONTAMINATED SOIL MANAGEMENT AND HANDLING PROCEDURES ....................................................................................................... 49

3.8.3 MONITORING ......................................................................................................... 50

3.8.4 RECORDS .............................................................................................................. 50

3.9 RECYCLABLE MATERIALS ........................................................................................ 50

3.9.1 REGULATIONS ....................................................................................................... 51

3.9.2 RECYCLABLE MATERIALS ACCUMULATION AND MANAGEMENT .................. 51

3.9.2.1 SCRAP METAL, WOOD, AND CARDBOARD ............................................... 51

3.9.2.2 HIGH-DENSITY POLYETHYLENE MATERIALS ........................................... 52

3.9.2.3 OFFICE RECYCLABLES ............................................................................... 52

3.9.3 MONITORING ......................................................................................................... 52

3.9.4 RECORDS .............................................................................................................. 52

3.10 EMPTY PRODUCT CHEMICAL CONTAINERS .......................................................... 52

3.10.1 REGULATIONS ....................................................................................................... 53


3.10.3 MONITORING ......................................................................................................... 54

3.10.4 RECORDS .............................................................................................................. 54

3.11 SECURED DOCUMENTS ........................................................................................... 54

3.12 PRINTER CARTRIDGES ............................................................................................ 55

4.0 CLOSURE AND BOND RELEASE ..................................................................................... 56

4.1 INTERIM CLOSURE .................................................................................................... 56

4.2 FINAL CLOSURE ........................................................................................................ 56

4.3 BOND RELEASE ......................................................................................................... 57

5.0 DATA MANAGEMENT ........................................................................................................ 58

6.0 REFERENCES .................................................................................................................... 59

Materials Management Plan, Rev. 3 Page vi

Appendices Appendix A Blasting Standard Operating Procedures (SOPs)

Appendix A-1 Construction Radio and Blast Site SOPs

Appendix A-2 Production Explosives and Blasting SOP

Appendix A-3 Ammonium Nitrate Handling SOP

Appendix B Universal Waste Management

Appendix B-1 Pima County Department of Environmental Quality – Management of Universal Waste

Appendix B-2 Arizona Department of Environmental Quality – Managing Universal Waste Lamps for Businesses

Appendix C Performance Assurance Plan for Septic Systems

Appendix D Landfill Methane Monitoring Plan

Appendix E Product Review Plan

Materials Management Plan, Rev. 3 Page 1

1.0 PLAN OBJECTIVES AND DESCRIPTION This Materials Management Plan (Plan) was developed as a 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-HM-01: Hazardous materials containment and management” on pages B-65 and B-66 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.

Hazardous materials containment and management involves the handling, storage, and use of hazardous materials in accordance with laws and regulations, including the proper communication of information with regard to such materials. This Plan documents the procedures that will be utilized to ensure that hazardous materials will be properly transported, used, stored, handled, and accumulated to reduce the potential impacts to human health and the environment. This Plan also covers the handling of universal and non-hazardous wastes, including recyclables.

Monitoring for Mitigation Measure FS-HM-01 will begin in the Pre-Mining Period of the Project and will continue through active operations (Active Mining Phase/Operations Phase) and into the Final Reclamation and Closure Phase (Closure Phase).

1.1 PLAN OBJECTIVES

The objectives of Mitigation Measure FS-HM-01 are to:

Reduce potential impacts to human health and the environment from the transportation, use, storage and handling of various hazardous materials including:

o Blasting Materials (ammonium nitrate and diesel fuel)

o Petroleum fluids (such as fuel and lubricants for vehicles and equipment)

o Refrigerants (Freon) for cooling systems

o Laboratory reagents

o Cleaning fluids

o Compressed gases for welding

Reduce potential impacts to human health and the environment from the generation, storage, and transportation of various wastes including:

o Hazardous waste

o Universal waste

o Used oil/oil filters

o Spent tires (large and small)

o Solid waste/general trash

o Septic waste

o Municipal landfill waste

o Special Waste (i.e. petroleum contaminated soil)


o Recyclable materials (scrap metal, wood, landscape/plant debris, paper, cardboard, aluminum cans, plastic bottles, glass, and plastics)

o Empty product chemical containers

o Secured document disposal

o Printer cartridges

Minimize loss or spillage of materials and waste during use, handling, generation, storage, and transportation; and

Fulfill the requirement to develop an explosive and blasting management procedure.

Other Forest Service mitigation measures and/or other permits associated with hazardous material issues include FS-HM-02, which is addressed in the Hazard Communications Program (Mine Plan of Operations [MPO] Volume II-n):

FS-HM-02: This mitigation measure requires on-site maintenance of Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS). This information must also be available to emergency service providers. See page B-66 in Appendix B of the FEIS.

Additionally, Rosemont will evaluate products that are proposed for use at the Project site, etc. This evaluation is described in the Product Review Plan in Appendix E of this document.

1.2 PLAN DESCRIPTION

While Rosemont expects the materials addressed herein to represent negligible risk to the environment, this Plan documents the procedures regarding how they will be properly handled, used, stored, and/or disposed to meet the applicable regulations and Forest Service requirements.

This Plan includes the following components:

Appropriate level of training for employees on the potential safety and health risks from hazardous materials in accordance with employee’s duties.

Pollution prevention procedures for all aspects of hazardous material management with an emphasis on source reduction as the primary means of maintaining compliance with applicable Federal, State, and local environmental regulations.

Procedures for the proper handling, storage, transportation, and disposal of hazardous materials. Recyclable materials are also included in this Plan to show the opportunities for reuse, etc.

Spill prevention and response procedures to ensure appropriate and timely response to release or threats of release of hazardous materials.

o Procedures for the handling of ammonium nitrate used in production blasting in order to minimize loss or spillage.

Management techniques for the transportation, use, and storage of hazardous materials other than those used for blasting purposes.

The following are some of the additional requirements that apply to hazardous materials management and reporting at Rosemont:

Hazardous Materials:


o Superfund Amendments and Reauthorization Act or SARA - Toxic Chemical Release Inventory (Section 313) requires annual reporting of chemicals in quantities above threshold levels on the use, release and disposal of those chemicals in a Toxic Release Inventory or TRI. Information about TRI reporting can be found at https://www.epa.gov/toxics-release-inventory-tri-program or in Emergency Planning and Community Right to Know Act (EPCRA) Section 313 Reporting Plan (TRI Plan) (MPO Volume IV-i).

o The Arizona Law (Arizona Revised Statutes-Title 26, Chapter 2, Article 3) authorized the Arizona State Emergency Response Commission for TRI reporting and can be viewed at: http://www.azserc.org/

o Mine Safety and Health Administration (MSHA), 30 CFR is the primary set of rules and regulations governing surface metal and non- metal mines (http://www.msha.gov). The Arizona State Mine Inspector’s Office has jurisdiction over surface metal and non-metal mines (https://asmi.az.gov).

o The United States Department of Transportation (DOT) enforces the codes for domestic transportation of explosives. For regulations from the DOT, refer to Title 49 of the Code of Federal Regulations, Chapter I, Parts 100-185; Chapter III, Parts 300-399; Chapter IV, Parts 400-499, Chapter X, Parts 1000-1399; Chapter XI, Part 1420 and Chapter XII, Parts 1500-1699. These regulations can be found at: https://www.gpo.gov/fdsys/


2.0 HAZARDOUS MATERIALS MANAGEMENT This section identifies the specific hazardous materials that are planned for use at the Rosemont Project. Although the hazardous materials described below include those that are predicted to only have a negligible impact, they are still described in order to ensure that compliance requirements for those materials are addressed and that properly handled on site to prevent any environmental impacts.

The applicable regulations, management and handling procedures, monitoring, and records are presented for each anticipated hazardous material. The regulation sub-section includes the applicable federal, state, county, and other requirements. The management and handling procedures present the procedures for use, handling, general management, spill prevention and response (if applicable due to quantity and risk to soil, surface water and groundwater), and storage. The monitoring subsection documents the inspections and tracking completed during the use, handling management, spill prevention and response, and storage. The records subsection identifies the records that are generated from each of the monitoring activities from each material.

2.1 BLASTING MATERIALS

Blasting materials include ammonium nitrate and diesel fuel. Because these materials are not explosives, they will be stored separately, handled per the procedures defined herein, and mixed only in quantities necessary for each blasting episode for both construction of the mine and during production. Elevated ammonium nitrate silos having a 75-ton capacity will be located at the south end of the open pit. The ammonium nitrate and diesel fuel would not be mixed until ready to be placed in the blast holes.

2.1.1 Regulations

The following regulations apply to the use of explosives at a mine site for construction and production:

Regulatory Agency

Regulation Regulatory Reference

Web Link

Mine Safety and Health Administration (MSHA)

Explosives Regulations

30 Part CFR Part 56 Subpart E

https://www.ecfr.gov/cgi-bin/text-idx?SID=d627d92a6120151b1fbbc7711c60796b&mc=true&node=pt30.1.56&rgn=div5#sp30.1.56.e

US Bureau of Alcohol, Tobacco, Firearms and Explosives (US BATFE)

Federal Explosives Law and Regulations

ATF Publication 5400.7

http://www.atf.gov/files/publications/download/p/atf-p-5400-7.pdf

Occupational Safety and Health Administration (OSHA)

Explosives regulations

29 CFR 1910.109

https://www.gpo.gov/fdsys/search/pagedetails.action?collectionCode=CFR&browsePath=Title+29%2FSubtitle+B%2FChapter+Xvii%2FPart+1910%2FSubpart+H%2FSection+1910.109&granuleId=CFR-1999-title29-vol5-sec1910-109&packageId=CFR-1999-title29-vol5&collapse=true&fromBrowse=true

US Department of Homeland Security (USDHS)

DHS regulations

6 CFR Chapter I Parts 5, 7, 9, 13, 15, 17, 21, 25, and 29

https://www.gpo.gov/fdsys/search/searchresults.action?st=6+CFR+Chapter+I+Parts+5%2C+7%2C+9%2C+13%2C+15%2C+17%2C+21%2C+25%2C+and+29

US Environmental Protection Agency (USEPA)

Federal environmental regulations

40 CFR Chapter I, Parts 1 to 789

https://www.gpo.gov/fdsys/search/search.action?na=&se=&sm=&flr=&ercode=&dateBrowse=&govAuthBrowse=&collection=&historical=false&st=40+CFR+Chapter+I%2C+Parts+1+to+789&psh=&sbh=&tfh=&originalSearch=&fromState=&sb=re&ps=10&sb=re&ps=10


2.1.2 Management and Handling Procedures

The following provide standard operating procedures (SOPs) developed for the handling of explosives at the main Project site or other Project related areas. Procedures will be updated as needed to ensure that Best Management Practices (BMPs) are applied.

2.1.2.1 License/Permits

Any person or corporation that wishes to use explosive materials must have a user permit issued by the Bureau of Alcohol Tobacco and Firearms (ATF). If you combine non-explosive components to produce an explosive material (such as mixing ammonium nitrate and fuel oil – ANFO), a manufacturing license from the ATF is required. Permits and licenses are valid for a period of three years.

2.1.2.2 Transportation of Explosives

Vehicles used to transport explosives must meet specific requirements and must be transported in a closed body vehicle. The vehicle must have exterior placards on all sides and be marked as required by the Department of Transportation. Personnel must not have firearms or smoke, carry matches or any other flame-producing device while in or near a vehicle transporting explosives.

Vehicles transporting explosives must be inspected to determine the following are in proper condition: fire extinguishers, electrical wiring is protected and secure, chassis, motor, pan and underside of body reasonably clean and free of excess grease or oil, fuel tank and feedline secure with no leaks, tires properly inflated with no defects, and all other aspects in proper condition and acceptable for handling explosives. Vehicles must only be driven by trained operators, not parked on a city street, be attended at all times unless it is locked within an area secured for that purpose. Nothing that could cause sparks or other unstable conditions can be transported in the same vehicle. Vehicles shall avoid congested areas and heavy traffic and finally delivery shall only be made to authorized persons and into authorized magazines or authorized storage and handling areas.

2.1.2.3 Magazine Construction

Magazines must be constricted according to strict regulations. All explosive storage must meet minimum requirements of location away from inhabited buildings, passenger railways, public highways and other magazines. Ground around the magazine must be sloped away for drainage and must be kept clear of brush, dried grass, leaves, and other materials for at least a distance of 25 feet. Magazines must also be secure and access limited to those with the appropriate licenses or permits.

Magazines in general should be weather resistant, fire resistant, ventilated, and bullet resistant. Specific construction requirements dependent upon the type of explosives will include wall thickness and protection specifications, foundation specification, ventilation specifications, roof specifications, requirement to countersink nails, door requirements and size requirements to eliminate piling explosives against walls.

2.1.2.4 Explosives and Blasting-Construction

Appendix A-1 provides Radio and Blast Site SOPs associated with construction blasting at the Rosemont Project site or other Project related areas. These procedures were developed for management of explosives and blasting operations to ensure that BMPs are applied. Procedures include the handling, storage, use, and communication information about hazardous materials, in accordance with the applicable laws and regulations identified in Section 2.1.1.

2.1.2.5 Explosives and Blasting-Production

Appendix A-2 provides an Explosives and Blasting Management Procedure associated with production blasting at the Rosemont Project site. This procedure was developed for management of


explosives and blasting operations to ensure that best management practices are applied. Procedures include the handling, storage, use, and communication information about hazardous materials, in accordance with the applicable laws and regulations identified in Section 2.1.1.

2.1.2.6 Blasting Materials Spill Prevention Procedures

Appendix A-3 provides an SOP for the proper handling of ammonium nitrate (prill) and emulsion in order to reduce product spillage. The concern for spilled or undetonated blasting agents is that ammonia and nitrates may leach into the groundwater from shot rock being stored in a waste rock pile. Studies have shown that by having a robust ammonium nitrate and emulsion management plan, the amount of ammonia and nitrates released to the environment can be significantly reduced.

2.1.3 Monitoring

Monitoring of blast material usage and items related to blasting for construction and production include inspections of equipment, completion of inventories of blast materials, and recording information regarding blast specifics.

During any activity that includes blasting, a pre-shift inspection is completed for all equipment (i.e. during loading and transporting blast ingredients to the blast holes for production blasting and during blast hole stemming) utilized in the blasting prior to operating the equipment.

The blasting contractor shall inspect their magazine(s) everyday they remove items or at least every seven (7) days to ensure no attempt to break into the magazine has occurred. Magazines will be located in a secure location that is separate from other blasting materials or activities. Additionally, an annual inventory is required by law to be taken and documented in the records.

The blasting contractor shall follow all of the regulations set forth by ATF. All inventories will be kept accurately and a copy of the inventory records will be in the magazine and available at all times for review by ATF, MSHA, Arizona State Mine Inspectors, and Responsible Rosemont Employees.

The operator shall record the appropriate blast hole information and load criteria into the Digital Blast Logger (DBL) or onto a loading sheet. Information on the blast setup will also be completed and will include:

Blast number;

Day and time of the blast;

Location of blast, including bench grade in blast area;

Hole pattern, including number; and

Amount of ANFO used per blast.

2.1.4 Records

In addition to the information above, records associated with blasting will include:

Equipment inspections;

Magazine inspections; and

Inventory of blast materials.

Blasting specific records necessary for reporting will be retained by the Rosemont Environmental Department. The blasting contractor will be responsible for collecting all records associated with blasting.


Reporting on Mitigation Measure FS-N-01 to the Forest Service will be done quarterly when production blasting is being performed and will include the following information:

Blasting times (date and hour); and

ANFO usage (tonnage) per blast.

2.2 PETROLEUM MATERIALS

Petroleum materials include diesel fuel, gasoline fuel, various oils, and lubricants used for the maintenance and operation of equipment onsite. At the Project site, petroleum and petroleum containing materials will be handled and stored according to the Spill Prevention Control and Countermeasures (SPCC) Plan (MPO Volume IV-p). Rosemont also has other SPCC plans for areas such as the Utility Corridor and equipment storage area.

Bulk quantities of gasoline, diesel fuel, lubricants, and miscellaneous types of oil for vehicle maintenance and operation will be stored in aboveground storage tanks (ASTs). Gasoline will be used to fuel small vehicles and construction equipment, and diesel fuel will be used to fuel haul trucks, other heavy equipment, portable generators, and light plants. Fuel will be dispensed to mobile equipment from a stationary filling station and remote equipment may be refueled using portable dispensing equipment. Bulk oil and lubricants will be stored in ASTs, totes, or drums located in the maintenance and truck shop areas.

2.2.1 Regulations

The following regulations apply to the use of petroleum materials at the mine site:

Regulatory Agency


Web Link

USEPA Spill Prevention, Control and Countermeasures

40 CFR Part 112

https://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR&searchPath=Title+40%2FChapter+I%2FSubchapter+D%2FPart+112&oldPath=Title+40%2FChapter+I%2FSubchapter+D&isCollapsed=true&selectedYearFrom=2016&ycord=1500


2.2.2.1 Petroleum Management and Storage

The Light Vehicle Fuel Station is located within the plant footprint between the grinding building and the coarse ore stockpile along the plant loop road. The facility consists of a 12,000 gallon diesel fuel tank, a 12,000 gallon gasoline fuel tank, a diesel exhaust fluid tank and associated pump and nozzles for filling light vehicle trucks. The entire facility is enclosed by a bund for spill containment.

The Bulk Diesel Fuel Station is located along the haul road at the eastern perimeter of the ultimate pit. The Bulk Diesel Fuel Facility provides exterior space for two fuel bays for the fueling of haul trucks and large mine vehicles. A center concrete containment pad between the two fuel bays includes 2 x 100,000 gallon diesel fuel storage tanks, 2 x 40-hp diesel fuel dispensing pumps, 2 x 10,000 gallon covered diesel exhaust fluid tanks. Space is allocated for a future diesel fuel storage tank. A concrete slab is provided adjacent to the containment pad for the fuel supply truck. Concrete filled steel bollards protect the fuel dispensing units and air compressor reels from vehicular traffic.

A mine truck wash and lube facility will be situated east of the mine truck shop. A tank farm for the various lubricants, antifreeze, used oil, and waste anti-freeze will be located north of the truck shop lube oil bay. Light vehicle repairs are currently expected to be through a contracted service in Tucson.


A 9,500-gallon diesel tank will also be located within the reagent storage area near the mill building. This tank will be situated within a curbed facility with containment equal to 110% of the largest tank in the containment.

2.2.2.2 Petroleum Handling

Diesel fuel, gasoline and various oil and lubricants will be handled daily at the Rosemont Project during bulk transfers to and from tankers and ASTs and during dispensing from ASTs to the various site vehicles and mine trucks. Diesel fuel would be received in tanker trucks with a capacity of approximately 6,000 gallons. While traffic patterns in the plant site may be adjusted as detailed designs are developed, the following description would generally apply: Delivery trucks routed to the Light Vehicle Refueling Area would travel on the west perimeter right hand drive road unloading on the west side of the ASTs. Delivery trucks routed to the Mine Diesel Fuel dispensing stations will continue on west perimeter road to the southeast corner of the Coarse Ore Stockpile turning southeast and switching to a left hand drive road at the mine infrastructure area, then continuing to the 1S haul road to the Mine Diesel Fuel dispensing stations unloading at one of the designated areas.

Due to the potential for discharges during tank truck loading and unloading operations, Rosemont has established minimum “active” containment measures, or procedures, for petroleum transfer operations. Petroleum transfer operations (tank truck loading and unloading procedures) are outlined below. The procedures were developed to safeguard against potential discharges associated with poor connections, overfilling, and premature departure.

1. Ensure that the tank truck is accurately spotted at the proper loading or unloading spot or spill containment apron if available.

2. Tank truck brakes will be set and the driver will remain with the vehicle during the entire transfer period. If flammable liquids are to be unloaded, the tank trailer engine will be shut off during transfer operations unless needed for pump operation.

3. Identify fire extinguisher(s) or fire suppressions devices. All plainly marked, maintained in fire-ready condition are strategically located and readily accessible. All fire extinguishers will be inspected monthly and certified annually in accordance with MSHA regulations.

4. Attach ground strap (plant) to bumper of tank truck or trailer.

5. The driver of the vehicle must securely chock the wheels of the vehicle to prevent unintended movement of the vehicle prior, during, or after loading or unloading operations.

6. The contractor driver and/or any Rosemont employee must closely inspect for discharges of all tanker truck lowermost drains and outlets for leakage prior to unloading or loading and departure, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit.

7. Caution signs will be placed in the vicinity of the tanker truck to give necessary warning to approaching personnel and must be left up until after tank truck is unloaded and disconnected from discharge connection. Signs will be at least 12 inches by 15 inches and bear the words: “Stop – Tank Truck Connected.”

8. Transfer operations shall only be performed by properly trained person who has been instructed for compliance with applicable regulations. At a minimum, the tanker driver shall be in view of the tanker, hose and tanks being filled during the entire transfer. The Rosemont Environmental Department is available via cell phone in the case of any spills or issues with the transfer.


9. No naked flame of any kind shall be permitted, for any purpose whatsoever, near the tank trailer or within the vapor area surrounding the tank truck. Smoking is strictly forbidden within this area. Only spark proof tools will be used. All cell phones must be turned off in the area.

10. Guard against excessive heat build-up of containers.

11. Make sure the facility storage tank is vented before connecting the loading or unloading line.

12. Tanker driver examines the sight gauge, “sticks” the receiving storage tank or uses another method to physically determine that sufficient space is available in the AST to receive contents of the tank truck.

13. Tank truck volume is to be compared with that on shipping papers on invoice to determine contents of trailer and avoid mixing of products.

14. When using bottom outlet valves for transfers, double check that outlet valve is closed and place spill container or bucket in position before slowly removing cap. If persistent leakage occurs when starting to remove cap, fully replace cap and do not proceed with the transfer until and unless the problem can be remedied.

15. After removing cap, visually inspect the outlet chamber to ensure that no blockage exists.

16. Attach loading or unloading line to the proper pipe connection on the facility tank or piping.

17. Open bottom outlet valve and proper valves in the unloading lines.

18. Start pump, checking to ensure there is no leakage at any of the connections. If there is leakage, immediately stop the pump.

19. After liquid transfer is complete, stop pump, close all valves, disconnect and remove unloading line or hose, replace cap to outlet, and make all other closures tight.

20. Remove ground strap, all portable signs and release tank truck.

21. Tanker driver takes paperwork to Rosemont personnel when the transfer process is complete.

NOTE: TANK TRUCKS SHALL NEVER BE LEFT UNATTENDED DURING UNLOADING.

TANK TRUCKS SHALL NOT BE ALLOWED TO STAND WITH THE HOSE CONNECTIONS ATTACHED AFTER UNLOADING IS COMPLETED.

Should there be an incidental spill at the fueling area, appropriate spill response materials are available in spill kits near the fueling areas.

In addition to bulk transfers, the following procedures shall be followed during dispensing of petroleum materials from the ASTs and mobile fuel supply vehicles to the vehicles or on-site equipment. The dispensing areas and/or mobile fuel supply vehicles will have absorbent spill cleanup materials and spill kits available, and nozzles for fueling and dispensing shall be equipped with an automatic shut-off to prevent overfill. The nozzles will also have locks to prevent vandals or unauthorized use. The following safe instructions will be posted in the fueling area with the contacts for spill notification and response including security and the Environmental Department. Mobile fueling will be minimized, and most vehicle and equipment will utilize the designated fueling area.

1. Locate the vehicle for fueling or addition of petroleum in the concrete paved dispensing area


if available.

2. Shut off the engine.

3. Ensure that the fuel or petroleum material is the proper type.

4. Unlock the nozzle and place nozzle into the fueling port of the vehicle. During dispensing, personnel shall always be in attendance and shall not “top off” the vehicle tank.

5. When the fueling is complete, remove the nozzle and re-secure in its storage place ensuring that no fuel drips onto the ground.

6. Check the fueling area for any drips, spills, or releases. If there are any spills, report the spill to security, supervisor, and the Environmental Department and ensure spill cleanup.

2.2.2.3 Petroleum Spill Prevention Procedures

Petroleum containing materials should be stored and handled in accordance with the SPCC Plan (MPO Volume IV-p). The SPCC Plan presents the spill prevention measures for the various petroleum materials during their use, handling, and storage.

Diesel fuel and gasoline ASTs located at truck and light vehicle fuel storage areas will be contained within a concrete containment structure that will contain 110% of the volume of the largest tank plus sufficient space for stormwater if the tank is uncovered. Loading and unloading will occur within a containment structure.

A lube bay would be located in the truck shop. The lube pad will contain embedded steel for track equipment and will drain to a wash water collection pit. An AST farm for the various lubrication oils and antifreeze, used oil and waste antifreeze will be located to the west of the lube oil bay. These ASTs will be located in a concrete containment structure that will contain 110% of the volume of the largest AST for spill control. Used oil and waste antifreeze will be collected and returned to the suppliers for recycling.

Grease associated with the hoisting, milling, and other operational equipment will be placed into drums or other bulk containers suitable for recycling. If the grease is not suitable for recycling, the contained waste will be sent off-site for disposal. While on-site, the waste grease containers will be managed in a secondary containment. Used oil from maintenance activities will be managed in bulk containers with secondary containment. Only oil acceptable for recycling would be placed in bulk containers. Waste oil not acceptable for recycling would be placed in drums and managed for proper disposal.

2.2.2.4 Petroleum Spill Response Procedures

Petroleum spills should be handled according to the SPCC Plan depending on the quantity and material. SPCC-trained employees using an appropriate absorbent will handle small, incidental releases, resulting from transfer and dispensing operations. Spill kits, absorbent materials, empty drums, and shovels are located throughout the facilities including at the bulk transfer and dispensing areas.

Small (less than 40 gallons) releases/spills from vehicles, equipment, generators, or containers onto the ground surface may, dependent upon spill location, be cleaned up by trained Rosemont employees and/or contractors directed by the Environmental Department Representative. Soils may be excavated and containerized into 55-gallon drums or other suitable containers. If necessary, representative soil samples will be collected and submitted to an Arizona-certified analytical laboratory for appropriate hydrocarbon analysis. Environmental Department employees will determine if notification is required for incidental releases.


Rosemont personnel or contractors will notify the Environmental Department via security regarding any release that poses an imminent danger, involves injured personnel, reaches a wash, creek, or stream, or is not contained by a secondary containment basin or diversionary structure, regardless of quantity. These spills are not considered an incidental release and must be reported to the Environmental Department.

Some spills, i.e. those that could impact an aquifer, create a visible sheen on surface water, or spills causing an imminent and substantial endangerment to human health and the environment, will be reported by the Rosemont Environmental Department as required.

The National Response Center (NRC) will be verbally notified following a discharge of oil of any quantity that meets any of the following conditions:

Violates an applicable water quality standard;

Causes a visible sheen or discoloration on the surface of waters or adjoining shorelines; or

Causes a sludge or emulsion to be deposited beneath the surface of waters or adjoining shorelines.

Notifications will be made as soon as possible to:

NRC: 1-800-424-8802

ADEQ reporting information is as follows:

ADEQ Emergency Response Duty Office: (602) 771-2330 or (800) 234-5677

Arizona Department of Environmental Quality (ADEQ) Emergency Response Unit 1110 W. Washington St. Phoenix, Arizona 85007 (602) 771-2330 or (800) 234-5677

ADEQ - Southern Regional Office: (520) 628-6733

400 West Congress, Suite 433 Tucson, Arizona 85701

When cleanup of the spill is conducted, the material will be placed into drums or other containers based on the volume to be generated. The drums and/or containers will be appropriately labeled and kept secured except when adding material. Rosemont will contract for waste recovery and removal. The Rosemont Environmental Department will coordinate waste disposal and will ensure that the proper paperwork from the disposal contractor is received, reported and maintained.

Petroleum spills are also addressed in the example of the Emergency Response and Contingency Plan (MPO Volume IV-j). A final plan is under development for the construction phase/ pre-mining period and will be updated for the operations phase. All actions listed above will be included and any requirements specified in the Emergency Response and Contingency Plan will supersede those listed above.

2.2.3 Monitoring

Monitoring of the petroleum materials during use, handling, and storage include inspections of the ASTs, containment and appurtenances. Inspections are conducted on a daily, monthly, or yearly basis. All ASTs will receive an initial inspection prior to being placed into service. This, one-time inspection, will be conducted by Rosemont personnel trained to identify and correct potential problems. A general check for common deficiencies will include visually inspecting tank condition,


checking wiring, electrical grounding, overfill-prevention devices, level sensing device, secondary containment structures, and anti-siphon devices, is sufficient.

Rosemont Environmental Department personnel and/or facility maintenance will conduct the various inspections. The following are the inspections, their frequency, and items to be checked:

Daily Inspections: Visual inspection by the area manager or other qualified person assigned by that manager of the petroleum ASTs for evidence of spills or leaks, any potential damage to the tank or secondary containment structures. Any problems identified during these inspections are documented on the Environmental Monitoring Checklist, which is provided to the Rosemont Environmental Manager for corrective actions including repair, cleanup, or replacement.

Monthly Inspections: Visual inspections of the ASTs by Rosemont Environmental Department personnel or other qualified person assigned by the Environmental Department Manager. The inspection will be documented on the Environmental Monitoring Checklist (or an electronic form of that checklist) contained in Appendix A of the SPCC Plan (MPO Volume IV-p) and reported to the Rosemont Environmental Department Manager. If need be, the Environmental Department Manager will arrange and coordinate for the corrective action to be completed as soon as possible. Pooled oil will be removed immediately upon discovery. Completed Monthly Inspection checklists will be kept electronically or in Appendix F of the SPCC Plan. The monthly inspections will address:

o The container’s exterior surface for leaks, corrosion, distortion, or other signs of potential failure.

o Exterior of portable and temporary storage containers (larger than 55-gallon capacity) for signs of deterioration or leaks.

o Secondary containment system for tears in the liner, evidence of leakage, and other signs of potential failure.

o Pipes, valves and other equipment for leaks, poor connections, and maintenance deficiencies.

o Safety interlocks, automatic shutoffs, level gauges, and level alarms.

o Spill response material and equipment; restock as needed.

o The general container area to ensure that the area is free of debris and flammable materials.

Annual inspections: Visual inspections of the ASTs, secondary containment, and appurtenances using the monthly check items and considering age of tank and progress of any deterioration. The inspection will be documented on the Environmental Monitoring Checklist (see example contained in Appendix A of the SPCC Plan (MPO Volume IV-p) and reported to the Rosemont Environmental Department Manager. If need be, the Rosemont Environmental Department Manager will arrange and coordinate for the corrective action to be completed as soon as possible

2.2.4 Records

Records generated as part of petroleum material handling, storage, and use will include:

Environmental Monitoring Checklists documenting the monthly and annual inspections.

Corrective action records that demonstrate the closure of any issues identified during inspections that require documented follow-up.


Maintenance records regarding the ASTs.

Training records documenting completion of training of personnel who do petroleum handling, inspections, or spill response.

Records for any spills that occur.

The aforementioned records will be kept in the Rosemont Environmental Department with the SPCC Plan (MPO Volume IV-p). Daily inspections shall be documented in a logbook or electronic log. Inspections are documented utilizing the Environmental Monitoring Checklist form (or its electronic equivalent, see example form in Appendix A of the SPCC Plan (MPO Volume IV-p) and filed electronically or in hardcopy in Appendix F of the SPCC Plan. Spills are documented using the spill reporting form (or its electronic equivalent) located in Appendix D of the SPCC Plan and filed electronically or in Appendix F of the SPCC Plan. The Environmental Manager is responsible for ensuring that records are properly filed and retained for at least three (3) years.

2.3 REFRIGERANTS/FREON

Equipment, including freestanding air conditioning units, will be serviced by certified technicians. Technicians will either be Rosemont personnel or authorized contractors. Equipment for buildings and vehicles may still require the use of R-22 refrigerants. In 1987, the Montreal Protocol, an international environmental agreement, established requirements that began the worldwide phase-out of ozone-depleting CFCs (chlorofluorocarbons). These requirements were later modified, leading to the phase-out in 1996 of CFC production in all developed nations. In 1992 the Montreal Protocol was amended to establish a schedule for the phase-out of HCFCs (hydrochlorofluorocarbons). HCFCs are less damaging to the ozone layer than CFCs, but contain ozone-destroying chlorine. The Montreal Protocol as amended is carried out in the U.S. through Title VI of the Clean Air Act, which is implemented by USEPA.

2.3.1 Regulations

The following regulations uniquely apply to the use, handling, and storage of restricted refrigerants at a mine or industrial site:

Regulatory Agency


Web Link

USEPA Clean Air Act regulations for CFCs

40 CFR Part 82 (2016)

https://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR&searchPath=Title+40%2FChapter+I%2FSubchapter+C%2FPart+82&oldPath=Title+40%2FChapter+I%2FSubchapter+C&isCollapsed=true&selectedYearFrom=2016&ycord=2040


2.3.2.1 Refrigerant Management

Refrigerants/freon is used in air conditioning systems for buildings and vehicles. R-22 is a restricted refrigerant containing hydrochlorofluorocarbons (HCFCs) whose use, handling, and storage are strictly regulated. The Clean Air Act regulations do not allow any refrigerant to be vented into the atmosphere during installation, service, or retirement of equipment. Therefore, R-22 must be recovered and recycled (for reuse in the same system), reclaimed (reprocessed to the same purity standard as new R-22), or destroyed. After 2020, the servicing of R-22-based systems will rely solely on recycled or reclaimed refrigerants. It is expected that reclamation and recycling will ensure that


existing supplies of R-22 will last longer and be available to service a greater number of systems. As noted above, chemical manufacturers will no longer be able to produce, and companies will no longer be able to import, R-22 for use in new A/C equipment after 2010, but they can continue production and import of R-22 until 2020 for use in servicing existing equipment.

Technicians must have USEPA Section 608 certification to service on-site refrigeration and air-conditioning equipment containing HCFCs. Rosemont anticipates having trained technicians and contractors performing repairs of refrigerant systems.

USEPA has established a technician certification program for persons ("technicians") who perform maintenance, service, repair, or disposal that could be reasonably expected to release refrigerants into the atmosphere. The definition of "technician" specifically includes and excludes certain activities as follows:

Attaching and detaching hoses and gauges to and from the appliance to measure pressure within the appliance;

Adding refrigerant to (for example "topping-off") or removing refrigerant from the appliance; and

Any other activity that violates the integrity of the motor vehicle air conditioning (MVAC)-like appliances, and small appliances.

In addition, apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician.

There are four types of technician certifications per the regulations:

For servicing small appliances (Type I).

For servicing or disposing of high- or very high-pressure appliances, except small appliances and MVACs (Type II).

For servicing or disposing of low-pressure appliances (Type III).

For servicing all types of equipment (Universal).

Technicians are required to pass a USEPA-approved test given by a USEPA-approved certifying organization to become certified under the mandatory program. Section 608 Technician Certification credentials do not expire.

The following are restrictions and best practices regarding refrigerant maintenance and repairs:

Technicians will locate and repair leaks instead of “topping-off” leaking systems.

It is illegal to intentionally release any refrigerant when servicing, repairing, or maintaining equipment.

Technicians must use refrigerant recovery equipment during service, maintenance, or repair. Rosemont technicians and contractors will only use USEPA-certified refrigerant recovery and recycling equipment.

In some cases, equipment will be recharged with recovered HCFC refrigerants. If the refrigerant is being charged back into the same piece of equipment or to another application, the used refrigerant does not need to be recycled or reclaimed.

Operators of refrigeration and air-conditioning equipment with refrigerant charges greater than 50 pounds are required to repair leaks within 30 days when those leaks result in the loss of more than a certain percentage of the equipment's refrigerant charge over a year.


For the industrial process refrigeration sectors, leaks must be repaired within 30 days when the equipment leaks at a rate that would release 35 percent or more of the charge over a year.

For all other sectors, including comfort cooling (such as building chillers), leaks must be repaired when the equipment leaks at a rate that would release 15 percent or more of the charge over a year.

Technicians are required to repair leaks within 30 days of discovery. This requirement is waived if, within 30 days of discovery, technicians develop a one-year retrofit or retirement plan for the leaking equipment.

The leak repair regulations do not apply to refrigeration and air-conditioning equipment with refrigerant charge sizes less than 50 pounds (such as residential split air-conditioning systems). However, smaller equipment is not exempt from the refrigerant venting prohibition. The intentional release of all refrigerants during the maintenance, service, repair, or disposal of air-conditioning and refrigeration equipment is prohibited.

2.3.2.2 Refrigerant Handling and Transfers

Existing units using R-22 can continue to be serviced with R-22. There is no USEPA requirement to change or convert R-22 units for use with a non-ozone-depleting substitute refrigerant. Such changes, called "retrofits," are allowed if the alternative has been found acceptable for that type of use. R-407C is allowed for retrofits but R-410A is not allowed in retrofits due to its higher working pressures. In addition, the new substitute refrigerants would not work well without making some changes to system components. As a result, service technicians who repair leaks to the system will most often continue to charge R-22 into the system as part of that repair.

The following is a general procedure for charging air conditioning systems and using a refrigerant transfer pump/gauge:

Determine the maximum capacity of gas for the unit. All systems have a decal installed at the factory that provides the data. If the decal is missing or you are not sure, please specify make, model, and the type of refrigerant used and whether your system is a factory or an after market

Connect both blue and red gauge hoses to the system's service ports. The discharge port (red hose) is located somewhere between the compressor and expansion device, either before the condenser or after it. In R-134a systems, the port is the thicker of the two. In R-12 systems, the port is the thinner one. In some aftermarket systems, the port is located in the back of the compressor.

Open both gauge valves. Connect the common hose (yellow one) to the vacuum pump. Make sure both gauge needles are zeroed. Adjust the needle by turning a fine screw inside the dial. The plastic lens must be removed to do this.

Turn the pump on. Both gauges should indicate drops from the needles. The blue gauge's needle will even dip into negative values. The desired low side reading should be less than -25, while the high side will remain at 0.

After approximately 5 minutes, close both gauge valves. Turn the pump off, and observe the needles. Any movement will indicate vacuum loss. The faster the movement, the greater the loss. If after two minutes and if there is no needle movement, open both valves, turn the pump on, and continue to vacuum for not less than 30 minutes. Close both valves and turn the pump off.

Prepare to add a charge and have the necessary refrigerant amount available.


Disconnect the yellow hose from the vacuum pump and connect it to the can tap or charging cylinder valve.

Add liquid refrigerant to the system (can upside down) by opening the red valve (high side) until it won't take anymore. Close the red valve. Jump the low pressure cycling switch (if so equipped).

Turn the engine on. Turn the A/C into MAX on its third or higher blower speed. You'll note that both gauge readings are now positive. The red gauge should read between 100 and 150 psi, while the blue gauge between 5 and 15 psi.

Once about 2/3 of the charge has been dispensed into the system, spray water in the condenser to optimize heat exchange and speed the process. When you get the condenser wet, the vent temperature is likely to rise. Note the pressure drop in both gauges.

Once the specified amount has been dispensed, close the blue valve. Let the system run for a minute. Turn the A/C off and then the engine. Wait another minute and disconnect the couplers from the service ports. Disconnect the low side first.

2.3.2.3 Refrigerant Leak Prevention and Response Procedures

As a best practice, the technician will locate and repair leaks instead of “topping-off” leaking systems. It is illegal to intentionally release any refrigerant when servicing, repairing, or maintaining equipment. Technicians must use refrigerant recovery equipment during service, maintenance, or repair. Rosemont will only use USEPA-certified refrigerant recovery and recycling equipment.

The following are best practices for conserving refrigerant during servicing:

Recover refrigerant.

Keep the system tight.

Find and repair leaks.

For larger systems, collect an oil sample to check for contaminants when the unit has a leak or major component failure.

Clean up the system after a burnout.

Always use a deep vacuum of at least 500 microns and use a triple evacuation method

Never flush the system with liquid refrigerant to clean field tubing. Instead, use a commercial, environmentally safe, non-aqueous (no water) flushing solution that is non-toxic and can remove oils, contaminants, acid, and water. Clean out the tubing using nitrogen gas with a pressure regulator before and after using the flushing solution. Properly dispose of any flushing solution.

When using dry nitrogen from a portable cylinder to pressurize, service, or install a refrigeration system, only use nitrogen vapor, and always use a pressure regulator with a relief valve inserted in the downstream line from the pressure regulator. Using pressurized nitrogen from a nitrogen cylinder without a pressure regulator is very dangerous because the pressure inside these cylinders is well over 2,000 psig. Putting this pressure inside a refrigeration system would cause the system to explode.

Always change the filter drier anytime the refrigeration circuit is opened for repair.

When acid is detected in an operating system, always change the filter drier and use acid treatment to flush the acid into the new fresh filter drier.


On burnouts, always flush the system; replace the compressor, oil, and refrigerant; and use both a new suction line and liquid line filter drier.

2.3.3 Monitoring

Technicians servicing equipment that contain 50 or more pounds of refrigerant must provide records that indicate the amount of refrigerant added to the equipment. Technicians must also keep a copy of their proof of certification on-site. Refrigeration technicians who violate the Clean Air Act may lose their USEPA certification, be fined, or be required to appear in federal court. Some of these violations include falsifying or failing to keep required records, failing to reach required evacuation levels before opening or disposing appliances, and knowingly releasing refrigerants while repairing appliances.

2.3.4 Records

Records generated during refrigerant maintenance include refrigerant transfer records and the technician certificate records. Refrigerant transfer records associated with the use of refrigerants will include the date, technician name, equipment type, start and end pounds of refrigerant used, and any issues or repairs. Copies of these records will be retained in the on-site Environmental Department office.

2.4 LABORATORY

It is anticipated that a Metallurgical laboratory will be onsite to process rock samples. Sample crushers, pulverisers, and sample splitters would be in the sample preparation area with a dust collection system to capture and contain any dust generated. The process reagents will be used in laboratory quantities and managed specifically to ensure that there is no outside contact with personnel or the environment. Depending upon the material, reagents may be reused in the process or properly disposed per the regulatory requirements as per the Resource Conservation and Recovery Act. These requirements may include disposal as a hazardous waste or as a solid waste.

2.4.1 Regulations

The following regulations apply to the handling, use, and storage of laboratory chemicals at the site:

Regulatory Agency


Web Link

USEPA Clean Air Act-Air Quality and Emission Controls

Title 1 Part A http://www2.epa.gov/clean-air-act-overview/clean-air-act-text

OSHA Laboratory Standard 29 CFR 1910.1450

https://www.osha.gov/pls/oshaweb/

USEPA Resource Conservation and Recovery Act

40 CFR Parts 260 - 270

http://nepis.epa.gov/Exe/ZyPDF.cgi/P1005SN6.PDF?Dockey=P1005SN6.PDF and http://nepis.epa.gov/Exe/ZyPDF.cgi/100049DH.PDF?Dockey=100049DH.PDF


2.4.2.1 Laboratory Chemical Management

In order to effectively manage chemicals, laboratory personnel will establish a program based on the following three principals:


Minimize Exposures. Laboratory personnel will take the necessary precautions when receiving, handling, and storing chemicals. As a means of minimizing the potential for exposure, Rosemont will pursue opportunities for product substitution.

Assess and plan for risks. Rosemont will ensure that the risk associated with each chemical is assessed, understood and communicated. Chemicals used in the lab will be assumed to be hazardous and handled accordingly.

Use proper control measures. Rosemont will eliminate hazards in the laboratory through engineering controls, personal protective equipment, and administrative procedures. Laboratory personnel will be properly trained in accordance with regulatory requirements (e.g., OSHA Laboratory Standard or MSHA requirements).

2.4.2.2 Laboratory Chemical Handling and Storage

Laboratory personnel will be trained to recognize the hazards that may be associated with chemicals coming into the facility. Shelves, tables, or caged areas will be designated for packages to avoid damage by receiving personnel. Transportation of chemicals within the laboratory facility will be done safely using a cart or other device to carry larger, heavier shipments or multiple small packages. The cart should have methods to secure the packages/chemicals. When opened, laboratory personnel should verify that the container is intact and labeled. Dates of expiration on the new chemical containers should be checked to ensure that the chemicals are within their shelf life.

Chemicals will be properly labeled, secured and stored in the building. Laboratory personnel will keep accurate and regular inventory and tracking of the chemicals used and stored. Chemical inventories are not only a vital management tool but also required for maintaining regulatory compliance.

Chemical storage inside the lab should be limited to those chemicals and quantities necessary to complete task requirements. Key considerations for lab storage and handling include:

Chemicals should not be stored on floors or benches. Storage on open shelves should be avoided. When necessary, lips or restraining devices will be used. Chemicals will not be stored in the lab above eye level;

Chemicals should primarily be segregated according to chemical classes and compatibility. Then they can be stored by a convenient finding method such as alphabetically. For example, acids should be kept separate from bases, oxidizers from organics, and cyanides from acids. Physical separation should be provided for reactive chemicals. Use secondary containers in storage areas if available space does not allow incompatible materials to be properly separated;

When possible, toxic chemicals should be segregated from other chemicals and stored in closed cabinets. Label the cabinets "TOXIC CHEMICALS" or with a similar warning;

Chemicals will be maintained per manufacturer requirements;

Containers will be labeled in accordance with the OSHA Laboratory Standard. Transfer containers will also be labeled;

Containers will be closed when not in use; and

As a general principle, secondary containment such as acid carriers will be used when transporting liquid chemicals more than a very short distance.

Proper personal protective equipment should be worn at all times. This includes, but is not limited to, the following: protective eyewear or splash guards, chemical resistant gloves, laboratory coat, and closed toe shoes.


Ventilation is an integral part of controlling and removing particulates, vapors, gases, and other airborne chemicals from the laboratory and exhausting them through control measures to the atmosphere. The types of ventilation devices used in laboratory may include fume hoods, biological safety cabinets, glove boxes, extraction hoods, benchtop slot hoods, and flexible ducting. Any ventilation device used must meet the design requirements set forth in USEPA, OSHA, American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE), and National Fire Protection Association (NFPA) regulations.

Air emissions are a potential occupational health issue. In 1991, OSHA recognized the unique nature of laboratories and established a separate lab standard (29 CFR 1910.1450) that requires a chemical hygiene plan that includes an assessment of potential personnel exposure to hazardous chemicals. Rosemont will prepare a chemical hygiene plan for their laboratory operation.

All lab fume hoods must meet the ASHRAE 110 standards for testing the performance of lab fume hoods. Ventilation is measured in air changes per hour (ACH). OSHA recommends lab ventilation systems have a ventilation rate of 4-12 ACH, NFPA 45 recommends greater than 8 ACH, and ASHRAE recommends a rate of 6-10 ACH. The lab should ensure its ventilation rate meets the highest minimum recommendation as well as local code requirements. Ventilation devices must be used properly to be effective. Before any Rosemont laboratory personnel uses a ventilation system, they will receive training in operating procedures and daily inspection procedures. To reduce the user's exposure to airborne hazards, good lab practices include:

Keep all containers at least six inches from the front of the hood;

Keep the hood sash closed to the minimum closure height as much as possible;

Do not obstruct the baffles in the rear of the hood;

Keep all containers tightly closed when not in use, and

Do not store unused chemicals in the fume hood.

2.4.2.3 Laboratory Chemical Spill Prevention and Response Procedures

Spills of laboratory chemicals create small quantities of chemical wastes or hazardous waste in some cases. These wastes can be disposed of under Arizona law in several ways including:

Elementary neutralization;

Recycling;

Treatment in accumulation containers; and

Small boilers or furnaces.

Since the site will collect sewage within a septic system, small quantities of waste should be neutralized or treated prior to disposal. No chemicals will be allowed to enter the septic system through any drains or sinks.

Any waste stream that presents more than one type of hazard requires special management consideration because the selected treatment technology appropriate for one type of waste may not be appropriate for the other types. Multi-hazardous wastes must be evaluated on an individual basis and the constituent that poses the greatest hazard should be given priority.

2.4.3 Monitoring

Laboratory personnel will perform daily inspections and monitor to ensure all ventilation devices are working properly to remove contaminants from inside the lab and exhaust them through controls to


the exterior of the building. The laboratory personnel will also perform regular inventories of laboratory chemicals to ensure that their condition and usage is tracked. Both the inventories and inspections will be documented.

2.4.4 Records

Records to document key environmental activities in the laboratory will include daily inspection and inventory records. The daily inspection records will include ventilation inspections, chemical storage inspections for any leaks, out-dated materials, or labeling issues and general good housekeeping. The inspection and inventory records will be retained in the metallurgical laboratory offices.

2.5 CLEANING FLUIDS

Cleaning fluids will be used for cleaning and housekeeping the buildings and equipment at the Rosemont Project. Manufacturers’ directions will be followed to ensure that potentially hazardous cleaning fluids are disposed properly.

2.5.1 Regulations

The following regulations apply to the use, handling and storage of cleaning fluids at the site.

Regulatory Agency


Web Link

OSHA Sanitation 1910.141

https://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR&searchPath=Title+29&oldPath=Title+29&isCollapsed=true&selectedYearFrom=2016&ycord=800


2.5.2.1 Cleaning Fluids Management

Cleaning fluids will be stored properly in janitorial areas or in cabinets away from food storage in break areas. Containers will be clearly labeled and kept upright. Unlabeled containers are a safety hazard and are subject to potential fines. Aerosols will not be stored with other cleaning chemicals.

2.5.2.2 Cleaning Fluids Handling

Cleaning fluids should never be disposed down drains, all drains report to on-site septic systems. Cleaning fluids should be used for their intended purpose and completely spent rather than having to dispose of the remaining material.

Janitorial cleaning products can degrade indoor air quality, pollute the water, and negatively impact the health of sensitive occupants. In order to reduce these negative impacts and ensure clean facilities, Rosemont would utilize the following best practices:

Rosemont would seek to substitute less toxic cleaning fluids where available.

Cleaning fluids would be stored in secured areas accessible to the janitorial personnel.

Contractor janitorial staff would be required to follow all manufacturer use instructions for use of cleaning fluids.

Containers of cleaning chemicals would be properly labeled including any transfer containers.


All cleaning fluid containers would be properly and safely stored with no liquids stored above eye level.

When cleaning, cleaning fluids would be applied onto a rag instead of directly onto the surface to be cleaned to prevent the inhalation of chemicals.

2.5.2.3 Cleaning Fluids Spill Prevention and Response Procedures

Only the necessary volume of cleaning chemicals would be on hand at the Rosemont Project. The cleaning chemical containers stored will be small in volume. Most cleaning fluid spills can be cleaned using rags, sorbents, or a mop.

2.5.3 Monitoring and Records

The janitorial contractor will maintain inventories of the cleaning chemicals to ensure that any outdated leaking or uncapped bottles are identified and addressed. The inventory will be retained at the point of storage of the cleaning fluids.

2.6 COMPRESSED GASES

Compressed gases, including welding, propane, and calibration gases will be used at the Rosemont Project. Compressed gases will be delivered, stored and used on-site in heavy-walled metal cylinders designed, produced, and tested for use with compressed gases. Rosemont maintenance personnel may use welding gases in the Mine Truck shop and Light Truck shop or in the Concentrator Operations areas. Propane may be used for fuel around the facility buildings and for fueling some forklift and other equipment. Rosemont laboratory personnel will be using calibration gases in the on-site laboratory to ensure proper calibration of laboratory instruments.

2.6.1 Regulations

The following regulations apply to the handling, use, and storage of compressed gases.

Regulatory Agency


Web Link

OSHA Compressed Gases

1910. 101, 1926.350

https://www.osha.gov/pls/oshaweb/

National Fire Code Compressed Gases

NFPA 55 http://www.nfpa.org/codes-and-standards


2.6.2.1 Compressed Gases Management

Compressed gas suppliers will deliver compressed gases to the Rosemont Project and specific areas on-site via metal, high-pressure cylinders on an as-needed basis. The risks for compressed gas use, handling, and storage that require proper procedures include receiving the cylinders from the supplier, handling, and securing the cylinders to use and storage. Rosemont will ensure suppliers with trained professionals transport and deliver the cylinders. When a cylinder is delivered to the receiving department, the cylinder should have:

Content identification by stenciling or labels;

A US Department of Transportation (USDOT) label;

Last cylinder test date; and


A valve protection cap.

Under no circumstances should the means of identification be removed from the cylinder. The valve protection cap should also remain in place until the user has secured the cylinder and is ready to withdraw the contents. USDOT labels are required for cylinders in interstate transportation. These labels have a minimum of precautionary handling information and will classify the cylinder contents as flammable, non-flammable, poison, or corrosive.

Proper identification of cylinder contents can be made by checking the cylinder’s shoulder label. Stencilling and/or cylinder color should never be used for positive identification. If any doubt exists as to cylinder content, do not accept the cylinder and contact the supplier.

2.6.2.2 Compressed Gases Handling and Storage

Compressed gas cylinders for transportation must meet Compressed Standards Association (CSA) standard CAN/CSA-B339 "Cylinders, Spheres and Tubes for the Transportation of Dangerous Goods" (CSA, 2014). This standard covers requirements for the manufacturing, inspection, testing, marking, re-qualification, re-heat treatment, repair, and rebuilding of cylinders, spheres, and tubes (containers) for the transportation of dangerous goods. In addition, the CSA standard includes the requirements for the qualification of new designs and registration requirements.

Rosemont receiving personnel will inspect incoming cylinders before storing to ensure they are undamaged and properly labelled. Defective cylinders or cylinders giving off odors, visible fumes, or leaking will not be accepted. The cylinder test date should be checked to ensure that it was tested within the required time (usually 5 or 10 years, but some containers may be as low as 3 years or as long as 12 years).

Cylinder labels must be intact and match other identifying markings on the cylinder. The cylinder color should not be used to identify the gas. Different suppliers may use different colors for cylinders of the same gas. Compressed gases will be identified by the name on the supplier label. Rosemont personnel will inspect the cylinder valve by looking through the ports in the valve cap. Cylinder with dirty, rusted or otherwise damaged valves and fixtures will not be accepted.

After receipt at the site, compressed gas cylinders shall be secured to prevent falling due to contact, vibration or seismic activity. Per 29 CFR 1910.101(b), the handling, storage and utilization of all compressed gas cylinders must be in accordance with Compressed Gas Association (CGA) Pamphlet P-1 Safe Handling of Compressed Gas Cylinders. When storing compressed gas cylinders of different types, they should be grouped by type of gas. This ensures that the cylinders are segregated per their content – for example, flammable gases should not be stored near oxidizing gases.

The following safe work practices would ensure that cylinders are properly handled to prevent damage and release of their contents:

Gas cylinders should be properly secured at all times to prevent tipping, falling or rolling. They can be secured with straps or chains connected to a wall bracket or other fixed surface, or by use of a cylinder stand.

The gas cylinders should be stored in a cool, dry, well-ventilated, fire-resistant area.

When a gas cylinder is empty or not being used, ensure that the valve is closed, the regulator removed and that the valve protector cap is secured in place.

Gas cylinders should be transported using hand trucks designed for that purpose and the cylinders should be secured so that they do not tip, fall or roll.


Appropriate lifting devices, such as cradles or nets must be used when using a crane, hoist or derrick to transport gas cylinders. Do not use magnets or slings to lift gas cylinders. Do not use the valve protection cap for lifting a gas cylinder.

Precautions must be completed to ensure that compressed gas cylinders are not dropped or allowed to strike each other or other objects. Dropping or striking may damage the gas cylinder valve, which could cause an explosion with the potential to destroy property and/or injure personnel.

The smallest practical cylinder size should be used for a particular job. Do not keep cylinders longer than the supplier recommends. Compressed gas cylinders are mainly shipping containers. They are built to be as light as possible while remaining safe and durable. Do not drop cylinders or otherwise allow them to strike each other. Rough handling, including using cylinders as hammers or as rollers to move equipment, can seriously damage them.

Never tamper with cylinders in any way. Do not repaint them, change markings or identification, or interfere with valve threads or safety devices.

Do not refill cylinders or change their contents as it is illegal and dangerous for non-specialists.

Empty cylinder valves must be closed to prevent atmospheric air from entering with moisture and contaminants that may degrade the interior of the cylinder.

Detailed information regarding the information on the chemical’s container in the cylinder are available in the appropriate safety data sheets (SDS). Specific chemical handling and storage precautions will be outlined in the SDS. The SDS will also have specifications for appropriate personal protective equipment for worker protection.

2.6.3 Monitoring

Users of compressed gas cylinders at the Rosemont Project will complete daily inspections of the cylinders and storage area prior to use. The visual inspections will include ensuring that required markings/ labels have not been altered or removed, valve protection caps are in place when not in use, exterior of the cylinders are not badly corroded, dented, bulging, gouged or otherwise damaged. Visual inspections will be recorded on an inspection form. If the cylinders are damaged, the flaws should be measured with a variety of devices and compared to defined limits. The other parts of the cylinder and compressed gas system including the regulators, pressure relief valves and cylinder connections will be inspected by personnel experienced with compressed gas systems. Cylinders that have questionable conditions or damage should be returned to the compressed gas supplier. Leaking regulators, cylinder valves, or other equipment should be taken out of service.

2.6.4 Records

Daily visual inspection records will be retained in the respective work areas where compressed gases are used and stored including the office of the Mine Truck Shop, Light Vehicle Shop, Concentrator Maintenance Office, and Laboratory.


3.0 WASTE MANAGEMENT This section identifies the specific wastes that will be generated at the Rosemont Project. This Plan includes wastes where applicable regulations or protocols are being established to ensure proper handling and recycling, reuse or disposal. In order to ensure that compliance requirements for all wastes are addressed, the wastes discussed include those that were predicted to have a negligible impact. The applicable regulations, management and handling procedures, monitoring and records are presented for each waste. The regulation sub-section includes the applicable federal, state, county and other requirements. The management and accumulation procedures subsections present the procedures for generation, accumulation, handling, general management, spill prevention and response (if applicable due to quantity and risk to soil, surface water and groundwater), and storage. The monitoring subsection documents the inspections and tracking completed during the generation, accumulation, handling, management, spill prevention and response, and storage. The records subsection identifies the records that are generated from each of the monitoring activities from each waste.

3.1 HAZARDOUS WASTE

Hazardous waste is a material that meets the definition of solid waste, is not specifically excluded, and presents a potential hazard to human health and the environment. The statutory definition for hazardous waste is: a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. Although the Bevill Amendment exempts much of the waste generated at mining facilities, hazardous waste generator activities that are “not unique” to the mining industry are subject to RCRA Subtitle C.

Hazardous wastes that may be generated at the facility include, but may not be limited to, the following:

Waste paint related materials such as thinners;

Chemical wastes from the on-site metallurgical laboratory such as acetone; and

Residue wastes from containers or cans.

3.1.1 Regulations

The Resource Conservation and Recovery Act (RCRA) gives USEPA the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. The RCRA regulation establishes basic hazardous waste management standards for persons who produce hazardous waste, called hazardous waste generators. These standards are found in title 40 of the Code of Federal Regulations (CFR) in part 262 and at 40 CFR §261.5. The generator regulations ensure that hazardous waste is appropriately identified and handled safely to protect human health and the environment, while minimizing interference with daily business operations.

The Arizona Department of Environmental Quality (ADEQ) and Pima County Department of Environmental Quality (PCDEQ), through delegated authority from the USEPA, regulate solid waste in Arizona and Pima County respectively. Both Arizona and Pima County have adopted by reference the federal rules for hazardous waste generators, with several additions that make the state's rules more stringent. The more stringent rules for small quantity generators (SQGs) and large quantity generators (LQGs) apply to manifests, registration, fees, annual reports, on-site storage, and special facility protections for facilities that accumulate ignitable, reactive, or incompatible waste. Conditionally exempt small quantity generators (CESQGs) must comply with less stringent reporting and waste disposal rules.


The regulations that apply to hazardous wastes generated at the Rosemont Project include:

Regulatory Agency


Web Link

USEPA RCRA

Subtitle C of RCRA (40 CFR Parts 239-299)

https://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR&searchPath=Title+40%2FChapter+I%2FSubchapter+I&oldPath=Title+40%2FChapter+I&isCollapsed=true&selectedYearFrom=2016&ycord=1500

ADEQ Hazardous Waste Disposal

ARS Title 49, Chapter 5. ARS 49-921 AAC R18-8-260 ARS 49-922

http://www.azleg.gov/arsDetail/?title=49

U.S. Department of Transportation (USDOT)

Hazardous Material Security Program

CFR Title 49, Subtitle B, Chapter 1, Subchapter C, Parts 171-177

https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title49/49cfrv2_02.tpl

Pima County Department of Environmental Quality (PCDEQ)

Hazardous Waste Management

Title 7 Chapter 7.09 and Title 13

http://webcms.pima.gov/cms/one.aspx?portalId=169&pageId=66301

3.1.2 Hazardous Waste Management

The amount of hazardous waste currently generated (less than 100 kilograms per month) at the Rosemont Project makes the site a conditionally exempt, small quantity generator (CESQG) under federal, state and county regulations. The general regulatory requirements that Rosemont must complete at the Rosemont Project include:

Identify all the hazardous waste generated and keep documentation of the waste determinations;

Hazardous waste types that will be generated include:

o Paints and thinners used for building maintenance and at truck shops;

o Chemical wastes generated at the laboratory; and

o Residue wastes from used products such as oil and gas containers.

Do not accumulate more than 1,000 kilograms of hazardous waste at any time.

Ensure that the generated hazardous wastes are delivered to a person or facility authorized to manage it.

It is possible to be an LQG for a short period and then switch status to a CQG or CESQG dependent upon the activities at a site. It is expected that for the operational life of the Project, Rosemont will have CESQG status and possibly for short periods during construction will that status change. Rosemont will meet the requirements set forth by the regulations that apply to the appropriate generator status.

As part of the pollution prevention and reduction of environmental impacts, Rosemont has committed to review the materials that used to consider whether the product residues or wastes would be


hazardous and consider effective non-hazardous substitutes. Rosemont will examine operations on an on-going basis to ensure that hazardous substances are eliminated whenever possible. Rosemont will also employ other strategies to reduce the amount of hazardous waste generation. Hazardous materials will be purchased close to the quantities that needed. The materials include, but are not limited to, the following:

Solvents for maintenance activities – high flash point solvents that do not contain chlorination are available both in aerosol and liquid forms;

Paints – latex paints that can be cleaned up with soap and water rather than enamel paints that require paint thinners will be used when possible;

Aerosol cans – when near empty, aerosol cans will be punctured and recycled as scrap metal. Equivalent non-aerosol products will also be considered.

Acetone – lab techniques will be considered that can recycle acetone on-site to determine if there is a safe and effective alternative to purchasing new and continuing disposal;

Bulk deliveries of chemicals will be considered compared to multiple individual containers whenever possible to avoid multiple containers with residues for handling and disposal;

Minimize purchases to the smallest amounts of chemicals needed for testing or use will be purchased to limit the possibility of chemical disposal; and

Use of only approved chemicals (generated in a list) within the Rosemont Project and restrictions on unapproved chemicals brought on-site by Rosemont personnel and contractors.

Potential hazardous waste that may be generated include waste paint materials and thinners, chemical wastes such as acetone from the metallurgical laboratory, and residual wastes from containers. In managing hazardous wastes, Rosemont will establish a separate collection, packaging, and storage system, so that all wastes are property segregated, identified and labeled to facilitate disposal through a commercial contractor. The hazardous waste will be segregated and stored in containers compatible with the waste. In order to reduce potential human health and environmental risks, hazardous waste will be managed and contained within facilities that are designed, constructed, and maintained per applicable regulations. These facilities will include a secure area, stormwater management controls or indoor storage, secondary containment, and recovery systems as required. Contractors that generate hazardous waste will follow Rosemont requirements and all applicable federal, state, and local regulations.

This section presents the following related to hazardous waste management:

Waste Profiles;

Accumulation and storage;

Pre-Transport;

Land Disposal Restrictions;

Emergency Preparedness and Prevention;

Contingency Plan and Emergency Procedures;

Monitoring; and

Records.


3.1.2.1 Waste Profiles

Waste profiles demonstrate the characterization of each waste generated on-site. Profiling means to determine whether it is hazardous waste or non-hazardous waste. Profiling can be completed using the Safety Data Sheet (SDS) for the waste product (if not potentially contaminated by other materials) or by using laboratory analysis of the waste. The waste profile must be provided to disposal facilities in order to demonstrate the characteristics and constituents of the waste to ensure it meets the Land Disposal Restrictions (LDRs). Rosemont would provide waste profiles for each waste generated from the Rosemont Project.

3.1.2.2 Hazardous Waste Accumulation and Storage Procedures

Proper management of hazardous materials and wastes should allow Rosemont to continue to have a CESQG of hazardous waste status. However, in the event that it becomes necessary to manage quantities of waste in excess of the CESQG threshold, Rosemont will remain in compliance by following several regulations attributed to a small quantity generator (SQG). As part of permitting, Rosemont filed for and was issued a hazardous waste identification number from the USEPA and has registered as a generator of hazardous waste with ADEQ. Once in construction, Rosemont will complete a similar registration with PCDEQ.

Rosemont will establish a separate collection, packaging, and storage system to ensure that all wastes are property segregated, identified and labeled to facilitate disposal using a commercial contractor.

Rosemont may accumulate hazardous waste on-site for 180 days or less without a permit or without having interim status. Hazardous waste accumulation and storage must be in compliance with the following requirements:

Container Labels: The date upon which each period of accumulation begins will be clearly marked and visible for inspection on each container. While being accumulated on-site, each container will be labeled or marked clearly with the words, “Hazardous Waste”.

Condition of Containers: If a container holding hazardous waste is not in good condition, or if it begins to leak, Rosemont will transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the storage requirements.

Compatibility of Waste with Container: Rosemont will use containers that are compatible with the hazardous waste contents.

Containers Holding Hazardous Waste:

o Will be closed at all times, except when adding waste.

o Will not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

Ignitable or Reactive Waste: Containers holding ignitable or reactive waste will be located at least 15 meters (50 feet) from the facility's property line.

Incompatible Wastes:

o Incompatible wastes and materials will not be placed in the same container.

o Hazardous waste will not be placed in an unwashed container that previously held an incompatible waste or material.


o A storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments will be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.

Accumulation and Storage Areas: Adequate aisle space in hazardous waste accumulation and storage facilities will be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency. The area must be curbed and covered.

Inspections: Rosemont will perform weekly inspections on areas where containers are stored. Rosemont will inspect all containers to check for any leaks, deterioration, or damage caused by corrosion or other factors.

3.1.2.3 Hazardous Waste Pre-Transport

The operation at the Rosemont Project that generates the hazardous waste is responsible for preparation of the containers and documentation for disposal and must comply with USDOT regulations for transport of hazardous materials. When off-site disposal is necessary, Rosemont will manage materials as required by RCRA and USDOT regulations. All shipments will be properly marked and manifested (using manifests or bills of lading as necessary), and characterizations of waste materials shipped will be included. Hazardous waste will be disposed through a licensed transporter and sent to a licensed disposal facility. Rosemont will prepare a manifest (OMB Control number 2050-0039) on USEPA Form 8700-22, and, if necessary, USEPA Form 8700-22A, and retain one copy, in accordance with 40 CFR Part 262.40(a). The hazardous waste manifest will accompany any materials, and the generator manifest copy will be retained in the Rosemont Environmental Department. Only those personnel who are trained in accordance with 49 CFR 172, Subpart C-Shipping Papers and 49 CFR 172.204 and 172.205, and who are formally designated and authorized by Rosemont, are authorized to execute hazardous waste manifests and related documents. Per regulatory requirements, Rosemont will formally designate and authorize personnel in writing and specify that the employee’s duties include executing the waste manifest and associated documents.

Chemical hazardous waste from the laboratory will be packaged in lab packs. In order for a package to be “lab packed”, the following would be completed:

1. Each hazardous waste must be categorized based on hazardous characteristics (corrosive, flammable, etc.).

2. Similar hazardous categories would be packed together with compatible absorbent.

3. The containers would be properly labeled and prepared for shipment and disposal.

4. Paperwork (manifests, shipping inventories, etc.) must be prepared and provided for shipment of the hazardous waste containers.

3.1.2.4 Land Disposal Restrictions

The Land Disposal Restrictions (LDR) program defined in 40 CFR Part 268 requires waste handlers to treat hazardous waste or meet specified levels for hazardous constituents before disposing the waste on the land (USEPA 2005). To ensure proper treatment, USEPA established a treatment standard for each type of hazardous waste. The USEPA lists these treatment standards in 40 CFR Part 268, Subpart D. The USEPA expresses treatment standards either as required treatment technologies that must be applied to the waste or contaminant concentration levels that must be met. USEPA bases treatment standards on the performance of the best demonstrated available technology that is able to substantially diminish the toxicity of a waste or to reduce the mobility of the hazardous constituents in a hazardous waste. Wastes that do not meet treatment standards cannot be land disposed unless USEPA has granted a variance, extension, exclusion, or the waste is


managed pursuant to an approved "no migration" petition. In addition to the disposal prohibition, there are prohibitions and limits in the LDR program regarding the dilution and storage of wastes. The program also requires tracking and recordkeeping to ensure proper management and safe land disposal of hazardous wastes.

Rosemont will meet the standards for placing wastes on the land and associated requirements for certifications, notifications, and waste analysis plans by meeting the requirements in Contingency Plan and Emergency Procedures, with all applicable requirements under 40 CFR Part 268 (Land Disposal Restrictions). In most cases, Rosemont will use the most final disposal method available for waste, i.e., incineration, rather than land disposal.

3.1.2.5 Hazardous Waste Emergency Preparedness and Prevention

The RCRA regulations include emergency preparedness and prevention requirements for procedures to be followed in the event of an emergency. Even though Rosemont is anticipated to be a CESQG, Rosemont will follow the requirements for SQG regarding preparedness and prevention and contingency plan and emergency procedures.

Rosemont will maintain and operate the hazardous waste accumulation and storage facilities to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.

The hazardous waste accumulation and storage facilities would be equipped with the following, unless none of the hazards posed by waste handled at the facility could require a particular kind of equipment specified below (USEPA, 2001):

An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to facility personnel;

A device, such as a telephone (immediately available at the scene of operations) or a hand-held two-way radio capable of summoning emergency assistance from local police departments, fire departments, or State or local emergency response teams;

Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control equipment, and decontamination equipment; and

Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems.

All facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, will be tested and maintained as necessary to assure its proper operation in case of an emergency.

Whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee.

If there is ever just one employee on the premises while the facility is operating, he or she will have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance.

Rosemont will maintain aisle space in hazardous waste accumulation and storage facilities to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency.


Rosemont will make the following arrangements with local authorities, as appropriate for the type of waste handled at Rosemont’s facility and the potential need for the services of these organizations:

Arrangements to familiarize police, fire departments, and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility, and possible evacuation routes;

Where more than one police and fire department might respond to an emergency, agreements designating primary emergency authority to a specific police and a specific fire department, and agreements with any others to provide support to the primary emergency authority;

Agreements with State emergency response teams, emergency response contractors, and equipment suppliers;

Arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility; and

Where State or local authorities decline to enter into such arrangements, Rosemont will document the refusal in the operating record.

3.1.2.6 Hazardous Waste Contingency Plan and Emergency Procedures

In order to be prepared for potential emergencies, Rosemont will comply with the contingency plan and emergency procedures requirements for SQG identified in 40 CFR 262.34(d)(5)(i-iv). Rosemont will develop procedures to follow during an unplanned major event and will incorporate the following requirements into the procedures:

At all times there will be at least one employee either on the premises or on-call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures. This employee is the emergency coordinator;

Rosemont will post the following emergency contact information next to the telephones on-site:

o The name and telephone number of the emergency coordinator;

o Location of fire extinguishers and spill control material, and, if present, fire alarm;

o The telephone number of the fire department, unless the facility has a direct alarm.

Rosemont will ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies;

The Rosemont emergency coordinator or his or her designee will respond to any emergencies that arise. The applicable responses are as follows:

o In the event of a fire, call the fire department or attempt to extinguish it using a fire extinguisher;

o In the event of a spill, contain the flow of hazardous waste to the extent possible, and as soon as is practicable, clean up the hazardous waste and any contaminated materials or soil;


o In the event of a fire, explosion, or other release which could threaten human health outside the facility or when the generator has knowledge that a spill has reached surface water. Rosemont will immediately notify the National Response Center (using their 24-hour toll free number 800/424-8802). The report must include the following information:

The name, address, and EPA Identification Number of the generator;

Date, time, and type of incident (e.g., spill or fire);

Quantity and type of hazardous waste involved in the incident;

Extent of injuries, if any; and

Estimated quantity and disposition of recovered materials, if any.

Rosemont will have spill response kits available at or near the hazardous waste accumulation and storage areas. The spill kits will include sorbent and other cleanup material. These kits will be checked as part of the hazardous waste accumulation and storage facilities.

An example Emergency Response and Contingency Plan can be found in MPO Volume IV-j. A final plan is under development for the construction phase/pre-mining period and will be updated for the operations phase. All items listed above will be included and any requirements specified in the Emergency Response and Contingency Plan will supersede those listed above.

3.1.3 Monitoring

Monitoring to be performed as part of hazardous waste management includes:

Characterization of the various wastes generated on-site to determine which ones are hazardous waste;

Accumulation, storage and disposal volumes of hazardous waste;

Length of time that hazardous waste is on-site from the accumulation start date; and

Inspections of hazardous waste accumulation areas, containers, spill and response supplies and equipment.

Waste characterization assists in generating waste profiles (see Section 3.1.2.1). Rosemont will generate waste profiles with a unique identifier/number for each waste that is generated at the Rosemont Project.

The volume of hazardous waste generated and the length of accumulation and storage time will be tracked to ensure that hazardous waste volumes do not exceed those for a CESQG. Rosemont will track the volumes and length of accumulation time for hazardous waste via information from each facility operation that generates a hazardous waste and from inspection records.

Rosemont will complete weekly inspections of hazardous waste accumulation and storage areas. Inspections will check all of the accumulation and storage requirements identified in Subsection 3.1.2.2. The inspections will assess the condition of the containers and determine if there have been any leaks or spills. If leaks or spills are detected, Rosemont will implement the Rosemont Project SPCC Plan (MPO Volume IV-p) and an Emergency Response and Contingency Plan, similar to the one created for the drilling projects (MPO Volume IV-j).

3.1.4 Records

Rosemont will retain the following records in the Environmental Department as part of hazardous waste management:


Waste characterization results and waste profiles for various wastes generated on-site,

Land Disposal Restriction Certifications,

Inspection forms that record the results of checks of hazardous waste accumulation areas, containers, spill and response supplies and equipment,

Manifests,

Exception reports, and

Hazardous waste registration and permit.

Rosemont will retain the waste characterization results and completed waste profiles, or other determinations made in accordance with 40 CFR Section 262.11 (hazardous waste determination). These records will be retained for as long as Rosemont operates the Rosemont Project.

Land Disposal Certifications are certifications made by Rosemont that either the waste is not restricted from land disposal or that it meets treatment standards outlined in RCRA. Rosemont will retain Land Disposal Certifications for a minimum of five years.

Records of inspections and any completed corrective actions will be retained for as long as Rosemont operates at the Rosemont Project.

Uniform Hazardous Waste Manifests, a form required by USEPA and the USDOT will be signed in accordance with §262.23(a). The signed generator copy of the manifests will be retained with the signed copy from the designated facility receiving the waste. Both manifest copies will be retained for at least five years from the date the waste was accepted by the initial transporter. The State of Arizona requires that one copy of each manifest (Generator, Transporter, and TSD Facility) be submitted to ADEQ.

Exception reporting involves waste shipments with a manifest where the disposal copy of the manifest is not returned to Rosemont. If Rosemont does not receive a copy of the disposal manifest with the handwritten signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter, Rosemont will submit a legible copy of the manifest, with an indication that Rosemont has not received confirmation of delivery, to the USEPA Regional Administrator for Region IX. Exception reports will be retained for at least five years.

Rosemont will register and obtain permits from the ADEQ and PCDEQ for the generation of hazardous waste. Registration paperwork and permits will be retained for at least five years.


3.2 UNIVERSAL WASTE

Universal wastes, a subset of Hazardous Waste, identifies widely generated wastes that can be managed using a streamlined system for recycling and reduces regulatory burden. Universal wastes at the Rosemont Project include:

Lamps that include mercury vapor bulbs, some fluorescent light bulbs and neon lights;

Batteries that include nickel cadmium and lead acid;

Waste pesticides from preventing or mitigating pests or use as a plant regulator or defoliant; and

Mercury-containing equipment that includes devices where elemental mercury are integral to their function such as thermostats and computer equipment.

Universal waste generators are required to provide notification of disposal based on the volume that they accumulate. Universal waste cannot be accumulated for more than one year.

3.2.1 Regulations

Federal regulations for universal waste, as amended July 1, 2000, have been adopted by the State of Arizona and Pima County. PCDEQ had delegated authority for hazardous waste management and has adopted the federal and state regulations. All SQG, LQG, and transporters of hazardous waste must register with the county and provide reports as required. Conditionally exempt small quantity generators (CESQGs) and SQGs are not required to notify Pima County Department of Environmental Quality (PCDEQ) of their universal waste management activities nor required to keep records of universal waste shipments. Rosemont anticipates being a CESQG for the Rosemont Project. However, Rosemont would register with the ADEQ and PCDEQ as a generator of hazardous waste including universal waste. As a best management practice, Rosemont will track and keep records of their universal waste management.

Regulatory Agency


Web Link

USEPA

Resource Conservation and Recovery Act (RCRA)-Standards for Universal Waste Management

40 CFR 273

https://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol28/xml/CFR-2012-title40-vol28-part273.xml

ADEQ-adopted federal regulations by reference with permitting and reporting

Hazardous Waste Management

AAC R18-8-262 and 273

http://www.azsos.gov/rules/arizona-administrative-code#ID18

PCDEQ-adopted federal regulations by reference with permitting and reporting

Hazardous Waste Generators

Pima County Title 7 Chapter 7.09

https://www.municode.com/library/az/pima_county/codes/code_of_ordinances?nodeId=TIT7ENQU_CH7.09HAWAGE_7.09.010AP


3.2.2 Accumulation and Management Procedures

3.2.2.1 Universal Waste Management and Storage

The universal wastes including the lamps, batteries, pesticides, and mercury-containing equipment will be generated at the Rosemont Project and properly stored in the Rosemont Project Waste Management Area.

3.2.2.2 Lamps

Lamps are the bulb or tube portion of an electric light including, but are not limited to, fluorescent, high intensity discharge, neon, mercury vapor, high-pressure sodium and metal halide lamps. Lamps may contain mercury and should not be included in the miscellaneous refuse. Procedures to be used for the management of mercury-containing waste lamps, considered to be a universal waste, must follow 40 CFR 273 (Standards for Universal Waste Management) and Arizona Administrative Code R18-8-273. Procedures to be used for the management of lamps are presented in the ADEQ and PCDEQ Fact Sheets for Managing Mercury-Containing Waste Lamps as Universal Waste (see Appendix B-1 and Appendix B-2). The lamps that qualify as universal waste generated at the Rosemont Project will be stored in secured containers located in the Waste Management Area. The key requirements for fluorescent lamps and bulbs that contain mercury is the proper accumulation and storage.

Bulbs will be stored in areas that are away from high traffic areas, clean, dry and free of broken lamp debris and should ideally have an independent air handling system in case of mercury bulb breakage.

The bulbs will be stored in a structurally sound container that is compatible with the contents of the lamp.

The container must be:

o Stored in such a way that it will not tip over and cause breakage of contents.

o Closed unless actively adding or removing universal waste lamps.

o Labeled or marked with the words “Universal Waste-Lamp(s)” or “Waste Lamps”, or “Used Lamps”.

o Marked with the start date of accumulation of waste lamps to demonstrate the length of time that the lamps have accumulated as a waste. The bulbs and other universal waste cannot be accumulated for longer than one year.

If a lamp breaks and there is mercury vapor inside, it will be released. Immediate cleanup is essential to ensure the containment and cleanup of lamp debris. The lamp debris should be managed as a hazardous waste. Broken lamps should be kept in a sealed container, preferably glass or metal. The storage containers should be removed from the building as soon as possible to a cool area away from high traffic. Containers of broken lamps should not be opened to add or remove broken lamps.

3.2.2.3 Waste Batteries Handling

Universal waste batteries include the nickel cadmium and lead acid batteries. Nickel-cadmium (NiCd) batteries, such as household batteries from calculators, flashlights, cameras, etc. may contain mercury and cadmium. The mine truck shop, light vehicle shop, and facilities maintenance will generate universal waste batteries. Office/administrative areas may generate universal waste batteries and non-hazardous waste batteries. Non-hazardous waste batteries that do not require management as a universal waste include alkaline, carbon zinc, chloride zinc, nickel metal hydride, zinc air, and lithium batteries that are nine volts or less and higher lithium batteries that have been


discharged to less than one volt. Although the nonhazardous batteries are not a universal waste, Rosemont will collect and recycle them.

Lead acid batteries will either be returned to the vendor for recycling or shipped off-site to a recycler. Universal waste batteries will be stored in the Waste Management Area. General management practices for universal waste batteries including nickel cadmium and lead acid batteries include:

Handle batteries carefully to prevent spilling battery acid.

Inspect batteries for damage or leakage.

Large batteries should be placed on pallets and stacked upright with nodes on top. Batteries can be secured with plastic wrap to prevent shifting.

Smaller batteries should be placed in plastic or metal drums or containers with the lid secured when not adding waste batteries.

All containers and pallets of batteries must be:

Stacked in a safe manner to prevent shifting.

Labeled with the words “Universal Waste-Batteries.”

Marked with date that accumulation of batteries began.

Containers and pallets with batteries should be stored in an area protected from the weather and that has secondary containment.

If a battery is leaking or damaged, seal it in a plastic bag before placing it in the accumulation container. If a larger battery is leaking, the battery should be placed in a secured container or overpack. Any spills of acid from batteries should be solidified and neutralized with battery acid cleanup material.

3.2.2.4 Pesticides

Pesticides will be used at the Rosemont Project for preventing, destroying, repelling, or mitigating any pests or as a plant regulator, defoliant, or desiccant. Careful selection, inventory and control of pesticide materials will help to reduce or eliminate the need for disposal. Any residues should be disposed of per the Federal, State, and County universal waste regulations. A contractor will complete most of the herbicide/pesticide activities and will be required to be state licensed who will comply with applicable Federal and State regulations. Universal waste regulations apply to pesticides when the unused volume of material is being discarded or when a recalled pesticide is disposed or returned.

3.2.2.5 Mercury-Containing Equipment

Mercury-containing equipment generated at the Rosemont Project will include thermostats, other temperature gauges, vehicle light switches, computer equipment and other equipment containing elemental mercury. The mine truck and light vehicle shops, facilities maintenance, and administration will generate waste mercury-containing equipment. When the equipment is discarded, it becomes a waste. The waste mercury-containing equipment will be stored in a structurally sound container to prevent damage of the mercury-containing ampule. The containers of mercury-containing equipment will be stored in the Waste Management Area. The container will be closed when not adding waste equipment.

If an ampule of mercury is broken and the elemental mercury is released, response and cleanup will involve the following considering that the elemental mercury vaporizes more quickly at room temperatures or warmer:


Evacuate the area and cordon off (barricade) the spill area; don't let anyone walk through the mercury as they exit.

Notify security and the Environmental Department.

Open all windows and doors to the outside; shut all doors to other parts of the building.

A cleanup contractor will complete the cleanup using a mercury testing device and mercury cleanup materials.

Remember to keep the area well ventilated to the outside for at least 24 hours after the completion of the cleanup.

3.2.3 Monitoring

The Rosemont Environmental Department will maintain an inventory of the universal waste stored in the Waste Management Area and will conduct at least monthly inspections of the universal waste management area to ensure that all of the containers are secured, properly labeled, and marked with the start date of accumulation. The inspection will also ensure that there are no leaks from the batteries or waste pesticide containers and that all containers of lamps and mercury-containing equipment are intact with no breakage indicating a potential release of mercury. The inspection will also ensure that there is adequate spill response material and equipment and that the area has adequate access and aisles. The results of the inspections and any corrective actions will be documented on Environmental Monitoring Checklists.

3.2.4 Records

Records generated as part of universal waste management will include:

Environmental Monitoring Checklists documenting the inspections.



The aforementioned records will be kept in the Rosemont Environmental Department or filed electronically. Inspections are documented utilizing the Environmental Monitoring Checklist form or the electronic equivalent. Spills are documented using the spill reporting form. The Rosemont Environmental Manager will ensure that universal waste records are retained per the hazardous waste record requirements in Subsection 3.1.4.

3.3 USED OIL/OIL FILTERS

Used oil is any oil that has been refined from crude oil, or any synthetic oil that has been used, handled, transported, or stored, and as a result of such use, handling, transportation, or storage, is contaminated by physical or chemical impurities, and is no longer suitable for its originally intended purpose. Used oil includes: motor oils, metalworking fluids, emulsions, transmission fluids, brake fluids, coolants, heating media, refrigeration oils, electrical oils, buoyants, and hydraulic fluids. Used oil is presumed to be recyclable. If it is not recyclable, it is waste oil. Used oil can halogens, many of which are listed hazardous wastes. In many instances, the presence of halogens in the used oil is the result of mixing with chlorinated solvents. The USEPA has determined that used oil containing 1,000 parts per million (ppm) or less total halogens is not a hazardous waste. Used oil containing 4,000 ppm total halogens or more is a hazardous waste subject to regulation under 40 CFR, Parts 260 through 266, 268, 270, and 124.

Although polychlorinated biphenyls (PCBs) have been banned for most applications, they are still occasionally encountered. PCBs are regulated under the federal regulations for the Toxic Substance


Control Act (TSCA) at 40 CFR 761. How used oil containing PCBs is regulated depends upon the concentration of PCBs in the used oil. Used oil containing less than the quantifiable level of two (2) ppm PCBs is not regulated as a TSCA waste, but rather as used oil under 40 CFR 279. Used oil containing 50 ppm or more PCBs is regulated as a TSCA waste. For used oil containing PCB concentrations of two (2) ppm or more, but less than 50 ppm, TSCA requires the used oil to be handled in the same manner as off-specification used oil. However, if the used oil is to be burned, the PCBs must be completely destroyed.

3.3.1 Regulations

The following regulations apply to the generation and accumulation of used oil at the Rosemont Project:

Regulatory Agency


Web Link

USEPA Spill Prevention, Control and Countermeasures

40 CFR Part 112

https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/overview-spill-prevention-control-and

USEPA Used Oil 40 CFR Part 279

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr279_main_02.tpl

ADEQ

Environment-used oil (adopts by reference the federal regulation 40 CFR Part 279 with definition clarification

ARS 49-801

https://www.azleg.gov/viewdocument/?docName=https://www.azleg.gov/ars/49/00801.htm


3.3.2.1 Used Oil Management and Storage

Used oil from maintenance activities will be managed in bulk containers with secondary containment. Only oil acceptable for recycling will be accumulated in ASTs in concrete containment located at the mine truck shop and the light vehicle shop. The mine truck shop will store waste oil in one 5,800 gallon tank as the lube and facility area. Waste oil will be generated at approximately 30,000 gallons per year from the mine truck shop area. The light vehicle shop will have one 5,800 gallon AST for used oil in a concrete containment pad at the north end of the building.

Greases associated with the hoisting, milling, and other operational equipment will be placed into drums or other bulk containers suitable for recycling. If it is determined that the grease is not suitable for recycling, the containerized waste will be sent off-site for destruction. Used oil and grease not acceptable for recycling will be placed in drums for proper disposal.

Assuming that analysis indicates the used oil does not contain more than 1,000 ppm halogens, the used oil will be accumulated in these dedicated ASTs and sent for recycling. The following management requirements will apply for used oil:

Used oil containers must be marked as “Used Oil” and must be kept clean and in good condition.

Transporters of used oil must have an EPA ID Number.

The oil must be tested for total halogen content prior to transport.

Records of shipments should be maintained for three years.


An SPCC Plan must be in place that addresses used oil handling and storage. An SPCC Plan was prepared by Rosemont in accordance with Title 40 of the Code of Federal Regulations (40 CFR), Part 112, Oil Pollution Prevention (MPO Volume IV-p).

Any used oil that contains more than 1,000 ppm halogens will be managed as hazardous waste and will be shipped off for disposal at a hazardous waste facility following the hazardous waste requirements for manifesting, transportation, and disposal detailed in Section 3.1.

All tanks and drums storing used oil for the Rosemont Project have, and will have, some type of secondary containment. The operational and emergency storage capacity of the secondary containment will be sufficient to handle the quantity of expected to be discharged in un-diked areas from tank overfills or transfer operations or at least greater than or equal to 110 percent of the volume of the tank or drum.

The following is a general list of secondary containment structures that will be employed for used oil.

Double-wall tank construction. The ASTs will have a double-walled design with a secondary shell designed to contain the inner shell capacity;

Curbed concrete containment structure. The ASTs will be placed within a concrete containment structure which will provide at least 110 percent of the AST capacity; or

Polyethylene secondary containment. The ASTs will be placed within polyethylene secondary containment structures which will provide at least 110 percent of the AST capacity.

3.3.2.2 Used Oil Handling

The used oil regulations require that anyone who collects or accepts used oil from generators of used oil and transports that used oil to another facility, is a used oil transporter or transfer facility, subject to regulation under the state statutes.

Prohibited practices for used oil are as follows:

Used oil cannot be discharged into sewers or waters of the state without a permit issued by an appropriate regulatory authority.

Used oil cannot be incinerated, except at a facility authorized to incinerate hazardous wastes.

Burning for energy recovery is not considered incineration.

Used oil cannot be used as a dust suppressant or contact herbicide.

Used oil cannot be disposed on land, except in a landfill that has an approved solid waste facility plan.

Used oil cannot be stored in a surface impoundment.

The same bulk transfer procedures documented in Section 2.2.2.2 of this Plan for petroleum materials will be followed when transferring used oil to tanker trucks for recycling. Only used oil acceptable for recycling will be placed in bulk containers. Waste oil not acceptable for recycling will be placed in drums for proper disposal.

3.3.2.3 Used Oil Filters Management, Handling and Storage

Used oil filters will be generated at the mine truck and light vehicle shops as part of routine maintenance. The USEPA and ADEQ regulations direct management practices and disposal of used oil filters to ensure that used oil filters are properly drained prior to disposal. Any business that


generates used oil filters is subject to these rules. Used oil filters at the truck shop and light truck shop are required to be drained using one of four ways:

Hot-draining the filters and crushing.

Puncturing the filter anti-drain back valve or the filter dome end and hot-draining for twelve (12) hours.

Dismantling and hot-draining for twelve (12) hours.

Any other equivalent hot-draining method which will remove the used oil.

Hot-draining is defined as draining the oil filter at or near-engine operating temperature but above 60 degrees Fahrenheit. In other words, remove the filter from the engine while it is still warm, then puncture or crush and drain the filter. The USEPA recommends hot-draining for a minimum of 12 hours.

Oil filter crushers should be used after draining to remove most of the residual oil, which is captured in a collection tank below the crusher. Drained and crushed filters will be recycled as scrap metal.

3.3.2.4 Used Oil Spill Prevention Procedures

All tanks and drums storing used oil will have some type of secondary containment. The operational and emergency storage capacity of the secondary containment will be sufficient to handle the quantity of used oil expected to be discharged in un-diked areas from tank overfills or transfer operations or at least greater than or equal to 110 percent of the volume of the tank or drum. Used oil will be transferred off-site once per week by tanker truck. Tanker trucks perform transfers over the concrete pads in which used oil is stored to contain any potential spills.

3.3.2.5 Used Oil Spill Response Procedures

The petroleum spill response procedures in Subsection 2.2.2.4 will be used for used oil spill response. Spill response kits will be kept in close proximity to each AST at the truck shop and light vehicle shop to be used during incidental spills. Spill response material will include one or more of the following:

Sorbent pads;

Sorbent socks;

Sorbent granular materials; and

Heavy equipment (e.g., backhoes, front-end loaders, etc.) for temporary berm construction.

Small releases/spills (less than 20 gallons) from vehicles and/or equipment, generators, or containers onto the ground surface will be cleaned up by trained Rosemont employees and/or contractors directed by the Environmental Department Representative. Contaminated soils will be excavated and containerized into 55-gallon drums or other suitable containers. Representative soil samples will be collected and submitted to an Arizona-certified analytical laboratory for appropriate hydrocarbon analysis.

3.3.3 Monitoring

Inspections will be conducted per the petroleum materials monitoring Subsection 2.2.3. In addition to these requirements, used oil volumes shall be monitored via manifests or shipping papers prepared for the transfer of used oil off-site for recycling.


Any identified problems or deficiencies from inspections will be documented on the Environmental Monitoring Checklist contained in Appendix A of the SPCC plan (MPO Volume IV-p) and reported to the Rosemont Environmental Manager. If need be, the Rosemont Environmental Manager will arrange and coordinate for the problem/deficiency to be repaired or mitigated as soon as possible. Pooled oil will be removed immediately upon discovery.

3.3.4 Records

Records generated as part of used oil generation, accumulation, storage and handling will include:

Environmental Monitoring Checklists documenting the monthly and annual inspections.


Maintenance records regarding the ASTs.

Training records documenting completion of training of personnel who do petroleum handling, inspections or spill response.


The aforementioned records will be kept in the Rosemont Environmental Department with the SPCC Plan (MPO Volume IV-p). Daily inspections do not require documentation unless an issue is discovered. Inspections are documented utilizing the Environmental Monitoring Checklist form (see example in Appendix A of the SPCC Plan) and filed in Appendix F of the SPCC Plan. Spills are documented using the spill reporting form located in Appendix E of the SPCC Plan and filed in Appendix F of the SPCC Plan. All forms and filing discussed in this section may be managed electronically and filed in electronic format. The Environmental Manager is responsible for ensuring that records are properly filed and retained for at least three (3) years.

3.4 SPENT TIRES (LARGE AND SMALL)

Spent tires and their management and disposal will be applied to tires less than three (3) feet in diameter and tires greater than three (3) feet in diameter. The light vehicle shop will generate spent tires less than three (3) feet in diameter, and the mine truck shop will generate the spent tires that are more than three (3) feet in diameter. Tires that are less than three (3) feet in diameter will either be returned to the vendor or sent for recycling or reuse. Tires greater than three (3) feet in diameter will be placed in an on-site Tire Disposal Area that will be located in the Dry Stack Tailings Facility. No tires from the Rosemont Project will be disposed of at landfills per ARS 44-1304.

3.4.1 Regulations

Regulatory Agency Regulation Regulatory

Reference Web Link

USEPA RCRA 40 CFR Part 243

https://www3.epa.gov/region9/waste/solid/tires/

ADEQ Waste Mine Tires

AAC Title 18 Chapter 13 Article 12

http://apps.azsos.gov/public_services/Title_18/18-13.pdf

ADEQ Solid Waste Management

ARS Title 49, Chapter 4 Solid Waste Management

http://www.azleg.gov/ArizonaRevisedStatutes.asp?Title=49

ADEQ AZ Waste Tire Disposal

ARS Section 44-1301 -1307

http://www.azleg.state.az.us/ArizonaRevisedStatutes.asp?Title=44



Reference Web Link

PCDEQ Solid Waste

Pima County Code of Ordinances Title 13 Div IV

https://www.municode.com/library/az/pima_county/codes/code_of_ordinances?nodeId=TIT13PUSE_DIVIVSOWA


3.4.2.1 Large Tire Management, Handling and Disposal

Tires that are greater than three (3) feet in diameter include tires from the mine haul trucks, front loaders, and other no tracked heavy equipment. Tires that are greater than three (3) feet in diameter are eligible for on-site disposal (AAC Title 18 Chapter 13, Article 12). Mining waste tires can be buried on-site if Rosemont completes the following specific requirements including:

Registers within 24 hours of burial commencement with the ADEQ on an ADEQ form that includes a statement that the site is in compliance with ARS 49-762.07(F) and ARS Title 44 Chapter 9, Article 8 as applicable. The registration fee of $500 must be paid within 30 days of invoice receipt. The information filed with ADEQ will include a map of the facility identifying the location and dimensions of the tire burial cell.

At no time will more than 500 mining waste tires be stored outside of the burial cell.

The cell must be included in the APP for the facility. The area identified includes the entire Rosemont Camp area within the Dry Stack Tailings Storage Facility, which is listed as a potentially discharging facility and therefore on the list of facilities to be permitted in the APP.

The burial cell must not be located within 10 feet of another cell.

The mining waste tires will be generated from on-site use.

Once placed in the cell, the mining waste tires will be covered with a minimum of six inches of material within 50 days of placement. Once the cell is full, at least three feet of final cover will be placed over the cell within 180 days.

By March 30 of each year until a burial cell certification is filed with the ADEQ, Rosemont will file an annual report with the Director of the ADEQ which documents the following:

o Location of each burial cell established during the previous calendar year,

o An alphabetical or numerical identifier of each burial cell, and

o The number of off-road motor vehicle waste tires that were placed in each burial cell.

Rosemont will file a burial cell closure certification within 30 days after placing final cover over the mining waste tires and shall include statements that no additional tires will be buried in the cell and an Arizona professional engineer certifies that the cover requirements have been met.

Rosemont continues to investigate the potential for reuse of these tires and will continue to seek contracts for beneficial uses of mining tires as they are identified. As appropriate, tires may also be used for erosion control or structural fill. If alternatives to burial exist, Rosemont will review them and manage the tires accordingly.


3.4.2.2 Small Tire Management, Handling and Disposal

Tires less than three (3) feet in diameter include light vehicle and small equipment tires. There are two opportunities for disposing of small tires from vehicles that can be licensed and that are less than three (3) feet in diameter.

1. The vendor will remove the waste tires from the property for appropriate disposal or recycling.

2. A waste handler will be contracted to remove the tires for appropriate disposal or recycling.

In general at mining sites, the vendors that supply the tires also remove them for recycling or disposal. Rosemont will contract with vendors or waste haulers that can appropriately manage waste tires smaller than three (3) feet in diameter.

3.4.3 Monitoring

Rosemont will track the number of large waste tires that are accumulated on-site and disposed in the on-site burial area. The inventory and purchasing systems will be used to track the number of small tires that are accumulated on-site and sent off-site for recycling/reuse.

3.4.4 Records

Rosemont will maintain records in the Environmental Department at the Rosemont Project regarding the number of tires buried in each cell for at least three years after the burial cell certification is filed with the ADEQ. The annual reports and burial cell closure certifications will also be retained for at least three years in the Environmental Department offices.

3.5 SOLID WASTE/GENERAL TRASH

According to 40 CFR Part 258.22, solid waste is defined as: any garbage; refuse; sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility; and other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities. Solid waste does not include solid or dissolved materials in domestic sewage, or solid or dissolved materials in irrigation return flows or industrial discharges that are point sources subject to permit under 33 U.S.C. 1342, or source, special nuclear, or by-product materials as defined by the Atomic Energy Act of 1954, as amended (68 Stat. 923).

The State of Arizona has used the same definition of solid waste as in the federal definition; however, trash, rubbish, and waste tires have been added. Pima County defines solid waste with the same definition as the State of Arizona. The Pima County definition means waste, as defined in A.R.S. Section 49-701, which includes any: garbage; trash; rubbish; refuse; sludge from a waste treatment plant, water supply treatment plant or pollution control facility; and other discarded material including solid, liquid, semisolid or contained gaseous material, but does not include domestic sewage or hazardous waste. For county solid waste facilities, solid waste does not include liquids or other materials prohibited for disposal in construction debris landfills by 40 CFR Part 257 or in a municipal solid waste landfill by 40 CFR Part 258

The types of solid wastes/general trash that may be generated at the Rosemont Project include municipal solid waste, putrescible waste, tires, nonhazardous batteries, septage, or sewage sludge. These materials will not be disposed in the planned Rosemont Project NMSWLF. The waste types that can be accepted at the planned Rosemont Project NMSWLF are defined in Section 3.7, Landfill Waste.


The generation, handling, and recycling, disposal, or reuse of nonhazardous batteries, used oil, spent tires, septage, special waste, recyclable materials, empty product chemical containers, secured documents, and printer cartridges are addressed in the following sections of this Plan:

Subsection 3.2.2.3 Waste Batteries Handling;

Section 3.3 Used Oil/Oil Filters;

Section 3.4 Spent Tires (Large and Small);

Section 3.6 Septic Waste;

Section 3.9 Recyclable Materials;

Section 3.10 Empty Product Chemical Containers;

Section 3.11 Secured Documents; and

Section 3.12 Printer Cartridges.

The solid wastes that will not be disposed of into the municipal landfill and that are discussed in this section include putrescible wastes from various food-related waste accumulation containers around the facility and some of the materials that are nonhazardous may be shipped off site for disposal. Materials such as used oil, scrap metal and other recyclables will be shipped to legitimate recyclers that are audited by Rosemont personnel or regulatory agencies. Grease, not acceptable for recycling or where there is no market readily available, will be disposed off-site.

3.5.1 Regulations

The Resource Conservation and Recovery Act (RCRA) is the public law that creates the framework for the proper management non-hazardous solid waste. Title 40 of the CFR, parts 239 through 259, contains the regulations for solid waste. The ADEQ, through delegated authority from the EPA, regulates solid waste in Arizona.

Arizona also has specific restrictions on location, design standards, operations, groundwater monitoring and corrective action, closure and post-closure care, and financial assurance.

Regulatory Agency

Regulation Regulatory Reference Web Link


Subtitle D of RCRA (40 CFR Parts 239-259)

https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-regulations

ADEQ Solid Waste Management



ADEQ Solid Waste Plan Approval

40 CFR 257 http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr257_main_02.tpl

PCDEQ Solid Waste Title 13 Division IV https://www.municode.com/library/az/pima_county/codes/code_of_ordinances?nodeId=TIT13PUSE_DIVIVSOWA


PCDEQ Environmental Quality-Solid Waste

Title 7 Chapter 7.29 http://webcms.pima.gov/cms/One.aspx?portalId=169&pageId=59726

3.5.2 Solid Waste/General Trash Management and Handling

Per the Federal, State and Pima County regulations, Rosemont is responsible for the lawful storage, removal, transport, and disposal of the solid waste until it is lawfully deposited in an approved site or collected by a permitted/licensed contractor. Rosemont will have a licensed non-hazardous waste contractor to supply solid waste/general trash dumpsters for accumulating the putrescible wastes and some of the materials that are non-hazardous.

Personnel who generate these wastes will place them in accumulation containers in the buildings or operation areas. Janitors will empty the non-hazardous solid wastes containers into the general trash dumpsters. The aforementioned measures will ensure that the solid waste is properly accumulated and stored so as not to present a hazard to the public health and safety or the environment.

3.5.3 Monitoring

Rosemont will conduct monthly inspections of the solid waste/general trash dumpsters as part of their facility environmental inspections as required by the Arizona Pollutant Discharge Elimination System (AZPDES) general stormwater permit for mining activities (ADEQ; 2010, 2013). The inspections that will be documented on the Environmental Monitoring Checklists will ensure that the dumpsters are properly secured with a lid and that no liquids or hazardous wastes are being disposed in them.

3.5.4 Records

Records generated as part of solid waste/general trash management and handling will include:

Environmental Monitoring Checklists documenting the monthly inspections.


The aforementioned records will be kept in the Rosemont Environmental Department with the Stormwater Pollution Prevention Plan (MPO Volume IV-q). The Environmental Manager is responsible for ensuring that records are properly filed and retained for at least three (3) years.

3.6 SEPTIC WASTE

Domestic wastewater, or sewage, is generated at the Rosemont Project through the use of toilets, bathroom sinks, showers, bathtubs, kitchen sinks, garbage disposals, dishwashers, and washing machines. Domestic wastewater contains dissolved organic and inorganic materials, suspended and settleable solids, and microorganisms, including bacteria and viruses. Sanitary waste will be treated and disposed in on-site septic systems, with underground tanks and leach fields located in the vicinity of each building. Although currently under design revision, previous plans had eight (8) sewage treatment systems for the Rosemont Project. Each system had a design flow less than 3,000 gallons per day (gpd) and consisted of a septic tank and a leach field. These systems were located near the following buildings:

Administration Building;

Analytical Laboratory;

Change House;

Copper/Molybdenum Flotation and Regrind Circuit;

Grinding and Classification Circuit;


Process Maintenance Facility;

Main Warehouse; and

Mine Truck Shop.

During the construction phase and where necessary during operations, portable toilets will be used in various locations throughout the plant and mine sites.

3.6.1 Regulations

The requirements in Arizona Administrative Code (AAC) R18-9-E323 Section 4.2.3 that specifies systems with 3,000 to less than 24,000 gallons per day gpd design flow will apply to the Rosemont Project. As noted, previous plans had eight (8) sewage treatment systems on the property under common ownership, and the systems had a combined total design flow greater than 3,000 gpd. The following regulations will apply to the disposal of sanitary wastewater at the Rosemont Project.


ReferenceWeb Link

ADEQ

Aquifer Protection Permit-General Permit

AAC Title 18 Chapter 9-E323


ADEQ Solid Waste-Sanitary

AAC Title 18 Chapter 13


3.6.2 Septic Management Procedures

The on-site septic systems will be used to dispose of domestic wastewater. Each treatment systems will be constructed as a 2-part system, consisting of a septic tank and a leach field. As previously planned, the design flows for the sewage treatment systems ranged from 125 to 1,500 gpd. These facilities had a total design capacity of 4,850 gpd.

Upon permanent cessation of any or all of the on-site sewage treatment systems, the system(s) will be closed in accordance with AAC. R18-9-A309.D.

A.A.C. R-18-9-E323(B)(1) requires a Performance Assurance Plan consisting of tasks, schedules, and estimated annual costs for operating, maintaining, and monitoring performance over an approximate 20-year operational life.

During the construction phase and where necessary during operations, portable toilets will be used in various locations throughout the plant and mine sites. The portable toilets will be serviced by a commercial sanitation company and the waste removed for off-site disposal.

3.6.3 Monitoring

Rosemont will conduct yearly inspections and servicing of each septic tank to satisfy the annual reporting requirements of AAC. R18-9-E323 (G). Additionally, if an emergency overflow condition occurs, Rosemont will haul wastewater until repairs are completed. Rosemont will use a certified operator or service provider (certified hauler) to perform the maintenance and inspections of the septic systems.

3.6.4 Records

Records will be kept of any inspection, repairs, or maintenance activities using the Record of Inspection/Maintenance form. Because the cumulative wastewater flows at the Project site facility are


expected to be greater than an average of 3,000 gallons per day, annual reports of system conditions and maintenance performed will be filed with the ADEQ.

Rosemont will submit an annual report to ADEQ by the anniversary of the Discharge Authorization. The annual report will consist of a form that 1) is signed by a certified operator or service provider (certified hauler) and 2) documents the following:

Inspection, repair and maintenance documentation/data per updates to the Performance Assurance Plan for Septic Systems (Tetra Tech, 2011) prepared for the previous design (see Appendix C);

Certifies compliance with the design and operation of the septic systems per updates to the Performance Assurance Plan for Septic Systems (Tetra Tech, 2011) prepared for the previous design (see Appendix C); and

Describes any additions to the facility during the year that increased flows and certifies that the flow did not exceed 24,000 gallons per day during any day.

The records will be kept in the Rosemont Environmental Department for at least three years.

3.7 NON-MUNICIPAL SOLID WASTE LANDFILL WASTE

Rosemont is permitted to construct and operate a non-municipal solid waste landfill (NMSWLF) at the Rosemont Project. The NMSWLF will be located within a 2.6-acre area on patented mining claims and approximately 1,800 feet north-northeast of the proposed pit. The NMSWLF will be designed and managed as a single cell with final cover.

3.7.1 Regulations

The following regulations apply to the construction, operation and maintenance of a non-municipal landfill at the Rosemont Project:

Regulatory Agency


USEPA RCRA Subtitle D of RCRA (40 CFR Parts 257, 258, and 503)

http://www.epa.gov/agriculture/lrca.html#Solid Wastes

ADEQ

Aquifer Protection Permit and Solid Waste Facility Plan approval.

ARS §49-761 to 868 and AAC R18-13-1301 to R18-13 Appendix B

http://www.azdeq.gov/environ/waste/solid/plan.html

PCDEQ Environmental Quality

Title 7 Section 7.29 https://www.municode.com/library/az/pima_county/codes/code_of_ordinances?nodeId=TIT7ENQU_CH7.25WACO_7.25.130DIREMA


3.7.2.1 Landfill Management

Rosemont may use the landfill for the disposal of allowable materials listed below. No municipal solid waste, putrescible waste, tires, batteries, septage, or sewage sludge will be disposed in the NMSWLF.

The wastes that are planned for the NMSWLF include:


Clean fill: Clean rock (no sulfide-bearing materials) and soil.

Construction and demolition waste: as defined in A.R.S. § 49-701(5) and 701 (7).

Inert material: as defined in A.R.S. § 49-701(15).

Landscape rubble: as defined in A.R.S. § 49-701(17).

Vegetative waste: as defined in A.R.S. § 49-701(36) and that cannot be recycled or reused.

Rubbish: as defined in A.A.C. R18-13-302.H.

White goods: Prior to disposal, chlorofluorocarbon compound-containing appliances will conform to the requirements of Title 40 CFR § 82 Subparts E and F.

Empty metal containers.

Dry paper and cardboard.

Plastic containers and products.

Glass.

The waste screening protocol for the NMSWLF will consist of visual inspections by operational personnel to determine if waste characteristics meet permit requirements. Only wastes identified above will be disposed of in the NMSWLF. However, depending on the status of the NMSWLF, some of these nonhazardous wastes may be sent off-site for disposal by a licensed nonhazardous solid waste disposal contractor (see Section 3.5 Solid Waste/General Trash).

The following wastes are PROHIBITED from disposal in the NMSWLF:

Used oil;

Human excreta;

Special waste as defined in ARS 49-851(A)(5);

Biohazardous medical waste;

Radioactive waste material;

Hazardous waste;

Bulk or non-containerized liquid waste; and

Waste containing polychlorinated biphenyls (PCBs).

3.7.3 Monitoring

Rosemont will conduct monthly inspections of the NMSWLF starting at the time of construction and will continue at least quarterly. Additional inspections will be conducted after major severe storm or run-off events. The inspections will be a visual assessment of integrity, physical appraisal of the design capacity, slope stability and excess erosion. These inspections and any follow-up corrective actions will be documented on the Environmental Monitoring Checklist.

In general, landfills generate gases during the decomposition of the buried wastes. Since the majority of the waste will likely be construction/demolition debris, the landfill gas of concern is methane. The regulation 40 CFR Part 257.3-8(a) states that methane gas concentrations at solid waste disposal facilities shall not exceed twenty-five percent (25%) of the lower explosive limit (LEL) in facility


structures or the LEL at the property boundary. To achieve compliance with this requirement, Rosemont will permanently install four methane punch bars around the perimeter of the “property boundary” to ensure that any potential methane gas that is produced in the landfill does not migrate into the native underlying sediments. The punch bars will be monitored for LEL and methane quarterly beginning at construction of the landfill through post-closure of the NMSWLF. The specific monitoring parameters are defined in the Methane Monitoring Plan (CEC, 2011) developed for the Project (see Appendix D). The information from the monitoring is recorded on the Methane Monitoring Report Forms. Rosemont will follow the contingency actions in the Methane Monitoring Plan (CEC, 2011) if there is ever an exceedance of the explosive gas threshold. Upon completion of the post-closure activities, the punch bars will be abandoned.

3.7.4 Records

Rosemont will maintain all design and construction documents required by statute or rule for the solid waste facility, and those documents shall be made available for inspection pursuant to ARS Section 49-763. Records associated with permitting, constructing, and operating the NMSWLF that Rosemont will retain in the Environmental Department include:

Landfill construction drawings and as-built plans.

Operating record.

Methane monitoring records.



The Environmental Manager is responsible for ensuring that records are properly filed and retained for at least 10 years.

3.8 SPECIAL WASTE

Special waste is solid waste that, while not a hazardous waste, requires special handling and management to protect public health and the environment. The special waste that may be found at the Rosemont Project during operations as a result of petroleum spills is petroleum-contaminated soil (PCS) as a result of petroleum spills. Petroleum contaminated soil is not hazardous waste but may contain concentrations of petroleum contaminants that exceed the non-residential soil remediation levels (SRLs). The following are petroleum contaminants and the associated non-residential SRLs:

Total petroleum hydrocarbons greater than 5,000 milligrams/kilogram (mg/kg);

Benzene greater than 0.13 mg/kg;

Toluene greater than 200 mg/kg;

Ethylbenzene greater than 68 mg/kg; and

Total xylene greater than 44 mg/kg.

If the petroleum contaminated soil contains concentrations of any one of these parameters greater than the non-residential SRLs, the petroleum-contaminated soil will be excavated and properly accumulated, stored and disposed of appropriately.

3.8.1 Regulations

The following regulations apply to special wastes and petroleum contaminated soil:


Regulatory Agency


Web Link

USEPA RCRA 40 CFR Part 261.4 (b)

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr261_main_02.tpl

ADEQ Management of Special Wastes

ARS §49-851 to 868 AAC R18-13-1301 to R18-13


3.8.2 Petroleum Contaminated Soil Management and Handling Procedures

Rosemont will conduct the following immediately after a petroleum spill incident that is greater than an incidental spill:

Secure the area of the spill by roping off the area and diverting all vehicle and foot traffic away from the area.

Contact Rosemont site management and/or the Environmental Department.

Contaminated soils from petroleum spills, with concentrations above the non-residential requirements for treatment, storage, transportation or disposal, will be managed as a special waste. The SRLs will be used as a guideline for determining the extent of soil excavation, including the management and disposition of the petroleum contaminated soil.

The Environmental Department will determine response actions by the estimated volume of impacted materials and the required containers or containment system to effectively contain and prepare the soil for off-site transport. The container sizes will typically be divided in to three categories or volume sizes as follows:

Plastic bucket under ten gallons in size and equipment needed for cleanup would be shovels or similar non-power hand tools.

Fifty-five gallon plastic drums and shovels or similar non-power hand tools.

Lined waste roll-off type containers and motorized power excavating equipment.

Any tank or container used for storage of petroleum contaminated soil must be leak-proof, and made of, or lined with, material that will not react with the petroleum contaminated soil. The tank or container must be closed at all times unless petroleum contaminated soil is being added or removed, and not opened, handled or stored in a manner that will lead to rupture or leaks.

If petroleum contaminated soil is going to be managed on-site, there are a number of best management practices specified in the regulations that must be met. The requirements specified in AAC R18-13-1601 to 1614 include:

Petroleum contaminated soil may be collected at an accumulation site for more than 12 hours but not more than 90 days prior to treatment, storage, or disposal.

Petroleum contaminated soil accumulation will be in a compatible container or containment system. The containment system will meet the design and performance standards in AAC R18-13-1608, 1609 or 1611.

Each petroleum contaminated soil storage area, tank or container used for storage or accumulation must be labeled appropriately.


Waste management for storage, offsite transportation, and disposal must comply with special waste manifest requirements (AAC R18-13-1302), special waste shipper requirements (AAC R18-13-1303) including placarding requirements and shipped to a special waste registered storage, disposal, or treatment facility permitted by ADEQ (AAC R18-13-1613). An ADEQ special waste manifest must accompany shipments of petroleum contaminated soil.

3.8.3 Monitoring

Rosemont will conduct sampling of the petroleum contaminated soil to determine the concentrations of petroleum-related parameters. The soil sampling will be conducted per the written site-specific sampling plan consistent with the requirements in US EPA SW846 or the ADEQ Quality Assurance Project Plan, Chapter 9 May 1991 Edition. (USEPA, 2014; ADEQ, 1991) Determinations of the concentrations of petroleum-related parameters are made using laboratory analysis by a laboratory licensed by the Arizona Department of Health Services.

Rosemont will track the volume of PCS that is collected in the accumulation area and will document the volume disposed on the ADEQ special waste manifest when the petroleum contaminated soil is sent for disposal.

Rosemont will conduct monthly inspections of the petroleum contaminated soil containers and/or piles as part of their facility environmental inspections as required by the Arizona Pollutant Discharge Elimination System (AZPDES) general stormwater permit for mining activities. The inspections that will be documented on the Environmental Monitoring Checklists will ensure that the petroleum contaminated soil areas are properly contained with a cover. The inspection will ensure that no runoff or liquid is flowing from the area. Any deficiencies and the corrective actions will be documented on the Environmental Monitoring Checklist.

3.8.4 Records

Records generated as part of petroleum contaminated soil management will include:

Analytical results or the determination of the soil is petroleum contaminated soil.

Special waste manifests and tracking of petroleum contaminated soil volumes.

Special waste annual report.



The records will be kept in the Rosemont Environmental Department for at least three years. The inspection records will be retained with the Stormwater Pollution Prevention Plan (SWPPP) (MPO Volume IV-q).

Rosemont will submit an annual report to ADEQ in accordance with ARS 49-860 by March 1st of each year for all special waste shipped the preceding year.

3.9 RECYCLABLE MATERIALS

Many materials that will be used at the Rosemont Project will have potential to be recycled into new products to prevent waste of potentially useful materials. Recycling has the potential to reduce the consumption of new materials, reduce energy usage, reduce air and water pollution, and lower greenhouse gas emissions.

Potential recyclable materials include scrap metal, wood products, cardboard, landscape materials, high-density polyethylene (HDPE) materials, glass, plastic, aluminum, and paper.


3.9.1 Regulations

There are no regulations requiring recycling; however, many solid waste regulations identify proper handling of wastes including recyclables. The following solid waste regulations address recyclable materials.

Regulatory Agency



Subtitle C of RCRA (40 CFR Parts 239-299)

https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-regulations

Arizona Department of Environmental Quality

Solid Waste Management



Arizona Department of Environmental Quality

Solid Waste Plan Approval

40 CFR 257

http://www.azdeq.gov/environ/waste/solid/plan.html http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr257_main_02.tpl

PCDEQ Solid Waste Title 13 Division IV https://www.municode.com/library/az/pima_county/codes/code_of_ordinances?nodeId=TIT13PUSE_DIVIVSOWA

PCDEQ Environmental Quality-Solid Waste

Title 7 Chapter 7.29 http://webcms.pima.gov/cms/One.aspx?portalId=169&pageId=59726

3.9.2 Recyclable Materials Accumulation and Management

There will be four major groups of potential recyclable materials at the Rosemont Project.

Bulk recyclables including scrap metal, wood, cardboard;

HDPE materials; and

Office recyclables including glass, plastic, aluminum, and paper.

Each of the materials will be accumulated on-site. Rosemont will recycle and reuse as much of the materials as feasible. What is not recyclable or reusable may be disposed in a Rosemont Project non-municipal solid waste landfill (if constructed) or shipped off-site to a local landfill.

3.9.2.1 Scrap Metal, Wood, and Cardboard

Rosemont will lease roll-off boxes from a licensed waste and recyclables transportation contractor to collect scrap metal, wood, and cardboard at the waste management area or near points of generation.

Contracts with scrap metal recyclers will be established for on-going recycling activities. In the event recycling becomes impossible or otherwise impracticable (i.e. scrap prices drop limiting recyclers or scrap prices become so high there are not enough recyclers), scrap metal will be stockpiled near the solid waste facility for bulk recycling. Empty aerosol cans will be punctured, drained to meet the definition of scrap metal [40 CFR 261.1(c)(6)], and recycled.

Much of the material delivered to the Rosemont Project will be packaged in wood crates, pallets, or cardboard. Rosemont will recycle as much of the wood and cardboard received at the site as possible, utilizing businesses in Tucson and the surrounding communities.


3.9.2.2 High-Density Polyethylene Materials

HDPE piping and liner materials will be reused on-site or sent for off-site recycling or disposal (if managed appropriately). These materials may also be disposed on-site in a non-municipal solid waste landfill.

3.9.2.3 Office Recyclables

Each office building and administrative areas of the Rosemont operations will have separate collection bins for glass, plastics, aluminum cans, and non-confidential paper materials. Rosemont will accumulate the office recyclables in roll-off boxes or dumpsters provided by a licensed solid waste and recyclables transportation contractor. The contractor will transport the glass, plastic, and aluminum to recycling centers in Tucson and the surrounding communities.

3.9.3 Monitoring

Rosemont will conduct monthly inspections of the recyclables roll-off boxes and collection areas as part of their facility environmental inspections as required by the AZPDES general stormwater permit for mining activities (ADEQ; 2010, 2013). Inspections will be documented on Environmental Monitoring Checklists to document that the roll-off boxes are properly covered and that no liquids or hazardous wastes are being disposed in them.

Rosemont will track the volume of the recyclables that are accumulated and shipped off-site compared to the volume of these materials that are disposed on-site in a planned on-site non-municipal solid waste landfill.

3.9.4 Records

Records generated as part of solid waste/general trash management and handling will include:



Recyclable material volume accumulation and shipping records (accumulation records and bills of lading).

The inspection records will be kept by the Environmental Department with the Stormwater Pollution Prevention Plan (SWPPP) (MPO Volume IV-q). The recyclable material volumes and off-site shipping records will be retained in the Environmental Department. The Environmental Manager is responsible for ensuring that records are properly filed and retained for at least three (3) years. Records related to the volume of recyclables disposed in the on-site non-municipal solid waste landfill will be retained for at least 10 years with the operating record.

3.10 EMPTY PRODUCT CHEMICAL CONTAINERS

After the usable portion of a containerized chemical is removed (i.e., from a drum, tote, bucket, etc.), the container needs to be evaluated regarding its next use. The next use of a container depends on the ownership of the container and the amount of residue left in the container. Leased reusable containers, such as totes, will be returned to the vendor or supplier. Containers that become the property of Rosemont when the material is received at the Rosemont Project will be evaluated to determine how much residue is present. The volume of residue remaining determines if the container can be safely disposed as solid waste, reused on-site or recycled.


3.10.1 Regulations

The RCRA regulation (40 CFR Part 261) includes a definition of “RCRA Empty” that is used to determine if the container can be reused, safely disposed as a solid waste, or recycled.

Regulatory Agency


Web Link

USEPA RCRA empty

Subtitle C of RCRA (40 CFR Part 261)

https://www.epa.gov/rcra

ADEQ

Hazardous Waste Disposal Permit

ARS Title 49, Chapter 5. ARS 49-921 AAC R18-8-260 ARS 49-922


PCDEQ Hazardous Waste Management

Title 7 Chapters 9 through 39

http://webcms.pima.gov/cms/one.aspx?portalId=169&pageId=66301


Leased reusable containers will be stored on the exterior of the building in which they are used or at a location at the warehouse to expedite shipping. These containers will be returned to the vendor.

Containers will be evaluated to determine if they are empty and how they will be managed. A container is considered empty if, after removing the contents using common practices (i.e. pouring, pumping, and aspirating), no additional material can be removed and contains less than one inch or 3% by weight of the total capacity of the container or inner liner. Containers that stored hazardous waste, and do not meet the RCRA-empty definition, are considered hazardous waste.

A container, including an inner liner that stored acutely hazardous waste (P-listed waste), is empty if the container liner was completely removed or if the container was cleaned by triple rinsing or with a method that removes the material to an equivalent level.

Best practices for the storage of empty containers that will either be reused on-site or sent for recycling include:

Mark or label the containers as empty.

Keep the lids closed and protect the containers from the weather.

The empty containers will be managed and disposed using one of the following options:

Reuse them on-site for containing materials compatible with the containers construction;

Send them off as scrap material based on their construction (i.e. metal, plastic);

Send them to a container re-conditioner or remanufacturer; or

Send them to an approved disposal facility as a solid waste.


3.10.3 Monitoring

Monitoring of empty containers will include periodic inspections of the empty container accumulation area in the waste management area to ensure that the containers are marked and the lids are closed to prevent precipitation accumulation. The inspection may also review the interior of the container to ensure that they are RCRA empty. Any issues of residues, spills, or leaks in the empty container area will be reported to the Rosemont Environmental Department for corrective actions.

3.10.4 Records

Records generated as part of empty container management may include:

Environmental Monitoring Checklists documenting the inspections.



The aforementioned records will be kept in the Rosemont Environmental Department. Inspections are documented utilizing an Environmental Monitoring Checklist form. Spills are documented using a spill reporting form. The Rosemont Environmental Manager will ensure that universal waste records are retained for at least three (3) years.

Materials that will either be reused on-site or sent for recycling include:

Mark or label the containers as empty.

Keep the lids closed and protect the containers from the weather.

Empty containers will be managed and disposed using one of the following options:

Reuse on-site for containing materials compatible with the container’s construction;

Send them off-site as scrap material based on their construction (i.e. metal, plastic);

Send them to a container re-conditioner or remanufacturer; or

Send them to an approved disposal facility as a solid waste.

3.11 SECURED DOCUMENTS

During the administrative and other tasks at the Rosemont Project, Rosemont personnel will generate and accrue numerous business documents containing private information. When the hardcopy or other versions of the documents are no longer needed, the documents and other versions will be disposed in a secure manner to avoid information theft. The disposal of this material is regulated as a solid waste item in 40 CFR Part 243. The key requirements of these regulations are addressed with the use of a secured document disposal service that provides the reusable waste containers that are constructed of plastic and are leak-proof. Items that need to be securely disposed of include:

Hardcopy documents

Hard drives

Media / backup tapes

Thumb / jump drives


CDs / DVDs

At the Rosemont Project, there will be secured containers for accumulating private and sensitive documents and information. Rosemont personnel that generate sensitive and private documents and information that can be disposed shall place the documents and information into the secured containers. These secured containers will be picked up by the secured document disposal service. The documents/information will be shred and/or destroyed on-site or at their facility. The secured document disposal service will provide tracking records of the volume of documents and information that is received, shredded and disposed.

3.12 PRINTER CARTRIDGES

Offices at the Rosemont Project will use printers for generating documents for administrative, reporting, and other communication functions. Printer cartridges are recyclable with the printer vendor or with general recycling vendors. In most cases where the printer vendor recycles the printer cartridges, the printer vendor provides envelopes or the original packaging for returning the spent cartridges. This recycling avoids disposing of the cartridges as solid waste and promotes their reuse. The following printer components may be sent for recycling/reuse: toner cartridges, laser printer cartridges, ink jet printer cartridges, bubble jet printer cartridges, copier cartridges, fuser drums, imaging units, and transfer rollers. To recycle the printer cartridges and any printer components, Rosemont personnel should complete the following:

When replacing the printer cartridge or printer component, the spent cartridge or component should be placed in the shipping box or container of the new printer cartridge or component and sealed. If the box or container is not available, place the cartridge or component in a clear bag and secure the bag before placing in an alternate box or container.

The sealed box or container should be clearly labeled as “used” or “recycle.”

The sealed printer cartridge or component box should be sent to the printer or recycling vendor.

No monitoring or formal records are required for ensuring that printer cartridges are sent for reuse/recycling.


4.0 CLOSURE AND BOND RELEASE This section addresses closure activities as they are associated with this plan as well as the plan for funding and bond release for 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 terms bonding terms and application for bond release as well as terms for that release are included.

4.1 INTERIM CLOSURE

Interim closure activities associated with this measure will include timely and appropriate disposal of any hazardous waste materials on-site. Hazardous waste must be removed from site within 30 days and weekly inspections of the waste storage facility are required until all waste is removed from site.

Additionally, a valid EPA Identification Number is required for shipments of hazardous waste and all employees inspecting the facility or signing shipment manifests must have appropriate training. Closure activities will need to include this training and application for an EPA ID number for the facility by the appropriate operator.

4.2 FINAL CLOSURE

While none of the materials used in the process other than the fuels are expected to contaminate foundational materials, final closure will include the following:

Testing any materials for disposal on-site that do not have a current waste profile on file to determine if they are hazardous waste;

Testing of all foundations around storage tanks, both chemical and petroleum, to determine if cleanup is required prior to breaking up the foundation;

Testing foundations in the process areas to determine if cleanup is required prior to breaking up the foundation;

Testing the foundation in the concentrate storage building to determine what sort of cleanup will be required to decontaminate the foundation before disposal;

Testing sludge in plant stormwater ponds to determine if managed disposal is necessary;

Appropriate management and disposal of any laboratory chemicals, disposal should include recovery of chemicals by vendors for reuse;

Appropriate management and disposal of any fuels, disposal in this case should include recovery of the fuels by vendors for reuse or use during reclamation and closure;

Appropriate management and disposal of any reagents, disposal in this case should include recovery of the reagents by the vendor for reuse; and

Testing the soils around the truck fueling station and the truck diesel fuel tank to be sure if any soils need to be recovered for disposal.

Additionally, other waste management areas will require specific closure including:

Final closure of the tire burial cell will require covering and closing the tire cell with ten (10) feet of waste rock;

Closure of the hazardous waste storage area will require inspecting and testing the foundation;

Closure of the ponds will require removing or evaporating the water from the pond (testwork for the pond water will have been completed the last year of operations) and once the water


is removed, the liners would be swept and the materials placed in the tailings facility, the liners would then be folded up and removed, and the subgrade inspected for evidence of leakage. If there is evidence of leakage, the area would be tested to determine cleanup requirements to achieve clean closure of the lined ponds per Aquifer Protection Permit closure requirements); and

Closure of the solid waste facility, if used, via capping.

4.3 BOND RELEASE

With the exception of activities that are covered by other bonding requirements, the activities associated with this measure are all requirements of closure. There is no bond release anticipated.


5.0 DATA MANAGEMENT Rosemont currently maintains data in various formats currently 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. A summary report will be provided annually to the Forest Service. 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.


6.0 REFERENCES

ADEQ, 1991. Quality Assurance Project Plan, Chapter 9. Prepared by the ADEQ Water Quality Standards Unit, dated May 1991.

2010. Arizona Pollution Discharge Elimination System Multi-Sector General Permit, December 20, 2010.

2013. Multi-Sector General Permit Authorization. Letter to Rosemont Copper Company. February 7, 2013.

CEC, 2011. Methane Monitoring Plan, Non-Municipal Solid Waste Landfill, Rosemont Copper Project, Pima County, Arizona. Plan dated August 2011.

CSA, 2014. Cylinders, Spheres, and Tubes for the Transportation of Dangerous Goods: CAN/CSA-B339 Sixth Edition. Prepared by the Compressed Standards Association dated 2014

Tetra Tech, 2011. Performance Assurance Plan for Septic Systems. Dated August 2011.

USEPA, 2001. Managing your Hazardous Waste- A Guide for Small Businesses. EPA530-K-01-005. December 2001.

2005. Training Module: Introduction to Land Disposal Restrictions (40CFR Part 228). EPA530-K-05-013. September 2005.

2014. SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods Update V Revision 8. July 2014.

USFS, 2013. Final Environmental Impact Statement for Rosemont Copper Project, Appendix B Mitigation and Monitoring Plan. December 13, 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.

APPENDIX A

Blasting Standard Operating Procedures (SOPs)

APPENDIX A-1

Construction Radio and Blast Site SOPs

RADIO Standard Operating Procedure

After tying in shot and evacuating area:

• Blaster distributes handheld radios to guards and performs radio checks.

• Blaster in Charge assigns blocking positions and posts guards at blocking locations and performs radio checks.

• Blaster Announces “Attention all personnel on “PROJECT NAME, This is the blaster in charge. We are five minutes from the blast. All personnel maintain radio silence until the all clear signal following the blast has been sounded or an actual emergency exists and announce CEASE FIRE.”

• Sound Five Minute Alert & wait 3 minutes.

• Blaster Announces “2 minutes to Blast.”

• Sound 2 Minute Alert & wait 1 minute for emergency communication

• Blaster Announces “1 minute to Blast.”

• Blaster Checks with all security positions to verify “All Clear” from each position & sound blast siren.

• Blaster Announces “Attention PROJECT NAME personnel, we will be blasting in 10, 9,8,7,6,5…(Pause for 4 seconds for Potential calls for Cease Fire…) Fire in the Hole!”

• Fire Shot

• Blaster Announces “All personnel remain at your positions until the all clear has been sounded.”

• Inspect Shot

• Blaster Announces “All Clear, All Clear.”

• Radios are collected and accounted for from blockers.

*No unnecessary or unprofessional communication should take place on company radios.

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BLAST SITE Standard Operating Procedure

Pre-shift Team Meeting

A pre-shift meeting will be held by blasting crews each shift. The pre-shift meeting shall include the following:

• Work locations

• Unique or continuing hazards

• Equipment/PPE needed for assigned work; reflective clothing, hard hat, safety glasses, gloves, steel toe shoes, fall protection, warning signs, remote, small tools, etc.

• Hole specific loading instructions for a pattern (Water, hardness, voids, decking, product, etc)

• Identification of parties for communication and unique work being done in areas adjacent to the blast site

• Assign blocking locations

• The anticipated time of the blast

• Other pertinent information

Pre-loading Area Inspection

The purpose of this section is to insure that the risks associated with the blast are identified and controlled.

• Blast area inspections shall be performed before loading starts.

• The Blaster in Charge will verify that the blast plan map accurately represent the blast pattern in the field (i.e. number of holes, hole locations, problem holes).

• Blaster will verify that all potentially affected persons have been informed of blast, proper signage and barricades have been placed,

• During the inspection blast site access and egress routes shall be evaluated and appropriate actions taken.

• The Blaster in Charge will determine the boundaries of the blast area. The following items shall be considered when determining the boundaries of the blast area:

o Concussion

o Fly rock

2

o Fumes, ventilation and prevailing wind conditions

o Air blast

o Subsidence

o Adjacent infrastructure

o Equipment locations including maintenance activities

o Noise and vibration

o Geological features

o Adjacent underground or surface workings

o Hazards associated with the loading pattern

• Holes are marked with flag or stake identifying hole ID & Depth

• Holes not intended to be loaded will be labeled with “do not load”

• Any unlabeled holes that are discovered will be properly identified through consultation with the map and the Blaster in Charge.

• Questions or concerns that arise from the area inspection will be resolved through consultation with the Blaster in Charge before loading starts.

Explosive Storage and Transportation

The purpose of this section is to insure that explosives are handled and transported safely and in accordance with regulations.

• A person or persons will be assigned responsibility for managing the magazines.

• All outdoor magazines will be built to the BATF standards and sited to the American table of Distances.

• All magazines will be:

o Properly grounded.

o Constructed outside the corridors of power transmission lines.

o Properly signed with; "No Smoking", "Explosives Stored Here" and "Authorized Personnel Only".

• The location of all fire extinguishers will be clearly marked.

• All magazines will contain a book or similar method for the recording of all explosives

movements in and out of the magazine and current inventories. If the records are kept in a

3

central office each magazine will have its own section to record movement of product from that magazine.

• If materials other than explosives are being stored within the magazines they will be segregated from the explosive materials.

• All magazines will contain an updated copy of authorization, permits or licenses.

• The locks on magazines will be rotated per regulatory standards.

• Bills of Lading (BOL's) and packing lists shall be kept in a secure location for the specified minimum period of 5 yrs.

• All explosives, detonators, and accessories will be transported in accordance with statutory regulations.

Priming

The purpose of this section is to insure that detonators and primers are handled safely and usage matches blast design. This will allow for proper accounting of detonators and primers prior to loading.

• All holes will be taped for depth and water level before priming. Blaster in Charge will be notified of any significant variance from expected measurements before the hole is primed.

• The blast site will be secured with yellow, green, or orange (jobsite specific) cones and warning signs will be used to block all accesses to the blast pattern to be primed and loaded.

• Explosives products will be laid out in a careful, efficient and well-coordinated manner (between holes, on the outside of the cuttings pile and out of the flow of traffic).

• Primers will be assembled only at the hole collar and will immediately be carefully lowered into the hole.

• All detonators will be fully enclosed within the booster according to the manufacturer’s recommended procedures.

• A anchor system should be used to secure down lines into position at the surface.

• An inventory of boosters and detonators will be done in the field, at each blast pattern and verified against the blast plan map. The Blaster in Charge will cross check the detonator inventory after the products are laid out to insure that the amount used matches the number of holes on the pattern.

Loading

The purpose of this section is to insure that holes are loaded per the blast design and that problems that arise during loading are dealt with appropriately.

4

• The loading trucks will wait to load holes until they have enough holes primed to empty a

truck or continuously load.

• The powder column rise of each hole will be continuously monitored until the stem height is reached or the appropriate weight of explosives is loaded. Any deviation from expected column rise over a set amount during loading will be immediately brought to the attention of the Blaster in Charge.

• Loading personnel will know the upper weight limit of product to be loaded and the planned stemming height of each hole.

• Interruptions in the loading process will be documented and communicated to the Blaster in Charge.

• All loading trucks will be parked off the pattern after loading is finished.

• Explosives transport trucks will not be left unlocked with explosives on board. They will be relocked immediately after unloading.

• Weather forecasts will be evaluated prior to each blast for chances of thunderstorms and lighting strikes. Continuous lighting detection will be done through use of an approved system. The detector can alert blasting personnel of lightning strikes up to 40 miles away, and if necessary allow for evacuation of personnel from the blast area.

Stemming

The purpose of this section is to insure that stemming activities are done in such a way to eliminate cut down lines, “bridge overs” and help identify problem holes.

• The recommended stemming material and equipment is: o Clean crushed gravel as specified in the definition of stemming

o Side-dump articulating loader

• The stemming process will not begin until after all the holes are primed and the loading is

far enough ahead so that stemming activities will not interfere with the loading process.

• Stemming material shall be strategically placed at the blast site using a spotter.

• Detonator down lines will be positioned to eliminate damage.

• Down lines will be secured prior to stemming.

• Stemming material shall be carefully poured down blast holes to eliminate down line damage and control dust.

• Stemming operators should safeguard against oversized material being accidentally introduced down blast holes.

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• Stemming operators must be properly trained in procedures used in case of a lost, cut or

damaged down line.

• Stemming operators shall inform the Blaster in Charge of any problem holes.

• The Blaster in Charge must address and ensure that any and all “problem holes” are reported on the Blast Summary paperwork. Unloaded or “bad” hole information should be included as well.

Tie-in

The purpose of this section is to ensure detonation of all holes in the blast pattern and proper timing of all holes.

• The Blaster in Charge shall generate a tie-in sequence diagram of every blast hole.

• This diagram will be included with the other blasting documentation required from the daily blasting activities.

• The Blaster in Charge shall review the sequence diagram with personnel doing the tie-in.

• Tie-in of pattern shall begin only if it will not interfere with other blasting unit processes or cause distractions to those tying in.

• A shift supervisor and\or shot blockers should be notified at least 30 minutes prior to completing tie-in so that shot blockers can prepare for the pre-blast meeting.

Pre-blast Meeting

The purpose of this section is to insure that all personnel involved in the clearing and initiation of a blast are clear about their assignments, properly equipped and know their responsibilities.

• The pre-blast meeting will include all blockers and sweepers and will be face-to-face.

• The Blaster in Charge will conduct the meeting.

• Each blocker and sweeper will receive their assignment in the meeting and the Blaster in Charge will ask them to repeat back their assignment and their responsibilities.

• All blockers will remain at the meeting until the meeting is over.

• All vehicles used for clearing and blocking will be equipped with a functional two way radio and functioning beacons and /or flashers.

• If vehicles are not used for blocking, a person with a flag, radio and cones is acceptable.

Securing and Holding Blocking Position

The purpose of this section is to insure that blocking positions are never compromised and clear, concise communication is maintained between the Blaster in Charge and each blocker.

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Securing and holding of blocking positions will be directed by the Blaster in Charge.

Blockers will:

• Will be trained and the trained to necessary standards and the training documented

• Drive to assigned blocking location

• Turn vehicles or equipment used for blocking perpendicular to the flow of traffic (if vehicles are used).

• Use cones to block the road.

• Have contact with the Blaster in Charge via radio.

• Communicate to the Blaster in Charge, in detail, actions taken to clear the area and the blocking position is secure.

• Not permit entry to the secured area by anyone without permission of the Blaster in Charge

The Blaster in Charge will:

o Prior to pre-blast meeting determine blocking locations and place a cone at each location. This is to mark the blocking location NOT to block the road.

o Maintain a blocker check list and use it to verify completion of assignments. o Ensure each Blocker is properly positioned prior to the last blast warning. o Instruct each blocker to hold their position if a delay occurs.

Clearing Blast Area

The purpose of this section is to insure that the blast is properly cleared and that all affected personnel are notified.

• Clearing for a shot will be directed / supervised by a Blaster in Charge.

• Clearing an area for a blast will begin at the blast site and proceed outward.

• All affected personnel will be notified prior to clearing to allow for orderly preparation and evacuation of the blast area.

• All affected equipment will be positioned or relocated to a safe position to minimize damage from fly rock or blast vibration.

• All equipment in the blast area will be physically cleared of personnel.

• During clearing, all entries previously cleared will be guarded to prevent re-entry into the cleared area.

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• Those clearing for a shot must be approved by the Blaster in Charge.

Blast Initiation

The purpose of this section is to ensure the blast area is clear and that all blocking positions are secure.

• Blast initiation will be directed/supervised by a Blaster in Charge

• Blast initiation will take place from a location safe from hazards resulting from blasting.

• The blast initiation location will be a safe distance from electrical interference (e.g. power lines, power cables, radios)

• The firing/initiation system will be enabled AFTER all clearing and blocking activities are finalized.

• The firing/initiation system will be in the possession of the blasters and under control of the Blaster in Charge at all times.

• The firing/initiation system will be connected by the Blaster in Charge or a person under his/her direct control.

• Two-way radio communication between the Blaster in Charge and all blockers will be maintained throughout the clearing, blocking and initiation processes.

• Blasting personnel will be competent in safe practices in the event that a blast fails to detonate.

Radio Procedures & Countdown

• Blaster in charge posts security at necessary locations with Radio Communications

• Blaster Announces “Attention all personnel on PROJECT NAME, This is the blaster in charge. We are five minutes from the blast. All personnel maintain radio silence until the all clear signal following the blast has been sounded or an actual emergency exists and announce CEASE FIRE.”

• Sound Five Minute sound warning & wait 3 minutes.

• Blaster Announces “2 minutes to Blast.”

• Sound 2 Minute sound warning & wait 1 minute

• Blaster Announces “1 minute to Blast.”

• Blaster Checks with all security positions to verify “All Clear” from each position & sound yelp siren (keyed over microphone).

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• Blaster Announces “Attention PROJECT NAME personnel, we will be blasting in 10, 9, 8,7,6…(5 Second Pause in case of a Cease Fire).. Fire in the Hole!”

• Fire Shot

• Blaster Announces “All personnel remain at your positions until the all clear has been sounded.”

• Inspect Shot

• Blaster Announces “All Clear, All Clear.”

Post Blast Inspection

The purpose of this section is to ensure that the blast holes have been detonated and the area is safe for reentry.

• A post-blast inspection will be performed by the Blaster in Charge once all dust, and dangerous fumes are no longer present.

• All blockers will remain in place during the post-blast inspection.

• Cones will demarcate the blast site until the post-blast inspection is complete and the Blaster in Charge gives the “all clear”.

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Misfired Hole

The purpose of this section is to insure that personnel involved in the blasting process are trained to recognize a potential misfire and are familiar with dealing with a potential misfire.

• All blasting personnel will:

o Know the definition of a misfire

o Be familiar with the blasting products used

o Be familiar with what a misfire looks like and how to determine if there is a misfire.

o Be familiar with the waiting period for a suspected misfire.

• There will be systems in place to:

o Document misfires and handle them properly

o Mark misfires in the field in an easily recognized manner

o Follow up on and investigate if there was a misfire and determine the cause

o Develop action plans to deal with misfires including SOPs

o Enter the misfire into shovel/loader computer GPS systems if used to alert shovel and loader operators of the location

o Familiarize pit personnel with the SOPs for handling a misfire

• A safety session on unfired powder column and blasting component recognition will be part of the pre blast safety meeting.

Sleeping/Guarding a Shot

The purpose of this section is to ensure shots slept overnight are safely managed.

• A procedure will be developed for sleeping a shot.

• Shots will be slept overnight only in extraordinary circumstance.

• Shots slept overnight will be guarded or barricaded to prevent unauthorized access to the blast pattern.

• In the event of an approaching electrical storm, The Blaster in Charge or a designated shift supervisor will be responsible for clearing the blast area in the same manner as clearing for a shot.

• The Blaster in Charge or a designated shift supervisor will determine when activities may resume within the blast area.

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Record Keeping

The purpose of this section is to ensure accurate records are kept as required by regulation.

• Daily Magazine inventories transactions shall be recorded for all blasting products checked out and unused product checked back in (verification required).

• Magazine physical inventories shall be checked for accuracy at least once per month and verified by supervision. Any discrepancy shall be immediately investigated.

• A yearly close out and starting inventory will be taken and maintained as part of the permanent records required by the regulatory agencies (verification required).

• Each site shall maintain daily blasting documentation (Blast Summaries) that contain information such as load amounts, blast diagrams, timing configurations, “bad” or “problem” holes, and other “out of the ordinary” or pertinent information.

• Licensees and permit holders must keep all records pertaining to explosives, in permanent form, for not less than 5 years.

• License and permit documentation shall be kept current and displayed in conspicuous areas.

• Records of Employee Possessors and Responsible Persons must also be maintained and updated as needed.

A yearly close out and starting inventory will be taken and maintained as part of the permanent records required by the regulatory agencies (verification required).

• Each site shall maintain daily blasting documentation (Blast Summaries) that contain information such as load amounts, blast diagrams, timing configurations, “bad” or “problem” holes, and other “out of the ordinary” or pertinent information.

• Licensees and permit holders must keep all records pertaining to explosives, in permanent form, for not less than 5 years.

• License and permit documentation shall be kept current and displayed in conspicuous areas.

• Records of Employee Possessors and Responsible Persons must also be maintained and updated as needed.

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Preliminary Blast Site SOP

Attachment 1 – Preliminary Transportation Standard Operating Procedures

Explosives Vehicle Drivers shall ensure:

• Proper placards visible in all four directions.

• Day boxes that are securely fastened to the vehicle or confined within the vehicle body to prevent spillage.

• Day boxes with explosives shall be locked in transit and on the pattern when product is not being unloaded.

• Vehicle loads that are within the rated vehicle carrying capacity.

• Non-sparking materials for container lining and fasteners.

• No other materials transported with explosives.

• Detonators transported on the same vehicle as explosives shall be placed in IME standard boxes.

• Vehicles will be equipped with two 20 pound multipurpose dry fire extinguishers.

• The volume and quantity of explosives shall not exceed the limits established by regulatory authorities.

• Means to control of inventory of explosives will be established.

• All working magazine areas shall be made secure with either a lockable gate and fence or lockable storage box for explosives, which will meet the requirements of the applicable agency.

• All magazines shall be designed to prevent vehicle impact to the magazine.

• The magazines shall be located in a proper manner to control surface drainage.

• Explosives refuse (empty boxes) shall be inspected, broken down and disposed of properly.

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Preliminary Blasting Site SOP

Attachment 2 – Preliminary Competency and Training

All employees who participate in drilling, sampling, blasting or support blasting activities shall be trained to effectively perform their duties. This training shall be documented. Sites will develop a list of required skills and evaluate individuals to verify they are competent prior to participating in or supporting blasting activities. The skills shall include:

• Staking drill holes

• Duties of Responsible FCX Employee

• Duties of a lead blaster

• Duties of a sampler

• Conducting a pre-loading site inspection

• The identification of unique hazards for blast patterns

• Hole loading practices for routine and non-routine holes

• Magazine inventory control

• Safe transport of explosives

• Field inventory control

• Inventory reconciliation

• Guarding a shot overnight

• Establishing evacuation areas for blocking

• Effective blocking for a blast

• Post blast inspections

• Managing misfires or discovered explosives

APPENDIX A-2

Production Explosives and Blasting SOP

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Standard Operating Procedure for Explosives and Blasting Management at the Rosemont Project

Purpose Mitigation requirement FS-HM-01 of the Rosemont Copper (Rosemont) Project Final Environmental Impact Study (FEIS) states that Rosemont will develop an explosives and blasting management procedure to ensure that best management practices are applied. This mitigation involves handling, storage, use and communication information about hazardous materials, in accordance with applicable laws and regulations as listed in Attachment 1. Attachment 2 contains required reporting. This document is incorporated in the Mine Plan of Operations (MPO) in fulfillment of that mitigation requirement. Summary Rosemont’s mining operations will be conducted on a 24 hours/day, 7 days/week, and 365 days/year schedule. Blasting operations will be limited to day shift whenever possible in accordance with required laws and permits. Rosemont will contract a licensed, insured and experienced contractor to perform their shot service, including a ”Blaster-In-Charge”, who will report directly to a “Responsible Rosemont Employee”, or his designee. The selected blasting contractor will hold all applicable Federal, State, and local licensing to operate. In accordance with the shot service contract, the blasting contractor will be responsible for installing and maintaining the storage magazines and bulk handling facilities, ordering, delivery and inventory of bulk and packaged blasting products, equipment and personnel to load and shoot the designated blast pattern, address misfires as well as performing all required reporting and record keeping. Rosemont personnel will be responsible for drilling the blast holes and communicating with the blasting contractor’s Blaster-In-Charge regarding the blast objective, what products are to be used and how the blast sequence will be initiated as well as other pertinent information. Rosemont personnel will be responsible for clearing and securing the blast area for initiation as well as overseeing misfire procedures. Rosemont will coordinate with the blasting contractor to develop, update and communicate to all appropriate personnel, Standard Operating Procedures (SOPs) for safe handling, storage, use and communication regarding explosives and blasting. Likewise, the delivery of blasting related products including explosives will be subcontracted to a licensed trucking company who will operate under their Department of Transportation (DOT) permit. Rosemont and its subcontractors will each operate under the authority of their respective MSHA ID numbers and Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) licenses and permits. Definitions

Responsible Rosemont Employee – Drill and Blast Supervisor or his designee, who is a qualified direct employee of Rosemont. This definition does not include contract blasting personnel.

Blast Site – The area where explosive materials are handled during loading including the perimeter formed by the loaded blast holes and 50 feet in all directions from loaded holes. A minimum distance of 30 feet may replace the 50 foot requirement if the perimeter of loaded holes is marked with a barrier.

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Blast Area – The area in which concussion, flying material or gases from an explosion may cause injury to persons.

Mobile Manufacturing Unit (Dry Hole Truck) – Truck that delivers separate components from on-site storage facilities to the blast site, where ammonium nitrate / fuel oil (ANFO) is manufactured immediately prior to loading into each dry blast hole.

Mobile Manufacturing Unit (Wet Hole Truck) – Truck that delivers separate components from on-site storage facilities to the blast site, where emulsion is manufactured immediately prior to loading into each wet blast hole.

Explosives Transport Truck (Powder Truck) – The vehicle that carries blasting accessories.

Dewatering Truck – The vehicle that contains a submersible pump capable of pumping water out of select wet holes, so that they may be sleeved with water resistant liners and loaded with ANFO based products

Stemming – Material placed in blastholes once the blasting products have been loaded. This material serves as a plug to contain explosive energy within the blasthole during detonation. Refers to rock crushed to 80% 1 inch to 1 ¼ inch with a maximum size of 2 inch. Depending on crushed rock availability, drill cuttings might be used for stemming.

Misfire – Complete or partial failure of explosive material to detonate.

Direct Control – Having face-to-face contact to ensure clear and concise communication.

Sweeping/Clearing – The process of ensuring all personnel are removed from the blast area prior to detonation.

Product Selection Rosemont expects to drill 10 5/8” or 12 ¼” diameter blast holes on a normal production pattern depending on rock hardness and geology with bench heights of 50 feet. It is anticipated that the majority of the blast holes will be dry or able to be pumped out and/or sleeved in order to use ANFO. If the holes are too wet or more energy is required to achieve the desired objective, various blends of ANFO and emulsion will be employed. Industry accepted blast design software will be used in conjunction with Rosemont’s mine design packages to assign electronic blasting sequences for each shot utilizing state of the art programmable electronic Detonators, Loggers and Blasters. Generally, each blast hole will be double primed, i.e. top and bottom, for added insurance of complete detonation. The timing sequence will be coordinated between the Responsible Rosemont Employee and the blasting contractor’s Blaster-In-Charge. Product Delivery Ammonium Nitrate Prill and Unsensitized Emulsion: The blasting contractor and their designated trucking contractor are responsible for delivering all blasting related products to the site in accordance with all federal and state regulations. Bulk

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ammonium nitrate prill and ammonium nitrate solution will be delivered to the site via semi-tractor trailers hauling a nominal 50,000 lbs. As these products are oxidizers and not explosives, the trucks will be identified as hauling hazardous materials. The owner of the truck will be registered with the USDOT as required by 49 CFR Part 107, subpart G. All drivers are required to be trained in accordance with 49 CFR, DOT Hazardous Materials transporting and unloading of bulk chemicals, and will use appropriate personal protective equipment. When arriving at the main gate, the trucks will weigh in and be directed to the bulk storage area for unloading. When finished unloading the delivery truck will return to the main gate and weigh out. Explosives All explosives in the form of stick powder, detonating cord, detonators and boosters will be transported from the manufacturer’s/supplier’s off site facility to the mine site in approved, licensed transports displaying appropriate explosives placards. These deliveries will normally occur during daylight hours only. The owner of the truck will be registered with the USDOT as required by 49 CFR Part 107, subpart G. Truck drivers will be trained in accordance with 49 CFR, DOT Hazardous Materials unloading of explosives. Drivers will carry applicable MSDS sheets and the names of (ATF certified employee) persons who can accept delivery as well as required personal protective equipment. Both the blasting contractor’s personnel and Responsible Rosemont personnel will be authorized to accept deliveries and serve as the Mine Contact person. Explosives Delivery Procedures

The driver will call the Mine contact with ETA 30 to 60 minutes before delivery.

Upon arrival, the driver will check in with Security at the main gate and wait for the Mine contact to arrive and escort him to the magazines.

At the magazine the Mine contact will receive and verify the delivery paperwork and witness the driver breaking the seal on the truck.

The driver will then be directed where to store the products.

The driver will inventory the delivery as it leaves the truck and the Mine contact will inventory the product as it enters the magazine ensuring that the Magazine Inventory log is updated accurately.

Upon completion of unloading, only the Mine contact person is authorized to sign for the delivery.

The driver is then escorted back to the main gate where he will sign out. Product Storage (Magazines) Separate magazines will be provided for explosives (powder) and detonator storage as described in section 3.5.8 of the MPO and in accordance with CFR Title 27 Chapter II, Part 555, Subpart K (ATF) and 30 CFR Part 56, Subpart E – Explosives (MSHA). The powder magazine and detonator magazine will be separated by 50-100 feet with intervening separation berms.

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The location of the magazines will be directly south of the ultimate pit limit and west of the Upper Barrel waste rock storage area. This area is remote, and is shielded on the west by the ridge of the Santa Rita Mountains, on the south and east by the waste rock storage area, and on the north by the pit. Access to the fenced compound will be by the mine haul road running southwest from the primary crusher between the open pit and the waste rock storage area. The blasting contractor will be responsible to inventory, order, deliver and store all bulk and packaged blasting products (on a consignment basis). The blasting contractor will be solely responsible for removing and using blasting products, returning unused products to the magazines and maintaining all product usage records.

Maintaining Inventory - The blasting contractor shall follow all of the regulations set forth by ATF as referenced in Appendix A of this document. All inventories will be kept accurately and a copy of the inventory records will be in the magazine and available at all times for review by ATF, MSHA, Arizona State Mine Inspectors and Responsible Rosemont Employees. A Responsible Rosemont Employee will cross check detonator and booster usage against inventories.

Safe Handling of Explosives - While explosives are in storage, they will be stored according to the appropriate regulations. When new shipments are received, the inventories will be rotated using the oldest supplies first. Stack the boxes up to an acceptable level that meets the regulatory compliance but never exceed a height of more than eight feet.

Magazine Inspections - The blasting contractor shall inspect their magazine(s) every day they remove items or at least every seven (7) days to ensure no attempt to break into the magazine has occurred. Additionally, an annual inventory is required by law to be taken and documented in the records.

Magazine Security - Magazine doors shall be attached with hinges that are welded, riveted or bolted with the nuts on the inside of the door. Two mortise locks or two padlocks will be used in separate hasps. Padlocks will be five-tumbler or five-blade. Padlocks will be protected with no less than ¼-inch steel hoods constructed so as to prevent sawing or lever actions on the locks, hasps, and staples.

Housekeeping - The inside of the magazine(s) shall be kept clean, dry, and free of excessive dirt, paper, empty packages and containers, and rubbish. Brooms and other cleaning utensils shall have non spark-producing metal parts. The area outside the magazine(s) shall be kept clear of rubbish, brush, dry grass or trees less than 10 feet tall for not less than 25 feet in all directions. Any other combustibles shall be kept a distance of not less than 50 feet from the magazine.

Product Storage (Ammonium Nitrate and Wet Hole Product Components) Elevated ammonium nitrate silos, with a combined capacity of 180-200 tons, and un-sensitized products to manufacture emulsion (at the blast site itself) will be located at the blasting contractor’s office complex on site to the south of the pit. The dry hole trucks will not mix ammonium nitrate and diesel until ready to be placed in blast holes. Likewise, the wet hole truck will not mix ingredients together until immediately before pumping into the blast hole. Diesel will be provided by Rosemont in the mine area but away from the ammonium nitrate silos and wet hole product storage.

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Pre-Shift Team Meeting A pre-shift team meeting will be held by blasting crews each shift. The pre-shift meeting shall include the following:

Work locations

Unique or continuing hazards

Equipment needed for the assigned work

Hole specific loading instructions for a pattern (water, hardness, product, etc.)

Identification of parties for communication and any unique work being done in areas adjacent to the blast site

Preliminary blocking locations

The anticipated time of the blast

Identification of the Rosemont responsible person and the blaster-in-charge

Any other pertinent information Explosives Transport Truck – (Powder Truck) This truck used to transport explosives must be well-maintained, clean, free of grease, and vented in accordance with all US Dept. of Transportation and MSHA regulations. Such vehicles must carry two multi-purpose dry-chemical fire extinguishers or one such extinguisher and an automatic fire suppression system, possess no spark-producing materials in the cargo space, and only transport persons directly involved with the blasting operations. Signs warning of explosives content must be posted on all sides of the powder truck.

When parking the powder truck containing explosives:

o The brakes must be set.

o The wheels must be chocked to prevent movement, and

o The engine must be turned off, unless it is powering equipment used in the loading process.

Explosives and detonators can be transported together if they are separated by 4 inches of hardwood or their equivalent. If a vehicle used for explosives transport must be sent for repair or maintenance, all explosives and blasting agents must be removed from the vehicle, and the vehicle and all components in contact with explosives or bulk agents thoroughly washed to remove all traces of agents or explosives. All blasting contractor employees will follow their company’s SOP for operating the Powder Truck.

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Procedures for Priming a Blast Hole All blasting contractor employees will follow their company’s SOP for priming a blast hole (shown below) as well as manufacturers’ recommendations.

1. General: When the blasting cap is placed in the cast booster, the assembly is then

considered a primer. The sensitivity of the blasting cap and the explosive power of the cast booster combined can create a potentially significant hazard.

Caution: Handling a primer can create an explosion hazard. A Job Hazard Analysis (JHA) must be performed and documented prior to preparing any primers.

2. Preparing a Primer: All cast boosters contain an axial tunnel that runs the length of

the booster. In addition, the booster also contains cap well(s) that run part way through the booster. The blasting cap shall be placed through the axial tunnel and then inserted into the cap well(s).

If a cast booster is damaged (generally by the deformation of the cap well), the date code and lot number for the cast booster shall be recorded. If a detonator is bent or damaged and will not fit into the cap well, the date code and lot number of the detonator shall be recorded. Cast boosters or detonators with any deformation shall have details recorded and forwarded to blasting contractor’s technical support for review.

Never force a blasting cap into a booster cap well.

o Cast boosters have either one or two cap wells.

Once the primer(s) are assembled, immediately lower them down the blast hole.

3. Priming blast holes that contain water: In blast holes that contain water and require the

use of an emulsion blasting agent, the primers must be weighted down to prevent the primer from floating up the powder (emulsion) column as the product is loaded into the blast hole. Follow site specific criteria to accomplish the task of weighting down the primer(s).

Caution shall be taken NOT to lower the primer on the bottom of the blast hole where mud is possible.

4. Placing the primer at the correct location in the blast hole: Determine the depth at

which the primer is to be placed into the blast hole, and lower the primer(s) down into the blast hole. Ensure the primer(s) are placed as accurately as possible. This will help in the recovery/remediation effort in case of a Misfire. The Blaster-In-Charge will determine the proper placement of the primers.

5. Anchoring of down line: Once the primer has been placed in the assigned location in

the blast hole, the down line shall be tied to a stake. Ensure the primer is securely fastened to the stake so the primer does not slip off the stake and fall into the blast hole when the blasting agent is being loaded.

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Loading and Transporting Ammonium Nitrate Prill to the Blast Pattern

Operating a Dry Hole Truck All blasting contractor employees will follow their company’s SOP for operating a Dry Hole truck (shown below).

1. A complete Pre-Shift Inspection and a Job Hazard Analysis must be conducted and the appropriate documentation completed. All components of the vehicle must be inspected prior to moving the truck.

2. Loading Ingredients into a Dry Hole Truck: The truck shall be pulled under the prill

bin (silo) in a manner so the discharge chute from the prill bin is aligned with the front bin of the truck. The operator will put on a harness and hook to the retractable lanyard, then ascend up the ladder to the top of the truck.

o All employees are required to wear a full body harness and be tied off when on top of any blasting contractor’s equipment.

o Prior to ascending onto the top of the vehicle, the operator shall chock the

wheels.

o When ascending up or down the truck ladder, the employee must maintain three points of contact at all times to reduce the potential of a trip or fall hazard.

Open the lid of the first prill bin and then open the discharge chute to begin loading prill into the Dry Hole truck. Once the first truck bin is full, close the door or gate to the prill bin, descend from the top of the truck, pull it forward and repeat the process until the other bins are loaded.

CAUTION: During certain times the prill may present dusty conditions. During those times it is recommended that employees wear a respirator as part of their personal protective equipment.

3. Driving Dry Hole Truck to the Blast Pattern: The operator shall drive to the blast

pattern using existing haul roads and drive according to traffic and weather conditions. Prior to entering any mine haul road, the truck driver must notify dispatch of their location and destination. Care must be taken, when driving around haulage equipment which has a large area of restricted vision from the equipment operator.

o Obey ALL signs and traffic controls o Maintain mine site radio frequency at all times

4. Drive Dry Hole Truck onto Pattern and align with Blast Holes: The operator shall

note all individuals, equipment, power cables, explosives products, and rough ground prior to pulling onto the blast pattern.

The blast pattern should be loaded in a logical manner dictated by the Blaster-In-Charge. The truck operator must confirm with the Blaster-In-Charge which holes are to

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be loaded with what product and the required stem height for all holes on the pattern. Every hole shall be taped prior to and during the loading process to ensure the proper amount of blasting agent is placed in the hole.

5. Operation of the Dry Hole Truck when loading blast holes: Align the truck down the first row of the pattern to be loaded. Begin loading the correct blasting agent into the blast hole until the powder (blasting agent) column has reached its assigned stem height. Once the stem height has been reached, the operator shall turn off the product and record the correct total pounds pumped into the Digital Blast Logger (DBL). Raise the drop hose over the drill cuttings, and move to the next dry blast hole to be loaded. Repeat these steps on every hole on the pattern that requires dry product. In many cases this will require several truckloads to finish the pattern. During the loading process, continually check the calibration. Make sure the fuel and additive (if any) (This is referred to as the calibration sheet) counters are correct to the proper formula of the product. Every production blast hole loaded with dry hole product must be taped to be sure the powder column rises to designed stem height.

o The only holes that will not be taped during loading are finals/zipper row as typically these holes will only contain 50-100 lbs of explosives. After loading this small amount of explosives these holes need to be inspected by pulling on the cords, to ensure the primers are ”locked” in the powder column prior to dropping an air bag or stemming.

Be aware of holes with voids, cracks or old underground workings that may consume excessive blasting agent. In these cases, corrective action such as adding a gasbag or sleeve prior to loading may be necessary.

o If a blast hole does not rise properly, the blasting contractor’s operator must notify their supervisor immediately.

o If any product spills on the drill cuttings, every effort should be made to place the product into the blast hole prior to stemming.

6. On the last hole of the pattern to be loaded, ensure that the stem height is lowered to

allow clean out of the hose and vertical augers. A good rule of thumb is to stop four feet from stem height depending on the dimension of the blast hole. Clean out the augers by turning off the main auger and allowing the vertical and overhead to run until empty. This ensures no blasting agents are in the augers of the Dry Hole Truck when the truck leaves the blast pattern. After the auger clean out procedure, saddle the auger and hose and disengage the PTO.

7. Dry Hole Truck Clean up: At the end of every daily use, clean out the cab of the truck.

Wash the truck at the wash bay located near the bulk silos. Thoroughly wash the body of the truck to ensure you will be able to see any leaks on the truck during the pre-shift inspection the following day.

Loading and Transporting Wet Hole Ingredients to the Blast Pattern

Operating a Wet Hole Truck

All blasting contractor employees will follow their company’s SOP for operating a Wet Hole truck (shown below).

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1. A complete Pre-Shift Inspection and a Job Hazard Analysis must be conducted and appropriate documentation completed. All components of the vehicle must be inspected prior to moving the truck.

2. Loading Ingredients into a Wet Hole Truck: The Wet Hole truck should be pulled

under the loading tower in a manner so the fill hoses line up with the solution loading port. If the loading stand does not have an overhead loading stand or railing, a harness must be used to ascend to the top of the truck. The lanyard must be connected on top at the engineered tie-off points.

o Wheel chocks need to be placed unless a permanent parking ditch is located at the loading stand.

o When ascending up or down the truck ladder, the employee must maintain three

points of contact at all times to reduce the potential of a trip or fall hazard.

Place the appropriate fill hoses into the appropriate tank openings. Turn on each of the ingredients and fill the tanks. When all the tanks have been filled, the operator shall turn off or shut the valve for the ingredients and blow out the solution hoses with air.

Caution shall be taken to ensure no tanks are over filled. Overflow of tanks can create a slip hazard on top of the truck and possible release of contaminates onto the ground.

All spilled product must be cleaned up immediately and placed in the covered containers provided.

3. Driving the Wet Hole Truck to the Blast Pattern: The operator shall drive to the blast pattern using existing haul roads and drive according to the traffic and weather conditions. Prior to entering any mine haul road, the truck driver must notify dispatch of their location and destination. Care must be taken when driving around haulage equipment, which has large areas of restricted vision from the view of the operator. Care must be taken when turning a fully loaded Wet Hole Truck as the liquid can shift creating a problem with the stability of the vehicle.

o The liquid can potentially cause the vehicle to turn over on its side, on sudden turns on ramps.

When Wet Hole Trucks are driven up or down ramps, the operator shall drive in a safe and correct gear. At no time shall an emulsion truck be operated in a higher gear while driving up or down a ramp.

o Prior to descending down a ramp the engine brake must be engaged depending on weather and road conditions.

4. Driving the Wet Hole Truck onto the Pattern: First locate all individuals, equipment,

power cables, explosive products, and identify any rough ground prior to pulling into a blast pattern. A JHA must be filled out and documented prior to loading any blast holes. The blast pattern should be loaded in a logical manner dictated by the Blaster-In-Charge. The Wet Hole Truck operator must confirm with the Blaster-In-Charge as to which holes are to be loaded with emulsion, the pounds to be loaded and the required stem height.

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o Prior to lowering the emulsion hose into the blast hole, the hose needs to be primed. Approach the first blast hole and preset the volume of fuel, M.D., and the desired speed control of the solution pump. Lower the hose to the top of the ground near the blast hole turn on the ingredient switch and moyno pump until good product begins to flow out the end of the hose. Any emulsion that is pumped on to the ground must be shoveled into a blast hole prior to stemming.

o The hose shall be placed above the top of the blast hole that will be loaded and material pumped into the hole until good product begins to flow out the end of the hose. At this time lower the emulsion hose down to the bottom of the blast hole and begin loading until the desired stem height or maximum pounds allowed is achieved.

o Always lower your tape prior to loading any blasting agent. o Use caution while the product is being pumped out of the loading hose. Care

must be taken to be sure the emulsion hose and the primer do not become entangled.

5. After priming the hose, once the emulsion hose is down to the bottom of the blast hole

a 50 ft. tape will be placed down the hole to check the powder column rise to the correct stem height. Once the correct amount of product or stem height has been reached, turn off the ingredient switch and moyno pump. Engage the hose wiper and begin reeling the loading hose up and out of the blast hole along with the tape. The hose wiper will ensure that emulsion will not spill on the ground as the truck moves from hole to hole.

o Care must be taken to limit the amount of the emulsion product that is spilled on the collar of the blast hole. Any spilled emulsion must be shoveled into the hole prior to stemming.

o A minimum of 20 minutes is recommended to allow the product to gas properly, prior to stemming the blast hole.

o The only holes that will not be stemmed are finals/zipper row but these holes need to be inspected by pulling on the cords, to ensure the primers are “locked” in the powder column prior to stemming the blast hole.

o The operator shall record the appropriate hole information and load criteria into the Digital Blast Logger (DBL) or onto a loading sheet.

If the powder column does not rise to the correct stem height, the operator must contact his supervisor immediately.

After ensuring the area is cleared of any personnel or equipment, the truck should be moved to the next emulsion hole in the row and repeat the procedures of loading any blast holes remaining on the pattern.

If blast holes are located in a reactive/hot area (Sulphide ore), these holes shall be primed and loaded at the very end of the loading process in accordance with the blasting contractor’s SOP for loading hot holes.

6. On the last hole to be loaded, the loading hose must be washed out by following the proper clean out procedure as outlined in the blasting contractor’s SOP.

7. Wash down the emulsion hose, reel and deck of the Wet Hole Truck prior to leaving the

pattern when possible to eliminate any possible ground contamination at the plant site.

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Stemming the Blast Holes All blasting contractor employees will follow their company’s SOP for Blast Hole Stemming.

1. As with all equipment, a Pre- shift inspection and a Job Hazard Analysis must be performed during a walk around prior to operating the equipment.

2. Once arriving at the blast pattern, a Job Hazard Analysis (JHA) must be completed.

The loader will be parked in a safe area with the bucket on the ground, parking brake set and wheels chocked. Make sure the loader “battery switch” is in the OFF position when stationary.

3. Checking the down lines: Once the blast holes have been loaded with a blasting agent, they can be stemmed. The employee stemming the blast holes should check all down lines in zipper and presplit holes before starting the stemming process. This involves pulling on the down line(s) to insure the primers are “locked” in the powder column and securely anchored on the surface. The employee shall also make sure all the blast holes have been completely loaded. Communications with the Dry and Wet Truck operators is also important prior to stemming blast holes. Stemming material will generally be crushed stone; however, in some circumstances it may be necessary to use drill cuttings if approved by the Blaster-In-Charge.

4. Placing stemming material in the blast hole: Whether the operator is using provided crushed stone stemming material or the blast hole cuttings, he must align or position the loader bucket with the blast hole to ensure the stemming materials fall into the blast hole away from the down lines.

o Always be cautious of blasting accessories placed on the blast site. o Always be aware of all people and equipment on the pattern prior to moving the

loader from hole to hole. Always maintain safe working distance from other equipment.

o If possible, tend down lines and make sure the employee on the ground is in the operator’s view.

o Care must be taken to limit the amount of material falling directly onto the down lines as this can create potential serious damage.

o Be sure the bucket does not pinch or scrape the down line. o Wear appropriate personal protective equipment while tending down lines.

5. Placing crushed rock in the blast hole: When stemming with crushed rock placed

within the pattern, the operator needs to ensure the pile is not covering any explosive product. The operator will also take the time to inspect the material to ensure there are no oversize rocks that could damage the down lines during the stemming process. The operator should approach the stemming pile with the bucket of the loader near the ground. Once the bucket is full of material the operator should tram the material to the blast hole.

All ground employees are to be positioned away from bucket and shall maintain safe working distance from the loader.

6. If any down lines are cut or potential misfire detected, make sure the Blaster-In-Charge is immediately notified to determine the appropriate methods or precautions to

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be taken. Refer to the (Misfire) SOP for guidance if you are not familiar with the procedures

o Always follow mine site procedures on reporting a possible problem hole or misfire.

Tie-in The purpose of this section is to ensure detonation of all holes in the blast pattern and proper timing of all holes.

The Responsible Rosemont Employee shall generate a tie-in sequence diagram of every blast hole.

This diagram will be included with the other blasting documentation required from the daily blasting activities.

The Responsible Rosemont Employee shall review the sequence diagram with the blasting contractor’s Blaster-In-Charge.

Programmable electronic Detonators, Loggers and Blasters will be utilized. Tie-in of pattern shall begin only if it will not interfere with other blasting processes. When using programmable delays, the blasting contractor will use the logger tests

to verify hook up reliability. Detonator count will be obtained from the data logger and a check made against the

field inventory recorded on the Blast Summary (adjusted for “bad” or extra detonators used if necessary). Any discrepancy must be reported to the Responsible Rosemont Employee and rectified before moving into the blast initiation stage.

A Rosemont shift supervisor and/or shot blockers should be notified at least 30 minutes prior to completing tie-in so that shot blockers can prepare for the pre-blast meeting.

Pre-Blast Meeting The purpose of this section is to insure that all personnel involved in the clearing and initiation of a blast are clear about their assignments, properly equipped and know their responsibilities.

The pre-blast meeting will include all blockers and sweepers (Rosemont personnel only) and will be face-to-face.

The Responsible Rosemont Employee or his designee will conduct the meeting. Each blocker and sweeper will receive their assignment in the meeting and the

Responsible Rosemont Employee will double check their understanding of the assignment and their responsibilities.

All blockers will remain at the meeting until the meeting is over. Orange cones will be provided for each blocking position. All vehicles used for clearing and blocking will be equipped with a functional two

way radio and functioning beacons and /or flashers. If vehicles are not used for blocking, a person with a flag, radio and orange cones is

acceptable.

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Clearing Blast Area The purpose of this section is to insure that the blast area is properly cleared and that all affected personnel are notified.

Clearing for a shot will be directed / supervised by the Responsible Rosemont Employee.

Clearing an area for a blast will begin at the blast site and proceed outward. All affected personnel will be notified prior to clearing to allow for orderly preparation

and evacuation of the blast area. All affected equipment will be positioned or relocated to a safe position to minimize

the possibility of damage from fly rock or blast overpressure. All equipment in the blast area will be physically cleared of personnel. During clearing, all entries previously cleared will be guarded to prevent re-entry into

the cleared area (“back doors” will be held). Those clearing for a shot must be Rosemont employees.

Securing and Holding Blocking Position The purpose of this section is to insure that blocking positions are never compromised and clear, concise communication is maintained between the Responsible Rosemont Employee and each blocker.

Securing and holding of blocking positions will be directed by the Responsible Rosemont Employee.

Blockers will:

o Turn vehicles or equipment used for blocking perpendicular to the flow of traffic (if vehicles are used).

o Use blast cones to designate the blocking point.

o Have contact with the Responsible Rosemont Employee via radio.

o Communicate to the Responsible Rosemont Employee, in detail, actions taken to clear the area and the blocking position is secure.

o Not permit entry to the secured area by anyone without permission of the Responsible Rosemont Employee.

The Responsible Rosemont Employee shall:

o Maintain a blocker check list and use it to verify completion of assignments.

o Do redundant checks with each blocker prior to the last blast warning.

Instruct each blocker to hold their position if a delay occurs.

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At the end of the delay, check with each blocker before continuing with the last blast warning.

All blockers will hold their position until released by the Responsible Rosemont

Employee. Blast Initiation The purpose of this section is to ensure all detonators are communicating, the blast area is clear and that all blocking positions are secure.

Blast initiation will be directed / supervised by the Responsible Rosemont Employee.

Blast initiation will take place from a location safe from potential blasting hazards.

The blast initiation location will be a safe distance from electrical interference (e.g. power lines, power cables, radios)

The firing / initiation system will be enabled AFTER all clearing and blocking activities are finalized.

The firing / initiation system will be in the possession of the blasters and under control of the Responsible Rosemont Employee at all times.

The firing / initiation system will be connected by the Responsible Rosemont Employee or his Rosemont designee.

Two-way radio communication between the Responsible Rosemont Employee and all blockers will be maintained throughout the clearing, blocking and initiation processes.

The Responsible Rosemont Employee will ensure that all electronic detonators used in a blast continue to “communicate” with the blast initiation device throughout the blast initiation process.

The “communication” with electronic detonators will be checked against the detonator inventory taken during the priming and loading of each blast pattern and double checked against the final blast map prior to initiating any blast.

Rosemont and the blasting contractor’s personnel will be competent in safe practices in the event that a blast fails to detonate.

Initiation Notification:

o The blaster in charge will notify dispatch 30 minutes prior to firing and dispatch will relay to all pit personnel.

o Dispatch will again announce the firing time 15 minutes prior to detonation.

o Five minutes prior to firing, dispatch will call for radio silence for all hands EXCEPT the blockers and the blaster in charge.

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o The blaster in charge will announce a one minute call to initiation counting

down at 10 second intervals 50, 40, 30, 20, 10 and then silence until announcing “Fire in the hole”. At any time during the count down, any blocker can stop the shot if they detect a danger.

Post Blast Inspection The purpose of this section is to ensure that the blast holes have been detonated and the area is safe for reentry.

After the shot has been fired and no misfires are suspected the Blaster-In-Charge will wait a sufficient amount of time to allow smoke and fumes to clear before walking the shot to confirm that there are no misfires. Misfires will be handled as described below. After the site is determined to be safe and free of any unshot materials, the Blaster-In-Charge will notify the Responsible Rosemont Employee who will then notify dispatch. The ALL CLEAR signal will be given and the guards will be released from their stations. Normal mining operations are then clear to resume. Misfires All blasting contractor personnel will follow the procedures as outlined in their company’s Misfires SOP.

Procedures for dealing with a potential misfire:

1. General: The discovery of a “Misfire” and the effort to eliminate the hazard constitutes one of the most dangerous activities associated with the blasting process. The explosive material may be damaged or compromised due to the nature of the blasting operation, potentially increasing the sensitivity of the product. In addition, the dig face in which the “Misfire” was found may be unstable. Care must be taken to ensure any large equipment used to help expose the product does not come into contact with the “Misfire” explosive product.

2. Determining the type of misfire involved in the incident: There are two types of misfires that can occur in an active mine. The first type involves the failure of explosive product to detonate when an attempt is made to detonate the product. The other type of misfire involves the discovery of an explosive column or explosive product in a shovel dig face during mining activities. Each type of misfire may require a different procedure to eliminate the hazard.

Misfire due to failure of product to detonate as planned: By MSHA definition a misfire “occurs when an attempt is made to detonate explosive product(s) and the product(s) fail to detonate. When this type of misfire occurs, MSHA requires a waiting period be observed prior to going to the blast pattern to determine the cause of the misfire. If a blasting cap and fuse (system) or electronic detonating (system) caused the misfire, individuals must wait 30 minutes prior entering the blast site. If a non-electronic (system) is used the waiting period is 15 minutes. Any “Misfire” occurring during the shift shall be reported to mine management not later than the end of the shift.

3. Investigation of a Misfire: Once the required waiting period has been observed, the Blaster-in-Charge and a second individual shall go to the pattern and determine the

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cause of the misfire. In cases where the misfire occurred due to the product being improperly connected, the initiation system shall be inspected to determine if any damage occurred to the initiation system. If the initiation system can be safely reconnected a second attempt shall be made to initiate the blast pattern. If the surface initiation has been damaged and an attempt cannot be made to initiate the blast pattern, the blast area shall be re-established until mine management can make a decision to initiate the product or to determine the necessary procedure(s).In case of a misfire, immediately call your Area Superintendent and the Responsible Rosemont Employee or his designee.

o Roadblocks must remain in place until the blast area is clear.

Flat ground with no surface displacement or fracturing of the ground is an indication of a potential misfire. When these indicators are encountered during the inspection process, the individuals inspecting the pattern will thoroughly inspect the area around each blast hole(s). Locating the surface initiation system and any down hole initiation system is critical so a determination can be made if the initiation system detonated. If a detonating cord system was used, any detonating cord exposed indicates the product(s) did not detonate. Non-electronic systems that employ shock tube will result in the tube remaining on the surface of the blast site. The tube must be inspected to determine if detonation of the tube occurred. If electronic detonating systems were used, the logger/scanner will have to be reconnected to the urface/down lines to determine if any detonators are considered to be “live”.

4. Active shovel face: If a misfire is discovered in an active shovel face, an initial attempt shall be made to determine what explosive product or material is part of the misfire. It is very critical to determine if the misfire contains a “primer”.

If any part of the down line initiation system is recovered from any powder column, the “primer” shall be considered to be “live” and dangerous. The potential blast area shall be re-defined based on the extent of the misfire and road blocks will need to be re-established to limit access to the area.

5. Recovery of a “Primer”: If the detonator slides out of the cap well from the booster, then tape the detonator and booster onto a primer(s) and lower them down a blast hole (unloaded) and initiate them with the primary shot. If necessary, the primer may need to be initiated by itself.

Caution: Note special site specific procedures may need to be followed.

Record as much information as possible

Technical Services may require saving and placing the detonator/booster into the magazine.

Photographs of recovered products can be very useful to understanding the possible causes of the misfire.

If the “primer” is still intact, (i.e. detonator will not come out of the booster) DO NOT place them back into the magazine. NEVER transport a primer in a vehicle. If necessary, the primer may need to be initiated by itself.

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If the detonator does NOT slide easily from the cap well, DO NOT pull with force

Follow mine site specific requirements if a primer may need to be guarded by mine site personnel or a powder man until the Blaster-In-Charge arrives to initiate the primer. Each misfire must be evaluated and dealt with as circumstances dictate. In certain cases the procedures may include the use of loading equipment such as a shovel or loader to dig the area of the misfire. Extreme caution must be taken in this case to ensure the shovel or loader operator digs around the misfire and not directly into the suspected misfire. If a misfire that has been exposed involves a dry blasting agent, a water truck shall be considered to be brought into the area and water being placed onto the blasting agent to possibly free the primer from the powder column. Watering the remaining column may also serve to reduce the hazard by desensitizing the product.

6. Detonation of a Misfire: If a determination is made to detonate any misfired explosive product(s), a thorough examination of the material surrounding the misfire must be taken. The activities associated with uncovering the misfire may create a potential for limited fly rock (stemming or burden) around the misfire and road blocks must be re-established at a further and safe distance.

7. Lightning Detection and Evacuation:

From the time loading operations begin until the shot is fired and cleared all personnel on the shot (blast area) will follow the Rosemont SOP for Lightning Detection if a thunderstorm is in the area.

The purpose of the Lightning Detection Safe Operating Procedure is to establish a safe method to determine if loading of a blast pattern should continue during the approach of a thunderstorm. If an evacuation is required the Lightning Detection Safe Operating Procedure will establish a safe method to evacuate the blast pattern and surrounding area. Sleeping/Guarding Shots, Lightning Storms From time to time circumstances may require a prolonged evacuation of a shot overnight. This is referred to as sleeping the shot and the purpose of this section is to ensure that shots slept overnight are safely managed. Examples of having to sleep a shot might include severe thunderstorm activity in the immediate area, maintenance issues with drills or shovels preventing them from being moved a safe distance from the shot or mechanical breakdown of product loading equipment on the shot.

All blast personnel will follow the Rosemont SOP for sleeping shots

Shots will be slept overnight only in extraordinary circumstances

Shots slept overnight will be guarded or barricaded to prevent unauthorized access to the blast pattern

The oncoming shift supervisor must be informed of the situation (face to face) and given a site map along with a clearing and blocking plan (documented)

The Rosemont responsible person or his designee will determine when activities may resume within the blast area

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Attachment 1 Applicable Regulations, the Regulatory Agency and Associated links to those Agencies Governing the Explosives and Blasting Operations at the Rosemont Mine

1. Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE), The primary resource is commonly referred to as the “Orange Book” is actually titled the “Federal Explosives Law and Regulations” circular and is referenced as ATF Publication 5400.7 http://www.atf.gov/files/publications/download/p/atf-p-5400-7.pdf

2. Mine Safety and Health Administration (MSHA), 30 CFR is the primary set of rules and

regulations governing surface metal and non- metal mines. http://www.msha.gov

3. The Department of Homeland Security (DHS) http://www.dhs.gov/index.shtm. For regulations from the department of Homeland Security, refer to Title 6 of the Code of Federal Regulations, Chapter I, Parts 5,7,9,13,15,17,21,25 and 29. These regulations can be browsed at http://www.gpoaccess.gov/cfr/index.html.

4. The Arizona State Mine Inspector’s Office has jurisdiction over surface metal and non-

metal mines. https://asmi.az.gov

5. The Environmental Protection Agency (EPA) enforces laws designed to protect the environment from explosives incidents. The Office of Surface Mining Reclamation and Enforcement (OSMRE) also has jurisdiction over some aspects of environmental protection. For regulations from the EPA, refer to Title 40 of the Code of Federal Regulations, Chapter I, Parts 1 to 789. These regulations can be browsed at http://www.gpoaccess.gov/cfr/index.html.

6. The United States Department of Transportation (DOT) enforces the international IATA,

IMO and ICAO codes for domestic transportation of explosives. For regulations from the DOT, refer to Title 49 of the Code of Federal Regulations, Chapter I, Parts 100-185; Chapter III, Parts 300-399; Chapter IV, Parts 400-499, Chapter X, Parts 1000-1399; Chapter XI, Part 1420 and Chapter XII, Parts 1500-1699. These regulations can be browsed at: http://www.gpoaccess.gov/cfr/index.html.

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Attachment 2 Required Reporting ATF – Magazine activation notification, Frequency – Initially & then anytime the magazine is moved or deactivated

MSHA – Manhours, Frequency – Quarterly

MSHA – Injury Information, Frequency – As Needed

AZ State Mine Inspector Manhours, Frequency – Quarterly

EPA – Toxic Release Inventory, Frequency – Annually (reported to the mine operator & owner of the explosive material, and they will compile it with all the other data from the mining process)

APPENDIX A-3

Ammonium Nitrate Handling SOP

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Standard Operating Procedure for Handling Ammonium Nitrate (AN) Prill and Emulsion at The Rosemont Project

Purpose

This standard operating procedure (SOP) defines the required steps for handling bulk Prill (AN) and Emulsion from the time it is delivered and pumped into the storage silos to the time it is mixed with fuel oil or sensitizers and placed in the blast hole. It also describes the procedures for minimizing spillage and the steps to be taken in the event of a spill. Steps to minimize misfires and misfire handling procedures are addressed to the extent of minimizing the release of undetonated ANFO or emulsion to the environment.

Definitions

Ammonium Nitrate (Prill) is mixed with fuel oil to make ANFO (ammonium nitrate – fuel oil) for blasting activities. Since Prill is considered an oxidizer, by definition, it is classified as a hazardous material.

ANFO - Prill and ammonium nitrate combined with diesel fuel in the appropriate amounts. Ammonium Nitrate - Oxidizer used as a blasting agent, when mixed with fuel oil. Blasting Agent - Any material or mixture, consisting of fuel and oxidizer, intended for blasting, not otherwise defined as an explosive. Emulsion - Is a mixture of two or more immiscible (un-blended) liquids to produce a blasting agent. Heavy ANFO (HANFO) - Is ANFO with emulsion at different percentages. STRANgel is added to ANFO to make HANFO. STRANgel - Un-Sensitized emulsion

Product Delivery

Upon delivery of bulk products to the site, the driver, who will be trained in accordance with 49 CFR, DOT Hazardous Materials unloading of bulk chemicals, will be directed to the bulk storage silos located at the onsite SW Energy Facility for unloading. When arriving at the silo site, the driver will position the bulk truck in close proximity to the silo. The driver will wear all applicable personal protective equipment (PPE) including hard hat, safety glasses with side shields, steel toe boots and reflector vest or reflective shirt. The driver will wear a seat belt at all times when operating the vehicle. When climbing up or down the truck ladder, the employee must maintain three points of contact at all times to reduce the potential for a slipping hazard. Additionally, the employee must wear a full harness and be tied off when on top of the truck.

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Connection of Equipment

Upon arrival on the silo pad, the driver will chock the wheels and set the park brake and follow these procedures while transferring the bulk products to the storage silos:

• Hook up product hose out of the hose tube to the silo and place bungee cords around the camlocks to assure vibrations won’t unlock the camlocks.

• Hook up the hot air hose from the trailer to the blower on the tractor.

• Check the bleeder valve on the trailer and make sure it is in the open position.

• In the truck cab, put the transmission in gear and with the clutch engaged, flip the PTO switch to the on position. Take the truck out of gear and let the clutch out slowly and turn the high idle switch on.

• Open the valve for tank air and close the bleeder valve. Build tank air to 8 lbs and then open the product valve. Open product air and regulate both the tank and product air at no more than 8 lbs. pressure.

• The operator must stay in attendance of the offloading process at all times. If the operator needs to leave the site, the unloading must be shut down and pressure bled off.

• When each cone runs empty, close the product valve and go to the next cone. Once all cones are empty, go through each cone again to verify they are empty. Blow out product line and pipe to silo to ensure that no product remains in the lines, open bleeder valve and bleed off the air in the tanker.

• In the truck cab, turn off the high idle, push the clutch in and turn off the PTO.

• After all air is out of the tanker through the bleeder valve, disconnect the product hose and place it back into the hose tube securing the hose tube door. Disconnect the hot air hose from the tractor and secure it to the trailer.

• If any ammonium nitrate or emulsion spills on to the ground, clean it up immediately and place it in the covered, labeled barrel provided. If a large spill occurs, notify dispatch immediately.

• Upon completion of unloading, unchock wheels and proceed to the main gate. LOADING AT PRILL SILOS

• Position the bulk truck under the silo, set the park brake and chock the wheels.

• When accessing the top of the truck, the operator must employ proper MSHA fall protection equipment (see Photo No. 1).

• Position the product hose over the fill hole and load the truck ensuring not to overfill. Load each bin individually.

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• Clean up and place any spilled product in the covered, labeled barrel provided. Prill that is not contaminated with dirt and rocks may be placed back in the bins.

• The containerized spillage will be taken to the blast site and poured into a blast hole. Site conditions may dictate that the prill be poured into a blast hole before adding the blasting agent or poured on top of the blasting agent column prior to stemming. Either way, the product will be detonated with the shot using standard blasting procedures.

• Once the truck is filled with prill, it will proceed to the fuel storage area where the diesel tank will be filled.

Loading At The Blast Site Loading ANFO or HANFO

• The loading hose is placed directly over the blast hole and about a foot above the collar to ensure product goes in the hole. The hole will be loaded through a completely enclosed auger that delivers the product from the truck to the hole with no exposure to the atmosphere. The ingredient selection switches are then placed in the neutral position prior to moving to the next hole. By placing the loading hose about a foot above the hole collar, it is well below the crest of the cuttings cone around the hole. This helps to prevent dispersal of ANFO due to high winds (see Photos No. 2 and 3).

• Blasting agent that is on the cuttings will be shoveled into the hole prior to stemming.

• Blasting agent that may be spilled between holes will be cleaned up and placed in blast holes prior to stemming.

• Prill or blasting agent that may be spilled during a cleanout procedure will be cleaned up and placed in blast holes prior to stemming.

Loading of Emulsion

• When priming the truck loading system for the first hole, it is necessary to pump a small amount of product thru the hose before lowering the hose into the hole. Any emulsion placed on the ground will be placed in the blast hole before stemming.

• Unlike the loading of ANFO, when loading Emulsion, the loading hose is lowered into the hole and withdrawn as the product is pumped into the hole. As a result, emulsion can accumulate on the outside of the hose. Therefore a wiper is used on the hose to clean it is pulled from the hole, effectively preventing the emulsion from accumulating on the hose reel thus minimizing any spillage (see Photo No. 4).

• Clean Up Spill

Use shovels and plastic barrels to completely clean up the spilled emulsion product, as well as any contaminated soil. In order of desirability:

o Place emulsion product material, along with any contaminated soil, on top of a loaded hole prior to stemming and consume as intended.

o Screen rock & debris from emulsion product and place back into truck or silo for future use. Place contaminated soil on top of a loaded hole prior to stemming.

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Ø Caution: When climbing up or down the truck ladder, the employee must maintain three points of contact at all times to reduce the potential for a slipping hazard. Additionally, the employee must wear a full harness and be tied off when on top of the truck returning the emulsion product to the appropriate hopper.

o Completely clean shovels and barrels used in the process as to not store a blasting agent inappropriately or allow spillage during vehicle or equipment transport.

BLAST DESIGN CONSIDERATIONS

For safety, environmental and economic reasons, blast designs at Rosemont will include measures to ensure complete detonation of all explosives. Any charge or portion of a charge that fails to detonate, for any reason, is considered a misfire. Some common causes of misfires, along with design practices that will minimize them are discussed below.

Cutoffs: We cannot control ground conditions, but we can control drill patterns, explosive loads and initiation methods. In ground having weak seams or joints, the gasses and the shock from early firing charges can cause premature movement of the rock containing adjacent, unfired holes. When the rock moves, it separates or cuts off the explosive columns within it. Many of these misfires can be eliminated by using multiple in-hole delay primers. Rosemont’s blasting procedures will include priming each blast hole on both the bottom and at the top of the explosive column. While this is more expensive than a single bottom primed hole, it provides a level of insurance against a cutoff and misfire which is even more expensive, dangerous and disruptive to production. In extremely fractured or faulted ground, it may be necessary to place more than two primers in a hole. This practice is referred to as decking and may be used as conditions dictate. Improper Timing Sequence: Some failures occur because there is either too much time or not enough time delay between holes or rows of holes. Rosemont will employ electronic detonators which are programmable to the millisecond with precise accuracy as well as verification of circuit continuity before the shot is detonated. This is another layer of dependability and assurance that all detonators are connected and functional before the shot is initiated. Sequencing of when each blast hole detonates plays a major role in how well the rock is fragmented. Every effort will be made to ensure maximum fragmentation, which in turn, means maximum mill throughput. Poor Explosives Product Choice: Rosemont is employing SW Energy to provide its blasting services. SW Energy provides the blasting services for most of the mines in the Tucson area as well as the rest of Arizona, New Mexico and Nevada. Their expertise in selecting the proper product and handling and loading those products in the most professional manner is unparalleled in the industry. Loading Controls: Surface auger-loading trucks with poorly designed, or aimed, discharge hoses spill ANFO prills onto the ground around hole collars during loading. Some spillage is unavoidable but with proper loading practices as defined in this document, coupled with properly designed equipment and properly trained personnel, spills will be minimized and addressed in an environmentally responsible manner. Trained explosives technicians will load each hole monitoring the explosive column continuously by means of a tape measure to track the hole filling process. By

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monitoring the filling, the operator can detect hole collapse or voids that may lead to a cutoff or misfire and ensure that the proper amount of blasting agent is put in each hole. As described above, any spillage around the hole will be shoveled into the hole before the stemming process begins. Loading Wet Holes: Loading bulk ANFO into wet holes or letting ANFO “sleep” too long in wet or damp holes are common causes of explosive loss. When water comes into contact with ANFO, it either dissolves it or wicks into it and desensitizes it. When wet conditions are identified, depending upon the volume of water, the hole may be pumped out or the hole will be loaded with a product other than ANFO i.e. heavy ANFO or Emulsion. The blaster in charge of the shot will determine the condition of each hole, the presence and amount of water and the product to be used at the time of loading the shot. Misfires: In spite of all precautions and practices, misfires will occur. If a misfire can be identified, the preferred remedial action is to reprime the undetonated explosives and detonate it. If this is not possible or practical and the misfire is ANFO product, the hole can be washed out with water. If a misfire is suspected but cannot be located, warning flags will be placed on the muck pile and the shovel operator will be advised to dig with caution and to notify dispatch if any undetonated explosives are sighted. The undetonated explosives will then be disposed of properly in accordance with Rosemont standard operating procedures.

Photo No. 1: Loading the Bulk Truck with Ammonium Nitrate Prills From The Storage Silo

6

Photo No. 2: Bulk Truck Loading ANFO Showing Auger and Hose

Photo No. 3: Close-up of Hose Positioning While Loading A Hole With ANFO

7

Hosewiper:Itisairactuatedandwhenthehoseispulledfromtheholethesejawsclamponthehosetowipeexcessslurryfromthehose.

Photo No. 4: Emulsion Hose Wiping Assembly on SW Energy Bulk Trucks

APPENDIX B

Universal Waste Management

APPENDIX B-1

Pima County Department of Environmental Quality – Management of Universal Waste

of 3

Pima County Department of Environmental Quality Hazardous Waste Generator Program 33 N. Stone Ave., Suite 700, Tucson, Arizona 85701-1429

Management of Universal Waste Technical Guidance

This technical guidance document describes some of the basic requirements for handlers of universal waste (UW). Universal waste is a subset of hazardous waste and contains mercury, lead, cadmium, copper and other substances hazardous to human and environmental health. Universal wastes are generated from a wide variety of sources (i.e., individuals, government agencies, hospitals, businesses, etc.) in a variety of settings, not just in traditional industrial settings. These wastes are referred to as universal because, at some point, almost every business, non-profit organization, and government agency generates them. Goals of the Universal Waste Regulations The universal waste regulations were developed with several interrelated goals in mind: • To encourage the recycling of the categories

of wastes designated as universal waste. • To improve the management of certain types

of hazardous wastes. • To reduce the amount of hazardous waste that

ends up in solid waste landfills and combustors.

• To ease the regulatory burden on the facilities that manage these wastes, particularly by allowing more time for accumulation of these wastes in order to facilitate appropriate recycling or disposal.

• To ensure that these wastes go to appropriate treatment or recycling facilities.

Categories of Universal Waste Certain widely-generated hazardous wastes have been designated as universal waste. Managing qualifying hazardous wastes as universal waste is optional. Generators have the choice to manage hazardous wastes that fit into the categories of universal waste under the streamlined requirements of 40 CFR 273 instead of the more stringent RCRA Subtitle C requirements for hazardous waste. UW includes: • Hazardous waste batteries – devices

consisting of one or more electrically connected electrochemical cells designed to receive, store and deliver electric energy. Includes nickel cadmium batteries and lead acid batteries.

• Certain hazardous waste pesticides –

substances that are intended for preventing or mitigating pests or intended for use as a plant regulator or defoliant. Excludes animal drugs and animal feed containing animal drugs.

• Mercury-containing equipment – devices that contain elemental mercury integral to their function. Includes thermostats, but does not include batteries or lamps.

• Hazardous waste lamps - bulbs or the tube portion of electric lighting devices that are specifically designed to produce radiant energy. Includes mercury vapor lamps, fluorescent light bulbs, and neon lights.

The applicability of the universal waste requirements to each category of waste described above can be found in 40 CFR Part 273 Subpart A. Universal wastes that are mixed with hazardous wastes are fully regulated as hazardous wastes. Mixtures of universal waste and conditionally exempt small quantity generator waste or household hazardous waste can be managed under the universal waste requirements since these hazardous waste are not subject to full hazardous waste regulation. Wastes that are not Universal Wastes • Non-hazardous batteries: Batteries that are

not hazardous at the time of disposal need not be managed as UW. Non-hazardous batteries include alkaline, carbon zinc, chloride zinc (commonly labeled heavy duty), nickel metal hydride (NiMH), zinc air, and lithium batteries

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=1b1eb8788ead07218a67cf9fd26bb618&tpl=/ecfrbrowse/Title40/40cfr273_main_02.tpl

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that are nine volts or less and higher voltage lithium batteries that have been discharged to less than one volt. Although non-hazardous, you are still encouraged to recycle them.

• Electronic waste: Circuit boards and cathode ray tubes (CRTs).

• PCB-containing ballasts and small capacitors: Lighting ballasts and small capacitors that may contain PCBs that are found in motors and appliances.

Advantages of Managing Hazardous Wastes as UW • Universal waste volume is not included when

determining hazardous waste generator status. This may benefit some companies by allowing them to reduce their generator status level which in turn would reduce their generator regulatory requirements.

• Universal waste can be accumulated for up to one year which is a longer accumulation time than allowed for small quantity and large quantity generators of hazardous waste.

• Less labeling is required on universal waste. • A hazardous waste manifest is not required to

accompany a universal waste shipment in Arizona or within any other state that recognizes it as universal waste.

• Less recordkeeping is required. • A shipment of universal waste can be

transported via a universal waste transporter rather than a hazardous waste transporter.

Universal Waste Handler Requirements The universal waste regulations create two groups of generators of universal waste, called handlers, based on the amount of universal waste accumulated on-site. Universal waste handlers are not just those that generate or produce universal waste, but also those who receive universal waste from other handlers. Below is a description of the two universal waste handler groups – Small Quantity Handlers of Universal Waste and Large Quantity Handlers of Universal Waste and the main requirements each must comply with. A full description of handler requirements can be found in 40 CFR Part 273 Subpart B and Subpart C.

Small Quantity Handlers of Universal Waste - accumulate less than 5,000 kilograms (or about 11,000 pounds) of universal waste at any one time on-site. SQHUWs must comply with the following: • Label or mark universal waste to identify the

type of universal waste it is (See 40 CFR 273.14).

• Manage universal waste in a way that prevents releases to the environment.

• Immediately respond to releases of universal waste and properly manage released waste.

• Distribute basic waste handling and emergency information to their employees to ensure that their staff is aware of these procedures.

• Accumulate universal waste for no more than one year.

• Comply with export requirements for foreign shipments.

SQHUWs are not required to notify PDEQ of their universal waste management activities, not required to keep records of universal waste shipments, and not required to use a hazardous waste manifest for off-site shipments of universal waste. However, PDEQ recommends keeping records of universal waste management as a best management practice (BMP). Handlers must comply with U.S. DOT hazardous materials requirements, if applicable.

Large Quantity Handlers of Universal Waste - accumulate on-site 5,000 kilograms or more of universal waste at any one time. The designation as a LQHUW is retained for the remainder of the calendar year in which the 5,000-kg threshold was exceeded, and may be reevaluated in the following calendar year. Handlers must comply with the following:

• Label or mark universal waste to identify the type of universal waste (See 40 CFR 273.34).

• Manage universal waste in a way that prevents releases to the environment.

• Immediately respond to releases of universal waste and properly managed released waste.

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TGD HW13 – Management of Universal Waste

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• Ensure that all employees are thoroughly

familiar with proper waste handling and emergency procedures relative to their responsibilities during normal facility operations and emergencies.

• Accumulate universal waste for no more than one year.

• Comply with export requirements for foreign shipments.

• Notify PDEQ and obtain an EPA identification number from ADEQ if they do not already have one.

• Maintain records of all universal waste shipments received by and sent from the facility and retain these records for three years.

Handlers are not required to use a hazardous waste manifest for off-site shipments of universal waste, but must comply with U.S. DOT hazardous materials requirements, if applicable.

Waste Specific Management Requirements Each type of universal waste has specific management requirements designed to prevent releases to the environment that handlers must comply with. These standards can be found in 40 CFR Section 273.13 for SQHUWs and Section 273.33 for LQHUWs. Additionally, these sections discuss those activities that universal waste handlers can perform under the universal waste regulations such as ampule removal from mercury containing equipment and mixing or discharging batteries and what standards they have to follow in order to do them.

Attachment: ADEQ Fact Sheet “Managing Universal Waste Lamps for Business” For additional information regarding proper management of solid or hazardous waste in Pima County, you may contact the Pima County Department of Environmental Quality (PDEQ) at (520) 724-7400, or the address at the beginning of this document, or visit the PDEQ website at http://www.deq.pima.gov/waste/index.html for access to the PDEQ Hazardous Waste Generators Handbook and waste or generator specific, technical guidance documents.





http://www.deq.pima.gov/waste/index.html

APPENDIX B-2

Arizona Department of Environmental Quality - Managing Universal Waste Lamps for Businesses

FACT SHEETArizona Departmentof Environmental Quality

Janice K. Brewer, Governor • Henry R. Darwin, Director

Facebook “f ” Logo CMYK / .eps Facebook “f ” Logo CMYK / .eps

Background:The U.S. Environmental Protection Agen-cy (EPA) finalized the Universal Waste Rule (40 CFR Part 273) on May 11, 1995, to provide a streamlined approach for businesses to collect and manage certain widely generated hazardous wastes. The rule was intended to facilitate environ-mentally sound collection and encourage proper recycling and treatment of these wastes.

This fact sheet summarizes universal waste regulations for lamps, EPA’s recom-mendations for management of fluores-cent lamps, and ADEQ’s adoption of the Universal Waste Rule for lamps.

What is a universal waste lamp?A lamp is the bulb or tube portion of an electric lighting device that is designed to produce radiant energy. It includes, but is not limited to, fluorescent tubular and compact florescent lamps (CFLs); high intensity discharge; neon; mercury vapor; high pressure sodium; and metal halide lamps.

EPA encourages the use of fluorescent lamps because they use about 20 percent to 25 percent less electricity, which in turn reduces mercury and greenhouse gas emissions from power generating stations.

The amount of mercury in a standard fluorescent lamp varies depending on the type and manufacturer of the lamp, but typically ranges from 8 milligrams – 14 mg, and can possibly be as high as 50 mg with some older lamps. The amount of mercury in a low-mercury bulb (often referred to as “green-tipped” lamps) can typically range from 3.5 – 4 mg depend-ing on the manufacturer. Newer fluores-cent lamps in general will typically have less mercury, but mercury is an essential

Managing Universal Waste Lamps for Businesses – March 2014

Publication Number: FS 14-10

component in fluorescent lamps and can-not be eliminated completely.

An unused mercury-containing lamp becomes a waste on the date the handler decides to discard it.

Who is affected by this rule?

BusinessesBusinesses that generate less than 100 kilograms of hazardous waste in one calendar month [Conditionally Exempt Small Quantity Generators (CESQG)] are strongly encouraged to participate in vol-untary collection and recycling programs by taking these spent lamps to collection centers for recycling or proper treatment and disposal.

Under federal regulations, the Toxicity Characteristic Leaching Procedure (TCLP) determines if a lamp is a hazardous waste. This test measures the leachability of certain metals, including mercury and organic constituents. Lamps that pass the TCLP test for mercury are not hazardous and not subject to federal regulation. The amount of mercury in a fluorescent lamp

typically exceeds and fails the TCLP limit. Therefore, the lamp is a hazardous waste when disposed.

Small and large quantity hazardous waste generators are required to manage spent lamps under 40 CFR Part 273 or under 40 CFR Part 261.

HouseholdsHouseholds that generate spent lamps are not regulated as hazardous waste. Households are encouraged to recycle spent lamps at local retailers or collec-tion centers that accept spent lamps (see back page).

“Green-Tipped” fluorescent lampsGreen-tipped lamps usually will not fail the TCLP limit for mercury and can be managed as a solid waste. Check the manufacturer literature to confirm that these lamps have been tested and do not fail the TCLP. However, ADEQ recom-mends that you have your spent green-tipped lamps analyzed to confirm they are non-hazardous; alternatively, assume they are hazardous waste and handle them accordingly. ADEQ also recom-

This document is not a substitute for the rules. To properly manage mercury-containing waste lamps as universal waste, you must comply with all applicable provisions in the Arizona Universal Waste Rule (A.A.C. R18-8-273) and the Federal Universal Waste Regulation (40 CFR Part 273).

Universal waste lamps includes, but is not limited to, fluorescent tubular and compact florescent lamps (CFLs); high intensity discharge; neon; mercury vapor; high pressure sodium; and metal halide lamps.

We advocate for Arizona’s environment.

We adhere to the highest standards of technical professionalism. We commit to the highest standardsof ethical behavior. We are committed to openness, honestyand transparency.

We foster relationships built on respect, courtesy and service.

We value creativity, innovationand performance.

We turn challenges into opportunities. We value our employees and work as a team.

Arizona Departmentof Environmental Quality

To protect and enhancepublic health and the environment

in Arizona.

To lead Arizona and the nation in protecting the environment and improving the quality of life for the people of our state.

OUR VISION

OUR MISSION

PRINCIPLES AND VALUES

FACT SHEET

mends that the facility keep hazardous and/or non-hazardous waste determi-nation records on file and periodically retests or checks for updated literature.

Green-tipped lamps still contain mer-cury and should be managed to prevent breakage. ADEQ encourages the recy-cling of all mercury-containing lamps, regardless of the mercury content. Spent lamps can be recycled to recover mercury, glass, and metal.

Management:

Regulatory DeterminationLamps can be managed as hazardous waste (regulations found in 40 CFR Part 262 and A.A.C. R18-8-262) or as univer-sal waste (regulations found in 40 CFR Part 273 and A.A.C. R18-8-273). If man-aging the lamps as hazardous waste, the facility must make a determination of how many lamps are generated per month to determine the generator sta-tus (ADEQ estimates that 350 four-foot lamps will generate 100 kg of hazard-ous waste). If managing the lamps as universal waste, the facility must make

a determination of how many lamps are accumulated on-site at any one time to determine the handler status (<5,000 kg on-site is considered a Small Quantity Handler of Universal Waste).

LocationIdentify an area in your facility where universal waste lamps will be stored. This area should be away from high-traffic ar-eas, should be clean, dry, and free of bro-ken lamp debris, and should ideally have an independent air handling system to help minimize employee exposure to mercury in the event a lamp is broken.

Handling of LampsEmployees handling lamps must under-stand the Universal Waste Rule for lamps. The lamps should be handled carefully to prevent breakage, placed immedi-ately in a sturdy container, and brought to the universal waste storage area.

Storage of Spent LampsLamps must be stored in a container that is structurally sound and compat-ible with the contents of the lamp. It also should lack evidence of leakage, spillage, or damage that could cause

releases of mercury. The container should be stored in such a way that it will not tip over and must be closed unless actively adding or remov-ing universal waste lamps. The container must be labeled or marked with the words “Universal Waste – Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).” A label with those words can be affixed to or the words can be written on the container.

A handler of universal waste lamps must be able to demonstrate the length of time that the lamps have been accumu-lated as a waste. The handler may not accumulate universal waste for longer than one year. Demonstrating accumu-lation time can be accomplished by:

a.) marking or labeling the container or storage area with the first date a lamp was placed in the container, or

b.) maintaining an inventory system on-site that identifies the date each lamp became a waste or the earli-est date that a lamp in a group of lamps became a waste.

Developing a recycling program:

1. Assess your facility with the follow-ing questions:

• How many lamps are in your facility?• Where are they located?• How many lamps are replaced per

month or year?• How do you currently manage and

store spent lamps?• Do employees know who to call if a

lamp is burned out?

2. Consult federal and state regula-tions concerning universal waste lamps.

3. Select a recycler that will best serve your needs and can provide assurance that your lamps are be-ing properly managed. Consider the following criteria in selecting a recycler:

• Service: responsiveness, timeliness, flexibility, capabilities

• Risk Management: environmen-tal record and compliance history, government permits and approval for facility operations and transpor-tation, maintained debris and dust-free public areas, insurance require-ments for general and pollution liability are met, and indemnities or other assurances offered to clients.

4. Establish a process for handling and storing spent lamps. See the above section for recommendations.

5. Getting your spent lamps to the recycler is important.

• Pick-Up Service: offered by transportation companies or the recycler.

• Mail-In or Box Program: the recycler may provide a container for your spent lamps, which can be

shipped when filled. In this pro-gram, your facility must ensure the containers meet all proper packag-ing, labeling, and shipping require-ments.

• Self-Transport: you can transport the lamps to the recycling facil-ity yourself. Ensure the lamps are managed in a way that prevents breakage.

6. Educate employees about the dangers of mercury, importance of minimizing the release of mercury, and your management procedures for lamp handling and storage. Employees must be trained in ac-cordance with applicable state and federal requirements.

7. Keep records of your recycling ef-forts, including documentation like a receipt or certificate that the recy-cler is properly recycling the lamps.








in Arizona.


OUR VISION

OUR MISSION


FACT SHEET

Containers holding lamps should not be overfilled or underfilled when shipped. Care should be used when stacking boxes to keep the lamps from being crushed. Do not secure lamps together with tape or rubber bands.

Broken LampsOnce a lamp breaks, it releases mercury vapors into the air so it is important to ensure the immediate cleanup and con-tainment of the lamp debris. Make sure your facility has proper procedures for reporting and managing broken lamps. Accidentally broken lamps and their de-bris can be managed as universal waste, whereas, intentionally broken lamps and their debris must be managed as hazardous waste unless other exemp-tions apply (i.e. lamps were generated in a household or a CESQG facility).

EPA recommends that broken lamps are to be kept in a sealed container, prefera-bly glass or metal. Containers should be removed from the building as soon as possible and kept in a cool place, away from high-traffic areas, in the Universal Waste Storage Area or the 180/90-Day Hazardous Waste Storage Area. Con-tainers of broken lamps should not be opened to add or remove broken lamps. Follow OSHA, EPA, and state regulations when managing broken lamps.

Drum Top Crushers:

Drum-top crushers (DTCs) are devices that fit on the top of a 55-gallon drum and crush fluorescent lamps into the drum; they are typically used to reduce waste lamp storage and transport.

Arizona allows the use of DTCs but all manufacturer requirements must be followed. A business that uses a DTC must follow applicable hazardous waste generator rules found in 40 CFR Part 262 and A.A.C. R18-8-262. Intention-ally crushed lamps must be counted towards the generator’s monthly hazardous waste generation and must be managed as hazardous waste at the point of generation.

A generator must minimize the release of hazardous waste to the environment.

Facilities using DTCs must minimize the release of mercury from the device. For example, facilities could prevent a release of mercury by having a control device on all DTCs to prevent emissions and by not transferring crushed lamps to another container. DTCs must be used in a cool room with adequate ven-tilation that does not recirculate the air per manufacturer requirements. Filters used in DTCs may be hazardous waste. Facilities must have a waste determina-tion for these filters per 40 CFR Part 261.

Facilities using DTCs to crush “green-tipped” lamps must ensure that only “green-tipped” lamps are being crushed. EPA has found that DTCs can cause exposures of mercury even with low mercury “green-tipped” lamps. ADEQ highly recommends that these facilities monitor mercury levels and install con-trol devices to minimize the release of mercury from the “green-tipped” lamps.

ADEQ does not endorse nor discourage the use of DTCs, but highly encourages the recycling of all mercury-containing

lamps, regardless of the mercury con-tent. ADEQ highly recommends that facilities periodically perform waste determinations on these crushed lamps, and keep this documentation on file.

The Arizona Industrial Commission may specify additional requirements for businesses operating bulb crushers. For additional information, please call (602) 542-5795.

Where can I get more information?

For additional information please con-tact ADEQ:

Hazardous Waste Inspections and Compliance UnitWaste Programs Division1110 W. Washington St.Phoenix, AZ 85007(602) 771-4673 orToll free at (800) 234-5677 Ext. 771-4673Hearing impaired persons callADEQ’s TDD line: (602) 771-4829www.azdeq.gov/environ/waste/index.html

Drum top crusher use is regulated by applicable hazardous waste generator rules.








in Arizona.


OUR VISION

OUR MISSION


FACT SHEET

The following Web sites offer additional information:

EPA’s Universal Wastes: www.epa.gov/osw/hazard/wastetypes/universal/

EPA’s Compact Fluorescent Light Bulbs (CFLs): www.epa.gov/bulbrecycling

EPA’s Spent Mercury-Containing Lamp Recycling: www.epa.gov/wastes/hazard/wastetypes/universal/lamps/index.htm

EPA’s Management and Disposal of Mercury-Contain-ing Light Bulbs (Lamps):

www.epa.gov/wastes/hazard/wastetypes/universal/lamps/faqs.htm#43

EPA’s Mercury and Mercury Containing Products: www.epa.gov/mercurywww.epa.gov/epawaste/conserve/tools/stewardship/products/mercury.htm

EPA’s Broken Lamps Clean-up Procedures: www.epa.gov/mercury/spills/index.htm#fluorescent

EPA’s Local Recycling Options for Households: www.epa.gov/bulbrecycling

EPA’s Mercury Lamp Drum-Top Crusher Study: www.epa.gov/waste/hazard/wastetypes/universal/drumtop/index.htm

Energy Star on Compact Fluorescent Lamps (CFLs): www.energystar.gov/cfls

Earth 911: www.earth911.org

Spent Lamp Management Facilities in Arizona:

Recycling your lamps can be accomplished through regular pick up by hazardous waste transporters, mail-in prepaid boxes offered by a num-ber of different retailers, or by dropping off your lamps at one of the following facilities:

WM LampTracker, Inc. 10 S. 48th St., Suite #4Phoenix, AZ 85043

(602) 353-9282(800) 414-0443

Lighting Resources, LLC 1522 E. Victory St., Suite #4Phoenix, AZ 85040

(602) 276-4278

Veolia Environmental Services 5752 W. Jefferson St.Phoenix, AZ 85043

(602) 233-2955

Treatment, Storage, & Disposal Facilities in Arizona

Clean Harbors 1340 W. Lincoln St.Phoenix, AZ 85007

(602) 258-6155

Heritage Environmental Services, LLC 284 E. Storey Rd.Coolidge, AZ 85228

(520) 723-4167

Safety-Kleen Corporation 4161 E. Tennessee St.Tucson, AZ 85714

(520) 790-7714

Safety-Kleen Corporation 6625 W. Frye Rd.Chandler, AZ 85226

(480) 940-7202

APPENDIX C

Performance Assurance Plan for Septic Systems

Performance Assurance Plan For Septic Systems Rosemont Copper Project

Prepared for:

4500 Cherry Creek South Drive, Suite #1040 Denver, Colorado 80246 (303) 300-0138 Fax (303) 300-0135

Prepared by:

3031 West Ina Road Tucson, Arizona 85741 (520) 297-7723 Fax (520) 297-7724

Tetra Tech Project No. 114-320877

Document Number: 151/11-320877-5.3

August 2011

ROSEMONT COPPER PROJECT

Performance Assurance Plan For Septic Systems

The following document has been prepared by the staff of Tetra Tech under the direct supervision of the ENGINEER of Record, whose seal and signature appear below.

The INFORMATION presented herein, was prepared in accordance with generally accepted professional engineering principles and practices.

Michael D. Thornbrue, P.E.

Performance Assurance Plan for Septic Systems Rosemont Copper Company

Tetra Tech August 2011 i

TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................... 1 1.1 Scope .................................................................................................................... 1 1.2 Domestic Wastewater ........................................................................................... 1 1.3 Septic System Overview ....................................................................................... 2

2.0 SEPTIC TANK – PRIMARY TREATMENT ....................................................................... 3

3.0 LEACH FIELD DISPOSAL ............................................................................................... 4

4.0 SEPTIC SYSTEM MAINTENANCE .................................................................................. 5 4.1 Schedule ............................................................................................................... 5 4.2 Procedure .............................................................................................................. 5 4.3 Estimated Costs .................................................................................................... 5

5.0 RECORDS AND ANNUAL REPORTING ......................................................................... 6

6.0 DIAGNOSING SYSTEM PROBLEMS .............................................................................. 7 6.1 Slow Draining Toilets ............................................................................................. 7 6.2 Standing Water ...................................................................................................... 7 6.3 Sewage Odors ....................................................................................................... 7

LIST OF TABLES

Table 1 Location and Size of On-Site Wastewater Facilities .............................................. 1

LIST OF APPENDICES

Appendix A List of Certified Service Companies in Pima County Appendix B Record of Inspection/Maintenance Form


Tetra Tech August 2011 1

1.0 INTRODUCTION

This Performance Assurance Plan (Plan) supports the anticipated septic systems associated with the Rosemont Copper Project (Project). Currently, there are eight (8) sewage treatment systems, listed in Table 1, planned for the Project to treat and dispose of domestic wastewater. Each system has a design flow less than 3,000 gallons per day (gpd) and consists of a septic tank and a leach field.

Table 1 Location and Size of On-Site Wastewater Facilities

APP Facility Number

Septic System Location

Septic Tank Capacity (gallons)

Design Flow (gpd)

AR-PS-04a Primary Crusher 750 125 AR-PS-04b Electro-Winning 1,000 250 AR-PS-04c Mine Truck Shop 4,000 1,500 AR-PS-04d Change House 3,000 1,200 AR-PS-04e Main Warehouse 1,000 200 AR-PS-04f Analytical Laboratory 1,000 250 AR-PS-04g Administration Building 3,000 1,200 AR-PS-04h Tailings Filter Plant 750 250

Total 14,500 4,975

Because there are eight (8) sewage treatment systems on the property under common ownership and the systems have a combined total design flow greater than 3,000 gpd and less than 24,000 gpd, the design guidelines published in A.A.C. R18-9-E323 are applicable.

1.1 Scope A.A.C. R-18-9-E323(B)(1) requires a Performance Assurance Plan consisting of tasks, schedules, and estimated annual costs for operating, maintaining, and monitoring performance over a 20-year operational life.

The information provided in this Plan is for two (2) purposes:

To serve as a guide for the operation and maintenance of the on-site wastewater disposal systems (septic tanks and leach fields) at the Project site; and

To outline the principles of operation for septic tanks and leach fields along with a troubleshooting guide for possible modes of system failure and possible solutions.

1.2 Domestic Wastewater Domestic wastewater, or sewage, is generated through the use of toilets, bathroom sinks, showers, bathtubs, kitchen sinks, garbage disposals, dishwashers, and washing machines. Domestic wastewater contains dissolved organic and inorganic materials, suspended and settleable solids, and microorganisms, including bacteria and viruses.

Direct discharge of domestic wastewater would cause a public health hazard. Therefore, a proper system must be used to treat and dispose of domestic wastewater. To ensure that public health is protected, wastewater treatment and disposal methods, including septic systems, are subject to regulatory review.



1.3 Septic System Overview A properly designed, operated, and maintained septic system provides treatment and disposal of domestic wastewater in the absence of modern municipal wastewater treatment systems. A septic system is a two (2) part sewage treatment and disposal system buried in the ground, and is composed of a septic tank with a filter to remove solids and greases from the sewage followed by leach fields to dispose of the effluent. The sewage generally flows by gravity into the septic tank where larger particles settle out and some primary decomposition takes place. The liquid portion of the sewage then flows into the leach field where it percolates into the ground.



2.0 SEPTIC TANK – PRIMARY TREATMENT

Untreated domestic sewage would quickly clog all but the most porous gravel if applied directly to the soil. The function of the septic tank is to condition the raw sewage so that it can percolate into the ground without clogging either the leach field pipelines or the receiving soil.

Septic tanks are watertight containers that remove large solids and greases, provide anaerobic digestion of the solids, and storage of sludge and scum.

Within the tank, four (4) important processes take place:

The heavier, solid particles in the sewage settle to the bottom of the tank forming a layer of sludge. Lighter materials, including fat and grease, float to the surface forming a scum layer;

Bacteria living in the septic tank break down some of the organic solids into liquid components, helping to reduce the build-up of sludge in the tank;

Sludge and scum are stored in the septic tank rather than being allowed to flow out of the septic tank where they would quickly clog the leach field; and

The septic tank filters and/or baffles prevent scum and other floatable materials from flowing out to the leach field.

Septic tanks are constructed of concrete or fiberglass and may contain one (1) or more compartments or the designer may have specified two (2) or more tanks for the system. Baffles are placed within the tank to improve solids settling and prevent the scum layer of lightweight solids, fats, and greases from floating out of the tank with the effluent. Regardless of the number of compartments or tanks in the system, the basic principle is the same.

The settled solids are biologically digested by bacteria which live in environments without air (anaerobic bacteria). Some of the products of anaerobic digestion are gases, including methane, carbon dioxide, and hydrogen sulfide, which has an odor similar to that of rotten eggs.

The gases are vented from the septic tank through the plumbing vents. Openings are provided in the roof of the septic tank and are located above the inlet and outlet pipes. A septic tank riser and cover provide access to the openings in the septic tank roof.

Inorganic and non-biodegradable materials cannot be digested by the microorganisms in the septic tank accumulate in the sludge or scum layers. The sludge and scum layers must be removed periodically to prevent the accumulated solids and greases from flowing into the soil absorption system (leach field) and clogging the soil pores.

Typically, there will be an effluent filter at the outlet of the septic tank. These filters are accessible through the riser and cover. Filters protect the leach field from excessive solids carryover caused by surge flows through the septic tank. Filters also limit the maximum size of particles going out to the leach field, typically, to about 1/16-inch. These units are partially self-cleaning, but must be thoroughly cleaned when the tank is pumped. They provide a fail-safe reminder that the tank needs pumping.



3.0 LEACH FIELD DISPOSAL

After primary treatment and filtering in the septic tank, the effluent (the liquid portion of the sewage) generally flows by gravity directly to the leach field through solid-wall plastic pipes. A leach field typically consists of a series of three (3) to four (4) inch diameter perforated pipelines placed in two (2) to three (3) foot wide trenches. The effluent may pass through a distribution box prior to flowing into the perforated plastic pipes. The perforated pipe is placed on top of gravel which is also used to backfill around the pipe. The gravel promotes drainage and reduces root growth near the pipeline. A minimum soil cover is placed over the gravel to protect the leach field, prevent contact with the wastewater, and reduce infiltration from rain and snow.

In the leach field the effluent flows through the gravel and is absorbed by the surrounding soil. A bacterial slime mat grows in the soil under the trench. The mat functions as part of the wastewater treatment process; however, the mat can also reduce the percolation rate as the leach field becomes older. Percolation rates can also be reduced by solids which flow from septic tanks that have not been pumped and by flooding due to high groundwater or sewage flowing from neighboring leach fields.

As the effluent moves both horizontally and vertically through the soil pores the dissolved organic material is removed by bacteria which live in the top ten (10) feet of the soil. Additionally the temperature and chemical characteristics of the effluent change to create an unfavorable habitat for most bacteria and viruses.

Generally, the treated effluent percolates downward through the soil and eventually enters an aquifer. Also, a portion of the treated effluent moves upwards by capillary action and is removed at the ground surface by evaporation and transpiration of plants.



4.0 SEPTIC SYSTEM MAINTENANCE

Septic tanks and leach fields provide a long-term solution to domestic wastewater management when properly designed, constructed, and maintained. Maintenance of the septic system primarily consists of removing accumulated sludge from the septic tank, inspecting the system, and cleaning the filters.

Rosemont will use a certified operator or service provider (Certified Hauler) to perform the maintenance and inspections. A list of several certified septic system maintenance companies in Pima County is provided in Appendix A of this Plan; however, Rosemont may contract with another Certified Hauler.

4.1 Schedule Yearly inspection and servicing of each septic tank is recommended to satisfy the annual reporting requirements of A.A.C. R18-9-E323(G) that are discussed in Section 5.0. Additionally, during emergency overflow conditions, it may be necessary to haul wastewater until repairs are completed.

4.2 Procedure A Certified Hauler must be contracted and waste hauled to an approved disposal location. The technician should use the access manhole to pump the accumulated sludge, inspect the system, and clean the filter(s).

Safety precautions during septic tank and leach field maintenance should be observed. Entry into the interior of a septic tank requires a confined space entry permit, special equipment, and training. Rubber gloves and eye protection should be worn to prevent contact with bacterial contaminates. The technician should practice overall safe hygiene and wash their hands when the service is complete.

While the tank is being inspected, the inlet and outlet baffles and/or septic tank filter should be inspected. If anything is broken, repairs should be done immediately. The inlet should also be checked to see if wastewater is continuously flowing into the tank from previously undetected plumbing leaks.

Acids or bleaches should not be used to clean the tank. Additionally, it is not necessary to leave any of the sludge in the tank as “seed”. Incoming sewage contains all the bacteria needed for proper operation

Flushing the septic tank will cause the solids to be forced into the soil absorption system and may cause irreversible damage to the leach field. Flushing water into a clogged leach field will prolong the saturation of the soils and prevent oxidation of organic material in the soil pores.

The use of enzymes or other septic system additives has not been shown to be of any value. It has been observed that some of these additives can actually harm the system.

4.3 Estimated Costs In general, a standard septic system pumping, maintenance, and inspection cost will vary based on the size of the tank and disposal fees. However, the cost for a standard septic tank pumping service will range from $900 to $1,800 for a 4,000 gallon septic tank.



5.0 RECORDS AND ANNUAL REPORTING

Records shall be kept of any inspection, repairs, or maintenance activities using the form provided in Appendix B. Because the cumulative wastewater flows at the Project site facility are greater than an average of 3,000 gallons per day, annual reports of system conditions and maintenance performed must be filed with the ADEQ.

Rosemont must submit an annual report to ADEQ by the anniversary of the Discharge Authorization. The report consists of a form, provided in Appendix B, that is signed by a certified operator or service provider (Certified Hauler) and documents the following:

Provides any data or documentation required by this Plan;

Certifies compliance with the requirements of this Plan; and

Describes any additions to the facility during the year that increased flows and certifies that the flow did not exceed 24,000 gallons per day during any day.



6.0 DIAGNOSING SYSTEM PROBLEMS

Septic system failures may be caused by accumulated solids in the septic tank or clogged soil pores. Signs of a failing septic system include:

Slow draining toilets or fixtures;

Sewage backing up into buildings; and/or

Standing water over or near the leach field.

Regular pumping of the septic tank remains the best insurance against system failure. Accurate records of the system’s inspections and pumping should be performed using the form provided in Appendix B of this Plan.

The following sections have been developed to assist with common septic system problems. Some problems with septic systems can be quite difficult to diagnose. For difficult issues, contact a professional engineer, the contractor who installed the system, and/or a licensed septic system hauler for assistance.

6.1 Slow Draining Toilets If toilets or fixtures are draining slowly, check the service records for the time between servicing and pumping. Have the tanks inspected and pumped, if necessary, and clean the septic tank filters to protect the leach field. The pipe between the tank and the leach field can also be checked for obstructions if needed.

If roots are blocking the pipelines contact a commercial root removal service. Many chemicals used to remove roots may harm the septic system. Only chemical that are considered safe for septic systems may be used.

If the leach field piping has been damaged due to travel of heavy vehicles, the leach field must be replaced.

6.2 Standing Water Standing water or sewage on or near the surface of the leach field, or lush growth over the leach field may indicate that the system is being overloaded. The problem may be excessive water use and/or groundwater intrusion into the septic tank through a leaking tank seam.

Check the system for water consumption from leaky toilets or fixtures and have the tank pumped so that the system can be checked for perched groundwater intrusion into the tank, especially after a wet, rainy season.

If the system is overloaded:

Reduce water usage through conservation;

Reduce landscape irrigation near leach field; and/or

Increase the design capacity of the leach field to meet the needs of the system.

6.3 Sewage Odors Sewage odors coming from vent pipes are common with all types of disposal systems and, generally, are not a problem. Atmospheric conditions may prevent dispersion of odors during early morning and late afternoon. This problem can be alleviated by increasing the height of the vent pipe to provide for better dispersion.

APPENDIX A LIST OF CERTIFIED SERVICE COMPANIES

IN PIMA COUNTY


Tetra Tech August 2011 A-1

List of Certified Service Companies In Pima County

Aarcher Contracting Corporation 5530 N Camino De La Tierra Tucson, AZ 85705 520-743-4808

Ace Pumping & Portables 8973 South Eisenhower Road Tucson, AZ 85756 520-889-3000

Affordable Septic Systems 15590 East Rincon Creek Ranch Road Tucson, AZ 85747 520-886-5900

Arizona Roadrunner Septic Services PO Box 90708 Tucson, AZ 85752-0708 520-326-4460

Avra Marana Pumping Service 10501 N. Maybrook Ave Avra Vly Tucson, AZ 85701 520-682-3404

Cummings Plumbing Heating and Cooling 1050 S. Park Tucson, AZ 85719 520-293-6900

Curtis Plumbing 4281 East Tennessee Street Tucson, AZ 85714 520-323-7697


Tetra Tech August 2011 A-2

Gross Septic & Drain Service 8701 North Burke Drive Tucson, AZ 85742 520-742-1369

Old Pueblo Septic & Drain Service, Inc. 6955 N. Camino Martin Suite #108 Tucson, AZ 85741 520-744-1100

Reddi Services 825 E. University Blvd. Tucson, AZ 85719 520-547-3349

APPENDIX B RECORD OF INSPECTION/MAINTENANCE FORM


Tetra Tech August 2011 B-1

Rosemont Copper Project – Septic Systems RECORD OF INSPECTION/MAINTENANCE FORM

Inspection and Maintenance Services Provided By:

Company: Telephone:

Name of Technician:

Date: Time:

Location of Facility:

Check One

Septic System Location

Septic Tank Capacity (gallons)

Primary Crusher 750 Electro-Winning 1,000 Mine Truck Shop 4,000 Change House 3,000 Main Warehouse 1,000 Analytical Laboratory 1,000 Administration Building 3,000 Tailings Filter Plant 750

Septic Tank Inspection Details:

Item Condition

Satisfactory Needs Repair NA

Tank Walls Baffles

Inlet Filter Outlet Filter

Vents

Required Maintenance:

Item Performed Yes No NA

Pump out Sludge Clean Filter(s)

Additional Maintenance

Additional Maintenance Performed:

Signature of Technician:

APPENDIX D

Landfill Methane Monitoring Plan

Civil & Environmental Consultants, Inc.

11811 N. Tatum Blvd., Suite 3057, Phoenix, AZ 85028

Phone 602/760-2324 ∙ Fax 602/760-2330 ∙ Toll Free 877/234-2324 ∙ E-mail [email protected]

Austin Charlotte Chicago Cincinnati Cleveland Columbus Export Indianapolis Nashville Phoenix Pittsburgh St. Louis

Corporate Web Site http://www.cecinc.com

METHANE MONITORING PLAN

NON-MUNICIPAL SOLID WASTE LANDFILL

ROSEMONT COPPER PROJECT

PIMA COUNTY, ARIZONA

Prepared for:

4500 Cherry Creek South Drive, Suite #1040

Denver, Colorado 80246

(303) 300-0138

Fax (303) 300-0135

Prepared by:

CEC Project No. 101-179

August 2011

http://www.rosemontcopper.com/

Methane Monitoring Plan i August 2011

Non-Municipal Solid Waste Landfill CEC Project No. 101-179

Table of Contents

1.0 INTRODUCTION..............................................................................................................1

2.0 SITE INFORMATION ......................................................................................................3

2.1 Site Location ............................................................................................................3

2.2 Detailed Site Topography ........................................................................................3

2.3 Property Boundary and Limit of Waste ...................................................................3

2.4 Types of Waste ........................................................................................................4

2.5 Proposed Onsite and Offsite Structures ...................................................................4

3.0 LANDFILL CHARACTERISTICS .................................................................................5

3.1 Construction Details.................................................................................................5

3.2 Depth of Excavation ................................................................................................5

3.3 Lowest Elevation of Waste Placement ....................................................................5

3.4 Potential Migration Pathways ..................................................................................6

3.5 Explosive Gas Generation Potential ........................................................................6

4.0 DESCRIPTION OF THE PROPOSED MONITORING SYSTEM .............................7

4.1 Proposed Permanent Punch Bar Locations ..............................................................7

4.2 Construction Details, Installation Procedures and Quality Assurance

Procedures ................................................................................................................7

4.2.1 Location and Installation of New and Replacement Punch Bars ................ 8

5.0 GAS MONITORING, SAMPLING AND REPORTING PROCEDURES ................10

5.1 Monitoring Equipment ...........................................................................................10

5.2 Monitoring Procedure ............................................................................................10

5.3 Monitoring Frequency ...........................................................................................11

5.4 Monitoring Parameters...........................................................................................11

5.5 Definition of Explosive Gas Threshold Limit .......................................................12

5.6 Validation and Evaluation of Field Sampling Results ...........................................12

Methane Monitoring Plan ii August 2011


5.7 Contingency Actions for Exceedance of Explosive Gas Threshold Limit ............13

5.8 Contingency for the Installation of Additional Punch Bars ...................................14

5.9 Protection of Human Health and the Environment ................................................14

5.10 Criteria to Discontinue Contingency Monitoring ..................................................14

5.11 Reporting Procedures .............................................................................................15

5.12 Certification Report ...............................................................................................16

6.0 DISCONTINUATION OF MONITORING ..................................................................17

FIGURES

Figure 1: Site Location Map

Figure 2: Permanent Punch Bar Locations

Figure 3: Punch Bar Detail

APPENDICES

Appendix A: Drawing 001 – Existing Site Topography

Appendix B: Methane Monitoring Report Forms

Methane Monitoring Plan 1 August 2011


METHANE MONITORING PLAN

1.0 INTRODUCTION

This document has been prepared by Civil & Environmental Consultants, Inc. (CEC) for

Rosemont Copper Company (Rosemont) and presents information and supporting documentation

regarding methane gas monitoring at the Rosemont Copper Project’s (Project) proposed Non-

Municipal Solid Waste Landfill (NMSWLF; Site). This Methane Monitoring Plan (Plan) has

been prepared in response to the Arizona Department of Environmental Quality (ADEQ) Solid

Waste Plan Review Unit’s request presented in a letter to Rosemont dated December 3, 2010.

The proposed Rosemont NMSWLF will contain primarily construction/demolition debris

(C&D). C&D debris do not contain much organic matter, which is necessary to produce landfill

gas, however, there is a small potential for wood and wood-containing materials to produce

methane as they decompose. In general, landfill gases may include methane, carbon dioxide,

nitrogen, oxygen, carbon monoxide, ammonia, sulfides, and non-methane organic compounds.

Because the Rosemont NMSWLF will accept primarily construction/demolition debris, the

landfill of concern at this Site is methane.

The Code of Federal Regulations, Title 40, Part 257.3-8(a) (40 CFR §257.3-8(a)) states that

methane gas concentrations at solid waste disposal facilities “shall not exceed twenty-five

percent (25%) of the lower explosive limit [LEL] in facility structures” or the LEL “at the

property boundary.” For the purpose of this Methane Monitoring Plan, the “property boundary”

of the Rosemont NMSWLF is defined as the area within and extending to the outermost

perimeter of the constructed solid waste disposal area. The “property boundary” is limited to the

proposed landfill cell, associated constructed berms and fill areas. No structures are currently

planned to be constructed within the “property boundary”.



To ensure compliance with 40 CFR §257.3-8(a), four methane monitoring punch bars will be

permanently installed around the perimeter of the “property boundary” to ensure that any

potential methane gas produced in the landfill does not migrate from the landfill into the native

underlying sediments.

The purpose of this Plan is to establish guidelines and operating procedures for the detection of

methane gas migration at the Rosemont NMSWLF. This Plan includes a schedule for

monitoring methane gas during the operational, closure, and post-closure periods of the Project,

and specifies contingency actions in the event of an exceedance of a gas level.

Rosemont will begin implementation of this Plan following the disposal of 2,500 cubic yards

(CY) of waste material in the constructed NMSWLF.

A copy of the approved Plan will be kept in the Rosemont files for the NMSWLF as stipulated in

the Non-Municipal Solid Waste Landfill Application for the Rosemont Copper Project prepared

by CEC, Inc., dated August 2010 (Rosemont NMSWLF APP Application).



2.0 SITE INFORMATION

2.1 Site Location

The proposed NMSWLF will be located in the northern portion of the Rosemont Copper Project

on privately owned land. The proposed NMSWLF will consist of 2.6 acres of disturbed area; the

actual footprint of the waste disposal area will be 1.85 acres. The NMSWLF will be located in

the northwest quarter of Section 30 in Township 18 South, Range 16 East. The approximate

latitude and longitude of the NMSWLF is 31° 50’ 8.42” North and 110° 44’ 47.40” West.

Figure 1 presents the proposed layout of the Project and the relative location of the NMSWLF

within the Project boundaries.

2.2 Detailed Site Topography

This existing topography of the NMSWLF area consists of steep hillsides with grades varying

from 5 to 50 percent, sloping from northwest to southeast. Elevations within the existing

NMSWLF area range from approximately 5,190 feet above mean sea level (amsl) in the

southeast to 5,280 feet amsl in the northwest. Existing topography of the NMSWLF is presented

on Drawing 001, provided in Appendix A of this Plan, and previously provided in Appendix N

of the Rosemont NMSWLF APP Application.

There are no perennial or intermittent drainage systems, springs, or wetlands within or adjacent

to the proposed NMSWLF.

2.3 Property Boundary and Limit of Waste

The “property boundary”, limits of grading, and the horizontal limit of waste placement of the

proposed NMSWLF are shown on Figure 2.



2.4 Types of Waste

Types of waste that will be accepted and placed in the proposed Rosemont NMSWLF include:

Clean fill: clean rock (no sulfide-bearing materials) and soil;

C&D debris, as defined in A.R.S. § 49-701(5) and 701(7);

Inert material, as defined in A.R.S. § 49-701(15);

Landscape rubble, as defined in A.R.S. § 49-701(17);

Vegetative waste, as defined A.R.S. § 49-701(36);

Rubbish, as defined in A.A.C. R18-13-302.H;

White goods;

Empty metal containers;

Dry paper and cardboard;

Plastic containers and products; and

Glass.

2.5 Proposed Onsite and Offsite Structures

Several mine-related structures are proposed to be constructed within the 1,000-foot offset from the

limit of waste placement within the NMSWLF. The locations of the nearest structures are

illustrated on Figure 1. A proposed rock conveyor and substation are located approximately 350

feet and 500 feet, respectively, from the outer perimeter of the NMSWLF.



3.0 LANDFILL CHARACTERISTICS

3.1 Construction Details

The proposed liner system for the Rosemont NMSWLF consists of (top to bottom):

Cover/cap - 24-inch thick compacted soil layer with a permeability of less than or equal

to 1x10-6

centimeters per second (cm/sec); and

24-inch thick re-compacted clay layer (referred to herein as the re-compacted soil liner,

or RSL) with a permeability of less than or equal to 1x10-6

cm/sec. Clayey soils,

excavated from an appropriate area within the Project boundaries, will be compacted to

form the RSL.

The final cap system will consist of (top to bottom):

6-inch evapotranspiration vegetative cover;

18-inch final cover soil; and

6-inch intermediate cover/foundation layer.

3.2 Depth of Excavation

The proposed NMSWLF excavation depths will range from five (5) feet to approximately 43 feet

deep, based on Site topography and the elevation of the base of the RSL. The lowest excavation

elevation of the entire NMSWLF footprint is approximately 5,190 feet amsl (at the toe of

northeastern fill slope).

3.3 Lowest Elevation of Waste Placement

The lowest elevation of waste placement in the proposed NMSWLF will be approximately 5,234

feet amsl.



3.4 Potential Migration Pathways

Potential gas migration pathways for the NMSWLF identified above include unpaved roads, fill

beneath an adjacent diversion channel, and possible underground utilities (although no utilities

are currently planned). Excavation depths required for the roadway construction will be shallow

with respect to native ground surface in comparison to the depth of the excavation of the landfill

floor, resulting in a low likelihood for landfill gas migration through the roadway fill. In

addition, because the liner system of the proposed NMSWLF will be excavated into the bedrock,

the potential for explosive gas to migrate offsite into unconsolidated fill or bedrock is unlikely.

If landfill gas migrated into the outer slopes of the NMSWLF, the gases would quickly find a

pathway upward and vent to the air.

3.5 Explosive Gas Generation Potential

Landfill gas is known to be produced at non-municipal solid waste landfills and is generated

during anaerobic degradation of organic wastes (food, paper, wood, etc.). Landfill gas consists

of methane, carbon dioxide and small trace levels of non-methane organic compounds. Because

the waste proposed to be accepted and disposed of in the Rosemont NMSWLF will consist

primarily of C&D debris, which does not contain much organic matter, the potential for the

production of explosive gas generation at this landfill is to be expected minimal.



4.0 DESCRIPTION OF THE PROPOSED MONITORING SYSTEM

The methane monitoring system described in this Plan is designed to detect the migration of

methane gas towards the “property boundary” or nearby structures. The early detection of gas

migration will allow corrective measures to be implemented as soon as possible.

The proposed monitoring system for the NMSWLF will consist of four (4) permanent

monitoring punch bars. Permanent monitoring punch bars will be installed at selected locations

around the perimeter of the NMSWLF as shown on Figure 2.

4.1 Proposed Permanent Punch Bar Locations

The proposed punch bar locations were selected to provide coverage of potential migration

pathways to nearby proposed structures as well as the nearby roadway and stormwater diversion

channel. The punch bars will extend below the base of the waste placement elevation as

measured in the vicinity of the nearest punch bar location.

4.2 Construction Details, Installation Procedures and Quality Assurance Procedures

The typical punch bar construction detail is provided in Figure 3. Each proposed gas monitoring

punch bar will be advanced to a depth equal to the greatest depth of buried waste nearest to the

punch bar. Boreholes will be advanced with a hand auger or other suitable method. Punch bars

will be constructed using a 1-inch or 2-inch inner diameter, Schedule 40 PVC solid riser and

screened pipe.

The screened section of the PVC will be either perforated with 3/16-inch diameter holes or

slotted with 0.020-inch wide slots to allow gas to collect within the riser. The flush threaded

solid riser pipe will extend from the perforations to approximately 3 feet above ground surface

and be fitted with a sample port; the sample port will provide positive closure when not being



sampled and facilitate connection to the gas sampling instrument. The screened section of the

PVC will extend from approximately 2-3 feet below the ground surface to the bottom of the

borehole. Gravel will be backfilled into the borehole annulus from the total depth of the boring

to approximately 3 feet below the ground surface. A 2-foot thick bentonite seal will be placed

above the gravel and a 3-foot thick concrete or concrete/bentonite seal will be placed in the upper

3 foot of the punch bar annulus. The permanent punch bar installation is then completed with a

steel protective casing, concrete pad and lock. The concrete pad will be sloped away from the

casing to provide positive drainage after settlement and concrete shrinkage. The casings will

have ½-inch condensate relief openings (weep holes). Bollards will be installed as necessary.

The punch bars will be constructed and installed under the supervision of a qualified engineer or

geologist. In addition to supervising the installation, a qualified Rosemont employee will document

the installation to ensure compliance with this approved Plan. Documentation will include boring

logs and installation details, copies of which will be provided to the ADEQ Solid Waste Inspections

and Compliance Unit.

4.2.1 Location and Installation of New and Replacement Punch Bars

In the event that a punch bar is damaged, Rosemont will notify the ADEQ Solid Waste

Inspections and Compliance Unit within 30 days of discovering the damage. A damaged punch

bar shall be replaced before the next monitoring event. A punch bar will be considered damaged

if it cannot be monitored for two consecutive months. The replacement punch bar shall be

located so as to monitor the same pathway and shall be located in the same vicinity as the

damaged punch bar.

In the event that a new occupied structure, or other future improvement resulting in the creation

of an additional gas migration pathway, is built within 1,000 feet of solid waste placement, a

location for a new additional methane monitoring punch bar will be submitted to the ADEQ

Solid Waste Plan Review Unit for review and approval. The new punch bar will be located



between the new structure or explosive gas pathway and the limit of solid waste placement. The

existing punch bars will continue to be monitored in accordance with the approved plan.



5.0 GAS MONITORING, SAMPLING AND REPORTING PROCEDURES

5.1 Monitoring Equipment

A portable gas monitor (such as Landtec GEM 500 or equivalent) will be utilized to determine

percent LEL and percent methane by volume. A differential pressure gauge will be used to

measure pressure in the punch bars.

Weather information, including barometric pressure, temperature, and relative humidity, will be

recorded in conjunction with methane monitoring. Temperature and relative humidity will be

obtained from an on-site local weather station. Barometric pressure will be obtained using a

handheld device.

5.2 Monitoring Procedure

The following procedure will be followed during each sampling event.

Pressure Test

1. Zero gauge on instrument.

2. Connect tube to stop-cock type fitting at top of gas punch bar riser pipe. Open

stop-cock valve and record the instrument reading on the Methane Monitoring Report

Form.

3. Close stop-cock valve and remove connector tube.

Percent Gas/LEL Test

1. Calibrate the instrument according to the instructions provided in the equipment manual.

2. Remove lock and protective cap.

3. Turn meter on and set instrument to zero on both LEL and percent gas scales.



4. Set meter to percent volume scale.

5. Insert the sample tube to into the punch bar riser.

6. Obtain an initial reading and record highest reading on the Methane Monitoring Report

Form. If no reading is shown, switch to percent LEL and repeat procedure.

7. Validate exceedances in accordance with Section 5.5 of this Plan.

Weather Data

1. Record temperature, barometric pressure, and relative humidity.

2. Record the weather data on the Methane Monitoring Report Form.

5.3 Monitoring Frequency

Four permanent gas monitoring punch bars are proposed to be installed at the Project NMSWLF

at the locations identified on Figure 2. The specified monitoring frequency will be quarterly,

beginning at construction of the landfill through post-closure of the landfill. Upon completion

of post-closure activities for the NMSWLF, the punch bars will be abandoned.

5.4 Monitoring Parameters

The monitoring equipment shall have a detection limit below 25 percent of the LEL with a

minimum detection limit of zero (0) percent by volume. The following parameters are to be

monitored as described in the following order:

Gas pressure in the permanent monitor

Initial combustible gas concentration in percent methane by volume

Water level in the permanent monitor

Ambient barometric pressure

Ambient air temperature



Observed weather conditions

Relative humidity

The collected data will be recorded on a Methane Monitoring Report Form and the information

managed as required in the APP permit. In addition, the Methane Monitoring Report Forms

must include date/time of measurement; punch bar ID from which measurement was collected;

and name of sampler. A copy of a Methane Monitoring Report Form is provided in Appendix B

of this Plan.

5.5 Definition of Explosive Gas Threshold Limit

Pursuant to 40 CFR §257.3-8(a), the explosive gas threshold limit is defined as:

100 percent of LEL (5 % CH4 v/v) at or within the “property boundary” (as defined in

Section 1.0); and

25 percent of LEL (1.25 % CH4 v/v) in structures located on the NMSWLF (applicable

only if structures are constructed within the “property boundary”.)

5.6 Validation and Evaluation of Field Sampling Results

Upon completion of testing for each monitoring event, results will be recorded in the appropriate

column of the Methane Monitoring Report Form and reviewed to identify possible anomalous

reading. If anomalous readings are evident, the punch bar in question should be retested to verify

results.

If an exceedance of the explosive gas threshold limit is detected in a gas monitoring punch bar,

the following steps shall be taken:



Recalibrate the equipment;

Immediately conduct a verification test; and

If the exceedance of explosive gas is verified, the procedures outlined in the contingency

plan (Section 5.7) will be followed. If the exceedance is not verified, quarterly

monitoring will continue with no further contingency actions required.

An anomalous reading is considered one that exceeds the explosive gas threshold limit or

maximum percent of gas allowable for each monitor location, which is listed in the Methane

Monitoring Report Form.

5.7 Contingency Actions for Exceedance of Explosive Gas Threshold Limit

In the event that explosive gas concentrations equal or exceed the explosive gas threshold limit

for a particular gas monitoring location, the following contingency actions will be implemented:

Take all necessary steps to ensure protection of human health and the environment.

Notify the ADEQ Solid Waste Inspections and Compliance Unit (at 602-771-4418)

within 48 hours.

Increase monitoring frequency of all punch bars from quarterly to weekly.

Continue weekly monitoring at all punch bars until such time that the gas concentration

in all punch bars has decreased to below the explosive gas threshold limit for three (3)

consecutive monitoring events, over a minimum period of two (2) weeks.

If methane gas exceedances continue, install punch bar(s) in the vicinity of the punch

bar(s) where exceedances are determined, as specified in Section 5.10 below.

Within 30 days of detection, submit a written corrective action plan to the ADEQ Solid

Waste Inspections and Compliance Unit for approval.



Upon approval by ADEQ, Rosemont will implement the corrective action plan within 30

days, or as soon as is practical. Rosemont will maintain records of all corrective activity

as per permit requirements.

5.8 Contingency for the Installation of Additional Punch Bars

If Rosemont determines that the concentration of explosive gas is of concern, additional punch

bar(s) may be installed and monitored in the vicinity of the area of concern to determine the

extent of gas migration. Punch bar stations will be installed on a 50-feet grid until the lateral

extents of the migrating gas are determined.

5.9 Protection of Human Health and the Environment

Section 5.7 lists the contingency actions that will be taken in the event of a recorded methane gas

measurement equal to or above the explosive gas threshold limit. Additional corrective measures

may be necessary to ensure that the validated exceedance of gas concentrations is decreased to or

below the explosive gas threshold limit. These steps will be taken after consultation and

approval from the ADEQ Solid Waste Inspections and Compliance Unit to ensure protection of

human health and the environment. Upon approval from ADEQ, mitigative or remedial measures

will be implemented by Rosemont to ensure protection of human health and the environment.

5.10 Criteria to Discontinue Contingency Monitoring

As stated above in Section 5.7, after three (3) contiguous monitoring events over a minimum

period of two (2) weeks in which concentrations in all punch bars are reported to be below the

explosive gas threshold limit, Rosemont will resume routine quarterly monitoring.



5.11 Reporting Procedures

Detection of gas concentrations equal to or exceeding the explosive gas threshold limit during

methane monitoring events will require the following reporting steps be taken:

Notify the ADEQ Solid Waste Inspections and Compliance Unit (at 602-771-4418) by

phone or in writing within 48 hours of the initial detection of gas concentrations equal to

or above the explosive gas threshold limit.

Within seven (7) days of initial detection of gas concentrations equal to or above the

explosive gas threshold limit, submit to ADEQ Solid Waste Inspections and Compliance

Unit, the monitoring results and description of contingency steps to be taken to protect

human health; and

Within 30 days of initial detection of gas concentrations equal to or above the explosive

gas threshold limit, submit to ADEQ Solid Waste Inspections and Compliance Unit a

written report that includes the following:

o A tabulated summary of the recorded gas measurements from the contingency

monitoring;

o Copies of the gas measurement forms;

o A description of the exceedance and its potential cause(s);

o The period of exceedance of the explosive gas threshold limit and the anticipated time

period during which the exceedance is expected to continue;

o A proposal for mitigative or remedial actions, if necessary, to be taken to ensure

protection of human health and the environment.

When contingency actions are no longer required, as described in Section 5.10, submit to

the ADEQ Solid Waste Inspections and Compliance Unit a written report containing the

following:

o Analysis and summary of the results from the contingency monitoring;

o Consideration of possible causes of the increase in gas concentrations; and



o Documentation of exceedances that initiated contingency action, any increased

monitoring, and any corrective actions taken.

A copy of all reports regarding the contingency actions will be kept as prescribed in the APP

permit.

5.12 Certification Report

Certification documentation for the proposed punch bars at the landfill will be provided

following installation. Locations and identification of the punch bars are shown on Figure 2.

Upon installation of replacement permanent punch bar stations, a certification report shall be

submitted with the initial reporting of the monitoring results. The documentation shall include

the following information:

Record drawing showing the locations and identifications of all punch bars.

Geologic logs from installation of each punch bar.

Depth and length of screened intervals for each punch bar.

Initial gas monitoring results.

Copies of all certification reports, monitoring results, contingency reports, and all revisions will

be maintained as specified in the permit



6.0 DISCONTINUATION OF MONITORING

Punch bar monitoring will continue through operation, closure, and post-closure of the Rosemont

NMSWLF as required by the area-wide APP. Upon completion of post-closure monitoring

activities at the Rosemont NMSWLF, and with the approval of ADEQ, the punch bars will be

removed or abandoned as will be specified in the Closure Plan.

FIGURES

APPENDIX A

DRAWING 001 – EXISTING SITE TOPOGRAPHY

APPENDIX B

METHANE MONITORING REPORT FORM

APPENDIX BROSEMONT COPPER NMSWLF GAS MONITORING

PUNCH BAR DEPTHS

PUNCH BAR DESIGNATION DEPTH (FT) THRESHOLD LIMIT (% of LEL)

GM-1 6 100

GM-2 6 100

GM-3 6 100

GM-4 6 100

GM-5 6 100

PROBE DESIGNATION DEPTH (FT) THRESHOLD LIMIT (% of LEL)

N/A N/A N/A


N/A N/A N/A

EXISTING GAS MONITORING PROBES

PROPOSED PUNCH BARS

EXISTING PUNCH BARS


N/A N/A N/A

PROPOSED GAS MONITORING PROBES

App B 101179.xls Civil & Environmental Consultants, Inc. February 2011

APPENDIX E

Product Review Plan

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

Product Review Plan

June 2018

Prepared by:

Rosemont Copper Company

Product Review Plan, Rev. 2 Page i

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

Product Review Plan, Rev. 2 Page ii

Table of Contents 1.0 INTRODUCTION ................................................................................................................... 1

2.0 DEFINITIONS ........................................................................................................................ 2

3.0 PLAN IMPLEMENTATION RESPONSIBILITY ..................................................................... 3

3.1 PLAN MANAGEMENT ................................................................................................... 3

3.2 PRODUCT REQUEST FOR APPROVAL ...................................................................... 4

3.3 PURCHASING ............................................................................................................... 5

3.4 DEPARTMENT SUPERVISORS ................................................................................... 5

3.5 EMPLOYEES ................................................................................................................. 5

3.6 CONTRACTORS ........................................................................................................... 5

4.0 PROCEDURES ..................................................................................................................... 6

4.1 GENERAL NEW PRODUCT APPROVAL REQUIREMENTS ....................................... 6

4.2 CHANGE IN PRODUCTS CURRENTLY IN USE AT THE FACILITY ............................ 6

4.3 RESEARCH PRODUCT APPROVAL ............................................................................ 6

4.4 TEMPORARY REMOVAL OR TERMINATION OF PRODUCTS................................... 6

4.5 CHANGE IN PRODUCT MANUFACTURER INFORMATION ....................................... 7

5.0 TRAINING ............................................................................................................................. 8

5.1 EMPLOYEE TRAINING ................................................................................................. 8

5.2 TRAINING RECORDS ................................................................................................... 8

Product Review Plan, Rev. 2 Page 1

1.0 INTRODUCTION

This Product Review Plan (Plan) has been prepared by Rosemont Copper Company (Rosemont) to provide an approach for evaluating products proposed for use at the Rosemont Copper Project (Project). This Product Review Program requires all products be submitted into Rosemont’s MSDSonline System for review and approval prior to use. Ultimately a master list of approved products will be retained in Rosemont’s MSDSonline System. This list will be available to Rosemont and to its vendors and contractors. This will help ensure that products are approved prior to transport to the Project site. Product information imported into the MSDSonline System will also inform Rosemont’s Hazard Communication Program Plan (MPO Volume II-n) and Emergency Planning and Community Right to Know Act, Section 313 Reporting Plan (TRI Plan) (MPO Volume IV-i).


2.0 DEFINITIONS

The following definitions are used in this Plan:

Current SDS – Current (one year old or less) Safety Data Sheet.

EPA List of Lists - found at (https://www.epa.gov/epcra/epcracerclacaa-ss112r-consolidated-list-lists-march-2015-version identifies hazardous and regulated materials.

MSDSonline – An online management software program that organizes, categories, and retains current SDS information.

Product – Any element, commercial product, compound, or mixture of elements and/or compounds which will be used or consumed on site.

Property – Areas associated with the Rosemont Copper Project.

SDS – Safety Data Sheet (previously known as Material Safety Data Sheet [MSDS]) is a formal document containing important information about the characteristics and actual or potential hazards of a substance. It identifies the manufacturer of the material (with name, address, phone, and fax number) and usually includes (1) chemical identity, (2) hazardous ingredients, (3) physical and chemical properties, (4) fire and explosion data, (5) reactivity data, (6) health hazards data, (7) exposure limits data, (8) precautions for safe storage and handling, (9) need for protective gear, and (10) spill control, cleanup, and disposal procedures. Mandated by the U.S. Occupational Safety and Health Administration (OSHA), it is used also in many other countries in one form or the other.

Requestor – Any entity, (department, group, employee, contractor, vender etc.) requesting a product for use on the Rosemont Project site(s). Toxic Substances Control Act (TSCA) - of 1976 provides EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics and pesticides.


3.0 PLAN IMPLEMENTATION RESPONSIBILITY

3.1 PLAN MANAGEMENT

The Environmental and Safety Departments and the respective Department managers where the products are planned for use will administer this Plan. The duties of the Managers, or their designees, are:

To oversee the administrative functions associated with this Plan;

Assure that the evaluation of each product requested is comprehensive and complete prior to product approval (i.e., risk assessment with regard to safety and environmental considerations).

With regard to environmental impact, the evaluation should include potential issues with hazardous material management, hazardous or solid waste disposal, empty container management and disposal, product tracking and reporting, effluent treatment system impact, emergency release considerations, storage requirements, and applicability to other current, proposed and new regulations.

If the product has constituents listed on the EPA List of Lists, the following actions should be initiated:

o Enlist the requestor to search for an unlisted replacement product;

o If replacement cannot be found, develop product management procedures for all that apply:

Hazardous material management;

Empty container management and disposal,

Effluent treatment system impact;

Emergency release considerations;

Labeling requirements;

Storage requirements; and

Waste determinations including hazardous disposal;

o Set up product Toxic Release Inventory (TRI) tracking, and Toxic Substances Control Act (TSCA) tracking in MSDSonline;

o Determine fire plan/permit quantity limits;

o Determine SPCC Plan requirements; and

o Review for other applicable regulatory restrictions.

Perform safety and health hazard determinations, including labeling criteria and safety/eyewash requirements and the identification of personal protective equipment for all new products.

Reject or limit use of products that could pose environmental, health, or safety concerns, business limitations, or excessive costs to store, use or dispose of properly.


Notify the requestor of approval and rejections upon completion of the review.

Audit, maintain and update the MSDSonline System database of approved products.

Develop appropriate training requirements prior to a product’s introduction in accordance with the Hazard Communications Program (MPO Volume II-n).

Notify contractors of the need to provide information to those affected by any hazards caused by a new product.

Assist requestor when needed with implementation of the control and safety requirements.

Manage all products that could become a waste with waste profile development, waste management, and tracking procedures as described in the Materials Management Plan (MPO Volume II-p).

3.2 PRODUCT REQUEST FOR APPROVAL

To introduce a new product or new use of an existing product, the requestor will:

Obtain current SDS and environmental information, and any other pertinent product literature or information, which may assist in the product evaluation.

Provide additional information regarding storage location, quantities, and use must be provided with the SDS so the material can be classified and evaluated completely.

Upload the SDS for the product being requested into the MSDSonline System for review.

Products required for submittal for approval include but are not limited to:

contractor specialty products used in construction or process equipment maintenance and repair;

mineral processing products or reagents;

research products;

laboratory reagents;

core and water well drilling products;

lubricants;

solvents;

products contained in aerosol cans;

insecticides;

pesticides;

herbicides; or

any other product that may have an environmental or safety impact.


3.3 PURCHASING

All new products must be submitted to and be reviewed and approved by the Environmental and Safety Departments prior to purchase. The Purchasing Department will be required to validate that the item being purchased is on the approved products in the MSDSonline System application.

3.4 DEPARTMENT SUPERVISORS

Department Supervisors will:

Ensure employees understand how to access the MSDSonline System; and

Provide adequate training as prescribed in the Hazard Communications Program Plan (MPO Volume II-n).

3.5 EMPLOYEES

Employees are responsible for using only products listed in MSDSonline list of approved products.

3.6 CONTRACTORS

Contractors and their sub-contractors are also responsible for complying with the Product Review Program. Products that are not approved and listed on MSDSonline are not allowed on the Project site.


4.0 PROCEDURES

4.1 GENERAL NEW PRODUCT APPROVAL REQUIREMENTS

The following applies to any new product that is requested for use on the Project.

All products must be submitted to MSDSonline for reviewed and approval by the Environmental and Safety Departments prior to purchase and or transported on to the Project site. New products must meet all environmental permit and authorization requirements prior to purchase. Products brought onto the property must have an accurate, complete, and legible SDS.

A separate product review is required for each product. This includes those products that have more than one manufacturer, i.e., diesel fuel from Chevron, diesel fuel from Firebird Fuels, etc.

A new product approval is required if the purpose for, or the application of, the product changes.

Third Party Contractor products must go through this same process and be registered in the MSDSonline System. The SDS and product evaluation associated with those products must be provided to the contractor so that Contractor employees receive the proper training on product handling.

4.2 CHANGE IN PRODUCTS CURRENTLY IN USE AT THE FACILITY

The new product must be submitted into the MSDSonline system for review approval by the Environmental and Safety Departments in accordance with the Hazard Communications Program (MPO Volume II-n).

4.3 RESEARCH PRODUCT APPROVAL

In the event that Rosemont finds it necessary to perform test work with a specific product, the following will apply:

The new product approval process must be followed (see Section 4.1).

Research products will be approved for use for no more than 12 months. Upon reaching this time limit, the user must be determined whether the product will be:

o Added to list as an approved product;

o Re-approved as a research product;

o Removed by Rosemont or the contractor/consultant;

o Returned to the vendor; or

o Disposed of in accordance with the Materials Management Plan (MPO Volume II-p).

The Requestor will be responsible for sending status reports to the Environmental, Safety, and affected departments regarding the status of research products.

4.4 TEMPORARY REMOVAL OR TERMINATION OF PRODUCTS

The Environmental and Safety Departments must be notified by a product Requestor if that product is being replaced or will no longer be used. The notification must include:


Name and manufacturer of product; and

Date when product will be removed from the site.

Either the Environmental or Safety Department will mark the product as inactive in the database. At this time, the product can no longer be used on-site.

4.5 CHANGE IN PRODUCT MANUFACTURER INFORMATION

The MSDSonline System constantly updates product SDS information as manufacturers release new data. Printed SDS should be considered out of date.

If a new SDS is received for an existing product, it must be compared to the data listed on MSDSonline. If there are changes in the product information, the Environmental and Safety Departments will review and approve the product (if warranted). If the status of the product changes, the Environmental and Safety Departments will work with the Requester to identify an acceptable substitute. The Environmental and Safety Departments will update the online MSDS System to reflect changes.


5.0 TRAINING

5.1 EMPLOYEE TRAINING

Employees who purchase, request, or use products will be trained on the MSDSonline program. Annual training will be provided in accordance the Hazard Communications Program Plan (MPO Volume II-n).

5.2 TRAINING RECORDS

Training records will be maintained in accordance the Hazard Communications Program Plan (MPO Volume II-n), applicable regulations, and Rosemont’s Records Retention Policy.