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HomeMy WebLinkAbout20140611_Operations_Plan NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL AND NATURAL RESOURCES DIVISION OF ENERGY, MINERAL AND LAND RESOURCES OPERATIONS PLAN FOR THE AURELIAN SPRINGS MINE ILUKA Submitted to: Iluka Resources, Inc. 413 Becker Drive Roanoke Rapids, NC 27870 (252) 533-9032 ( KL EINFEL DER &right People.Right Solutions. Submitted By: Kleinfelder Southeast, Inc 3500 Gateway Centre Blvd, Suite 200 Morrisville, NC 27560 (919) 755-5011 Aurelian Springs Mine Iluka Resources, Inc. Table of Contents 1.0 Executive Summary...........................................................................................................5 2.0 Permit Application .............................................................................................................5 2.1 Introduction..................................................................................................................5 2.2 North Carolina Mining Permit Application....................................................................6 3.0 Permit Notification .............................................................................................................6 3.1 Adjacent Property Owner Notification .........................................................................6 3.2 Local Government Notification ....................................................................................6 4.0 Signage...............................................................................................................................7 5.0 Bond and Permit Fees.......................................................................................................7 6.0 Other Permit Requirements ..............................................................................................7 7.0 Operations Plan..................................................................................................................8 7.1 Introduction..................................................................................................................8 7.2 Mining Method.............................................................................................................8 7.2.1 General............................................................................................................8 7.3 Impoundment Design Guidelines..............................................................................11 7.4 Processing Method....................................................................................................15 7.4.1 Concentration ................................................................................................15 7.5 Spoil, Overburden and Waste Disposal Handling .....................................................16 7.6 Topsoil Handling........................................................................................................17 7.6.1 Class "B„ Biosolids ........................................................................................18 7.7 Haul Road and Access Points...................................................................................18 7.8 Dust Control ..............................................................................................................20 7.9 Groundwater..............................................................................................................20 7.9.1 Groundwater Monitoring and Protection.......................................................22 7.10 Process Water Discharges........................................................................................23 8.0 Drainage & Erosion Control Plan ...................................................................................23 8.1 Drainage & Erosion Control Design ..........................................................................23 8.1.1 Active Mining Area.........................................................................................23 8.1.2 Perimeter Sediment Control ..........................................................................24 8.1.3 Concentrator Plant.........................................................................................25 8.1.4 Tailings Area..................................................................................................25 8.1.5 Slurry Piping ..................................................................................................26 Kleinfelder, Inc. Page 2 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. 8.2 Construction, Maintenance and Abandonment.........................................................26 8.2.1 Construction ..................................................................................................26 8.2.2 Maintenance..................................................................................................27 8.2.3 Decommissioning ..........................................................................................27 9.0 NPDES Permit...................................................................................................................27 9.1 Concentrator Site Discharges ...................................................................................27 9.2 Mine Area Discharges...............................................................................................27 9.2.1 Inspection and Representative Outfall Status Plan .......................................27 9.2.2 Representative Outfall Status........................................................................28 9.2.3 Diffuse Flow...................................................................................................28 9.2.4 Pumping O&M Plan.......................................................................................28 10.0 Reclamation Plan .............................................................................................................28 10.1 Post-Mining Land Use...............................................................................................28 10.2 Backfilling and Regrading..........................................................................................28 10.2.1 Waste Materials.............................................................................................28 10.2.2 Regrading Topsoil .........................................................................................30 10.3 Re-vegetation............................................................................................................31 10.4 Wetland Mitigation and Restoration ..........................................................................32 11.0 References........................................................................................................................32 Kleinfelder, Inc. Page 3 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. List of Figures Figure 1 General Location Map Figure 2 USGS Map Figure 3 County Highway Map Figure 4 Parcels Map Figure 5 1000' Offset from Parcels Map Figure 6 Stream and Wetlands Map Figures 7 Mine Plan Figure 8 Well Piping Schematic Overview Figure 9 Reclamation Plan Figure 10 Visibility Plan List of Appendices Appendix A Table of Adjacent Parcel Owners Appendix B Halifax County Conditional Use Permit Appendix C Affidavit of Notification and Certified Mail Receipts (Forthcoming) Appendix D Land Entry Agreements (Forthcoming) Appendix E Groundwater Withdrawal Mitigation Plan Appendix F Process Flow Diagrams Appendix G Erosion and Sediment Control Plans Appendix H Erosion and Sediment Control Calculations Appendix I Concentrator Site Plans Appendix J Concentrator Site Stormwater Calculations Appendix K Correspondence with USACE Appendix L Copy of Declaratory Ruling Request Kleinfelder, Inc. Page 4 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. 1.0 Executive Summary Iluka Resources (NC) LLC (Iluka) is proposing a new mineral sands operation in Halifax County, North Carolina. The mining operation includes the operation of a centralized wet mill concentrator site. Ore will be mined with a mobile mining unit and pumped to the concentrator. A mineral sand concentrate will be produced at the concentrator and will then be hauled off-site to an existing separation plant in Stony Creek, Virginia. This permit application is for mining activities and the associated concentrator site. Located southwest of Roanoke Rapids, North Carolina, this mine and concentrator plant would be the first such facility operated in North Carolina. Mineral Sands (titanium-bearing ilmenite and zircon) occur within the ore bodies situated in the innermost Coastal Plain sediments adjacent to the Fall Zone. Mining will occur in mining pits of varying size. Ore is a mixture of minerals sands (-10%), quartz sand (-60%), and kaolinitic clay (-30%), and will be excavated by a track-mounted excavator. Mining depths will average 15 to 20 feet across the site. Operations to be conducted at the Aurelian Springs mine and concentrator plant include land preparation ahead of mining, mineral sand ore excavation, concentration, tailings placements, regrading, and reclamation. Iluka has completed a permitting analysis to identify the local, state, and federal permits needed for the Aurelian Springs mine. The surface water, stormwater, and process water will be addressed through the required permit activities. The mining permit application identifies the adjacent property owners, utilities, and local governments notified of the planned mining operation. Supporting documentation is included in the appendices of this document. The necessary bond for this application will be submitted once Iluka is notified by the North Carolina Department of Environmental Protection (NCDENR), Division of Energy, Mining and Land Resources of the final bond. 2.0 Permit Application 2.1 Introduction Mineral sands are the name most often given to sands containing ilmenite (a titanium mineral) and zircon. These sands occur in economically viable concentrations in Coastal Plain sediments adjacent to a geologic feature known as the Fall Zone, which runs from New Jersey to Florida primarily west of Interstate 95. Iluka Resources Ltd. (together with its subsidiaries) (collectively and individually herein referred to as "Iluka") is one of the world's leading producers of zircon and titanium minerals. Iluka's operations in the United States presently are conducted by its subsidiary, Iluka Resources Inc. and include: (1) a mineral separation plant in Stony Creek, Virginia; (2) two active mine sites, one in Greensville County, Virginia and one in Dinwiddie/Sussex Counties, Virginia, including a wet concentrator plant at each site; and (3) three former mine sites in final reclamation located in Dinwiddie County, Virginia; Clay/Putnam Kleinfelder, Inc. Page 5 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Counties, Florida; and Brantley County, Georgia. Iluka is proposing the development of a new mineral sands mine and wet concentrator plant in Halifax County, North Carolina, which will be called the Aurelian Springs mine. Operations to be conducted at the Aurelian Springs mine and concentrator plant include mineral sand ore excavation, concentration, tailing, and reclamation. Extractable deposits are discontinuous throughout the area. The mining strategy will be to operate a centralized concentrator site in close proximity to several mineral sands mining locations. Ore will be mined with excavators and placed in a mobile mining unit and pumped to the concentrator. At the concentrator, the mineral sands ore will be concentrated by gravity separation and a mineral-sand concentrate produced. The mineral-sand concentrate will then be trucked to the existing Mineral Separation Plant (MSP) in Stony Creek, Virginia. The life of the mine is anticipated to be approximately 5 to 10 years with average mining depths of 15 to 20 feet. The proposed Aurelian Springs project site includes 70 parcels encompassing approximately 3,772 acres. This also includes approximately 68 acres for a new wet concentrator plant location. Figures 1, 2, and 3 identify the proposed permit boundaries for the Aurelian Springs Mine and Concentrator Plant. Figure 4 identifies the 70 parcels within the permit boundary. Land entry agreements for those 70 parcels are provided in Appendix D (forthcoming). Disturbance activities will include discreet active mining areas, the construction and operation of a new wet concentrator plant, a lay-down yard, pipeline corridors, process water and storm water ponds, a developed water source, and various support services. This operations plan provides support for the NCDENR Mining Permit Application and the National Pollutant Discharge Elimination System (NPDES) NCG020000 Notice of Intent. 2.2 North Carolina Mining Permit Application The mining permit application is under separate cover. 3.0 Permit Notification 3.1 Adjacent Property Owner Notification Adjoining property owners within 1,000 feet of the proposed permit boundary were notified to allow public participation in the permitting process. Figure 5 presents shows the adjoining owners within 1,000 feet of the permit boundary, and Appendix A identifies the tax parcel numbers for these owners. Appendix C presents the Affidavit of Notification for all adjoining property owners notified. Appendix C will also include the forthcoming certified mail receipts. 3.2 Local Government Notification Halifax County issued a Conditional Use Permit (CUP) to Iluka on November 13, 2013 allowing surface mining and reclamation within the 70 subject parcels. The CUP is included in Appendix Kleinfelder, Inc. Page 6 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. B. The county was also notified and is included on the affidavit in Appendix C. 4.0 Signage Signs will be erected on Aurelian Springs Road at the entrances to the concentrator site property. The site layout for the concentrator plant is presented as in Appendix I. The signs will display the following: ILUKA RESOURCES (NC) LLC AURELIAN SPRINGS MINE AND CONCENTRATOR PLANT NCDENR PERMIT# (pending) MSHA MINE ID # (pending) 5.0 Bond and Permit Fees The appropriate reclamation bond will be provided upon Iluka receiving a request or billing from NCDENR. It is anticipated that the blanket bond will apply to this operation. Figure 7 illustrates two proposed boundaries for the mine site: a permit boundary and a bond boundary. The total acreage within the proposed permit boundary is 3,772 acres. The bond boundary represents the limits of disturbed land within the first three to four years (approximately) of operations and includes 590 acres (includes concentrator, mine, and surrounding operations). The remaining unaccounted acreage includes buffer areas and wetlands within the permit boundary, which are not anticipated to be disturbed. 6.0 Other Permit Requirements To assist Iluka's Aurelian Springs project team in the permitting process, other local, state, and federal permits were identified that may be required for the proposed Aurelian Springs Mine and Concentrator Plant. Anticipated required permits include: • Halifax County Conditional Use Permit (issued November 13, 2013) • North Carolina Division of Water Resources 401 Water Quality Certification (not required for initial mine area) • NCDWQ NPDES Permit(s) (application pending) • North Carolina Department of Transportation (NCDOT) Driveway Permits and Encroachment Agreements (application pending) • United States Army Corps of Engineers Section 404 Permit (not required for initial mine area) The first three to four years of mining does not include any impacts to streams or wetlands and, therefore, does not require a 401 or 404 permit. Correspondence from the United States Army Corps of Engineers confirming this approach is included in Appendix K. Kleinfelder, Inc. Page 7 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. 7.0 Operations Plan 7.1 Introduction The proposed mining activities are situated in rural portions of Halifax County, North Carolina. Topography of the area is described as rolling hills with several swamps and streams that drain east and south. Elevations range from 350 feet to 200 feet above mean sea level (USGS). A location map and USGS map of the site are included as Figures 1 and 2. Based on information from the United States Department of Agriculture's (USDA) Natural Resources Conservation Service (NRCS), soils near the mining area are predominately sandy or clayey loams. Slopes of the soil layers vary between 0% and 25%. The main soil units are Emporia-Wedowee, Nankin, and Wedowee (NRCS, 2012). Based on the National Land Cover Dataset (NLCD, 2001), evergreen and deciduous forest and cultivated crops are the predominant land cover in the proposed mining areas. Silviculture operations consist of harvesting local hardwoods and pines on a 30- to 35-year rotational cycle. Agricultural activities are primarily cash crops of tobacco, peanuts, cotton, soybeans, corn, wheat, and rye rotated alternately with soybeans, corn, wheat and rye. Most crops are planted in the spring and harvested in the fall of the year. Mining activities will not be conducted within 200 feet of a principal residence unless Iluka first complies with the provisions within the mining lease concerning residences. 7.2 Mining Method Information on the proposed mining method to be used at the mine is presented in the following sections. 7.2.1 General Ground clearing operations begin six to 24 months prior to mining. Typical areas to be mined will undergo the following sequence. Prior to disturbance, the boundaries of disturbance will be surveyed and marked followed by the placement of sediment and erosion control measures. The areas will then be cleared and root raked (if necessary). If necessary, brush and tree material will be burned under appropriate burn regulations. The topsoil (averaging six inches thick) will be stockpiled to the sides of the mine perimeter to create earthen berms for containment of stormwater, noise abatement, and visual screening purposes. The boundaries of mining disturbance are surveyed as the first step in the clearing process. The disturbance line is then marked by flagging tape, pin flags, or the installation of silt fence or brush barriers. The limits delineated by sediment control structures and County-required property line, public right-of-way, and residential structure setback requirements are used to restrict mining activities. A minimum 25-foot buffer will be provided between any mining activity and any mining permit boundary or right-of-way. An undisturbed buffer will be left around streams and wetlands that are not permitted for impact. The buffer will be a minimum of 50 feet in width for stream and wetland areas, and no mining or land disturbance activities will occur Kleinfelder, Inc. Page 8 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. within the buffer area adjacent to stream and wetland areas. The sediment control structures will be installed along the inside of the buffer line. In special circumstances, Iluka may request that an allowance be made to reduce the width of the buffer. This request would be made to NCDENR Division of Energy, Mineral and Land Resources and the United States Army Corps of Engineers (if required as a permit condition) in the form of a permit amendment request. Clearing activities begin with placement and construction of erosion and sediment controls (erosion and sediment control barriers) consistent with the North Carolina Erosion and Sediment Control Planning and Design Manual (2009). The erosion and sediment control barriers will include silt fences, silt fence outlets, coir logs, sediment traps, sediment basins, brush barriers, and diversion berms/ditches, as required based on site topographic conditions. These measures will be monitored and maintained as needed until the reclamation activities are completed. Following construction of erosion and sediment control barriers, forested areas will be logged and the topsoil removed and stockpiled in perimeter berms to be constructed inside of the erosion and sediment control barrier. Logging activities may be performed prior to installation of sediment controls. Clearing and grubbing activities that involve ground disturbance will be conducted after controls are put in place. Clearing activities are expected to take approximately six months. The height of the perimeter topsoil berms will vary from a minimum of 1.5 feet to greater than 10 feet. The minimum height of 1.5 feet is consistent with the design manual. The height will depend on several factors including the size of the mining area, the amount of topsoil to be stockpiled, the amount of area set aside for topsoil storage, and whether or not the topsoil berms will also provide a screening function. In certain sensitive areas (i.e., close proximity to local residences or high-traffic public roads), Iluka may use the topsoil berms for purposes of noise abatement and as a visual screen. When used for this purpose, the berms will be built to an effective height (depending on purpose and topography). Figure 10 illustrates the screening of the berm at the concentrator site. Topsoil berms will be vegetated, and, if additional screening height is desired, tall-standing vegetation may be planted along the crest. Refer to the typical perimeter berm cross-section. Kleinfelder, Inc. Page 9 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Typical Perimeter Berm Cross-section PERMIT BOUNDARY (TYP.) PERIMETER TOPSOIL BERM 1 DISTANCE VARIES INN- ; 2H:7V OR FLATTER SLOPE (TYP.) 1, HEIGHT VARIES MINE [MIN].1.5) AREA i —i Topsoil berms will also provide a barricade to prevent inadvertent public access to the mine area and will provide a barrier to prevent physical hazard to neighboring dwellings and public roads from mine excavation. Additionally, mining activities will not be conducted within 200 feet of a principal residence unless Iluka first complies with the provisions within the mining lease concerning residences. Mining will occur in mining pits of varying size. Ore is a mixture of mineral sands (-10%), quartz sand (-60%}, and kaolinitic clay (--30%), and will be excavated by track-mounted excavator. Mining depths average 15 to 20 feet across the proposed mine footprint. Interception of the surficial water table may occur at the lower elevations within the mine pit based on NRCS data. If this is the case, the pit will be dewatered, and the water will be captured and recirculated through the mining process. Mine pit walls will vary in height depending on the depth of the ore being mined. The slope angles on the pit walls will be a function of the wall height and the ground characteristics. The pit wall at deep portions of the pit may require the use of benches at the working face. The benches help stabilize the working face and provide an intermediate level from which equipment can work. Generally, very sandy ground containing low levels of clay is less stable than ground containing higher levels of clay and would require shallower slopes to maintain slope stability. Slopes may be as shallow as 60 degrees and may be as steep as 90 degrees, depending on ground conditions and excavation depth. A horizontal distance equal to three times the pit depth of the pit will be maintained between the permit boundary and the toe of the pit slopes. Refer to typical mine pit wall cross-section. Kleinfelder, Inc. Page 10 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Typical Mine Pit Wall Cross-section PERMIT BOUNDARY (TYP.) 3x DEPTH OF PIT PERIMETER BERM[TYP.) I MINE _ FVARY) PITwALL(SLOPES WILL i Excavated mineral sand ore is placed in a mobile mining unit. The mining unit pumps the ore to the mine concentrator plant through aboveground slurry pipelines. The concentrating process is discussed further in Section 7.4.1. Due to the water use of the concentrator plant site, additional make-up water will be needed. The present design proposes supplying additional make-up water drawn from wells and municipal supply. Water will be drawn by pump and piped to recirculation ponds. The recirculation ponds will also receive water recirculated from the concentrator plant process, stormwater from the concentrator plant site, stormwater from the mine site, decanted water recovered from tailings pits, and stormwater from tailings areas. The swell factor of the clay in the ore necessitates larger tailings volumes for containment. Structures (such as berms) will be designed and constructed in accordance with all state and federal regulations. The structures will typically be constructed with material from within the mine area and will be compacted in lifts. The impoundment berms will typically be adjacent to the topsoil berms making it unnecessary for further sediment erosion control measures. For external impoundment berms, sediment erosion control measures applied to the topsoil berms will be applied to the impoundment berms. Topsoil and impoundment berms will have minimum two feet horizontal to one foot vertical slopes. 7.3 Impoundment Design Guidelines Guidelines for a typical mine tailings/reclamation impoundment are as follows: • Typical impoundment areas vary from 2 to 7 acres in size. Kleinfelder, Inc. Page 11 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. • Constructed outer embankment walls will have side slopes of 2:1 or flatter with a minimum top width of 15 feet. • Slopes will be tracked and compacted to prevent rilling or other erosion. Embankments will be monitored and surveyed during construction to ensure that approved construction standards, slope angles and dimensions are met. Embankment footprints will be inspected prior to construction. Where seeps are evident, a blanket or toe drain will be installed to transport water away from the toe area. On the surface, positive drainage will be maintained to drain runoff away from toe areas. The criteria listed below are to serve as design guidelines that will ensure that impoundments are constructed such that they are below the G.S 143-215.25A size criteria. In the future if it is found that these criteria do not provide definitive guidance, they will be modified as agreed to by the NCDENR Division of Energy, Mineral and Land Resources and Iluka Resources, Inc. (Iluka). G.S 143-215.25A(6) applies to impounding structures less than 25 feet in height or that have an impoundment capacity of less than 50 acre-feet, unless the Department determines that failure of the dam could result in loss of human life or significant damage to property below the dam. A minimum of at least two feet of freeboard will be maintained for surface impoundments unless open channel spillways are provided. In lieu of open channel spillways, the freeboard for surface impoundments may be reduced to one foot if weirs designed to handle a 50-year storm event are part of the surface impoundment design. The design for each surface impoundment required at the facility will be developed based on the site-specific conditions and material availability. Waste material tailings of clay, quartz sands, heavy minerals and gravel will serve as backfill for the mine cells. After being pumped back to the mined-out cells, the tailings are allowed to dewater. The tailings initially include approximately 40% to 45% solids, of which approximately 35% is clay. Complete consolidation of the tailings is time-dependent, but the tailings begin consolidation immediately. The tailings remain flowable for relatively short periods of time, and Iluka has found that the material is not flowable at the time the impoundments are broken during final grading. General For the purpose of this text, the following terms and definitions are used: • in-situ ground - unmined ground or undisturbed ground below an excavation. The integrity of in-situ ground shall not be disturbed by excavation, backfilling or scarification (except for keyway cuts). • pre-mined natural ground elevation - the existing contour elevations prior to land disturbance activities. • downstream - the direction of lower adjacent impounded water/silt levels Documents titled "Form to determine if a dam is governed by the Dam Safety Law of 1967" and Kleinfelder, Inc. Page 12 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. the "Dam Hazard Classification Form" will be submitted to the NC Dam Safety Program in order to receive approval that a dam safety permit is not required. See below for the definitions exhibit. Definitions Exhibit PROPOSEDIMPOUNDMENT F PRE-MINED NATURAL (TyP-) i GROUND ELEVATION 21HAV OR FLATTER SLOPE DOWNSTREAM IMPOUNDED WATER V � I I III III � v 0 0 IN-SITU GROUND I ' Impoundment Construction Sequence Whenever practical, impoundments will be constructed such that impoundments at lower elevations are constructed first. This will not always be practical, and impoundments may be constructed in any sequence. Regardless of constructions sequence, all impoundments will be constructed according to the design criteria. Overview Iluka will submit design plans to NCDENR if dams exceed the jurisdictional threshold. There will be three criteria to determine if an impoundment is considered exempt. Each impoundment will be designed and constructed in accordance with these criteria as applicable. Criterion 1 — Exterior Embankments The first criterion is to be used when any portion of an impoundment is built on unmined ground surrounding the pit and thus the embankment wall is an exterior wall. In Diagram 1, this criterion would apply to: • the north portion of Dam 1 (constructed entirely on unmined ground); • the western portion of Dams 1 and 2 (constructed partially on unmined ground above the pit crest and partially within the pit); and • the eastern portion of Dams 1 and 3 (constructed partially on unmined ground above the pit crest and partially within the pit). Impoundments that meet the first criterion must be constructed so that they are less than 25 feet Kleinfelder, Inc. Page 13 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. in height or contain less than 50 acre-feet of capacity above in-situ (unmined) ground. Diagram 1: 0I TIDE CAM 2 DAM J w RM PIT nN r n+ts: Height and volume for exterior walls will be calculated from the lowest in-situ ground point along the pit crest (Le the lowest downstream toe). The height will be calculated from the lowest downstream toe along the pit crest to the embankment crest, and the impoundment volume will be calculated from the lowest downstream toe along the pit crest to the maximum pool within the impoundment. Criterion 2— Interior Walls For interior walls, pursuant to the declaratory ruling request dated May 5, 2014 and included in Appendix L, the impoundment will be considered exempt if the volume contained within the impoundment can be contained entirely within the downstream pit. Impoundments that meet the second criteria must be constructed so that the water and tailings volume will be completely contained within the open pit adjacent to the structure, in the event of an impoundment failure. As long as the impoundment in question has an unobstructed wall that faces in the pit, adequate volume will be maintained within the pit to contain the impounded material should failure of the impoundment ever occur. The ruling is subject to review and approval by the Environmental Management Commission (EMC). Should the EMC deny the request, Iluka will adhere to the current interpretation of the dam height and volume measurements, which is taken from in-situ ground. Criterion 3— Workers Present in Downstream Pit Whenever persons are required to work in the mine cell below these impoundments an open pit must be constructed between the employees in the downstream pit and the active tailings pit. Kleinfelder, Inc. Page 14 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. The open pit shall be sized such that it can contain the volume of the upstream tailings pit. Diagram 2: ACTIVE TAILINGS PIT OPEN PIT EMPLOYEES IN PIT all (VOLUME EQUAL TO ® VOLUME OF ACTIVE I 0 TAILINGS PIT) II II II I�I' 7.4 Processing Method Ore processing methods proposed for the Aurelian Springs mine are discussed in the following sections. Conceptual process flow diagrams for the mine and plant operations proposed at the Aurelian Springs Mine and Concentrator Plant are presented in Appendix F. 7.4.1 Concentration Excavated mineral sand ore is placed in a mobile mining unit. The mining unit pumps the ore to the mine concentrator plant through aboveground slurry pipelines. At the concentrator, the initial treatment process consists of passing the slurried ore through a trommel screen. The trommel screen separates the feed into undersize (quartz sand, mineral sands, and kaolinitic clay) and oversize (rocks, gravel, roots, and clay balls) materials. The oversize material from the trommel is used as backfill in mined-out cells or around the plant for road base and other uses. The undersize fraction from the trommel is pumped through desliming cyclones to separate the clay fraction from the sand. The clay fraction (the overflow) is treated through thickeners. This process is discussed further below. The sand fraction from the desliming cyclones (the underflow) becomes the concentrator feed. Oversize material may be stored temporarily at the plant. Oversize material that contains an appreciable amount of clay will be disposed of in the mine pits. Oversize material that is mostly "clean" rock with low concentrations of clay and root material may be used for road base or other similar uses around the site. The nature of the material being mined will dictate the composition of the oversize material. Some areas will produce oversize material with significant clay content, while other areas are expected to produce relatively clean granular material. The desliming cyclones underflow is directed to a sump and then pumped to a series of spiral separators, which separate the higher specific gravity (SG) mineral sands (SG>3.5) from the lighter quartz sands (SG<2.6). The lower SG quartz sands are combined with the clay fraction and will become tailings. The spiral separators upgrade the mineral sands in the concentrator feed to approximately 90 percent heavy mineral sands, thus producing mineral sand concentrate. The mineral sand concentrate is then fed through an attritioner and a hydrosizer, Kleinfelder, Inc. Page 15 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. which removes additional fine to very fine quartz sand grains from the concentrate. The quartz sands from the spiral separators and hydrosizer are processed through tailings cyclones, which dewater the sands to approximately 75% solids. The tailing sands are combined with the thickener underflow (clays) and are pumped to mined-out cells where they are dewatered and reused with the reclamation activities. The mineral sand concentrate is then dewatered by a cyclone and stockpiled. The stockpiled mineral concentrate is loaded onto trucks with a front-end loader and hauled to the Mineral Separation Plant, located in Stony Creek, Virginia for further processing. The various mineral products from the Mineral Separation Plant will be sold commercially for manufacture of titanium dioxide pigment and/or titanium metal, use in high temperature metal casting, in the production of ceramics, and/or other industrial mineral applications. The clay from the desliming cyclones overflow is pumped to a thickener. The addition of a flocculent to the thickener increases the percent solids of the clay from approximately 5% to 30%, effectively dewatering the material. Water from the process is returned to the clarifying pond for reuse. The thickened clay is then pumped to the total tailings sump along with the dewatered sands from the tailings cyclone. The resultant mixture is then pumped at approximately 50% solids to the active reclamation cell. The tailing materials from the Aurelian Springs Mine Concentrator, as discussed, will consist primarily of quartz sand, clays, and gravel. After being pumped back to the mined-out cells, the tailings are allowed to settle and dewater pending reclamation activities. In general, the landscape restoration activities will be conducted simultaneously as the mining activities progress, with mined-out cells being reclaimed while new cells are being mined. After completing the mining activities, cell backfilling with tailings is expected to require 12 to 24 months. Once the tailings are sufficiently dewatered to allow reworking of the material, reclamation activities, including recontouring of the site (mined area) topography, top soil placement, and revegetation are expected to require 12 to 24 months. Following completion of the revegetation activities, the reclaimed areas will be monitored for a minimum of two growing seasons pending release from the mine reclamation activities by NCDENR. Once the reclaimed area is sufficiently vegetated, the erosion and sediment barriers (silt fences) will be removed. Depending on mine phasing, weather conditions, and the location of mined areas relative to ancillary mine operations, the schedule for restoring some areas of the mine cells can vary from the timeframe discussed above. Excess water from tailings is decanted, collected, and pumped back to the clarifying pond at the concentrator site and recycled. Approximately 90% of the water utilized in the mining process is recycled, with the only losses expected in the tailings entrained in the clay particles, infiltration into the ground, in the concentrate stockpile, and through evaporation. 7.5 Spoil, Overburden and Waste Disposal Handling The mining process for mineral sands involves very little if any spoil or overburden, as would be encountered in other types of mining operations. Waste disposal is primarily related to the handling of the clay and quartz sand tailings that are to be utilized in the reclamation process. Kleinfelder, Inc. Page 16 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. The handling of this material at the concentrator location has been previously described in Section 7.4. These waste products are hydraulically pumped to previously mined cells for use in the reclamation process. Tailings impoundments will be constructed according to the guidelines in Section 7.3 to create storage volume for the tailings, as well as to serve as stormwater containment. Topsoil berms may be used to divert stormwater runoff from the backside of the berms into sediment traps. If topsoil berms are not used, silt fencing or other sediment control measures will be installed until vegetative cover is established on the out slopes of the berms. Water within the berms will be decanted from the clays and sands, collected, and then pumped back to the recirculating pond at the concentrator site for reuse. The plant oversize material storage area will be located in the area marked "Oversize Stockpile Area", as shown on the site plans in Appendix I. The oversize material will be placed on a prepared earthen pad that may be covered with aggregate. Drainage from the pad will be diverted to the process water ponds and reused in the process. Stormwater from the stormwater basin will be captured and reintroduced into the system at the plant or clarifying pond as make-up water, as required. The retention basin will be exempt from being permitted as a discharge point under a National Pollutant Discharge Elimination System (NPDES) Permit because it is designed to contain the 25-year, 24-hour storm event and will have capacity available again within five days. Normal operating parameters will involve pumping the stormwater runoff into the process pond. 7.6 Topsoil Handling Initially, topsoil at the mining site will be removed and utilized to create the stormwater containment berms, which will also provide screening of the mine operation. Topsoil removed prior to mining may also be stored in stockpiles. The topsoil will remain in the containment berms or stockpiles until it is replaced during the reclamation process. Topsoil will be utilized and spread over the completed reclamation area. Once a mine cell has been filled with the clay-sand mix, dewatered and regraded, the topsoil berms will be spread over the mining cell for use in the reclamation process. The topsoil will provide a suitable growing medium as well as a "seed bank" for native vegetation. The following guidelines will be used in all areas where topsoil is being returned. • Efforts will be made to distribute the topsoil evenly over the area. • No areas (greater than just a few square yards) will be left with less than three inches of topsoil. Some very small areas may be exceptions. • Scrapers, pull pans, dozers, or other appropriate equipment will be used to distribute the topsoil. • Conditions for biosolids use (discussed below) will include a requirement that the company provide proof of landowner permission. Application of biosolids may be performed during the final stages of the reclamation process. Kleinfelder, Inc. Page 17 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Lime- stabilized biosolids may be utilized to help condition the soils prior to seeding with final pasture grasses. Incorporation of lime-stabilized biosolids raises the soil pH, adds organic content, and adds a significant amount of phosphorous, all of which are beneficial for productive pasture growth. 7.6.1 Class `B"Biosolids North Carolina law uses the term "residuals" instead of "biosolids." Residuals are defined broadly as "...any solid, semisolid, or liquid waste, other than effluent or residues from agricultural products and processing, generated from a wastewater treatment facility, water supply treatment facility or air pollution control facility permitted under the authority of the Environmental Management Commission" (15A NCAC 02T). Class B biosolids can be applied to the land by those who have a permit to produce them. North Carolina permit restrictions state that Class B biosolids must be applied at least 30 days, 14 months, 20 months, or 38 months before harvest, depending on the amount of contact between the eaten part of the crop and the soil, and how long the biosolids are left on the soil surface before they are incorporated. There are additional environmental requirements about where Class A and B residuals can be applied (15A NCAC 02T). North Carolina law regulates how high heavy metal concentrations can be for Class B biosolids. 7.7 Haul Road and Access Points The concentrate from the concentrator plant site will be hauled to the off-site mineral separation plant. Two driveways are proposed on Aurelian Springs Road for the proposed concentrator site. The spacing between driveways and from intersections is in compliance with the NCDOT Policy on Street and Driveway Access to North Carolina Highways. The driveways shall be paved and have been designed to allow a safe and efficient traffic flow into and out of the site. Access to the concentrator site and tailings area is shown on the site plans in Appendix I. Access to and between future mining areas is shown on the erosion and sediment control plans in Appendix G. There are four proposed access points onto public roads within the mine area: three crossings of Lonnie B. Green Road and one crossing of Aurelian Springs road. Access road entrances will be constructed according to the following guidelines: • The entrance will be graded such that runoff from the entrance surface either drains away from the public road or drains to small sediment traps designed to keep sediment from migrating to roadside ditches. Shallow entrance-side ditches may be used to help divert water. See Diagrams 4 and 5 below. • A culvert will be placed along the public road ditch line to ensure that the entrance does not restrict pre-existing drainage along the roadside. Culverts will be a minimum of 15 inches in diameter and will be sized as appropriate for the location. • The entrance surface will be covered with clean crushed stone (3-inch size) for a minimum distance of 100 feet. The aggregate surface will be at least six inches thick. • Prior to completion, entrances will be used for construction traffic only. Kleinfelder, Inc. Page 18 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. • In the event that the surface aggregate becomes filled or covered with sediment (clay and/or sand), the entrance will be reworked or resurfaced with clean rock as required. • When the entrance is no longer required for mining or reclamation purposes, it will be removed. The aggregate surface will be removed, the culvert will be removed, and roadside drainage will be re-established to pre-existing conditions or better. In the cases where pre-existing entrances are upgraded for mining purposes, the upgraded entrance will often be left in place and used by landowners for future access to their property. Diagram 4: Typical Road Entrance Plan View A I 1 A' I 1 Se�llnerstTrot'.0 (As Culvert 15"Diameter Min. QR MD&h / ■w Kleinfelder, Inc. Page 19 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Diagram 5: Typical Road Entrance Cross-Secdon View i.: 6..vty0a T VW. Each main access road to the mine will be equipped with a lockable gate to prevent unauthorized access to the mine. The gate will interlink with the perimeter berm (minimum height of 4 feet), which will extend for a minimum of 50 feet in both directions from the central gate location. Additionally, Iluka will construct and operate a facility suitable for washing vehicles at the Aurelian Springs Concentrator Plant site. There are no stream or wetlands crossings planned for the first three to four years of the Aurelian Springs Mine site. Future proposed impacts to streams and wetlands are being addressed in the 401 and 404 Individual Permit Applications, which are being coordinated with the North Carolina Division of Water Resources and the United States Army Corps of Engineers. 7.8 Dust Control Iluka utilizes a wet process for material separation, and thus, dust is not anticipated to be an issue in and around the concentrator plant and associated material stockpiles. Dust will be controlled along the access roads by use of stabilized construction entrances as described in Section 8.1.2. Dust control will be supplemented by spraying/wetting roads as necessary. 7.9 Groundwater Some areas of the proposed Aurelian Springs mining activities may extend below the current water table, resulting in a general lowering of the shallow water table for areas immediately Kleinfelder, Inc. Page 20 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. adjacent to the mine cells. Iluka will dewater the cells as needed to maintain a dry working environment below the local water table. Cardno conducted a preliminary dewatering study last year to look at the feasibility of dewatering the initial mine area in advance of mining. This study is complete. Extensive advanced dewatering does not appear necessary in the area studied as only a small proportion of the ore is below the water table. At a minimum, process water for the mine and plant will be obtained from a series of groundwater production wells and facility stormwater detention ponds. The wells are surface- cased, open-borehole type wells that will draw water from the lower fractured bedrock aquifer in the project area. At this time, no pump stations are planned for the production wells as part of this project. Extracted groundwater will be pumped directly to the plant and discharged to the process water ponds for use as needed. The approximate routes of proposed pipelines and access roads are shown on Figure 7. Additional make-up water will be pumped from the facility detention ponds as needed, weather conditions permitting. The municipal supply will supplement groundwater when needed. The current design is for a 50/50 groundwater/public water sourced system. Iluka has planned on having a total daily capacity of 1.0 million gallons per day available, with groundwater serving as the primary source. Public water would only be used when the well field system is unable to sustain Iluka's daily withdrawals. Groundwater is to be pumped from approximately 21 bedrock wells and public water would be drawn from a connection to Halifax County Public Utilities' (HCPU) existing 6-inch line that runs in front of the plant. The production wells were selected from among 34 test wells installed and tested between 2013 and 2014. No pump stations are required for the well system but a booster station is to be added to the HCPU 12-inch water main running along Highway 48 to the north. The booster is required to maintain line pressure along Aurelian Springs Road on occasions when Iluka uses this source. Figure 8 illustrates the well system. Gravel/dirt roads will be used to access the drilling locations for the wells. Following construction, the same roads will generally be used to access the wells for maintenance as required. The roads will change with the mine configuration as a function of the mine plan. The pipeline and power supply network will be interconnected to the point of use at the processing plant. Iluka will improve access roads to the well field as needed. Well development is generally performed following construction to remove fines generated during the drilling process from the borehole and to connect the borehole hydraulically to the fractured bedrock aquifer. Development is typically performed with a large diameter bailer, an air-lift pump, or an electric pump. Development water is usually discharged to the ground surface some distance from the well head. The wells are of open-hole construction and penetrate either granite or mafic rock formations. The wells were drilled using the direct air rotary method using water and in some cases a foaming agent for drilling fluids. The wells are developed with using direct air lifting with native formation water which is discharged on the ground next to the well. A 6-inch diameter steel surface casing excludes water from the unconfined water table aquifer. Usually there are no screens and the water enters the well bore directly from intersecting fractures. In a few instances the unstable nature of the bedrock requires the installation of a 4-inch PVC liner to maintain borehole integrity. Kleinfelder, Inc. Page 21 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Following completion of the well development activities, the yield on the wells is evaluated with drawdown tests, which typically are run for six to 48 hours to determine the well yield (gallons per minute) and specific capacity of the well (gallons per foot of drawdown). Wells that are determined to be useable will be equipped with appropriately sized submersible pumps and accessory materials (piping and electrical lines). Surface features associated with the production wells will include a surface completion for the well and a utility pole with an electric meter. The pipeline for the production wells will generally follow the shortest route from the well head to a centralized water production pipeline node leading to the Aurelian Springs concentrator plant. Periodically during operation of the production wells, redevelopment is required due to declining well yields, which can occur as a result of mineral precipitation in the well bore and the adjacent aquifer matrix. The most typical mineral precipitates are manganese oxides, iron oxides, and carbonate minerals. In the area of the Aurelian Springs mine, carbonate minerals are not expected to be an issue. The potential for manganese and iron oxide precipitation exists. If redevelopment is required due to oxide precipitation, the redevelopment activities are typically accomplished with a combination of dilute acid treatment, mechanical scrubbing, and hydraulic jetting with water, followed by additional purging to remove fines and reestablish the hydraulic connection between the borehole and aquifer formation. Following completion of the mining activities, Iluka will coordinate with the appropriate property owner to discuss the disposition of the well. Typically, the property owner will request that the well be left in place for future use. In the event that a property owner requests the removal of the well, Iluka will contract for decommissioning of the well in accordance with applicable NCDENR regulations. Well locations and water line corridors are shown on Figure. Water lines are to be laid on existing ground without disturbance and are, thus, not included within the bonded area. 7.9.1 Groundwater Monitoring and Protection Based on Iluka's experiences in Virginia, it is anticipated that activities at the Aurelian Springs site will demonstrate no negative impact on shallow wells. Analysis of data collected from observation wells at Iluka's Virginia operations indicate that following the completion of reclamation activities, the groundwater table beneath the reclaimed mine cells and the adjacent properties, recovers to levels similar to those observed prior to the mining activities. If during operation of the mine, information indicating that the mining-related dewatering activities have adversely affected the groundwater supply beneath an adjoining property(s), Iluka will devise an alternative operating plan to minimize the effects of the dewatering. In the event that one or more adjoining properties at the Aurelian Springs facility are adversely affected by the mining associated dewatering activities, Iluka is proposing to implement a Groundwater Withdrawal Mitigation Plan (GWMP), a copy of which is presented in Appendix E. As presented, the GWMP outlines procedures and steps for Iluka and potential claimants [adjacent property owners whose wells have been adversely affected (wells that have experienced significant dewatering)] to follow as necessary to obtain a mutually agreeable and Kleinfelder, Inc. Page 22 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. prompt resolution to any claims that may arise during and from the mine operation. The plan is intended to address groundwater users' claims within 2,000 feet of the mine and plant. For the purposes of the GWMP, the mine is defined by the mine permit boundary and groundwater production wells. This includes the mine pits, concentrator plant, and production well field. 7.10 Process Water Discharges Process water discharges are only anticipated during extreme weather events or during periods of sustained heavy rains. Process water discharges are being coordinated and permitted with NCDENR as part of an NPDES permit. Refer to Section 9.0. 8.0 Drainage & Erosion Control Plan The area proposed for mining activities is situated in a rural portion of Halifax County and is approximately five miles long and four miles wide. The initial area proposed for mining activity is approximately 1.6 miles long and 1.4 miles wide. The site is predominantly farmland interspersed with woodlands. The project area straddles portions of five sub-watersheds, including Marsh Swamp, Mill Swamp, Martin Swamp, Rocky Swamp, and Bear Swamp. Elevations range from a high of 350 feet above mean sea level to a low of approximately 200 feet. 8.1 Drainage & Erosion Control Design 8.1.1 Active Mining Area Approximately 100 acres will be disturbed per year. Rainfall that lands in areas where topsoil has been cleared in preparation for mining or in active mining areas will be collected either in the mining pit or pass through sediment and erosion control structures. Such controls will be in place prior to mining activities and will be in accordance with the North Carolina Erosion and Sediment Control Planning and Design Manual, dated May, 2013. Stormwater runoff not directed into the mining pits will only be collected and utilized in the mining and processing functions if practicable. Sediment control devices will be installed according to manufacturers' guidelines or state guidelines. Sediment and erosion controls will remain in place until vegetation is fully established. Once the exterior has been stabilized with vegetation, any runoff from the outside of the berms will be directed off-site via existing flowways, ditches, and culverts. Iluka may, if practicable, collect and utilize the stormwater. Groundwater that may seep into the active mine pit will be pumped as needed to other pits or into one of the process water ponds. Kleinfelder, Inc. Page 23 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. 8.1.2 Perimeter Sediment Control Sediment traps and basins primarily serve to catch surface water runoff and allow settling of solids, which prevents the transport of sediment to off-site locations. Drainage from disturbed land is directed to the traps and basins before exiting the mine site. Whenever possible, natural contours are utilized to direct surface runoff towards sediment traps and basins. Earthen berms or ditches may also be used to direct runoff that would otherwise flow away from the traps and basins or off-site. The earthen berms will remain in place for the duration of the mining activities. The berms will act as diversions to direct runoff to traps and basins. The diversions will be unlined and will include rock check dams and/or coir logs. The berms will be removed during the reclamation phase as part of the final landform grading. See section 10.0 for more information on the reclamation plan. Sediment traps and basins are strategically located so that they can be utilized in clearing, berm construction, and reclamation activities. Mine plans are designed to leave access to the sediment traps/basins so that they can be cleaned out as they fill with sediment. A thorough erosion and sediment control audit is performed every quarter. This audit covers all sediment control structures, including sediment traps and basins. Inspections are discussed further in section 9.2.1. Each trap is inspected for inlet protection, outfall protection, and percent full. Once a sediment trap/basin is 50 percent full of solids, the sediment is removed. Sediment that is removed from traps is placed into adjacent tailings ponds or returned to the mining area whenever practical. If it is not practical, then the material will be placed up gradient of the sediment trap or basin to dry. Attempts will then be made to stabilize the material to prevent it from washing into the trap during future rain events. The traps and basins will remain in place until the final stages of reclamation, when they are either removed and regraded or cleaned and left as permanent structures. Sediment traps and basins have at least one wall at a 2:1 slope or flatter to allow an escape route for any person or animal that inadvertently enters the trap. The traps and basins are designed with flat or near flat spillways that are placed along the natural path of water flow. The sediment traps account for a storage volume of 3600 cu-ft. capacity for each acre of disturbed area. The sediment basins account for a storage volume of 1800 cu-ft. capacity for each acre of disturbed area. The traps and basins were designed in accordance with NCDENR standards. The traps and basins with the largest contributing drainage areas were analyzed for capacity and discharge rates. The analysis showed that these traps and basins can control the 25-year storm event with discharge velocities lower than two feet per second. These analyses are included in Appendix H. In most areas, topsoil perimeter berms will be utilized to contain and direct runoff to the sediment traps. Sediment barriers, such as silt fence will be installed, remaining around the outside base of the berms to control sediment until vegetation is fully established. In areas where topsoil perimeter berms are absent, the external slopes of pond embankments will be vegetated to minimize erosion and sediment transport from the slopes. Additionally, temporary construction entrances shall be utilized to provide a buffer area where vehicles tires are cleaned to avoid transporting it onto public roads, to control surface runoff, Kleinfelder, Inc. Page 24 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. and to help control dust. 8.1.3 Concentrator Plant Stormwater Best Management Practices (BMPs) for the concentrator plant are shown in Appendix I. Stormwater calculations are included in Appendix J. As presented, the concentrator plant site includes the plant, three process water ponds, a permanent sediment basin at the process water outfall, a wet detention pond for stormwater management, support facilities, and a stockpile area. Additional drainage controls around the concentrator plant include diversionary berms and swales. The detention pond and swales collect runoff from the vicinity of the non-process areas such as the office buildings and parking areas. The purpose of the detention pond is to trap sediment and runoff to ensure sediment does not leave the area. The pond will be designed to contain the 25-year, 24-hour storm in its entirety and will have that capacity available again within five days. Stormwater collected within the detention pond may be pumped into the clarifying pond, where it will be used as make-up water in the plant. 8.1.4 Tailings Area Perimeter sediment controls will be maintained throughout the mining process from mine development to final reclamation. Active tailings areas will be checked regularly throughout each shift to ensure proper functioning. This includes tailings levels and impoundment walls. Inactive ponds will be checked as often as necessary to ensure they are functioning properly. Tailings pond levels will be checked regularly to ensure a minimum freeboard of one foot is maintained. Pond levels will be checked more frequently during periods of heavy rain or when other conditions might dictate. If the freeboard reaches one foot, no further tails will be placed, and the level in the pond will be reduced via pumping or through a decant structure to another pond on site. Weir boxes may be used as decant structures. Typical dimensions for the weir boxes currently used are approximately seven feet wide, six feet tall and three feet in depth. The face of the weir box is closed by sliding several two-inch by six-inch boards into channels from the top to the bottom and opened by the reverse, removing boards. The discharge of the box is typically through three 12-inch high-density polyethylene (HDPE) pipelines or one 18-inch HDPE pipeline. This exceeds the required overflow capacity for all of the anticipated site dams. In the case that additional capacity would be needed, supplementary lines could be added to the box. Buried pipes or culverts through the berms may also be used as decant structures. Unless open channel spillways are provided, at least two feet of freeboard will have to be maintained within all impoundments. Weirs with adequate discharge capacity (25-year design storm) may be used instead of open channel spillways. With properly designed and installed weirs, freeboard may be reduced to one foot. The decant capacity of open channel spillways or weirs will be based on the pond's size and its location within the local pond network. Weirs are placed in locations such that the water is discharged into an adjacent tailings Kleinfelder, Inc. Page 25 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. impoundment. The weirs remain in place throughout the tailings and capping process. During the final stages of dewatering before reclamation, several boards may be removed from the weirs to maximize dewatering of the pond. Once the tailings within the pond have been sufficiently dewatered and stabilized, the weir may be removed allowing water to flow through an open cut from one impoundment to the adjacent, lower, impoundment. 8.1.5 Slurry Piping Slurry piping is used for transportation between mining cells, plant site, and tailing areas. Typically, HDPE pipe is used and ranges in size from 12- to 16-inch diameter. Wall thickness varies between SDR 7 and SDR 17. It is anticipated that 16" SDR 9 HDPE pipe (specification includes a minimum wall thickness of 1.778 inches) will be used for the feed pipe and 12" SDR 11 HDPE pipe (specification includes a minimum wall thickness of 1.159 inches) will be used for the tailings pipe. The pipe is typically fused into sections ranging in length from 120 to 600 feet. Individual sections are joined together with bolted flanges. In order to reduce the chances of pipe leaks and potential discharges, the following procedures will be followed: • All slurry pipes may be rotated to minimize wear due to internal friction. Slurry pipes will be marked to indicate when they were last rotated and to what position. • Where slurry pipes cross under public roads or sensitive areas, they may be encased in a larger diameter pipe that will outflow to one or more sediment control structures. Alternatively, thick-walled pipe may be used to reduce the chance of failure. • Team leaders will be required to document pump and pipeline inspections as performed each shift. Sediment traps below booster stations and pipelines will also be inspected weekly, with the inspections documented. • Pressure gauges will be installed at the suction and discharge points on the booster pumps. Pressure gauges on the suction side of the pumps will relay information to the concentrator control room and the data will be used to control pump speed and minimize pump cavitation. Pressure readings at the discharge side of pumps will also be relayed to the control rooms at the concentrators. The real-time data will indicate to operators if there is a problem with the pump. • Electricians will perform regular preventative maintenance on the booster pumps to ensure that the controls are working properly. • Leak detection/blow out detection will be installed 8.2 Construction, Maintenance and Abandonment The following sections present information on the construction, maintenance and decommissioning of structures and appurtenances associated with the mine operation. 8.2.1 Construction Piping will be appropriately sized based on anticipated volumes pumped. HDPE pipe will be used throughout the site to transport process water, storm water, make-up water, tailings and Kleinfelder, Inc. Page 26 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. ore. 8.2.2 Maintenance Berms, drainage swales, culverts, and pumping equipment will be visually inspected to ascertain if any maintenance is required. The aboveground HDPE pipes used to transport the tailings make- up water, ore, and stormwater runoff will be visually inspected at least once per shift for damage or malfunction. If maintenance is required, pumping would be discontinued and repairs initiated immediately. 8.2.3 Decommissioning The topsoil containment berms surrounding the active mine area will be used in the reclamation process as described in Sections 7.6 and 10.2.2. The containment berms will be graded as described in Section 10.2.2 and reclaimed to state standards at the time of reclamation. 9.0 NPDES Permit Stormwater and process water discharges will be permitted through NCDENR under the NPDES NCG020000 permit. 9.1 Concentrator Site Discharges The concentrator site will include a wet detention pond for collection of stormwater runoff and three process water ponds. The wet detention pond, as described above, is being designed such that it will be exempt from analytical monitoring. Analytical monitoring is not required for any basin or pond designed to contain the 25-year, 24-hour storm without discharging and that can regain capacity to hold such an event within five days' time through means other than discharge to surface waters. A basin or pond that meets this provision is considered a non- discharging stormwater control. The process water ponds will have one process wastewater discharge point as shown on the plans in Appendix I. 9.2 Mine Area Discharges Sediment traps and basins within the mine area are considered stormwater discharges under the permit. Iluka's inspection and representative outfall status plan is presented in the following sections. 9.2.1 Inspection and Representative Outfall Status Plan Iluka will perform quarterly qualitative monitoring at all outfalls. The monitoring will include a visual inspection, on-foot, of the following at each outfall: • Capacity • Downstream conditions Kleinfelder, Inc. Page 27 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. • Inlet and outlet conditions • Water quality (color, odor, clarity, etc.) • Embankment conditions The qualitative monitoring will result in an action item list for each outfall and associated erosion and sediment control measures to remediate any issues noted during the inspection. Personnel performing the qualitative monitoring will be certified in erosion and sediment control. 9.2.2 Representative Outfall Status Iluka will select 10%, to a maximum of 20, of the total number of outfalls for Representative Outfall Status (ROS). The ROS will apply to both the analytical and qualitative monitoring requirements of the permit. Once the pit or impoundments are developed into a drainage area, ROS sampling will no longer be required at outfalls within that drainage area. The representative outfalls will be identified on the erosion control plans in Appendix G. 9.2.3 Diffuse Flow Diffuse flow is required at all outfalls per NCDENR's buffer requirements. However, outfalls with non-erosive velocities, velocities less than two feet per second, can discharge into the buffer in lieu of diffuse flow measures. Non-erosive velocities are anticipated at all outfalls per the erosion control plans and calculations shown in Appendices G and H. If erosion is observed downstream of an outfall, the erosion and sediment control plans will be supplemented during construction. 9.2.4 Pumping O&M Plan As described above, the mine pit may be dewatered if mining operations encounter the water table. However, based on Iluka's previous experience and the relatively temporary duration of dewatering, it is not anticipated that impacts to surface or ground water will occur. Approximately six to 12 months is the typical time frame from groundwater exposure to pumping to refill the pits. 10.0 Reclamation Plan 10.1 Post-Mining Land Use The majority of the land proposed for mining consists of agricultural lands utilized for a variety of row crops including tobacco, peanuts, soybeans, corn, wheat, rye and cotton. As shown in Figure 9, the reclamation plan post- mining land use will be to return these lands to a condition of pasture/grassland for soil stabilization and erosion control. 10.2 Backfilling and Regrading 10.2.1 Waste Materials Kleinfelder, Inc. Page 28 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. As previously discussed, waste materials of clay and quartz sands will serve as backfill for the mine cells, mimicking pre-mining topographic features. Topsoil will then be graded across the mined areas as a top dressing for the final reclamation contouring. Due to material swell associated with the high clay content of the ore, the final grades of some reclamation areas might be approximately 20% to 30% higher than the pre-mining contours. The dewatering process may utilize several methods to liberate water from the tailings ponds. Ditches may be dug around the interior perimeter of the ponds to allow water to migrate out of the tailings. When this method is employed, the spoils from the ditching activities will be placed on the interior of the ponds so that the sediment does not migrate off site. Controlled breaches of the ponds may also be used during the dewatering process. These breaches will only be installed in ponds containing tailings that have sufficiently dewatered and stabilized, limiting the amount of solids that will be transported through the breach. In most cases, the breaches will allow water to migrate from one pond to the interior of an adjacent pond. In some cases, exterior pond walls may be breached. When exterior walls are breached, proper sediment control structures will be in place below the area to ensure sediment is properly contained. Sediment traps may be installed interior or exterior of the pond wall to allow solids to settle. Decant pipes may be installed during the final phases of the capping and reclamation process to aid in pond dewatering efforts. Sediment control structures will be installed below the decant pipes if the runoff is not fully contained by other structures. Reclamation will be performed in a manner that mimics the pre-construction land surface to the extent practicable so as to ensure that sufficient slope is present for positive surface flow drainage as required to prevent the development of stagnant flow areas that may develop from minor subsidence following completion of the reclamation activities. In general, the land surface within the reclamation area will be graded to facilitate positive drainage (greater than 1% slope). Areas with less than 1% grade will generally be limited to restored upland areas that drain at the perimeter. The need to accommodate for material swell may dictate that some areas are left at higher elevations (as compared to pre-mining topography) and may have steeper slopes. In order to provide for the planting and establishment of vegetative cover to prevent erosion following the completion of base grading activities, the maximum slope in the reclamation area will be maintained at three feet horizontal to one foot vertical (18%). Refer to the typical reclamation cross-section. Typical Reclamation Cross-section PERMITSOUNNARY (TYR-) 3H:IV OR FLATTER SLOPE POST-RECLAMATION TOPOGRAPHY(TYP-) I I I PRE-MINING I TOPOGRAPHY P-YP.] Kleinfelder, Inc. Page 29 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. Following completion of the mining activities, the structures that are constructed to support the mining operations (concentrator plant, office buildings, storage buildings, etc.) will be dismantled and removed from the site at the conclusion of the project. Likewise, support equipment (pumps, pipelines, transformers, etc.) will be removed from the site after mining and reclamation have been completed. At the end of the mine life, the only remaining stockpiles will be oversize piles (roots, rocks, and clay as discussed above). Any remaining oversize will be disposed of in the final mining voids and utilized in the reclamation process. All concentrate stockpiles will be hauled to the MSP in Stony Creek to be processed. Access roads will be seeded and reclaimed unless requested to be left in place by the land owner. All trash, garbage, oil, and other wastes will be disposed of off-site in a legal manner. These wastes will be disposed of at Halifax County and NCDENR approved facilities. 10.2.2 Regrading Topsoil When regrading is complete, the sub-soil is tested for various qualities, such as pH. Agricultural lime may be added to the sub-soil, adjusting its pH to a level conducive for the end land use. The proposed end land use is pasture/grassland. The sub-soil samples will also be used to determine other necessary amendments required to create a favorable environment for the end land use. The amendments may include phosphate, potassium, nitrogen and other nutrients as required. After the sub-soil amendments have been applied, the topsoil is regraded over the area. The topsoil is sampled and the area is fertilized and seeded, pending the results of the soil samples and the desired end land use. Whenever possible the seeding will be done during the optimal seeding windows in the spring and fall. In some cases, a temporary cover crop may be seeded prior to final cover during periods that are subject to inclement weather. Iluka is committed to reclaiming as concurrently as feasible. The intent is to minimize the total acres of disturbed land while maintaining efficient operations. At any given time, Iluka will have a number of acres disturbed; these acres will include: • Areas cleared in advance of the mining operations — This acreage will vary with season, weather, and topographic conditions. • Production areas — This would include all areas that are actively being mined, all areas where tailings are being disposed, and areas that are in between these defined phases. • Areas under reclamation —These areas are being worked, capped, and graded. • Lands that have been seeded and in the bond release process. In addition to the four areas mentioned above, there will be areas and structures that will not be reclaimed in accordance with this plan. Their expected useable life is often longer than the State required two-year window. Examples would be the area covered by the concentrator; long- term active roadways to access areas; clear water ponds that control water throughout the mining, tailing, and reclamation processes; and long-term sediment control structures maintained until the area has been seeded and substantial growth is established. Reclamation time frames will be updated on the mine map, as applicable. Kleinfelder, Inc. Page 30 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. The total number of acres of disturbed land will vary due to several conditions. The greatest unknown variable will be the depth of the ore body. A deeper ore body results in a smaller surface area than shallower mining areas. The typical range of yearly disturbance could range from 50 to 150 acres per year. In the event that weather or other conditions prevents the above plan from being achieved in any given year, a considerable effort will be made in the following year to reduce the number of disturbed acres and resume the described schedule. Research has shown that compaction of the topsoil and subsoil during the reclamation process can negatively impact post-reclamation crop productivity. As a result, the company is continually testing methods to reduce compaction. Deep ripping (18 to 36 inches) with a tracked dozer has been successful when used in conjunction with agricultural tillage and disking. 10.3 Re-vegetation The site will be scarified and planted with a grass-legume mixture. Several seed mixtures may be used for temporary seeding sediment control and final perennial pasture establishments. These seed mixtures will be applied to the site as soon as practical, typically no longer than one month after initial disturbance for temporary seeding and in the spring or fall for permanent seeding. Iluka, in cooperation with the Virginia Polytechnic Institute and State University (VPISU), has conducted replicated field plot experiments for reclamation of similar mine sites for row crops including corn, wheat, soybeans, tobacco, and cotton. The results of these field plot experiments may be used in conjunction with conventional farming activities to establish row crops once the land has been released by the state and returned to the landowners. Temporary Grasses Several temporary grasses will be used to provide soil stabilization for areas such as tailing impoundments, sediment structures, and graded fields. The seed mixes in these areas will contain a combination of any of the following: • Cool season —Winter wheat, cereal rye, annual rye grass, and tall fescue. • Warm season — Foxtail millet, annual rye grass, and Korean lespedeza. General temporary grass establishment will utilize approximately 200 pounds of seed per acre. Perennial Seed Mixes The perennial seed mixes will be used as permanent vegetative cover for reclamation of mining areas. These grasses will be planted in early spring or fall to provide an optimum growing environment. The mixtures may include a combination of any of the following grasses and legumes: tall fescue, orchard grass, red clover, ladino clover, and alfalfa. Cereal rye will be the preferred nurse crop for cool season establishment, and foxtail millet will be used as nurse crop for warmer season plantings. Kleinfelder, Inc. Page 31 of 32 June 11, 2014 Aurelian Springs Mine Iluka Resources, Inc. General perennial pasture establishment will utilize approximately 60 Ib/ac orchard grass, 60 Ib/ac tall fescue, 15 Ib/ac red clover, and 15 Ib/ac ladino clover. Lime and Fertilizer Lime application rates may vary from two to five tons per acre, and fertilizer application rates may vary from 200 to 350 Ib/ac based on soil test results. Fertilization will generally apply 75 to 100 Ibs per acre N, 100 to 200 Ibs per acre P2O5, and 100 to 150 Ibs per acre K20. 10.4 Wetland Mitigation and Restoration The initial mine area does not require any impacts to wetlands or streams and as such, wetland mitigation and restoration is not required. As Iluka develops additional mine area, wetland mitigation and restoration will be addressed as required by the 401 and 404 permits. 11.0 References http://websoilsurvey.nres.usda.gov (accessed April 12, 2013) Kleinfelder, Inc. Page 32 of 32 June 11, 2014 FIGURES APPENDIX A TABLE OF ADJACENT PARCEL OWNERS APPENDIX B HALIFAX COUNTY CONDITIONAL USE PERMIT APPENDIX C AFFIDAVIT OF NOTIFICATION AND CERTIFIED MAIL RECEIPTS (FORTHCOMING) APPENDIX D LAND ENTRY AGREEMENTS (FORTHCOMING) APPENDIX E GROUNDWATER WITHDRAWAL MITIGATION PLAN APPENDIX F PROCESS FLOW DIAGRAMS APPENDIX G EROSION AND SEDIMENT CONTROL PLANS APPENDIX H EROSION AND SEDIMENT CONTROL CALCULATIONS APPENDIX I CONCENTRATOR SITE PLANS APPENDIX J CONCENTRATOR SITE STORMWATER CALCULATIONS APPENDIX K CORRESPONDENCE WITH USACE APPENDIX L COPY OF DECLARATORY RULING REQUEST