FINAL AMENDED PLAN OF OPERATIONS FOR BUCKHORN MOUNTAIN PROJECT by tae47486

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									   FINAL AMENDED PLAN OF OPERATIONS FOR
   BUCKHORN MOUNTAIN PROJECT FACILITIES
      AND ACTIVITIES LOCATED ON LANDS
   ADMINISTERED BY THE US FOREST SERVICE




                                Submitted to:

                            USDA Forest Service
                               1 West Winesap
                         Tonasket, Washington 98855


                                Submitted by:

                         Crown Resources Corporation
                             624 Central Avenue
                          Oroville, Washington 98844

Revised September 2007                                 043-2265
        FINAL AMENDED PLAN OF OPERATIONS
                       FOR
BUCKHORN MOUNTAIN PROJECT FACILITIES AND ACTIVITIES
                        ON
    LANDS ADMINISTERED BY THE US FOREST SERVICE




                     Prepared by:

          CROWN RESOURCES CORPORATION




                Revised September 2007
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                                                                                            TABLE OF CONTENTS


1.0                PROJECT BACKGROUND AND PERMITTING..........................................................1
         1.1                Introduction .........................................................................................................................1
         1.2                Project History ....................................................................................................................2
         1.3                Applicant Information.........................................................................................................4
         1.4                Permits, Approvals, and Regulatory Requirements ............................................................4

2.0                PROJECT OVERVIEW.....................................................................................................7
         2.1           Project Components ............................................................................................................7
         2.2           Project Location and Land Ownership................................................................................7
         2.3           Work Force and Operating Schedule ..................................................................................8
         2.4           Project Schedule..................................................................................................................9
         2.5           Project Development...........................................................................................................9
         2.6           Fire Fighting Equipment/Emergency Response................................................................10
         2.7           Power Requirements .........................................................................................................11
         2.8           Water Requirements and Water Rights.............................................................................11
         2.9           Project Transportation Plan...............................................................................................12
                   2.9.1 Ore and Backfill Haulage ...........................................................................................12
                   2.9.2 Fuel and Supplies........................................................................................................13
                   2.9.3 Transportation Routes.................................................................................................13
                   2.9.4 Haul Road Construction .............................................................................................14
                   2.9.5 Haul Road Alignment .................................................................................................15
                   2.9.6 Infiltration Gallery and Pipeline .................................................................................16
                   2.9.7 Roosevelt Adit and Wetland Flow Augmentation......................................................19
                   2.9.8 Supply and Employee Access.....................................................................................20
                   2.9.9 Road Use and Maintenance ........................................................................................21
                   2.9.10 Proposed Fence...........................................................................................................22
                   2.9.11 Monitoring and Piezometer Sites and Access Roads..................................................23
                   2.9.12 Water Tower Access...................................................................................................23

3.0                ENVIRONMENTAL PROTECTION MEASURES......................................................24
         3.1     Introduction .......................................................................................................................24
         3.2     Environmental Management Programs.............................................................................24
             3.2.1 Spill Prevention, Hazardous Materials, Fire Prevention, and First Aid Programs .....24
             3.2.2 Land Use Programs ....................................................................................................26
             3.2.3 Range ..........................................................................................................................28
             3.2.4 Permitting and Financial Assurances..........................................................................30
             3.2.5 Recreation Programs...................................................................................................31
             3.2.6 Transportation Program ..............................................................................................31
             3.2.7 Employee Training .....................................................................................................34
             3.2.8 Solid Waste (Refuse) Management ............................................................................35
         3.3     Resource Mitigation ..........................................................................................................35
             3.3.1 Air Quality..................................................................................................................35
             3.3.2 Heritage Resources .....................................................................................................36
             3.3.3 Water Quality .............................................................................................................37
             3.3.4 Wetlands and Streams ................................................................................................43
             3.3.5 Scenic Resources ........................................................................................................44



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             3.3.6 Wildlife and Fish Mitigation and Enhancement .........................................................44
             3.3.7 Noise...........................................................................................................................48
             3.3.8 Soils ............................................................................................................................48
         3.4     Monitoring ........................................................................................................................48
             3.4.1 Monitoring Measures..................................................................................................48
             3.4.2 Water Resources Monitoring......................................................................................49
             3.4.3 Range Allotment Monitoring Measures .....................................................................52
             3.4.4 Wildlife Road Closures ..............................................................................................52
             3.4.5 Fish Populations .........................................................................................................52
             3.4.6 Timber Monitoring .....................................................................................................53
             3.4.7 Noxious Weed Monitoring .........................................................................................53
             3.4.8 Transportation Monitoring .........................................................................................53
             3.4.9 Reclamation Monitoring.............................................................................................54
             3.4.10 Cut and Fill Slope Monitoring....................................................................................54
             3.4.11 Monitoring of Silt Fences and Straw Bales ................................................................55

4.0                TEMPORARY SHUTDOWN .........................................................................................56
         4.1                General Activities in the Event of a Temporary Shutdown ..............................................57
         4.2                Maintenance Programs......................................................................................................57
         4.3                Monitoring During a Temporary Shutdown......................................................................57
         4.4                Reclamation Activities during a Temporary Shutdown ....................................................58
         4.5                Notification .......................................................................................................................58
         4.6                Permanent Cessation .........................................................................................................58

5.0                RECLAMATION .............................................................................................................59
         5.1     Introduction .......................................................................................................................59
         5.2     Reclamation Goals and Objectives ...................................................................................59
         5.3     Methodology .....................................................................................................................59
         5.4     Current Land Use ..............................................................................................................60
         5.5     General Reclamation Procedures ......................................................................................60
             5.5.1 Vegetation Clearing and Topsoil Salvage and Stockpile............................................60
             5.5.2 Decommissioning of Facilities ...................................................................................61
             5.5.3 Road Grading and Stabilization..................................................................................61
             5.5.4 Topsoil Placement ......................................................................................................62
             5.5.5 Fertilization.................................................................................................................62
             5.5.6 Revegetation ...............................................................................................................62
             5.5.7 Noxious Weed Control ...............................................................................................63
             5.5.8 Revegetation Success Monitoring ..............................................................................63
         5.6     Reclamation Performance Securities ................................................................................64
             5.6.1 Requirements ..............................................................................................................64
             5.6.2 Closure Cost Estimate ................................................................................................64
         5.7     Reclamation Schedule.......................................................................................................66

6.0                REFERENCES CITED ....................................................................................................68




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                                                                                              LIST OF TABLES

Table 1.1                                  Permit Summary
Table 2.1                                  Summary of Disturbance Acreages
Table 2.2                                  Equipment that Could be Used for Fire Fighting
Table 2.3                                  Backslopes and Fillslopes
Table 3.1                                  Road Cross Drain Frequency


                                                                                             LIST OF FIGURES

Figure 1                                   Project Location Map
Figure 2                                   Haul Road Alignment (1 of 3)
Figure 3                                   Haul Road Alignment (2 of 3)
Figure 4                                   Haul Road Alignment (3 of 3)
Figure 5                                   Typical Haul Road Cross Sections
Figure 6                                   Pipeline and Infiltration Gallery
Figure 7                                   Plan and Profile of Infiltration Gallery Line
Figure 8                                   Typical Infiltration Pipeline Cross Sections
Figure 9                                   Infiltration System and Dosing Siphon Plan
Figure 10                                  Infiltration System Details
Figure 11                                  Infiltration Trench Detail
Figure 12                                  Augmentation Pipeline
Figure 13                                  Overview of Proposed Mitigation Activities
Figure 14                                  Bedrock Monitoring Well/Piezometer Construction Detail
Figure 15                                  Unconsolidated Material Monitoring Well/Piezometer Construction Detail


                                                                                            LIST OF APPENDICES

Appendix A                                 Fire Protection Plan
Appendix B                                 Spill Prevention Control and Countermeasures Plan
Appendix C                                 Haul Road Design Report (Telesto 2007)
Appendix D                                 Road Use and Maintenance Plan
Appendix E                                 Hazardous Materials Transportation Plan
Appendix F                                 Noxious Weed Plan
Appendix G                                 Storm Water Pollution Prevention Plan
Appendix H                                 Monitoring Plan – NPDES Permit
Appendix I                                 Surety Estimate
Appendix J                                 Technical Memorandum No. 5.7 Conveyance Pipe and Infiltration Gallery


                                                                                      LIST OF ATTACHMENTS

Attachment A Buckhorn Mountain Claims Map




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                                                         LIST OF ABBREVIATIONS AND ACRONYMS


amsl                                            above mean sea level
API                                             American Petroleum Institute
ASTM                                            American Society of Testing Materials
CFR                                             Code of Federal Regulations
CWA                                             Clean Water Act
DOE                                             Department of Ecology (Washington State)
DNR                                             Department of Natural Resources (Washington State)
EA                                              Environmental Assessment
EIS                                             Environmental Impact Statement
FR                                              Federal Register
INFISH                                          Inland Native Fish Strategy
MSDS                                            Material Safety Data Sheet
NEPA                                            National Environmental Policy Act
NPDES                                           National Pollution Discharge Elimination System
P.E.                                            Professional Engineer
SPCC                                            Spill Prevention, Control, and Countermeasure
SEIS                                            Supplemental Environmental Impact Statement
USEPA                                           United States Environmental Protection Agency
USFS                                            United States Forest Service
WDFW                                            Washington State Department of Fish and Wildlife




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                    CROSS REFERENCES – MITIGATION, MANAGEMENT, AND MONITORING

     No.,                                   Mitigation, Management, and
   (EIS ID)                                     Monitoring Measures                                               EIS Citation   FAPOO Citation
                                  Air Quality
      (AQ-1)                      Best Available Control Technology                                             EIS, p. 64       Sec. 3.3.1, p. 34
      (AQ-2)                      Fugitive Dust Control                                                         EIS, p. 64       Sec. 3.3.1, p. 34
      (AQ-3)                      Slash Burning                                                                 EIS, p. 65       Sec. 3.3.1, p. 35
      (AQ-4)                      Car Pooling/Van Pooling/Busing                                                EIS, p. 65       Sec. 3.3.1, p. 35
      (HR-1)                      Heritage Resources                                                            EIS, p. 66       Sec. 3.3.2, p. 35
                                  Spill Prevention, Hazardous Materials, Fire                                   EIS, p. 75       Sec. 3.2.1, p 23
                                  Prevention, and First Aid
       (SP-1)                     Fuel Storage and Other Hazardous Substances                                   EIS, p. 75       Sec 2.9.2. p. 13
                                                                                                                                 Sec. 3.2.1, p 23
                                                                                                                                 Appendix B
       (SP-2)                     Transportation Spill Response Plan                                            EIS, p. 76       Sec. 3.2.1, p. 25
                                                                                                                                 Appendix E
       (SP-3)                     Fire Protection and Suppression Plan                                          EIS, p. 77       Sec 2.6, p 10
                                                                                                                                 Sec. 3.2.1, p. 25
                                                                                                                                 Appendix A
       (SP-4)                     External Spill Response and Materials Handling                                EIS, p. 77       Sec. 3.2.1, p. 25
                                  Training
                                  Land Use
      (LU-1)                      Land and Vegetation Disturbance                                               EIS, p. 67       Sec. 3.2.2, p. 25
      (LU-2)                      Timber Settlement Contract                                                    EIS, p. 67       Sec. 3.2.2, p. 25
      (LU-3)                      Noxious Weed Control                                                          EIS, p. 68       Sec. 3.2.2, p. 26
      (LU-4)                      Equipment Washing                                                             EIS, p. 68       Sec. 3.2.2, p. 27
      (LU-5)                      Noxious Weed-Free Mulch and Seed                                              EIS, p. 69       Sec. 3.2.2, p 27
      (LU-6)                      Reclamation of Past Disturbances                                              EIS, p. 69       Sec. 3.2.2, p. 27
                                  Range
     (RA-1)                       Livestock Water Development                                                   EIS, p. 71       Sec. 3.2.3, p. 27
     (RA-2)                       Bat Canyon Livestock Fencing                                                  EIS, p. 72       Sec. 3.2.3, p. 28
     (RA-3)                       North Side Marias Creek Livestock Fencing                                     EIS, p. 72       Sec. 3.2.3, p. 28
     (RA-4)                       Water Gaps                                                                    EIS, p. 72       Sec. 3.2.3, p. 28
     (RA-5)                       Corral                                                                        EIS, p. 73       Sec. 3.2.3, p. 29
     (RA-6)                       Cattle Drives                                                                 EIS, p. 73       Sec. 3.2.3, p. 29
     (NO-1)                       Noise                                                                         EIS, p. 70       Sec. 3.3.7, p. 47
                                  Permitting and Financial Assurances
     (PFA-1)                      Permit Acquisition                                                            EIS, p. 70       Sec. 3.2.4, p. 29
     (PFA-2)                      Performance Securities                                                        EIS, p. 70       Sec. 3.2.4, p. 29
     (PFA-3)                      Collection Agreement                                                          EIS, p. 71       Sec. 3.2.4, p. 30
                                  Recreation
       (RE-1)                     Traffic Restrictions                                                          EIS, p. 74       Sec. 3.2.5, p. 30
       (RE-2)                     Hunting Restrictions                                                          EIS, p. 74       Sec. 3.2.5, p. 30
       (SO-1)                     Soils                                                                         EIS, p. 74       Sec. 2.5, p. 9
                                                                                                                                 Sec. 2.8, p. 11
                                                                                                                                 Sec. 3.3.3, p. 36
                                                                                                                                 Sec. 3.3.8, p. 47
                                                                                                                                 Sec. 5.5.1, p. 59
                                                                                                                                 Sec. 5.5.4, p. 61
                                  Water Quality
      (WQ-1)                      Erosion and Sedimentation                                                     EIS, p. 86       Sec. 3.3.3, p. 39


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     No.,                                    Mitigation, Management, and
   (EIS ID)                                      Monitoring Measures                                              EIS Citation   FAPOO Citation
    (WQ-2)                        Water Quality                                                                 EIS, p. 89       Sec. 3.3.3, p. 37
    (WQ-3)                        Water Infiltration Augmentation                                               EIS, p. 89       Sec. 3.3.3, p. 37
                                  Transportation
       (TR-1)                     Winter Road Maintenance and Haul                                              EIS, p. 79       Sec. 3.2.6, p. 30
       (TR-2)                     Remote Office                                                                 EIS, p. 79       Sec. 3.2.6, p. 31
       (TR-3                      Supply Deliveries                                                             EIS, p. 80       Sec. 3.2.6, p. 31
       (TR-4)                     Road Use Permit                                                               EIS, p. 80       Sec. 3.2.6, p. 32
       (TR-5)                     Road Closure                                                                  EIS, p. 81       Sec. 3.2.6, p. 32
       (TR-6)                     Road Junction Improvement                                                     EIS, p. 81       Sec. 3.2.6, p. 32
                                  Wetlands and Streams -
      (WS-1)                      Culverts in Live Streams                                                      EIS, p. 90       Sec. 3.3.4, p. 42
      (WS-2)                      Sensitive Plants                                                              EIS, p. 90       Sec. 3.3.4, p. 43
                                  Scenic Resources
       (SR-1)                     General Scenic Mitigation Measures                                            EIS, p. 77       Sec. 3.3.5, p. 43
       (SR-2)                     Exterior Fixed Lights                                                         EIS, p. 78       Sec. 3.3.5, p. 43
                                  Wildlife and Fish Mitigation and Enhancement
      (WF-1)                      Wildlife Road Closures                                                        EIS, p. 82       Sec. 3.3.6, p. 43
      (WF-2)                      Fencing for Deer Movement                                                     EIS, p. 83       Sec. 3.3.6, p. 44
      (WF-3)                      Dogs                                                                          EIS, p. 83       Sec. 3.3.6, p. 44
      (WF-4)                      Snags                                                                         EIS, p. 83       Sec. 3.3.6, p. 44
      (WF-5)                      Wildlife Run-outs                                                             EIS, p. 83       Sec. 3.3.6, p. 45
      (WF-6)                      Woody Material Replacement                                                    EIS, p. 84       Sec. 3.3.6, p. 45
      (WF-7)                      Fish Kills                                                                    EIS, p. 84       Sec. 3.3.6, p. 45
      (WF-8)                      Project Speed Limits                                                          EIS, p. 84       Sec. 3.3.6, p. 45
      (WF-9)                      Fish Passage Improvement                                                      EIS, p. 85       Sec. 3.3.6, p. 45
     (WF-11)                      Amphibian Kills                                                               EIS, p. 85       Sec. 3.3.6, p. 46
     (WF-12)                      Notification Procedures in the Event of Wildlife                              EIS, p. 86       Sec. 3.3.6, p. 46
                                  Road Kill
     (WF-13)                      Disposal of Killed Ungulates                                                  EIS, p. 86       Sec. 3.3.6, p. 46
      (ET-1)                      Employee Training                                                             EIS, p. 65       Sec. 3.2.7, p. 33
      (SW-1)                      Solid and Sanitary Waste (Garbage)                                            EIS, p. 78       Sec. 3.2.8, p. 34
                                  Management
                                  Monitoring Measures                                                           EIS, p. 90       Sec. 3.4.1, p. 47
                                  Water Resources Monitoring                                                    EIS, p. 91       Sec. 3.4.2, p. 48
                                                                                                                                 Appendix H
                                  Range Allotment Monitoring Measures                                           EIS, p. 93       Sec. 3.4.3, p. 51
                                  Wildlife Road Closures                                                        EIS, p. 93       Sec. 3.4.4, p. 51
                                  Fish Populations                                                              EIS, p. 93       Sec. 3.4.5, p. 51
                                  Timber Monitoring                                                             EIS, p. 94       Sec. 3.4.6, p. 52
                                  Noxious Weed Monitoring                                                       EIS, p. 94       Sec. 3.4.7, p. 52
                                  Transportation Monitoring                                                     EIS, p. 94       Sec. 3.4.8, p. 52
                                  Reclamation Monitoring                                                        EIS, p. 95       Sec. 3.4.9, p. 53
                                                                                                                                 Sec. 5.5.8, p. 62
                                  Cut and Fill Slope Monitoring                                                 EIS, p. 95       Sec. 3.4.10, p. 53
                                  Monitoring of Silt Fences and Straw Bales                                     EIS, p. 96       Sec. 3.4.11, p. 54
                                  Performance Securities                                                        EIS, p. 96       Sec. 5.6, p. 63




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1.0                PROJECT BACKGROUND AND PERMITTING

1.1                Introduction

This Final Amended Plan of Operations (FAPOO) describes construction programs, operational
programs, and mitigation programs for the haul road and access roads, the pipeline, and the treated
water infiltration area, fencing, wells and utilities on the Okanogan and Wenatchee National Forests,
Tonasket Ranger District, to facilitate the underground mining operations of the Buckhorn Mountain
Project. The Buckhorn Mountain Project is owned and operated by Crown Resources Corporation, a
wholly owned subsidiary of Kinross Gold Corporation, (Crown/Kinross). Whereas the Buckhorn
Mountain ore body is located on patented mining claims held by Crown/Kinross, it is surrounded by
lands administered by the United States Forest Service (Forest Service) and the Bureau of Land
Management. Figure 1 illustrates the location of the project and the general land ownership in the
area.


The Buckhorn Mountain Project is located in the Myers Creek mining district in Okanogan County,
Washington, and has been developed on a combination of private, federal, and state lands. The
federal and state lands are administered by the Okanogan and Wenatchee National Forests (Tonasket
Ranger District) and the Washington Department of Natural Resources (DNR), respectively.


The FAPOO addresses the amendments and programs described in the “Amended Plan of
Operations” submitted in February 2004 (2004 Amended Plan of Operations) and the “Amended Plan
of Operations for the Proposed Buckhorn Mountain Project on Lands Administered by the US Forest
Service” submitted March 15, 2005, (2005 Amended Plan of Operations) which were necessary due
to changes in the land status in the project area as a result of the issuance of patents for the Buckhorn
Mountain ore deposit. The mining facilities that were described in the 2004 Amended Plan are now
located on private land (i.e., patented claims) owned by Crown Resources Corporation, a
wholly-owned subsidiary of Kinross Gold Corporation (Crown/Kinross). As described below, the
project components that remain on lands administered by the Forest Service include a portion of the
haul road, access roads, fencing, an infiltration area, pipeline, monitoring wells and sites, and utilities.
This FAPOO describes the history of the project, provides an overview of the operation, and
discusses in detail the portions of the project that are located on lands administered by the USFS.




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1.2                Project History

Crown discovered the Buckhorn Mountain deposit in 1988. The deposit is located on Buckhorn
Mountain, approximately 3.5 air miles east of Chesaw, Washington, in the Myers Creek mining
district in Okanogan County. An economic feasibility study, completed by Battle Mountain Gold
Corporation (BMG) in 1992, indicated that the deposit was commercially viable as an open-pit mine
with a nearby milling facility. BMG proceeded with environmental permitting of the Crown Jewel
Mine on Buckhorn Mountain that proposed an open-pit gold and silver mine and associated on-site
processing facilities. Relative to this proposal, BMG submitted a Plan of Operations in 1992 and
subsequent revisions in 1993, 1997, and 1998 (BMG 1992). In 2000, BMG withdrew from its joint
venture with Crown, and the project assets reverted to 100 percent Crown ownership.


Subsequent to BMG’s withdrawal from the project, Crown submitted a Plan of Operations in July
2003 (Crown Corporation 2003) for the Buckhorn Mountain Project to the Forest Service and the
Washington Department of Ecology (DOE). Crown’s 2003 Plan proposed an underground mine with
processing facilities located near the Buckhorn Mountain site.


On November 20, 2003, Kinross, and its wholly owned subsidiary Echo Bay Minerals Corporation
(EBMC), announced it had entered into an agreement to acquire Crown and the Buckhorn Mountain
gold deposit. The acquisition was completed August 31, 2006. Completion of the merger places
Crown as a wholly owned subsidiary of Kinross.


The merger between the two companies presented the opportunity to process the Buckhorn Mountain
ore at EBMC’s existing Kettle River milling facility located near Republic, Washington in Ferry
County. Consequently, Crown amended the 2003 Plan with the 2004 Amended Plan of Operations
(Crown Resources Corporation 2004) to reflect the hauling of ore in highway trucks from the
Buckhorn Mountain Project to the Kettle River Mill rather than building a new processing facility
near the mine.


In December 2004, the U.S. Department of the Interior, Bureau of Land Management (BLM) issued
patents to Crown for nine mining claims on Buckhorn Mountain. The patents give Crown title to this
land, eliminating the Forest Service’s jurisdiction over this land. With the issuance of the patents, the
majority of the project development is on Crown’s private land (i.e., on the patented mining claims;
see Attachment A).




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As described in the 2004 Amended Plan of Operations (Crown Resources Corporation 2004),
Crown/Kinross’s Buckhorn Mountain deposit will be mined using underground mining techniques.
The ore from the Buckhorn Mountain Project will be transported by road to Kinross’ Kettle River
Operations—processing facility (mill)—located on private land owned by the company near Republic
in Ferry County, Washington. The mine will be similar in nature to six other mines that have
operated in the vicinity and have shipped ore to the Kettle River Mill since its commissioning in
1990.


In the 2004 Amended Plan of Operations, Crown Resources Corporation (2004) describes the
proposed project in its entirety including the underground mine, the associated mine surface facilities,
the haul route between the Buckhorn Mountain Mine and the Kettle River Mill, and a quarry site that
will be located along the haul route. As previously mentioned, the FAPOO addresses those aspects of
the Buckhorn Mountain Project that are located on Forest Service administered land. Those activities
include construction of new roads and upgrades to existing roads that are utilized to haul ore to the
Kettle River Mill, a fence around the perimeter of the mine site, monitoring wells/sites, along with an
infiltration area and associated road and pipeline.


The 2004 Amended Plan of Operations and this FAPOO are based in part on the extensive studies
performed during the environmental review of the BMG proposal. However, compared with the
previous BMG Crown Jewel Mine, important changes were made to address issues identified in the
previous environmental analyses, including revisions and modifications to operating facilities and
reclamation, mitigation, and monitoring plans. Specifically, Crown/Kinross eliminated the open-pit
mine and associated rock storage areas, mill, tailings impoundment, and substantially reduced the
water consumption required for the project thereby reducing the environmental impacts noted in the
Crown Jewel Mine Final Environmental Impact Statement (FEIS) (USFS 1997). Crown/Kinross
made the decision to eliminate the processing and tailings disposal facilities near the mine, as
originally proposed in the 2003 Plan, based on public comments received during the first scoping
period for the Supplemental EIS (SEIS). With the issuance of the patents for the mining claims the
scope of the project occurring on lands administered by the USFS was reduced to approximately
1.5 miles of new road construction and 5.2 miles of road upgrades, fencing the perimeter of the mine
site, monitoring wells/sites, and a water infiltration area and associated road and pipeline.


As described above, substantial differences in the project exist between the FAPOO and the 2004
Amended Plan of Operations and all of the alternatives studied and assessed in the previous Crown




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Jewel permitting process. However, much of the technical information from the earlier studies is
relevant for this project, particularly the information describing the existing environment. Extensive
baseline work was compiled and reviewed in the selected studies performed by BMG, its contractors,
and the agencies and contractors who assessed the project as part of the earlier EIS and permitting
process. Additionally, new baseline data was collected by Crown/Kinross, the Forest Service, and
DOE to augment previously collected data. Based on this supplemental information Crown/Kinross
has developed environmental protection measures and monitoring programs as described herein.
Finally, the extensive public record from the previous Crown Jewel Mine and the scoping comments
received on the 2003 Plan were reviewed and considered in the design of the 2004 Amended Plan of
Operations and in the FAPOO.


1.3                Applicant Information

Crown is incorporated in the State of Colorado and is focused on developing the Buckhorn Mountain
Project. Contact information for Crown/Kinross is shown below:


                   Buckhorn Mountain Project
                   Crown/Kinross Corporation
                   624 Central Ave.
                   P.O. Box 1988
                   Oroville, WA 98844
                   (509) 476-2301

1.4                Permits, Approvals, and Regulatory Requirements

In addition to the terms and conditions of the FAPOO, Crown/Kinross will comply with other federal,
state, and local laws and regulations. Table 1.1 lists the permits, approvals, and authorizations that
describe the construction, operation, and closure requirements of the Buckhorn Mountain Project.
This list is subject to any changes in the operation and requirements of the regulatory agencies.




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                                                                                        Table 1.1 - Permit Summary
                Agency                                                                                                    Description
Federal Government
USFS                                                                                               Plan of Operations Approval
                                                                                                   Special Use Permits (Rights-of-Way, Utilities, etc.)
                                                                                                   Timber Sale Agreement
Dept. of Homeland Security (Department of                                                          Explosives Permit
Alcohol, Tobacco, and Firearms)
Mine Safety and Health Administration                                                              Mine Identification Number (No permit Necessary)
                                                                                                   Miner Training Plan Approval
                                                                                                   Notice of Start of Operations
Federal Communications Commission                                                                  Radio License
US Army Corps of Engineers                                                                         Nation Wide Permit
US Environmental Protection Agency                                                                 National Pollution Discharge Elimination System
                                                                                                   (NPDES)/Construction Activities Storm Water General
                                                                                                   Permit and Operational Permit
State of Washington
Washington Department of Ecology                                                                   National Pollution Discharge Elimination System
                                                                                                   (NPDES)/Construction Activities Storm Water General
                                                                                                   Permit and Operational Permit
                                                                                                   Waste Water Discharge permit
                                                                                                   EPCRA Sara Title III compliance
                                                                                                   Notice of Construction Permit (Air Quality)
                                                                                                   Sand and Gravel Permit
                                                                                                   Water Rights/Change of Use
                                                                                                   Notification of Dangerous Waste Activity
Washington Department of Fish and Wildlife                                                         Hydraulic Project Approvals
Washington Department of Health                                                                    Public Water Supply Approval
Washington Department of Natural Resources                                                         Road Maintenance and Abandonment
                                                                                                   Mined Land Reclamation Permit
                                                                                                   Forest Practices Act
                                                                                                   Burning Permit
                                                                                                   Right of Way and Timber Sale Agreement
                                                                                                   Utilities Easement
                                                                                                   Surface Mine Permits
Washington Department of Labor and Industries                                                      Explosives License
                                                                                                   Safety Regulation Compliance (No Permit)
Wash., Dept of Community Development,                                                              SHPO/106 Review
Office of Archaeology and Historic Preservation
Local Government
Okanogan Planning Department                                                                       Conditional Use Permit/Zoning Requirements
                                                                                                   Building Permits
                                                                                                   Joint Aquatic Resource Permits
                                                                                                   Maximum Environmental Noise Levels (Compliance Item)
                                                                                                   Socioeconomic Impact Analysis Approval
                                                                                                   Growth Management Critical Areas Regulations
Okanogan County Health District                                                                    Solid Waste Handling
                                                                                                   Septic System Approval
Okanogan Public Works Department                                                                   Road Construction and/or Realignment
Ferry County Public Utility District                                                               Power Service Contract
Ferry County Planning Dept.                                                                        Quarry Approval




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The FAPOO focuses on facilities located on lands administered by the Forest Service consisting of
approximately 1.5 miles of new road construction and 5.2 miles of road upgrades, fencing the
perimeter of the mine site, monitoring wells/sites, and a water infiltration area and associated road
and pipeline.




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2.0            PROJECT OVERVIEW

2.1              Project Components

The part of the Buckhorn Mountain Project described by this FAPOO consists of road
improvements/construction, pipeline and infiltration area and associated roads, a fence, and
monitoring wells/sites. Key project components are listed below and discussed in the following
sections.


                   •        Fencing;

                   •        Infiltration area and associated road and pipeline;

                   •        Water augmentation pipeline and outfalls;

                   •        Monitoring wells/sites;

                   •        Existing Forest Service Roads to the Water Tower;

                   •        Existing Forest Service Roads to the monitoring and mitigation sites; and

                   •        Haul road (new and reconstructed).

The road alignment is illustrated on Figure 1. Most of the project roads will be roads that existed
prior to project initiation; however, some new alignments will be constructed and some existing
alignments will be upgraded. The fence and infiltration area are shown on Figure 1, and the water
monitoring locations on Figures 2-3, 2-4, 2-5, and 2-6 in Appendix H.


2.2              Project Location and Land Ownership

Table 2.1 shows the estimated area of disturbance for the facilities described in this FAPOO.




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                                                                Table 2.1 - Summary of Disturbance Acreages
                                                                                                                Approximate Area of Disturbance
                                                    Project Component
                                                                                                                      on FS Lands, Acres
Ore Haulage Route                                                                                                            <36
Monitoring Wells, Surface Water Monitoring Points and
                                                                                                                              <1
Piezometers
Infiltration Gallery and Pipeline                                                                                             <6
Fence                                                                                                                         <4
Mitigation Acres:
     • Well and Watering Troughs
     • Fencing Along Road
     • Water Gaps
     • Corrals                                                                                                               <10
     • Cattle Guards and gates
     • Culverts removed or replaced
     • Guzzlers
     • Nicholson Creek Culvert
                                Total                                                                                         57


2.3              Work Force and Operating Schedule

The estimated number of construction employees for the fence, road, monitor wells, and infiltration
area is approximately 40 (at the peak of construction activities). Approximately 120 employees will
utilize the road to travel to work at the mine site, and an additional 30 employees will be employed
directly or under contract for ore hauling activities. Employment at the mine will be somewhat lower
during the several years of the pre-production and will be lower during the post-production periods.
Supplemental contractors will be hired on an as-needed basis to perform road maintenance.


Crown/Kinross’ corporate philosophy is to employ personnel from the local communities surrounding
the mine site when feasible. Every effort will be made to maximize local hires. Local hiring
practices include the use of local contractors and contract personnel whenever practical.
Crown/Kinross will maintain an office, away from the mine site, at the Kettle River Operations – Key
Mill Facility, near Republic, Washington, for most personnel hiring to facilitate hiring and reduce
traffic to the mine site.                                        New worker training is available, particularly to support local hiring
practices.


Empty and full ore trucks are only allowed to operate on USFS roads between the hours of 6 a.m. and
6 p.m. 7 days per week. Although some shift staggering may occur, mine employees would be
assigned to either an 8-hour shift or a 12-hour shift, depending on their responsibilities. Most




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supplies would be delivered between 6:00 a.m. and 6:00 p.m. except infrequent, unplanned,
emergency supply deliveries outside these hours for immediately needed supplies.                                With the
capability to store at least several days needs for all supplies, the need for deliveries outside of the
6:00 a.m. to 6:00 p.m. time period should be relatively infrequent.


2.4              Project Schedule

Construction of the fence, road, utilities, monitor wells, and infiltration area will commence after
issuance of the permits and is expected to take approximately 4 to 6 months of work to complete.
Transport of ore to the mill and gravel to the mine as backfill will commence based upon the mining
schedule; it is anticipated that ore haulage will begin in approximately 8 months and backfill
aggregate transport will begin in approximately month 10 of operation. Transport of ore and gravel
will not start until the proposed new haul road construction is accepted as completed and satisfactory
by the USFS.


2.5              Project Development

The construction, widening, and realignment of access and haul routes will require some tree cutting.
The design for the access and haulage routes addresses safety concerns, while at the same time
minimizes impacts to vegetation, wildlife, aquatic resources, and water quality (Telesto 2007). All
road upgrades and new construction conform to county and/or USFS/Washington State Department
of Natural Resources (DNR) standards and regulations, including the proper construction of ditches
and water control structures. Only minor stretches of blasting of road cuts will be required.


Topsoil and subsoil will be removed from within the road disturbance footprints, monitor well access
roads, monitor well pads and sumps, along with the road and pipeline to the infiltration area prior to
construction of facilities. The topsoil will be placed on completed cut and fill slopes as the road is
constructed. The topsoil will be in close proximity to the disturbed area where it can easily be
accessed during reclamation activities. This soil will be used to reclaim the fill slopes of the road
following construction.




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2.6              Fire Fighting Equipment/Emergency Response

Kinross has prepared a Fire Prevention and Suppression Plan (Appendix A) for all components of the
Buckhorn Project. The following presents a summary of the components of the plan that relate to the
project components on public land. See Appendix A for a more detailed discussion.


All power-driven equipment operated by Crown/Kinross or their contractors using the road will be
equipped with an axe, shovel, bucket, and fire extinguisher during fire season, as required by the
USFS. In addition, all vehicles and other internal combustion engines will have adequate spark
arresters. There will be telephone service at the mine and mill sites for communication in case of fire
or other emergencies. Appropriate fire fighting equipment will be on all power-driven equipment
during the construction, timber harvesting and operation periods.


Ore haul trucks and Crown/Kinross light vehicles will be equipped with radio equipment for
emergency communication in the case of accident or fire.


Project equipment will be utilized for fire fighting purposes based on the threat to human safety, the
threat to public and private property, the severity of the fire, and the availability of equipment.
Equipment available at the Mine Site and the Borrow Area that could possibly be used for fire
fighting is listed in Table 2.2.


                                                                            Table 2.2
                                                           Equipment that Could be Used for Fire Fighting
                                                                               Mine Site
                                                                                      Tractor
                                                                                      Dozer, D8
                                                                                      Loader 988
                                                                                      Water Truck
                                                                               Borrow Area
                                                                                      Dozer, D8
                                                                                      Loader, 988
                                                                                      Water Truck

Crown/Kinross will strictly control open fires within the Project area. Crown/Kinross will not allow
open fires on the public lands portion of the Project without permission in writing from the USFS.
Unless restricted by State Law or Federal Regulations, smoking will be permitted only in such
portions of the Project area that are free of flammable material. Smokers will sit down to smoke in




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such a position that any burning material will fall within a cleared area, and will extinguish and press
out in mineral soil all burning material before leaving the cleared area.


Crown/Kinross will promptly comply with any emergency directives by the USFS or the State and
will obey any fire precautions imposed on operations during the summer fire season. Also, existing
water sources at the mine site will be available to assist fire-fighting efforts in the area.


An emergency medical transfer vehicle will be present on site at the mine during production. Trained
emergency medical technicians employed by Crown/Kinross will be available to respond to
emergencies that may occur on the road.


2.7              Power Requirements

Power will be purchased from the Ferry County Public Utilities District (PUD). Electrical lines
would be buried in the Marias Creek Road across National Forest System land and right-of-way. A
solar power source would be installed at the well being developed adjacent to FR 3550 to provide
power for the water developments above the road.


In order to minimize surface disturbance and visual impacts, the new line to the mine will be buried
along the road easements with the exception of two more direct routes in section 36 where the line
may take a more direct route for short sections. A substation will be constructed at the site.


The electrical power requirement at the mine site is projected to be approximately 2.4 megawatts
(MW) of installed capacity averaging 1.2-MW usage.


2.8              Water Requirements and Water Rights

Water rights controlled by Crown/Kinross are adequate to provide the water needed for dust control
on the road. However, a change in the point of use and season of use will be required to utilize these
rights for road dust control and mitigation. Crown/Kinross will work with DOE and local authorities
to ensure that the consumptive use of water in no way impairs the water rights of others.


Water, required during the expected four to six months of road construction, will come from the on-
site well and Toroda Creek (Crown/Kinross has a water right on this stream). Dust suppression and




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general construction requirements will require approximately 150 gallons per minute (gpm) during
this period.


After initial startup, there will be excess water entering the underground workings. This will be
collected in sumps, pre-treated by settling solids and removing organics, and subsequently pumped to
a water treatment plant for treatment of elevated nitrates and other constituents, as required. The
treated water will be discharged or piped to an engineered infiltration system that will return the water
to the groundwater system in accordance with the NPDES permit. The infiltration system will consist
of a series of subsurface pipe laterals with drain rock infiltration beds. The infiltration bed will be
designed and constructed to infiltrate the treated water at the peak design flow rate.


Topsoil removed from the infiltration area during construction will be replaced soon after
construction is complete and seed placed on the disturbed area. At final reclamation, the road along
the pipeline (from the water treatment plant to the junction with the augmentation to the Roosevelt
Adit) will be reclaimed to mimic the pre-disturbance topography, the topsoil replaced, and the
disturbed area re-vegetated.


2.9              Project Transportation Plan

2.9.1                    Ore and Backfill Haulage

The project site is accessible by paved and unpaved county and USFS roads. Crown/Kinross is
proposing to upgrade portions of the Marias Creek Road (USFS 3550) in order to comply with road
and traffic safety requirements. Additionally, Crown/Kinross is proposing to construct an unpaved
spur road from the existing Marias Creek Road (3550) to the mine site (see Figure 1).


Ore stockpiled at the mine will be loaded into highway-legal haul trucks by a front-end loader for
transportation to Kinross’ Kettle River Mill and tailings disposal facility (TDF) near Republic in
Ferry County. Haul trucks returning from the mill will transport backfill gravel to the mine from the
Backfill Borrow Site located on private land east of the Job Corps. The ore hauling procedures and
equipment will be similar to the ore hauling operations used for the past 15 years by the Kettle River
Operations.


The ore transportation will be contracted to a company specializing in highway haulage. The trucks
would probably be side-dump trucks rated at a 30- to 32-ton capacity. Alternatively, 20- to 25-ton




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capacity trucks with a 10- to 15-ton tandem trailer may be used. The actual payload is expected to be
between 30 and 32 tons. The number of round trips will, therefore, average approximately 50 per
day. However, during some periods such as immediately before and after spring breakup, the average
trips per day will increase in order to compensate for those times during which hauling is not
permitted or feasible. Haulage rates also may vary based on operational and weather considerations.
All trucks and trucking procedures will conform to requirements of the Washington State Department
of Transportation, Okanogan and Ferry County Road Departments, Washington DNR, and the USFS
and will be permitted by the agencies, as required. Empty and full ore trucks are only allowed to
operate on USFS roads between the hours of 6:00 a.m. and 6:00 p.m. daily.


2.9.2                    Fuel and Supplies

Crown/Kinross will use gasoline and diesel fuel for the operation of mining and mining support
equipment. Petroleum products will be delivered to the site by outside vendors using their own
vehicles and equipment. The capacity of the fuel trucks will depend on the supplier but could be as
large as 6,000 gallons. Approximately 15 fuel deliveries are expected per month. Additionally, other
petroleum products will be delivered to the site in 5-gallon and 55-gallon barrels via delivery trucks.
The maximum volume of petroleum products to be stored at the mine site is estimated to be
51,250 gallons and Crown/Kinross has prepared a Spill Prevention Control and Countermeasure Plan
(SPCC) meeting the requirements (40 CFR 112). The SPCC is attached as Appendix B.


2.9.3                    Transportation Routes

Crown/Kinross will use and extend the Marias Creek Road for access to the mine site.


New road construction and upgrading will be required in order to improve the Marias Creek Road to
safe operational standards.                                               Approximately 8,000 feet of new road construction is on lands
administered by the USFS in the upper parts of the Marias Creek drainage approaching the mine site.
Most of the route from the mine site to the Toroda Creek Road is located on USFS land, and road
construction will comply with Forest Service specifications. These specifications indicate an in-
sloped double-lane graded road of a 24-foot travel way width with shoulders and ditching to control
storm water runoff. Sufficient storage will be provided for snow removal adjacent to roadways.
When within 100 feet of fish bearing streams, snow will not be plowed off the downhill side of the
road. Any snow that can not be plowed onto the uphill side of roads in these areas will be removed
off National Forest System lands.



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The Buckhorn Mountain Project requires a haul road that can accommodate highway approved haul
trucks with a design weight of 32 tons. The ore transportation will likely be contracted to a company
specializing in highway haulage. The trucks would probably be side-dump trucks rated at a 30- to
32-ton capacity. Alternatively, 20- to 25-ton capacity trucks with a 10- to 15-ton tandem trailer may
be used. The actual payload is expected to be between 30 and 32 tons. The number of round trips
would, therefore, average approximately 50 per day. A minimum 24-foot running width will be
required at a maximum grade of 8.5%.


The haul road will be constructed from the Intersection of Marias Creek Road (USFS Road 3550) and
Toroda Creek Road to the Mine Site, a distance of 8.7 miles. The haul road will utilize and improve
approximately 5.3 miles of existing roads (USFS Road 3550 and USFS Road 3550-125) as well as an
additional 3.4 miles of new road construction from the end of USFS Road 3550-125 to the mine site.


The SWPPP covers the development and construction of the haul road over the 8.7-mile alignment.


2.9.4                    Haul Road Construction

The haul road design conforms to the standards required by the USFS and Washington Department of
Natural Resources (DNR).                                                  Additional operational elements of the road design required by
Crown/Kinross are also incorporated. The Final Design (Telesto 2007) is included as Appendix C.
Key design criteria and elements are listed below:


                   •        24-foot minimum running width;

                   •        3-foot shoulder on fill side of road with 3H:1V slope;

                   •        Ditch on cut side of road, 1 foot deep with 3H:1V slope adjacent to running
                            surface, 1.5-foot bottom width, backslope per Table 2.3;

                                                                          Table 2.3 - Backslopes and Fillslopes

                                                      Backslopes                                                   Fillslopes
                       2:1                        Flat ground cuts under 3 feet                          1-1/2:1    Common Material
                       1:1                        Common slopes under 55%                                1-1/2:1    Rock
                       ¾:1                        Common slopes over 55%
                       ½:1                        Hardpan, Soft Rock
                       ¼:1                        Solid Rock




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                   •        Surface cant of 3% towards ditch on cut side of road;

                   •        First approximately 825 feet of USFS Road 3550 will be paved;

                   •        18-inch CMP ditch relief culverts placed on approximate 166-foot to 370-foot
                            centers depending on road grade (see Table 3.1);

                   •        Culverts skewed 20 degrees from perpendicular to the road and on the original
                            ground slope;

                   •        All aquatic life passable culverts for the Marias Creek Crossing per Washington
                            Department of Fish and Wildlife (WDFW) design standards;

                   •        The road has a design speed of 30 mph for all curves except for five curves that
                            require radii less than 200 feet. These curves have design speeds of 20 mph.
                            Speed limit signs will be posted;

                   •        The Mine Safety and Health Administration (MSHA) requires berms or other
                            barriers on the edge of the road within the mine property boundary. Safety berms
                            will be constructed on sections of the road located within the mine property.
                            Safety berms will be at least as tall as the mid axle height of the largest vehicle
                            expected to utilize the road;

                   •        The majority of earthwork on USFS Road 3550 will be north of Marias Creek
                            with the additional road width being obtained by widening into the uphill side of
                            the existing road, thereby creating no new disturbance closer to Marias Creek;
                            and

                   •        Within the Heritage Site located at the lower end of the Marias Creek haul road, a
                            professional archeologist must be present during any ground disturbing activities
                            in that area.

The haul road will be constructed with a 6-inch thick, unpaved aggregate surface, consisting of 97%
to 100% passing the 1-inch sieve. The road including the aggregate surface will be constructed from
balance point to balance point and no section of road will be left open for more than approximately
10 days. The balance point to balance point will be a rolling distance, allowing construction to
advance as erosion control measures are installed.


2.9.5                    Haul Road Alignment

The haul road alignment is presented on Figures 2, 3 and 4. The haul road will utilize 4.3 miles of the
existing USFS Road 3550 (Marias Creek Road) from Toroda Creek Road to the intersection of USFS
Road 3550-125. The entire 1.0-mile length of USFS Road 3550-125 will be utilized. The existing




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roads will be widened to accommodate a 24-foot width and reconstructed in isolated areas to produce
a more uniform grade. Typical cross sections through the haul road are presented in Figure 5.


Approximately 3.4 miles of new road will be constructed from the end of USFS Road 3550-125 to the
mine site. The haul road will cross over USFS Road 130 and USFS Road 120 and will require
realignment of the USFS roads to create near 90 degree intersections.


A utility corridor will be placed adjacent to the haul road alignment and within the haul road
disturbed footprint, with the exception of two areas where the buried underground utilities will leave
the haul road alignment to cross between switchbacks of the road as shown on Figure 4.


2.9.6                    Infiltration Gallery and Pipeline

System Overview

The following discussion provides a summary of the infiltration gallery and pipeline design from
Morrison-Maierle (2006). A more detailed discussion is included in Appendix J. The pipeline system
consists of a 4-inch gravity conveyance pipe from the mine water treatment building, an access road
along the pipe route (from the water treatment plant to the junction with the line to the Roosevelt
Adit), a gravity dosing siphon in a concrete tank, and four infiltration trenches with a buried
perforated pipe installed in glacial outwash soils. Figure 6 provides a site layout for this system.


The conveyance pipe route has been selected to generally follow a previously reclaimed road prism
on the site, based on information provided by the USFS. The location of the treated water pipeline
(outfall) will be field approved by the Forest Service prior to construction. Minor modifications have
been made to maintain gravity flow without significant cuts through localized topographic highs in
the area uphill from the dosing tank. The total pipe length from the mine water treatment building to
the dosing tank is 4,980 feet, dropping from a ground elevation of 5,006 feet to a ground elevation of
4,346 feet (Figure 7).


The average slope of the line is 13% but some sections are much steeper. For instance, a 60-foot
segment immediately downstream from the patent boundary and another 100-foot segment uphill
from the dosing tank exhibit slopes as high as 50%. However, those slopes could be reduced to 25 to
35% in those two areas by regrading a 200-foot to 300-foot long segment of the route. Those
considerations will be investigated further during construction. Ground profiles will be completed




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during final design to determine actual slopes, but a minimum slope of 1% will be maintained. The
pipe will be 4-inch fusion-welded high density polyethylene (HDPE) pipe. Manholes will be installed
at approximately 500-foot intervals for pipe maintenance. Approximately three additional manholes
will be installed along the series of long bends in the area immediately uphill from the dosing tank.
Manholes will be either polyethylene or precast concrete, depending on the cost of the two
alternatives and the availability of H-20 traffic rated polyethylene structures.


A typical section for the pipe and access road is included in Figure 8. The road will be 12 feet wide
with a 1-foot ditch and a 3% cross-slope down to the roadside ditch. Culverts will be placed at all
topographic lows and on 25- to 103-meter (82- to 338-foot) spacing depending on centerline slope
(see Table 3.1). Culverts are anticipated to be 18-inch diameter pipes with materials to be selected
during final design. It is anticipated that a 40-foot wide corridor will provide adequate space to allow
installation of the road and pipe given the expected cut and fill requirements. The access road will
only be present along the section of pipe from the water treatment plant to the junction with the
augmentation pipeline to the Roosevelt adit. The road and pipeline arrangement shown in Figure 8 is
only applicable to the portion of the pipeline where the access road is required (from the water
treatment plant to the junction with the line to the Roosevelt Adit).


In order to minimize surface disturbance, the section of pipe within the 100-foot wide, Gold Bowl
Creek Riparian Habitat Conservation Area (RHCA) will be installed using a Horizontal Directional
Drilling (HDD) technique. The length of pipe installed using HDD will be field determined, and will
include the 100-foot RHCA plus the distance required to angle the hole to an appropriate depth on
either side of the RHCA. The drill will be a Vermeer 50X100 directional drilling machine which will
be used to drill the hole and install the pipe. In addition to the drill, a 10-wheel semi-trailer will be
required at the entry point that will contain a water tank, mixing tank and pumps. No equipment will
be required at the exit point. A temporary access road will be constructed along the pipeline
alignment from the junction with the line to the Roosevelt Adit to the entry point. Drilling mud will
consist of Maxbore Wyoming Drilling Clay (bentonite). Most of the mud will remain in the ground.
Excess cuttings and bentonite will be collected and properly disposed at a site off of Forest Service
land.




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Pipeline Specs

The conveyance pipe and infiltration gallery system will be designed to handle a peak design flow of
40 gal/min during wet times of the year. The total pipe length from the mine water treatment building
to the dosing tank is 4,980 feet. The pipe will be 4-inch fusion-welded high density polyethylene
(HDPE) pipe. Consideration will be made to the potential pressure that the pipe could experience in
the event the line became plugged.


The total elevation drop of 660 feet corresponds to a maximum pressure of 285 psi. Because the peak
pressure of 285 psi would only occur during an extreme event, a pipe will be selected for each
segment that has a design pressure of at least half the anticipated pressure at that location.


Dosing Systems Specs

The peak design flow into the dosing siphon system is 40 gal/min. Details for the dosing tank and
system components are provided in Figures 9 and 10.


For this system, both dosing siphons will be Orenco Model 316F siphons, which have an estimated
flow rate of 74 gal/min and a drawdown of 16 inches per dose. The actual volume per dose will
depend on the dosing tank geometry selected. An AMSSI Siphon Sitter I dose counter will be
installed in the tank for each dosing siphon (2 counters total). An additional float switch (Orenco
Model MF2A) with two floats will also be installed. One float will activate a battery-operated high
level alarm (Orenco AMSENTII-W), which will be installed above ground on a post near the dosing
tank to signal an alarm condition. The second float will act as a “dry contact” for a high level alarm
signal for the Supervisory Control and Data Acquisition (SCADA) system. A twisted pair of fiber-
optic cable to connect the high level alarm on the dose tank with the SCADA may be buried in a
small-diameter conduit next to the conveyance pipeline if telemetry is not feasible.


The feeder pipe from the dosing tank to the laterals will be 4-inch HDPE pipe, while the laterals will
be perforated 4-inch Schedule 40 PVC drainfield piping.                                                         The total volume for the system is
270 gallons. The selected dosing siphon has a drawdown of 16 inches at each cycle. Each infiltration
gallery zone provides 600 ft2 of infiltrative surface, resulting in a total of 1,200 ft2 for the overall
system. Assuming a 1,000-gallon tank is provided, a 16-inch drawdown will result in a dose volume
of 330 gallons, or 25% larger than the total pipe volume.




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Infiltration Trench Design

The gallery would consist of two 200-foot long infiltration gallery laterals. As shown in Figures 9
and 10, each 200-foot long lateral is broken into two separate 100-foot long laterals for better flow
distribution. Each pair of adjacent laterals will be gravity dosed as a separate zone. Thus, the system
will include two zones. The laterals will be installed within a 3-foot wide drainfield trench. The
trenches will be installed at a depth of 4 to 5 feet, in order to be below the anticipated frost depth of
45 inches. Each trench will be installed level to insure uniform distribution throughout the trench.
The trenches will be installed in accordance with Figure 11, which was modified from DOH (1999).
The only changes made in this figure were the maximum trench depth (from 3 feet to 4 or 5 feet) and
the depth of cover soil (from 6 to 24 inches to 3to 4 feet). The 4- to 5-foot trench depth will consist
of a minimum of 24 inches of washed gravel at the bottom, covered with a geotextile meeting the
requirements of DOH (1999). Amoco Nonwoven Geotextile Type 4535 meets those requirements.
The geotextile will be covered with 2-3 feet of topsoil and seeded with a native grass seed. The
distribution pipe will be a 4-inch diameter ASTM D-3034 PVC pipe with perforations per
ASTM D-2729. One inspection port will be installed in each trench in accordance with Figure 11.


Washed gravel meeting the requirements of DOH (1994) will be installed in the trenches. The
washed gravel shall consist of aggregate material ranging from ¾-inch to 1 ½-inch in diameter, with
no more than 0.5% of material passing the No. 200 sieve. It is also recommended that a small run-on
diversion berm be constructed immediately upgradient of the infiltration trenches. Stormwater and
snowmelt water will be diverted around each side of the infiltration gallery to reduce the overall load
of infiltration water on the site.


Each infiltration gallery zone provides 600 ft2 of infiltrative surface, resulting in a total of 1,200 ft2
for the overall system. Assuming a peak flow rate of 74 gal/min, results in a net application rate of
12 inches per hour.


2.9.7                    Roosevelt Adit and Wetland Flow Augmentation

Augmenting the flows that feed the wetlands and riparian areas below Roosevelt Adit will occur after
the spring runoff and during the growing season to help maintain wetland productivity (see
Figure 12). Flow augmentation is proposed by diverting water from the pipeline leading from the
water treatment plant at the mine to the infiltration gallery. A pipe (estimated 2-inch diameter) will
be extended from the water treatment pipeline to the discharge area within the Roosevelt Adit. A gate



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valve would be located where the water treatment pipeline is directly upslope from the Roosevelt Adit
(Detail 1, Figure 12). The diversion pipe would be buried at a depth of about 4 feet, either by a small
trenching machine or by hand. In areas of solid rock and/or steep slopes where excavation is not
feasible, the pipe will be covered with approximately 12 inches of soil. The final segment of the
pipeline will be adjacent to the wetland complex but will not enter the wetland site. Treated water
will be discharged from the pipeline just above the wetland area and will flow overland into the
wetland. A totalizing flow meter will be installed to record the quantities of treated water discharged
within the Roosevelt Adit. The return of treated mine water to the headwaters of the South Fork
Nicholson Creek will augment surface water flow through the nine-acre Wetland area (see wetlands
RA1 through RA7 on Figures 1 and 4 and minimize any impacts on the wetland from mining
activities.


Flow of treated mine water would be also be diverted to a small wetland at the headwaters of Marias
Creek via a stock-watering tank (Figure 4). A smaller pipe equipped with a gate valve and flow meter
(Detail 2, Figure 12) would continue past the Roosevelt Adit and extend to below the USFS
Road 3575-120 to an old skid road upslope from wetlands that are fed by seeps and are part of the
headwaters of Marias Creek. This pipe would be installed with a small trenching machine or other
appropriate method and would follow a route that would not require removal of any tree larger than
sapling size. The pipe would discharge to a stock tank that would encourage cattle to drink there
instead of in the wetlands. The overflow from the tank would be piped to a culvert under the road and
then flow directly downslope to the wetlands and offset a modeled reduction in flow in the Marias
Creek drainage of about 0.1 gpm (at the end of mining). The discharge to augment flows at the
Roosevelt Adit and the head of Marias Creek will be in July, August, and September starting in
Year 4 to target the best productivity in the wetlands and riparian areas.


The flow augmentation pipelines and outfall locations for both the Roosevelt Adit and at the
headwaters of Marias Creek will be field approved by the Forest Service prior to construction. As
mentioned in Section 2.8.6, the location of the treated water outfall line will be field approved by the
Forest Service prior to construction.


2.9.8                    Supply and Employee Access

During road construction/reconstruction of the ore haul route, mine access will be over Forest Roads
(FR) 3575-120 and 3575-140 from Okanogan County Road 4895 (Pontiac Ridge Road).                                       In




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accordance with the Road Use Permit, Forest Roads 3575-120 and 3575-140, across National Forest
System lands and rights-of-way will receive road maintenance to make them passable by trucks
bringing equipment and supplies to the site. Signs warning of heavy traffic will be posted on
FR 3575-140 during mine construction for public safety until construction supply is transferred to the
ore haul route once that road is completed. FR 3575-140, a one lane dirt and gravel road, will be used
by 10 to 20 supply trucks per day, 1 to 2 supply trucks per hour, for a period of up to 10 to 14 months.
During ore haul operations, the supply route will be the same as the ore haul route. Employee access
24 hours per day will be allowed on the haul route and Forest Roads 3575-120, 3575, 3575-100
(between April 1 to November 30), and 3575-150.


2.9.9                    Road Use and Maintenance

Crown/Kinross will use all roads and perform road maintenance (grading, cleaning culverts, etc.) as
defined in this Final Amended Plan of Operations and the Forest Service Road Use Permits in effect
at any particular time. Maintenance will be performed on the supply haul route during construction
and operations, the ore haul route, the infiltration pipeline road, access roads to the water tower,
access roads to monitoring wells and surface water monitoring locations, and access to the infiltration
gallery. Additionally, Crown/Kinross will conduct deferred (non-routine) road maintenance such as
surface rock and culvert replacement. See Appendix D for a copy of the Road Use Permit and Road
Maintenance Plan. A new Road Use Permit will be entered into once the haul route is constructed
and accepted by the Forest Service.


Road maintenance will be conducted to provide smooth and clean road surfaces for efficient, safe and
economic use of haulage equipment and for minimizing dust.                                                           Haul roads will be maintained
regularly by a motor grader to remove any large rocks, silt or any other debris. Gravel will be
replaced as necessary to reduce dust and maintain the running surface.


During blading of roads, vegetation in ditches will not be disturbed. Road maintenance will only
remove large debris from ditches and will be done to avoid disturbance of vegetation in ditches.


Road maintenance will occur in a manner where toe slopes of cutbanks will not be refreshed by
grading and ditch cleaning equipment.                                                         This will be designed to prevent renewed soil erosion
occurrences from cutbanks.




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Winter road maintenance will provide for regular snow plowing and/or removal by Crown/Kinross to
minimize snow packing and interference with day-to-day activities. Road sanding will avoid the use
of salt. Turn-arounds will be plowed at all road junctions along the ore and supply haul route.


Crown/Kinross has defined the terms of the Road Use Permit with the Forest Service to define which
roads, or portions of roads, can be snow plowed and the conditions when roads will be open to use.
In general, only the ore and supply haul route, a route to the water tower, and a route to the infiltration
gallery can be snowplowed December 1 to March 31.                                                               Forest Roads 3575-120, 3575-150 and
3575-100 will only be plowed in winter if requested by Crown/Kinross. When within 100 feet of fish
bearing streams, snow will not be plowed off the downhill side of the road. These areas will be
marked on the ground with posts or other suitable methods. Any snow that can not be plowed onto
the uphill side of roads will be removed off National Forest System lands.


All ore and supply haul roads on National Forest System land or in National Forest rights-of-way will
be managed to control dust during construction and operation. The dust suppression program will
involve a chemical treatment with magnesium chloride and/or periodic watering. A mine water truck
will run periodically, wetting the roads to minimize dust. Water utilized to control dust will come
from water rights on private land, and not from National Forest System lands. Roads on National
Forest System lands will be maintained regularly by a motor grader to remove any silt and other
debris from the road surface and to maintain the road running surface. Smooth and clean road
surfaces are essential for not only minimizing dust but also for allowing efficient, safe, and
economical use of the haul roads. Truck drivers will be required to report dusty road conditions and
roads needing maintenance to mine personnel. Prior to the application of brine on National Forest
roads, Crown/Kinross will provide the Forest Service with a certificate stating that the dust
suppressant meets the chemical requirements of the Pacific Northwest Snowfighters including the pH
of the product. Additionally, a toxicity test (ASTM E-729) will be submitted. Crown/Kinross will
maintain detailed records of the specific locations, amount, and source of brine applied.


2.9.10                   Proposed Fence

The proposed fence has been located to encompass the mine workings with an appropriate buffer to
protect public safety. The fence will generally be 3 strands of barbed wire spaced so that it will only
be a minor obstacle to wildlife such as deer and will be constructed to minimize removal of trees in
the alignment. All fences will be designed to keep cattle from passing while allowing for deer




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passage in either direction.                                              Special modifications will be used at obvious deer crossing sites
including slight fence realignment or constructing pole fences for short distances. It is assumed that a
12-foot width of disturbance will be sufficient for fence construction. The fence alignment is shown
on Figure 1.


2.9.11                   Monitoring and Piezometer Sites and Access Roads

New monitoring wells and piezometers will be constructed according the Washington State
regulations, as described in WAC-173-160. A generalized conceptual design of a monitoring well
and/or piezometer is provided in Figures 14 and 15. After completion, the monitoring well and
piezometer sites will consist of a small concrete pad, generally less than 3 square-feet with a 2- to
3-foot high, 8-inch diameter stand-pipe (or stick-up). The monitoring wells and piezometers are
accessed via the stand-pipe.


The new monitoring wells and piezometers will be situated adjacent to existing Forest Service roads
or on drill pads that are located adjacent to the Forest Service roads. The drill site access pads are
unmaintained and will be created by driving the drill rig over native ground in order to facilitate
access during well construction. The access pads will not be used after drilling is completed. After
construction, the monitoring wells and piezometers will be accessed by foot for water level
measurement and water quality sampling. Access pad locations will be determined in the field, prior
to well construction. The access pads will be situated away from streams or other surface waters.


After drilling is completed, the drill cuttings will be managed in a manner that will prevent erosion,
protect vegetation and water quality, and the drill sites will be restored.                                           The locations of the
piezometers and monitoring wells and additional details of the monitoring protocol are provided in
Appendix H.


2.9.12                   Water Tower Access

During operations, the water tower would be accessed off Forest Roads 3575-143, 3575-120 and
3575-140 (Figures 1 and 4). Snowplowing would be permitted along these roads to provide access to
the water tower year round for inspection and maintenance. These roads would not be open to the
public from December 1 to March 31.




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3.0            ENVIRONMENTAL PROTECTION MEASURES

3.1              Introduction

Crown/Kinross has developed and will implement environmental management programs to minimize
impacts to Forest Service Lands during construction and operation of the Buckhorn Mountain Project
as described in this plan. Many of these programs, resource mitigation measures, and monitoring
programs were identified and described in the Final Environmental Impact Statement prepared by the
Okanogan-Wenatchee National Forest (USFS 2007).


3.2              Environmental Management Programs

3.2.1                    Spill Prevention, Hazardous Materials, Fire Prevention, and First Aid Programs

General. Crown/Kinross has prepared and will maintain detailed plans for spill prevention and
control of hazardous materials. These plans describe the toxic or hazardous materials to be utilized,
how they are transported, stored, and used along with the methods of disposal, and the emergency
procedures, equipment, and personnel that will be used to respond to an accidental spill on the site.
The plans describe the spill response training of employees involved in the handling and using of oil
and hazardous substances, as well as subcontractors and their employees and the haulers.


These plans describe the monitoring procedures to ensure the following:


                   •        Storage and containment facilities meet the prescribed standards;

                   •        Emergency first aid and spill response materials are available and stored in the
                            proper place; and

                   •        Communications equipment is in working order.

Fuel Oil and Petroleum Products. Crown/Kinross has prepared a SPCC for all components of the
Buckhorn Mountain Project. The SPCC is attached as Appendix B. Fuel and other petroleum
products stored on National Forest System land during construction activities will be located outside
of Riparian Habitat Conservation Areas. Crown/Kinross will take appropriate preventative measures
to ensure that any spill of oil, oil products, or other hazardous substances does not enter any stream or
other waters of the United States or any of the individual states. Storage tanks will meet the
requirements of American Petroleum Institute (API) Standards 620, 650, and 653.




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All equipment that operates on National Forest System land will be maintained, operated in good
repair, and free of abnormal leakage of lubricants, fuel, coolants, and hydraulic fluid. Crown/Kinross
and its sub-contractors shall not service tractors, trucks, or other equipment on National Forest
System lands where servicing is likely to result in pollution to soil or water. All mobile equipment,
such as trucks, would be fueled outside of the Riparian Habitat Conservation Area along Marias and
Nicholson Creeks. Crown/Kinross will furnish oil-absorbing mats for use under stationary equipment
or equipment that is being serviced, to prevent leaking or spilling of petroleum based products from
contaminating soil and water resources. Crown/Kinross will remove from National Forest System
lands all contaminated soil, vegetation, debris, vehicle oil filters, batteries, oily rags, and waste oil
resulting from use, servicing, repair, or abandonment of equipment. During operations, maintenance
will be performed at the mine site or the Kettle River Mill.


Crown/Kinross proposes to use gasoline and diesel fuel for the operation of mining and mining
support equipment. Petroleum products will be delivered to the site by outside vendors using their
own vehicles and equipment. The capacity of the fuel trucks will depend on the supplier but could be
as large as 6,000 gallons. Approximately 15 fuel deliveries are expected per month. Additionally,
other petroleum products will be delivered to the site in 5-gallon and 55-gallon barrels via delivery
trucks. The total volume of petroleum products to be stored at the mine site is estimated to be
51,250 gallons.                           Crown/Kinross has prepared a Control and Countermeasure Plan meeting the
requirements of 40 CFR 112.


Crown/Kinross shall notify appropriate agencies, including the Forest Service, of all reportable
(40 CFR 110) spills of oil, oil products, or other hazardous substances by Crown/Kinross, its
suppliers or contractors, directly or indirectly, as a result of Crown/Kinross’s operations.
Crown/Kinross will take whatever initial action that may be safely accomplished to contain all spills.


Hazardous Substances. Crown/Kinross shall notify the National Response Center, the Washington
Department of Emergency Management, and the Forest Service of all releases of reportable quantities
of hazardous substances on National Forest System lands and right-of-ways that are caused directly or
indirectly as a result of Crown/Kinross’s operations, in accordance with 40 CFR 302 and
WAC 173-303-145.


No explosives will be stored on National Forest System land.




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Transportation of Hazardous Substance.                                                            Crown/Kinross has prepared a Transportation Spill
Response Plan as required by the Forest Service for transport of hazardous materials across National
Forest System roads and rights-of-way (see Appendix E). It will be incorporated into the Road Use
Permits for the Project. Under the terms of this plan, suppliers of hazardous materials will be
required to submit spill response plans to Crown/Kinross which describe the procedures, equipment,
and personnel which will be used in case of a spill during transport on National Forest roads.
Suppliers of hazardous materials or petroleum products will be required to comply with the
Transportation Spill Response Plan insofar as it affects any part of their activities.


Fire Protection and Suppression Plan. Crown/Kinross will comply with Forest Service and DNR
procedures for protecting against starting wildfires and assuring suppression of accidental wildfires.
All equipment and vehicles on National Forest System land and roads will meet fire preparedness
requirements during the proclaimed fire season. Crown/Kinross has prepared a Fire Protection and
Suppression Plan incorporating the fire codes and standards of the DNR for the National Forest
portion of the Project (see Appendix A). Industrial Fire Precaution level requirements will be
complied with during all phases of the operation.


External Spill Response and Materials Handling Training.                                                            Crown/Kinross will ensure that
appropriate spill response and materials handling training be provided to the local sheriffs
departments, fire departments, and appropriate administering agencies. Crown/Kinross will meet
with the appropriate local authorities to discuss coordinated responses to Project related vehicle
accidents or other emergencies on Forest roads.


3.2.2                    Land Use Programs

Land and Vegetation Disturbance. Crown/Kinross will minimize disturbance by maintaining a
compact operation. Vegetation will be cleared only in those areas necessary for construction of
approved roads and facilities and only the minimum amount of timber necessary will be removed
from National Forest System lands.                                                          Erosion and sediment control measures such as sediment
collection ponds, segmental reclamation, and temporary revegetation will be implemented to prevent
downstream sediment impacts.


Timber Sale. Crown/Kinross will clear and sell timber on areas scheduled for disturbance such as
roads, pipelines, monitoring wells, and the infiltration gallery in accordance with Forest Service




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management requirements for timber harvesting. Crown/Kinross will work with the Forest Service to
designate timber to be removed prior to removal. Crown/Kinross will enter into a settlement contract
for timber harvest with the Forest Service.


During road construction/reconstruction Crown/Kinross will adjust the road as necessary away from
Marias Creek to ensure that the road is no nearer Marias Creek than the existing road. Crown/Kinross
will not remove any trees that are outside the marked clearing limits without Forest Service approval.


Volume estimation and payment will be calculated by cruising. Crown/Kinross will pile slash and
unmerchantable timber, not stockpiled for future use, for burning in locations that will not cause
damage to surrounding vegetation and/or it will be chipped for blending with topsoil. Crown/Kinross
will burn designated slash piles as directed by the Forest Service and allowed under smoke
management regulations of the Department of Natural Resources. Debris left from burning will be
spread or buried depending on the volume of material present. Constructed slash piles that are burned
will be seeded as soon as practical following burning.


Noxious Weed Control. Crown/Kinross and the Forest Service will work cooperatively to control
noxious weeds. Whereas Crown/Kinross will take financial responsibility for noxious weed control
on National Forest System lands involved with the Buckhorn Mountain Project, the Forest Service
will conduct the work. It has been estimated that this will cost approximately $4,000 per year
including monitoring and control. Crown/Kinross will provide this level of funding from the start of
operations until 5 years after the reclamation is complete. Crown/Kinross has prepared a Noxious
and non-Native Weed Management Plan for the Buckhorn Mountain Project, which is attached as
Appendix F.


The noxious weed program will include protection of all existing noxious weed posts and monitoring
plots. These are blue fiberglass posts, green carsonite posts, orange posts (monitoring sites), or 4-inch
aluminum tags on trees.                                           Posts and tags may need to be relocated prior to commencement of
activities.


Crown/Kinross will take measures to ensure that all gravel placed on roads or other fill brought onto
National Forest lands is free of noxious weeds and noxious weed seeds. Crown/Kinross will certify
that all gravel sources are noxious weed and seed free prior to placement on National Forest System
land or right-of-ways. Written certification will be provided to the Forest Service prior to placement.




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Equipment Washing. Crown/Kinross will ensure that all off-road equipment is free of soil, seeds,
vegetative matter, or other debris that could contain or hold seeds prior to moving on to National
Forest System land.                                      Crown/Kinross will certify in writing that all logging and construction
equipment, except haul trucks, service vehicles, water trucks, pickup trucks, cars, and similar vehicles
are free of noxious weeds and noxious weed seed. Crown/Kinross, and its subcontractors, shall
employ whatever cleaning methods are necessary to ensure off-road equipment is free of noxious
weeds. Equipment shall be considered free of soil, seeds, and other such debris when a visual
inspection does not disclose such material. Disassembly of equipment components or specialized
inspection tools is not required.


Noxious Weed-Free Mulch and Seed. Crown/Kinross will use certified noxious weed-free mulch,
straw and erosion blankets, and certified noxious weed-free seed mixtures to promptly reclaim
disturbed areas and control noxious weeds.                                                             Any reseeding will be done with a Forest
Service-approved seed mixture based on the list of Washington State noxious weeds.


Reclamation of Past Disturbances.                                                              Crown/Kinross will reclaim all past exploration and
development disturbances on National Forest System land, that are no longer needed, such as roads to
monitoring wells and piezometers wells, at the first available opportunity per previous National
Environmental Policy Act (NEPA) decisions.


Interim Revegetation. Crown/Kinross will conduct interim revegetation that will be designed to
stabilize embankments or structures (e.g., road cuts and fills) that are expected to remain in place until
final reclamation.


3.2.3                    Range

Livestock Water Development.                                                                During construction/reconstruction of Forest Road 3550,
Crown/Kinross will install a well adjacent to Forest Road (FR) 3550 to provide water to three water
developments that will be reconstructed north of FR 3550 at an elevation that encourages cattle to
remain on the bench above the road rather than putting pressure on the fence along the road. (See
Figure 13 for specific locations.) The pipe will be buried along the road from the well to a location
directly below the troughs and laid on the surface up the hillside to the troughs. The system will be
designed so that approximately 2 gpm flows to each trough and less than 5,000 gallons per day will
be pumped from the well. Water will be pumped during hours when the cattle typically water and the




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hours per day will be limited to assure the 5,000 gallons per day exemption is not exceeded. The
system will only be operated when cattle are in the allotment and drained prior to winter. The solar
power supply will be left in place, post mine operations, if the grazing permittee agrees to become
responsible for the solar power supply and operation of the well and watering troughs. If the grazing
permittee decides to not become responsible, the entire system will be removed off National Forest
System land by Crown/Kinross and the well capped to Forest Service standards. Crown/Kinross will
be responsible for maintenance of the system during operation of the mine.


Bat Canyon Livestock Fencing. Crown/Kinross will construct, in the area of the Bat Canyon and
Marias Creek confluence (located in Section 5, T. 39 N., R. 31 E.), approximately 1 mile of fence
that ties into the existing drift fence on the west end and steep topography on the east end on the south
side of Marias Creek to minimize cattle migration onto the Marias Creek Road. The fence will be
located to allow cattle from Bat Canyon access to Marias Creek for water. Crown/Kinross will
stabilize and armor stream banks and beds where the cattle will be watering. In addition, a cattle
guard and gate will be installed in FR 3550-080. (See Figure 13 for specific location.)


North Side Marias Creek Livestock Fencing. During construction/reconstruction of Forest Road
3550, Crown/Kinross will fence the north side of the Marias Creek Road from the Forest boundary to
the existing drift fence near Bat Canyon. The fence will be located up-gradient of the Marias Creek
Road cuts to prevent cattle from migrating onto the road. Gates will be located to accommodate
cattle movement by the grazing permittee. Northwest of the existing drift fence at Bat Canyon both
sides of the road will be fenced to the intersection of Forest Roads 3550-125 and 3550-130. To the
southeast of this intersection, Crown/Kinross will install a cattle guard in the Marias Creek Road.
Gates will be constructed at the cattle guard and roads intersecting the Marias Creek Road. Gates at
road intersections will be swing type gates. (See Figure 13 for specific locations.)


During the life of mining operations, Crown/Kinross will maintain these fences and gates. At the end
of the mining program, the fence and gate maintenance will be taken over by the grazing permittee.
If the grazing permittee determines that the fences are not necessary for his grazing operations or
elects not to maintain the fence and gates, they will be removed by Crown/Kinross during
reclamation.


Water Gaps. During construction/reconstruction of Forest Road 3550, Crown/Kinross will develop
two water gap crossings in the lower Marias Creek drainage by constructing openings in the brush




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berms or approximately one-half mile of fence with a gate and appropriate modifications to the brush
berms to allow access to or across Marias Creek Road. Crown/Kinross will stabilize and armor
stream banks and beds where the cattle will be crossing. (See Figure 13 for specific locations.)


Corral. During construction/reconstruction of Forest Road 3550, Crown/Kinross will construct a
corral in the lower Marias Creek drainage. The corral will be of post and pole construction with lever
latch gates as manufactured by Powder River, or equivalent. The corral will have three pens, and an
alley to accommodate loading of cattle into a trailer. The corral will have water access. The two pens
in the corral with water access will be sized to hold cattle overnight and the smaller pen will be
located between the larger pens and the loading alley such that cattle can be separated prior to
loading.


Cattle Drives. Spring and fall cattle drives will be completed on weekends and coordinated by the
permittee with Crown/Kinross to accommodate cattle being moved on days when ore and supplies are
not being hauled. The allotment permittee will notify Crown/Kinross at least one week prior to all
cattle drives. Cattle drives will be communicated to the ore and supply drivers by the allotment
permittee through CB radio communications. A CB radio will be provided to the permittee by
Crown/Kinross, if needed.


3.2.4                    Permitting and Financial Assurances

Permit Acquisition. NEPA documentation and Forest Service approval of the Final Amended Plan
of Operations serves as an authorization to conduct the activities described herein. Approval of
Special Use Permits for the electrical and communications line and new Road Use Permit are also
required (separate from this Plan) prior to the placement of the facilities. Crown/Kinross has included
a Reclamation Plan as part of Final Amended Plan of Operation that includes reclamation methods,
schedule and the performance securities cost estimates.


Performance Securities. The regulations of the Forest Service require that Crown/Kinross submit a
reclamation performance security to ensure that adequate reclamation and restoration of National
Forest System land is achieved following activities. Crown/Kinross has also posted a reclamation
bond with the Washington DNR for portions of the Buckhorn Mountain Project on private land and
environmental protection performance security (EPPS) with Washington Department of Ecology.
The EPPS includes funding for activities that will be on Forest Service land, including:




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                   •        Water quality monitoring (surface water and groundwater);

                   •        Groundwater level and surface water flow monitoring; and

                   •        Decommissioning of wells, piezometers and surface water monitoring stations.

Collection Agreement. Crown/Kinross will voluntarily enter into a collection agreement with the
Forest Service to pay for the costs of all plan of operation and permit approvals and administration,
including but not limited to the costs for timber marking, settlement contract preparation, road
construction inspections, water quality monitoring, fish monitoring, cultural resource monitoring, and
noxious weed control.


3.2.5                    Recreation Programs

Traffic Restrictions. No unauthorized vehicles, personnel, or firearms will be permitted within the
fenced area surrounding the mine. Public access restrictions will be implemented to control public
access within the fenced area by posting warning signs to prohibit unauthorized entry. However,
these plans will provide for administrative traffic, as well as access for Forest grazing permittees,
contractors, or operators. All gates in the fence on National Forest System roads, except the haul
route, will be kept locked at all times. Public and administrative access within the fenced area will be
re-established immediately after closure of the mine.


Hunting Restrictions. The possession of firearms, the discharging of firearms, and hunting will be
prohibited within the fenced areas around the mine area and facilities on National Forest System
lands. There will be no hunting by any parties within the fenced boundary surrounding the mine site.
The Colville Confederated Tribe members will retain access to the Buckhorn Mountain Mine site for
traditional purposes, but only under appropriate safety conditions.


3.2.6                    Transportation Program

Winter Road Maintenance and Haul. Crown/Kinross will secure a Road Use Permit that will detail
when roads are open to use and which roads, or portions of roads, can be snow plowed. In general,
only the ore and supply haul route, a route to the water tower, and a route to the infiltration gallery
will be snowplowed December 1 to March 31. Forest Roads 3575-120, 3575-150 and 3575-100 will
only be plowed in winter if requested by Crown/Kinross. Crown/Kinross will provide storage areas
for snow removal adjacent to roadways.                                                            Snow will be removed or plowed regularly by



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Crown/Kinross to minimize snow packing and interference with day-to-day activities. Road sanding
will avoid the use of salt. .Road sand would not be stockpiled for use on National Forest System
lands or right-of-ways.


When within 100 feet of fish bearing streams, snow will not be plowed off the downhill side of the
road. These areas will be marked on the ground with posts or other suitable methods. Any snow that
can not be plowed onto the uphill side of roads will be removed off National Forest System lands.
Turn-arounds will be plowed at all road junctions along the ore and supply haul route.


Winter haul and haul during spring breakup would cease when normal, routine road maintenance can
not be kept up with the surfacing standard as substantially free of chuckholes, wheel ruts, or
washboard corrugations.


Remote Office. Crown/Kinross will maintain an office, away from the mine site, at the Kettle River
Mill, for most personnel hiring and most purchasing requirements.


Supply Deliveries. Supply deliveries to the mine site will be limited to 6:00 a.m. to 6:00 p.m., 7 days
a week, except infrequent, unplanned, emergency supply deliveries outside these hours for
immediately needed supplies. With the capability to store at least several days needs for all supplies,
the need for deliveries outside of the 6:00 a.m. to 6:00 p.m. time period should be relatively
infrequent. During road construction/reconstruction for the ore haul route, supply deliveries will be
over Forest Roads (FR) 3575-120 and 3575-140 from Okanogan County Road 4895 (Pontiac Ridge
Road). In accordance with the Road Use Permit, Forest Roads 3575-120 and 3575-140, across
National Forest System lands and rights-of-way will receive road maintenance to make them passable
by trucks bringing equipment and supplies to the site. Signs warning of heavy traffic will be posted
on FR 3575-140 during mine construction for public safety until construction supply is transferred to
the ore haul route once that road is completed. FR 3575-140, a one lane dirt and gravel road, will be
used by 10 to 20 supply trucks per day, 1 to 2 supply trucks per hour, for a period of up 10 to
14 months


During operations, the primary access route will be by way of OCR 9495 (Toroda Creek Road) and
an improved FR 3550 (Marias Creek Road).




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Road Use Permit. Crown/Kinross’s Operating Plan/Road Use Permits (Appendix D) will include
the following provisions: 


                   •        Any upgrades on Forest Roads will meet Forest Service Standards (FSH 7709.56
                            Road Preconstruction Handbook) specifications for road width, grade, alignment,
                            drainage, quality control, gross vehicle weights, and signing. Exceptions to these
                            standards may be used only with Forest Service approval.

                   •        Unpaved roads will be surfaced with adequate gravel. This will minimize
                            surface soil erosion occurring from the road while still creating a permeable
                            surface.

                   •        The road route in the Marias Creek drainage will avoid the population of
                            Hedwigia ciliata. This may require moving the road route slightly up the hill
                            from its present proposed location.

                   •        Crown/Kinross will encourage car/van pooling to the site during construction and
                            operations to reduce traffic on and disturbance from project roads.

                   •        Contractors will comply with Forest Service rules for oversized and overweight
                            loads.

                   •        Location and design changes for access roads on National Forest System land or
                            right-of-way must receive approval from the Forest Service before any ground-
                            disturbing activities take place.

                   •        Crown/Kinross will be responsible for deferred (non-routine) road maintenance
                            such as surface rock or culvert replacement. Crown/Kinross will be responsible
                            for all recurrent road maintenance (grading, cleaning culverts, etc) as specified in
                            the Forest Service Road Use Permits or this FAPOO. This will apply to the
                            supply haul route during construction and operations, the ore haul route, the
                            infiltration pipeline road (from the water treatment plant to the junction with the
                            augmentation line to the Roosevelt Adit), access roads to the water tower, access
                            roads to monitoring wells and surface water monitoring locations, and access to
                            the infiltration gallery.

Road Closure. For safety considerations, signs warning of heavy traffic will be posted on Forest
Road 3575-140 at the intersection with Forest Road 3575-120 during mine construction. Heavy haul
trucks will be using this one lane, dirt road for 10 to 20 trips per day. In Marias Creek, the portion of
FR 3550-125 above the FR 3550-130 junction will be closed to public access. The new road from the
junction with FR 3575-120 to the mine site will be closed to public access during project operations.
These roads will re-open to the public once mine operation is complete.




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Road Junction Improvement. The junction of the new road to the mine site with FR 3575-120 will
be improved to increase safety. A near-perpendicular junction with stop signs will be created.


3.2.7                    Employee Training

Crown/Kinross will initiate a comprehensive program of training and education for employees and
contractors, as needed. A major portion of this training and education will involve the health and
safety practices of the construction and operation of the haul roads for the mine. Environmental
programs will be included in this training.


Environmental training will outline major rules and regulations that define key aspects of the
operation. This will include objectives, rationale, and compliance requirements will be reviewed.
Environmental training and education will explain the “hows” and the “whys” of the environmental
requirements; and emphasize the important role of each mine and contractor employee in contributing
to the success of the environmental programs.


Potential wildlife impacts and mitigation measures will be a key component of environmental training
and education. Items including, but not limited to the following, will be discussed in the training:


                   •        Hunting prohibitions;

                   •        Firearm prohibitions;

                   •        Traffic speed limits on roads;

                   •        Proper handling of spills;

                   •        Measures to prevent wildlife harassment;

                   •        Hunting and fishing regulations;

                   •        Identification and notification procedures in the event of road kill of deer and
                             other wildlife and aquatic species;

                   •        Identification and reporting requirements for threatened and endangered species.
                            (Crown/Kinross will secure a list of species and reporting requirements from the
                            Forest Service and the U.S. Fish and Wildlife Service.);

                   •        Importance of habitat conservation and reclamation; and

                   •        Likely wildlife and livestock concentration areas along roads.




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3.2.8                    Solid Waste (Refuse) Management

During construction and operation on National Forest System land, solid waste will be contained and
hauled off-site as appropriate. All solid waste will be hauled to state-approved sanitary landfills.
Facilities such as portable toilets will be used for sanitary waste. Crown/Kinross will not engage in
open burning of solid waste and refuse on National Forest System land. Spills of oil, fuel, grease, and
other materials will be cleaned up immediately.


3.3              Resource Mitigation

3.3.1                    Air Quality

Best Available Control Technology (BACT). Crown/Kinross will use BACT to control vehicle
emissions to meet all applicable federal and state air quality standards. Vehicles and equipment will
receive regular preventative maintenance to ensure they operate efficiently and completely burn fuels.


Fugitive Dust Control. All ore and supply haul roads on National Forest System land or in National
Forest rights-of-way will be managed to control dust during construction and operation. The dust
suppression program would involve a chemical treatment with magnesium chloride and/or periodic
watering. A mine water truck will run periodically, wetting the roads to minimize dust. Water
utilized to control dust would come from water rights on private land, and not from National Forest
System lands. Roads on National Forest System lands would be maintained regularly by a motor
grader to remove any silt and other debris from the road surface and to maintain the road running
surface. Smooth and clean road surfaces are essential for not only minimizing dust but also for
allowing efficient, safe, and economical use of the haul roads. Truck drivers will be required to
report dusty road conditions and roads needing maintenance to mine personnel.                                   Prior to the
application of brine on National Forest roads Crown/Kinross will provide the Forest Service with a
certificate stating that the dust suppressant meets the chemical requirements of the Pacific Northwest
Snowfighters including the pH of the product. Additionally, a toxicity test (ASTM E-729) will be
submitted. Crown/Kinross will maintain detailed records of the specific locations, amount, and
source of brine applied.


Road maintenance will be an integral part of the fugitive dust control program. Smooth and clean
road surfaces are essential not only for efficient, safe and economic use of haulage equipment but also
for minimizing dust. Haul roads will be maintained regularly by a motor grader to remove any large




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rocks, silt or any other debris. Ore and supply haul truck drivers will report dusty conditions. Gravel
will be replaced as necessary to reduce dust and maintain the running surface.


Slash Burning. The majority of slash from timber removal for road and facility construction will be
stockpiled on site and burned. Slash burning during clearing operations will comply with DNR and
Forest Service burning requirements.


Car Pooling/Van Pooling/Busing. Crown/Kinross will encourage car/van pooling by employees and
take necessary measures to minimize traffic to the site.


3.3.2                    Heritage Resources

Heritage resources identified during baseline surveys and other known historic and prehistoric sites,
buildings and properties will be protected through avoidance or data recovery. Data recovery will be
employed where avoidance of an area is not possible. Mitigation measures will be developed in
consultation with property owners, the Colville Confederated Tribes, and the State Historic
Preservation Officer.


If heritage resources are discovered during project activities, Crown/Kinross will either avoid the area
of interest or stop work in the area and take efforts to protect the site until it can be evaluated and
appropriate resource protection measures developed and implemented per the Memorandum of
Agreement between the Washington State Historic Preservation Office and the Forest Service.1


Proposed activities on National Forest System land or right-of-ways were field inventoried during
2006 (Harder 2005; Hughes 2005.) These activities are listed below.


                   •        A 354-acre block to accommodate new road construction and road reroutes
                            within the Marias Creek drainage;

                   •        Mine project fence;

                   •        Underground utility conduits (power lines) plus access roads to these facilities
                            (utilities installation to be covered under Special Use Permits);

                   •        Proposed infiltration gallery and new monitoring well;
1
         The Forest Supervisor has indicated that it may unilaterally modify or terminate permits to protect an area,
         object of antiquity, artifact, or similar object that is or may be entitled to protection regardless of when the
         area, object, or artifact is discovered or identified on National Forest System land. (USFS, FEIS, 2007)




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                   •        Guzzlers locations in the headwaters of Ethel and South Fork of Bolster Creeks;

                   •        Water gaps in Marias Creek;

                   •        Replacement water troughs north of Forest Road 3550 and a pipeline right-of-
                            way to the water troughs;

                   •        The extension of the fence south of Marias Creek from the corral near
                            FR 3550-080.

                   •        Proposed fence right-of-way from Forest Road 3550-122 to Forest Road 3550
                            and along Forest Road 3550 to its junction with Forest Road 3550-125;

                   •        A proposed monitoring well, staff gauges and piezometers; and

                   •        Three proposed culvert replacements or removals.

Two cultural resources were identified (the Cow Camp Ranch Complex and the Roosevelt adit), that
are not eligible for listing on the National Register of Historic Places (NRHP). A third site (the
Wheaton Site) was identified as potentially eligible for the NRHP and will require a professional
archeologist to be present during the road improvements in the affected area along Marias Creek
Road.


3.3.3                    Water Quality

Crown/Kinross, working with the Forest Service and DOE, has defined water quality monitoring
programs that maintain and enhance the pre-project surface and groundwater monitoring programs.
Even though many of the surface water monitoring locations are located on Forest Service lands, they
are accessed via existing roads eliminating additional land disturbance.


Project groundwater monitoring wells include both existing and proposed wells. Access to the wells
currently being monitored will be via existing access. To the extent possible, existing roads are being
used to access the proposed monitoring wells. Short sections of road construction may be necessary
to fully access the well sites. Small pads and sumps have been constructed to accommodate drilling
and construction of the wells. The disturbance area for the pads and sumps is estimated to be 50 feet
by 100 feet. The sump and slopes of the pads will be reclaimed following drilling to stabilize the
soils and reduce erosion.




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Wells will be drilled and constructed in accordance with State of Washington regulations. Figures 14
and 15 present conceptual details for monitoring wells constructed into bedrock and wells constructed
in unconsolidated material.


The infiltration area and pipeline will be inspected daily for signs of water reaching the surface
(excessively moist soils, distinct changes in vegetation, and flow). The monitoring wells associated
with the infiltration area will have the depth-to-water measured monthly and water quality samples
collected quarterly. The remaining water monitoring sites will be monitored on a monthly basis.


Water Quality. Water discharged at the infiltration gallery and any other ground water infiltration
sites will meet State ground water quality standards. Limits are set by the NPDES operating permit
issued by the Washington State Department of Ecology. Permit limits are based on the Washington
State Water Quality Standards.                                                      Enforcement will be by the Washington State Department of
Ecology.


Water discharged at surface water augmentation sites will meet the limits set in the NPDES operating
permit issued by the Washington State Department of Ecology. Permit limits would be based on the
Washington State Surface Water Quality Standards (Chapter 173-201A WAC) and human health
standards (National Toxic Rules, 40 CFR 131.36). Enforcement will be by the Washington State
Department of Ecology. Enforcement may also be by the Forest Service if compliance is not
maintained with the USFS water quality monitoring requirements.


Flow Augmentation.                                          It has been projected that underground mining will cause direct flow
reductions at seeps, springs, and stream headwaters near the mine from dewatering (e.g., maximum
reduction of 6.3 gpm, baseflow, at Roosevelt Adit and 0.1 gpm in the headwaters of Marias Creek)
during mine dewatering and initial refilling. Crown/Kinross will replace lost flow during the growing
season by storing water in the surge pond (800,000 gallons during operation and 1,000,000 gallons
after mining) at the mine during the spring and from water pumped to dewater the mine to supplement
flow during July, August, and September. Discharge would be via the treatment plant and the
infiltration/augmentation pipeline and would vary over the project life. Flow would be split, with up
to approximately 6.3 gpm going to lower Roosevelt Adit to augment flow in the stream starting from
the adit and up to 1 gpm going to a trough and the wetlands at the headwaters of Marias Creek. A
pipe would drain the overflow from the trough to the wetlands. Monitoring of flow at Roosevelt Adit
and monitoring of wetlands will guide adjustment of flow supplementation. (See Figure 1 for the




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location of the pipeline and points of augmentation.) Any additional discharges in streams or to the
infiltration gallery above flows needed to replace lost flows due to mine dewatering would be made
so that resulting stream flows remain below bank full conditions.


Surface soils (topsoil) will be saved during trenching, when the pipelines are not in roads, to reuse
and bury pipes for the infiltration gallery and conveyance pipeline. The area would be seeded with an
approved certified noxious weed free, appropriate seed mix.


Storm Water. Crown/Kinross has prepared and implemented a “Construction Storm Water Pollution
Prevention Plan” that defines the programs in-place to minimize and where possible, eliminate any
impact to area streams from storm water runoff entering or originating along the road alignment
through best management practices. Storm water control will be implemented primarily through
construction of channels to manage storm water flow. Culverts will be used to convey flow beneath
the access road. Storm water will be directed through sediment control structures and traps that will
be designed to detain flows originating from disturbed surfaces (see Appendix C). This will allow
sedimentation to occur behind the structures prior to or during proposed infiltration into specially
designed storm water infiltration structures. Sediment controls and diversions will be constructed and
made fully operational prior to beginning road construction or other surface disturbance activities and
will be maintained throughout such activities. The “Construction Storm Water Pollution Prevention
Plan” is attached as Appendix G.


Erosion control on roads will be accomplished by diverting existing flow to the inside of roads during
construction and reconstruction, thus eliminating excessive surface runoff across disturbed areas.
Sediment detention basins designed for catching and storing sediment from relief culverts will be
built as part of road construction and reconstruction. Detention basins will have an adequate retention
time to allow the sediment to settle out prior to discharge to surface waters. Sediment traps will be
placed in ditches, depending on slope, and below unrevegetated slopes to aid in erosion and sediment
control. The size and spacing of structures will be based on site specific design considerations.


Best Management Practices for runoff and sediment control include the following measures:


                   •        The disturbed area will be kept to a minimum at any given time through phased
                            disturbance and segmental reclamation;




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                   •        Drainage structures installed as part of the construction and reconstruction access
                            and haul roads will include channels, water-bars, cross drains, culverts, sediment
                            traps, and silt fencing;

                   •        Silt fencing will be placed below all fill slopes where the toe of the fill is within
                            100 feet of a stream;

                   •        Rapidly developing and sod-forming plant species will be planted to promote
                            rapid stabilization of disturbed slopes;

                   •        Seeding and planting will occur in the first appropriate season after soil
                            disturbance;

                   •        Mulches, with tackifiers (as needed), will be applied for erosion control and
                            moisture retention;

                   •        Grasses, forbs, shrubs, and trees will be planted, where appropriate, for
                            stabilization. Trees and shrubs will not be planted on road cut and fill slopes;

                   •        Interim seeding will be used to stabilize inactive, disturbed areas;

                   •        Roads and water control structures will be maintained periodically, as needed;
                            and

                   •        Sediment control structures will be maintained until reclamation and revegetation
                            are completed and the structures are no longer needed. The structures will then
                            be reclaimed. Some areas (e.g., the infiltration site) will be reclaimed at the end
                            of water augmentation.

A detailed Storm Water Pollution and Prevention/Erosion and Sediment Control Plan (SWPPP)
utilizing Best Management Practices has been developed for the road construction phase as required
by the Clean Water Act (see Appendix G). The SWPPP also incorporates operational maintenance
and monitoring as required by the USFS.


Erosion and Sedimentation. Crown/Kinross will employee Best Management Practices for erosion
and sediment control. Maintenance of diversion structures and sediment traps will be conducted by
Crown/Kinross to ensure short- and long-term effectiveness of the erosion and sediment control
facilities.


The following Best Management Practices will be used to minimize erosion and sedimentation:


                   •        Vegetation will only be removed from those areas directly affected by project
                            activities. Other areas will not be cleared.




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                   •        Cut and fill slopes for roads will be designed to prevent soil erosion. Drainage
                            ditches with cross drains will be constructed where necessary (Appendix C).
                            (See Table 3.1 for frequency of cross drains.)


                                                                     Table 3.1 - Road Cross Drain Frequency

                                                   Road Grade                                                   Spacing of Drains
                                                    (percent)                                                      (meters *)
                                                        2                                                             103
                                                        4                                                              86
                                                        6                                                              71
                                                        8                                                              57
                                                       10                                                              44
                                                       12                                                              33
                                                       14                                                              25
                   * The above guidelines have been adjusted according to the following (Packer and
                      Christenson 1964):
                   1. Reduce the spacing by 5 m. if the road is located in the middle one-third of a slope.
                   2. Reduce the spacing by 11 m. if the road is located in the bottom one-third of a slope.
                   3. Reduce the spacing by 3 m. if the road is on an east or west exposure.
                   4. Reduce the spacing by 6 m. if the road is on a south slope.
                   5. If the resulting spacing after items 1 – 4 falls below 17 m., use relief culverts at 17-m.
                      spacing and apply aggregate surfacing and erosion protection measures such as vegetative
                      seeding to ditches, road surfaces, fills, shoulders, and embankments.



                   •        Cutbanks will be stabilized after road construction/reconstruction and road
                            widening. Hydromulching will be initially applied. The area will be seeded with
                            an approved, certified noxious weed free seed mix. Hydromulching will be
                            applied in two steps—initially the seed will be applied followed by the mulch.
                            Tackifiers will be applied on harsh slopes.

                   •        Disturbed slopes will be revegetated, mulched, or otherwise stabilized, to
                            minimize erosion as soon as practicable following construction.       Road
                            embankment slopes will be graded and revegetated, as practicable, including
                            grasses and forbs to prevent erosion.

                   •        Runoff from roads, buildings and other facilities will be handled through Best
                            Management Practices, including sediment traps, check dams, dispersion
                            terraces, riprap aprons, settling ponds, berms, filter fences, adequate relief
                            culverts, etc. The design of these features will be based upon an analysis of local
                            hydrologic conditions for at least the 20-year, 2-, 3-, and 24- hour storm events.

                   •        Road ditches will be adequately revegetated during road construction, or other
                            methods will be utilized to prevent soil movement such as noxious weed/seed-
                            free wattles.

                   •        Wattles will be placed in the ditch with spacing of at least one between each pair
                            of relief culverts, but no more than 150 feet from a culvert or each other the




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                            initial year, post road construction, to trap sediment until vegetation in the ditches
                            becomes established.

                   •        During blading of roads, vegetation in ditches will not be disturbed. Road
                            maintenance will only remove large debris from ditches and will be done in a
                            manner to minimize disturbance of vegetation in ditches. If monitoring shows
                            that sites with wattles and/or vegetation are insufficient in checking sediment
                            delivery, then, in addition to wattles and/or vegetation, these sites will be lined
                            with rock or other erosion prevention measures will be installed.

                   •        Physical structures such as gabions, large boulders, etc. will be constructed at the
                            toe slopes of cutbanks at site specific locations where soil erosion concerns are
                            present. This will be designed to prevent sediment from reaching ditches, road,
                            and eventually the stream.

                   •        Off-road vehicle travel will be avoided.

                   •        The number of stream crossings will be kept to a minimum. All stream crossings
                            will be designed to accommodate at least the peak flow from the 100-year,
                            24-hour event. All relief culverts will meet the spacing specifications described
                            in Relief Culverts by Johansen, et al. (1997) (see Table 3.1).

                   •        Reclamation and revegetation will be implemented as soon as practical for long-
                            term stability.

                   •        Diversion ditches and sediment traps will be maintained as necessary during the
                            life of the operation. Sediment will be removed from sediment traps annually, at
                            a minimum,

                   •        Where a stream is within 100 feet of a road edge (bottom of fill slope), silt
                            fencing will be placed between the road edge and the stream to intercept
                            sediment before it could be delivered to the stream. Silt fencing will be installed
                            prior to the placement of road fill.

                   •        Erosion control structures and other measures will be implemented, as the road is
                            constructed/reconstructed. The road will be constructed from balance point to
                            balance point and no section of road will be left open for more than
                            approximately 10 days. The balance point to balance point will be a rolling
                            distance, allowing construction to advance as erosion control measures are
                            installed. Silt fencing will be in place prior to the beginning of construction
                            where needed. This will primarily apply in Riparian Habitat Conservation Areas
                            when within 100 feet of streams and to a more limited extent in other areas.

                   •        The silt fence will be supported by metal or thick wood posts (not lath), that will
                            be constructed to stay in place and upright, supporting the silt fence even with a
                            heavy load of sediment, loose soils, and/or rock against it.

                   •        Windrows of slash with good ground contact will be placed in-between the road
                            edge and the silt fence to provide an intermediate opportunity for sediment to be
                            entrained, not reach the stream, and reduce the sediment load that will be




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                            intercepted by the silt fence. The silt fencing and windrow(s) of slash will be
                            regularly maintained through the life of the project, though it is recognized these
                            will likely not be effective in a heavy rain/storm event that creates mass
                            movement of saturated soils from the road and road banks that will overrun the
                            sediment fence.

                   •        Silt fencing and straw bales below relief culverts will be installed immediately
                            following the installation of each relief culvert;

                   •        Silt fencing, including straw bales where present, will be repaired within
                            24 hours when a break or damage is reported by truck drivers, the range
                            permittees, the Forest Service, or a regulatory agency.

                   •        Damaged silt fencing will be replaced or repaired.

                   •        Straw bales, below the silt fencing, will be placed below all relief culverts in
                            RHCAs along the Marias Creek Road route and above Cow Camp on the new
                            road. Damaged straw bales will be replaced in the above locations except if
                            damage is caused by cows above Cow Camp.

                   •        Road maintenance will be performed to prevent renewed soil erosion occurrences
                            from cutbanks. Grading and ditch cleaning equipment will be operated in a
                            manner that will avoid fresh excavations of toe slopes of cutbanks. If substantial
                            sedimentation occurs, construction and operational activities responsible for the
                            sedimentation will be suspended or modified to reduce sediment delivery.

3.3.4                    Wetlands and Streams

Culverts in Live Streams. Crown/Kinross will construct new, and improve existing culverts and
other stream crossings on the ore haul route to accommodate the peak flow from the 100-year,
24-hour event, including associated bedload and debris. Crown/Kinross will apply the same standard
for the replacement of the lowest culvert on FR 3575. Additionally, Crown/Kinross will provide and
maintain fish passage at all road crossings of existing and potential fish-bearing streams and construct
small wetlands above culverts on live streams to compensate for wetlands lost from culvert
replacement (see the JARPA submitted to Washington DOE, WDFW, Okanogan County Planning
and Army Corps of Engineers). See Section 3.3.6 and Appendix C for a more detailed discussion of
the culvert location and design.


Wetlands, Watershed, and Habitat Restoration.                                                            Crown/Kinross will design and implement
wetlands, watershed, and habitat restoration projects in a manner that promotes the long-term
ecological integrity of ecosystems, conserves the genetic integrity of native species, and contributes to
attainment of Riparian Management Objectives under the Inland Native Fish Strategy (INFISH). The




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Aquatic Resources Mitigation Plan (Golder 2006a) presents a detailed discussion of proposed
mitigation activities on US Forest Service and private land.


Sensitive Plants. Crown/Kinross will avoid populations of sensitive plants during piezometer and
stream gauge installation. The known populations of the sensitive moss, Hedwigia ciliata, in Marias
Creek will be avoided during access road construction/reconstruction by moving the road centerline
uphill, if necessary.


3.3.5                    Scenic Resources

General Scenic Mitigation Measures. Crown/Kinross will utilize the following guidelines, to the
extent practical, to protect scenic resource:


                   •        Locate facilities where they can be screened;

                   •        Paint all structures with non-reflective earth-tone paints;

                   •        Retain vegetation and trees to screen facilities and maintain a forested
                            appearance;

                   •        Plant native species to screen facilities and revegetate disturbed areas; and

                   •        Design cuts, fills, and clearings to blend in with the surrounding topography.

Exterior Lighting. The Project will use exterior lighting that will provide the minimum light
required for safety and security purposes. Permanently mounted lights will be sodium or a type of
equal spectrum and intensity and will be directed down.


3.3.6                    Wildlife and Fish Mitigation and Enhancement

Wildlife Road Closures. In conjunction with Forest Service planning, Crown/Kinross acknowledges
that the existing “Special Order” and “Travel Plan” closed roads (mostly in the Ethel Creek area and
Forest Road 3575-125 on the ridge between Nicholson and Marias Creek) will remain in that
condition during the life of the project. Other roads in the area have been closed after NEPA
Analysis. Many of these road closures, particularly along Forest Roads 3575 and 3575-150 have been
breached by the public and will be reclosed during this project (up to 12 breaches per year).




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Additionally, Crown/Kinross agrees to the closure to all motorized vehicles except administrative
traffic of Forest Road 3550, past the junction with Forest Road 3550-125, and that Forest
Road 3550-122 will be closed after Marias Creek to all motorized vehicles except administrative
traffic.


Existing winter range road closures will be maintained except as part of the ore and supply haul route.
Forest Roads 3575-140 and 3575-143, in deer winter range, will be closed to the public from
December 1 to March 31, but plowing for administrative and mine related traffic will be allowed to
access the water tower and radio installations on Buckhorn Mountain.


Fencing for Deer Movement. Crown/Kinross will design all fences to keep cattle from passing
while allowing for deer passage in either direction. Special modifications will be used at obvious
deer crossing sites including slight fence realignment, constructing pole fences for short distances or
installing gates in deer crossing areas. The fence will generally be three strands of barbed wire
spaced so that it will only be a minor obstacle to wildlife such as deer.


Dogs. Employee owned dogs will not be allowed to run loose on National Forest System land.


Snags. Crown/Kinross will create snags in riparian areas, other than those along the ore and supply
haul route and generally more than 200 feet from open roads, by topping or methods accepted or
recommended by the Forest Service. This will be done to compensate for snags lost during project
construction and operations and for disturbance impacts of operations. The number of snags created
will be 3.5 times the number of new acres of National Forest System land cleared. At least 50% of
the replacement snags will be 21 inches in diameter at breast height (dbh) (or greater). All snags
created will be greater than 16 inches in diameter. The location of the snags to be created will be
agreed upon between the Forest Service and Crown/Kinross but will generally be along Marias Creek,
Ethel Creek and/or Nicholson Creek.


Water Guzzlers. Water guzzlers would be placed on National Forest System lands in the headwaters
of Ethel Creek and the South Fork Bolster Creek, one each location, to provide replacement water
sources for wildlife (Figure 13). These guzzlers will be placed on existing hardened sites and will
have a barbed wire fence placed around them to protect them from cows.                                          The Washington
Department of Fish and Wildlife is required to approve the design for these devices which will be
reviewed by the Forest Service prior to installation.




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Wildlife Run-outs. Snow plowing of roads can create high banks that make it difficult or impossible
for animals on the road from escaping on coming traffic. So animals can escape on-coming traffic
Crown/Kinross will create wildlife run-outs on both sides of the roads, at least every 1,000 feet, if
banks along the roads become greater than 2 feet high.


Woody Material Replacement. Crown/Kinross will replace down woody material on the reclaimed
infiltration pipeline and infiltration gallery at a rate of seven tons per acre. Efforts will be made to
use large diameter logs; and the use of stumps for this material will be limited to less than 10 percent
of the total weight.


Fish Kills. If fish kills are detected, Crown/Kinross will conduct an investigation to determine the
reason for the deaths. Based on the results of the investigation, and if determined appropriate, a
restoration plan to restore habitat or populations for fish or other aquatic species will be developed.
(Any investigation or restoration will be based on technically acceptable procedures, practices, and
methods, such as the American Fishery Society [AFS] standards and the Field Manual for the
Investigation of Fish Kills by USDI [USFWS Resource Publication #177]).


Use of magnesium chloride for dust abatement will be stopped until it is determined that the fish kills
are not the result of this dust suppressant. Water or lignin sulfonate will be used temporarily to allow
continued haulage of materials.


If a fish kill occurs that is attributable to the infiltration gallery or other augmentation sites, a fish kill
investigation will be preformed as described above. Water releases from the infiltration gallery or
augmentation site will be suspended, except as necessary to complete any investigations.


Project Speed Limits. Crown/Kinross will post project haul and supply road speed limits at 30 mph.
Ore truck drivers will be required to follow these speed limits; and drivers who do not follow them
will be replaced. All ore haul trucks will be provided with large (minimum 12 inches high), visible,
identifying numbers.


Fish Passage Improvement. Crown/Kinross will replace the lower most culvert on Nicholson Creek
Road (Forest Road 3575), and two culverts on Marias Creek near Forest Road 3550-080 with
fish-friendly culverts (Figure 13) that will allow native rainbow trout to move upstream into more
habitat area. The design of these structures includes stream simulation and may include rock vanes as




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catch points for upstream down-cutting of the channel and measures to protect the road from erosion.
The structures are designed to accommodate a 100-year flood, including associated bedload and
debris.


Amphibian Kills. If amphibians are found dead within the vicinity of project roads, riparian areas,
the infiltration gallery, or the water augmentation pipeline, an investigation will be conducted to
determine the reason for the deaths. Based on the results of the investigation, a restoration plan to
restore habitat or populations will be developed. If the deaths are the result of a dust abatement
compound, another method of dust control, will be utilized. This might include utilizing additional
water, paving portions of the road, or utilizing a different chemical such as lignin sulfonate. The
procedures described for investigation of “Fish Kills” will be followed for amphibian kills.


Notification Procedures in the Event of Wildlife Road Kill.                                                           Crown/Kinross will provide
immediate notification to the Forest Service and U.S. Fish and Wildlife Service in the event of road
kill of a threatened or endangered species, such as a bald eagle, Canada lynx, gray wolf, or a grizzly
bear. In the event of road kill of other sensitive species, Crown/Kinross will prepare a quarterly
report for the Forest Service.                                                      Sensitive species include raptors (including owls), California
wolverine, water fowl, woodpeckers, ruffed grouse, sharp-tailed grouse, blue grouse, bats, American
marten, mule deer, or some other bird species.


If monitoring shows a substantial road kill, the Forest Service and Crown/Kinross will consult with
the Washington Department of Fish and Wildlife to determine a strategy to reduce road kills. Some
strategies that might be considered include signing of wildlife congregation areas, modifications of
existing fencing to discourage wildlife use of an area, and lowering speed limits through an area.


Disposal of Killed Ungulate. The carcass of any ungulates, such as deer and cattle, killed by traffic
along the ore haul, supply, or employee access routes across National Forest System lands and right-
of-ways will be promptly removed by Crown/Kinross. Removal of these carcasses would be done in
accordance with appropriate County, State, or Federal regulations, whichever is the most restrictive.
This will reduce the likelihood of effects on carnivores that may be attracted close to the roads
because of the carcasses.




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3.3.7                    Noise

Crown/Kinross will comply with all Washington State and Okanogan County health and safety
requirements pertaining to noise generation. All supply and ore haul trucks will meet Motor Vehicle
Noise Performance Standards, Chapter 173-62 WAC. All compression type brakes will be muffled.


3.3.8                    Soils

As appropriate, Crown/Kinross will windrow, stabilize and utilize suitable soils from roads and other
disturbances as part of reclamation for these disturbances. Some soils, as along the haul route, may
be utilized almost immediately. Some soils along the pipeline to the infiltration gallery may be
utilized as part of the reclamation at the time of mine closure.


3.4              Monitoring

3.4.1                    Monitoring Measures

Crown/Kinross will implement environmental monitoring programs as outlined herein. Some of this
monitoring, such as water quality and quantity, will be required in conjunction with other agencies
permits. Monitoring programs have been designed to quantify any measurable environmental impacts
accompanying construction, operation, reclamation, and post-reclamation closure conditions with
reference to pre-operational data obtained during baseline monitoring.                                          Impacts that result in
violations of regulatory stipulations, such as water quality permits, will require alterations of project
operations or additional mitigation actions. Any exceedance of monitoring criteria required by the
Forest Service will be reported to the Forest Service within 7 days of discovery unless other
timeframes are required by permit or law.


Crown/Kinross will prepare an annual report for monitoring studies. Crown/Kinross will submit the
annual report to the Forest Service by March 15, and will meet with the Forest Service to review the
monitoring results and plan. Crown/Kinross will periodically review monitoring data to assess the
possible presence of shorter long-term impacts resulting from the project.


Crown/Kinross will provide the Forest Service with all water quality and quantity data provided to
WDOE, for the Buckhorn Mountain area, in compliance with State permits, or a summary of that
data, semi-annually.




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3.4.2                    Water Resources Monitoring

Crown/Kinross has established a ground water and surface water monitoring programs to assess:


                   •        Compliance with state and federal permits;

                   •        Operational performance;

                   •        Long-term changes in water quality and quantity;

                   •        Closure and reclamation success; and

                   •        Magnitude and extent of unanticipated releases of regulated substances.

A Hydrologic Monitoring Plan has been established that addresses all components of the project (i.e.,
Federal, State and Private land). The plan is included as Appendix H. The monitoring program
includes water quality, quantity, and levels of regulated substances. The water quality monitoring
program involves collection and analysis of key parameters necessary to assess each phase of the
project. Water monitoring samples will be collected at many locations, including existing and
proposed monitoring wells, and existing and new surface water monitoring points including three
directly adjacent to the Marias Creek haul routes. Turbidity levels will be monitored before, during
and for at least three years after road construction/ reconstruction. During construction, turbidity
levels will be monitored at all culverts along the mine access road located on state or private land, as
part of Ecology stormwater monitoring requirements.                                                         Some examples of key surface water
parameters include flow, pH, chloride, sodium, calcium, magnesium, turbidity, total dissolved solids,
total suspended solids, dissolved oxygen, temperature, and total petroleum hydrocarbons along the
ore haul route.


Presently, there are nine monitoring wells and 20 surface water monitoring stations in use on all land
ownerships. Seven of these monitoring wells and 14 of these surface water monitoring stations are on
National Forest System land or are accessed off National Forest System roads. One new monitoring
well will be installed on National Forest System land in the vicinity of the infiltration gallery;
approximately 50 feet from the previously reclaimed site of monitoring well 3a.


In addition, there are at least five small diameter wells containing piezometers for measuring
groundwater levels on National Forest System land. Four new piezometer wells will be installed in
the vicinity of the infiltration gallery. Three of these wells will be shallow (15 to 20 feet) paired wells




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with existing deeper piezometer wells (45 to 60 feet). One new shallow piezometer well will be
placed along Forest Road 3575-125 below the infiltration gallery, between two existing wells to
monitor changes in ground water levels. An estimated 14 shallow piezometers and staff gauges will
be placed in seeps and springs on both sides of Buckhorn Mountain to monitor changes in water
levels during mining operations and refilling of the aquifer at the end of operations.                             These
piezometer wells will be about 3 feet deep and 2 inches in diameter and will likely be driven into the
ground with a fence post driver or sledge hammer.


In addition, several new surface water monitoring sites will be placed in the lower reaches of Marias
Creek to monitor surface water quality. See Appendix H for approximate locations of the new
surface water monitoring sites.


Surface water quality and quantity monitoring stations will be established in streams, springs, and
seeps that have the potential to be impacted by ore haul, water infiltration, or mining operations.
Water at these stations will be sampled and analyzed for physical and chemical parameters. The
existing baseline monitoring network will be preserved to the extent possible.


Surface water quality and flow will be measured at two locations, one upgradient of the infiltration
gallery in Gold Bowl Creek (SW-9) and one downgradient of the infiltration gallery in South Fork
Nicholson Creek (SW-7). The stations will be monitored monthly during operations, reclamation and
post-closure and reequilibrium (currently expected to be Year 40).


Surface water will be monitored at three locations along Marias Creek (MC-1, MC-2 and MC-3) as
part of Ecology and USFS requirements. Sampling of the stormwater stations along Marias Creek
will involve:


                   •        Monthly sampling for magnesium;

                   •        Sampling every two weeks for chloride;

                   •        Continuous sampling for turbidity and temperature at two locations (MC-1 and
                            MC-3) using an in-stream turbidity probe and data logger set at 1-hour intervals
                            to meet USFS requirements;

                   •        Continuous followed by reduced sampling of turbidity and temperature in two
                            locations in Toroda Creek as specified in Appendix D of the Final USFS EIS
                            (2007); and




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                   •        Additional turbidity samples will be taken following rain events that meet the
                            criteria specified in the General Storm Water Construction Permit and
                            Operational Mine Site SWPPP (Golder 2007).

Two other stations along Marias Creek will be monitored as part of Ecology requirements (SW-2
[also called MC-1] and SW-8).                                                        See Figure 2-3, Appendix H.   Water quality monitoring (see
Table 3-1a, Appendix H) will be monthly at SW-8. Flow rates will be monitored at both SW-2 and
SW-8. SW-2 will be monitored through the post-reclamation monitoring period, and SW-8 will be
monitored until one year after flow augmentation at the Roosevelt Adit stops. Flows at the Roosevelt
Adit may be monitored through Year 40. The length of the monitoring period at the Roosevelt Adit
beyond Year 40 will be determined after the data up to and including Year 40 have been evaluated.


Ground water monitoring wells will be located as close to the potential source of contamination as
physically or reasonably possible. The locations and list of ground water monitoring parameters are
presented in Appendix H. The locations of water monitoring wells are found on Figure 2-5 in
Appendix H. The existing baseline monitoring network will be preserved to the extent possible.


Additional piezometers (small diameter pipes, usually one inch or less in diameter, sunk into the
ground to measure the “surface” of the groundwater) and staff gauges will be used to monitor effects
on seeps and springs. Piezometer locations are shown on Figure 2-6, Appendix H. Water level in the
piezometers will be monitored monthly.


Crown/Kinross will install, maintain, and record measurements from devices for measuring
precipitation, temperature, wind speed/direction, and the depth and water content of the snow pack at
the lower portal area of the mine site.


Post closure monitoring will continue for a period of at least 3 to 5 years, depending on location. The
focus of this monitoring will be long-term water quality effects. The frequency will be adequate to
document changes in water quality and quantity.


If necessary, Crown/Kinross will access monitoring wells by overland traversing (snow mobiles or
snow shoeing). Crown/Kinross will not snow plow roads to access water monitoring wells and
surface water monitoring points.




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3.4.3                    Range Allotment Monitoring Measures

Crown/Kinross, the Forest Service, and the grazing permittee will annually review range allotment
measures to evaluate the effectiveness of the mitigation programs, identify areas that need
improvement, and make appropriate adjustments.


Crown/Kinross will monitor and if necessary make ongoing improvements to the mitigation programs
to reduce the potential for truck and cattle interaction. Additional measures that may be implemented
include additional fencing, additional water troughs, additional water gaps, and changes in procedures
to place or remove cattle from the area.


3.4.4                    Wildlife Road Closures

Crown/Kinross will check road closures proposed for wildlife mitigation in Bear Trap Canyon on a
monthly basis to assure that they are intact. Crown/Kinross will repair any closures that have been
breached. Other roads in the area have been closed after NEPA Analysis. Many of these road
closures, particularly along Forest Roads 3575 and 3575-150 have been breached by the public and
will be reclosed during this project (up to 12 breaches per year). Crown/Kinross would monitor these
closures twice yearly, once in the spring and once in the fall prior to the general rifle season.


3.4.5                    Fish Populations

Crown/Kinross will monitor fish populations in the streams along the ore and supply haul routes in
years 1 through 5, 8, and 10. If it is determined that fish populations have significantly declined or if
there is a significant change in species diversity that can be attributed to project activities, additional
mitigation measures will be considered to reverse the changes.


A Work Plan will be developed to guide the study. The Work Plan will be developed in consultation
with the USFS and be implemented by a qualified contractor paid by Crown/Kinross. Historical
information on fish species, abundance and fork length upstream and downstream of existing fish
passage barriers collected previously by the USFS, Pentec and URS (Ecology 2005) will be utilized
as the baseline conditions for analysis purposes.


Monitoring of fish abundance will follow Methods for Estimating Instream Juvenile Salmonid
Abundance (Golder 2006b). Sampling for juvenile abundance will occur during the low flow period




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in late summer. It will be done in one or two days within the same week to avoid changes in
conditions, rainfall events, etc using the following procedures:


                   •        The sampling team will place blocking nets at the upstream and downstream end
                            of the sample reach in order to reduce escapement of fish from the sample area;

                   •        Using an electrofisher adjusted for maximum non-lethal efficiency, the sample
                            reach will be covered thoroughly and all fish discovered will be captured and
                            placed in buckets for later enumeration. This process will be repeated two more
                            times;

                   •        At the end of the sampling, each pass will be enumerated by species and size in
                            order to develop an estimate of the total number of fish within the sampled area.
                            Three passes will be used to improve accuracy;

                   •        Sampled fish will be identified as to species and measured for fork length; and

                   •        Juvenile population will be marked with fin clips.

3.4.6                    Timber Monitoring

Crown/Kinross will work with the Forest Service on clearing, harvest and slash disposal.
Crown/Kinross recognizes that the Forest Service will monitor these activities to ensure compliance
with the Timber Sale Contract and this Final Amended Plan of Operations.


3.4.7                    Noxious Weed Monitoring

Crown/Kinross will provide the Forest Service with funding of up to $4,000 per year to monitor and
control disturbed and reclaimed sites for noxious weeds. Crown/Kinross will provide this level of
funding from the start of operations until 5 years after reclamation is complete; estimated 13 years
total.


3.4.8                    Transportation Monitoring

Crown/Kinross will meet with the Forest Service annually to review transportation and related safety
issues. Crown/Kinross will develop an inspection schedule for all construction and reconstruction to
ensure that of all mine access and operational roads on National Forest System land are constructed
and maintained to Forest Service standards. Additionally, Crown/Kinross will inspect all mine access
roads on National Forest land prior to winter operations and during and after spring runoff. The




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purpose of these inspections will be to certify that drainage structures are functioning as designed,
and/or to identify needed improvements or changes.


Crown/Kinross will monitor traffic speed on project supply and ore haul roads. Mileage markers will
be placed along the haul route every ½ mile.


3.4.9                    Reclamation Monitoring

Crown/Kinross will monitor reclamation success in accordance with the Reclamation Plan (see
Section 5). Areas to be monitored will include road cut and fill slopes, other reclaimed areas such as
temporary access roads, and the infiltration area and pipeline.


Crown/Kinross will evaluate the vegetation cover, species composition, and tree planting success
during the first, third, and fifth year following seeding or planting. Road cuts and fills will be
reseeded to grasses and forbs. Tree planting success criteria will be measured against the criteria
outlined in Section 5.0.


3.4.10                   Cut and Fill Slope Monitoring

Crown/Kinross will monitor cut and fill slopes for soil erosion and displacement once road
construction is complete. If significant erosion of slopes is identified, additional soil stabilizing
methods will be implemented. Options may include additional seeding, tackifiers, erosion mats,
and/or placement of boulders.


Crown/Kinross will visually survey and record any damage to cut and fill slopes along the length of
the haul route weekly during April and May, monthly June through September and quarterly (i.e.,
November and February) the remainder of the year. In addition, a visual survey of the road will be
done within 24 hours following any period of rainfall of more than 0.25 inches in 24 hours measured
at the Buckhorn weather station. Any rills greater than 4 inches in depth would be stabilized and re-
vegetated within the week. The Forest Service would be notified quarterly of the results of those
inspections.




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3.4.11                   Monitoring of Silt Fences and Straw Bales

Field surveys will be made visually and a written record kept of all findings. Collected information
will be sent to the Forest Service quarterly. Silt fencing and straw bales will be monitored monthly
May through September and quarterly (i.e., November and February) the remainder of the year. On
the Nicholson Creek haul route, silt fencing and straw bales would be monitored monthly except
when cattle are present on the allotment and then they would be monitored weekly.


Crown/Kinross will survey sediment control structures along the length of the haul route within
24 hours following any precipitation events of more than 0.25 inches in 24 hours measured at the
Buckhorn weather station. This is a rolling 24-hour period for rainfall events. If the structures and
measures are not functioning, require maintenance, or are not in the proper location, Crown/Kinross
will take action to repair, move, or supplement the sediment reduction measures within 48 hours of
the survey.




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4.0            TEMPORARY SHUTDOWN

Although the project will operate year-round, it is possible that conditions may be encountered during
the life of the project that may require temporary shutdown of the operations. The primary concern
during a temporary closure will be maintenance of the water control structures.


The temporary closure plan is based on an economic shutdown of more than 1 year duration but not
to exceed 2 or 3 years. The following steps will be followed to ensure that the closure and subsequent
restart activities will be accomplished in a timely and environmentally safe manner:


                   •        In the event of a temporary shutdown planned for more than 1 year, the
                            appropriate regulatory officials in the USFS, DNR and Washington Department
                            of Ecology (DOE) will be promptly notified. As required by 36 CFR 228.1, a
                            statement of Temporary Cessation will be filed with the District Ranger within
                            30 days of work stoppage.

                   •        Inventories of petroleum products, explosive and other potentially hazardous
                            supplies that will not be used during shutdown will be used at other sites,
                            returned to suppliers, or disposed of in compliance to the appropriate regulations.

                   •        Concurrent reclamation will be implemented on areas not scheduled for
                            additional disturbance.

                   •        Crown/Kinross personnel will regularly inspect and perform maintenance
                            activities which will include:

                            ○ Maintaining access roads to all project facilities and monitoring locations;

                            ○ Diversion ditches and infiltration ponds will be inspected annually in the fall
                                      to ensure that spring runoff can be handled and that the systems continue to
                                      function properly after major storm events. Maintenance will be performed
                                      as necessary;

                            ○ Appropriate sediment control measures will be implemented as necessary to
                                      control erosion from disturbed areas which cannot be finally reclaimed; and

                            ○ Security and fire patrol of the facilities;

                   •        Appropriate monitoring inspection reports will be completed and submitted to
                            appropriate state and federal regulatory agencies during the temporary closure
                            period as required.

                   •        The water treatment plant will be operated as needed to maintain acceptable
                            water quality within the mine workings. Water augmentation will continue as
                            needed.




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4.1              General Activities in the Event of a Temporary Shutdown

Although a temporary shutdown of operations is not planned, circumstances beyond the control of
Crown/Kinross may require a temporary cessation of operations. In the event that the facility has to
be temporarily closed due to severe weather conditions, unfavorable economic conditions, or for other
reasons, a security caretaker crew will remain onsite through the temporary closure period. These
personnel will be responsible for maintaining the integrity of pipelines, trenches, diversion structures,
berms, and embankments during shutdown and maintaining adequate stormwater capacity in the
ponds. Water will be recirculated as long as necessary to prevent lines from freezing.


4.2              Maintenance Programs

Crown/Kinross will maintain access to the mine site and will perform road maintenance and snow
removal as necessary. This will include security and fire patrol of the facilities. Crown/Kinross will
continue to supply utilities, such as electricity, water, and fuel at levels necessary for site
maintenance.


The water treatment plant, pipeline, and infiltration gallery will be operated, as needed, to effectively
manage the water balance.


Diversion ditches and sedimentation ponds that are part of road system will be cleaned and repaired
to ensure that approved design criteria are met and that they continue to function properly.


Additional, sediment management structures will be installed to minimize erosion and sediment
delivery, as necessary. Appropriate sediment control measures will be implemented as necessary to
control erosion from disturbed areas which cannot be finally reclaimed.


4.3              Monitoring During a Temporary Shutdown

Monitoring will continue to be performed in accordance with the requirements of the permits.


Diversion ditches and sedimentation ponds will be inspected after major storm events to ensure that
the systems will continue to function properly.




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Appropriate monitoring inspection reports will be completed and submitted to appropriate state and
federal regulatory agencies during the temporary closure period as required


4.4              Reclamation Activities during a Temporary Shutdown

Crown/Kinross will undertake interim reclamation measures, as necessary, to stabilize disturbed
areas. Grading and seeding will be implemented on areas not scheduled for additional disturbance.


4.5              Notification

Crown/Kinross will notify the Forest Service and other regulatory authorities of any temporary
shutdowns or closures. Notification will include a description of the procedures and controls that
have been or will be carried out to maintain process components during the shutdown period. This
will include facility manning levels and duties, description of maintenance programs, monitoring and
inspection plans, any proposed, temporary, changes to any monitoring plan, any reclamation plans,
and an estimate of the duration of the temporary shutdown.


4.6              Permanent Cessation

In the unlikely event that operations permanently cease prior to the scheduled completion of
operations, Crown/Kinross will work with the Forest Service to develop a revised reclamation plan
that specifically addresses the existing conditions at the time of closure.




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5.0            RECLAMATION

5.1              Introduction

Crown/Kinross has prepared a Reclamation Plan for the Buckhorn Mountain Project that outlines
activities to return the disturbed areas to a stabilized and productive condition and to protect long-
term land, water, and air resources.                                                        The following discussion summarizes the contents of the
Reclamation Plan.


5.2              Reclamation Goals and Objectives

Crown/Kinross’ reclamation policies are to return disturbed lands to their pre-mining uses consistent
with the Forest Services policies. Following from that policy are the basic goals of the Reclamation
Plan, which include:


                   •        Establishment of stable surface, topographic, and drainage conditions that are
                            compatible with surrounding landscapes and that control erosion, water quality
                            and air quality impacts from the operation;

                   •        Establishment of surface soil conditions that are conducive to regeneration of a
                            stable plant community through removal, stockpiling, and reapplication of
                            suitable topsoil and cover soil material, where possible;

                   •        Revegetation of disturbed areas using species adapted to site conditions and
                            approved by the Forest Service in order to establish a long-term productive, self
                            sustaining, biotic community compatible with currently identified future land
                            uses and comparable to what currently exists on the site;

                   •        Consideration of public safety; and

                   •        Consideration of the post-mining land uses on Forest Service lands.

5.3              Methodology

The reclamation program for the Buckhorn Mountain Project is designed to reclaim mining and ore
haul related disturbances on National Forest System land, where conditions and current reclamation
technology reasonably permit, in compliance with the requirements of the Forest Service.
Crown/Kinross has outlined procedures to reclaim affected areas to a productive post-mining land use
that is similar to pre-mining land uses.




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Whereas reclamation practices and technology are changing and developing, future modifications in
the Reclamation Plans are possible. Crown/Kinross will explore new reclamation techniques and
more potentially improved methods for erosion control. The Reclamation Plan will be updated at
least once every five years or as appropriate using improvements in reclamation technology.


5.4              Current Land Use

The current land use of much of the site is primarily for timber management, range land for cattle
grazing, wildlife habitat, and dispersed recreation. The emphasis of the Reclamation Plan is to create
forested habitats similar to what existed prior to the start of project activities and improved deer
winter range, where appropriate.


5.5              General Reclamation Procedures

This section includes the general steps to be followed in reclaiming each of the disturbance areas.
Where feasible, project features to be reclaimed will be designed to achieve a topography that blends
into the surrounding terrain.


5.5.1                    Vegetation Clearing and Topsoil Salvage and Stockpile

Initial construction activities will be site clearing that will include harvesting and removing
merchantable timber. Careful consideration will be given to right-of-way requirements and saving
timber and vegetation needed to meet erosion control requirements. To the extent possible, remaining
vegetation will be removed and be placed below the road as part of the project erosion control
measures. Logs that will be used for replacement of large woody debris during concurrent or final
reclamation will be stockpiled during operations. Stockpiling of large woody debris will be done
along the pipeline route to the infiltration gallery. Stumps will be chipped and returned onto the cut
and fill slopes of roads. Other woody debris including limbs, brush, etc. will be placed in a windrow
below road fill slopes to provide an erosion barrier.


Prior to land disturbing activities, topsoil and other soils that provide suitable growth media will be
salvaged from areas to be disturbed. Growth media is soil that is used for reclamation purposes.
Both topsoil and some subsoils are commonly excavated and stockpiled for use in reclamation but
may require amendments to make them productive as growth media. The salvaged soils will be




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stockpiled for later use and seeded with a fast growing seed mix approved by the Forest Service to
control invasive weeds and erosion.


Seedlings and seed mixes approved by the Forest Service will be used to establish acceptable
vegetation on disturbed sites. The collection of tree and shrub seeds from proper seed zones and then
providing these seeds to a private tree nursery to grow the necessary seedlings needed for reclamation
may be required to establish acceptable vegetation.


5.5.2                    Decommissioning of Facilities

Following permanent closure of the operation, salvageable equipment and tanks will be removed
from the site. Utilities lines will be disconnected, piping will have sections removed at the top and
bottom and be capped or plugged, access ports will be removed from the infiltration pipeline, and any
surface structures removed.


5.5.3                    Road Grading and Stabilization

Construction/reconstruction slopes on the ore and supply haul route, except between the 3575-120
road and the patented lands, will be shaped for reclamation during initial material removal and
placement. Road cut slopes in bedrock will be left as near vertical walls to minimize the amount of
disturbed land.


During the reclamation period, Forest Roads 3550 and 3550-125 would be returned to their present
17- to 18-foot usable surface width, with intervisible turnouts, by ripping and revegetating the
running surface. The access road to the patented land from its junction with Forest Road 3575- 120
will be reclaimed back to a one lane road. The access road for the infiltration gallery pipeline from
the water treatment plant to the junction with the augmentation line to the Roosevelt Adit will be
obliterated and returned to its natural contour. Access roads to monitoring wells will be returned to
their natural contour on National Forest System land.


Sediment control structures will be maintained until reclamation and revegetation are completed and
the structures are no longer needed. The structures will then be reclaimed.


Grading during reclamation will be designed and conducted to minimize the potential for erosion.
Specifically, the following measures will be implemented:




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                   •        Fill slopes and other potential sediment sources will be visually inspected
                            throughout the operation to allow early detection of erosion and vegetation
                            problems. Critical runoff events are spring snow melt and thunderstorms; and

                   •        Reclaimed slopes will be inspected after spring runoff and after major storm
                            events for a period of at least 5 years after the completion of reclamation grading.
                            Any rills or gullies greater than 4 inches deep that develop will be stabilized and
                            revegetated.

5.5.4                    Topsoil Placement

Topsoil and cover soil suitable for revegetation will be placed, as possible, to help in revegetation
along roads and pipelines.


5.5.5                    Fertilization

Soil testing will be conducted prior to seeding and planting to determine if fertilizers are needed to
provide an initial source of nutrients for establishment of the desired plant community. Fertilizer
recommendations will be based on the nutrient requirements of species to be planted, the
effectiveness of fertilizers on a given soil type, depth of plant growth layer, and measured nutrient
deficiencies of the soils. Fertilizer application rates will be approved by the Forest Service prior to
application. Use of fertilizer may be a concern since it could promote noxious weed spread.


5.5.6                    Revegetation

The species mixture chosen for revegetation will be selected to provide a stable environment that is
capable of supporting pre-mining land uses of timber production, livestock grazing, wildlife habitat,
and dispersed recreation use. Seeding and planting activities for grasses and forbs will be conducted
in the fall to take advantage of winter and spring moisture. Where necessary, planting of trees and
shrubs will take place in the spring. If seeding or planting are unsuccessful, follow-up applications in
the next appropriate season will occur until revegetation meets release criteria.


The surface of prepared seedbeds will be left relatively rough to create sufficient micro sites to
facilitate burial of seed and establishment of seedlings. Areas that are compacted will be ripped to an
18-inch depth to loosen the plant rooting zone and create an adhesive surface for topsoil application.
Grass and forb seeds will be broadcast with a cyclone-type broadcast seeder where possible and if
necessary, inaccessible areas will be hydro-seeded. It is desirable to use broadcast seeding techniques
to the extent possible since it creates a more natural appearing plant community. Tree and shrub



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seedlings will be planted where necessary and desirable (e.g., at the infiltration gallery and along the
infiltration pipeline). They will be planted randomly at approximately 250 trees and 425 shrubs
(250 kinnikinnick, 100 snowberry, and 75 baldhip rose) per acre from containerized stock.
Permanent road cuts and fills will not be planted with trees. Road cuts and fills will be planted with
grasses and forbs


5.5.7                    Noxious Weed Control

Crown/Kinross will provide up to $4,000 a year in funding for the Tonasket Ranger District to
undertake necessary noxious weed monitoring and control measures utilizing various mechanical,
biological, cultural, and chemical control techniques on project haul roads and facilities under
existing District Noxious Weed Environmental Assessments until 5 years after reclamation is
complete.


5.5.8                    Revegetation Success Monitoring

Crown/Kinross will monitor reclamation to estimate reclamation success. Areas to be monitored will
include road cut and fill slopes, and other reclaimed areas such as temporary access roads, and the
infiltration area and pipeline.


Crown/Kinross will begin monitoring the first growing season following planting and seeding and
will continue until successful revegetation criteria have been met. Revegetation will be considered
successful when herbaceous cover and production values, as well as, woody plant densities and tree
seedling survival rates, meet or exceed proposed success criteria.


Crown/Kinross will evaluate the vegetation cover, species composition, and tree planting success
during the first, third, and fifth year following seeding or planting. Tree planting success criteria
would be measured against the following standards:


                   •        First year, > 90% of trees alive and well distributed;

                   •        Third year, >75% trees alive, well distributed, and in fair or better condition; and

                   •        Fifth year, at least 250 trees per acre, 134 well-distributed crop trees.




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Shrub planting success would be measured against the following standards:


                   •        First year, > 200 shrubs/acre; and

                   •        Third and fifth years, > 140 shrubs per acre.

The planting success will be a minimum of at least three shrub species present, each representing at
least 10 percent of the total population, or a minimum of five shrub species present, each representing
at least 8 percent of the total population. Grass seeding success will be measured against the
following standards, except where directly underlain by rock:


                   •        First year, >30% ground cover; and

                   •        Third year, >60% ground cover.

In areas where these standards are not met, replanting will take place until they are met.


5.6              Reclamation Performance Securities

5.6.1                    Requirements

The regulations of the Forest Service require that the Crown/Kinross submit a reclamation
performance security to ensure that adequate reclamation and restoration of National Forest System
land is achieved following activities. The reclamation performance security will provide the Forest
Service with sufficient funds to reclaim, revegetate, and remove facilities from National Forest
System land, and to monitor and correct water quality problems should Crown/Kinross fail to do so.


An Environmental Protection Performance Security Plan (EPPS) bond has been posted with DOE.
The following items are included in the EPPS and will not be included here:


                   •        Water quality monitoring and mitigation of water quality problems; and

                   •        Abandoning monitoring wells, piezometers and surface water stations.

5.6.2                    Closure Cost Estimate

Closure costs were developed for use in determining the reclamation bond.                                       Closure costs are
summarized in the following table:




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      Project Activity                                                                 Cost                               Comments and Notes
Lower haul road reclamation                                                           $8,740           Rip running surface to reduce width and revegetate
                                                                                                       5.2 miles along Marias Creek
BMPs                                                                               $60,600             Assumes 4000 feet of access road under construction at any
                                                                                                       one time
Road surfacing                                                                     $87,404             2.2 miles of rock surfacing
Regrade and revegetate upper                                                       $25,587             Regrade to 1-foot width by excavating fill and revegetate
haul road                                                                                              (0.63 miles)
Pull back topsoil and brush                                                        $30,039
berm
Seed lower haul road cut and                                                       $40,251             Hydroseeding
fill slopes
Regrade infiltration gallery                                                          $5,230           Assumes cut/fill required and revegetation; only the portion
pipeline road                                                                                          of the pipeline from the water treatment plant to the
                                                                                                       junction with the augmentation line to the Roosevelt Adit
                                                                                                       (0.4 miles).
Infiltration Gallery Demolition                                                    $10,700             Includes infiltration gallery and cattle trough appurtenances
Monitoring wells, piezometers,                                                     $40,000
and surface water monitoring
station abandonment
Rip infiltration gallery and                                                              $175
spread topsoil
Replace large woody debris                                                         $11,706
Revegetate infiltration gallery                                                    $19,477
area
Remove perimeter fence on                                                          $17,322
USFS land
Reclaim access roads to                                                            $22,749
monitoring wells
Disconnect utilities                                                                $345
Turbidity, Sediment Control,                                                    $218,760               Turbidity monitoring for 3 years, Sediment control
and Post-closure monitoring                                                                            structures surveys for 2 years, and Post-closure monitoring,
                                                                                                       13 years. Includes $4,000/year for noxious weed control
Weather station                                                                     $600
Total Direct Cost                                                               $599,685               Sum of direct costs

Mobilization/Demobilization                                                        $29,984             5% of Direct Costs
Engineering/Construction                                                           $29,984             5% of Direct Costs
Quality Assurance
Contractor Profit and Overhead                                                     $89,953             15% of Direct Costs
Contract Administration                                                            $59,969             10% of Direct Costs
Contingency                                                                        $89,953             15% of Direct Costs
Performance and Payment                                                            $17,991             3.0% of Direct Costs
Bond
Total Indirect Costs                                                            $317,833               Sum of indirect costs
Total Cost                                                                      $918,000               Rounded sum of direct and indirect costs
Total Cost with 2 Years’                                                        $967,000               Rounded sum of direct and indirect costs
Inflation




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Equipment and labor costs are based on costs for a contractor to perform the tasks. Labor costs are
based on Davis-Bacon rates for Okanogan County (USDOL 2007).                                                    Equipment costs were
determined using Means (2003, 2005, 2006 and 2007), Rental Rates Blue Book (Primedia 2002),
Cost Estimating Guide for Road Construction (USFS 2006) and Construction Equipment Owning and
Operating Expense Schedule Region VIII (ACOE 2005). Rates were increased by 2.65 percent per
year to adjust for inflation. The rates were increased using recommendations in ACOE (2005) to
account for increases in fuel costs since 2005. Productivity was determined from Means (2006) and
the Caterpillar Performance Handbook Ed. 35 (2004). The estimated cost is approximately $967,000.
Detailed calculations are included in Appendix I.


5.7              Reclamation Schedule

Reclamation and closure measures will be incorporated into the Buckhorn Mountain operations.
Reclamation activities will be initiated as soon as practical after project activities in a particular area
are completed, thus minimizing erosion and sedimentation problems.


In general, reclamation activities will be timed to take advantage of optimal climatic conditions.
Seedbeds will be prepared and seeding will be completed in the fall in order to take advantage of
winter and spring moisture. Tree and shrub planting will occur in the spring.


During the life of the project, interim and concurrent reclamation will be conducted to reduce erosion
and the potential for water quality degradation. Interim revegetation will be applied to temporary
road embankments along the pipeline to the infiltration gallery (the portion of the pipeline from the
water treatment plant to the junction with the augmentation line to the Roosevelt Adit) and road
embankments of the new road to the lower portals from FR 3575-120. These activities will be
performed to reduce erosion and sediment during the life of the operation. Topsoil will not be applied
to interim revegetated areas. Mulch will be applied, as appropriate, following seeding. Concurrent
reclamation will be used on disturbed areas that have been graded to final reclamation topography,
such as road fill slopes and cut slopes that will not be further modified at the end of operations.


Final surface contouring and revegetation activities on portions of the roads, the infiltration gallery,
and the fence will occur at the time of construction since the surface disturbances in these areas will
be modest and will remain intact after construction. Portions of the pipeline and road to the water




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infiltration gallery (the portion of the pipeline from the water treatment plant to the junction with the
augmentation line to the Roosevelt Adit) and portions of the newly constructed road from the
3575-120 road to the patented lands will undergo reclamation at mine closure. Final reclamation will
be implemented upon the completion of ore haulage. Forest Roads 3550 and 3550-125 will be further
reclaimed but this reclamation will not disturb the cut and fill slopes but only the road surface. The
surface of the road will be reduced to its present width of 17 to 18 feet, plus intervisible turnouts, with
ripping and grass seeding of the remaining portion of the road.




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6.0            REFERENCES CITED

ACOE (see Army Corps of Engineers).

Army Corps of Engineers. 2005. Construction Equipment Owning and Operating Expense Schedule
      Region VIII. EP 1110-1-8, Volume 8. July 2005.

Battle Mountain Gold Company (BMG). 1992. Plan of Operations, and its subsequent revisions in
        1993, 1997, and 1998.

Caterpillar Inc. 2004. Caterpillar Performance Handbook, Ed. 35. Peoria, IL.

Crown Corporation. 2003. Plan of Operations for the Buckhorn Mountain Project. July 2003.

Crown Resources Corporation. 2004. Amended Plan of Operations for the Buckhorn Mountain
      Project. February 2004.

Golder Associates Inc. (Golder) 2006a. Buckhorn Mt. Project Aquatic Resources Mitigation Plan.
       Submitted to Kinross Gold USA, Inc. August 18, 2006.

Golder Associates Inc. (Golder) 2006b. Buckhorn Mt. Project Ecological and Aquatic Resources
       Monitoring Plan.

Golder Associates Inc. (Golder) 2007. Revised Operational Stormwater Pollution Prevention Plan
       Buckhorn Mountain Project Mine Site. Submitted to Kinross Gold USA, Inc. May 23, 2007.

Harder, David. 2005. Buckhorn Mountain Project: Cultural Resource Surveys in Okanogan and Ferry
        Counties. Plateau Investigation, Pullman, Washington.

Hughes, Bradley. 2005. Buckhorn Mine Infiltration Gallery. Ms. on file, Heritage Program Report
       R2005060803002, USDA Forest Service, Wenatchee, Washington.

Johansen, David K., Ronald Copstead, and Jeffry Moll. 1997. Relief Culverts. USDA Forest Service,
       Technology & Development Program Center, San Dimas, CA. 7 pages.

Morrison Maierle 2007. Technical Memorandum No. 5.7 – Conveyance Pipe and Infiltration Gallery,
       Kinross Gold Corporation Buckhorn Mountain Project Surface Improvements, Morrison
       Maierle, Inc. June 20, 2006.

Packer, Paul E. and George F. Christensen. 1964. Guides for Controlling Sediment from Secondary
        Logging Roads. USDA Forest Service Intermountain Forest and Range Experiment Station
        and Northern Region.

Primedia 2002. Rental Rate Blue Book for Construction Equipment, Volume 1. Equipment Watch,
       San Jose, CA.

RS Means 2003. Site Work and Landscaping Cost Data. 22nd Annual Edition.

RS Means 2005. Environmental Remediation Cost Data – Unit Price 2005. 11th Annual Edition. 2005.

RS Means 2006. Means Heavy Construction Cost Data. 20th Annual Edition. 2006



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September 2007                                                                                    -69-          043-2265

RS Means 2007. Means Heavy Construction Cost Data, 21st Edition

Telesto 2007. Buckhorn Mountain Haul Road Design Report. Prepared for Crown Resources
        Corporation, Telesto Solutions, Inc., January 2007, Fort Collins, CO.

USDOL (see US Department of Labor).

U.S. Department of Labor.       2006.      General Decision: WA070001 2/23/2007 WA1.
      http://www.wdol.gov/wdol/scafiles/archive/davisbacon/2007/wa1.r1 Accessed Feb 28, 2007.

U.S. Department of Agriculture, Forest Service (USFS). 1997. Final Environmental Impact
      Statement: Crown Jewel Mine, Okanogan County Washington, Volumes 1 through 4
      assembled by TerraMatrix for the USFS and the Washington State Department of Ecology.
      Tonasket, Washington: USDA Forest Service, Tonasket Ranger District.

U.S. Department of Agriculture, Forest Service (USFS). 2007. Final Environmental Impact
      Statement: Buckhorn Access Project. Tonasket Ranger District, Okanogan and Wenatchee
      National Forests.

U.S. Department of Interior, Fish and Wildlife Service (USFWS). 1990. Field Manual for the
       Investigation of Fish Kills (Resource Manual 177). Meyer, F. P. and L. E. Barclay, eds. 128
       pp.

US Forest Service. 2006. Cost Estimating Guide for Road Construction, Forest Service Northern
       Region Engineering, February 2006.

Virginia Tech 2006. Road Planning and Costing Guide. Industrial Forestry Operations Coop.
        http://www.cnr.vt.edu/ifo/iforesearch.htm.

Washington Department of Ecology (Ecology), 2005. Draft Supplemental Environmental Impact
      Statement for Buckhorn Mountain Project.




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                                                                                               FIGURES




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                                                                                             APPENDIX A

                                                                                FIRE PROTECTION PLAN




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                                                                                             APPENDIX B

                   SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN




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                                                                                             APPENDIX C

                                                HAUL ROAD DESIGN REPORT (TELESTO 2007)




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                                                                                             APPENDIX D

                                                             ROAD USE AND MAINTENANCE PLAN




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                                                                                             APPENDIX E

                                       HAZARDOUS MATERIALS TRANSPORTATION PLAN




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                                                                                             APPENDIX F

                                                                                     NOXIOUS WEED PLAN




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                                                                                             APPENDIX G

                                           STORM WATER POLLUTION PREVENTION PLAN




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                                                                                             APPENDIX H

                                                             MONITORING PLAN – NPDES PERMIT




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                                                                                              APPENDIX I

                                                                                            SURETY ESTIMATE




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                                                                                             APPENDIX J

                                             TECHNICAL MEMORANDUM NO. 5.7
                                        CONVEYANCE PIPE AND INFILTRATION GALLERY




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                                                                                            ATTACHMENT A

                                                            BUCKHORN MOUNTAIN CLAIMS MAP




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