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EXHIBIT 99
FILED:
�Qi&.¼ ERIE
i!lll7 COUNTY
-- CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020
#00013.353
DOC. NO. 309_
Volume 5 of 5
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Barretts Regal Mine
Non-Ore Rock Management Plan
Barretts Minerals, Inc.
Dillon, Montana
July 27, 2000
AUG O '3 2000
NIAXIM Technologies Inc ®
r• f
·-' · t, 201 South Wallace Street, Suite 83A
Bozeman, Montana 59715
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Barretts Minerals Regal Mine
Non-Ore Rock Management Plan
Figure 1-1. Air photo of Regal Mine Site (11 miles E of Dillon, Montana)
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Barretts Minerals Regal Mine
Non-Ore Rock Manag_ement Plan
Figure 1.2 Concep tual Overvie w of Regal Mine Operatio ns
Balld ls--M ne
Cal0El lld Owniew afOHa..lil •-=
NIAXt\1 Technologies Inc•
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Barretts Minerals Regal Mine
Non-Ore Rock Management Plan
2.0 Non-Ore Characteristics
tal impacts associated with
The objective of this plan is to manage potential environmen
A comprehensive program
non-ore rock that will be mined from the Regal deposit.
element geochemistry has
evaluating the geology, mineralogy, and sulfur and trace
has included review of available
been completed for the Regal ore deposit. This work
analyses including
data and published literature; geologic mapping; mineralogy
ling of all lithologies throughout
characterization of asbestiform mineralization; and samp
ty and potential for ARD
the deposit with geochemical analysis of trace metal mobili
with reference to more detailed
formation. The following is a brief overview of this work,
identified the need for this
documents that present the non-ore characterization that
management plan.
2.1 Geology and Mineralogy
orphic Cherry Creek
The Regal Mine talc ore body is hosted in the Archean metam
schist, and magnesium-rich
lithologic unit. This unit consists of metamorphic gneiss,
been metam orphosed and isoclinally
marbles (dolomites). The Cherry Creek unit has
north. Four primary rock types
folded, so that the talc beds strike NE-SW and dip to the
se intrus ives, and schist/gneiss.
occur in the deposit, talc, marble, amphibolite and diaba
e 2-1 ). These include Okuma,
Several geologic studies of the area are available (Figur
tion of the ore deposit is
1971; Berg, 1979; and Anderson et al, 1990. The forma
and their mineralogy are
reviewed by Maxim, 2000b. The primary lithologic units
described below.
2.1.1. Talc
to tabular veins along strike of
Tale occurs within dolomitic beds of this unit, as lenticular
ct between schist and
the hosting dolomitic marble. The talc occurs along the conta
alogy data collected through x-ray
gneisses of the footwall and overlying dolomite. Miner
, March 18, 1996) were
diffraction analysis of a set of ore samples (Tomaino memo
, and discussed further by
reviewed in the environmental geochemistry baseline report
magnesiohornblende and
Maxim (2000b) These results indicate that talc, chlorite,
trace occurrences of
dolomite (calcite) dominate the mineral assemblage, with
phlog opite, and biotite), and
pyrite/hematite, rutile/microcline, mica (muscovite,
als were identified.
graphite/quartz. No tremolite or other asbestiform miner
2.1.2. Dolomitic Marble
and ranging from 30 to several
Well layered marbles, primarily dolomitic in composition
. Texture is variable, with
hundred feet in thickness, occur in the Cherry Creek Group
e is not strongly recrystallized.
finer texture occurring in calcitic marbles and where marbl
red along local faults and
Metasomatic replacement of the marble at the Regal occur
magnesite, siderite, ankerite,
joints, producing a mineral assemblage that includes talc,
ite, chlorite, mica,
magnesiohornblende, apatite, calcite, pyrite, hematite, graph
serpentine, quartz, iron oxides, and rutile.
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Barretts Minerals Regal Mine
Non-Ore Rock Management Plan
2.1.3. Amphibolite and Diabase Intrusives
ally, a set of Archean
Two types of northwest trending mafic dikes are recognized region
et al, 1990). Three
amphibolites and a set of Paleozoic diabase dikes (Anderson
in the ore deposit.
ultramafic dikes cross cut the schist, gneiss, and talc that occur
appears to be an
(Barretts, 1997). In handspecimen, the largest of these dikes
interstitial feldspar.
amphibolite, primarily composed of pyroxene and hornblende with
r dikes appear to be
No quartz is evident in the amphibolite. In contrast, the two smalle
r, minor quartz , and trace calcite. No
diabase, composed of pyroxene with some feldspa
hornblende was observed in the diabase.
2. 1.4. Footwall Schist/Gneiss
muscovite-sillimanite
The footwall of the Regal ore deposit is a medium-grained biotite
se gneiss (Barre tts, 1997). The
mica schist and biotite quartzofeldspathic and schisto
in the south highwall.
rocks are strongly foliated and weathered where they occur
the ore deposit is
The proposed plan of operations for the Regal Mine indicates that
Non-ore rock will be
comprised of 10% ore, 75% dolomite, and 15% schist/gneiss.
re rock will be end-
composed of 83% dolomite and 17% schist and gneiss. Non-o
which is projec ted to stand 250 feet
dumped as valley/side hill fill in a single rock pile,
high and contain 120 million cubic feet of material.
2.2 Potentially Asbestiform Mineralization
n and describe the
Maxim Technologies visited the Regal Mine to map the locatio
amphibole)
geological occurrence of potentially asbestiform (serpentine and
work was initiate d to follow- up on the recent
mineralization in non-ore rock. This
minera lization in non-or e on a road in the Regal
identification of some fibrous serpentine
this minera lization was identified at the
pit (Maxim, 2000b). A narrow zone containing
itic marble in the northwest
contact between an ultramafic intrusive dike and dolom
and 2-2.
corner of the existing pit. This zone is shown in Figures 2-1
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Barrer,_ .v1inerals Regal Mine
Non-Ore RoIJk .ManfilJ..ement Plan
Figure 2-1 Regal Mine geologic map
D 1N40-5 • Sample Location w ith
2 .25% Percent Chrysotile
D1N40-4
0.0%
'.~~ f~~--
' - ' )' ,',I _: .' ;;;,,;-::::_
--·1 •/lr;;, • , .',, / r---
0}\ l(((l·~">1/~) l>·:-
tJJiJ_~•jf(;/r):fi_fl}
' /// (/') s- 1,,
111/~,Xff;:2
;:://;i/; / 1//1 •.' ,
:;1{?;fJ r:..~;~.: /1.1~ _/.· '-.,_ __
\S\~\ i,_, \ ~\·'
'/ / ) Sch tsV
,::>,:/ ~ ~ ~ j-~~'1i_
'/ _./ ·~·1~\'1 \;I
/.{fi1 1'1l iA '
01 NTP-6 -~;is);
0.25% tt4,#J .
~·.:.;11,;._.. U,;,.
01 NHW-3
1.0%
01NtJ-7 $~_t-fr•.~
0 .75 Yo _j,,/,//,1.
Diabase
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Barretts Minerals Regal Mine
Non-Ore Rock Manaqement Plan
Regal Mine - View Looki ng West at Dike
. ...
..:_~
.:_.7/.,.~ ..Ji(":./ -:-" _.,
Figure 2-2 Zone of PAR mineraliz ation Dike 1- Dolomitic Marble contact
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Barretts Minerals Regal Mine
Non-Or e Rock Manage ment Plan
The goals of the reconnaissance level field mapping were three-fold:
mineralization,
1. To map and describe the occurrence of serpentine and amphibole
al
particularly chrysotile, where previously identified, and to identify any addition
occurrences associated with the existing and ultimate pits
ally affected
2. To prepare an initial estimate of the volume of non-ore material potenti
to the total
by the presence of this asbestiform mineralization, and compare this
volume of anticipated non-ore production associated with pit expansion.
that will
3. To provide guidance for a more detailed sampling and analysis program
ing chrysot ile
permit a more accurate estimate of the volume of material contain
mineralization.
rock produced
The volume of PAR rock represents an estimated 0.3% of total non-ore
minera logic analyse s completed to
during life of mine, based on geologic mapping and
iform minera lization are
date. The geologic studies and analyses of potentially asbest
mapping of the
summarized in Appendix B. This work has included reconnaissance
contacts to the
entire Regal Mine pit, as well as mapping of the ultramafic dike-marble
north and south of the pit.
Dike 1 with the
Fibrous serpentine mineralization was only observed at the contact of
2 and 3, and in
dolomite (Figure 2-2). In all other portions of the pit, including Dikes
lization was the
areas mapped surrounding the pit (Figure 2-1), the serpentine minera
ed. No amphibole
non-fibrous form (lizardite) or no serpentine mineralization was observ
mineralization in
mineralization was identified in handspecimen. Samples of hornblende
for minera logic analysi s, to test for the
the amphibolite dike (Dike1) were also collected
d for minera logic analysis
presence of asbestiform amphiboles. Samples were collecte
s. Results of these
to verify these conclusions by PLM, TEM, and petrographic analysi
2-1.
analyses are presented in Appendix C and summarized below in Table
in a zone 35
Serpentine mineralization was identified as discontinuous veins and lenses
ed ultimate pit layback area. It was
feet wide on the east side of Dike 1 inside the propos
the east and west sides of
also identified in a zone approximately 20 feet wide on both
for approx imately
Dike 1, that extends along strike from the talc ore body to the north
2000 feet.
on one foot
In a second phase of mapping, detailed geologic descriptions were made
on the pit highwa ll that extend s
intervals along transects through a 100 foot zone
Photos 2-1 and 2-2. A series of
through the ultramafic dike-marble contact, as shown in
the expose d pit
horizontal bulk channel samples were collected at four depths in
d at seven
highwall within this study zone, and vertical channel samples were collecte
are shown in the
locations throughout the management zone. These sampling locations
s located to the
Photos 2-3, 2-4, and 2-5. Samples were also collected in three trenche
propos ed ultimat e pit layback area.
north along strike of the dike-marble contact, in the
location D1 NTP-6
These trenches are located between the pit highwall and sample
(Plate 1).
were also studied
Each of the samples studied for trace element and ARD geochemistry
the analyse s from the reconn aissanc e and
for PAR characteristics. Combined with
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Barretts Minerals Regal Mine
Non-Ore Rock Manage ment Plan
total of 71 PLM
detailed mapping studies, as well as samples collected by MT DEQ, a
analyses were completed as summarized in Table 2-1.
as rock with
Potentially Asbestiform Rock (PAR) is operationally defined in this study
ble above 0.25%, based on PLM
concentrations of asbestiform chrysotile detecta
ation using TEM.
analysis using EPA/600/R-93/116 methodology, with confirm
to the contact
The concentration of PAR rock varies depending upon location relative
much as 47% in
zone. The concentration of chrysotile varies from below detection to as
0.25% (below
a 6-inch wide zone at the contact. The PAR content drops to less than
e. The averag e over the mirieable unit
detection), 15 feet from the contact in the dolomit
from below detecti on to 1%,
that extends 20 feet to the east of the contact ranges
2-1 and Photos 2-1
depending upon vertical location in the highwall, as shown in Table
the South Trench
and 2-2. To the north of the highwall, no PAR rock was identified in
below detectio n
(Photo 2-3) or the Test Pit (Photo 2-4), but concentrations ranging from
also not
to 1.25% were measured in the North Trench (Photo 2-5). PAR rock was
units, as indicate d in Table 2-1.
present in the intrusive, talc, or schist rock
based on an
The overall content in the management zone is calculated to be 0.50%,
vertical and
average of all detected concentrations in bulk channel samples (both
was calculated
horizontal) in the highwall and to the north of the existing pit. This value
percent for each
using conventional spatial averaging techniques to determine a weight
were then weighte d to calcula te overall
of the five locations sampled. These averages
lization in the total tonnage
volume in the zone of interest. The average of PAR minera
of the overall non-
of non-ore is approximately one-thousandth of one percent (0.001 %)
during layback of
ore volume. This mineralization will be mined in several short phases
undistu rbed
the north highwall, between which the mineralization of concern will remain
mining in the manag ement zone will produc e
in the north highwall. Each phase of
that will be selectiv ely handle d,
approximately 7,200 tons of non-ore PAR rock,
riate dust control,
appropriately placed, and covered with non-PAR bearing rock. Approp
be implem ented.
respiratory protection, and health monitoring programs will also
non-ore, roughly
Maxim estimates that this material represents 28,800 tons of remaining
feet, over 4
0.17% of the remaining tonnage. This is based on a strike length of 150
If we project a compa rable thickne ss
benches in one 20 foot wide mineable unit.
, to accoun t for historic
through the existing pit south to the dolomite-talc contact
ically double this
production over a total distance of 300 feet of strike length, we theoret
imately 0.30%
estimate of total volume. The life of mine total of 56,600 tons is approx
Regal Mine.
percent of the non-ore volume to be mined over the life of mine of the
collected from
Additional studies involving detailed mineralogic analyses for samples
comple ted, to confirm minera logic
vicinity of the dolomite-Dike 1 contact were
on the petroge nesis of the
descriptions made in handspecimen and provide detail
an operati onal basis.
chrysotile mineralization to support future selective handling on
Results of this work are presented in Appendix D.
Mountains
The model for petrogenesis genesis of Archean talc deposits in the Ruby
d. This model,
proposed by Anderson et al. (1990) is widely referenced and well accepte
s 3 episodes of
which is summarized by Dr. Mogk in his report (Appendix D-3), identifie
event (M1) that
metamorphism including an initial regional amphibolite/granulite facies
a regiona l retrogr ade greenschist
was followed by serpentine mineral formation during
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Barretts Minerals Regal Mine
Non-Ore Rock Manage ment Plan
zation
facies metamorphic event (M2). A final event (M3) involved metasomatic dolomiti
all
of the marbles, followed by talcification of dolomitized marbles and in many cases,
earlier calc silicate minerals including serpentine. A later, more localized
to
serpentinization event may have followed talc formation, particularly in proximity
Regal mine are clearly associat ed
amphibolite dikes. The serpentine minerals at the
with the contact between the amphibolite dike and the marble, suggest ing that
serpentine formation at the Regal mine is likely post-M3.
ne
Petrographic results summarized in Appendix D-3 indicate multiple events of serpenti
e
mineral development. The association of fine grained carbonate, lizardite, and chrysotil
Mine is spatially controlle d by metasom atic
in the PAR manage ment zone at the Regal
lite
processes along a gradient (approximately 30 feet wide) proximal to the amphibo
limited by the rate of
dike. The degree to which serpentinization occurred was probably
serpentine mineral formation as it was constrained by availability of Mg and Si rich
the
water. The occurrence of lizardite in radial "bleb" structures in the marble near
via open-sp ace filling or volume replacem ent
Regal dike contact zone may have formed
that local fracturin g also played a
in these metasomatic reactions. It is clear in outcrop
e for metasom atic reaction s
role in making magnesium and silica rich solutions availabl
the formatio n of
to occur. Volume changes related to mineral replacement may explain
zation to grow
shrinkage cracks, which might have produced space for chrysotile minerali
ile
as cross-fibers along cracks and as rims of the observed lizardite blebs. Chrysot
obviously cross-cuts lizardite minerali zation in thin section. The relative timing of
chrysotile development in massive veins in the contact, in rims on blebs, and in
crosscutting veinlets is uncertain. Most of the chrysotile is texturally late in the
petrogenetic sequence, and it is possible that multiple fracturing events could have
produced numerous, discrete generations of serpentine veinlets.
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Barre ,v1inera/s Regal Mine
Non-Ore Rock Management Plan
Table 2-1 Regal Mine PLM Analyses of Asbestos Mineral Content
Lab# Location Type Rock % %
Sample# Date
Type Chrysotile Asbestos
archived Core Schist/Gneiss NA 0.0
BR02-R29-22 8-229 03/16/2000 2566091 BHPL
03/16/2000 2566082BHP L archived Core Dolomitic Marble NA 0.0
BR03-R26-20-21
03/16/2000 2566090BHP L archived Core Schist/Gneiss NA 0.0*~
BR04-R26-13 4-135
03/16/2000 25660928HP L archived Core Schist/Gneiss NA 0.0*~
BR05-R32-330-331
03/16/2000 2566077BHP L archived Core Dolomitic Marble NA 0.0
BR06-R32-118-121
03/16/2000 2566086BHP L archived Core Intrusive Dike NA 0.0
BR07-R33-13 4-135
03/16/2000 2566089BHP L archived Core Schist/Gneiss NA 0.0*
BR08-R33-28 5-286
03/16/2000 2566081 BHPL archived Core Dolomitic Marble NA 0.0
BR09-R 12-265-266
03/16/2000 2566079BHP L archived Core Dolomitic Marble NA 0.0
BR 10-R38-89-90
03/16/2000 2566085BHP L archived Core Intrusive Dike NA 0.0*
BR 11-R38-360-361
03/16/2000 2566083BHP L archived Core Dolomitic Marble NA 0.0
BR12-R38-17 0
archived Core Schist/Gneiss NA 0.0*
BR 13-R34-343-3 44 03/16/2000 2566093BHP L
03/16/2000 2566087BHP L archived Core Dolomitic Marble NA 0.0
BR14-R08-120-121
03/16/2000 2566094BHP L archived Core Dolomitic Marble NA 0.0
BR15-R21-39 -48
03/16/2000 2566078BHP L archived Core Schist/Gneiss NA 0.0*
BR16-R21-17 4-175
03/16/2000 2566080BHP L archived Core Dolomitic Marble NA 0.0**
BR17-R38-49 .5-50.5
03/16/2000 2566088BHP L archived Core Schist/Gneiss NA 0.0
BR 18-R43-483- 484
archived Core Talc NA 0.0
BR-19 R44 285-287 03/16/2000 2566509BHP L
archived Core Dolomitic Marble NA 0.0
BR1-R24-87- 89 03/16/2000 2566084BHP L
03/16/2000 2567997BHP L archived Core Talc NA 0.0
BR-20 R35 287-288
archived Core Talc NA 0.0
BR-21 R38 03/16/2000 2567998BHP L
03/16/2000 2567993BHP L archived Core Talc NA 0.0**
BR-22 R31
03/16/2000 2566510BHP L archived Core Talc NA 0.0
BR-23 R15
archived Core Talc NA 0.0
BR-24 R34 247-248 03/16/2000 2567994BHP L
archived Core Talc NA 0.0
BR-25 R29 240-241 03/16/2000 2567999BHP L
archived Core Talc NA 0.0
BR-26 R19 183-184 03/16/2000 2566512BHP L
highwall Grab Intrusive Dike NA 0.0*
BR-27 S6475 03/16/2000 2567996BHP L
highwall Grab Intrusive Dike NA 0.0*
BR-28 6475 N of BR-27 03/16/2000 2566513BHP L
highwall Grab Intrusive Dike NA 0.0
BR-29 6475 N OF BR-28 03/16/2000 2567996BHP L
03/16/2000 2566514BHP L highwall Grab Intrusive Dike NA 0.0*
BR-30 Upper Contact
hlghwall Grab Intrusive Dike NA 0.0*
BR-31 N 6475 03/16/2000 2566511 BHPL
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Ba,. ~ds Minerals Regal Mine
Non-Ore Rock Management Plan
Table 2-1 Regal Mine PLM Analyses of Asbestos Mineral Content (continue d)
Date Lab# Location Type Rock % %
Sample#
Type Chrysotile Asbestos
dike 3 contact Grab Dolomitic Marble 0.0 NA
D3NHW-1 06/30/2000 2573699BHPL
2573700BHPL dike 3 contact Grab Dolomitic Marble 0.0 NA
D3NHW-2 06/30/2000
35 E Dike 1 contact Upper Grab Dolomitic Marble 1.0 NA
D1NHW-3 06
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FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 EXHIBIT 99 FILED: �Qi&.¼ ERIE i!lll7 COUNTY -- CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 #00013.353 DOC. NO. 309_ Volume 5 of 5 NYSCEF RECEIVED NYSCEF: 03/17/2023 Barretts Regal Mine Non-Ore Rock Management Plan Barretts Minerals, Inc. Dillon, Montana July 27, 2000 AUG O '3 2000 NIAXIM Technologies Inc ® r• f ·-' · t, 201 South Wallace Street, Suite 83A Bozeman, Montana 59715 MDEQ - 002751 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002752 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002753 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002754 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002755 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002756 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002757 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002758 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002759 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002760 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002761 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002762 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002763 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002764 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002765 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002766 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 MDEQ - 002767 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Management Plan Figure 1-1. Air photo of Regal Mine Site (11 miles E of Dillon, Montana) Maxim Technologies, Inc. Barretts\report\norkmgmt2.doc 6 MDEQ - 002768 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Manag_ement Plan Figure 1.2 Concep tual Overvie w of Regal Mine Operatio ns Balld ls--M ne Cal0El lld Owniew afOHa..lil •-= NIAXt\1 Technologies Inc• Maxim Technologies, Inc. Barretts\report\norkmgmt2.doc 7 MDEQ - 002769 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Management Plan 2.0 Non-Ore Characteristics tal impacts associated with The objective of this plan is to manage potential environmen A comprehensive program non-ore rock that will be mined from the Regal deposit. element geochemistry has evaluating the geology, mineralogy, and sulfur and trace has included review of available been completed for the Regal ore deposit. This work analyses including data and published literature; geologic mapping; mineralogy ling of all lithologies throughout characterization of asbestiform mineralization; and samp ty and potential for ARD the deposit with geochemical analysis of trace metal mobili with reference to more detailed formation. The following is a brief overview of this work, identified the need for this documents that present the non-ore characterization that management plan. 2.1 Geology and Mineralogy orphic Cherry Creek The Regal Mine talc ore body is hosted in the Archean metam schist, and magnesium-rich lithologic unit. This unit consists of metamorphic gneiss, been metam orphosed and isoclinally marbles (dolomites). The Cherry Creek unit has north. Four primary rock types folded, so that the talc beds strike NE-SW and dip to the se intrus ives, and schist/gneiss. occur in the deposit, talc, marble, amphibolite and diaba e 2-1 ). These include Okuma, Several geologic studies of the area are available (Figur tion of the ore deposit is 1971; Berg, 1979; and Anderson et al, 1990. The forma and their mineralogy are reviewed by Maxim, 2000b. The primary lithologic units described below. 2.1.1. Talc to tabular veins along strike of Tale occurs within dolomitic beds of this unit, as lenticular ct between schist and the hosting dolomitic marble. The talc occurs along the conta alogy data collected through x-ray gneisses of the footwall and overlying dolomite. Miner , March 18, 1996) were diffraction analysis of a set of ore samples (Tomaino memo , and discussed further by reviewed in the environmental geochemistry baseline report magnesiohornblende and Maxim (2000b) These results indicate that talc, chlorite, trace occurrences of dolomite (calcite) dominate the mineral assemblage, with phlog opite, and biotite), and pyrite/hematite, rutile/microcline, mica (muscovite, als were identified. graphite/quartz. No tremolite or other asbestiform miner 2.1.2. Dolomitic Marble and ranging from 30 to several Well layered marbles, primarily dolomitic in composition . Texture is variable, with hundred feet in thickness, occur in the Cherry Creek Group e is not strongly recrystallized. finer texture occurring in calcitic marbles and where marbl red along local faults and Metasomatic replacement of the marble at the Regal occur magnesite, siderite, ankerite, joints, producing a mineral assemblage that includes talc, ite, chlorite, mica, magnesiohornblende, apatite, calcite, pyrite, hematite, graph serpentine, quartz, iron oxides, and rutile. Maxim Technologies, Inc. 8 Ba"etts\report\norkmgmt2.doc MDEQ - 002770 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Management Plan 2.1.3. Amphibolite and Diabase Intrusives ally, a set of Archean Two types of northwest trending mafic dikes are recognized region et al, 1990). Three amphibolites and a set of Paleozoic diabase dikes (Anderson in the ore deposit. ultramafic dikes cross cut the schist, gneiss, and talc that occur appears to be an (Barretts, 1997). In handspecimen, the largest of these dikes interstitial feldspar. amphibolite, primarily composed of pyroxene and hornblende with r dikes appear to be No quartz is evident in the amphibolite. In contrast, the two smalle r, minor quartz , and trace calcite. No diabase, composed of pyroxene with some feldspa hornblende was observed in the diabase. 2. 1.4. Footwall Schist/Gneiss muscovite-sillimanite The footwall of the Regal ore deposit is a medium-grained biotite se gneiss (Barre tts, 1997). The mica schist and biotite quartzofeldspathic and schisto in the south highwall. rocks are strongly foliated and weathered where they occur the ore deposit is The proposed plan of operations for the Regal Mine indicates that Non-ore rock will be comprised of 10% ore, 75% dolomite, and 15% schist/gneiss. re rock will be end- composed of 83% dolomite and 17% schist and gneiss. Non-o which is projec ted to stand 250 feet dumped as valley/side hill fill in a single rock pile, high and contain 120 million cubic feet of material. 2.2 Potentially Asbestiform Mineralization n and describe the Maxim Technologies visited the Regal Mine to map the locatio amphibole) geological occurrence of potentially asbestiform (serpentine and work was initiate d to follow- up on the recent mineralization in non-ore rock. This minera lization in non-or e on a road in the Regal identification of some fibrous serpentine this minera lization was identified at the pit (Maxim, 2000b). A narrow zone containing itic marble in the northwest contact between an ultramafic intrusive dike and dolom and 2-2. corner of the existing pit. This zone is shown in Figures 2-1 Maxim Technologies, Inc. 9 Barretts\report\norkmgmt2.doc MDEQ - 002771 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barrer,_ .v1inerals Regal Mine Non-Ore RoIJk .ManfilJ..ement Plan Figure 2-1 Regal Mine geologic map D 1N40-5 • Sample Location w ith 2 .25% Percent Chrysotile D1N40-4 0.0% '.~~ f~~-- ' - ' )' ,',I _: .' ;;;,,;-::::_ --·1 •/lr;;, • , .',, / r--- 0}\ l(((l·~">1/~) l>·:- tJJiJ_~•jf(;/r):fi_fl} ' /// (/') s- 1,, 111/~,Xff;:2 ;:://;i/; / 1//1 •.' , :;1{?;fJ r:..~;~.: /1.1~ _/.· '-.,_ __ \S\~\ i,_, \ ~\·' '/ / ) Sch tsV ,::>,:/ ~ ~ ~ j-~~'1i_ '/ _./ ·~·1~\'1 \;I /.{fi1 1'1l iA ' 01 NTP-6 -~;is); 0.25% tt4,#J . ~·.:.;11,;._.. U,;,. 01 NHW-3 1.0% 01NtJ-7 $~_t-fr•.~ 0 .75 Yo _j,,/,//,1. Diabase Maxim Technologies, Inc. Barretts\report\norkmgmt2.doc 10 MDEQ - 002772 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Manaqement Plan Regal Mine - View Looki ng West at Dike . ... ..:_~ .:_.7/.,.~ ..Ji(":./ -:-" _., Figure 2-2 Zone of PAR mineraliz ation Dike 1- Dolomitic Marble contact Maxim Technologies, Inc. Barretts\report\norkmgmt2.doc 11 MDEQ - 002773 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Or e Rock Manage ment Plan The goals of the reconnaissance level field mapping were three-fold: mineralization, 1. To map and describe the occurrence of serpentine and amphibole al particularly chrysotile, where previously identified, and to identify any addition occurrences associated with the existing and ultimate pits ally affected 2. To prepare an initial estimate of the volume of non-ore material potenti to the total by the presence of this asbestiform mineralization, and compare this volume of anticipated non-ore production associated with pit expansion. that will 3. To provide guidance for a more detailed sampling and analysis program ing chrysot ile permit a more accurate estimate of the volume of material contain mineralization. rock produced The volume of PAR rock represents an estimated 0.3% of total non-ore minera logic analyse s completed to during life of mine, based on geologic mapping and iform minera lization are date. The geologic studies and analyses of potentially asbest mapping of the summarized in Appendix B. This work has included reconnaissance contacts to the entire Regal Mine pit, as well as mapping of the ultramafic dike-marble north and south of the pit. Dike 1 with the Fibrous serpentine mineralization was only observed at the contact of 2 and 3, and in dolomite (Figure 2-2). In all other portions of the pit, including Dikes lization was the areas mapped surrounding the pit (Figure 2-1), the serpentine minera ed. No amphibole non-fibrous form (lizardite) or no serpentine mineralization was observ mineralization in mineralization was identified in handspecimen. Samples of hornblende for minera logic analysi s, to test for the the amphibolite dike (Dike1) were also collected d for minera logic analysis presence of asbestiform amphiboles. Samples were collecte s. Results of these to verify these conclusions by PLM, TEM, and petrographic analysi 2-1. analyses are presented in Appendix C and summarized below in Table in a zone 35 Serpentine mineralization was identified as discontinuous veins and lenses ed ultimate pit layback area. It was feet wide on the east side of Dike 1 inside the propos the east and west sides of also identified in a zone approximately 20 feet wide on both for approx imately Dike 1, that extends along strike from the talc ore body to the north 2000 feet. on one foot In a second phase of mapping, detailed geologic descriptions were made on the pit highwa ll that extend s intervals along transects through a 100 foot zone Photos 2-1 and 2-2. A series of through the ultramafic dike-marble contact, as shown in the expose d pit horizontal bulk channel samples were collected at four depths in d at seven highwall within this study zone, and vertical channel samples were collecte are shown in the locations throughout the management zone. These sampling locations s located to the Photos 2-3, 2-4, and 2-5. Samples were also collected in three trenche propos ed ultimat e pit layback area. north along strike of the dike-marble contact, in the location D1 NTP-6 These trenches are located between the pit highwall and sample (Plate 1). were also studied Each of the samples studied for trace element and ARD geochemistry the analyse s from the reconn aissanc e and for PAR characteristics. Combined with Maxim Technologies, Inc. 12 Barretts\report\norkmgmt1.doc MDEQ - 002774 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Manage ment Plan total of 71 PLM detailed mapping studies, as well as samples collected by MT DEQ, a analyses were completed as summarized in Table 2-1. as rock with Potentially Asbestiform Rock (PAR) is operationally defined in this study ble above 0.25%, based on PLM concentrations of asbestiform chrysotile detecta ation using TEM. analysis using EPA/600/R-93/116 methodology, with confirm to the contact The concentration of PAR rock varies depending upon location relative much as 47% in zone. The concentration of chrysotile varies from below detection to as 0.25% (below a 6-inch wide zone at the contact. The PAR content drops to less than e. The averag e over the mirieable unit detection), 15 feet from the contact in the dolomit from below detecti on to 1%, that extends 20 feet to the east of the contact ranges 2-1 and Photos 2-1 depending upon vertical location in the highwall, as shown in Table the South Trench and 2-2. To the north of the highwall, no PAR rock was identified in below detectio n (Photo 2-3) or the Test Pit (Photo 2-4), but concentrations ranging from also not to 1.25% were measured in the North Trench (Photo 2-5). PAR rock was units, as indicate d in Table 2-1. present in the intrusive, talc, or schist rock based on an The overall content in the management zone is calculated to be 0.50%, vertical and average of all detected concentrations in bulk channel samples (both was calculated horizontal) in the highwall and to the north of the existing pit. This value percent for each using conventional spatial averaging techniques to determine a weight were then weighte d to calcula te overall of the five locations sampled. These averages lization in the total tonnage volume in the zone of interest. The average of PAR minera of the overall non- of non-ore is approximately one-thousandth of one percent (0.001 %) during layback of ore volume. This mineralization will be mined in several short phases undistu rbed the north highwall, between which the mineralization of concern will remain mining in the manag ement zone will produc e in the north highwall. Each phase of that will be selectiv ely handle d, approximately 7,200 tons of non-ore PAR rock, riate dust control, appropriately placed, and covered with non-PAR bearing rock. Approp be implem ented. respiratory protection, and health monitoring programs will also non-ore, roughly Maxim estimates that this material represents 28,800 tons of remaining feet, over 4 0.17% of the remaining tonnage. This is based on a strike length of 150 If we project a compa rable thickne ss benches in one 20 foot wide mineable unit. , to accoun t for historic through the existing pit south to the dolomite-talc contact ically double this production over a total distance of 300 feet of strike length, we theoret imately 0.30% estimate of total volume. The life of mine total of 56,600 tons is approx Regal Mine. percent of the non-ore volume to be mined over the life of mine of the collected from Additional studies involving detailed mineralogic analyses for samples comple ted, to confirm minera logic vicinity of the dolomite-Dike 1 contact were on the petroge nesis of the descriptions made in handspecimen and provide detail an operati onal basis. chrysotile mineralization to support future selective handling on Results of this work are presented in Appendix D. Mountains The model for petrogenesis genesis of Archean talc deposits in the Ruby d. This model, proposed by Anderson et al. (1990) is widely referenced and well accepte s 3 episodes of which is summarized by Dr. Mogk in his report (Appendix D-3), identifie event (M1) that metamorphism including an initial regional amphibolite/granulite facies a regiona l retrogr ade greenschist was followed by serpentine mineral formation during Maxim Technologies, Inc. 13 Barretts\report\norkmgmt2.doc MDEQ - 002775 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barretts Minerals Regal Mine Non-Ore Rock Manage ment Plan zation facies metamorphic event (M2). A final event (M3) involved metasomatic dolomiti all of the marbles, followed by talcification of dolomitized marbles and in many cases, earlier calc silicate minerals including serpentine. A later, more localized to serpentinization event may have followed talc formation, particularly in proximity Regal mine are clearly associat ed amphibolite dikes. The serpentine minerals at the with the contact between the amphibolite dike and the marble, suggest ing that serpentine formation at the Regal mine is likely post-M3. ne Petrographic results summarized in Appendix D-3 indicate multiple events of serpenti e mineral development. The association of fine grained carbonate, lizardite, and chrysotil Mine is spatially controlle d by metasom atic in the PAR manage ment zone at the Regal lite processes along a gradient (approximately 30 feet wide) proximal to the amphibo limited by the rate of dike. The degree to which serpentinization occurred was probably serpentine mineral formation as it was constrained by availability of Mg and Si rich the water. The occurrence of lizardite in radial "bleb" structures in the marble near via open-sp ace filling or volume replacem ent Regal dike contact zone may have formed that local fracturin g also played a in these metasomatic reactions. It is clear in outcrop e for metasom atic reaction s role in making magnesium and silica rich solutions availabl the formatio n of to occur. Volume changes related to mineral replacement may explain zation to grow shrinkage cracks, which might have produced space for chrysotile minerali ile as cross-fibers along cracks and as rims of the observed lizardite blebs. Chrysot obviously cross-cuts lizardite minerali zation in thin section. The relative timing of chrysotile development in massive veins in the contact, in rims on blebs, and in crosscutting veinlets is uncertain. Most of the chrysotile is texturally late in the petrogenetic sequence, and it is possible that multiple fracturing events could have produced numerous, discrete generations of serpentine veinlets. Maxim Technologies, Inc. Barretts\report\norkmgmt2.doc 14 MDEQ - 002776 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Barre ,v1inera/s Regal Mine Non-Ore Rock Management Plan Table 2-1 Regal Mine PLM Analyses of Asbestos Mineral Content Lab# Location Type Rock % % Sample# Date Type Chrysotile Asbestos archived Core Schist/Gneiss NA 0.0 BR02-R29-22 8-229 03/16/2000 2566091 BHPL 03/16/2000 2566082BHP L archived Core Dolomitic Marble NA 0.0 BR03-R26-20-21 03/16/2000 2566090BHP L archived Core Schist/Gneiss NA 0.0*~ BR04-R26-13 4-135 03/16/2000 25660928HP L archived Core Schist/Gneiss NA 0.0*~ BR05-R32-330-331 03/16/2000 2566077BHP L archived Core Dolomitic Marble NA 0.0 BR06-R32-118-121 03/16/2000 2566086BHP L archived Core Intrusive Dike NA 0.0 BR07-R33-13 4-135 03/16/2000 2566089BHP L archived Core Schist/Gneiss NA 0.0* BR08-R33-28 5-286 03/16/2000 2566081 BHPL archived Core Dolomitic Marble NA 0.0 BR09-R 12-265-266 03/16/2000 2566079BHP L archived Core Dolomitic Marble NA 0.0 BR 10-R38-89-90 03/16/2000 2566085BHP L archived Core Intrusive Dike NA 0.0* BR 11-R38-360-361 03/16/2000 2566083BHP L archived Core Dolomitic Marble NA 0.0 BR12-R38-17 0 archived Core Schist/Gneiss NA 0.0* BR 13-R34-343-3 44 03/16/2000 2566093BHP L 03/16/2000 2566087BHP L archived Core Dolomitic Marble NA 0.0 BR14-R08-120-121 03/16/2000 2566094BHP L archived Core Dolomitic Marble NA 0.0 BR15-R21-39 -48 03/16/2000 2566078BHP L archived Core Schist/Gneiss NA 0.0* BR16-R21-17 4-175 03/16/2000 2566080BHP L archived Core Dolomitic Marble NA 0.0** BR17-R38-49 .5-50.5 03/16/2000 2566088BHP L archived Core Schist/Gneiss NA 0.0 BR 18-R43-483- 484 archived Core Talc NA 0.0 BR-19 R44 285-287 03/16/2000 2566509BHP L archived Core Dolomitic Marble NA 0.0 BR1-R24-87- 89 03/16/2000 2566084BHP L 03/16/2000 2567997BHP L archived Core Talc NA 0.0 BR-20 R35 287-288 archived Core Talc NA 0.0 BR-21 R38 03/16/2000 2567998BHP L 03/16/2000 2567993BHP L archived Core Talc NA 0.0** BR-22 R31 03/16/2000 2566510BHP L archived Core Talc NA 0.0 BR-23 R15 archived Core Talc NA 0.0 BR-24 R34 247-248 03/16/2000 2567994BHP L archived Core Talc NA 0.0 BR-25 R29 240-241 03/16/2000 2567999BHP L archived Core Talc NA 0.0 BR-26 R19 183-184 03/16/2000 2566512BHP L highwall Grab Intrusive Dike NA 0.0* BR-27 S6475 03/16/2000 2567996BHP L highwall Grab Intrusive Dike NA 0.0* BR-28 6475 N of BR-27 03/16/2000 2566513BHP L highwall Grab Intrusive Dike NA 0.0 BR-29 6475 N OF BR-28 03/16/2000 2567996BHP L 03/16/2000 2566514BHP L highwall Grab Intrusive Dike NA 0.0* BR-30 Upper Contact hlghwall Grab Intrusive Dike NA 0.0* BR-31 N 6475 03/16/2000 2566511 BHPL Maxim Technologies, Inc. Barretts\report\norkmgmt2. doc 15 MDEQ - 002777 FILED: ERIE COUNTY CLERK 03/17/2023 09:06 PM INDEX NO. 815818/2020 NYSCEF DOC. NO. 309 RECEIVED NYSCEF: 03/17/2023 Ba,. ~ds Minerals Regal Mine Non-Ore Rock Management Plan Table 2-1 Regal Mine PLM Analyses of Asbestos Mineral Content (continue d) Date Lab# Location Type Rock % % Sample# Type Chrysotile Asbestos dike 3 contact Grab Dolomitic Marble 0.0 NA D3NHW-1 06/30/2000 2573699BHPL 2573700BHPL dike 3 contact Grab Dolomitic Marble 0.0 NA D3NHW-2 06/30/2000 35 E Dike 1 contact Upper Grab Dolomitic Marble 1.0 NA D1NHW-3 06