Michael A. Malusis, Ph.D., P.E.

Consulting Geotechnical and Geoenvironmental Engineer

(570) 412-2069

15 Hawthorne Drive Lewisburg, PA 17837 Fax (570) 577-3415

February 5, 2014

Ms. Kathryn Hoffman Staff Attorney Minnesota Center for Environmental Advocacy 26 East Exchange Street, Suite 206 Saint Paul, MN 55101 Subject: Containment system assessment report, Supplemental Draft Environmental Impact Statement (SDEIS), NorthMet Mining Project and Land Exchange Dear Ms. Hoffman: I am pleased to provide the following assessment to the Minnesota Center for Environmental Advocacy (MCEA) regarding the technical viability of the tailings and waste rock containment systems proposed by PolyMet Mining Inc. for a new copper-nickel mine in northeastern Minnesota (the NorthMet Project). This assessment was conducted in accordance with the scope of work identified in my proposal to MCEA dated November 19, 2013, which included the following tasks: 1. Review and evaluation of the design and implementation of bentonite amendments to the beaches, embankment faces, and bottom of the tailings basin; 2. Review and evaluation of the design and efficacy of the ground water containment system for the tailings basin (in terms of seepage rates through or under the embankments); 3. Review and evaluation of the design, timing of implementation, and efficacy of the groundwater containment system and cover for the Category 1 waste rock stockpile; 4. Review and evaluation of the design and efficacy of the geosynthetic double liner system at the hydrometallurgical residue facility; 5. Review and evaluation of the assumptions, inputs, and calibration of models used to calculate seepage rates through the embankments and/or liner systems of the tailings basin, the Category 1 stockpile, and the hydrometallurgical residue facility; and 6. Preparation of an expert opinion report and submission of this report to MCEA by January 31, 2014 Authorization to execute this work was provided to me in an e-mail from Ms. Jill Bathke of MCEA, dated December 6, 2013. 1

Final Assessment Report NorthMet Project SDEIS Review 1. INTRODUCTION

Michael A. Malusis January 28, 2014

My assessment report, presented herein, has been developed based upon my review and interpretation of relevant NorthMet Project documents provided by MCEA. Specifically, I reviewed relevant sections of the following project documents during this assessment: Supplemental Draft Environmental Impact Statement (SDEIS), NorthMet Mining Project and Land Exchange, Prepared by Minnesota Department of Natural Resources, U.S. Army Corps of Engineers, and U.S. Forest Service, November 2013; Mine Plan (Version 2, December 2012); Rock and Overburden Management Plan (Version 5, December 2012); Water Management Plan Plant (Version 2, February 2013); Adaptive Water Management Plan (Version 5, March 2013); Flotation Tailings Management Plan (Version 3, April 2013); Residue Management Plan (Version 2, December 2012); Geotechnical Data Package Volume 1 (v4, April 12, 2013); Geotechnical Data Package Volume 2 (v3, October 12, 2012); Geotechnical Data Package Volume 3 (v2, May 29, 2012); Water Modeling Data Package Volume 1 - Mine Site (Version 12, March 2013) Flotation Tailings Basin Slope Stability Impacts memo (April 19, 2013); Project Description (Version 4, October 2012);

My comments to the Co-Lead Agencies regarding the efficacy of the various containment systems proposed for this project are presented below. The comments are divided into five sections (i.e., Sections 2 through 6), with each section pertaining to a different containment system, as follows: the Category I Stockpile groundwater containment system and cover (Section 2); the Flotation Tailings Basin groundwater containment system (Section 3); the Flotation Tailings Basin bentonite-amended layers (Section 4); the Hydrometallurgical Residue Facility liner and cover systems (Section 4); Category 2/3 and Category 4 Stockpile liner systems (Section 6). Comments pertaining to assumptions, inputs, and calibration of the seepage models (Task #5 in the scope of work) are not listed in a separate section, but rather are contained in the appropriate section for the particular containment system being modeled.

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The comments in Sections 2 through 6 contain citations to the project documents listed above, where appropriate, as well as citations to relevant literature sources used to support my observations and recommendations. All documents cited in the text are cited by number and listed by citation number in Section 7 (References), with the exception of the SDEIS, which is simply referred to in the text as the SDEIS. It should be noted that my assessment is focused on the geotechnical and geoenvironmental aspects of the containment systems proposed for this project and is based solely on my review of the project documents listed above. I did not perform any independent geotechnical, hydraulic/hydrologic, or contaminant transport calculations or modeling as part of my work.

2.

Category I Waste Rock Stockpile: Groundwater Containment System and Cover

Most of the Category 1 waste rock generated during the mining activities will be placed in a permanent stockpile that will be capped in place and surrounded by a groundwater containment system consisting of a circumferential (fully encircling) cutoff wall and a drainage collection system. As is noted in (1), in-situ containment systems consisting of a circumferential cutoff wall, groundwater collection system and overlying cover system are commonly employed for long-term in-situ containment around waste disposal facilities and contaminated source areas. However, based on my review of the SDEIS and (1), I have several concerns with the plans described for this particular system. My comments are as follows: 1. No commitments are made regarding the nature of the soil materials that will comprise the wall, and no details are provided regarding the proposed construction method, other than that the soil material will be compacted. Likewise, it is unclear whether or not a geosynthetic barrier will be used in the wall and, if so, what type of geosynthetic barrier will be used and whether or not the geosynthetic barrier will be used in conjunction with soil (i.e., a composite barrier). The absence of such commitments and details is problematic, as the options proposed are not commonly employed for long-term containment of contaminated groundwater and do not have a strong track record of success in these applications. The materials and construction method need to be specified and thoroughly described. 2. Regarding the type of geosynthetic barrier that could be installed in the cutoff wall, the phrase "geosynthetic clay barrier" is used in the SDEIS, implying that this barrier would be a geosynthetic clay liner (GCL) rather than a conventional geomembrane. However, there is no readily available evidence in the literature indicating that geosynthetic barriers other than geomembranes have been used in vertical barriers. Also, research indicates that walls containing a geomembrane alone (as opposed to a composite wall containing a geomembrane and a low-permeability, soil-bentonite backfill) are not likely to be effective for controlling underseepage, even if the geomembrane is placed in direct contact with the confining unit at the bottom of the aquifer (2). 3. The vast majority of vertical barriers employed in the U.S. for long-term geoenvironmental containment are soil-bentonite slurry walls, or cutoff walls that are constructed using the

Final Assessment Report NorthMet Project SDEIS Review

Michael A. Malusis January 28, 2014

slurry trench method and contain backfill comprised of native soil admixed with bentonite. This point is underscored by the very references and case studies cited by PolyMet in Attachment D of (1), and by the fact that a soil-bentonite slurry wall is proposed for the containment system around the tailings basin. In fact, it does not appear that any of the sites identified in Attachment D utilized a compacted soil cutoff wall or a soil-based wall with no bentonite, although a full review of the case studies in Table 1 was not possible from the references provided (i.e., the web links provided for the project descriptions were broken, or the project descriptions were no longer available on the company websites). Compelling evidence needs to be provided that demonstrates the viability of a compacted soil or geosynthetic wall in lieu of the widely used and well proven soil-bentonite slurry trench method. This demonstration should include valid references/web links to relevant case studies and must address the following construction issues: (a) how trench stability will be maintained during construction; (b) how the soil material will be processed and placed to ensure that the wall is homogeneous, meets the design hydraulic conductivity, and is free of high-permeability defects; and (c) how the geosynthetic barrier (presumably a geomembrane), if used, would be installed to ensure the integrity of the panels/interlocks and adequate control of underseepage. 4. The maximum allowable hydraulic conductivity of 10-5 cm/s for the cutoff wall is 10 to 100 times higher than the typical hydraulic conductivity requirement for vertical barriers used in long-term hydraulic control or geoenvironmental containment applications (10-6 to 10-7 cm/s; e.g., see (3) through (6)). If constructed at 10-5 cm/s, the wall likely would be ineffective as a long-term barrier unless a sufficient inward head difference is maintained continuously to prevent outward advective transport and adequately reduce outward diffusive flux of miscible contaminants in the groundwater. However, there does not appear to be a commitment to maintaining a particular minimum gradient at all locations along the wall, and the cross-sectional schematics (e.g., Figure 7.1 in (1)) indicate that an inward gradient will not be maintained on the south side of the stockpile adjacent to the West Pit. The model simulations also do not appear to consider the possibility that the efficiency of the groundwater collection system could be diminished over time (e.g., due to clogging of the drainage medium caused by biological activity or chemical precipitation). PolyMet should commit to maintaining a particular magnitude of inward gradient or head difference across the wall, to ensure that the containment system functions as intended based on consideration of both advection and diffusion as viable transport mechanisms for contaminants leached from the waste rock. In addition, a soil-bentonite slurry wall, with a maximum hydraulic conductivity no greater than 10-6 cm/s, should be employed for this containment system (as appears to be the case for the vertical barrier to be employed around the tailings basin). A maximum hydraulic conductivity of 10-6 cm/s is a reasonable design criterion for a soil-bentonite backfill, as backfill hydraulic conductivities of 10-6 to 10-8 cm/s are easily achievable for a wide range of native soil compositions. 5. The groundwater modeling assumes that no groundwater from outside the containment area will be captured by the containment system (7). However, there is no indication in the text of

Final Assessment Report NorthMet Project SDEIS Review

Michael A. Malusis January 28, 2014

the SDEIS or other project documents that the wall will be keyed into the underlying bedrock. Likewise, schematics showing the conceptual cross section of the containment system (i.e., Figures 3.2-11 and 3.2-16 in the SDEIS and Figure 7.1 in (1)) indicate that the wall will not be keyed into the bedrock, but rather will terminate at the top of the bedrock. The key is one of the most important aspects of cutoff wall design, and specifications generally call for a minimum depth of key (typically 3 ft, or deeper in fractured bedrock) into the lower confining bed to ensure an adequate seal that minimizes underseepage (e.g., see (8, 9)). Without a proper key, significant underseepage could occur, either into the containment area or out of the containment area (i.e., at locations where an inward gradient is not maintained). The text and schematics should be revised to reflect an appropriate minimum depth of the key into the bedrock. 6. Although the minimum required thickness of the cutoff wall is not explicitly stated in the text of the SDEIS, the groundwater flow model assumes a wall thickness of five feet. Therefore, the thickness of the constructed wall should be at least five feet. Please confirm. 7. According to the Adaptive Water Management Plan (10), a minimum surface slope of 1.0 % is proposed for the final cover system. The justification provided for such a flat slope is insufficient. Although minimal settlement of the waste rock may be expected, constructability also needs to be considered. The surface slope must be sufficient to promote runoff and minimize ponding of water on the cover surface, thereby minimizing infiltration. It is unlikely that a loosely compacted vegetation layer can be sloped uniformly at 1 % without creating areas where ponding will occur. Indeed, solid waste landfill covers typically are designed to have a minimum inclination of 2 to 5 %, after accounting for settlement (emphasis added), to promote runoff and minimize ponding (11). Based on this consideration, the minimum cover slope should be at least 2 %. Also, monitoring and maintenance provisions should be included in the closure plan to repair localized areas of grade reversal or subsidence.

3.

Tailings Basin: Groundwater Containment System

According to the SDEIS and supporting project documents, a seepage containment system will be installed around the northern and western sides of the LTVSMC tailings basin. The SDEIS states that the system "would be similar to the Category 1 Stockpile groundwater containment system". Although this proposed system is similar to the Category 1 Stockpile groundwater containment system in that this system also will consist of a cutoff wall and upgradient groundwater collection system, it is noted that a soil-bentonite slurry wall with a maximum hydraulic conductivity of 10-6 cm/s is proposed for this system (12), as opposed to a compacted soil barrier or geosynthetic barrier. The following are my comments pertaining to this system: 8. As was also mentioned for the Category 1 Stockpile vertical barrier, PolyMet should commit to (a) maintaining a particular magnitude of inward gradient or head difference across the wall, to ensure that the containment system functions as intended based on consideration of both advection and diffusion as viable transport mechanisms for contaminants released from

Final Assessment Report NorthMet Project SDEIS Review

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the tailings, and (b) establishing a minimum depth of the key into the underlying bedrock. Regarding the latter, there is a mention in the SDEIS that the wall will be keyed into bedrock, but the minimum depth of the key is not specified. Also, schematics in the SDEIS and (12) indicate that the wall will be constructed to the top of the bedrock, but will not penetrate into the bedrock. 9. According to Attachment C of (12), a thickness of one foot was specified for the slurry wall in the groundwater flow model simulations. While a thickness of one foot is conservative from a modeling standpoint, a wall this thin will be too difficult to construct and backfill properly (13). Also, the unit cost of slurry wall installation is typically given on a per-area basis (i.e., where area is defined as the product of the length and depth of the wall), assuming a standard width of 2.5-3 ft based on the standard width of conventional trenching equipment (14). Thus, in addition to being imprudent from a technical standpoint, construction of a 1-ftthick wall likely would not result in significant cost savings relative to a 3-ft-thick wall. As such, a wall thickness of three feet is highly recommended, which would be consistent with conventional practice and provide a factor of safety from a groundwater flow perspective.

4.

Tailings Basin: Bentonite-Amended Layers

According to the SDEIS and supporting documents (10, 15), PolyMet proposes to cover the outer faces of the tailings dam embankments with a two-layer cover system consisting of a bentoniteamended soil layer followed by a vegetated soil layer. Also, PolyMet would place a similar twolayer cover (i.e., a bentonite-amended layer followed by tailings) on top of the tailings beaches after operations end in year 20. In both cases, the bentonite-amended layer apparently will be created by mixing dry granular bentonite (~3 % by dry weight) with tailings to reduce infiltration and create an oxygen barrier that reduces the potential for oxidation of sulfide minerals in the tailings. Finally, PolyMet proposes to cover the tailings basin pond bottom with a bentonite layer to maintain a permanent pond that would limit oxygen diffusion. Based on my review of the SDEIS and (10, 15), I have several concerns regarding the efficacy of these bentonite layers in both the short and long terms. My comments are as follows: 10. There appear to be inconsistencies between the SDEIS and (15) regarding the thickness and embedded depth of the bentonite-amended layers to be installed on the dam raises. According to page 5-162 of the SDEIS, PolyMet proposes to cover the embankments with a 12-inch-thick bentonite-amended soil layer, followed by an 18-inch-thick vegetated soil cover. However, page 33 of (15) states that the bentonite-amended layer will be 18 inches thick and overlain by a 30-inch vegetated layer. These differences need to be resolved. 11. The design criteria for the bentonite-amended layers need to be defined. For example, what design hydraulic conductivity and moisture retention characteristics will be required for these layers to function effectively as oxygen and water infiltration barriers? 12. The likelihood that a uniform barrier with low hydraulic conductivity could be created by amending predominantly coarse tailings with only 3 % granular bentonite is small, as many

Final Assessment Report NorthMet Project SDEIS Review

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of the flow paths within the barrier will likely be devoid of bentonite. For example, research by Abichou et al. (16) indicates that a granular bentonite content of at least 8 % may be necessary in a compacted sand-bentonite mixture to ensure that most or all of the inter-sand voids are filled with bentonite. Bench-scale tests need to be performed using materials with gradations representative of those anticipated for the bentonite-amended layers to determine the percentage of bentonite required to meet the relevant design criteria (see Comment 11 above). 13. On page 5-162 of the SDEIS, the text states that the objective of the two-layer cover systems is to maintain the bentonite-amended layer at or above 90 percent saturation so that the layer would operate as an effective oxygen barrier. However, no evidence is presented in (15) to show that a saturation 90 % would be maintained in this layer over the long term. Unsaturated flow modeling is needed to evaluate the potential for changes in saturation of the bentonite-amended layers over time. 14. In addition to evaluating the potential for loss of saturation, PolyMet needs to address the potential for the hydraulic and moisture retention properties of the bentonite-amended soil layers to change over time due to development of soil structure caused by wet-dry cycling and other pedogenic processes, most notably freeze-thaw cycling and plant root penetration. Root penetration likely will occur after some period of time, and there is no evidence provided to support the suggestion by PolyMet in (15) that adding 3 % granular bentonite will provide adequate protection against root penetration. Likewise, there is no evidence provided to indicate that an 18-inch (or even 30-inch) vegetated layer will provide adequate protection against freeze-thaw cycling. These processes create macropores (i.e., large scale features such as cracks and fissures) that alter the network of pores controlling retention and movement of water (and air) in barrier layers. These types of problems are well documented in a recent, peer-reviewed study Benson et al. (17), which investigated changes in the field properties of 27 different earthen and composite cover systems installed at 12 locations in eight states across the US. The results showed that changes in hydraulic properties occurred in all 27 covers after 4-9 years in service due to the formation of soil structure, regardless of climate (arid, semi-arid, or humid), cover design (e.g., the embedment depth of the barrier layer, the presence/absence of geosynthetic layers, etc.), or service life. Benson et al. (17) also observed that these changes tended to be greater in barriers exhibiting higher plasticity due to the presence of active clay minerals such as montmorillonite (i.e., the active ingredient in bentonite). 15. What field performance benchmarks and associated monitoring methods will be employed to demonstrate that the bentonite-amended layers function as intended over time? 16. Three possible methods are proposed for creating a bentonite seal at the bottom of the tailings pond, viz. (1) subaqueous broadcasting of bentonite pellets or bentonite-coated sand; (2) in-situ mixing (with bentonite injection) from a barge; and (3) subaqueous placement of a GCL. With the possible exception of subaqueous GCL placement, which has been employed in a few projects to cover contaminated sediments, these proposed options are, at best, experimental. Although it is noted that PolyMet proposes a field demonstration to prove the

Final Assessment Report NorthMet Project SDEIS Review

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efficacy of the chosen method, case-study evidence should be provided to indicate that these methods (particularly the broadcasting and in-situ mixing methods) have been implemented successfully on similar projects. In addition, PolyMet should explain why alternatives that involve draining the pond prior to installation of the bottom seal are not being considered as potentially more prudent options relative to the subaqueous installation methods. 17. The GCL hydraulic conductivity reported by the manufacturer should not be assumed to be representative of the field hydraulic conductivity. If a GCL is to be placed on the tailings pond bottom, the selected GCL should be subjected to laboratory testing (ASTM D6766) with the pond water to determine the expected hydraulic conductivity in the field. Likewise, the hydraulic conductivity of a broadcast bentonite layer or in-situ mixed bentonite layer to the pond water should be verified by laboratory or field testing.

5.

Hydrometallurgical Residue Facility: Liner and Cover Systems

The Hydrometallurgical Residue Facility (HRF) is to be constructed over a subgrade of highly compressible tailings and peat in the existing LTVSMC emergency basin area. Preloading and combined vertical/radial consolidation (with wick drains) is proposed to consolidate the subgrade materials prior to construction and waste placement, to mitigate future strains in the liner system components. The proposed double liner system for the facility would be an entirely geosynthetic system containing the following components (from top to bottom): (1) an upper geomembrane; (2) a geocomposite drainage net (for leak detection); (3) a lower geomembrane; and (4) a geosynthetic clay liner (GCL). Prior to closure, the residue would be covered with a temporary cover, dewatered, and consolidated prior to placement of a final cover system. Gradefill (LTVSMC tailings) would be placed above the consolidated residue to create a gently sloping surface that would serve as the subgrade for a composite final cover consisting of a GCL and geomembrane, overlain by a 4-ft vegetated layer of LTVSMC tailings. The following are my comments regarding the proposed liner and cover systems for this facility: 18. The values of compression index (C c ) and swell index (C s ) for the LTVSMC tailings, peat, and residue that were used to determine the analogous parameters and for the MCC model do not appear to have been reported in the SDEIS or the relevant data package (18). Please report these values along with the calculations producing the values of and for these materials as given in Table 4.2 of (18). The values = 0.05 and = 0.01 seem too low for fine tailings and slimes. 19. According to the SDEIS and (18), the settlement analysis for the subgrade yielded a maximum strain of 0.20 % in the liner system. However, the LTVSMC tailings appear to have been modeled in the settlement analysis as homogeneous, with a single value of and used in the analysis for the tailings and slimes. The assumption of homogeneity needs to be further justified. While this assumption may yield conservative estimates of total settlement, it is not clear that this approach would yield conservative values of differential settlement and strain in the geosynthetic layers. Consolidation test results for the LTVSMC tailings do not appear to have been included in (18). How many consolidation tests have been performed on

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the tailings/slimes? Have multiple consolidation tests been performed on samples collected at various locations and depths within the footprint of the proposed disposal facility? If so, how much variability in the compressibility parameters is evident? Have any analyses been performed to demonstrate that material variability in the tailings does not lead to greater differential settlement and strain in the liner? 20. The potential for spreading and separation of the GCL panel overlaps due to the anticipated settlement of the subgrade and elongation of the liner needs to be addressed in the geotechnical analysis. 21. The computed factors of safety presented in the SDEIS for slope stability along the interfaces of the various liner system components for the HRF (Table 5.2.14-5, page 5-576) are based on values of interface friction angle reported in the literature. Citations and references for the sources in which these values are reported should be provided. Also, although PolyMet proposes project-specific interface shear testing if the anticipated material types change, geosynthetic-geosynthetic and geosynthetic-soil interface friction angles vary among different geosynthetic products of the same type. Site-specific and material specific tests should be performed for final design (see (19)). 22. A slope "on the order of 1.0 percent" is proposed for the top of the cover system (20). As mentioned previously for the Category 1 waste rock stockpile cover (see Comment 5 above), landfill covers typically are designed to have a minimum inclination of 2 to 5 %, after accounting for settlement, to minimize ponding while also promoting runoff and minimizing erosion (11). A minimum cover slope of least 2 %, after accounting for residue settlement caused by placement of the gradefill and cover, is recommended. 23. The liner leakage calculations assume a defect frequency of 2.5 defects per acre. However, field evidence indicates that liner leakage predictions assuming such low frequencies of defects are lower bound estimates that may significantly underestimate the actual leakage unless strict construction quality assurance (CQA) procedures are followed during installation to prevent and detect/repair defects and minimize wrinkles in the geomembrane (see (21)). Regarding the latter, wrinkles are a common problem in geomembrane installations and exacerbate the leakage through composite liners. Simplified model predictions that do not account for wrinkles have been shown to be inconsistent with (i.e., lower than) the observed leakage in case studies involving composite (geomembranecompacted clay or geomembrane-GCL) liners (22). PolyMet should commit to employing a rigorous CQA program that includes continuous observation during installation, nondestructive testing of all seams, periodic collection and testing of seam samples for shear and peel strength, and elimination of wrinkles. 24. In addition to the routine CQA practices described in Comment 23 above, electrical leak detection should be considered as part of the CQA program for the geomembrane installations. Electrical leak detection is becoming more commonplace as a CQA tool for geomembranes, as this technique provides greater confidence in the quality of the

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installation. As noted in (21), defects detected in electrical surveys are typically exposed and repaired, such that the post-installation defect frequency is reduced to a minimal value. 6. Category 2/3 and Category 4 Stockpiles: Liner Systems

Composite liner systems are proposed for the Category 2/3 and Category 4 stockpiles. These stockpiles, although temporary, will still require effective containment (via underlying liner systems) for more than a decade to mitigate potential impacts associated with contaminated water released from the waste rock. The following are my comments on the efficacy of the proposed liner systems for these stockpiles: 25. For the same reasons as described in Comment 23 above, PolyMet should commit to employing a rigorous CQA program for geomembrane installation that includes continuous observation during installation, nondestructive testing of all seams, periodic collection and testing of seam samples for shear and peel strength, elimination of wrinkles, and possibly electrical leak detection (highly recommended; see Comment 24). Otherwise, the predicted leakage rates, which are based on a 90th percentile frequency of only 4 defects per acre, may grossly underestimate the true leakage through the liners. 26. There do not appear to be any provisions in the liner design to protect against puncture of the geomembrane in the liner system. Will any restrictions be imposed on the maximum size and angularity of the drainage layer material (proposed to be crushed rock or gravel) or soil liner material? Such restrictions should be considered, along with installation of a cushion geotextile between the geomembrane and drainage layer, to minimize the potential for defects created after the geomembrane is covered (which would not be detected, and therefore would not be repaired). 27. Although PolyMet is correct that the composite liner systems proposed for these stockpiles are similar to those used for modern heap leach facilities, a maximum hydraulic conductivity of 10-6 cm/s is generally recommended for the compacted soil component of heap leach pad liners (e.g., see (23)). While this is indeed the case for the Category 4 stockpile, a maximum hydraulic conductivity of 10-5 cm/s is prescribed for the Category 2/3 stockpile liner. This difference in the two designs seems arbitrary and is not well justified.

7. (1)

References PolyMet (2012). NorthMet Project Rock and Overburden Management Plan, Version 5, December 28. Lee, T. and Benson, C.H. (2000). Flow past bench-scale vertical ground-water cutoff walls. Journal of Geotechnical and Geoenvironmental Engineering, ASCE, 126(6), 511520.

(2)

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Final Assessment Report NorthMet Project SDEIS Review (3)

Michael A. Malusis January 28, 2014

Owaidat and Day (1998). Installation of a composite slurry wall to contain mine tailings. Tailings and Mine Waste '98, Balkema, Rotterdam, 421-429. McKnight, J.T. and Owaidat, L.M. (2001). "Quality control and performance of a cutoff wall for containment of a DNAPL plume." Proc., 2001 Int. Containment and Remediation Technol. Conf., Orlando, FL, Florida State University, Tallahassee, FL, CD-ROM (5 p). Spaulding, C.A. (2007). Soil Bentonite Cut-off Walls for Confinement of Existing Landfills: Tempe Tip a Case Study. Proc., XVIth Asian Conference, New South Wales, Australia. Ryan, C.R. and Spaulding, C.A. (2008). Strength and permeability of a deep soil bentonite slurry wall. Proc., Geo-Congress 2008, New Orleans, LA, ASCE. Ryan, C.R. and Day, S.R. (2003). "Soil-bentonite slurry wall specifications." Proc., Soil and Rock America 2003, 12th Pan-American Conf. on Soil Mech. Geotech. Engrg., Cambridge, MA, 8 p. PolyMet (2013). NorthMet Project Water Modeling Data Package Volume 1 - Mine Site, Version 12. Andomalos, K.B., Fisher, M.J., and Beardsley, P.E. (2007). Design and construction considerations for the use of slurry walls to construct water reservoirs in the Denver formation. Proc., 32nd Annual Conference on Deep Foundations, Colorado Springs, CO.

(4)

(5)

(6)

(7)

(8)

(9)

(10) PolyMet (2013). NorthMet Project Adaptive Water Management Plan, Version 5, March 7. (11) EPA (2004). Draft Technical Guidance for RCRA/CERCLA Final Covers. EPA 540-R-04007, Office of Solid Waste and Emergency Response, Washington, D.C. (12) PolyMet (2013). Water Management Plan Plant (v2, February 2013). (13) Evans, J.C. (1993). Vertical cutoff walls. Geotechnical Practice for Waste Disposal, Ch. 17, D.E. Daniel, Ed., Chapman & Hall (14) Personal communication with Daniel Ruffing, P.E., Geo-Solutions, Inc. (15) PolyMet (2013). NorthMet Project Flotation Tailings Management Plan, Version 3, April 12. (16) Abichou, T., Benson, C.H., and Edil, T.B. (2002). Micro-structure and hydraulic conductivity of simulated sand-bentonite mixtures. Clays and Clay Minerals, 50(5), 537545.

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Final Assessment Report NorthMet Project SDEIS Review

Michael A. Malusis January 28, 2014

(17) Benson, C.H., Albright, W.H., Fratta, D.O., Tinjum, J.M., Kucukkirca, E., Lee, S.H., Scalia, J., Schlicht, P.D, and Wang, X. (2011). Engineered Covers for Waste Containment: Changes in Engineering Properties and Implications for Long-Term Performance Assessment. NUREG/CR-7028 Volume 1, U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research (http://www.nrc.gov/reading-rm/doc-collections/nuregs/ contract/cr7028/). (18) PolyMet (2012). NorthMet Project Geotechnical Data Package Volume 2 Hydrometallurgical Residue Facility, Version 3, October 12. (19) Koerner, R.M. (1998). Designing With Geosynthetics, 4th Edition, Prentice Hall, Upper Saddle River, NJ. (20) PolyMet (2012). NorthMet Project Residue Management Plan, Version 2, December 14. (21) National Research Council (2007). Assessment of the Performance of Engineered Waste Containment Barriers, The National Academies Press, Washington, DC. (22) Rowe, R.K. (2005). Long-term performance of contaminant barrier systems, 45th Rankine Lecture. Geotechnique, 55(9), 631-678. (23) Lupo, J.F. (2008). Heap leach pad liner design. http://www.geosynthetica.net/ Uploads/Lupo.pdf.

Thank you for the opportunity to offer my services to MCEA on this project. If you have any questions or concerns regarding this assessment or my comments, please do not hesitate to contact me at 570-412-2069 or michael.malusis@bucknell.edu. Sincerely,

Michael A. Malusis, Ph.D., P.E. Consulting Engineer cc: Jill Bathke, MCEA

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