TECHNICAL MEMORANDUM 5: UNDERGROUND WORKINGS …

Nobis Engineering, Inc.

585 Middlesex Street

Lowell, MA 01851

T (978) 683-0891

www.nobiseng.com

Underground Workings Investigation Plan Technical Memorandum #5 Ely Copper Mine Superfund Site Operable Units 2 and 3

Vershire, Vermont Remedial Investigation / Feasibility Study EPA Task Order No. 0070-RI-CO-017L

REMEDIAL ACTION CONTRACT No. EP-S1-06-03 FOR

US Environmental Protection Agency Region 1 BY

Nobis Engineering, Inc. Nobis Project No. 80070

July 11, 2014


Lowell, Massachusetts

Concord, New Hampshire

Phone (800) 394-4182

www.nobisengineering.com

U.S. Environmental Protection Agency

Region 1

5 Post Office Square, Suite 100

Boston, Massachusetts 02109-3919

NH-3964-2014-D Nobis Engineering, Inc.


585 Middlesex Street

Lowell, MA 01851

T (978) 683-0891

www.nobiseng.com

Underground Workings Investigation Plan

Ely Copper Mine Superfund Site Operable Units 2 and 3 Vershire, Vermont Remedial Investigation / Feasibility Study EPA Task Order No. 0070-RI-CO-017L

REMEDIAL ACTION CONTRACT No. EP-S1-06-03 For US Environmental Protection Agency Region 1 By Nobis Engineering, Inc. Nobis Project No. 80070 July 2014

Andrew J. Boeckeler, P.G. Senior Project Manager


NH-3964-2014-D 1 Nobis Engineering, Inc.

ELY COPPER MINE SUPERFUND SITE

OPERABLE UNITS 2 AND 3

TECHNICAL MEMORANDUM #5

DRAFT UNDERGROUND WORKINGS INVESTIGATION PLAN

1.0 INTRODUCTION .................................................................................................... 2

2.0 BACKGROUND ..................................................................................................... 3

3.0 FIELD INVESTIGATIONS ...................................................................................... 5 3.1 Retrofit Underground Workings Boreholes for Monitoring Wells ................. 5 3.2 Underground Workings Monitoring Wells Sampling .................................... 8 3.3 Groundwater Level and Adit Discharge Monitoring ................................... 11 3.4 Underground Workings Surface Water Sampling ..................................... 12 3.5 Underground Workings Outlet/Surface Water Discharge Mapping ........... 13 3.6 Bedrock Outcrop Fracture Measurements ................................................ 13

4.0 WORK PRODUCTS ............................................................................................. 14

TABLES

NUMBER

3-1 Bedrock Borehole Details 3-2 Bedrock Monitoring Well Conversion Details 3-3 Groundwater Sampling LocationsFigures 3-4 Underground Workings Sampling and Monitoring Equipment 3-5 Monthly Monitoring Locations 3-6 Surface Water Sampling Locations

FIGURES

NUMBER

1-1 Site Locus 1-2 Site Operable Units 2-1 Site Plan 3-1 Surface Water Monitoring Locations


1.0 INTRODUCTION

This Underground Workings Investigation Plan (UWIP) Technical Memorandum (Tech Memo 5)

was prepared by Nobis Engineering, Inc. (Nobis) for the United States Environmental Protection

Agency (EPA) under Contract Number EP-S1-06-03, Task Order Number 0070-RI-CO-017L

(Task Order). The Task Order objective includes the completion of a Remedial

Investigation/Feasibility Study (RI/FS) for the underground workings components of Operable

Units 2 and 3 (OU2 and OU3) of the Ely Copper Mine Superfund Site (“Site”). The UWIP

describes the technical approach for elements of Nobis’ Amendment 2 Work Plan dated May

2014.

The Site is located approximately 4 miles southeast of the village of Vershire Center and is

approximately 1.5 miles northwest of the village of West Fairlee in Orange County, Vermont. The

Site encompasses approximately 350 acres along the south slope of Dwight Hill, to the north of

Schoolhouse Brook and South Vershire Road, and the underground workings extend

approximately 3000 feet northeastward beneath the crest and north slope of Dwight Hill (Figure

1-1).

The EPA has defined the Operable Units for the Ely Copper Mine Superfund site as follows:

Operable Unit 1 (OU1): OU1 includes all mine waste piles and all associated surface water

and sediment impacts in Ely Brook, Ely Brook Tributaries, and on-site ponds.

Operable Unit 2 (OU2): OU2 includes all groundwater impacts associated with the Ely

Copper Mine Site that are within Ely Mine Forest, Inc. (EMFI) property; any surface water

impacts associated with the Underground Workings that are within the EMFI property; the

smelter and slag areas; and surface water and sediments in Schoolhouse Brook.

Operable Unit 3 (OU3): OU3 includes the underground workings and associated

groundwater and surface water impacts within the Green Crow property (i.e. north of the

crest of Dwight Hill).

The current Operable Units are shown on Figure 1-2.


OU3 has been created, in part, to assess and address potential groundwater and surface water

(if any) impacts on Green Crow property related to the Site underground workings and associated

water pool contained within those workings (“mine pool”). The goal of the Underground Workings

RI/FS, which will address OU3 and those portions of OU2 related to the underground workings,

is to develop the minimum amount of data necessary to support the selection of a remedy that

eliminates, reduces, or controls risks to human health and the environment and that can be used

to prepare a well-supported Record of Decision (ROD).

The purpose of this UWIP is to describe the means and methods for underground workings

borehole retrofits and monitoring well construction; groundwater sampling from those retrofitted

wells; underground workings adit discharge or seep sampling and monitoring; and other field

investigations and data collection activities related to the underground workings that are included

in the Work Plan, Amendment 2 but are not covered by the project QAPP (Revision 3, November

2012). The objectives, technical approaches, and specifications for these investigation elements

are presented below.

The field investigations described herein build upon previous work performed between 2012 and

2014, as described in Nobis’ prior memoranda: “Underground Workings Field Investigation” dated

12 September 2012 (“Tech Memo 1”); “Underground Workings Bedrock Hydrogeology

Characterization” dated 15 February 2013 (“Tech Memo 2”); “Final Underground Workings

Bedrock Drilling Locations and Access Road Plan” dated 24 June 2013 (“Tech Memo 3”); and

“Phase 1 Deep Bedrock Investigation” dated January 17, 2014 (“Tech Memo 4”).

2.0 BACKGROUND

The primary objective of the OU2/OU3 field investigations described in this UWIP is to assess the

potential groundwater and surface water impacts related to the underground workings at Ely Mine.

The underground workings originate at the Main Shaft, located on property of Ely Mine Forest,

Inc. (EMFI) and plunge in the N40E direction at an angle of approximately 25 degrees, extending

beneath property of Green Crow Corporation (Green Crow). In this Tech Memo, the “up-plunge”

direction is southwest, and northeast is referred to as the “down-plunge” direction and is

topographically higher on Dwight Hill (Figure 2-1).


Safety and logistical concerns preclude direct entry to the underground workings. Therefore, in

order to investigate groundwater impacts related to the underground workings, three boreholes

were drilled in 2013 that successfully intercepted the underground workings mine pool (Tech

Memo 4). Two boreholes (MW-UP1 and MW-UP2) are located in an up-plunge (with respect to

the underground workings) location, and one borehole (MW-DP1) is located in a down-plunge

location. All three boreholes are located on Ely Mine Forest Inc. property (Figure 2-1).

The mine pool was observed at an elevation approximately 1,276 to 1,278 feet above mean sea

level (ft amsl) when measured in 2013 by Nobis in the underground workings boreholes (Tech

Memo 4, Figure 5-1). Initial sampling and analysis of mine pool groundwater indicated metals

impacts related to the underground workings. However, because MW-DP1 is open to inflow from

flowing fractures above the mine pool, it is possible that mine pool water was mixed with

unimpacted fracture inflow during sample collection. This condition results in a degree of

uncertainty regarding the degree of impacts caused by the mine pool at this location. To address

this uncertainty, Nobis recommended the installation of a cased monitoring well in this borehole

and subsequent sampling and analysis (Tech Memo 4). Nobis also recommended that the

borehole MW-UP1 be converted to a shallow cased monitoring well to collect water quality data

from the assumed unimpacted shallow bedrock zone (Tech Memo 4).

The data collected during the underground workings field investigations described herein will be

used to help resolve the following key questions and data gaps for the OU2/OU3 Underground

Workings RI/FS.

What is the degree of metals impacts within the mine pool?

How variable is mine pool water quality with distance and depth? If there is variability in

metals concentrations or geochemical characteristics, what is the cause of the variability?

How do the underground workings and bedrock structure influence groundwater flow in

the vicinity of the mine pool?

If the mine pool is impacted, does the potential exist for these impacts to migrate beyond

the underground workings?


At what distance (i.e. buffer zone) from the mine pool would it be reasonable to assume

that water supplies would not be impacted under realistic future-use scenarios?

Could any mine pool impacts threaten potential future drinking water sources?

How do discharges from the underground workings through seeps and adits impact

surface water?

The specific information to be collected during the investigations described herein include:

additional water quality data (i.e. metals concentrations and geochemistry) from mine pool

groundwater and underground workings surface water discharges;

seasonal variability and fluctuations of the mine pool elevations and underground workings

surface water discharges; and

bedrock outcrop lithology, fracture, and structure orientations in the vicinity of the mine

pool.

3.0 FIELD INVESTIGATIONS

Field investigations described below include planned OU2/OU3 activities associated with the

underground workings and that are not included in the QAPP (Revision 3, dated November 2012).

3.1 Retrofit Underground Workings Boreholes for Monitoring Wells

The objective of this activity is to convert the existing bedrock boreholes that intercept the

underground workings to monitoring wells that are suitable for sample collection and water level

measurement. An additional objective is to seal the wells so that they are secure when not in use

and so that air currents will not disturb bats that hibernate in the underground workings. Borehole

construction details and other observations are included in Table 3-1. Additional information

regarding the previous borehole OU2/OU3 investigations can be found in Tech Memo 4. The

proposed bedrock monitoring well conversion details are provided in Table 3-2.

This activity will include the following steps:


Nobis’ road building and excavation subcontractor, Northwoods Excavating (Northwoods),

will improve the access road, as necessary, removing any water bars, smoothing runoff

gullies, removing fallen trees, etc. to allow the well drilling rigs to reach the existing

underground workings boreholes. Nobis will specify the technical requirements for this

work and will provide oversight of this activity.

Nobis’ drilling subcontractor, Cushing and Sons (Cushing), will mobilize the necessary

drilling rig(s) and support truck(s) to the borehole locations. Northwoods will be available

to assist pulling Cushing’s rig and trucks to the borehole locations, if needed. Nobis will

specify the technical requirements for this work and will provide oversight of this activity

MW-UP1: The objective of this monitoring well conversion is to isolate the depth interval

58 to 75 feet below ground. This monitoring location and depth interval will be used to

characterize the shallow bedrock groundwater that is inferred to be unimpacted by the

underground workings. The following procedure is planned:

o The existing locking seal will be removed.

o A cementing plug will be installed at a depth of 180 feet below ground surface (ft

bgs) by Nobis’ drilling subcontractor using the drilling rig as needed. This is

shallower than the top of the void that represents the underground workings at this

location.

o The existing 6-inch diameter borehole will be filled with bentonite-cement grout,

from the cementing plug up to 75 ft bgs, using a tremie pipe. The bentonite-

cement grout shall consist of a mixture of Portland cement (ASTM C 150),

bentonite (4 to 5 pounds of bentonite powder per 94-pound sack of cement), and

water in the proportion of not more than 7 gallons of clean approved water per bag

of cement.

o After the grout has set up (the next day following grout emplacement), sand will be

placed in the bedrock borehole up to a depth of 73 ft bgs and a two-inch diameter

PVC screen (20-slot) will be installed from 73 ft bgs to 58 ft bgs; then 2-inch PVC

pipe will be installed to the surface and approximately the same height at the

existing 6-inch steel casing.


o The annulus between the screen and the bedrock borehole to four feet above the

screen (i.e. from 73 ft bgs to 54 ft bgs) will be filled with sand, graded appropriately

for the screen slot size. For a 20-slot screen, the sand pack should consist of

clean, well rounded quartz grains ranging in size from 0.5 to 1.0 mm (0.020 to 0.39

inches), with a uniformity coefficient of 2.5 or less. The sand will be overlain by

four feet of bentonite (from 54 to 50 ft bgs); this in turn will be overlain by bentonite-

cement grout to the surface (in the annulus), which will have the composition

described above.

o The screened interval for the newly constructed MW-UP1 will be developed until

the water is visibly clear. The well will be pumped by using a submersible pump in

accordance with the standard operating procedure (SOP) HYD-004 (QAPP). The

pump should be gently raised and lowered while pumping to allow for water

movement into and out of the sand pack. Care should be taken that the entire

length of the well screen is surged and pumped. A written record of the well

development will be kept.

When constructed as described above, this well will be suitable for sampling groundwater

from fractures above the underground workings (assuming there is sufficient flow). Also,

the well will effectively provide a seal above the air-filled portion of the underground

workings, thereby preventing air currents from the well from disturbing wintering bats in

the underground workings.

MW-UP2: No modifications will be made to this borehole, because the six-inch diameter

steel casing presently extends to the void that represents the underground workings.

When observed during video camera and borehole geophysical surveys, water levels were

within the casing but only a short distance above the bottom of the casing. Water level

measurements described below may determine whether water levels ever drop below the

bottom of the casing. This information will indicate whether a well seal is needed to

prevent air circulation that may disturb bats that winter in the air-filled portion of the

underground workings. As presently constructed, the borehole is a well that can be used

to sample the mine pool in the underground workings in the up-plunge location.

A stilling tube will be installed in MW-UP2 in order to accommodate a pressure transducer

and to allow it to remain in place during sampling, without interfering with the sampling


pump. The stilling tube will be installed to the bottom of the boring, which is estimated at

approximately 225 ft bgs and will consist of 1-inch PVC with slots or other openings in the

bottom 5 feet to allow water entry. The stilling well will be secured to the casing so that it

does not become dislodged or impede future sampling efforts.

MW-DP1: The existing locking seal will be removed, and the borehole will be converted

to a monitoring well intended to sample the mine pool in the underground workings at this

down-plunge location while preventing inflow from shallower water-bearing zones. The

following procedure is planned:

o A 4-inch diameter Schedule 40 galvanized steel pipe will be advanced to 380 ft

bgs using a drill rig in order to place a nominal 4-inch x 6-inch Jaswell seal at this

depth.

o The Jaswell seal will be installed to 380 ft bgs and will have a nominal 4-inch x 7-

inch shale trap above the seal.

o Bentonite chips will be placed above the shale trap; these will be covered with

bentonite-cement grout, which will be emplaced in the annulus from 380 ft bgs up

to the surface using a tremie pipe.

This will result in a well that allows sampling of the mine pool with a 3-inch submersible

pump while preventing inflow from shallower bedrock fractures. Because this well will be

installed in a water-filled void, development is not necessary.

3.2 Underground Workings Monitoring Wells Sampling

As part of larger site-wide groundwater monitoring events to be performed in the summer and fall

of 2014, groundwater samples will be collected from MW-UP1, MW-UP2, and MW-DP1 and 27

other overburden and bedrock monitoring wells installed during the OU1 RI (Table 3-3). It is noted

that the sampling procedures for the OU1 monitoring wells has been provided previously in the

QAPP. Therefore, this UWIP only includes the procedures to be utilized for the sampling of MW-

UP1, MW-UP2, and MW-DP1.

Before emplacing a sampling pump or any other equipment, a manual water level measurement

will be taken using an electronic water level probe. The start and stop times for pumping will be


recorded. This information will be used to examine transducer data from the other two wells for

evidence of possible hydraulic connections between wells. Samples will be submitted for

laboratory analysis of total and dissolved metals, sulfate, chloride, alkalinity, carbonate,

bicarbonate, hydroxide, and acidity.

Because of differences in well construction and depth, details of the sampling procedures will vary

for the three wells, as noted below. Table 3-4 includes a list of the specific equipment required to

perform sampling and water level monitoring of each of the underground workings wells.

MW-UP1: The sample will be collected from the 2-inch diameter screened interval at 58

– 73 ft bgs using a nominal two-inch Grundfos™ submersible pump. The transducer (see

Section 3.3) will be removed prior to sampling. Manual water level measurements will be

made with an electronic water level probe when the transducer is removed and again

when it is replaced. Real-time transducer water level measurements will be taken and

recorded prior to removing the transducer and after replacing the transducer. If possible,

the well will be pumped at a rate low enough to allow the water levels to stabilize. It is

noted that water level stabilization will likely not be possible, because recharge during

packer sampling in an interval from 15 – 65 ft bgs occurred at only 0.016 gallons per

minute (gpm) (Tech Memo 4). In this case, the well will be evacuated and allowed to

recharge before sample collection. Nobis will record water levels and geochemical

parameters (pH, specific conductivity, temperature, dissolved oxygen, oxidation-reduction

potential, and turbidity) every five minutes during pumping. Purge water will be discharged

to the ground surface in the vicinity of the well in a manner that does not impact the work

area. Nobis will collect the samples directly from the pump discharge hose after one hour

of pumping or after evacuation of triple the volume of water in the well plus triple the

volume of water in the tubing, whichever occurs first. It is noted that for a 2-inch well, the

volume of water is about 0.16 gallons per vertical foot.

MW-UP2: The sample will be collected from the mine pool in this 6-inch diameter well

using a 3-inch diameter submersible pump set with an intake at 205 ± 5 ft bgs. In the

event the sample cannot be collected using the submersible pump because of limited

available water and the presence of rubble in the underground workings, the sample will

be collected using a bailer. The transducer (see Section 3.3) will be removed prior to

sampling. Manual water level measurements will be made with an electronic water level


probe when the transducer is removed and again when it is replaced. Real-time

transducer water level measurements will be taken and recorded prior to removing the

transducer and after replacing the transducer. Nobis will record water levels and

geochemical parameters (pH, specific conductivity, temperature, dissolved oxygen,

oxidation-reduction potential, and turbidity) every five minutes during pumping or at least

every 1.5 gallons during the bailing process. Purge water will be discharged to the ground

surface in the vicinity of the rig in a manner that does not impact the work area. If the

sample is pumped, Nobis will collect the samples directly from the pump discharge hose

after one hour of pumping. If the sample is bailed, Nobis will fill the sample bottles from

the bailer after a minimum of one water-filled casing volume is removed. This volume is

expected to be between 3 and 5 gallons, based on 2013 water levels (Tech Memo 4).

MW-DP1: The sample will be collected from the 4-inch diameter well casing using a 3-

inch submersible pump set with an intake at 300 ± 5 ft bgs. The transducer (see Section

3.3) will be removed prior to pump placement. Manual water level measurements will be

made with an electronic water level probe when the transducer is removed and again

when it is replaced. Real-time transducer water level measurements will be taken and

recorded prior to removing the transducer and after replacing the transducer. Nobis will

record water levels and geochemical parameters (pH, specific conductivity, temperature,

dissolved oxygen, oxidation-reduction potential, and turbidity) every five minutes during

pumping. Purge water will be discharged to the ground surface in the vicinity of the well

in a manner that does not impact the work area. Nobis will collect the samples directly

from the pump discharge hose after one hour of pumping or after evacuation of triple the

volume of water in the wellbore above the underground workings, whichever occurs first.

For the 4-inch well, the volume of water is about 0.65 gallons per vertical foot; for the 6-

inch borehole, the volume of water is about 1.5 gallons per vertical foot. If the starting

water level is 273 ft bgs, there will be about 70 gallons stored in the 4-inch casing and 6

gallons in the 6-inch borehole above the underground workings. Therefore, triple the

water in the borehole above the underground workings is approximately 228 gallons.


3.3 Groundwater Level and Adit Discharge Monitoring

This investigation includes monthly site-wide water level monitoring events that include 40

monitoring wells, Ely Brook surface water weirs, and adit discharge locations. Table 3-5 is a

summary of the monthly monitoring locations.

Well water levels will be measured using an electronic water level probe. Measurements at the

weirs will be read from the staff gauges installed at each weir, with the water level data later

converted to discharge. Water discharge measurements from adit locations will be made using

weirs or other appurtenances to be constructed at the adits openings, as feasible. Water level

and/or flow measurements will be made using calibrated staff or volumetric gauges to be

incorporated in adit discharge appurtenances. If there is insufficient flow to feasibly measure or

if it is infeasible to construct weirs or other appurtenances at any of the adit discharge locations,

other means for measuring discharge (for example flow meter recording, visual flow observations

and manual volume estimates, or other methods) shall be used as appropriate for the particular

adit or underground workings outlet. If quantitative measurements of water level or flow are not

feasible at a given underground workings opening, qualitative descriptions of the discharge will

be recorded.

In addition to the site-wide monthly groundwater level and surface water measurements, pressure

transducers will be placed in MW-UP1, MW-UP2, MW-DP1, and one background bedrock well.

The transducers will collect continuous data for up to 13 months. For the “background well”, a

well on Dwight Hill that does not intercept the Underground Workings will be selected. The Bureau

of Mines well BOM-1 (Figure 2-1) has not been re-located in 2014. It is likely that this well was

destroyed during 2013 road building. Therefore, the next nearest accessible on-site bedrock well

will be used. This will probably be MW-19D, although this well has obstructions (presumably

rocks) that will have to be cleared by Nobis’ drilling subcontractor.

The transducers will be set to collect water level measurements once every ten minutes, but will

be re-programmed to collect water level measurements once per minute prior to the summer and

fall 2014 sampling events (except for transducers that must be removed during sampling; see

Section 3.2, above). For each well, the transducer will be selected so that its pressure rating is

the lowest (most sensitive) that can be safely emplaced in that well based on the amount of water

expected to overlie the transducer. Each transducer will be hung in the well with a communication


cable that allows data to be downloaded from the transducer without pulling the transducer to the

surface.

The transducers will be hung at the following depths below the ground:

MW-UP1: 70 ft

MW-UP2: 205 ft

MW-DP1: 300 ft

Background well MW-19D: depth to be determined (assume 100 ft)

Non-vented transducers and non-vented cables will be used in conjunction with a barometric

pressure transducer; this will be used to correct data from the non-vented transducers for

barometric pressure effects. A mark will be placed on the transducer cable at the targeted

placement depth with respect to the well’s measurement point to provide a reference during

installation. The required cables for each well are specified in Table 3-4.

Manual water level measurements will be taken immediately before and after emplacing each

transducer and immediately before and after removing each transducer. Manual water level

measurements will also be taken from the transducer-equipped wells during each monthly event.

At the same time any manual water level measurements are taken, the “real-time” transducer

head level (i.e. the transducer reading that corresponds to the manual water level measurement)

will be downloaded and recorded. These measurements will be used to calibrate the water level

data obtained from the transducers. In addition to the real-time calibration readings, the full data

set for the preceding continuous monitoring period will be downloaded during each monthly event.

Following correction of the transducers for barometric pressure effects if necessary, the water

level data will be converted to depth below measuring point, depth bgs, and elevation above mean

sea level (amsl). The resulting water elevations will be graphed versus time for each of the wells.

3.4 Underground Workings Surface Water Sampling

As part of larger site-wide surface water monitoring events (described in the Work Plan,

Amendment 2 and the QAPP), surface water samples will be collected in spring and fall 2014

from up to six adit discharge locations (Table 3-6, Figure 3-1). Samples will be submitted for

laboratory analysis of total and dissolved metals, sulfate, chloride, alkalinity, carbonate,

bicarbonate, hydroxide, and acidity.


Because of potential differences in the weirs or appurtenances to be constructed (as described

above in Section 3.3), details of the surface water sampling procedures may vary for the adit

locations. If possible, surface water samples will be collected in accordance with the standard

operating procedure (SOP) for surface water sampling included in the QAPP (Appendix B: SOP

SA-11).

3.5 Underground Workings Outlet/Surface Water Discharge Mapping

Nobis will locate and flag all known surface features associated with the underground workings,

including openings for mine shafts and adits. Nobis will be accompanied by a subcontracted

historical resources specialist with specific knowledge of these features. The historical specialist

will assist in locating, identifying, and interpreting the underground workings openings and other

surface features associated with the underground workings.

Each identified feature will be described and or photographed. Particular emphasis will be placed

on any outflow of water from the openings or evidence of outflow having occurred in the past.

Minor modifications may be made at sites with water flow or standing water that has exited the

outlets to allow water level or discharge measurements (as described in Section 3.3 above). Each

underground workings outlet with water discharge will be photographed.

Nobis will survey the locations of all know surface features related to the underground workings

using a Trimble™ GPS. The Trimble™ GPS will achieve the data quality objectives needed to

understand water flow that may be associated with the underground workings. The location

surveying will be done concurrently with one of the initial water level monitoring events described

above.

Also, following the monitoring well construction described above, Nobis will survey the elevations

of measuring points on the new inner casings for MW-UP1 and MW-DP1 using a laser level

referenced to established elevation benchmarks.

3.6 Bedrock Outcrop Fracture Measurements

Nobis will conduct a fracture length and intersection study at one or more bedrock outcrops near

the surface trace of the underground workings. The objectives of this investigation include


assessing the expected lengths of fractures of various key orientations, assessing the typical

spacing between fractures, counting the number of fracture intersections that can be observed

within a given distance along a traverse or within an area of the outcrop, and improving the

conceptual site model for fracturing in the bedrock in the vicinity of the underground workings by

building on outcrop strike and dip measurements taken previously at outcrops on both EMFI and

Green Crow property.

The outcrop(s) to be selected may be the same or may be different from outcrops previously

selected for strike and dip measurements (Tech Memo 2). Outcrops will be sought with sufficiently

large exposures to lay out tape measure traverses at least several tens of feet long, in order to

intersect multiple fractures along the same traverse. Each outcrop will be described for lithology

and general aspect (pavement outcrop, cliff outcrop, hogback outcrop, etc.). The length and

orientation of each traverse will be recorded. Fractures will be counted along selected traverses,

and the lengths of individual fractures will be measured to the extent that exposures allow.

Fractures with sufficiently long traces exposed on the outcrop will be walked, with intersections

counted. Strikes and dips of fractures counted along the traverses will be measured and

recorded. The measured outcrops will be approximately located using a hand-held GPS unit.

The results will be analyzed in order to estimate the average fracture length and average fracture

spacing for key fracture sets. Counts of observed fracture intersections will also be made, and/or

the likelihood that fractures of given sets will intersect based on the length and spacing data will

be assessed. The results will be compared to similar assessments made using fracture data

obtained from acoustic televiewer logs of the underground workings boreholes.

4.0 WORK PRODUCTS

All of the field investigations described above will provide information for an updated Underground

Workings Conceptual Site Model Technical Memorandum (CSM Tech Memo). The CSM Tech

Memo will summarize the available technical data and information related to the underground

workings component of OU2/OU3 and will use the same report structure as the RI so that

information presented can be readily incorporated into the Draft RI Report. The CSM Tech Memo

will provide maps in plan-view and cross-section that depict the surveyed surface features and

inferred subsurface extent of the underground workings, including dead-end adits and shafts.


Specific work products to be provided in the CSM Tech Memo that will be derived from the UWIP

field investigations include the following:

Retrofit Underground Workings Boreholes for Monitoring Wells:

o a summary of field activities and observations, including field notes and

photographs;

o well construction diagrams for MW-UP1, MW-UP2, and MW-DP1;

o a description of any deviations from the Work Plan, Amendment 2 and the UWIP;

o surveyed elevations of new measuring points for MW-UP1 and MW-DP1; and

o well development record for MW-UP1.

Underground Workings Monitoring Wells Sampling:


photographs;

o field data sampling sheets, including water levels and geochemical field parameter

measurements; and

o tabulated and validated laboratory analytical results.

Groundwater Level and Adit Discharge Monitoring:

o tabulated list of transducers used and their depths in each well, along with manual

water level calibration measurements;

o tabulated monthly water level measurement results;

o tabulated transducer results for the underground workings wells with graphs of

water elevation versus time for each of the three wells; and

o overburden groundwater potentiometric surface maps for selected months that will

be chosen to provide a representative depiction of seasonal variation;

Underground Workings Outlets and Surface Water Discharge Mapping and Surveying:



photographs;

o revised site map showing the features identified and mapped, relocated if

necessary; and

o photo documentation of any outlets showing evidence of current or recent water

outlet flow and any features deemed to be of special interest by the historical

resources specialist.

Bedrock Outcrop Fracture Measurements:


photographs;

o tabulated results for fracture orientation and spacing for each traverse;

o tabulated results for fracture length measurements and fracture intersection

counts;

o a map showing the approximate locations of the bedrock outcrops;

o rose diagrams and stereonet plots showing strike and dip of fractures measured;

o a discussion comparing the 2014 outcrop study results to fracture measurements

collected during previous bedrock borehole acoustic televiewer surveys,

o a discussion regarding the implications for groundwater flow in the bedrock near

the underground workings.

T A B L E S

Table 3-1

Bedrock Borehole Details

Ely Copper Mine Superfund Site - OU2/OU3

Vershire, Vermont

Stickup

(ft) Elev. ft bgs Elev. ft bgs Elev. ft bgs Elev. ft bgs Elev. ft bgs Elev. ft bgs Elev.

MW-UP1 0.5 1476.69 11.3 1464.35 18.5 1457.15 NA NA 185.5 1290.15 NA NA 221.0 1254.65

MW-UP2* 2.0 1477.52 11.5 1463.81 201.0 1274.31 199.3 1275.92 185.0 1290.31 225.0 1250.31 350.0 1125.31

MW-DP1 2.0 1551.29 4.0 1545.18 15.0 1534.18 273.0 1276.29 384.0 1165.18 NA NA 401.0 1148.18

Notes:

ft bgs = feet below ground surface

Elev. = elevation in feet above mean sea level (MSL)

Water level in MW-UP2 and MW-DP1 measured by hand using a water level indicator on 7/19/13 and 7/25/13, respectively.

*Top of void estimate based on drilling (casing installed through void prior to borehole geophisics). Bottom of boring collapsed/obscured by rubble;

approximate total depth reachable by instruments is 211 ft bgs.

End of BoreholeTop of Static WL

Boring ID

Top of Casing Top of Bedrock Top of Void Bottom of RubbleBottom of casing


Table 3-2

Bedrock Monitoring Well Conversion Details

Ely Copper Mine Superfund Site - OU2/OU3

Vershire, Vermont

Stickup

(ft) Elev. ft bgs Elev. ft bgs Elev. ft bgs Elev.

Top (ft

bgs)

Bottom

(ft bgs)

MW-UP1 0.5 1476.69 18.5 1457.15 185.5 1290.15 221.0 1254.65

PVC monitoring

well 2" 73 58.0 73.0

MW-UP2* 2.0 1477.52 201.0 1274.31 185.0 1290.31 350.0 1125.31 PVC stilling well 1" 205

MW-DP1 2.0 1551.29 15.0 1534.18 384.0 1165.18 401.0 1148.18

Jaswell Seal and

steel monitoring

well 4" 380

Notes:

ft bgs = feet below ground surface

Elev. = elevation in feet above mean sea level (MSL)

approximate total depth reachable by instruments is 211 ft bgs.

Boring ID

Top of Casing Top of Void Screened IntervalBottom of casing

Open at 380

Open at 225

End of Borehole

Well Type Well IDWell

Depth (ft)

*Top of void estimate based on drilling (casing installed through void prior to borehole geophisics). Bottom of boring collapsed/obscured by rubble;


Table 3-3

Groundwater Sampling Locations

Ely Copper Mine Superfund Site OU2/OU3

Vershire, Vermont

Page 1 of 1

MW-01C Shallow Bedrock Smelter/Slag X X X No exceedances of PRGs, near by to MW-02 couplet

MW-02A Shallow Overburden Smelter/Slag X X X Assess impacted groundwater in the slag area

MW-02B Deep Overburden Smelter/Slag X X X Assess impacted groundwater in the slag area

MW-02C Shallow Bedrock Smelter/Slag X X X Assess impacted groundwater in the slag area

MW-05A Shallow Overburden UWA X X X Assess groundwater impacts to tramway/UWA erosion area

MW-05B Deep Overburden UWA X X X Assess groundwater impacts to tramway/UWA erosion area

MW-05C Shallow Bedrock UWA X X X Assess groundwater impacts to tramway/UWA erosion area

MW-08A Shallow Overburden UWA X X X Assess impacted groundwater in Pond 4 & 5 area

MW-09A Shallow Overburden UWA X X X Assess the impacts from UWA on non-waste areas

MW-09C Shallow Bedrock UWA X X X Assess the impacts from UWA on non-waste areas

MW-11A Shallow Overburden Smelter/Slag X X X Assess groundwater impact in the smelter area

MW-11C Shallow Bedrock Smelter/Slag X X X Assess groundwater impact in the smelter area

MW-12C Shallow Bedrock UWA X X X Assess impacted groundwater in Pond 4 & 5 area

MW-13A Shallow Overburden UWA X X X Provide data near access road/UWA buffer zone

MW-14A Shallow Overburden EB-LR X X X Assess groundwater impacts outside of the boundary of EB-LR floodplain

MW-14C Shallow Bedrock EB-LR X X X Assess groundwater impacts outside of the boundary of EB-LR floodplain

MW-14D Deep Bedrock EB-LR X X X Assess groundwater impacts outside of the boundary of EB-LR floodplain

MW-15A Shallow Overburden EB-TZ X X X Assess groundwater impacts west of EB-MR

MW-18A Shallow Overburden UWA X X X Historically dry location; however, if water is present a sample should be collected due to lack of data points for the location

MW-19A Shallow Overburden UWA X X X Only location with consistent data in the UWA

MW-19C Shallow Bedrock UWA X X X Only location with consistent data in the UWA

MW-19D Deep Bedrock UWA Well is damaged with an obstruction at about 30 feet bgs. In the event the can be repaired, sampling will be re-evaluated.

MW-20A Shallow Overburden LWA X X X Assess the impacts of the LWA on non-waste area

MW-20C Shallow Bedrock LWA X X X Assess the impacts of the LWA on non-waste area

MW-20D Deep Bedrock LWA X X X Assess the impacts of the LWA on non-waste area

MW-21A Shallow Overburden LWA X X X Represents the core of the LWA

MW-21C Shallow Bedrock LWA X X X Represents the core of the LWA

MW-22A Shallow Overburden Tailing X X X Only location within the TA

MW-DP1 Deep Bedrock BMW X X X Target of investigation to determine potential impacts from mine pool

MW-UP1 Deep Bedrock BMW X X X Target of investigation to determine potential impacts from mine pool

MW-UP2 Deep Bedrock BMW X X X Target of investigation to determine potential impacts from mine pool

Total Wells Monitored: 30 30 30

Notes

1. EB-LR = Ely Brook-Lower Reach; EB-TZ = Ely Brook-Transition Zone; ORB = Ore Roast Bed

LWA = Lower Waste Area; UWA = Upper Waste Area; WC = West Cell; BMW = Bedrock Mine Workngs

2. PRG = Preliminary Remediation Goal; AES = Atomic Emission Spectroscopy; MS = Mass Spectrometer

3. "Other Inorganics" = sulfate, chloride, alkalinity, carbonate, bicarbonate, an acidity.

Well NumberTotal

MetalsRationale for SamplingAquifer Area

Dissolved

Metals

Other

Inorganics 3


Table 3-4

Underground Workings Sampling and Monitoring Equipment


Vershire, Vermont

Groundwater Sampling

Item Required for Well Manufacturer Model Performance Specification Power Requirements Comments

Pumps, Controls, and Power

Nominal 3-Inch Submersible Pump MW-UP2, MW-DP1 10SQ330230 V; rated at 3-15 gpm; 1.5HP; pump curve suggests 10 - 12 gpm at water depth of 280 ft;

flow will decrease as water level drops -- may be 6 gpm or less at 380 ftGenerator For cables, assume sample depth 300 ft for DP1,plus 10 ft = 310 ft;

Nominal 2-Inch Submersible Pump MW-UP1 pump curve output = 8 gpm at 75 ft head;220 V; 0.5HP; 400Hz; For cable, assume sample depth 70 ft plus 10 ft = 80 ft;

2" Submersible Pump Control Box MW-UP1 100 ml/min to 9 gpm; pump has interconnect cable for voltage conversion

Generator MW-UP1, MW-UP2, MW-DP1 Generac GP5500 5000 W; has 200-240V output and 100-115V output Gasoline

MW-UP1 83 ft; 3/8 inch clear polyethylene For tubing, assume sample depth 73 ft, plus 10 ft;

MW-UP2 215 ft; 1 inch black polythylene For tubing, assume sample depth 205 ft, plus 10 ft;

MW-DP1 310 ft; 1 inch black polythylene For tubing, assume sample depth 300 ft, plus 10 ft;

Other fitings and/or adaptors MW-UP1, MW-UP2, MW-DP1 plastic "transducer savers" on rim of well N/A

Monitoring and Sampling Field Measurement Meters

Water level meter MW-UP1, MW-UP2, MW-DP1 Solinst 101 - 300' 300'; also may need extra weight to get probe down the deviated borehole in DP1 Battery

Pressure Transducer and Barometric Data Reader MW-UP1, MW-UP2, MW-DP1 In Situ Rugged Reader 520 MHz with comm cable; Optional -- can use laptop Battery

Laptop Computer MW-UP1, MW-UP2, MW-DP1 Not required if using Rugged Reader; also need comm cable Battery

Multi-parameter water quality meter YSI 600XL MPS w/ Flow Cell

Turbidity meter Hach 2100P

Peristaltic pump with battery/charge GeoPump Battery pack

Filter MW-UP1, MW-UP2, MW-DP1 .45 micron N/A

Monthly Water Level Monitoring

Item Manufacturer Model Performance or Other Specifications Power Requirements Comments

Water level meter MW-UP1, MW-UP2, MW-DP1 Solinst 101 - 300' 300' Batterymay need extra weight to get probe down the deviated borehole

in DP1

Pressure Transducer and Barometeric Data Reader MW-UP1, MW-UP2, MW-DP1 in Situ Rugged Reader 520 MHz with comm cable; Optional -- can use laptop Battery

Laptop Computer MW-UP1, MW-UP2, MW-DP1 Not required if using a Rugged Reader; also need comm cable Self-charging

Continuous Water Level Monitoring

Item Manufacturer Model Performance Specification Power Requirements Comments

MW-UP1, MW-UP2, MW-19D In Situ99240 Level Troll 400, 30

psiaLevel sensor range 11 m (35 ft); unvented

MW-DP1 In Situ99250 Level Troll 400,

100 psiaLevel sensor range 60 m (197 ft); unvented

MW-UP1 52000-03-01-02 Rugged twist-lock cable, poly, non-vented, no reel; max 100 ft; need 75 ft

MW-DP1 52000-03-03-02 Rugged twist-lock cable, poly, non-vented, small spool; max 900 ft; need 300 ft

Barometric data logger NA In Situ 89100 Baro Troll 1.14 bar ( 16.5 psi); requires backshell or cable Deploy in convenient location near wells

Pressure Transducer and Barometric Data Reader In Situ Rugged Reader 520 MHz with comm cable; Optional -- can use laptop

Laptop Computer Must have if not using Rugged Reader; also need comm cable Self-charging

All Wells

Tubing

MW-UP2, Background Well

MW-UP1, MW-UP2, MW-DP1Or equivalent; Also need Solution Zero Oxygen; Solution-Zobell;

and Solution .447s ConductivitySpecified in QAPP SOP SA-003

Self-charging

Use laptop or Rugged Reader; need comm cable either way; Win

Situ software will come with purchase or rental



BatteryPressure Transducers

Data cables



Battery

Not specified

Generator

N/A

In Situ 52000-03-02-02 Rugged twist-lock cable, poly, non-vented, small spool; max 500 ft; need 210 ft N/A

Grundfos

Redi-Flo2

Not specified

Not specified

Not specified

Not specified


Table 3-5

Monthly Monitoring Locations


Vershire, Vermont

Page 1 of 2

1834 Tyson/1854 Pollard Adit UMW UMW X X X Determine if flow is emanating from underground mine working

1850 Pollard Adit UMW UMW X X X Determine if flow is emanating from underground mine working

1861 Pollard Adit UMW UMW X X X Determine if flow is emanating from underground mine working

Deep Adit UMW UMW X X X Determine if flow is emanating from underground mine working

Main Adit UMW UMW X X X Determine if flow is emanating from underground mine working

Shaft #4 UMW UMW X X X Determine if flow is emanating from underground mine working

SW above Main Adit Surface Water UMW X X X Determine if surface water is contributing to Main Adit water

FS-01 Surface Water EB-UR X X X X Assess surface water flow from EB-UR

FS-02 Surface Water EBT3 X X X X Assess surface water flow from EBT3

FS-03 Surface Water EBT2 X X X X Assess surface water flow from Pond 5 discharge

FS-04 Surface Water EBT2 X X X X Assess surface water flow upstream of EB-MR confluence and downstream of EBT3 confluence

FS-05 Surface Water EB-LR X X X X Assess surface water flow downstream from EBT2 confluence

BOM-01 Bedrock UWA X Monitor site-wide groundwater elevations

BOM-03 Bedrock UWA X Monitor site-wide groundwater elevations

MW-01A Shallow Overburden Smelter/Slag X Monitor site-wide groundwater elevations

MW-01B Deep Overburden Smelter/Slag X Monitor site-wide groundwater elevations

MW-01C Shallow Bedrock Smelter/Slag X Monitor site-wide groundwater elevations




MW-03C Shallow Bedrock ORB X Monitor site-wide groundwater elevations

MW-04A Shallow Overburden LWA X Monitor site-wide groundwater elevations

MW-04C Shallow Bedrock LWA X Monitor site-wide groundwater elevations

MW-05A Shallow Overburden UWA X Monitor site-wide groundwater elevations

MW-05B Deep Overburden UWA X Monitor site-wide groundwater elevations

MW-05C Shallow Bedrock UWA X Monitor site-wide groundwater elevations



MW-07A Shallow Overburden Background X Monitor site-wide groundwater elevations

MW-07C Shallow Bedrock Background X Monitor site-wide groundwater elevations










MW-14A Shallow Overburden EB-LR X Monitor site-wide groundwater elevations

MW-14C Shallow Bedrock EB-LR X Monitor site-wide groundwater elevations

MW-14D Deep Bedrock EB-LR X Monitor site-wide groundwater elevations

AquiferFlow

VelocityFlow Rate Rationale for SamplingMonitoring Location

Presence

of Flow

Water

LevelArea


Table 3-5

Monthly Monitoring Locations


Vershire, Vermont

Page 2 of 2

AquiferFlow

VelocityFlow Rate Rationale for SamplingMonitoring Location

Presence

of Flow

Water

LevelArea

MW-15A Shallow Overburden EB-TZ X Monitor site-wide groundwater elevations

MW-16A Shallow Overburden EB-TZ X Monitor site-wide groundwater elevations





MW-19D Deep Bedrock UWA X Monitor site-wide groundwater elevations



MW-20D Deep Bedrock LWA X Monitor site-wide groundwater elevations



MW-22A Shallow Overburden Tailing X Monitor site-wide groundwater elevations

MW-23A Shallow Overburden ORB X Monitor site-wide groundwater elevations

MW-24B Deep Overburden WC X Monitor site-wide groundwater elevations

MW-24C Shallow Bedrock WC X Monitor site-wide groundwater elevations





MW-DP1 Deep Bedrock BMW X Monitor site-wide groundwater elevations

MW-UP1 Deep Bedrock BMW X Monitor site-wide groundwater elevations

MW-UP2 Deep Bedrock BMW X Monitor site-wide groundwater elevations

TP-228-PZ Shallow Overburden WC X Monitor site-wide groundwater elevations

TP-230-PZ Shallow Overburden WC X Monitor site-wide groundwater elevations

SB-103 Deep Overburden ORB X Monitor site-wide groundwater elevations



Total Locations Monitored: 63 12 12 12

Notes

EB-LR = Ely Brook-Lower Reach; ORB = Ore Roast Bed; EB-TZ = Ely Brook-Transition Zone;

LWA = Lower Waste Area; UMW = Underground Mine Workings; UWA = Upper Waste Area;

BMW = Bedrock Mine Workngs; WC = West Cell;


Table 3-6

Surface Water Sampling Locations


Vershire, Vermont

Page 1 of 1

EM-POND4 Pond 4 x x x Assess impacts to pond

EM-POND5 Pond 5 x x x Assess impacts to pond

ES-4 Seep 4/1850 Pollard Adit x x x Potential leaching from adit discharge

ES-8 Seep 8/Deep Adit x x x Potential leaching from adit discharge

SW-06 SHB x x x Assess impacts downstream of Ely Brook-Schoolhouse Brook confluence

SW-12 EB-MR x x x Assess impacts downstream of EBT2 confluence

SW-13 EB-UR x x x Assess impacts upstream of EBT3 confluence

SW-14 EBT2 x x x Assess impacts upstream of EBT2 confluence

SW-17 EB-UR x x x Assess impacts upstream of EB-UR confluence


SW-32 EBT2 x x x Assess impacts upstream of EB-MR confluence and downstream of EBT3 confluence

SW-34 EBT1 x x x Assess impacts upstream of EB-LR confluence

SW-39 EB-LR x x x Assess impacts downstream of EBT1 confluence

SW-40 EB-UR x x x Assess impacts downstream of EBT4 confluence

SW-42 Seep 14/Ponds 4 and 5 x x x Assess impacts of drainage potentially discharging to ponds


SW-76 UWA x x x Assess impacts from seepage from UWA waste pile

SW-82 EBT3 x x x Assess impacts upstream of tailing area

SW-100 Main Adit x x x Main adit discharge

SW-101 SW above Main Adit x x x Surface water directly above main adit that may be contricuting to water in the adit

Total Locations Monitored: 20 20 20

Notes

1. EB-LR = Ely Brook-Lower Reach; UWA = Upper Waste Area; EBT# = Ely Brook tributary with identifying number; SHB = Schoolhouse Brook

2. SW = Surface Water; AES = Atomic Emission Spectroscopy; MS = Mass Spectrometer

Sample LocationDissolved

Metals

Total

MetalsRationale for SamplingArea Sulfate


F I G U R E S

³ APPROXIMATE SCALE

Revision No. 00

Drawn By: JRS Checked By: AJB FIGURE 1-1

0 800 1,600400Feet

August 2012

Quadrangle LocationSite Locus

Ely Copper MineVershire, Vermont

USGS TOPOGRAPHIC MAP

VERSHIRE, VERMONT1981; (Photo-inspected 1983)

Ely Copper MineStudy Area

Ely Copper MineSuperfund Site

Schoolhouse Brook

South Vershire Road

Beanville Road

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Concord, NH 03301(603) 224-4182

Vershire

West Fairlee

Underground Workings OU2

General Extent of the Ely Copper Mine Superfund Site

Schoolhouse Brook

South Vershire Road

Beanville Road

LegendRoad

General Extent of the Ely Copper Mine Superfund Site

OU1 Area

OU2 Area

OU3 Area

Underground Mine Working

Waste Area

Property Boundary

East Branch of theOmpompanoosuc River

Route 113


Revision No. 01

Drawn By: DWG Checked By: AJB Figure 1-2

0 1,500 3,000750Feet

June 2014Nobis Engineering, Inc.

18 Chenell DriveConcord, NH 03301

(603) 224-4182

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Main Adit

Main Shaft

Burleigh Shaft

1850 Pollard Adit

1850s Pollard Shaft

Back Stopes Entrance

1834 Tyson/1854 Pollard Adit

Unidentified Rock-Walled Hole

Shaft II - 1850s Pollard Shaft

MW-DP1

MW-UP1MW-UP2

MW-9CMW-9A

MW-8A

MW-7CMW-7A

MW-6CMW-6A

MW-5CMW-5BMW-5A

MW-4CMW-4A

MW-3C

MW-2CMW-2BMW-2A

MW-1CMW-1BMW-1A

MW-23A

MW-22A

MW-21CMW-21A

MW-20DMW-20CMW-20A

MW-19DMW-19C

MW-19A

MW-18A

MW-17A

MW-16A

MW-15A

MW-14DMW-14CMW-14A

MW-13A

MW-12C

MW-11CMW-11A

MW-10CMW-10B

MW-26CMW-26B

MW-25CMW-25B

MW-24CMW-24B

BOM-03

BOM-01

1300

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1500

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!A Monitoring Well

!A OU2 Phase I Borehole

XY Adit

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Gravel Road

Paved Road

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Treeline

Stream

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Topographic Contour


Revision No. 00

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FIGURE 2-1

Nobis Engineering, Inc.18 Chenell Drive

Concord, NH 03301(603) 224-4182

Site PlanEly Copper Mine

Vershire, Vermont

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ES-8

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SW-60

SW-13

SW-42

SW-76

SW-82

SW-06

SW-14

SW-40

SW-29

SW-32SW-12

SW-34

SW-17

SW-39

SW-101SW-100

EM-POND5

FS-05

FS-04

FS-03FS-02

FS-01

Shaft II - 1850s Pollard Shaft

Unidentified Rock-Walled Hole

1834 Tyson/1854 Pollard Adit

Back Stopes Entrance

1850s Pollard Adit A

Main ShaftAir Vent

Main Adit

1850 Pollard Adit

Deep Adit

Burleigh Shaft

1850s Pollard Shaft

Shaft #4

³ APPROXIMATE SCALERevision No. 01

Drawn By: DWG Checked By: AJB

0 300 600150Feet

July 2014 Nobis Engineering, Inc.18 Chenell Drive

Concord, NH 03301(603) 224-4182

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FIGURE 3-1

Documents

TECHNICAL MEMORANDUM 5: UNDERGROUND WORKINGS …