STATE Of NEVADA

Department of Conservation and Natural Resources

Division of Environmental Protection

Bureau of Mining Regulation and Reclamation

Water Pollution Control Permit

Permittee: Rawhide Mining LLCDenton-Rawhide Mine ProjectP.O. Box 2070Fallon, Nevada 89407

Permit Number: NEV0088018Review Type/Year/Revision: Renewal 2019, Revision 00

Pursuant to Nevada Revised Statutes (NRS) 445A.300 through 445A.730, inclusive, andregulations promulgated thereunder by the State Environmental Commission and implemented bythe Division of Environmental Protection (the Division), this Permit authorizes the Permittee toconstruct, operate, and close the Dcnton-Rawhide Mine Project, in accordance with thelimitations, requirements, and other conditions set forth in this Permit. The Permittee is atithorizedto process tip to 7,000,000 tons of ore per year.

The facility is located on private land and public land administered by the U.S. Bureau of LandManagement in northeast Mineral Cotinty, within portions of Sections 3-10, 14-18, 21-23, and 26,Township 13 North (T13N), Range 32 East (R32E); Sections 30-33, TI4N, R32E; Sections 1 and12, 113N, R3U/2E; and Sections 25 and 36, TI4N, R31V2E, Mount Diablo Baseline and Meridian.approximately 36 air miles southeast of the town of Fallon and 32 air miles north of the town o[Hawthorne.

The Permittee must comply with all terms and conditions of this Permit and all applicable statutesand regulations.

This Permit is based on the assumption that the information submitted in the application of 28September 1992, as modified by subsequent approved amendments, is accurate and that the facilityhas been constructed and is being operated as specified in the application. The Permittee mustinform the Division of any deviation from, or changes in, the information in the application, whichmay affect the ability of the Permittee to comply with applicable regulations or Permit conditions.

This Permit is effective as of 30 July 2019, and shall remain in effect until 14 July 2024, unlessmodified, suspended, or revoked.

Signed this - day of July 2019.

&JP_ .J.

Joseph Sawyer, P.Chief Bureau of Mining Regulation and Reclamation

Rawhide Mining LLCDenton-Rawhide Project

Permit N NEVOO88O 18 (Renewal 2019, Revision 00)Page 2 ol 18

Specific facility Conditions and Limitations

A. In accordance with operating plans and facility design plans reviewed and approved by theDivision the Permittee shal 1:

1. Construct, operate, and close the facility in accordance with those plans;

2. Contain within the fluid management system all process fluids including allmeteoric waters which enter the system as a result of the 25-year, 24-hour stormevent; and

3. Not release or discharge any process or non-process contaminants from the fluidmanagement system.

B. Schedule of Compliance:

1. Phase VI-Al heap leach pad was approved in August 2015 as an engineering designchange (EDC) included in the 2015 Renewal, Thirty days prior to initiatingconstruction of the remaining Phase VI heap leach pad expansion approvedSeptember 2000 as a minor modification to the Permit, the Permittee shall meetwith the Division to review the design, Any change from the approved design willrequire submittal of an appropriate modification proposal, approval by the Divisionprior to construction and may require payment of applicable fees.

2. If, at closure, conversion of the South Pregnant Pond to an evapotranspiration cellis required for management of heap draindown, once cessation of operation allowsfor removal of the piping and other infrastructure presently blocking access to theexisting liner anchor trench, the primary liner and geonet shall be removed, and anew liner and geonet installed using a conventional anchor trench design, butwithout disturbing the existing secondary liner anchor trench.

The schedule of compliance items above are not considered completed until approved inwriting by the Division.

C. The fluid management system covered by this Permit consists of the following processcomponents:

1. The composite-lined heap leach pad, Phase Ithrough Phase V, VI-Al, and WesternExtension Phase 1 through Phase 4, the underdrain solcition collection system, andsolution collection channels with leak detection systems;

2. Solution transfer pipelines and lined solution transfer channels;

3. Double synthetic-lined North, South, Phase IV, Phase V Pregnant, Safety Supply,Barren, Phase IV Recirculation, Intermediate, and Northwest Pregnant Solutionponds and corresponding leak detection and recovery systems;

4. Single synthetic-lined Sludge and Phase IV Storm ponds;

5. Merrill-Crowe process recovery building including, but not limited to, all tanks,basins, sumps, pumps, and piping necessary to interconnect the components withinthe building;

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6. Carbon Adsorption-Desorption Regeneration (ADR) process facility including, butnot limited to, carbon—in-column (CIC) plant, process solcttion containmentstructure, leak detection and recovery system, all tanks, basins, sumps, pumps, andpiping necessary to interconnect the components;

7. Six Deep, 80 Shallow, $0 Intermediate, and 43 Bench heap leach pad gravityapplication solution wells:

8. One-hcindred-six pressure solution application wells; and

9. Transfer pipes, valves, and pumps used in conveyance, control or detection ofprocess fluids between process components.

0. Monitoring Requirements:

Identification Parameter Frequency

1. Water Supply Well (WS) Profile 1(2) Annually

2, Process Solution

Pregnant Solution (PS) Profile j(2) QuarterlyBarren Solution (BS)

3. Pond Leak Detection Sumps (fluid capacity)

North Pregnant (PPN - 210 gal) Average WeeklyW

South Pregnant (PPS - 210 gal) accumulationBarren (BP - 50 gal) (gpd)Safety Supply (SSP - 50 gal)Phase IV Pregnant (P4P - 158 gal)Phase IV Recirculation (RCP - 197 gal)Phase V Pregnant (PP5 - 330 gal)Phase V Intermediate (1P5 - 330 gal)Phase V Storm (SP5 - 330 gal)Northwest Pregnant (NW? - 2, 1 54 gal)Western Extension Phase 4 Sump (WE4 - 475gal)

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Rawhide Mining LLCDenton—Rawhide Project

Permit N° NEVOO8$018 (Renewal 2019, Revision 00)Page 4 of’ 18

Identification Parameter Frequency

4. Channel and Buried Pipeline Leak DetectionSumps/Ports (fluid capacity if applicable)

Phase II Collection Channel (DL2 - 235 gal) Average WeeklyW

Phase III Collection Channel (DL3 - 235 gal) accumulation!Buried Yard Line (BYL - 210 gal) flow (gpd)Buried Sludge Line (BSL - 108 gal)Phase IV Pregnant Channel (P4D2 - 300 gal)Phase IV Recirc Channel (RCD2 - 300 gal)Phase V Pregnant Channel (P505 - 222ga1)Phase V Intermediate Channel (ISD5 - 222ga1)Phase V Pregnant Pipeline (PSP5 - 222 gal)Phase V Intermediate Pipeline (ISP 5 - 222 gal)Western Extension Pipe Inlet (WEPT - 1 6 gal)Western Extension Phase 4 Wick (PH4W)Western Extension Phase 4 Sump Stand Pipe(WE4-475)CIC Tank TIOl Wick (CIC1)CIC Tank T102 Wick (CIC2)‘E Cell Sump (ECS - 28 gal)Northwest Collection Tie-In Wick (NEW)Southeast Sump Stand Pipe (SESS - 272 gal)Northwest Sump Standpipe (NESS - $25 gal)Phase VT-Al Sump (S6AI- 202 gal)Phase VI-Al Header Pipe (HP6AI)Phase VI-Al Conveyance Pipe (CP6A1)Phase VI-Al Pregnant Solution Pipeline (P6PS)Phase VI-Al North Collection Pipe Wick(P6PCPN)Phase VI-Al East Collection Pipe Wick(P6CPE)

IfPhase VI is constructed:Phase VT Intermediate Channel (TSC6 - 1 50 gal)Phase VI Pregnant Channel (PCS6 - 1 50 gal)Phase VI Intermediate Pipeline (BlP6 - 150 gal)Phase VI Pregnant Pipeline (BSP6 - 150 gal)

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Identification Parameter Frequency

5. Channel and Buried Pipeline Leak DetectionPipes

Phase I Collection Channel (DLI) Average flow WeeklyW

Phase I Pregnant Line (BPL) (gpd)Phase IV Pregnant Channel (P4D 1)Phase IV Recirculation Channel (RCDI)Phase V Pregnant Drop Box (PDB5)Phase V Intermediate Drop Box (IDB5)Phase V Pregnant Pond Sump (PTP5)Phase V Storm Pond Sump (STP5)Phase V Intermediate Pond Sump (ITP5)Northwest Expansion Liner Tie-In (NWEL)

6. Mined Materials

Waste Rock (WR)t I I); Quantity and Quarterlyt1;Group Type,MWMPt3-Profile j(2)

ANP/AGPt3;

Leach Pad Ore (LO) ANP/AGP13161 Quarterly

7. Phase IV Stormwater Pond fluid level Weekly (whenmeasured as fluid present)depth (feet).p1-I, specificconductance(tS/cm), fieldWADcyanidet9

8. Heap Leach Pad Gravity Application SolutionWells

Shallow, Intermediate, Deep, Bench Inspect water Daily, when inlevelt8; use:

Number of Weeklywells in use by

1; type, averageflow rate

]_(gpm)

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Permit N° XEVOOX8O 18 (Renewal 2019. Revision 00)Page 6 of 8

Identification Parameter Frequency

9. Heap Leach Pad Pressure Solution Wells

Pressure wells Inspect water Daily, when inlevel8: use:

Number of Weeklywells in use,by typeaverage flowrate (gpm)

The Permittee may request a reduction of the monitoring and frequency after four quartersof complete monitoring based on justification other than cost. Scich reductions may beconsidered modifications to the Permit and required payment of modification fees.

Abbreviations and Definitions:

ANP/AGP = Acid Neutralizing Potential:Acid Generation Potential ratio: ASTM =

American Society for Testing and Materials: CaCO3 = calcium carbonate: EPA U.S.Environmental Protection Agency; gal = gallons: gpd gallons per day: gpm = gallons perminute; gpm/ft2 = gallon per minute per square foot; MWMP Meteoric Water MobilityProcedure; N = nitrogen; NAC = Nevada Administrative Code; NDEP = Nevada Divisionof Environmental Protection; PCS = Petroleum-Contaminated Soil; pH = the negative ofthe base 10 logarithm of the activity of the hydrogen ion; SU = standard units for p1-Imeasurement; WAD = weak acid dissociable; < = less than; t$/cm = microSiemens percentimeter

Footnotes:

(1) The sump must be inspected and evacuated on a more frequent basis than weekly ifthe fluid level is above the top of the sump or the invert of any pipe which dischargesinto the sump, whichever level is lower, or if the potential exists to exceed the sumpcapacity. Records are required documenting volume, date and time of extraction toshow that sumps are maintained in this condition.

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(2) Profile I:

Rass hide \liniiia LLCDenton—Rawhide Project

Permit NC NEVOO8SO IX (Renewal 2019. Revision 00)Page? of 8

Alkalinity (as CaCO) Cadmium Magnesium Silver

Bicarbonate Calcium Manganese Sodium

Total Chloride Mercury S uliate

Aluminum Chromium Nitrate + Nitrite (as \) Thattium

Antimony Copper Nitrogen, Total (as ) Total Dissolved Solids

Arsenic fluoride pH (±0.1 sL)0 WAD Cyanide

Barium Iron Potassi urn Zinc

Beryllium Lead Selenium —

(3) When static testing6 characterization of Mined Materials shows the potential for acidgeneration as set forth in the current version of the Division guidance document“Waste Rock. Overburden, and Ore Evaluation”, the Permittee shall, as applicable,notify the Division in writing and initiate kinetic testing17 within 10 days.

If the kinetic test results indicate acid generation conditions exist, the Permittee shallsubmit in writing. within 30 days, the methods proposed for providing containmentof these materials and the anticipated impact this acid generation potential may haveon final stabilization of all components affected as defined in NAC 445A.359.

(4) When waste rock is generated in any quarter. characterization, classification, andreporting shall be in accordance with the Waste Rock Management Plan datedfebruary 2018.

(5) The Meteoric Water Mobility Procedure (MWMP) shall be performed by a Nevada-approved laboratory, in accordance with ASTM Method E 2242-13 (or the mostcurrent method).

(6) Acid Neutralizing Potential/Acid Generating Potential (ANP/AGP. also known asstatic testing or acid-base accounting) shall be performed by a Nevada-approvedlaboratory using a LECO-tvpe analysis. with full sulfur speciation ifANP/AGP < 1 .2.in accordance with the most current update of the Nevada Modified Sobek Procedure.

(7) Kinetic testing (humidity cell testing) shall be performed by a Nevada-approvedlaboratory, in accordance with ASTM Method D 5744-18 Option ‘A (or the mostcurrent approved method): tests shall be run for a minimum of 20 weeks and for alonger duration if warranted or recommended by the analytical laboratory or requiredby the Division; samples shall be collected weekly (all weeks) and measurementsshall be recorded for redox potential, p1-i, specific conductance (hiS/cm), acidityand/or alkalinity (as deemed appropriate by the laboratory). sulfate, iron (total. plusferric and ferrous speciation if total iron > 0.6 mg/L and pH < 5 SU), and dissolvedcalcium and magnesium; weekly filtered extracts per the method will be digested andanalyzed for total recoverable concentrations during week 0, 1. 2. 4. 8. 12. 16. and20: 4-week extracts thereafter (i.e.. week 24. 28, 32, etc.) shall be analyzed by a

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Permit N° N EVOI)880 18 (Renewal 21)19. Revision Of))Page 8 oF IS

Nevada-certified analytical laboratory for Profile jt2) parameters and p11, specificconductance (tS/crn), acidity and/or alkalinity shall be recorded as recommended bythe analytical laboratory; final results reported shall include initial and final static testresults6, a Profile jt2) analysis of the final leachate, all kinetic test results above, andany additional analyses required by the Division.

(8) Overflowing of gravity application solution well(s) and pressure wells, ponding ofsolution on the surface at the crest of the heap leach pad, or seepage on the side slopeof the heap leach pad must be addressed by immediate cessation of solutionapplication, which may not resume until the stability of the heap is verified and/orthe solution application rate is adjusted accordingly.

(9) Field WAD cyanide tests are to be conducted in the laboratory of the Permittee, IfWAD cyanide is detected in the Phase IV Stormwater Pond, a full Profile 1(2) analysisshall be performed by a Nevada-certified laboratory.

(10) All sample analyses resulting in a p1-I value less than or equal to 5.0 SU shall alsobe analyzed for acidity (mg/L, as CaCO3 equivalent).

(11) The sample for waste rock material shall be collected from material placed in thewaste rock facilities only. Material placed within the pits as backfill does not

require sampling.

E. Quarterly and annual monitoring reports and release reporting shall be in accordance withPart 11.3.

F. All sampling and analytical accuracy shall be in accordance with Part lIE.

G. Permit Limitations

1. The daily accumulation of flow exceeding 150 gallons per day averaged over thequarter in any leak detection sump identified in Part l.D.3.

2. The daily accumulation of flow exceeding 50 gallons per day averaged over the yearin any leak detection sump identified in Part l,D.3.

3. The daily accumulation or flow exceeding 45 gallons per day averaged over the quarterin any leak detection sump, port, or pipe identified in Parts I.D.4 and I.D.5.

4. The daily accumulation or flow exceeding 15 gallons per day averaged over the yearin any leak detection sump, port, or pipe identified in Parts I.D.4 and I.D.5.

5. failure to meet a Schedule of Compliance date or requirement.

6. The storage of process solution in a single-lined pond for more than 20 conseccitivedays for any single event.

7. Heap leach pads Phase I through Phase V, Western Extension Phase 1 and Phase 2, asmeasured vertically from the top of the synthetic liner for any point on the pad,constructed in excess of a maximum permitted elevation of 400 feet over minimum 80-mil I-IDPE liner.

8. Heap leach pad Western Extension Phase 3 and Phase 4 and Phase VI-Al as measuredvertically from the top of the synthetic liner for any point on the pad, constructed in

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Permit N° NEVOO88OI$ (Renewal 2019. Revision 00)Page 9 ol 18

excess of a maximum permitted elevation of 200 feet over minimum 80-mi! I IDPEliner.

9. Except as othertvise allowed by this Permit, a minimum 2-foot II’ceboard shall hemaintained in all ponds.

10. The cumulative solution application rate to the heap leach pad by all methods shall notexceed the permitted 6,500 gpm. Additionally, the solution application rate per tinitcirca for surface application shall not exceed 0.005 gpm/ft2. Additionally, the solutionapplication rate per unit area for surface application on Phase VI-Al shall not exceed0.002 gpmi”ft2.

Grcn’iiy So/ui/On I’Ve//s

11. A maximum of six Deep Heap Leach Pad Gravity Application Solution Wells arepetmitted. Additional wells must be approved by the Division in advance,

12. In accordance with the approved design, Deep Heap Leach Pad Gravity ApplicationSolution Wells shall be located a minimum of 80 feet from the crest of the heap leachpad lift and shall not be completed within 100 feet of the top of the heap leach pad liner.

13. A maximum of $0 Shallow and 80 Intermediate Heap Leach Pad Gravity ApplicationSolution Wells are permitted. Additional wells must be approved by the Division inadvance.

14. In accordance with the approved design, Shallow and Intermediate I-leap Leach PadGravity Application Solution Wells shall be located a minimum of 150 feet from theedge of the heap leach pad lift and a minimum of 50 feet apart.

15. In accordance with the appi’oved design, Shallow and Intermediate I-leap Leach PadGravity Application Solution wells shall be completed to depths no greater than 35 and65 feet. respectively, below the surface of the heap leach pad lift and no well shall becompleted less than 100 feet above the top of the heap leach pad liner.

16. In accordance with the approved design. Bench heap Leach Pad Gravity ApplicationSolution Wells shall be completed to depths no greater than 50 feet below the surf aceof’the bench, and no well shall be completed less than 50 feet above the top ot’the heapleach pad synthetic liner,

17. In accordance with the approved designs, no heap leach pad gravity application solutionwell shall be sealed, and solution shall not be applied at a pressure in excess of gravityhead.

Press tire Wells

1 8. The Pressure leach pad injection system shall be operated in accordance with theDivision-approved design to minimize the potential to create a phreatic surface withinthe heap material

a. Injection boreholes shall be drilled to a depth not less than 26 feet above the linersurface;

b. Boreholes shall be placed no less than 50 feet apart;

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c. Any gravity wells shall not be operated within 100 feet of an active pressure well:

d. Any two pressure solution wells shall not be operated within 300 feet of each other.

e. Two adjacent injection veils shall not receive solution simultaneously;

f Solcition shall not be applied to the surface of an area under active injection;

g. Injection shall occur for a maximum of 3 hours in one zone with 2 hours of restbefore injection to an adjacent zone;

h. A seal ring shall be used to control the zones receiving injected solution within eachcasing, both during the pressure stirncilation phase and the leaching phase;

i. Injection shall not occur until the static solcition level in the well is established, andis at or below the lowest perforations in the casing;

j Solution levels shall be monitored in all wells within 200 feet from an activeinjection well. If the solution level rises in any of these nearby wells, the injectionrate shall be reduced until the solution level drops again. If the solcition level doesnot drop in a well that initially rose, injection shall be terminated and may be movedto another well that did not exhibit a rise in solution level;

k. Injection rates shall not exceed the permitted application rates for the heap;

1. Daily visual observation of the side slopes will be conducted. If solution seepage

appears on the heap side slopes, solution injection shall be terminated and may bemoved to another zone or well that did not exhibit a rise in solution level; and

m. The Pressure injection system shall be operated in a non-sequential progression toavoid creating and sustaining a phreatic surface in the heap. The operation shall

not proceed in sequence from north to south, left to right. circular, or an’ otherpattern that causes adjacent wells to be operated in succession to one another,

19. A maximum of 106 Pressure SolLttion Wells are permitted. Additional wells must beapproved by the Division in advance.

20. The Pressure Solution Wells may only be operated under pressure during day shift.

Exceedances of these limitations may be Permit violations and shall be reported asspecified in Part 11.3.4.

1-1. The facility shall maintain an acitomated or manual calibrated rain and snow gauge(s).which shall be monitored at least daily to record precipitation (inches of water: includingsnow water equivalent). A written and/or electronic record of daily precipitation data shallbe maintained on site and shall be submitted to the Division upon request. with each Permitrenewal application, and pursuant to Parts 11.B.1 and I1.B.2, as applicable, in a Division-approved electronic format.

The Permittee shall inspect all control devices, systems, and facilities weekly, and during(when possible), and after major storm events. These inspections are performed to detectevidence of:

Deterioration, malfunction, or improper operation of control or monitoring systems;

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Permit N° XEV00880 18 (Renewal 2019. Revision 00)Page oilS

2. Sudden changes in the data from any monitoring device;

3. The presence of liquids in leak detection systems and

4. Severe erosion or other signs of deterioration in dikes. diversions. closcire covers. or

other containment devices.

.1. Prior to initiating permanent closure activities at the facility or at any process component

or other source within the facility, the Permittee must have an approved final plan for

permanent closure.

K. The Permittee shall remit an annual review and services fee in accordance with NAC

445A.232 starting July 1 after the effective date of this Permit and every year thereafter

until the Permit is terminated or the facility has received final closure certification from the

Division.

L. The Permittee shall not dispose of or ti-eat Petroleum-Contaminated Soil (PCS) on the mine

site without first obtaining from the Division approval of a PCS Management Plan.

M. When performing dust suppression activities, the Permittee shall use best management

practices and appropriate selection of water source and additives to prevent degradation of

waters of the State. If a dust suppressant exceeds a water quality standard and the

corresponding natural background water concentration in the area where dust suppression

will occcir, the Permittee shall demonstrate no potential to degrade waters of the State.

N. Continuing Investigations

1. The Permittee shall submit to the Division for review and approval an updated wasterock management plan (WRMP) with each Permit renewal and with any application to

modify the Permit that cocild affect the WRMP. A revised WRMP must also beapproved prior to initiating mining or in-pit backfill activities not previously approved.The WRMP must include representative characterization data for all anticipated wasterock and overburden in accordance with the current version of the Division guidancedocument “Waste Rock, Overburden, and Ore Evaluation,” in addition to a detaileddescription of how, when, and where the materials will be managed and monitored. andappropriate controls to eliminate any potential to degrade waters of the State, ifapplicable. Approval may require modification of’ the Permit and payment ofmodification fees.

11. General Facility Conditions and Limitations

A. General Requirements

1. The Permittee shall achieve compliance with the conditions, limitations, andrequirements of the Permit upon commencement of each relevant activity. TheAdministrator may. upon the request of the Permittee and after public notice (ifrequired). revise or modify a Schedule of Compliance in an issued Permit if he or shedetermines good and valid cause (such as an act of God. a labor strike. materialsshortage, or other event over which Pei-mittee has little or no control) exists for suchrevision.

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Permit N° NEVOO88t) 18 (Renewal 2019, Revision 00)Page I2o1l8

2. The Permittee shall at all times maintain in good working order and operate asefficiently as possible, all devices, facilities, and systems installed or used by thePermittee to achieve compliance with the terms and conditions of this Permit.

3. Whenever the Permittee becomes aware that he or she failed to submit any relevantfacts in the Permit application or submitted incorrect information in a Permitapplication or in any report to the Administrator, the Permittee shall promptly submitsuch facts or correct information. Any inaccuracies found in this information may hegrounds for revocation or modification of this Permit and appropriate enforcementaction.

B. Reporting Requirements

1. The Permittee shall submit quarterly reports in both hard copy and a Division-approvedelectronic format, which are due to the Division on or before the 28 day of the monthfollowing the quarter and must contain the following:

a. Monitoring results from the leak detection sumps, ports, or pipes identified in Parts1.0.3, 1.0.4, and I.D.5, reported on NDEP Form 0590 or equivalent;

b. Analytical results of the solution collected from 17onitoring locations identified inParts I.D.2 and I.D.7. reported on NDEP Form 0190. or equivalent:

c. The quantity of each group type of waste rock generated. if applicable. as identifiedin Part 1.D.6:

d. Analytical results of the mined material characterization, if applicable, as identifiedin Part 1.0.6. reported on NDEP Form 0190 or equivalent;

e. Monitoring results for the heap leach pad application solution wells as identified inParts 1.D.8 and 1.D.9;

f. For any kinetic test initiated, continued, or terminated with Division approval.during the quarter, provide a brief report of the test status and an evaluation of theresults to date, which shall include all analytical data generated from the date testingwas initiated through the reporting quarter; and

g. A record of releases, and the remedial actions taken in accordance with theapproved Emergency Response Plan on NDEP Form 0490 or equivalent,

Facilities which have not initiated mining or construction. must submit a quarterlyreport identifying the status of mining or construction. Subsequent to anynoncompliance or any facility expansion which provides increased capacity. theDivision may require an accelerated monitoring frequency.

2. The Permittee shall submit an annual report, in both hard copy and a Division-approvedelectronic format, by February 28th of each year. for the preceding calendar year. whichcontains the following:

a. Analytical results of the water quality sample collected from the water supplyidentified in Part 1.D.1, reported on NDEP Form 0190 or equivalent;

b. A synopsis of releases on NDEP form 0390 or equivalent;

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c. A brief summary of site operations, including the number of tons of ore placed onheaps (as applicable) during the year, construction and expansion activities, andmajor problems with the fluid management system;

d. A table of total monthly precipitation amounts and other weather data, asapplicable, recorded in accordance with Part I.H, reported for either a five-yearhistory previous to the date of submittal or the history since initial Permit issuance,whichever is shorter;

e. An updated version of the facility monitoring and sampling procedures andprotocols, as applicable;

f. An updated evaluation of the closure plan, as applicable, using specificcharacterization data for each process component with respect to achievingstabilization; and

g. Graphs of leak detection flow rates, pH, total dissolved solids (TD$), sulfate,chloride, nitrate + nitrite (as N), WAD cyanide, fluoride, zinc, and arsenicconcentration (as applicable), versus time, for all fluid sampling points. Thesegraphs shall display either a five-year history previous to the date of submittal orthe history since initial Permit issuance, whichever is shorter. Additionalparameters may be required by the Division if deemed necessary.

3. Release Reporting Requirements: The following applies to facilities with an approvedEmergency Response Plan. If a site does not have an approved Emergency ResponsePlan, then all releases must be reported as per NAC 445A.347 or NAC 445A.3473, asappropriate.

a. A release of any quantity of hazardous substance, as defined at NAC 445A.3454,to surface water, or that threatens a vulnerable resource, as defined at NAC445A,3459, must be reported to the Division as soon as practicable after knowledgeof the release, and after the Permittee notifies any emergency response agencies. ifrequired, and initiates any action required to prevent or abate any imminent dangerto the environment or the health or safety of persons. An oral report shall be madeby telephone to (88$) 331-6337 for in-State callers or (775) 687-9485 for out-of-State callers, and a written report shall be provided within 10 days in accordancewith Part I1.B.4.b.

b. A release of a hazardous substance in a quantity equal to or greater than that whichis required to be reported to the National Response Center pursuant to 40 Code ofFederal Regulations (CFR) Part 302 must be reported as required by NAC445A.3473 and Part Il.B.3.a.

c. A release of a non-petroleum hazardous substance not subject to Parts 1I.B.3.a. or1I.B.3.b., released to soil or other surfaces of land, and the total quantity is equal toor exceeds 500 gallons or 4,000 pounds, or that is discovered in or on groundwaterin any quantity, shall be reported to the Division no later than 5:00 P.M. of the firstworking day after knowledge of the release. An oral report shall be made bytelephone to (888) 331-6337 for in-State callers or (775) 687-9485 for out-of-Statecallers, and a written report shall be provided within 10 days in accordance with

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Rawhide Mining LLCDenton — Raw h de Proj ect

Permit N° N hVOQS8Q 18 (Renewal 2019. Revision 00)Page 14of 18

Part II.B.4.b. Smaller releases, with total quantity greater than 25 gallons or 200

pounds and less than 500 gallons or 4,000 pounds. released to soil or other surfacesof land. or discovered in at least 3 cubic yards of soil, shall be reported quarterly onNDEP Form 0390 or equivalent.

d. Petroleum Products and Coolants: If a release is subject to Parts II,B,3.a. orII.B.3.b., report as specified in Part IT.B.3.a. Otherwise, if a release of any quantityis discovered on or in groundwater, or if the total quantity is equal to or greater than100 gallons released to soil or other surfaces of land, report as specified in PartII.B.3.c. Smaller releases, with total quantity greater than 25 gallons but less than100 gallons, released to soil or other surfaces of land, or if discovered in at least 3cubic yards of soil, shall be reported quarterly on NDEP Form 0390 or equivalent.

4. The Permittee shall report to the Administrator any noncompliance with the Permit.

a. Each such event shall be reported orally by telephone to (775) 687-9400, not laterthan 5:00 P.M. of the next regular work day from the time the Permittee hasknowledge of the circumstances. This report shall md tide the following:

i. Name, address, and telephone number of the owner or operator;

ii. Name, address, and telephone number of the facility;

iii. Date, time, and type of incident, condition, or circumstance;

iv. If reportable hazardous substances were released, identify material and reporttotal gallons and quantity of contaminant;

v. Human and animal mortality or injury;

vi. An assessment of actual or potential hazard to human health and theenvironment outside the facility: and

vii. If applicable, the estimated quantity of material that will be disposed and thedisposal location.

b. A written summary shall be provided within 10 days of the time the Permitteemakes the oral report. The written summary shall contain:

i. A description of the incident and its cause;

ii. The periods of the incident (including exact dates and times);

iii. If reportable hazardous substances were released, the steps taken and plannedto complete. as soon as reasonably practicable, an assessment of the extent andmagnitude of the contamination pursuant to NAC 445A.2269;

iv. Whether the cattse and its consequences have been corrected, and if not, theanticipated time each is expected to contincte; and

v. The steps taken or planned to reduce, eliminate, and prevent recurrence of theevent.

c. The Permittee shall take all available and reasonable actions, including morefrequent and enhanced monitoring to:

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Rass hide Mining LLCDenton—Rawhide Project

Permit N° \EVOO8$0 18 (Renewal 2019, Revision 00)Page 15o116

i. Determine the effect and extent of each incident;

ii. Minimize any potential impact to the waters of the State arising from eachincident;

iii, Minimize the effect of each incident upon domestic animals and all wildlife;and

iv. Minimize the endangerment of the public health and safety which arises fromeach incident.

d. If required by the Division. the Permittee shall submit. as soon as reasonablypracticable. a final written report summarizing any related actions. assessments, orevaluations not included in the report required in Part ll.B.4.b., and including anyother information necessary to determine and minimize the potential fordegradation of waters of the State and the impact to human health and theenvironment. Submittal of the final report does not relieve the Permittee from anyadditional actions, assessments, or evaluations that may be required by theDivi si Ofl.

C. Administrative Requirements

• A valid Permit must be maintained until permanent closure and post-closure monitoringis complete. Therefore, unless permanent closure and post-closure monitoring havebeen completed and termination of the Permit has been approved in writing by theDivision, the Permittee shall apply for Permit renewal not later than 120 days beforethe Permit expires.

2. Except as required by NAC 445A.419 for a Permit transfer, the Permittee shall sLibmit

current Permit contact information described in paragraphs (a) through (c) ofsubsection 2 of NAC 445A.394 within 30 days after any change in previouslysubmitted information.

3. All reports and other information requested by the Administrator shall be signed andcertified as required by NAC 445A.23 1.

4. All reports required by this Permit, including, but not limited to, monitoring reports.corrective action reports, and as-built reports. as applicable, and all applications forPermit modifications and renewals, shall be submitted in both hard copy and aDivision-approved electronic format.

5. The Permittee shall submit any new or ctpdated Universal Transverse Mercator (UTM)location data for all monitoring points specified in Part I.D, expressed in meters anddecimals of a meter, using the Nevada Coordinate System of 1 983 (also known as theNorth American Datum of 1983 or NAD83), with each Permit renewal, as-built report.and monitoring plan update, as applicable. Data shall be submitted electronically tothe Division in Excel forn’iat.

6. When ordered consistent with Nevada Statutes, the Permittee shall furnish any relevantinformation in order to determine whether cacise exists for modifying, revoking and

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Rawhide Minina LLCDenton—Rawhide Project

Permit N° NEV0088018 (Renewal 2019, Revision 00)Page i6o1’18

reissuing, or permanently revoking this Permit, or to determine compliance with thisPermit.

7. The Permittee shall maintain a copy ot and all modifications to, the current Permit atthe Permitted facilities at all times.

8. The Permittee is required to retain during operation, closure and post-closuremonitoring, all records of monitoring activities and analytical results. including alloriginal strip chart or data logger recordings for continuous monitoringinstrumentation, and all calibration and maintenance records. This period of retentionmust be extended during the course of any unresolved litigation.

9. The provisions of this Permit are severable. If any provision of this Permit, or theapplication of any provision of this Permit to any circumstance, is held invalid, theapplication of such provision to other circumstances, and the remainder of this Permit,shall not thereby be affected.

1 0, The Permittee is authorized to manage fluids and solid wastes in accordance with theconditions of this Permit. Issuance of this Permit does not convey property rights ofany sort or any exclusive privilege; nor does it authorize any injury to persons orproperty, any invasion of other private rights, or any infringement of federal, State orlocal law or regulations. Compliance with the terms of this Permit does not constitutea defense to any order issued or any action brought cinder the Water Pollution ControlStatutes for releases or discharges from facilities or units not regulated by this Permit.NRS 445A.675 provides that any person who violates a Permit condition is subject toadministrative or judicial action provided in NRS 445A.690 through 445A.705.

D. Division Authority

The Permittee shall allow authorized representatives of the Division, at reasonable times.and upon the presentation of credentials to:

1. Enter the premises of the Permittee where a regulated activity is conducted or whererecords are kept per the conditions of this Permit;

2. Have access to and copy any record that must be kept per the conditions of this Permit;

3. Inspect and photograph any facilities, equipment (including monitoring and controlequipment), practices, or operations regulated by this Permit; and

4. Sample or monitor for any substance or parameter at any location for the purposes ofassuring Permit and regulatory compliance.

E. Sampling and Analysis Requirements

1. Samples and measurements taken for the purpose of monitoring shall be representativeof the monitored activity.

2. for each measurement or sample taken pursuant to the conditions of this Permit, thePermittee shall record the following information:

a. The exact place. date. and time of the inspection. observation. measurement. orsampling; and

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Rawhide Mining LLCDenton-Rahide Project

Permit N N EVOO$80 18 (Renewal 2)) 19. Revision 00)Page 7 oil 8

b. The person(s) who inspected, observed, measured. or sampled.

3. Samples must be taken, preserved, and labeled according to Division approvedmethods.

4. Standard environmental monitoring chain of custody procedures must be followed.

5. Samples shall be analyzed by a laboratory certified or approved by the State of Nevada,as applicable for the method(s) being performed. The Pei’mittee must identify in allrequired reports the certified and approved laboratories used to perform the analyses,laboratory reference numbers, and sample dates, and For the electronic version of eachreport only, include all associated laboratory analytical reports, including test results,test methods, chain-of-custody forms, and quality assurance/quality controldocumentation.

6. The accuracy of analytical results, unless otherwise specified, shall be expressed inmg/L and reliable to at least two significant digits. The analytical methods used musthave a practical quantitation limit (PQL) equal to or less than one-half the referencevalue for Profile I parameters. Laboratories shall report the lowest reasonable PQLbased on in-house method detection limit studies. Samples for Profile I parametersshall be filtered and analyzed for the dissolved fraction, unless otherwise required bythe Division. Unless otherwise approved by the Division, analytical results that are lessthan the PQL shall be reported quantitatively by listing the PQL value preceded by the“<“symbol.

F. Permit Modification Requirements

1. Any material modification, as defined at NAC 445A.365. or plan to construct a newprocess component. or proposed change to Permit requirements must be reported to theDivision by submittal of an application for a Permit modification. or if such changesare in conformance with the existing Permit. by submittal of a written notice of thechanges. The Permit modification application must comply with NAC 445A.39 1through 445A.399. 445A.410, 445A.412. 445A.4 14. 445A.4 155. 445A.41 6. 445A.41 7,445A.440. and 445A.442, as applicable. The construction or modification shall notcommence nor shall a change to the Permit be effective, until written Division approvalis obtained.

2. Prior to the commencement of mining activities at any site within the State which isowned or operated by the Permittee but not identified and characterized in a previouslysubmitted application or report, the Permittee shall submit to the Division a reportwhich identifies the locations of the proposed mine areas and waste disposal sites. andcharacterizes the potential of mined materials and areas to release pollutants. Prior todevelopment of these areas the Division shall determine if any of these new sourceswill be classified as process components and require engineered containment as wellas Permit modification.

3. The Permittee shall notify the Division in writing at least 30 days before theintroduction of process solution into a new process component or into an existingprocess component that has been materially modified, or of the intent to commenceactive operation of that process component. Before introducing process solution or

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Rawhide Mining LLCDenton-Rawhide Project

Permit N° NEV008801$ (Renewal 2019, Revision 00)Page I8of 18

commencing active operation, the Permittee shall obtain written authorization from theDlvi sion.

4. The Permittee must obtain a written determination from the Administrator of anyplanned process component construction or material modification, or any proposedchange to the Permit requirements, as to whether it is considered a Permit modification,and if so, what type.

5. The Permittee must give advance notice to the Administrator of any planned changesor activities which are not material modifications in the permitted facility that mayresult in noncompliance with Permit requirements.

Prepared by: Natasha Zittel, P.E.Date: 10 July 2019

Revision 00: Permit Renewal 2019

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