Contract analysis

Section 1: Executive Summary 1.1 Purpose and Scope of This Document This document constitutes the Framework and Outline for the Ridgecrest Remedial Action Work Plan (the "Work Plan") required under the consent decree entered in United States of America and State of Montana v. Torchlight Mining Corp. et al., Civil Action No. 9:24-cv-00087-DWM, United States District Court for the District of Montana, Missoula Division

Section 2: Site Description and Background 2.1 Site Location and Physical Setting The Ridgecrest Copper-Molybdenum Mine is located in Granite County, Montana, approximately 12 miles northwest of the town of Drummond. The Site is accessed via Ridgecrest Mine Road, which connects to Montana State Highway 1 approximately 7 miles south of the mine gate. The property is situated in the upper Flint Creek Valley, within the

Section 3: Remedial Action Objectives (RAOs) 3.1 Overall Remedial Goals The remedial action objectives for the Ridgecrest Site, as established in the Consent Decree and further developed through the RI/FS process, are as follows:

1. Eliminate unpermitted discharges. Eliminate all unpermitted discharges of pollutants from the Ridgecrest Site to Flint Creek, its tributaries, and all other waters of the United States, thereby achieving compliance with CWA § 301 and applicable MPDES permit conditions.

2. Achieve surface water quality standards. Achieve and maintain compliance with applicable Montana surface-water quality standards for all COCs at designated compliance points on Flint Creek and its tributaries, with particular emphasis on achieving the chronic aquatic life standard for copper of 0.0087 mg/L.

3. Stabilize and contain the tailings impoundment. Stabilize the tailings impoundment embankment to ensure long-term geotechnical integrity and construct containment systems to prevent further seepage of contaminated water from the impoundment to surface water and groundwater.

4. Manage hazardous waste. Properly inventory, characterize, manage, treat, and/or dispose of all hazardous wastes associated with the SX/EW circuit in compliance with RCRA § 3004 and applicable RCRA closure and corrective action requirements.

5. Restore groundwater quality. Restore groundwater quality to applicable Montana groundwater quality standards and/or federal maximum contaminant levels ("MCLs") at designated compliance points within a reasonable timeframe, recognizing that groundwater restoration is a long-term objective that may extend through and beyond the 30-year remediation obligation period.

6. Long-term site stability. Achieve and maintain long-term site stability to protect human health and the environment, including ensuring the physical integrity of mine waste containment structures, maintaining institutional controls, and providing for long-term stewardship of the Site beyond the active remediation period. 3.2 Contaminant-Specific Cleanup Standards The remedial action will be designed to achieve the

Section 4: Remedy Selection Summary 4.1 Selected Remedy Overview The selected remedy for the Ridgecrest Site, as agreed upon in the Consent Decree, addresses three principal components of environmental contamination:

1. Acid Mine Drainage Treatment System — Construction and long-term operation of a permanent active water treatment plant to intercept, collect, and treat AMD from the open pit, waste rock dumps, and other sources prior to discharge.

2. Tailings Impoundment Stabilization and Containment — Installation of a seepage interception and collection system, construction of an engineered cover system over the tailings surface, embankment stability improvements, and stormwater management infrastructure.

3. Flint Creek Water Quality Restoration — Implementation of in-stream and riparian measures to address contamination that has already reached Flint Creek, coordination with the SEP, natural attenuation evaluation for downstream areas, and a comprehensive biomonitoring program to track ecological recovery. In addition, the remedy includes proper management and disposal of hazardous waste from the SX/EW circuit and RC

Section 5: Remedial Action Phasing and Schedule 5.1 Phasing Overview The remedial action at the Ridgecrest Site is organized into four sequential phases, each with defined objectives, activities, and mile