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Climax Mol <br />A Freeport- McMoRan Company <br />February 3, 2015 <br />Sent by Certified Mail <br />Eric Scott <br />Environmental Protection Specialist <br />� Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Climax Mine <br />Hwy 91 — Fremont Pass <br />Climax, CO 80429 <br />Phone (719) 486 -2150 <br />Fax (719) 486 -2251 <br />Re: Proposed NPLs for POC Wells - Climax Mine, Permit No. M- 1977 -493 <br />Dear Mr. Scott: <br />Climax has completed baseline data collection at Point of Compliance (POC) wells to calculate Numeric <br />Protection Levels (NPLs) for the Indicator Parameter list specified in the Water Quality Monitoring Plan <br />(WQMP) of the Environmental Protection Plan (EPP). Two POC wells (ARwell and GW #2) had <br />previously established NPLs in the EPP -WQMP (TR -18 and TR -24). Climax continued to collect <br />baseline data from other POC wells to calculate NPLs according to Section 5.1 of the WQMP. The <br />attached spreadsheet shows the results of the calculations and the proposed NPLs for these other wells. <br />NPLs for indicator parameters were originally submitted with the 2013 Annual Report to DRMS. <br />Following the methods stated in Section 5.1 of the WQMP, Climax calculated the mean concentration <br />plus two standard deviations of valid data collected during the monitoring period. The NPL was then <br />determined by comparing the result of this calculation to the Colorado Water Quality Control <br />Commission Basic Standards for Groundwater (CBSG) table value; if the result was above the CBSG <br />table value the ambient data calculation was proposed as the NPL, otherwise the proposed NPL was set at <br />the CBSG table value. Due to observed seasonal variability of dissolved iron and dissolved manganese at <br />well EV -MW -004, and dissolved manganese at wells EVMW -3S, EVMW -3D and TM- MW -002D, <br />Climax had requested and DRMS approved, monthly monitoring at these sites for those specific <br />parameters during 2014. <br />Data from well ARK- MW -00 ID also show apparent seasonal variability in groundwater concentrations <br />for several constituents, including dissolved manganese and dissolved iron (see attached spreadsheet). <br />Climax therefore requests that DRMS allow further monitoring at that site in 2015 to characterize <br />conditions and establish NPLs for all indicator parameters. With DRMS concurrence, Climax will begin <br />monthly monitoring at ARK- MW -00 ID and the results will be reviewed at the end of 2015 to establish <br />appropriate NPLs. <br />Please contact me at 719 - 486 -7584 if you have any questions on the attached data. <br />Sincerely, <br />Raymond Lazuk <br />Environmental Manager <br />attachments <br />