Laserfiche WebLink
11 A LeonardRice <br />ENGINEERS,INC. <br />March 20,201S <br />Eric Scott, Environmental Protection Specialist, P.G., R.G. <br />Division of Reclamation Mining and Safety <br />1313 Sherman St., Rm. 215 <br />Denver, CO 80203 <br />RE: Numeric Protection Levels for Point of Compliance Wells <br />Dear Eric, <br />Integrated Water Resources Engineering <br />Innovative Solutions for Water and Land <br />I am writing to express concerns on behalf of the Eagle Park Reservoir Company (EPRC) regarding <br />protection of groundwater quality in the vicinity of the Eagle Park Reservoir (EPR) and the East <br />Fork of the Eagle River (East Fork), which are located adjacent to the Climax Molybdenum <br />Company's (Climax) molybdenum mine property in Leadville, Colorado. The concerns are <br />associated with Climax's proposal for Numeric Protection Levels (NPLs) at two Point of Compliance <br />(POC) well locations, which are not adequate to protect groundwater quality at existing levels, and <br />which could lead to degradation of groundwater and surface water quality. Based on our recent <br />conversations, it is our understanding that the DRMS intends to adopt NPLs for the POC wells in the <br />near future. <br />CLIMAX PROPOSAL FOR NPLS <br />In its Annual Report on 2013 operations, dated March 3, 2014, Climax indicated that it believes <br />adequate data are available to establish NPLs for its POC wells, EVMW 3 S /D, and EVMW 4, which <br />are located at the property boundary near the East Fork of the Eagle River, and above the EPR <br />facility, respectively. Climax's proposed NPLs are generally based on the Colorado Basic Standards <br />for Groundwater (CBSG) tables contained in Regulation No. 41, with the exception of dissolved <br />manganese at wells EVMW 3S /D and dissolved manganese and dissolved iron at well EVMW 004. <br />Climax has suggested that ambient -based NPLs would be appropriate for those parameters. Climax <br />provided an analysis of groundwater quality as compared with CBSG table values in its Annual <br />Report (Climax 2013 Annual Report, Appendix 3), which is shown in Table 1 below.: <br />