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LeonardRice <br />ENGINEERS,INC. <br />LRE REVIEW OF CLIMAX'S PROPOSED NPLS <br />Integrated Water Resources Engineering <br />Innovative Solutions for Water and Land <br />LRE has conducted a review of the information provided by Climax and provides the following <br />summary of findings: <br />Climax's proposed NPLs do not protect groundwater quality at existing levels, and may <br />authorize impairment of current or future uses of the groundwater and /or adjacent surface <br />water. <br />During the drafting of Technical Revision 18 (TR -18) to AM -06, EPRC opposed the use of NPLs <br />based on CBSG values alone, and stated that ambient quality for parameters that have better water <br />quality than the CBSG values should be considered in establishing NPLs. Climax and EPRC disagreed <br />on the application of ambient quality in this situation. <br />Table 2 shows the large disparity between existing ambient quality and Climax's proposed NPLs <br />based on CBSG data. For most parameters, the proposed NPLs are an order of magnitude or more <br />higher than the existing ambient quality, and if groundwater quality were to increase to these <br />levels, it would exceed surface water standards in the EPR and East Fork by large multiples. For <br />example, the proposed dissolved copper NPL is over 300 times higher than the existing ambient <br />quality and over 100 times higher than the surface water standards in Eagle Park Reservoir. <br />5 <br />