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Integrated Water Resources Engineering <br />Leo n a r Rice Innovative Solutions for Water and Land <br />ENGINEERS,INC. <br />NPLs should not be established at levels that would allow degradation of water quality to levels that <br />are significantly higher than current conditions, particularly when quantification of groundwater <br />inflows to EPR or to the East Fork has not occurred or been presented to EPRC. Robinson Lake <br />seepage flows may also be variable over time depending on operating conditions and the condition <br />of infrastructure such as the Robinson Seep cutoff wall. <br />Climax's evaluation of baseline water quality is incomplete, and additional parameters should <br />be evaluated for potential use as indicator parameters: <br />The Environmental Protection Plan (EPP) that is included with Climax's reclamation permit as <br />Technical Revision No. 18, includes a Water Quality Monitoring Plan (WQMP) that specifies the <br />frequency of sampling and water quality constituents to be analyzed. Climax's monitoring list for <br />the point of compliance wells includes the following "indicator" parameters, which it believes are <br />adequate to identify potential changes in water quality over time, and can therefore be used for <br />early warning detection: <br />Cadmium (dis), copper (dis), lead (dis), manganese (dis), molybdenum (dis), zinc (dis), pH, <br />sulfate, and total dissolved solids. (see WQMP, Table 5 -2) <br />Additional parameters that have been analyzed during the baseline data collection period include <br />the following: <br />Aluminum (dis), antimony (dis), arsenic (dis), barium (dis), beryllium (dis), calcium (dis), <br />chromium (Crlll +CrVI, dis), cobalt (dis), magnesium (dis), mercury (dis), nickel (dis), <br />potassium (dis), selenium (dis), silver (dis), sodium (dis), thallium (dis), vanadium (dis), <br />bicarbonate (HCO3), total alkalinity, chloride (dis), cyanide (WAD), cyanide (total), fluoride <br />(dis), total nitrate + nitrite as N, total organic carbon. (see WQMP, Table 4 -1) <br />Climax's WQMP recognizes that the indicator parameters are the parameters anticipated to be <br />measured following collection of the baseline dataset; however the WQMP is clear that the results <br />of the baseline dataset would be reviewed to verify or modify the routine monitoring parameters <br />list (WQMP, pg. 14). Climax has only proposed NPLs for the indicator parameter list, and has not <br />provided an evaluation of other parameters to determine whether any should be added for <br />continued monitoring. <br />Due to the direct hydrologic connection between ground water on Climax's property and surface <br />water in EPR and the East Fork, EPRC believes that parameters should be added to the NPLs list if <br />concentrations are at or near the CBSG or surface water standards or if there is the potential for the <br />mining operation to cause a deterioration of the water quality concentration. Quarterly monitoring <br />should be maintained for those parameters so that unchecked degradation cannot occur and so that <br />trends can be evaluated. <br />7 <br />