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Integrated Water Resources Engineering <br />Leo n a r Rice Innovative Solutions for Water and Land <br />ENGINEERS,INC. <br />Baseline water quality should be established for all water quality parameters <br />If DRMS authorizes Climax to reduce or remove monitoring requirements for any of the baseline <br />parameters, it is still necessary to characterize baseline quality using the recently collected baseline <br />data, so that a reference point will be available for all parameters that were included in the baseline <br />dataset. The analysis of baseline conditions should be conducted at the time a parameter is <br />removed in order to make it clear that baseline conditions have been established. If future <br />monitoring shows degradation for parameters that have been removed from consideration, that <br />degradation should be evaluated against the established baseline conditions to determine if <br />detrimental impacts have occurred as a result of operations at the Climax Mine. <br />LRE RECOMMENDATIONS FOR IMPLEMENTING MORE PROTECTIVE GROUNDWATER <br />MEASURES <br />The EPRC has worked closely with Climax since the mine was reopened in 2012, and Climax's <br />recent efforts to monitor potential pollutant sources, such as the Robinson Seep discharge are <br />commendable, but do not substitute for the underlying objective of the EPRC to protect its surface <br />water quality at existing levels. Climax and the EPRC have entered into Agreements that afford <br />additional water quality protections to the EPR and East Fork, and those agreements may be relied <br />upon in the future if necessary. The 1998 Reservoir Purchase Agreement prohibits Climax from <br />undertaking actions that adversely affect the quality of water that can be collected by Eagle Park <br />Reservoir, and requires Climax to pump capture and pump back any and all groundwater, surface <br />water, seepage or other water released or escaping from Robinson Reservoir. The adoption of CBSG <br />values as NPLs could put Climax on a path that would allow it to violate the Reservoir Purchase <br />Agreement and the Stipulated AM -06 Settlement Agreement. <br />The DRMS has an important role in establishing NPLs or other regulatory and non - regulatory <br />measures that should be protective of current and future uses of groundwater. If the DRMS adopts <br />Climax's proposed NPLs, it would pose a significant risk to surface water quality in EPR and the <br />East Fork as a result of hydrologically connected groundwater. <br />Climax's EPP acknowledges that there is a direct hydrologic connection between groundwater <br />occurring on its property and the East Fork and EPR facility. <br />"The current use ofgroundwater is limited to recharge of the East Fork Eagle River and Eagle <br />Park Reservoir, which are classified for aquatic life, recreation, water supply, and agricultural <br />uses." (Climax Environmental Protection Plan, Appendix T -C, Water Quality Monitoring Plan, <br />Section 3.2.1, Existing and Potential Future Uses of Groundwater) <br />Also, DRMS's rules authorize the use of NPLs or other permit conditions to provide protection for <br />unclassified groundwater uses: <br />(2) Establishing permit, or notice of intent to conduct prospecting (NOI), conditions, including <br />numeric protection levels, protective of unclassified groundwater uses. <br />8 <br />