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Demonstration of Compliance Climax Molybdenum Company <br /> With Regulation 41 Permit M-1977-493 <br /> 1.0 INTRODUCTION <br /> This document provides a review of the Climax Molybdenum Company— Climax Mine (Climax) <br /> groundwater monitoring plan and available site groundwater monitoring data. These data are <br /> then compared against the Interim Narrative Standard as contained in the Colorado Department <br /> of Public Health and Environment (CDPHE) Water Quality Control Commission (WQCC) <br /> Regulation 41 —The Colorado Basic Standards for Groundwater(CBSG). <br /> 1.1 Regulatory and Historical Framework <br /> The Climax Water Quality Monitoring Plan (WQMP) was prepared pursuant to Rule 3.1.7(5) of <br /> the Mineral Rules and Regulations of the Colorado Mined Land Reclamation Board for Hard Rock, <br /> Metal, and Designated Mining Operations. The WQMP establishes a formal monitoring program <br /> to demonstrate that the Environmental Protection Plan (EPP) requirements are being met. The <br /> WQMP was originally approved by DRMS in December 2011 as a component to the EPP <br /> submitted as part of Technical Revision 18 (TR-18) to Climax Reclamation Permit. <br /> Prior to submittal to DRMS as TR-18, the WQMP was provided to representatives from Eagle <br /> Park Reservoir Company and Clinton Ditch & Reservoir Company for review and comment. <br /> Climax met with representatives of these reservoir companies and exchanged comments and <br /> responses on several separate occasions before and after TR-18 was submitted to DRMS. As a <br /> result of these discussions, the WQMP contains monitoring and reporting conditions specific to <br /> the monitoring sites above Eagle Park and Clinton Reservoirs in addition to those that would be <br /> required under DRMS rules. <br /> The 2011 WQMP was updated with information on new monitoring locations, including <br /> groundwater point of compliance (POC) wells and internal groundwater monitoring locations <br /> between mine facilities and downgradient points of compliance. The current WQMP was <br /> approved in 2014 with a revised EPP as TR-24. <br /> Section 5.1 of the WQMP incorporates the Interim Narrative Statewide Standard, CBSG <br /> 41.5(C)(6)(b)(i), that requires groundwater quality to be maintained for each parameter at <br /> whichever of the following levels is least restrictive: existing ambient quality as of January 31, <br /> 1994, or the most stringent criteria set forth in Tables 1 through 4 of the CBSG. In paragraph <br /> 41.5(C)(6)(b)(iii), implementing agencies, including DRMS in this instance, are to exercise their <br /> best professional judgment as to what constitutes adequate information to determine or estimate <br /> existing ambient quality, taking into account location, sampling date, and quality of all available <br /> data. Data generated subsequent to January 31, 1994, shall be presumed to be representative <br /> of existing quality as of January 31, 1994, if the available information indicates that there have <br /> been no new or increased sources of groundwater contamination initiated in the area in question <br /> subsequent to that date. <br /> Colorado Revised Statute (C.R.S.) 25-8-202(7) and the December 14, 2010 Memorandum of <br /> Agreement (MOA) between CDPHE, WQCC, and DRMS confirm that WQCC is the entity solely <br /> responsible to adopt water quality standards and classifications for state waters. The MOA <br /> recognizes the responsibility of each agency for protecting water quality within the State of <br /> Colorado. The WQCC has not established classified uses for groundwater at or near Climax for <br /> December2016 1 <br />