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PLAN FOR ADOPTION OF NUMERIC PROTECTION LEVELS AT <br /> GROUNDWATER POINT OF COMPLIANCE WELLS <br /> Climax Molybdenum Company— Climax Mine <br /> DRMS Reclamation Permit No. M-1977-493 <br /> 1.0 Introduction <br /> The Climax Mine (Climax) Water Quality Monitoring Plan (WQMP) was prepared for the Division <br /> of Reclamation, Mining and Safety (DRMS) pursuant to Rule 3.1.7(5) of the Mineral Rules and <br /> Regulations of the Colorado Mined Land Reclamation Board (MLRB) for Hard Rock, Metal, and <br /> Designated Mining Operations. The WQMP established a formal monitoring program to <br /> demonstrate that the Environmental Protection Plan (EPP) requirements are being met as well <br /> as a formal process for determining numeric protection levels (NPLs) at groundwater point of <br /> compliance (POC) wells. The WQMP was approved by DRMS in December 2011 as a <br /> component of the EPP submitted as Technical Revision 18 (TR-18) to the Climax Reclamation <br /> Permit during the restart of Climax operations. Version R3 of the WQMP, approved by DRMS as <br /> TR-24 in 2014, superseded the 2011 WQMP with updated information on new monitoring <br /> locations, including groundwater points of compliance(POC) and internal groundwater monitoring <br /> locations between mine facilities and downgradient POC wells. <br /> Section 5.1 of the WQMP references the Interim Narrative Statewide Standards of Regulation 41 <br /> Colorado Basic Standards for Groundwater (CBSG). Regulation 41.5(C)(6)(b)(i) provides that <br /> "ground-water quality shall be maintained for each parameter at whichever of the following levels <br /> is least restrictive: (A) existing ambient quality as of January 31, 1994, or (B) that quality that <br /> meets the most stringent criteria set forth in Tables 1 through 4 of [CBSG]". In paragraph <br /> 41.5(C)(6)(b)(iii), the WQCC stated its intent that implementing agencies "exercise their best <br /> professional judgment as to what constitutes adequate information to determine or estimate <br /> existing ambient quality,taking into account the location, sampling date, and quality of all available <br /> data." As described in both TR-18 and TR-24, the DRMS-approved EPP adopted NPLs for two <br /> wells using both the CBSG tables and existing ambient quality. <br /> This submittal responds to DRMS's request that Climax submit a plan, due January 18, 2018, for <br /> modifying its Reclamation Permit to establish numeric protection levels consistent with Regulation <br /> 41 for identified POC locations, and for pursuing discussions with the Water Quality Control <br /> Division (WQCD) and Water Quality Control Commission (WQCC) to consider setting <br /> groundwater classifications and associated site specific manganese standards. <br /> The following sections of this document provide the plan requested by DRMS, including a <br /> proposed timetable for Climax actions that will request a revision of Permit M-1977-493 to set <br /> NPLs in the WQMP that reflect CBSG table values except for manganese in the Arkansas River <br /> and Eagle River basins, and to initiate discussions with WQCD and WQCC regarding site specific <br /> groundwater classifications and site specific standards for manganese in the Arkansas River and <br /> Eagle River basins. The steps in the processes are described below; and the attached Figure 1 <br /> presents a Gantt chart schedule to graphically present the proposed schedule. Climax notes that <br /> because the steps in the schedule involve agency processes and that any agency process can <br /> be affected by other priorities and commitments of the agency and by actions of third parties over <br /> Page 1 <br />