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Plan for Adoption of NPLs Climax Molybdenum Company <br /> at Groundwater POC Wells Permit No. M-1977-493 <br /> which Climax has no control, this schedule is presented as a proposal with the recognition that <br /> the schedule may require revision. <br /> Overview of Plan Contents: <br /> A. Climax to submit to DRMS an updated WQMP that adopts CBSG table values as NPLs <br /> as provided for in the Interim Narrative Standard for all POC wells currently identified in <br /> the WQMP, with the exception of manganese in the Arkansas River and Eagle River <br /> basins, <br /> B. Steps to pursue discussions with DRMS, WQCD and WQCC regarding site-specific <br /> groundwater standards: <br /> 1. Kick-off Meeting with Climax, DRMS, WQCD, and WQCC staff <br /> 2. Technical analysis of existing data and consultation with DRMS and WQCD <br /> 3. Consultation with DRMS, WQCD, and WQCC as to consensus on technical, policy, <br /> timing and procedural issues <br /> 4. Decisions as to next steps in the WQCC and DRMS processes <br /> 2.0 Plan to Update Water Quality Monitoring Plan to Adopt CBSG Table <br /> Value NPLs <br /> Climax will prepare an updated WQMP that proposes adoption of the most stringent criteria set <br /> forth in Tables 1 through 4 of CBSG table values as NPLs, with the exception of manganese in <br /> the Arkansas River and Eagle River basin, for all POC wells currently identified in the WQMP. <br /> NPLs for manganese in the Arkansas River and Eagle River basins will not be proposed in this <br /> revision. This WQMP revision will be submitted to DRMS as a Technical Revision (TR). This <br /> revision will contain much of the same information as TR-18 (December 2011) and TR-24 <br /> (September 2014) but with updated information and water quality data to reflect current <br /> conditions. The updated WQMP will also include an evaluation of the baseline monitoring data <br /> and present a final indicator parameter list for long-term monitoring. The revision will specify NPLs <br /> for all indicator parameters in groundwater with the exception of manganese in the Arkansas and <br /> Eagle River basins. It is anticipated that proposed NPLs will be based on the most stringent <br /> criteria set forth in Tables 1 through 4 of the CBSG, as provided for in the Interim Narrative <br /> Statewide Standards. The submittal of the WQMP TR is targeted for late February or early March, <br /> as shown on Figure 1. <br /> The development of the revised WQMP TR will not be dependent on the proposed WQCC <br /> consultation process for manganese. However, Climax will submit the TR to DRMS in advance <br /> of a proposed multi-party kick-off meeting described in the following section for the WQCC <br /> process so that any questions or concerns with the proposed revisions to the WQMP can be <br /> discussed at that meeting as well. <br /> Page 2 <br />