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Plan for Adoption of NPLs Climax Molybdenum Company <br /> at Groundwater POC Wells Permit No. M-1977-493 <br /> 3.0 Plan for Discussions with DRMS, WQCD & WQCC regarding Site- <br /> Specific Standards for Manganese <br /> The principal steps associated with working with DRMS, WQCD and WQCC are shown in Figure <br /> 1. The estimated durations are based on best professional judgment and experience; inherent in <br /> the steps are the needs to analyze data and evaluate results, and allow time for DRMS and <br /> WQCD to review information and provide questions or comments, and time for Climax to review <br /> and respond accordingly. All milestone and meeting dates are approximate, providing an initial <br /> goal or tentative date, subject to the availability of all needed participants. Summary descriptions <br /> of the efforts associated with each step are provided below. <br /> Step 1: Kick-off Meeting with DRMS and WQCD <br /> Climax proposes a process kick-off meeting among Climax, DRMS, WQCD, including staff of the <br /> WQCC as they deem appropriate; the weeks of March 19 or March 26, 2018 are targeted for a <br /> kick-off meeting. The primary purpose of the meeting will be to discuss the process and seek <br /> agency guidance for establishing site-specific classifications and standards for manganese, the <br /> roles of each of the parties, and the requirements for each of the subsequent steps of the process. <br /> Climax will be prepared to discuss potential approach(s) for the analysis of existing data and <br /> information to define the following for use in a site-specific process for manganese: <br /> • Use Classification; <br /> • Specified Areas; <br /> • Representative manganese concentrations; and <br /> • Applicable groundwater quality standards for manganese. <br /> Climax will be prepared to conceptually discuss potential and existing uses of groundwater in the <br /> vicinity of the mine, monitoring and POC locations in each basin, property boundaries, and <br /> variability of manganese concentrations both spatially and between aquifers. The proposed <br /> schedule for additional tasks described below will also be discussed to determine the <br /> appropriateness of the suggested dates for subsequent meetings. The timeframes for the <br /> completion of the remaining steps may be refined based on the discussions in this first meeting. <br /> Step 2: Technical Analyses of Existing Data and Consultation <br /> Based on the results of discussions with WQCD and DRMS during the initial meeting, Climax will <br /> begin aggregating and evaluating existing groundwater quality data, operating parameters, <br /> property boundaries, on-site groundwater uses, off-site groundwater uses/conditions, and attempt <br /> to identify topics for further discussion or consideration reaching technical and policy consensus <br /> respecting site-specific standards for manganese in the Arkansas and Eagle River basins. It is <br /> anticipated that these topics will include use classifications, specified areas, site-specific <br /> standards, POC locations, and the identification of NPL values for DRMS use as the implementing <br /> agency. It is anticipated that the initial technical evaluation by DRMS, WQCD and Climax will <br /> require approximately 3 to 4 months, assuming that no additional data collection or site <br /> investigations are required that would extend this timeline. <br /> As a part of this step, Climax also proposes several progress meetings with WQCD and DRMS <br /> to discuss interim results and processes, and to obtain consensus. These meetings are <br /> tentatively proposed for early May and the end of July. <br /> Page 3 <br />