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least the two proposed and one existing EVMW locations to establish appropriate Numeric Protection Levels <br />(NPLs) and monitor for potential groundwater impacts to the reservoir or off site impacts. <br />As previously discussed with DRMS, the existing wells may not be in suitable locations for a POC well(s). <br />As described in the revised WQMP, Climax is proposing a new POC groundwater monitoring well above <br />Eagle Park Reservoir. Climax is developing a conceptual hydrogeological model of this and other areas <br />of the mine site to help characterize groundwater flow patterns for the purpose of identifying new <br />monitoring well locations The results of this analysis will be completed in March 2012 to allow sufficient <br />time for DRMS review and approval prior to the 2012 field season. If appropriate, a shallow /deep well <br />pair will be completed if separate hydrostratigraphic units (alluvial and bedrock units) are encountered. <br />The general area of the proposed new well site is shown in the revised WQMP. <br />- Please provide DRMS with final locations of EVMW -2 and any surface springs selected for long term <br />sampling if these locations are modified from the revised Figure 3 provided to DRMS. <br />A revised Figure 3 has been included in the revised WQMP with the addition of shallow (S) and deep (D) <br />suffixes at the three well locations. <br />Tenmile Creek Basin <br />- Well construction details and historical data have not been provided for GMW -1. GMW -1 appears to be a <br />valuable internal monitoring point that should be included in the WQMP. Please detail why this well should not <br />be included in the EPP/WQMP. If GMW -1 is not suitable, will new wells be installed to replace it for internal <br />groundwater monitoring below 5 Dam and upstream of GMW -2? <br />Climax has incorporated GWM -1 as an internal monitoring location in the revised WQMP and historical <br />data and well construction details are incorporated in the appropriate appendices. <br />Water Quality Monitoring Plan — general comments <br />- The Division will require some attempt to identify, characterize, and monitor deeper groundwater (bedrock <br />vs. alluvial) in the three drainage basins. DRMS suggests that bedrock wells be installed adjacent to all <br />existing alluvial groundwater monitoring locations, and that all new wells are installed as nested pairs (one <br />shallow alluvial and one bedrock well). NPLs for deep groundwater wells (and all other new monitoring wells) <br />will be established in the same fashion as currently proposed - based on CBSG Table Values or on sampling <br />data if table values are exceeded during baseline sampling. <br />Climax incorporated this suggestion into the monitoring well drilling program conducted in 2011. Deeper, <br />bedrock wells were constructed at monitoring locations EVMW -1 (former EVMW site), EVMW -2 and <br />EVMW -3. As mentioned in previous responses, Climax is developing a conceptual hydrogeological <br />model of the mine site to help characterize groundwater flow patterns for the purpose of identifying new <br />monitoring well locations The results of this analysis will be completed in March 2012 to allow sufficient <br />time for DRMS review and approval prior to the 2012 field season. Based on the results of this <br />characterization, Climax will construct deeper, bedrock wells adjacent to ARwell in the Arkansas River <br />Watershed, and adjacent to GWM -1 and GWM -2 in the Tenmile Creek Watershed. These changes have <br />been incorporated in the revised WQMP. The construction of these deeper wells will be dependent on <br />the presence of more than one hydrostratigraphic units at these locations. The siting of additional internal <br />10 <br />