1996-02-06_REVISION - M1977493 (11)

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Mr. Allen Sorenson Division of Minerals and Geology February 1, 1996 Page 2 Division review of the Climax Ground Water Technical Revision, TR -08. 4. CMC does not agree that submitting either a surface water monitoring plan or existing surface water quality data for the Arkansas River and the Eagle River basins is necessary or appropriate. We indicated in Part 1.1.1 of the EPP, Referencing and Indexing, that information currently in the public record, either by submittal to the WQCD or to DMG would not be resubmitted. There was no indication in your November 29, 1995 letter that this was unacceptable. Water quality data is presently available in the public record for both the Arkansas River and the East Fork of the Eagle River. CMC has submitted surface water quality data required by Rule 6.4.19(11)(b) for Tenmile Creek in Discharge Monitoring Reports. Surface water data for the Tenmile drainage is available in the Climax CPDS files as part of permit data. Conditions at Climax Mine and Mill have not changed to warrant the need for the submittal of all existing surface water data, and the Division has not provided any additional justification to require this information. Climax maintains an water monitoring program that is formulated to maintain process control of the water treatment system, to comply with requirements and terms of the Climax CPDS Permit, and to develop a baseline data for what has been long -term involvement in regional water quality dialog. The surface water data that has been collected by CMC consists of data from many location and for various constituents. Since much of the data has been for internal use, it has not been subject to rigorous QA/QC, and has frequently changed both in terms of sampling locations and analytical parameters. Much of this data does not exist in electronic form making the preparation of tabulated data, as requested by the Division, an extremely time consuming exercise. Its use to the Division, without further information as to the nature of this request, is questionable. These monitoring activities have not historically been conducted to assess adequacy of Environmental Protection Facilities (EPF's) nor are they necessarily meaningful to assess this adequacy. Climax Molybdenum does not believe that a surface monitoring plan is justified for the Climax Mine and Mill. Rule 6.4.19(12) requires that a surface water monitoring plan be proposed where necessary to demonstrate that all EPF's designed to protect water quality are functioning as designed. Rule 6.4.19(12) also states that CPDS permit requirements may be adequate to meet the requirements of this Part. You will note from the August submittal of the Environmental Protection Plan Technical Revision application that engineered components of the Climax water treatment system identified as EPF's function as water handling systems that direct water either around the Climax Process facilities or to treatment. The failure of any specific EPF in water handling may effect compliance with the Climax CPDS Permit. Other EPF's at Climax relate to the containment of Designated Chemicals and are not directly designed to protect water quality. Surface water monitoring is not necessary to determine the adequacy of the secondary containment structures at the facility. Such monitoring would only be useful in the event of total failure of a containment facility. These containment structures are already subject to inspection requirements under the SWMP and SPCC requirements.