2018-03-26_REVISION - M1977493 - Laserfiche WebLink

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COLORADO Division of Reclamation, AV- Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, Colorado 80203 March 26, 2017 Climax Mine Attn: Mr. Ray Lazuk Highway 91 Climax, CO 80429 RE: File M 1977493; Climax Mine; Technical Revision 27 (TR27) - Water Quality Monitoring Plan, Revision 4 Mr. Lazuk: The Division of Reclamation, Mining and Safety received Technical Revision 27 - Water Quality Monitoring Plan, Rev. 4, on March 5, 2018. The decision date for this revision is currently set at April 4, 2018, Please be advised that if you are unable to satisfactorily address any concerns identified in this review before the decision date, it will be your responsibility to request an extension of the review period. If there are outstanding issues that have not been adequately addressed prior to the end of the review period, and no extension has been requested, the Division must deny this revision. DRMS has completed the initial adequacy review of TR27. As with most revisions of this scope and complexity, there are items that will require clarification of the existing information or submittal of additional information. The first paragraph of section 5.1 of the submitted WQMP correctly states: "The Interim Narrative Statewide Standard (CBSG Section 41.5(C)(6)(b)(i)) provides that "ground -water quality shall be maintained for each parameter at whichever of the following levels is least restrictive: (A) existing ambient quality as of January 31, 1994, or (B) that quality that meets the most stringent criteria set forth in Tables 1 through 4 of [CBSG]". However, the remainder of section 5.1 of TR27 as submitted seems to state that through this revision Climax intends to modify the approved permit to seUadopt NPLs (numeric protection Ievels) equal to the most stringent criteria set forth in Tables 1 through 4 (Table Value Standards or TVS) for only the nine listed parameters, defined by Climax as "indicator parameters", at the listed points of compliance. DRMS cannot exempt Climax from the full requirements of the Interim Narrative Standard. Modifications to the Interim Narrative Standard Table Value Standards, including the analyte list, may only be granted by WQCC through the site specific classification and standards process. DRMS acknowledges that Climax intends to address existing manganese values in the Eagle River and Arkansas River basins through a recently initiated process involving the WQCD and WQCC to develop site specific groundwater classifications and standards for manganese. However, with the exception of manganese in the Eagle River and Arkansas River basins, DRMS and WQCD have determined that WQCC Regulation 41 table value standards for all analytes listed in Tables 1 through 4 apply to the Climax site. Climax will need to modify the approved permit to adopt the table value standards of WQCC Regulation 41 for all analytes, other than manganese, listed in Tables 1 through 4 as NPLs at the points of compliance at this time. pF - Cp`� 1313 Sherman Street, Room 215, Di-wor, CO 80203 P 303.866.3567 F 303.832.8106 http://mining,state,€o.us John W. Hickentooper, Governor I Robert W. Randall, Executive Director I Virginia Brannon, Director * r + 1876 {