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Corrective action #2: <br />The Operator shall, within 120 days of the signature date of this inspection report, provide to the <br />Division the laboratory results of such analyses, include a report summarizing the results, <br />describing where the material will be moved to accordingly, and providing an estimated timeline <br />for completion. <br />CC& V's response: Due to the potential for metal mobility focus was given to obtaining TCLP <br />results with a Total Metals analyses; the results are found in Attachment 1. With the exception of <br />Barium, all results were at the practical quantification level (PQL). In fact, TCLP results <br />indicated elements As, Ba, Cd, Cr, Pb, Hg, Se, and Ag were between 2 and 3 orders of <br />magnitude lower than the regulatory limits set for the procedure indicating that only a trace <br />concentration of these elements exist in the rock material. <br />The Net Neutralizing Potential (NNP), or the potential for a rock mass to neutralize acid, was <br />determined for each of the sampling locations. All six samples were analyzed for acid generation <br />potential and acid neutralizing potential. A summary of the Acid Base Accounting (ABA) <br />laboratory results can be seen below in Table I whilst a fill report analyses are found in <br />Attachment 1. All samples were found to have a NNP between 0 and -20. <br />Based ort literature from Fey (1003), NNP values between -20 kg/ton CaCO3 and 20 kg1lon <br />CaCO3 are considered in the range of uncertainty whether acid will be generated or remain a <br />neutral pH. Any sample with NNP <20 is potentially acid generating, while any sample with <br />NNP > -20 might not generate acid (de Wet, 1012). <br />Table 1 : Chicago Tunnel Acid Base Accounting (ABA) Summary <br />Sample Location <br />Acid Generation Potential <br />(t CaCOVM) <br />Acid Neutralization <br />Potential <br />t CRC03/gt <br />Net Neutralizing Potential <br />(t CaCOWIM) <br />#1 <br />19.1 <br />5.0 <br />-14.1 <br />#2 <br />14.7 <br />5.0 <br />-9.7 <br />#3 <br />15.6 <br />7.0 <br />-8.6 <br />#4 <br />11.3 <br />6.0 <br />-5.2 <br />#5 <br />10.0 <br />5.0 <br />-5.0 <br />#6 <br />11.3 <br />6.0 <br />-5.2 <br />CC&V estimates approximately 5,000 tons of development rock material is present in the piles <br />shown in Figure 1. Given the short residence time of the rock material and its very low <br />likelihood for metal mobility away from the piles, CC&V proposed to address the final <br />management of the identified stockpiles within the Cresson Project Amendment 12 submission, <br />due to be submitted to the State in mid -2017. Options currently being considered for the <br />management of the material include; <br />• Insittr reclamation of the material; <br />• Relocation of the material <br />PortalrAdit Buttressing); or <br />• Relocation of the material <br />ECOSA). <br />to an appropriate location at the Chicago Tunnel Site (Eg <br />to an appropriate location at the Cresson Project Site (eg <br />