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0.8 percent sulfur have been underlain by neutralizing rock or amended with lime. 4. According to the Division's interpretations of data and consultants reports provided by the Operator, a significant amount of waste rock from the Cresson pit has the potential to generate acid or toxic substances (i.e. dissolved metals), or both, in excess of appropriate surface water quality standards or groundwater conditions, or both. The Operator has disagreed with this position on several occasions, but has not conducted adequate testing or calculations to support their alternative interpretations. All previous submittals, including both reports by David Hyatt, the report by McClelland Laboratories, the report by Kim Lapakko, the report by HCI, and.the Operators submittals have been examined by the Division and determined not to support the Operator's position. Because of this unresolved situation, the Division is proceeding with the interpretation that the potential exists for the waste rock to produce acid or toxic substances in excess of appropriate standards or conditions, unless such waste rock is adequately amended or protected from weathering. Therefore, within 10 working days from receipt of this letter, the Operator must provide the Division with adequate testing or calculations showing that any release of acid or toxic substances will not exceed TVS for surface water at AG 1.5. Furthermore, within 10 working days, the Operator must provide the Division with adequate testing or calculations showing that the release of such acid or toxic substances will not exceed ambient groundwater conditions as measured in the Carlton Tunnel discharge. 5. The Operator has disagreed with the Division's interpretation of what constitutes "appropriate standards." The Division iterates again that the appropriate standards to be applied are those that might reasonably be expected to be in place at the time the mine closes. For surface water, the Division anticipates that temporary modifications or technology based standards imposed during mining will be removed after mining, and that table value standards will prevail. For groundwater, the Division allows for metal concentrations equal to the ambient condition or to the current drinking water standards, whichever is higher. Therefore, these are the protocols that the Operator must follow in evaluating potential discharges from acid-generating or metals leachable waste rock. 6. As is evident from the above presentations, the Operator has not timely supplied verification of the sulfur content of waste rock, as placed, or that high sulfur waste rock has been adequately amended. As such, the Operator has not verified, with records, that permit conditions are being adhered to. Therefore, within 10 working days, the Operator must provide to the Division a verification monitoring protocol, for Division review, that will adequately identify the sulfur