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conditions, and for failure to maintain adequate records, and <br />taken to the Board. <br />Note: <br />The operator's statement that the Division required sulfur or <br />carbon analyses is not supported by anything I am aware of. <br />The sulfur analyses, if keyed to the disposition of waste <br />rock, would be useful, but only if we could show that the <br />waste rock sulfur content was directly tied to acid rock <br />generation potential and to metals release potential. Neither <br />of these has been proved. <br />4. Problem <br />Even assuming that waste rock having the low (<0.8~) sulfur <br />content needs no protection, the corollary is that the high 1 <br />sulfur rock does need protection. However, there are no V <br />measures in place at this time to assure such protection, and <br />so there is no bond to cover such measures. <br />Solution <br />The .operator should submit, within 30 days, an amendment to <br />the EPP showing how the high sulfide waste rock will be <br />protected from weathering. This may include capping or other <br />,/\, means acceptable to the Division. If the Operator cannot find <br />Iv a solution to the problem, the Division should consider <br />issuing a possible violation for failure to meet permit <br />conditions by providing adequate protection to the hydrologic <br />balance. <br />Final notes. The permit was approved on the condition that the <br />Operator would resolve the issues of acid rock drainage (including <br />metals generation) within 6 months. We are now nearly three years <br />into the operation, and the issue is still not resolved. Despite <br />the Division's determinations and the conclusions of four <br />consultants reports, the Operator still maintains that there is no <br />potential for generation of acid rock drainage from the waste rock. <br />'Also, the operator has consistently clouded the record by providing <br />"cover reports" to the consultants' reports which recount sentences <br />favorable to the operator while ignoring unfavorable portions of <br />the reports .l These "cover reports" all conclude there is no <br />potential or acid rock drainage, thus leaving the record with the <br />impression that the company feels there is no ARD potential. The <br />Division has consistently disagreed. <br />It may be time to go to the Board for a decision. In the absence <br />of more representative samples from the same areas, covering the <br />same topics as before, I can see no benefit to having the company <br />4 <br />