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conduct more tests. There is already a measured potential for <br />these rocks to produce acid in the weathering environment - not all <br />of them, but a significant number of them. There is also a <br />measured potential for some of the rocks to generate dissolved <br />metals in excess of current groundwater (Carlton discharge) <br />conditions and surface water table value standards. <br />What is missing is a reliable model calculation, prepared by <br />someone independent of the company, and acceptable to the Division, <br />showing how quickly such acid and metals could be released, and <br />what such releases would mean at the first, down-gradient, surface <br />water and groundwater compliance points. Even in the face of <br />private studies to the contrary, and even considering the contrary <br />results of the various leach tests, it is evident that the Operator <br />believes there is no problem. If the Operator disagrees once <br />again, the Division should take decisive steps to curtail this <br />persistent exchange of disagreements, opt for our own <br />interpretation, and have the operator install adequate <br />environmental protection measures. <br />5 <br />