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<br />days of receipt of all of the results by the operator. Interim reports may also <br />be submitted. Should the Office determine that the generation and release of <br />acid and/or metals has the potential to violate applicable water-quality <br />standazds for surface water or jeopardize the existing or potential future uses <br />of ground water, CC&V will propose to the OMLR measures that will protect <br />the receiving waters from noncompliant releases. Such proposal will be in <br />the form of a permit modification and will be submitted to the OMLR within <br />30 days of notification." <br />In view of the fact that CC&V has already submitted data on the Carlton Tailing material <br />(see Volumes II, III, and VI of Application), and in view of the fact that the projections of <br />water quality from the overburden suggest than ambient water quality is closely approximated <br />by the humidity cell data for the oxide and certain "transitional" rocks and, therefore that <br />applicable water-quality criteria will be met in Arequa Gulch, and in view of the fact that <br />CC&V is to segregate material based on sulfur content and reclaim the surface of the <br />overburden so as to minimize infiltration and oxygen though the plant growth medium, <br />CC&V disagrees with a conclusion that states CC&V has not abided by its commitment. <br />Reaction Equations. <br />Dr. Posey, in the "INTRODUCTION" on page 2 of the memorandum, states "Section 4, on <br />background chemistry, provides several disingenuous formulas meant to represent the notions <br />of acid generation and acid neutralization. The reaction of pyrite with water and oxygen <br />(reaction [1]) expresses only part of the potential for pyrite to produce acid. The reactions <br />shown for the attack of dolomite and calcite by acid aze equilibrium reactions: one should <br />not anticipate such reactions in the weathering environment. Equilibrium thermodynamics <br />should not be used to represent the dissolution of minerals where the solutes can be expected <br />to be carried away from the reaction site. Simple addition of acid to carbonate minerals <br />causes effervescence due to the generation of CO2. This is not represented by the reactions <br />shown..." He continues to conclude "The section on background chemistry does not <br />correctly represent the weathering environment at Cresson, and should not be consulted for <br />predictive purposes. The better predictive tests are the acid generation and acid <br />neutralization tests themselves." <br />First, Dr. Posey, we are certain, recognizes that the equations are academic given-the state <br />of the art in predicting acid generation and acid neutralization. The equations contribute <br />little in terms of generating quantitative water~uality data. Second, the entire discussion that <br />Dr. Posey discards as "disingenuous" was developed by one of the preeminent reseazchers of <br />acid-base reactions. <br />With respect to the solubility of calcite and dolomite, they are soluble at a moderate rate <br />(The Handbook of Physics and Chemistry), dissociate to calcium, magnesium, and cazbonate, <br />and the data available to us indicate that it is not an equilibrium reaction. While we have <br />never depended upon the reaction going to completion in any of our quantitative projections, <br />14 <br />