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~ • • <br />The oxide zone is characterized by CC&V in terms of total sulfur and, therefore, pyrite <br />content. The definition of "oxide zone" includes limits on the percentage of pyrite. Thus <br />the statement in the OMLR Memorandum about variation in pyrite content of the oxide zone <br />seems irrelevant. <br />Presence of Carbonate Rocks. <br />Dr. Posey next states (page 3 of Memorandum) "Also in this section, the operator persists in <br />presenting conclusions about the degree of carbonate available in the rock for neutralizing <br />acid despite the absence of evidence showing that carbonate is actually available. Actual <br />identification of carbonate minerals has been rare. Also, the humidity cell tests indicate that <br />whether carbonate is present or not, it is not doing the job of neutralizing the acid." <br />Dr. Posey's commentary about carbonates seem to ignore the difficulty of identifying specific <br />carbonate types using some petrographic analysis methods. Regazdless of the mineral- <br />specific identification of carbonates, the carbonates present serve to neutralize some acid, <br />especially in the sulfide zone rocks where carbonates remain in lazger quantities. CC&V is <br />not arguing that the presence of carbonates changes the data; it is only presenting facts <br />observed by researchers as to the presence of carbonates and the role of those carbonates in <br />Cresson rocks. The behavior of the higher sulfur humidity cell samples is a direct indicator <br />of the presence of carbonate in the specimens according to current researchers. <br />The Vancouver Petrographic Lab's measurements identify carbonate minerals in general. <br />Honea's identified calcite (44'0) in sampled CC91-11 (140). <br />Visual Pyrite and Total Sulfur Contents. <br />Dr. Posey reflects on the correlation between total sulfur and visual pyrite as follows Page 3 <br />of Memorandum: "Section 6.2 refers in part to the strong positive correlation between total <br />sulfur and visual sulfides. In fact, visual estimates aze generally higher than precisely <br />measured sulfide sulfur contents. However, the Division is concerned about how pyrite <br />content will be monitored in the ore and waste rock during open pit mining operations. The <br />Division will require a detailed plan to be approved by the Division which explains; (1) how <br />the pyrite content will be accurately determined and at what frequency, and (2) how specific <br />volumes of material will be handled to protect surface and groundwater quality during mining <br />operations." <br />CC&V has proposed the following procedure which includes the monitoring of total sulfur <br />content to ensure that the correlation between visual pyrite and total sulfur is adequately <br />characterized: <br />"10.2 Waste Rock Handling Plan <br />"The basis of the waste rock management plan is to maintain the ambient <br />water quality by minimizing the potential for degradation resulting from acid <br />or metals release from the waste rock storage facilities. The waste rock will <br />17 <br />