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,: <br />dated July 29, 1993. That report consists of the data Dr. Posey refers to and McClelland <br />Laboratories' description of the test procedures and their conclusions. The report is <br />discussed starting on page l 1 of the July 29, 1993 submission to the OMLR. <br />APPENDIX 8. <br />Dr. Posey observes that the original data reporting sheets from McClelland Laboratories are <br />not included in the submission. The Appendix contains a copy of the last tabulation from <br />each of the humidity cell data reports supplied by the Laboratory. This tabulation has not <br />been altered by CC&V. In most cases, the McClelland Laboratories report includes this <br />tabulation and two graphs, one graph of cumulative concentrations of SO,, Acidity, and <br />alkalinity, along with a chart of the pH, and one graph of weekly concentrations. These <br />graphs are provided in Appendix 10 of our submission. We do not request, and therefore do <br />not receive, individual laboratory analyses sheets because of the volume of the material that <br />would be involved. We examine the continuity of the data for quality control (effectively <br />using a control chart approach). <br />APPENDIX 9 <br />Again Dr. Posey comments that "None of the original reporting sheets from the labs aze <br />presented." The sheets that are included for "ICP-33 Metal Analytical Results" aze copies of <br />the original laboratory report sheets from McClelland Laboratories. Again, as stated above, <br />we aze not routinely requesting the in-house laboratory work-up sheets for these analyses. <br />Similazly, the sheets listing "Analytical Results, Quantitative Metals" aze also copies of the <br />sheets supplied by the Laboratory. McClelland Laboratories receives the analytical results <br />from AccuLabs and transfers the data onto these summary forms. Therefore CC&V has not <br />prepazed these Tables in the submission (Volume X). To supply all laboratory data sheets <br />would involve a great deal of additional paperwork. CC&V is not aware of any data quality <br />issues that would be revealed by the AccuLabs data report sheets in view of the fact that we <br />compaze consecutive measurements for anomalies. <br />Dr. Posey states "Detection levels are not low enough for some metals." <br />Detection limits were specifically lowered by sending humidity cell samples to Acculabs, the <br />same laboratory that processes CC&V's NPDES compliance samples and each and every <br />detection limit for these samples is adequate for determining potential compliance. <br />Dr. Posey states "Many of the humidity cell tests were stopped after the tests were initiated. <br />There is no justification for stopping these tests, either for purposes of predicting long-term <br />acid production or for predicting the potential for metals release. Analysis of at least 28 of <br />the 42 samples were halted after week 4 or 12. This means that metal and acid generation <br />predictions covering the entire ore body and all of the waste rock aze to be made using only <br />10 samples. This is not acceptable. The Division agreed to accept analyses of 42 samples; <br />not 10." <br />19 <br />