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. ~ <br /> <br />current water-quality of water emanating from the Cripple Creek Mining <br />District. Nonetheless, Cripple Creek & Victor Gold Mining Company is <br />proposing herein to segregate certain of the Cresson Mine-derived overburden <br />containing the slightly elevated (naturally) higher pyrite contents by placing <br />this material in completed surface mines, namely the Ironclad and Globe Hill <br />mines, as well as back into the Cresson mine, and to monitor water quality in <br />the Arequa Gulch overburden storage area." <br />With respect to analytical detection levels, Cripple Creek & Victor Gold Mining Company <br />("CC&V") did exactly what Dr. Posey states was not done. Each 4-week humidity cell <br />"extract" was separately sampled by McClelland Laboratories and sent to AccuLabs, Inc., <br />which is CC&V's routine analytical laboratory for all water samples. Aceulabs specifically <br />performed analyses at the achievable levels of detection selected to be at, or below, relevant <br />water-quality standazds for Cripple Creek, which is the neazest classified stream'. In <br />Appendix 9 of Volume X, seventeen Tables titled "Analytical Results, Quantitative Metals, <br />Humidity Cell Extracts, mg/1," report 4th week and 12th week composite samples from <br />seventeen. samples that are undergoing continued (not discontinued) dynamic testing. These <br />are AccuLabs data that have been tabulated by McClelland Laboratories. <br />Reporting limits for the parameters aze shown in Table 1 (below). Accompanying the <br />reporting levels in the Table aze computations of Cripple Creek Water Quality Standazds <br />using a hazdness value of 400 mg/1 selected for Arequa Gulch by the Water Quality Control <br />Division of the Colorado Department of Public Health Services and Environment as well as <br />220 mg/1 used by CC&V for Cripple Creek. With the single exception of mercury, each and <br />every AccuLabs reporting limit is below the computed TVS and, therefore, well below <br />ambient concentrations in Arequa Gulch. With regard to mercury, the concentration <br />specified as the standard is generally not measurable using commercially available routine <br />techniques. This fact is well recognized by the Water Quality Control Division. <br />TABIE 1. REPORTING I1MIT5 FOR ACCUTABS DATA -APPENDIX 9, VOWME X, APPI~CATION FOR AMENDMFM <br />NUMBER 6, PF7tAGT M-80.244 (CRFSSON PROJECn submived b OMIR Ocbba 7, 1994. <br />WATER-QUAIIIY PARAMETER ACCUfABS'REP0RTING Cripple Crat'SmdeNe' Cripple CnxY 'Standertls' <br />(Na eR src'smderde.') IlMfr (nq/D (Se`mmt22)ActivJChrooic (Se`mat22)AavlChr"oic <br /> (Computed ueies 400 m`/1 (Compwd u.~ 220 mt/1 bbl <br /> total hertlness) (rry/~ hudms) (m{/D <br />Ahmmum 0.1 Nom Nam <br />AbmM o.aos o.meoro.lso o.ossoro.lso <br />Barium O.OS Nme Nom <br />' It should be nosed, ea we arc certain Dr. Posey is well aware, These concentrations levels arc 'reporting limits' end arc more <br />instrument defection limit rather then either method detection limit or practical qusnlitation limit. Therefore They represent, el these <br />levels, only a certainty that some amount of the substance ie present. The ecmal quantity cannot be specified with any certainty. For many <br />emlyticel methods, the reported value may need to be a lector of five Iimee (or more) the reporting limit may be required before there is a <br />strong statistical certaimy that the wbatence is actually present ei the reported value. - <br />3 <br />