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~. <br />John Hardaway ~i- May 30, 1995 <br />the case. if and when the ultimate standards for Arequa Gulch discharges are relaxed, the <br />Division should re-visit the issues raised by the operator. <br />2. CC&V argue in their May 2 Letter that upland diversions, bactericides, and alkaline <br />amendmenu are either too expensive, impossible to install or implement, will have no effect, <br />or will not be necessary. It does not negate the Division's opinion, however, that the ore and <br />waste rock must be protected in order to prevent the generation and release of acid and toxic <br />materials. <br />The WOCC Proposal. <br />~r <br />In the Division's previous written exchanges and meetings with the Company, we established <br />logical premises for azsessing the quality of discharges of process water from the CCC&V site. <br />In those cases, water quality was assessed on the basis of what the Division understood at the <br />time to be the most likely discharge limitations. <br />In this review it is assumed that the operative discharge limitations for the long term are likely <br />to be the "numeric standards" listed in the WQCC Proposal. The WQCC has not accepted <br />the company's proposal, but az the Division understands, the WQCD agrees with it; so, <br />considering that, the Division has used their initial acceptance in evaluating the geochemical <br />leach tesu. <br />The "temporary modifications and qualifiers" are not applicable because they will apply for <br />three years only. Our responsibility is to protect mining sources of acid and toxic materials <br />from leaving the site for the life of mine. <br />Conclusions. <br />CC&V's refutations of the Division's review, assessment, and conclusions regarding the <br />potential for the ore and waste to generate acid and toxic materials have been considered. As <br />part of that consideration the Division has re~acamined all of the initial, new, and cited <br />information. <br />The Division's conclusions, based on this examination of new information and reexamination <br />of the older data is the same az before. The evaluation is based on the premise that the water <br />quality standards for Arequa Gulch that will be applicable for the long term are the proposed <br />"numeric standards" for Arequa Gulch. <br />A complete assessment of the "contact tesu" has not been completed az the Division is not <br />familiar with the test parameters, and no supporting explanation has been offered. Also, the <br />"report" iuelf is anoperator-generated rendition of the test resulu that lacks verification, <br />analytical uniu, locations of samples, explanation of representativeness, and sampling <br />