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Mr. Robert Ernst <br /> Page Two <br /> following this revised rinsing process, was collected and analyzed using SPLP. <br /> The SPLP testing method (EPA Method 1312) may be used to characterize waste <br /> material for the potential to release metals and other constituents into the <br /> environment in unacceptable amounts due to exposure to normal meteoric <br /> precipitation. In this procedure a minimum of 100 grams of solid waste is <br /> combined with 20 times that weight of slightly acidic, artificial rain water. <br /> Traditionally, the U.S. EPA recommends that concentrations of constituents in the <br /> resulting leachate be compared to 100 times drinking water standards as an <br /> indication of the material's toxic characteristics. This rationale assumes that a <br /> 100-fold dilution will occur prior to use of the leachate mixture as a drinking <br /> water source and follows from the practice of comparing Toxic Characteristic <br /> Leaching Procedure(TCLP) results to Maximum Concentrations of Contaminants <br /> for Toxicity Characteristics (MCCTCs) which are equivalent to 100 times <br /> drinking water standards. <br /> Table 1 presents the results of the SPLP procedure performed on the tailings and <br /> values equal to 100 times U.S. Primary and Secondary Drinking Water Standards, <br /> where available. None of the measured constituents exceeded the comparison <br /> values. <br /> Manganese was the only constituent to exceed a direct comparison to the drinking <br /> water standard. Manganese has a secondary drinking water standard of 0.05 <br /> mg/L. The level detected in the leachate sample was 0.321 or approximately 6 <br /> times the standard. To determine the probability of the manganese in the leachate <br /> affecting a drinking water source, we obtained a list of the nearest wells to the <br /> Joker Mine. According to the Colorado Division of Water Resources database, <br /> the nearest down-gradient well is approximately 5 miles from the site. This well <br /> is listed as a domestic use well. Another domestic use well is located <br /> approximately 1.5 miles east of the mine site, but based on topography is not <br /> down gradient from the mine. If leachate were to enter the ground water, by the <br /> time it reached the nearest well, manganese levels are expected to be undetectable <br /> due to the dilution from precipitation leaching the material and existing ground <br /> water. Five wells are located on the Joker Mine property and their listed uses <br /> include industrial and domestic. These wells are not likely to be used for <br /> domestic sources of water. <br /> The Elkhead Joint Venture proposes to monitor the ground water during <br /> operations. Quarterly monitoring of one up-gradient and one down-gradient well <br />