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(c) The tumbling process exposes even more surface area through semi- autogenous grinding; 2. The SPLP test results were compazed to the most restrictive (lowest value) water quality standards established by the Water Quality Contro] Commission for groundwater in Regulation 41; 3. Because compliance with numeric protection levels is measured in the groundwater at established compliance point(s) downgradient, because there are not propagated standazds for dissolved constituents in unsaturated soils or bedrock, and because to push contaminants to the water table requires the force -and thereby dilution by -rain or snowmelt waters, the operator [Cotter Corporation) was encouraged to evaluate the rate of dilution that could be expected by this process; 4. The Contaminant Transport Modeling was proposed and accepted by the Division. The first modeling runs incorporated both the effects of dilution and sorption (to minerals in the stratigraphic columns); 5. The Division rejected the effects of sorption as being non-conservative. Modeling of sorption presumes that contact between the contaminants is ideal, and the amount of adsorbing materials through which the contaminants must travel downward were not well constrained; and 6. The bivision noted that Cotter subsequently submitted a simple dilution model, which dismissed the effects of sorption. Explanation of the model "raised questions that are the subject of the remainder of this review." The Division then concluded at page 4 of its Januazy 17, 2006 review that: We agree that sorption should retard the movement of contaminants through this stratigraphic column. The actual amount of sorption, however has not been quantified so cannot be permitted in the models in an unconstrained fashion. If the ultra-conservative approach of assuming zero sorption provides a simple way to reach the hoped-for 7