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to be protected from weathering and leachates from them must not be permitted to leave the site without treatment. Many of the humidity cell tests were stopped shortly after the tests were initiated. There is no justification for stopping these tests, either for purposes of predicting long-term acid production or for predicting the potential for metals release. Analysis of at least 28 of the 42 samples were halted after week 4 or week 12. This means that metal and acid generation predictions covering the entire ore body and all of the waste rock are to be made using only 10 samples. This is not acceptable. The Division agreed to accept analyses of 42 samples: not 10. APPENDIX 10 Most of the samples have turned acidic; that is, the pH has dropped below 6.5. (For this assessment, the value 6.5 is used because that is the lowest acceptable surface water pH.) Therefore, it should be obvious that the waste rock will produce acid if not protected from weathering and release of solution. Even for most of the humidity cell tests that were curtailed after only 4 to 12 weeks, acid production is high (pH low). Given these data, it would be impossible to honestly and knowingly conclude that the surface and groundwaters can be adequately protected simply with a monitoring program, as CC&V have proposed. APPENDIX 11 This appendix presents results of water quality monitoring at CDPHE station number AG-1 (Arequa Gulch No. I, above the Carlton Mill} for June 4, 1987 to November 9, 1992. AG-1 is a Health Department mandated compliance point. Some of the sampling events exceed water quality standards at that point in Cadmium, Copper, Manganese, Mercury, Silver and Zinc. APPENDIX 12 This appendix compares the 1987-1992 AG-I metal values -some of which exceed WQ standards -with the humidity cell test results. The text explains the data in terms of detection limits. The text does not explain the data in terms of water quality standards. Without conducting a rigorous analysis of the data leading up to generation of the charts presented in this appendix, my assessments are shown in the following section (Table 1).