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-.. Review of 5/31/94 Golder Response Letter From H. Posey to B. Keffelew; 6/7/94 Page 2 lJ Per opinion and conclusions expressed through various memoranda, document reviews, and Stipulation 17 itself, it should be evident that the Division disagrees with the Operator's Response. Reiteration of data and conclusions presented in the Amenement Application does not satisfy the Stipulation. It was the Division's original position that the data available in the Amendment Application did not satisfy our concerns, and we stand by that position. Rather than re-state our original concerns, the Division suggests that Pikes Peak or their representatives re-examine the Division's adequacy comments, identify those pertinent to this Stipulation, and address them accordingly. If upon reviewing these documents the operator still maintains that adequate information has been made available already, the Division would suggest holding a meeting between Division personnel and the operator so that we can clarify or explain our positions. In addition to adequacy comments furnished previously, the operator should be prepared to discuss the following observations, at a minimum: 1. The number and location of samples appears not to adequately characterize the diversity composition and physical parameters of the tailings. 2. The cyanide analyses reported in mg/kg should be converted to mg/L, considering the porosity of the tailings, the percent fluid in the pore spaces, and the percent of cyanide whose species will be controlled in order to comply with water quality control conditions. 3. Tests for metals leachability, extractable cyanide, and acid generation should be performed using procedures that will mimic the conditions under which the tailings will be deposited. For example, low sulfide samples that will remain dry except for occasional washing by storm water may be appropriately analyzed using a rapid and inexpensive method such as the Meteoric Water Mobility Procedure whereas samples that are saturated or that are oxidizing quickly might require more rigorous longer term testing to prove compatibility of the tailings with their physical surroundings and with water quality compliance. 4. Because groundwater and surface water parameters must meet water quality discharge standards at compliance points, all analyses should be collected using procedures that meet or exceed the detection limits required for applicable water quality standards. The operator needs to determine from the Health Department which elements or compounds are regulated by WQCD and which components are present in the Cresson ore and waste. The operator should also determine whether aquatic life, domestic drinking water, or agricultural standards apply, and then measure down to the required detection limits.