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Date: June 13, 2005 <br />To: Steve Shuey <br />From: Harry Posey <br />Re: SPLP results review: Cotter Corporation, SM-18 (Wright) Mine; M-1978-116 <br />/. <br />This memo assesses the results of SPLP tests on waste rock and ore samples from the above captioned <br />operation. These were presented in Cotters letters received separately at the Division on May 16 and May <br />23, 2005. The analytical results and the conclusion of this memo should be applicable to similaz ore and <br />waste rock piles in the neaz vicinity provided they aze mined from the same geologic units and that have <br />similaz mineralogical chazacteristics. <br />The following SPLP results exceed certain applicable water quality parameters, <br />Analyte SPLP Test Results Standard Comments: Dilution required to meet standard <br /> u <br /> Waste Ore <br /> Rock <br />Aluminum 636 140 87 Chronic aquatic life standazd. <br /> 8x dilution needed. <br />Lead na 7.3 0.5 Chronic aquatic life standard @ Hardness of 25 <br /> 15x dilution needed <br />Selenium / 86 230 4.6 Chronic aquatic life standazd. Agricultural standard = 20 <br /> ug/L for 30 day period. <br /> 19x dilution needed for surface water <br /> SOx dilution needed for oundwater <br />Uranium na 2700 326 Chronic aquatic life standazd @ hardness = 25. <br /> 9x dilution needed. <br />Zinc na 190 36 Chronic aquatic life standazd @ hardness = 2S. <br />^°~a ~ 6x dilution needed. <br />The Division must consider potential impacts to both groundwater and surface water from the ore and <br />waste rock piles. Impacts to the hydrologic balance maybe minimized by a variety of means including: <br />• dilution of the pollutants prior to reaching a receiving stream of groundwater, <br />^ isolation of pollutants in holding ponds or treatment facilities <br />^ caps, covers or diversions to m;n;m;~e infiltration or rain or snowmelt, or <br />^ limited holding times, i.e. limited time for precipitation to be in contact with the ore or waste rock. <br />For the Division to allow waste rock to remain unprotected and still consider that impacts to the <br />hydrologic balance have been minimized, the operator should show that pollutants released from either <br />ore or waste rock would be diluted sufficiently prior to entering groundwater at some use point or prior to <br />