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that the Division has accepted for other sites, including the Occidental OiI Shell Evaporation <br />Pond.)" <br />In swnmary, the Division's ,Tannary 17, 2006 letter review: <br />1. Identified the rigorous nahne of the Synthetic Precipitation Leach Procedure <br />("SPLP") used to test representative samples of ore and waste rock. The Division considered the <br />SPLP test to be conservative for several reasons: <br />(a) The rock samples present an extraordinarily high surface area to the <br />leachant, relative to what would be presented in the field; <br />(b) The tumbling provides maximum exposure to all reactive sites to the <br />[eachant; and <br />(c} The tumbling process exposes even more surface area through semi- <br />autogenous grinding; <br />2. The SPLP test results were compared to the most restrictive (lowest value) water <br />quality standards established by the Water Quality Control Commission for groundwater in <br />Regulation 41; <br />3. Because compliance with numeric protection levels is measured in the <br />groundwater at established compliarce point(s) downgradient, because there are not propagated <br />standards for dissolved constituents in unsaturated soils or bedrock, and because to push <br />contaminants to the water table requires the force -and thereby dilution by -rain or snowmelt <br />waters, the operator [Cotter Corporation] was encouraged to evaluate the rate of dilution that <br />could be expected by this process; <br />8 <br />