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., <br />U <br />current water-quality of water emanating from the Cripple Creek Mining <br />District. Nonetheless, Cripple Creek & Victor Gold Mining Company is <br />proposing herein to segregate certain of the Cresson Mine-derived overburden <br />containing the slightly elevated (naturally) higher pyrite contents by placing <br />this material in completed surface mines, namely the Ironclad and Globe Hill <br />mines, as well as back into the Cresson mine, and to monitor water quality in <br />the Arequa Gulch overburden storage area." <br />With respect to analytical detection levels, Cripple Creek & Victor Gold Mining Company <br />("CC&V") did exactly what Dr. Posey states was not done. Each 4-week humidity cell <br />"extract" was separately sampled by McClelland Laboratories and sent to AccuLabs, Inc., <br />which is CC&V's routine analytical laboratory for all water samples. AccuLabs specifically <br />performed analyses at the achievable levels of detection selected to be at, or below, relevant <br />water-quality standards for Cripple Creek, which is the nearest classified stream`. In <br />Appendix 9 of Volume X, seventeen Tables titled "Analytical Results, Quantitative Metals, <br />Humidity Cell Extracts, mg/l," report 4th week and 12th week composite samples from <br />seventeen samples that are undergoing continued (not discontinued) dynamic testing. These <br />are AccuLabs data that have been tabulated by McClelland Laboratories. <br />Reporting limits for the parameters are shown in Table 1 (below). Accompanying the <br />reporting levels in the Table are computations of Cripple Creek Water Quality Standards <br />using a hardness value of 400 mg/1 selected for Arequa Gulch by the Water Quality Control <br />Division of the Colorado Department of Public Health Services and Environment as well as <br />220 mg/1 used by CC&V for Cripple Creek. With the single exception of mercury, each and <br />every AccuLabs reporting limit is below the computed TVS and, therefore, well below <br />ambient concentrations in Arequa Gulch. With regard to mercury, the concentration <br />specified as the standard is generally not measurable using commercially available routine <br />techniques. This fact is well recognized by the Water Quality Control Division. <br />TABfE 1. REPORTING LIh11TS FOR ACCULABS DATA - APPENDU( 9. VOLUME X, APPLICATION FOR AMENDMENT <br />NUISiHER 6, PERMIT M-80-244 (CRESSON PROTECT) eubmieed b OMLR October 7, 1994. <br />WATER-QUALITY PARAMETER ACCUTABS'REPORTING Cripple Credc'Stmdardi Cripple Creek 'StnrdeAe' <br />(Not eR arc 'slanderde.') LIM]T (mg/p (Segment 22) Acute/Chronic (Segment 22) Acure/Chmoic <br /> (Computd wing 400 mg/I (Computed wing 220 mg/1 mul <br /> mlal hardness) (mg/q hrudnem) (mg/D <br />Aluminum O.I None Noee <br />Arsenic 0.005 0.0360/0.150 0.0360/0.150 <br />Bariwn 0.05 None Nonc <br />' It should be noted, es we arc certain Dr. Posey is well aware, Ihex concentrations levels arc 'reporting limits' end are more <br />instrument defection limits rasher Then either method defection lllllll9 or practical quenlilelion lirttita. Therefore They reprexnl, et these <br />levels, only a certainty that some amount o(the substance is prcxnt. The actual quantity cannot be specified with any certainty. For many <br />enelylicel methods, the reported value may need to be a factor of five times (or more) dte rcportine limit may be required before there ie e <br />strong slatislical certainly Thal the substance is actually prcsenl at the reported value. <br />3 <br />