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procedure). Analyses of the solids appear to be for total metals, and analyses from the SPLP tests appear to be dissolved metals. However, without keying the analytical methods noted in the charts with published protocols, this is not certain. The operator should clarify this uncertainty. Notes: Organics 1. A number of organics analyses are reported for organics that are not regulated. The operator should explain the significance of these analyses and why they were measured. 2. Not all of the regulated organic materials were analyzed. The operator should explain why, and describe how the analyses presented represent the full suite of regulated organic compounds. 3. Organic compounds that appeared at measurable levels in the dry samples were generally the same as those in the leachates. 4. None of the organic parameters reported above regulated levels, even at the most restrictive levels. 5. It is not clear from the analyses and narratives whether organic chemicals that might appear from inefficient burning of tires would be adequately monitored using the available data. (See recommendations at end of this narrative.) Metals and other parameters 6. Metals analyses are reported for several metals that are not regulated. As these do not constitute a whole rock analysis, it is not evident why these were measured. The operator might explain the significance of these analyses and why they were measured. 7. Analytical detection limits for Mn was lower than the regulated value for the secondary drinking water standard (0.05 mg/L). As other metals appeared in the analyses that might indicate an upset in groundwater conditions, the Division need not require additional testing for Mn. 8. A suite of metals and sulfate reported at concentrations above detection limits in both the solids and the leachates analyses. Generally, these were higher in the coal/tire ash than in the coal ash. It is interpreted that these metals are present in the metal components of tires, perhaps in steel belts, other metal reinforcements, or perhaps additives in the rubber. Regardless of source, I would anticipate that these would appear in the ash and in groundwater. Thus, a representative suite of these particular mefa/s that report above regulated levels should be added to the existing groundwater monitoring parameters list, if tires are incorporated into the fuel. if tire fuel is anticipated, it would be useful to establish background levels for these parameters. 9. All samples reported pH above the accepted range for waters. Provided this parameter already is monitored, it would not need to be added to the parameters list. 2