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method D 5744 -07, and the test must be run for a duration of at least six months. The sample to <br />be submitted shall be subject to prior DRMS approval. The specific sample selected, parameters <br />to be evaluated over the test duration, and the analytical frequency are to be determined in <br />collaboration with DRMS before the testing commences. <br />Because the new requirement for TR -14 to include humidity cell testing (ASTM method <br />D5744 -07) was not specified by the Division during its review and approval of TR -14, <br />insufficient sample volumes were collected to now permit humidity cell testing on any of the <br />samples collected in the fall of 2010 under TR -14. In accordance with the sampling and analysis <br />plan approved by the Division, splits from 12% of all samples were sent to a commercial <br />laboratory for analysis of Ra -226, U -nat, and leaching by SPLP (EPA method 1312). A <br />minimum sample volume of 1 kilogram is required for humidity cell testing (ASTM, 2010). <br />None of the samples collected during the TR -14 field work contained sufficient volume to <br />accommodate this requirement. <br />According to the scope of humidity cell testing as outlined in ASTM method D5744 -07 (ASTM, <br />2010), method applications are limited by the following considerations: <br />1. The method is not intended to provide leachates that are identical to leachate produced <br />from a solid material in the field. <br />2. The method is not intended to produce leachates as a sole basis of engineering design. <br />3. The method is not intended to simulate site - specific leaching conditions. <br />4. The method has not been demonstrated to simulate actual disposal site leaching <br />conditions. <br />5. The method is not designed to produce effluents that are in chemical equilibrium with the <br />solid phase sample. <br />Humidity cell testing would provide information only with respect to longer term leaching <br />behavior under a very specific set of laboratory conditions. The same limitation applies to SPLP <br />testing by EPA method 1312. Neither method is expected to accurately simulate leaching <br />conditions under actual hydrological/geochemical regimes that exist within the alluvial fill or <br />underground mine workings at the Schwartzwalder site. However, Cotter has identified an <br />alternate approach for assessment of leaching behavior that is specific to in -situ field conditions <br />at the site. A detailed analysis of this issue has been developed for inclusion in the TR -14 <br />report. <br />Reference: <br />ASTM International. 2010. Standard test method for laboratory weathering of solid materials <br />using a humidity cell. ASTM method D5744 -07. <br />2 <br />