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In order to demonstrate the imported material does not create a potential for release of <br />contaminants to the groundwater system, the Division recommends that you, as the Operator, <br />develop a plan for sampling and analyzing the imported material in a manner that adequately <br />characterizes the entirety of the material imported and placed as permanent fill. The Division <br />recommends EPA Method 1312 Synthetic Precipitation Leaching Procedure (SPLP) be used, <br />and recommends the following analytes for the SPLP test: pH, Conductivity, Arsenic, Boron, <br />Cadmium, Chromium, Copper, Iron, Lead, Manganese, Mercury, Molybdenum, Nitrate + Nitrite, <br />Selenium, Sulfate, Uranium, and Zinc. <br />In addition to the SPLP test, the Division recommends conducting an Acid -Base Accounting <br />(ABA) test that includes sulfide sulfur. <br />Division approval will be required prior to implementation of any sampling/testing plan <br />proposed by the Operator. <br />If you require additional information, have questions or concerns, please contact me at the <br />DRMS Grand Junction Field Office. <br />Environmental Protection Specialist <br />Department of Natural Resources <br />Division of Reclamation, Mining and Safety <br />101 South 3 Suite 301 <br />Grand Junction, CO 81501 <br />Phone: (970) 243 -6299 <br />Fax: (970) 241 -1516 <br />Ec: Steve Shuey, DRMS <br />Tim Thulson, Balcomb and Greene P.C. <br />STATE OF COLORADO <br />Page 2 of 2 <br />