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<br />Review of Abatement f8 Response <br />August 4, 1993 <br />Page 2 <br />Pages Comment Number and Comment/Question <br />2. Text indicates that the products of HZOZ ~x idation of <br />metallocyanide complexes include ammonia and carbonat It ie my <br />understanding that nitrate and or nitrite may also be products of <br />this reaction. It is my further understanding that nitrates in <br />groundwater may be problematic. ~ ~, <br />Please comment on the accuracy of my underetandi~gs, and if <br />warranted, assure the Division that nitrates will Knot cause a <br />problem in the future from weathering of the tailings. <br />3. With regard to the explanation of INCO chemistry an with regard <br />to comment 2 above, it appears that nitrates may also be a product <br />of the INCO process. <br />Please clarify the second equation shown in Figure R.S; namely, <br />identify the composition of the fertilizer that is li red. Also, <br />please quantify the amount of nitrogenous fertilizer hat will be <br />produced, and express that quantity in terms of i e pollution <br />potential. ~, <br />8-30 4. The text indicates that maximum depths of the tai inga sample <br />34-35 holes were drilled to maintain an elevation at least fie feet above <br />the liner cover in order not to penetrate the liner. ~ A few holes <br />were augered near the strand line of the ponds; others were augered <br />near the edge of the tailings. Elevations of the tolls sand depths <br />of each well are provided, but the total depths f the holes <br />relative to the depth of the liner at each drill hole location are <br />not provided. The narrative and the drill hole descriptions <br />indicate that the holes were terminated generally because of <br />sugaring difficulties or because the material became oo saturated <br />to retrieve, not because of elevation considerations. <br />Using the general elevations derived from Figure 2.1 nd the auger <br />well loge, it ie apparent that (a) moat of the wells b rely reached <br />the pond water level, (b) virtually none of the wells ame near the <br />area five feet above the liner (some were 40 to 70 f t above the <br />liner), and (c) wells in the lower impoundment did not each the AVR <br />level. <br />From the discussion (p 9-30) it is apparent that, whe~ the project <br />was initiated, tailings water either was considered not to be a <br />component of "the tailings chemical constituency" (see batement #`8) <br />or was overlooked ae a tailings constituent of neceaea y interest. <br />Considering that liquids were not retrieved or meas~red in most <br />wells, that moat of the wells barely reached the st nding water <br />level, that only one attempt was made to sample tailings liquids, <br />and knowing that part of the requirements of Abatement 8 called for <br />a study of the "tailings chemical constituency," t ie calls to <br />question whether an appropriate methodology was employe to retrieve <br />liquids from the samples. I am skeptical about a cepting the <br />analysis of a single fluid sample to be representative f all fluids <br />in the tailings, both in the vertical and lateral dim nsions. <br />