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<br />Review of Abatement #8 Response <br />August 4, 1993 <br />Page 5 <br />3. In general, there appears to be considerable sample seZec ion for the <br />testing leading to uncertainty in our minds regarding ve~ticaZ sites <br />selected. We cannot be sure that leachate tests were perfprmed at the <br />proper vertical ZeveZ (i.e., at the level where tailings w e deposited <br />during the time when excessively high levels of cyanide we a being put <br />into the ponds). <br />See my comments above. In general, I do not believe t~e pre-cytox <br />tailings fluids were adequately tested. <br />4. The detection limits for selenium analyses are not Zowl, enough for <br />obtaining significant data. <br />While the detection limit may not be ae low as PASS w uld prefer, <br />selenium, to my knowledge, has not been shown to have a sou ce from the <br />San Luie facility. PAES should be more specific in their re est on this <br />point. <br />5. It would have been a good idea to perform leachate tests~on the same <br />sample (site 8.5) that pore water analysis were conducted to etermine how <br />much of the metals, etc. were tied up in the solid ph se at that <br />particular location. <br />I believe my general comments about sampling adequacy addres$ this point. <br />6. There are a number of statements where "the lab was in error'~or "data was <br />aberrant" (e.g. pages 22,29). Zn the past we have observed this type of <br />dismissal of data when ever Zab figures did not correlate th expected <br />results. <br />The latter statement in this comment is an unjustified critliciem of the <br />compilers of the report. Provided there is evidence of past impropriety, <br />and that such improprieties apply to this situation, t would be <br />appropriate for PASS to mention it here. As stated, th comment ie <br />without standing. <br />The observation about "a number of statements" of lab error~or aberrant <br />data needs to be responded to. However, if there are stat mente other <br />than those on pages 22 and 29, the reviewers themselves should identify <br />them. <br />7. On page 32 the statement is made that rinsed samples were pot used for <br />leachate testing however, in Table 3.8 the report cites dada for rinsed <br />upper impoundment operational tailings. <br />I believe the reviewers are confusing leachate testing wi~h acid/base <br />testing. <br />