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C~ The interpretation of the particle-size distribution by Sunnyside is that if the Terry Tunnel sediment had been derived by precipitation from mines drainage water, the resulting texture would be clay with no silt or sand-sized material present. If a flocculent were added to the mine drainage water to cause precipitation, the resulting sediment would be predominantly silt sized from agglomeration, and not clay sized as proposed. The particle size distribution for the Terry Tunnel sample, as shown in Table 2, may indeed be similar to a sludge from a water treatment system based on precipitation. I find it difficult to conclude that the textural analysis alone confirms these materials are lake sediments washed through the mine from Lake Emma, and that they are not sludges derived from the chemical treatment of mine drainage water as stated in the Sunnyside report. Conclusion Based on the chemical analyses provided for the Terry Tunnel sediment samples collected, and baseline data from the permit, the material is similar to a sludge or slime produced at the Sunnyside Mine. The texture indicates. it is fine grained with a deficit of sand-sized particles. The concentrations of heavy metals, especially Cd, Cu, Pb, Zn and Mn, are similar to sludges rather than native soils or waste rock. Metal concentrations are high and may pose problems for water contacting this material. The sediment is acid forming, potentially toxic, and unsuitable as a plant growth media. Based on these characteristics, it should be disposed of in a lined basin, and covered with material which will allow re vegetation of the disposal area. References Cited Smith, R. M., W. E. Grube, Jr., T. Arkle, Jr., and A. Sobek. 1974. Mine spoil potentials for soil and water quality. U.S. EPA Report EPA-670/2-74-070. Sobeck, A. A., W. A. Schuler, J. R. Freeman, and R. M. Smith. 1978. Field laboratory methods applicable to overburden and minesoils. U. S. EPA Report EPA-600/2-18-054. J1D/eke 8263E