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9/30/93 <br />Responses to Comments <br />San Luis Reclamation Evaluation Report <br />Page 19 <br />The ammonia is converted to an ammonium precipitate. <br />This precipitate is a complex ammonia double salt <br />which is highly stable and does not tend to break <br />down into nitrates. In the equations provided by <br />INCO they have used the term fertilizer quite <br />incorrectly since this is a highly stable form of <br />ammonia. INCO has performed numerous tests on the <br />stability of this material and the rest}lts are <br />available if the DMG would like additional <br />information. Also, for additional information on <br />the INCO reactions see Smith and Mudder, Chapter 6 <br />and TR 10. <br />Comment: <br />Page 8-10, 34-35, 4. The text indicates that maximum depths of <br />the tailings sample holes were drilled to maintain an elevation <br />at Ieast five feet above the liner cover in order not to <br />penetrate the Iiner. A few holes were augered near the strand <br />line of the ponds; others were augered near the edge of the <br />tailings. Elevations of the collars and depths of each well <br />are provided, but the total depths of the holes relative to the <br />depth of the liner at each drill hole location ere not <br />provided. The narrative and the drill hole desc¢~iptions <br />indicate that the holes were terminated generally betrause of <br />angering difficulties or because the material begame too <br />saturated to retrieve, not because of elevation considerations. <br />Using the general elevations derived from Figure 2.2 and the <br />auger well logs, it is apparent that (a) most of the wells <br />barely reached the pond water Ievel, (b) virtually none of the <br />wells came near the area five feet above the liner (some were <br />40 to 70 feet above the liner), and (c) wells in the lower <br />impoundment did not reach the AVR level. <br />From the discussion (p 9-10) it is apparent that, When the <br />project was initiated, tailings water either was considered not <br />to be a component of "tailings chemical constituengy" (see <br />abatement #e) or was overlooked as a tailings constituent of <br />necessary interest. <br />Considering that liquids were not retrieved or measured in most <br />wells, that most of the wells barely reached the standing water <br />level, that only one attempt was made to sample tailings <br />liquids, and knowing that part of the requirements of Abatement <br />8 called for a study of the "tailings chemical constituency", <br />this calls to question whether an appropriate methodology was <br />employed to retrieve liquids from the samples. I am skeptical <br />