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9/30/93 <br />Responses to Comments <br />San Luis Reclamation Evaluation Report <br />Page 23 <br />continue to compact throughout the life of the <br />operation. A permeability of 10~ cm/sec is <br />equivalent to the requirements for an impermeable <br />earthen liner and therefore little fluid movement is <br />expected. Based on calculations presented in the <br />Reclamation Evaluation Report, approximately <br />eighteen months after cessation of deposition flows <br />from the underdrain will drop to less than 0.5 <br />gallons per minute (gpm). These flows will continue <br />to decrease to less than 0.1 gpm after 24 to 30 <br />months. <br />The tailings surface will be graded to slope at <br />approximately 0.5$. At this slope, runolff flows <br />will not be erosive. Information on the graded <br />tailings surface and potential for erosion was <br />addressed in detail in the approved permit <br />application and associated adequacy responses. <br />Comment: <br />B. Some of the weathered tailings samples have metal <br />concentrations which are at or near the levels for surface <br />water standards for, say, the Rio Grande River. <br />BMRI should explain the high metal concentrations in terms of <br />the site conditions that will exist upon closure. The Division <br />needs certain assurance that, under the present reclamation <br />plan, surface water that leaves the site will not be degraded <br />by weathering of the tailings. <br />Response: An analogy of the EPA 1312 test results to water <br />quality standards is inappropriate for the reasons <br />above in the response to comment 2. <br />In any case, the tailings surface upon reclamation <br />will be graded to 0.5$. This slope has been <br />demonstrated not to be erosive under any flows. <br />Concerns with tailings erosion were addressed as <br />gart of the adequacy review by the DMG of the <br />approved permit amendment and additional infiormation <br />can be found in the adequacy review responses. <br />Comment: <br />Some of the humidity cell test results look odd, although this <br />observation is certainly limited by my knowledge of the <br />mineralogy of the ore body. <br />