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"By comparison to data in Table D-4 on page D: 5 of the 112 <br /> application for the Sunnyside Mine and Mill , Terry Tunnel <br /> pond muds show an increase in the silt/sand ratio over <br /> native Lake Emma sediments. Selective transport through the <br /> mine has resulted in a reduction in the sand content and <br /> increase in the silt content. Otherwise the materials are <br /> similar texturally. If these materials had been derived by <br /> precipitation from mine drainage water , the texture would <br /> have been clay with no silt or sand sized material present. <br /> The textural analysis alone confirms that these materials <br /> are lake sediments washed through the mine from Lake Emma, <br /> anJ that they are not sludges derived from the chemical <br /> treatment of the mine drainage waters. <br /> Extract results show that copper , lead , manganese and zinc <br /> concentrations are relatively high, but generally consistent <br /> with the Lake Emma Sediments in the Sunnyside Basin <br /> (Table D-2, page D: 4 112 application for the Sunnyside Mine <br /> and Mill) . pH, conductivity, acid-base potential , and <br /> texture are all within reasonable bounds for plant growth <br /> media. Given these characteristics , it would be reasonable <br /> to attempt revegetating these materials . " <br /> The following documents the Division ' s review of the Terry Tunnel <br /> sediment analysis , justifying the requirement to dispose the <br /> Terry Tunnel sludge on the approved Tailing Pond Number 3 <br /> disposal site: <br /> a) The October 20 , 1987 analysis relates the textural analysis <br /> of the Terry Tunnel ponds sediment to be: <br /> Sand : 16 . 5 - 28 . 4% <br /> Silt: 55. 8 - 66 . 8% SiL <br /> Clay: 14 . 9 - 16 . 7% <br /> Table D-4 on page D: 5 of the consolidated permit relates <br /> Lake Emma sediment textures as : <br /> Sand: 64% <br /> Silt: 16% SCL/SL <br /> Clay: 20% <br /> and American Tunnel sludge textural analysis as: <br /> Sand: 61% <br /> Silt: 21% SL <br /> Clay: 18% <br /> The American Tunnel treated mine drainage precipitates (sludge) <br /> more closely relate to the Lake Emma sediments than do the Terry <br /> Tunnel Pond sediment analysis . Sand and silt components of file <br /> American Tunnel sludge comprise 82% of the particle :sizes <br /> evaluated. <br /> -15- <br />