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The interpretation of the particle-size distribution by Sunnyside is that if <br /> the Terry Tunnel sediment had been derived by precipitation from mine drainage <br /> water, the resulting texture would be clay with no silt or sand-sized material <br /> present. If a flocculent were added to the mine drainage water to cause <br /> precipitation, the resulting sediment would be predominantly silt sized from <br /> agglomeration, and not clay sized as proposed. The particle size distribution <br /> for the Terry Tunnel sample,_as shown in Table 2, may indeed be similar to a <br /> sludge from a water treatment system based on precipitation. I find it <br /> difficult to conclude that the textural analysis alone confirms these materials <br /> are lake sediments washed through the mine from Lake Emma, and that they are <br /> not sludges derived from the chemical treatment of mine drainage water as <br /> stated in the Sunnyside report. <br /> Conclusion <br /> Based on the chemical analyses provided for the Terry Tunnel sediment samples <br /> collected, and baseline data from the permit, the material is similar to a <br /> sludge or slime produced at the Sunnyside Mine. The texture indicates it is <br /> fine grained with a deficit of sand-sized particles. The concentrations of <br /> heavy metals, especially Cd, Cu, Pb, Zn and Mn, are similar to sludges rather <br /> than native soils or waste rock. Metal concentrations are high and may pose <br /> problems for water contacting this material . The sediment is acid forming, <br /> potentially toxic, and unsuitable as a plant growth media. Based on these <br /> characteristics, it should be disposed of in a lined basin, and covered with a <br /> material which will allow revegetation of the disposal area. <br /> References Cited <br /> Smith, R. M., W. E. Grube, Jr. , T. Arkle, Jr. , and A. Sobek. 1974. Mine spoil <br /> potentials for soil and water quality. U.S. EPA Report EPA-670/2-74-070. <br /> Sobeck, A. A., W. A. Schuler, J. R. Freeman, and R. M. Smith. 1978. Field <br /> laboratory methods applicable to overburden and minesoils. U.S. EPA Report <br /> EPA-600/2-78-054. <br /> JTD/eke <br /> 8263F <br />