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J ~ <br />III III IIIIIIIIIIIII prrse~~~~f i~e~^~-.vas <br />.* <br />PROPOSAL <br />To: MINED LAND RECLAMATION BOARD <br />From: BATTLE MOUNTAIN RESOURCES PARTY OBJEC'~'ORS <br />Date: JUNE 24, 1992 <br />RE: Detoxification of Battle Mountain Resources <br />Operation at San Luis, Colorado <br />On April 23, 1992 the MLRB gave BMR 60 days, or yntil the <br />June Board Meeting, to detoxify the operation. Th~ cyanide <br />levels are still in excess of the permit levels. he party <br />objectors oppose an extension of the Battle Mountain ;Resourc- <br />es detoxification deadline beyond today's date, if tk~e exten- <br />sion includes permission for full operation of thei facili- <br />ties with cyanide ppm above the permit levels. <br />This position of the party objectors is taken because: <br />1. The cyanide level of the permit requires a cyanide <br />level of 4.4ppm for Total cyanide and 3.8ppm for AD cya- <br />nide. Battle Mountain Resources, in full operat on, has <br />been in violation of its permit since at least Septe ber 13, <br />1991. This is nine months and eleven days of nonco liance. <br />A continued full scale operation will result in ntinued <br />non-compliance by BMR. <br />2. BMR has used or considered the use of three different <br />de-toxification processes: cytox, hydrogen peroxide,'and the <br />INCO sulfur dioxide process. The ability of these p~ocesses <br />to reduce the cyanide to permit levels is questionab e. YET <br />BMR CONTINUES IN FULL OPERATION. <br />3. Full operation means the addition of new cyani e. The <br />continued use of the toxic agent, cyanide, while at empting <br />to detoxify the operation is illogical. <br />BMR claims that full operation is essential for e~Efective <br />detoxification. We maintain that full operation -is only <br />essential from a profit standpoint. The permit i~sued by <br />MLRB in 1990 was not issued as a profit guarantee bu rather <br />as a safeguard for the environment and for humans. Our ex- <br />pert maintains that neither cyanide nor additionaliore are <br />necessary for effective detoxification. (see EXHIBITIA) <br />We propose that BMR continue the detoxification ttempts <br />WITHOUT THE ADDITION OF CYANIDE as an incentive fo BMR to <br />comply with the permit. The cytox and the hydrogen eroxide <br />can be effectively mixed into the pond without ad itional <br />cyanide. The operation of the system without the add tion of <br />cyanide is a minimum first step for Battle Mountain esourc- <br />es to achieve permit compliance. <br />