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<br /> <br />-3- <br />4. Tailince Cvanide Detoxification: (continued) <br />CCCD Question: What ie being done to detoxify the tailings placed during the <br />period of non-compliance? ~I <br />Division Answer: At present no direct effort is being made to detoxify <br />non-compliant tailings treated by the original AVR cyanide destruction system. <br />The only detoxification taking place in these tailings at this time ie due to <br />attenuation. <br />CCCD Question: What ie the level of cyanide in these tailings? <br />Division Answer: We do not know. BMRI ie sampling and analyzing the <br />non-compliant AVR tailings in an effort to satisfy Division conc rns about <br />BMRI's evaluation of their tailings area reclamation plan (Abate ent Item 8). <br />All parties will have access to these analytical results at the ime they are <br />submitted to the Division. <br />CCCD Question: What is the level of cyanide in the effluent fromthe tailings <br />underdrain system? <br />Division Answer: BMRI monitors cyanide concentrations at this to¢Iation to <br />determine how much hydrogen peroxide must be added to treat coll$ction pond <br />water. Recent analyses indicate 7.5 ppm WAD and 8.5 ppm total ccc snide. <br />CCCD Question: Which "compliance" requirements are being met forthe process <br />water monitoring sites, the tailings pond, and collection pond - the <br />requirements of the permit level of cyanide or the Division leve} of cyanide <br />referred to in the February 24, 1993 report? <br />Division Answer: The requirements of the permit. <br />5. Leak Detection Svetem Effluent Containment: <br />Status: Completed. <br />BMRI has committed in a letter dated April 16, 1992, to repair tk~e primary liner <br />if a leak is detected. <br />Exolanation: The leak detection system referred to in abatement requirement no. <br />5 ie the eystem in place at the collection pond below the tailin a ponds. If <br />leakage exceeds EPA allowable limits, BMRI would be required to epair the <br />primary liner. A pump back system is in place to dewater the pond if repairs <br />become necessary. <br />CCCD Statement: A commitment from Battle Mountain Gold to repairthe primary <br />liner is not sufficient. There must be a plan which outlines thepJJ specifics so <br />that speed and efficiency are maximized in the event of a disaster. We do not <br />feel there is such a plan. <br />Division Answer: Any such leak referred to above would be a leak in the primary <br />liner and would be contained between the primary and secondary 1' er. This <br />water can be pumped back into the collection pond and then to th plant storage <br />tanks and/or the free water pools on the tailings surface. The ivieion <br />interprets your comment ". in the event of a disaster" to refs to a leak <br />beyond the secondary (lower) liner. Any such leak is overed b lan, <br />Technical Revision No. 9, which contains a plan for containment and <br />remediation of contaminated ground water if it should migrate fr the <br />containment area. <br />