1992-06-12_REVISION - M1988112 ‎(5)‎

• Permit No: M1988112
• IBM Index Class Name: Revision
• Doc Date: 6/12/1992
• Doc Name: MEMO-CRITIQUE OF DAVID HYATT COMMENTS AND BMG RESPONSE TR-007-ADDITION OF H2O2 TO THE TAILINGS POND
• From: MLRD
• To: JIM PENDLETON
• Type & Sequence: TR7
• Media Type: D
• Archive: No

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MINED LAND RECLAMATION DIVISION
Department of Natural Resources
1313 Sherman 57., Room 215
Denver, CO 60203
303 866-3567
Fn x: 303 632-8106
DATE: June 12, 1992
TO:
Jim Pendleton
FROM: Harry Posey
MEMORANDUM
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qoy Romer,
Gwemor
Micnaei B. Long,
Division Director
RE: Critique of David Hyatt comments and HMG's response; TR-007;
addition of H2O2 to the tailings pond; Battle Mountain Gold Company;
San Luis Project; Permit No. M-88-112.
Having completed a review of Dr. Hyatt's technical adequacy comments and Battle
Mountain Resource's response to those comments, I offer tthe following
observations reaardina the status of TR-007.
Comment #1.
The Division understands that application of hydrogen peroxide (H2O2) to
the containment ponds is not intended to lower the concentrations of weak
acid dissociable (WAD) cyanide to specific levels. Rather, the intent is
to lower the WAD concentrations to levels that are safer for the
environment.
Comment #2
The Division has questioned from the beginning the characterization that
CYTOX generated complexes are known to be stable under the range of
conditions that will affect the tailings in future. However, the Division
accepts that CYTOX is a temporary treatment, not to be cased for the
duration of the operation.
Comment #3
Dr. Hyatt has questioned the justification for continued operation of the
processing plant during the impLementationm of H2O2 treatment. Battle
Mountain is under a Board order to continue operating the plant to
implement the CYTOX treatment process in accordance with TR-005. In
accordance with that order, the question of whether or not plant operation
will continue will be considered by the Board during their JWne 24, 1992
Board meeting.
Comment #4
The Division considers H2O2 treatment to be a temporary and interim measure
designed to lower WAD cyanide levels in the pond. The Divisimn considers
H2O2 treatment to be a temporary and interim measure designed to lower WAD
cyanide levels in the pond. The measure does not release BMG from the
present requirement for a 24-hour guard to protect wildlife from entering
the facility. Under these conditions, the Division considers the present
H2O2 delivery system to be adequate for the intended purpose and for the
intended short duration.
Comment #5
See comment #1.
Comment #6
Battle Mountain Gold has committed in response to earlier Division
comments to monitor the pond at six sampling stations and 2 levels. The
Division considers this to be an adequate sampling protocol far the pond.