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<br />Memo to Board <br />BMRI Compliance Deadline <br />page 2 <br />Recommendation for Compliance Deadline <br />In directing the recommendation of a deadline, the Board also asked the <br />Division to consider the fact that problems could occur at the site end allow <br />enough time for potential problems to be resolved prior to the onset of <br />freezing weather conditions. In completing my formulation of a dead ine <br />recommendation, I have considered; (1) the potential for weather rel ted <br />problems, (2) BMRI's schedule for implementation of the approved INC <br />S02/Air tailings treatment process, (3) the hydraulic capability of he <br />ponds to respond to treatment, and (4) the chemical capability of th ponds to <br />respond to treatment. <br />(1) Normal weather conditions in the San Luis Valley suggest that hard <br />freeze is possible at the BMRI project site anytime after the nd of <br />November. <br />(2) BMRI stated in its TR-O10 application and technical adequacy r~sponses <br />that it intended to complete equipment installation by "late <br />September". BMRI also observed that it anticipated several we ks would <br />be required to test and calibrate the INCO equipment. This se f-imposed <br />schedule suggests that BMRI intends to have the INCO reactor p oducing <br />tailings at the spigot in compliance with the permit standards by <br />October 15, 1992. <br />(3) The hydraulic capability of the ponds to respond to treatment akes it <br />impossible for the collection pond to achieve compliance for u to 7.8 <br />years. I have addressed this consideration in detail in an ac ompanying <br />Memo to the file entitled "Long-Term Detoxification of the Bat le <br />Lower Tailings Pond Upper Tailings Pond Collec ion Pond <br />Date Total (ppm) W.A.D. Total (ppm) W.A.D. Total ( pm> W.A.D. <br />9/13/91 130 110 110 84 <br />1/30/92 240 210 <br />4/24/92 210 210 150 140 <br />5/28/92 230 200 150 110 160 110 <br />6/11/92 270 230 150 110 160 77 <br />CH2O2 Treatment Begun in Lower Pond] <br />7/03/92 31 <br />7/07/92 40 <br />7109/92 12 [H2O2 Treatment Begun in Upper P~nd] <br />7/20/92 10 <br />7/22/92 57 16 15 1 100 52 <br />Clow % Copper Ore Processed] <br />8/03/92 4 1 50 <br />8/12/92 3 1 46 <br />