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BEFORE THE MINED LAND RECLAMATION BOARD STATE OF COLORADO Permit No. M-88-112 INTERIM ORDER CONCERNING DETOXIFICATION ------------------------------- BATTLE MOUNTAIN RESOURCES, INC. DRAFT 1. This matter concerns an enforcement action brought by the Mi ed Land Reclamation Division ("the Division") against Battle Mountain Resources, Inc. ("BMRI") pursuant to §34-32-124, C.R.S. (1984 & 1991 Suppl.) for failu e to comply with the terms and conditions of its permit. Following a hearing, the Mined Land Reclamation Board ("Board") issued an order dated May 28, 1992 ("the M y Order") which among other things required BMRI to bring the cyanide levels in he tailings slurry and the ponds into compliance with the permit provisions by no ater than June 24, 1992. 2. Pursuant to paragraph 18 of the May Order, the Board held a Baring on June 24, 1992 to consider detoxification efforts at the site and to co Sider the need for additional corrective actions. 3. Following the June 24, 1992 hearing, the Mined Land Reclamat on Board ("Board") issued an additional corrective action order dated June 25, 992 ("the June Order"), which among other things required BMRI to reduce the wea acid dissociable (WAD) cyanide level in the tailings ponds to less than 50 pm by July 3, 1992, and to maintain it below that level thereafter. The order also equired BMRI to implement the additional ground water monitoring proposed in its to hnical revision TR-008, and to use all reasonably practical steps to continue to lower the cyanide levels in the ponds to the lowest reasonably achievable levelsII and to continue to use its best efforts at all times to achieve that goal. Tlhe order directed the Division to provide the Board with a status report on thel detoxification process at the July 22, 1992 Board meeting. The order ~lso directed the Division to recommend a compliance schedule, including any necessa y corrective actions, for reducing the level of cyanide to 4.4 ppm total cyanide an 3.8 ppm WAD cyanide. 4. As of July 3, 1992, BMRI had reduced the cyanide levels in t e "active" (actively receiving tailings from the ore processing plant) lower tail ngs pond to less than 50 parts per million ("ppm") weak acid dissociable "(WAD") c anide as required by the June Order. In addition, BMRI has maintained the WAD yanide level below 50 ppm thereafter. As of July 9, 1992, the WAD cyanide level in the active lower tailings pond was determined to be 12 ppm. Monitoring of the ac eve lower pond during the implementation of iR-007 has determined that the hydro en peroxide treatment appears capable of reducing the WAD cyanide level to 15 ppm r less in an active pond. 5. BMRI has agreed to continue to implement TR-007 and to use t e approved hydrogen peroxide method as an interim process to achieve additional r duction in the cyanide level in the tailings ponds. BMRI also proposes to implem nt the INCO S02/Air tailings treatment process described in TR-010 as a final proc ss to