1992-06-12_REVISION - M1988112 ‎(7)‎

• 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

999
•
STATE OF COLORADO
MINED LAND RECLAMATION DIVISION
Department of Natural Resources
1313 Sherman SL, Room 215
Denver, CO 80203
303 866-3567
FA%:303 832-8106
MEMORANDUM
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Roy Romer,
GOVerrgr
DATE: June 12, 1992 Michael B. Long,
Division Director
TO: Jim Pendleton
FROM: Harry Posey
RE: Critique of David Hyatt comments and BMG'e response; TR-007;
addition of H2O2 to the tailings pond; Battle Mountain Gold Company;
San Luia Project; Permit No. M-88-112.
Having completed a review of Dr. Hyatt's technical adequacy commends and Battle
Mountain Resource's response to those comments, I offer the following
observations regarding the status of TR-007.
Comment #1.
The Division understands that application of hydrogen peroxide (HZ02) to
the containment ponds is not intended to lower the concentrations of weak
acid dissociable (WAD) cyanide to specific levels. Rather, the intent ie
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 used 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 'fR-005. In
accordance with that order, the question of whether or not plant operation
will continue will be considered by the Board during their Jyne 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 Division considers
H2O2 treatment to be a temporary and interim measure designed do 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 earlieir Division
comments to monitor the pond at six sampling stations and 2 levels. The
Division considers this to be an adequate sampling protocol for the pond.