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<br />Discussion: <br />The permit approval for the BMG tailings area required <br />that humidity cell testing be performed on a quarterly <br />basis to verify the tailings characterization in the <br />original application, specifically the charact rization <br />that the tailings do not exhibit acid generati g poten- <br />tial. Four tests have been performed since the start of <br />the BMG operations and have shown no appreciable hange in <br />acid generation potential. <br />BMG will conduct additional geochemical testing d ring the <br />cyanide detoxification procedures currently ongoi gat the <br />site. At the conclusion of the detoxification pr cedures, <br />BMG will conduct acid generating/acid neutralizin testing <br />and humidity cell testing to monitor any Chang s in the <br />chemical constituency of the tailings which migh require <br />changes in the approved reclamation plan. The testing, <br />data review and development of a modified plan ill take <br />approximately eighteen weeks to complete (twelve weeks to <br />complete humidity cell testing, two weeks to obt in final <br />water sample analysis, one week to review the ata, and <br />three weeks to modify the reclamation plan, if n cessary, <br />and develop a comprehensive report for submittal to the <br />agency). <br />BMG will submit a comprehensive report detai ing the <br />results of the testing to the Division for re iew and <br />approval no later than 180 days following compl tion of <br />the tailings cyanide detoxification program, whi h should <br />occur by May 25, 1992. If the test results indi ate that <br />a permit revision or permit amendment is n cessary, <br />documentation of the revised reclamation plan wil also be <br />submitted. Should a permit amendment or technical revision <br />be necessary, the report will be prepared in a cordance <br />with applicable standards. <br />(9) Amendment of Environmental Monitoring Plan: <br />BMG shall revise its environmental monitoring plan to <br />include direct monitoring of the cyanide an metals <br />content of the tailings slurry and liquids. W'thin 15 <br />days following the cyanide detoxification of the ailings <br />area contents, described in item (4), BMG shal submit <br />sampling methodology, sampling locations and sampling <br />protocol for tailings cyanide and metals content <br />monitoring to the Division for review and approvlal. <br />Further, BMG shall appropriately revise its entire <br />environmental monitoring plan, including gro nd and <br />surface water, and processing circuit monito ing, to <br />reflect all revisions completed in compliance wi h these <br />6 <br />