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~. ~. <br />• <br />Letter to Andre' Douchane, BMRI <br />Comments regarding June 25, 1992 Order <br />page 2 <br />In addition to thorough and verifiable data on WAD cyanide levels i the <br />tailings ponds, I recommend that BMRI maintain a precise record of ~lydrogen <br />Peroxide application to the tailings ponds. I suspect you maintain'~these <br />records for process supervision and management purposes. Compariso of <br />Peroxide application with the WAD cyanide level data should allow B RI to <br />determine the response of the tailings ponds and facilitate perfect on of the <br />Hydrogen Peroxide treatment project approved under TR-007. Finally I <br />recommend that BMRI document all efforts expended in its pursuit of the Board <br />ordered "lowest reasonably achievable levels" of cyanide in the tai ings ponds. <br />With all of the above enumerated data and related information, the ivision <br />should be able to render an enlightened statement of its "belief" o July 22, <br />1992, in the context of the status report on the detoxification pro ess <br />required by sub-paragraph (5,a) of the Order. Finally, based on th above <br />data, the Division should be able to "recommend a compliance schedu e, <br />including any necessary corrective actions, for reducing the level f cyanide <br />to 4.4 ppm total cyanide and 3.8 ppm WAD cyanide", as directed by <br />sub-paragraph (5,b). If, in the unfortunate alternative, the Divi~icn is not <br />in possession of thorough and verifiable data and supporting inform tion as <br />discussed above, I may be hard pressed to find that BMRI has exerci ed "its <br />best efforts" towards achieving the "lowest reasonably achievable 1 vets". <br />If you have any questions regarding my observations and comments, I encourage <br />you to respond expeditiously. I believe it absolutely critical for BMRI that <br />we eliminate any misunderstanding as soon as possible. <br />Sind, <br />~w <br />-James/A. Pendleton, PhD. <br />~ ~ / technical & Scientific Coordinator <br />cc: Michael Long, MLRD Director <br />James Stevens, PhD., MLRD <br />Bruce Humphries, MLRD <br />Larry Oehler, MLRD <br />Gary Dodson, BMRI <br />Dean Massey, Esq. <br />Doc. No: 3884E <br />JP/jP <br />