1992-06-18_REVISION - M1988112 ‎(3)‎

• Permit No: M1988112
• IBM Index Class Name: Revision
• Doc Date: 6/18/1992
• Doc Name: CLASSIFICATION OF TR 009 TO PN M-88-112
• From: MLRD
• To: BATTLE MOUNTAIN RESOURCES INC
• Type & Sequence: TR9
• Media Type: D
• Archive: No

~ III IIIIIIIIIIIII III sTA~ OF COLORADO ~°b
MINED LAND RECLAMATION DIVISION of ~o~
Department of Natural Resources ~~`~_~>
re p
7313 Sherman St.. Room 275 ••.~ ~-{ 7
Denver, CO 80203 4csJ~_
303 866-3567 +,87g
FA X: 303 832.8706
Roy Romer.
Governor
Michael B. Long,
Division Direttor
June 18, 1992
Andre' Douchane
Manager of North American Operations
Battle Mountain Resources, Inc.
5670 Greenwood Plaza Boulevard, #106
Englewood, Colorado 80111
Re: Classification of Technical Revision No. 009 to Permit M-88-112
Dear Mr, Douchane;
On Tuesday, Jun^ 16, 1992, your office submitted a proposal "for the inclusion
of an INCO S02/air cyanide destruction system at the San Luis mine". The
Division is proceeding with its technical adequacy review of your proposed
permit modification. You labeled this submittal "Technical Revision No. 009
to Permit M-88-112". Our rules and regulations state; "'technical revision'
means a change which does not have more than a minor effect upon the approved
reclamation plan." [Rule 1.1(11)] In contrast; "'amendment' means a change
which increases the acreage of the affected land, or which has a significant
effect upon the approved reclamation plan." [Rule 1.1(2)7 As you will
undoubtedly recall, I have previously, both in Board and informal exchanges,
voiced reservations about the classification of this proposed permit
modification.
On page 12 of your application document you state "The INCO S02/Air Cyanide
destruction system for the San Luis site has been designed to reduce the
cyanide concentrations in the tailings slurry to meet permit limitations for
the tailings impoundment solution as set forth in the MLRD Permit No.
M-88-112. An oversized single reactor treatment system will be installed to
ensure that regulated effluent limitations are met. The system has fi0 percent
more cyanide destruction capacity than required for typical operating
conditions. With the proposed system, the mill should continue to operate and
remain within regulatory even under unusual operating conditions."
Based upon your indication that the purpose of the process implementation is
to achieve compliance with the current permit limitations for cyanide within
the tailings solutions, it is my opinion that your INCO 502/Air application
does constitute a technical revision. As I explained to Mark Seminoff in
another context, however, the correct sequence number is TR-010.