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` ~ Page 2 • • <br />Letter to Dr. James A. Pendleton <br />June 11, 1992 <br />Comment #5 <br />BMG believes that there is no technical basis for concerns <br />relating to the simultaneous use of peroxide and CYTDX. BMG <br />has discussed this issue with Degussa in the context of the <br />treatment at the San Luis facility, who has confirfied that <br />there is no potentially adverse effect related to the <br />simultaneous use of peroxide and CYTOX. BMG has consiistently <br />and clearly stated that CYTOX was intended to reduce the free <br />cyanide levels in the pond as a first step in a theee step <br />process aimed at reducing overall cyanide levels at the <br />tailings facility. Free cyanide was identified as the <br />constituent of immediate concern and CYTOX was selected as the <br />most readily available and an environmentally acceptable <br />reagent for free cyanide removal. The results of studies <br />conducted by BMG and ASCI and submitted to the MLRD clearly <br />indicate that the utilization of CYTOX resulted in a reduction <br />in the free cyanide levels at the pond. The hydrogen peroxide <br />treatment system is not a "maybe technical fix", as sipggested <br />by Dr. Hyatt. Rather, the peroxide treatment process is a well <br />known, documented and proven technology verified by Degussa and <br />FMC from prior similar successful applications. Test results <br />submitted with this application clearly demonstrated tihat the <br />process will be effective in further reducing cyanide <br />concentrations at the facility. <br />Comment #6 <br />There has been no indication from BMG that pond solution color <br />will be used as a analytical method. That was only used as an <br />indication of the progression of the reactions. There will <br />obviously be an adequate number of samples taken and aTalyses <br />made to verify pond results of the cyanide removal in <br />accordance with the approved sampling and analytical protocol. <br />Comment #7 <br />BMG remains committed to the most effective and expeditious <br />process for lowering cyanide levels at the facility and <br />believes that the hydrogen peroxide system is an essential <br />component to attaining this goal. <br />Comment # 8 <br />The INCO process has been selected because it is the most <br />controllable and reliable process which consistently produces <br />the desired results. The INCO process has been thoroughly <br />tested and successfully implemented commercially at a large <br />number of similar facilities. <br />