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-HNULL6IE~ INC. TEL~303-7.+2-5533 Jun 09 92 ~0~07 No.OG2 P.03 <br />• <br />o There ie no indication that the processing of the pond with pero a will <br />require continued processing of ore through the plant (as was pu ported <br />with the CY4'OX process) and thus I would again raise the su estlon <br />that the processing of ore be stopped while the cyanide levels in the pond <br />ere reduced to the target 4 ppm total cyanide by peroxide alone. <br />In introducing this approach at the May public hearing, BMG indicated <br />that the delay in putting peroxide treatment in place would mitigate <br />against Its use as an alternative to CY1Y)X, but this delay seems to not be <br />an Issue of substance at this point. <br />o The introduction of peroxide into the pond w(thout some means of mixing <br />certainly raises the probability that uneven treatment will occur ana that <br />cyanides w;ll escape destruction. Gravity Induced mixing and diflY;sion of <br />the reagent are not reliable techniques. <br />Dr. E.A Devuyst, in the paper entitled "Cyanide Pollution Control .The <br />Inco Process" distributed at the (SMG sponsored) meeting we reoently <br />attended to hear details of the process notes that; <br />"Hydrogen cyanide is selective for cyanide in solutions, but i an <br />extremely expensive reagent which, In many cases decomposes rapit~ly in <br />the presence of solids. This may lead to high reagent consumption anld/or <br />incomplete cyanide destruction" (italics, mine). <br />If peroxide Is used in the San Luis ponds, then it would seem prudeht to <br />assure mitdng to at least have a chance oP maximizing cyadldes <br />decomposition. I~ection of the peroxide at the spigot might move toward <br />accomplishing this but probably at the cost of signiflcanlly hiklter <br />peroxide demand. <br />o As in much of the work and proposed work which has preceded this i test <br />revision, there to precious little laboratory data with real solutfons under <br />conditions that accurately redact practice at San Luis (for exa le, <br />simultaneous use of peroxide and CYTOX) to demonstrate the abilit to <br />reach 4 ppm cyanide levels. <br />The AVR system was supposed to work (based on design estimates) anki it <br />apparently did not. The decomposition of cyanide in the ponds did hot <br />proceed as MODELED and inadequate testwork was performed'. to <br />determine whether it should have. Ore characterizations were not all t~ey <br />should have been, and hence the copper "problem" which complicates the <br />cyanide destruct[on chemistry. CYTOX was supposed to reduce cyanl~lea <br />(total cyanides as we were given to understand at the hearing) to 4 ppm <br />but there la no evidence that this is going to be achieved. <br />All in all, then seems to 6e too much emphasis to jump on the latest <br />"maybe" technical fix and not to test it first in a thorough manner. A <br />1A60992DEH1 <br />