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<br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman SI.. Room 275 <br />Denver. CO 80203 <br />303 866-3567 <br />Fn x. 303 832-8706 <br /> <br />STATE OF COLORADO <br />pF' COQ <br />- 4 <br />7 <br />•. ' P o <br />~/&~ obi <br />MEMORANDUM <br />Roy Romer. <br />Governor <br />DATE: June 12, 1992 Micnaei 6. bong, <br />Division Dnector <br />TO: Jim Pendleton~,~// <br />FROM: Harry Posey CLF~~r`~-7 <br />RE: Critique of David Hyatt'/comments and BMG's response; TR-007; <br />addition of H2O2 to the tailings pond; Battle Mountain Gold Company; <br />San Luis Project; Permit No. M-88-112. <br />Having completed a review of Dr. Hyatt's technical adequacy comments and Battle <br />Mountain Resource's response to those comments, I offer the following <br />observations regarding the status of TR-007. <br />Comment #1. <br />The Division understands that application of hydrogen peroxide (H2O2) to <br />the containment ponds is not intended to lower the concentrations of weak <br />acid dis~ociable (WAD) cyanide to specific levels. Rather, the intent is <br />to lower the WAD concentrations to levels that are safer for the <br />environment. <br />Comment #2 <br />The Division has questioned from the beginning the characteNization that <br />cYTOx generated complexes are known to be stable under the range of <br />conditions that will affect the tailings in future. However, the Division <br />accepts that cYTOX is a temporary treatment, not to be ysed for the <br />duration of the operation. <br />Comment #3 <br />Dr. Hyatt has questioned the justification for continued operation of the <br />processing plant during the implementationm of H2O2 treatment. Battle <br />Mountain is under a Board order to continue operating the plant to <br />implement the CYTOX treatment process in accordance with TR-005. In <br />accordance with that order, the question of whether or not plautt operation <br />will continue will be considered by the Board during their June 24, 1992 <br />Board meeting. <br />Comment #4 <br />The Division considers H O treatment to be a temporary and interim measure <br />designed to lower WAD cyanide levels in the pond. The Division considers <br />H2O2 treatment to be a temporary and interim measure designed to lower WAD <br />cyanide levels in the pond. The measure does not release CMG from the <br />present requirement for a 24-hour guard to protect wildlife from entering <br />the facility. Under these conditions, the Division considers the present <br />H2O2 delivery system to be adequate for the intended purpose and for the <br />intended short duration. <br />comment #5 <br />See comment #1. <br />Comment #6 <br />Battle Mountain Gold has committed in response to earli@r Division <br />comments to monitor the pond at six sampling stations and 2 Levels. The <br />Division considers this to be an adequate sampling protocol for the pond. <br />