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UGC _ -_ u_~Sc F't1 • <br />APPENDIX I <br />GENERAL CDMMENTS <br />• F' . <br />It may be beneficial for all of us to discuss now, certain future considerations <br />that the state must address to help prepare the way. There is no particular <br />order to these Comments. <br />1. Cyanide Definitions <br />Definitions within the mining, chemical and medical industry about "Cyanide" are <br />quite varied. In the gold processing industry we talk about 3 cydnide "types," <br />namely Free, MAD and Total. We at BEI agree with the generally held definitions <br />of the industry, as follows: <br />Free - Limited to only 2 species: (CN)~ and HCN. (CN)~ is highly soluble <br />in water but it exists exclusively only at pH > 11.0. HCN exists, <br />exclusively, at pH < 7.5. At pH's tretween 7.5 and 71.0 both species <br />mutually exist in proportion to the pH, see attached fig. 1. <br />The only exact way to be certain of free-cyanide content is to adjust the <br />pH to 11.0 or greater and analyze for {CN) once all HCN i5 converted to <br />(CN)~, by ion chromatography. The silver nitrate technique is <br />inappropriate as an analytical method because of interference from WAD's <br />end other chemicals present within the tailings. <br />WAD - "Weak Acid Dissociable Complexes" are those metal-cyanide complexes <br />which can, under certain acidic conditions, liberate (CN)_ to the "free" <br />state but which, under typical analytical conditions are often not <br />revealed. At a pH of 4.5 all WAD will release cyanide. Attached as table <br />1 are these complexes in order of their strength (resistance to <br />breakdown). WAD analysis is first accomplished by distillation and <br />therefore WAD inevitably also includes all the free-cyanide component of <br />the solution. <br />Hence WAD cyanide analyses must show a greater cyanide level than a free- <br />cyanide analysis. <br />Total - A total cyanide analysis is composed of all the free-cyanide, all <br />the WAO cyanide, and all other compounds normally not broken down when <br />analyzing for WAD. Thus, compounds Such as Zn2Fe(CN)6 also then "give-up" <br />their (CN) to the total analysis. <br />The writer considers the key components to be Free and WAD since immutable <br />compounds present no hazard. <br />2. Cyanide Concentrations at San_Luis1Doc. No. 2382F). Point (1) <br />BMG has been restricted to "must attain total cyanide levels of less than 4.4 ppm <br />or less, and the weak-acid-dissociable levels of less than 3.8 ppm." <br />With respect, these are unattainable anywhere in the world in any ~o1d extraction <br />process. Before further discussion, however, two points of clarification are <br />offered. <br />