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Page 4 • • <br />Dr. James A. Pendleton <br />July 31, 1992 <br />remedial measures being implemented by BMR to <br />achieve compliance. BMR shall sample the active <br />pond no later than the following day and submit the <br />samples for analysis in accordance with the approved <br />protocol. <br />(5) In the event that three subsequent weekly rolling <br />average determinations exceed 3.8 mg/1 WAD cyanide <br />and/or 4.4 mg/1 total cyanide, BMR shall immediately <br />cease the operation of its ore processing plant and <br />notify the Division. BMR shall not re-initiate <br />operation of the ore processing plant until the <br />active tailings pond has been determined to be in <br />compliance with the permit limit of 3.8 mg/1 WAD <br />cyanide and 4.4 mg/1 total cyanide and the Division <br />has approved its operation. <br />MLRD Comment No. 2 Part D <br />On the basis of current information, BMR has no reason to <br />believe that the conditions of the tailings at closure would <br />result in the mobilization of cyanide ions in the referenced <br />metallo-cyanide complexes. Therefore, there is no basis at <br />this time to expect deviation from the post closure conditions <br />contemplated in the current permit. This issue as described in <br />the MLRD "interpretation", is fully covered by Abatement <br />Requirement No. 8. As required by Abatement Requirement No. 8, <br />BMR will address any changes to the currently approved <br />reclamation plan which result from documented deviations in the <br />tailings chemistry from that contemplated in the currently <br />approved permit. <br />MLRD Comment No. 3 <br />BMR concurs with the numeric limitations to be established for <br />the tailings ponds, but believes that compliance should be <br />determined on the basis of a calendar monthly average as <br />described in the response to paragraph 2 above. <br />RESPON8E8 TO MLRD'S ANALYSIS OF DAVID HYATT~S COMM~NTB <br />DATED JUNE 18, 1992 <br />DH-3 <br />BMR will monitor the active pond on a daily basis as requested. <br />It should not be necessary to monitor the inactive pond which <br />is in a static condition on a daily basis to assure compliance. <br />BMR believes weekly samples are adequate for compliance <br />monitoring as long as the pond continues to be static and <br />inactive. <br />