A few random thoughts.
1) Typically for a new ISR project or a major modification to an existing one, as per the change from alkaline to acidic, a field leach trial would be performed to test chemistry, metallurgy, etc. and to demonstrate environmental compliance.
2) I'm puzzled that PEN has not mentioned the requirement to conduct this field leach trial for the acid conditions. They would definitely require regulatory approval for this field leach trial so the possibilities are:
a) Is PEN planning on doing a field leach trial for the low pH scenario? Considering their past performance, I would say it is mandatory for them to do the trial to confirm the chemistry over a long period of time. The lab tests cannot / should not be used to demonstrate the technology and design the plant. I can't recall PEN announcing a field leach trial.
b) Has PEN applied for and received approval for the trial?
c) Has the duration for the trial been considered - 6 to 9 months would be my guess.
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