SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      June 22, 2005

via U.S. mail and facsimile to (801) 984-0231

Dennis P. Gauger
Chief Financial Officer
Nevada Chemicals, Inc.
9149 So. Monroe Plaza Way, Suite B
Sandy, UT 84070

      RE:	Nevada Chemicals, Inc.
		Form 10-K for the year ended December 31, 2004
      Filed March 18, 2005
      File No. 0-10634

Dear Mr. Gauger:

      We have reviewed your response letter dated June 7, 2005 and
have the following additional comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable.
In
some of our comments, we may ask you to provide us with
supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Form 10-K for the year ended December 31, 2004

Financial Statements

Note 7.  Income Taxes, page F-13

1.	We have reviewed your response to prior comment 8 in our
letter
dated May 9, 2005.  Please confirm our understanding that the
deferred tax assets arising from foreign tax and other credit
carryforwards relate to the income tax amounts accrued for
resolution
of the audit by the CCRA, as disclosed in note 14.  If so, please
explain why, if these accruals meet the "probable" criterion in
paragraph 8.a of SFAS No. 5, the realization of the resulting
deferred tax asset does not meet the lower threshold of "more
likely
than not" in paragraph 17.e of SFAS No. 109.  As part of your
response, please tell us how the expiration dates of the tax
credits
compare to your estimates regarding the length of time for CCRA to
complete the audit.  In addition, in future filings, please revise
your disclosures to clarify:

* that the foreign tax and other credit carryforwards are
comprised
primarily of estimated foreign tax credits projected to result
from
the final settlement and payment of income taxes in Canada.

* that the realization of these deferred tax assets depends on the
results of the CCRA audit process discussed in note 14 and the
expiration date of these tax credits.

* the expiration date of these tax credits, pursuant to paragraph
48
of SFAS No. 109.

Cyanco Company Financial Statements

Note 2.  Acquisition, page 7

2.	We note your response to prior comment 10 in our letter dated
May 9, 2005.  We do not understand your basis in GAAP for charging
amounts in excess of the minimum revenue sharing amount of
$900,000
to cost of sales.  In future filings, please recognize these
excess
amounts as part of the cost of the acquisition, as required by
paragraph 28 of SFAS No. 141.  Separately, please test for
impairment
as required by SFAS No. 142 and SFAS No. 144, when indicators
suggest
that the carrying amount of the acquired property, equipment, and
customer relationships is not recoverable.

Note 5.  Intangible Assets, page 10

3.	We have reviewed your response to prior comment 11 in our
letter
dated May 9, 2005.  Please note that potential competitive harm
that
may arise from disclosure of the facts and circumstances leading
to
the impairment of your customer-related intangible is not a
sufficient reason for not complying with GAAP.   Please show us
your
proposed disclosures to comply with paragraph 46.a of SFAS No. 142
in
future filings.  In addition, in your management`s discussion and
analysis, please disclose known trends and uncertainties related
to
your customer`s negotiations on Cyanco`s revenues and your net
income, in light of Cyanco`s significant dependence on customers,
as
disclosed on page 2.  See Item 303(a)(3)(ii) of Regulation S-K.
Please also show us what these disclosures will look like.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your  responses to our comments.

      You may contact Jenn Do at (202) 551-3743 or me at (202)
551-
3255 if you have questions regarding these comments.

								Sincerely,

								Nili Shah
								Branch Chief
??

??

??

??

Mr. Dennis P. Gauger
Nevada Chemicals, Inc.
June 22, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>