SecProbe.io

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      August 2, 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 July 18, 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 1 in our
letter dated June 22, 2005.  Please confirm in writing our
discussions
conducted on July 29, 2005 regarding the timing and nature of
information related to the ongoing audits, as well as the
uncertainties communicated to you by the IRS with respect to the
realization of your foreign tax credits.  Please also confirm our
discussions as to why you expect to realize a portion of the
deferred
tax asset associated with your foreign tax credits in 2005 and how
this portion differs from the remainder for which you maintain a
full
valuation allowance.

Cyanco Company Financial Statements

Note 5.  Intangible Assets, page 10

	2.	We have reviewed your response to prior comment 3 in our
letter dated June 22, 2005.  We have the following comments:
* We note, in your response, that a significant customer notified
you
in January 2005 that it may not extend its supply contract with
Cyanco
beyond December 2005.  However in your discounted cash flow
analysis,
you assumed that Cyanco would supply a portion of the customer`s
product through 2006.  Please confirm in writing our discussion
conducted on July 29, 2005, regarding the nature and timing of the
communications with this customer, as well as the reasons for your
assumption at December 31, 2004 and March 31, 2005, that this
customer
would continue some sourcing of Cyanco product into 2006, until
you
received notice to the contrary in June 2005.  As part of your
response, please confirm our discussion regarding the timing and
implication of the closure of one of your competitor`s raw
materials
sources on your discounted cash flow analysis in measuring the
fair
value of the customer-related intangible at December 31, 2004 and
March 31, 2005.
* In future filings, please revise your proposed disclosure to
indicate the reasons for your belief in January 2005 that the
customer
would buy a portion of Cyanco product through the end of 2006.
Please
show us what these disclosures will look like.
* Please be advised that the change from using the straight-line
amortization method to units-of-production amortization method is
a
change in accounting principle, not a change in estimate.  See
paragraph 9 of APB 20.  In future filings, please ensure that you
comply with the disclosure requirements in paragraphs 17 and 19 of
APB
20 related to your change in principle.  If the impact is
material,
please also include a preferability letter as Exhibit 18, pursuant
to
Item 601 of Regulation S-K.
* In future filings, disclose in MD&A the impact that the loss of
this
customer will have on your equity in earnings and net income for
2005.

  	3.  In future filings, we remind you to disclose in MD&A the
uncertainties surrounding your significant assumptions on
impairment
and deferred tax valuation allowance matters.  For example, with
respect to your intangible asset impairment, in your Form 10-K and
first quarter 2005 Form 10-Q, you should have disclosed that you
assumed continuation of some supply through 2006 due to informal
discussions and your assessment of market dynamics.  However,
formal
notification indicated supply would only last through 2005, so
additional impairment may be possible.  Similarly, regarding your
deferred tax valuation allowance, please disclose your assumptions
regarding the outcome of the CCRA and IRS audits and the
implication
of the realizability of your foreign tax credits.  Please show us
what
your 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
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Mr. Dennis P. Gauger
Nevada Chemicals, Inc.
August 2, 2005
Page 3

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

         DIVISION OF
CORPORATION FINANCE

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