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• The upper threshold limit (lower for pH) would be considered a control limit. If a <br />• water quality pazameter goes out-of-control, BMRI would notify the Division and <br />institute additional response measures. <br />• If the CUSUM test for any required parameter shows that three consecutive sampling <br />events have positive CUSUM values (indicating a trend of increasing average <br />concentration for the average value in the eleven wells of the performance monitoring <br />zone), BMRI would notify the Division and initiate an investigation of the cause of <br />the trend. BMRI will report the results of the investigation artd recommend <br />contingency actions, if any aze needed, before a pazameter exceeds the upper control <br />limit. <br />The Phase lperformance-monitoring program would continue until DMG is satisfied that water <br />quality in the alluvial groundwater system has been restored to a satisfactory level. <br />As water quality approaches levels that anticipates DMG final goals, BMRI will submit a <br />detailed plan for post-closure water quality monitoring in the alluvial system <br />6.4.2.2 Final Groundwater Monitoring of Alluvial Groundwater <br />• While the post-closure monitoring plan for groundwater will be submitted in the future, BMRI <br />anticipates that such a plan would include the following elements: <br />• Identification of a final "compliance zone," rather than a traditional "point of <br />compliance," to address the issues of flow-field heterogeneity discussed above and in <br />the CWQCC Statement of Basis. This might be a set of wells located at or neaz the <br />property boundary, rather than the Phase lperformance-monitoring zone defined <br />above. <br />• Identification of a final set of numeric criteria for water quality in the alluvial <br />groundwater. These values would be either standazd values or site-specific values <br />established using procedures identified and approved by the State. <br />• Identification of monitoring procedures and testing and reporting schedules <br />• Identification of the statistical basis for demonstrating compliance <br /> <br />Battle Mountain Resources, /nc <br />pa/002671reportslmnrchrptltr?6wermngrmarch.dac 75 Mnrch 22,/999 <br />