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~~ <br />at this well in the same manner as approved for new <br />wells SF-1, M-4R and M-15. <br />MONITORING PARAMETERS AND COMPLIANCE LEVELS: Does BMRI <br />want to include mention that Permit Condition values for <br />all new wells intended to be drilled in the near future <br />and to subsequently serve as Points of Compliance, eg. <br />SF-1, M-4R and M-15, will be set at the end of the first <br />monitoring year using the same Dixon methodology employed <br />to establish Permit Conditions for the existing wells <br />selected to serve as Points of Compliance? <br />REPORTING: The wording in the first paragraph under this <br />heading is phrased as to suggest that only values that <br />exceed Permit Conditions will be subject to notification <br />requirements and sample verification procedures. This <br />would seem to eliminate reporting and sample verification <br />of pH values that fall below the range of Permit <br />Conditions. It is suggested that the wording in this <br />paragraph be revised to consistently indicate values <br />outside the approved range of Permit Conditions are <br />subject to notification and sample verification <br />prodcedures. <br />REPORTING: The Divison would prefer some acknowledgement <br />be made by BMRI, possibly under this heading, that if an <br />indicator parameter value lies outside the range of the <br />equivalent Permit Condition in any quarterly monitoring <br />event and also continues to lie outside that range in <br />both of the two verification samples, that the Division <br />mad! notice BMRI of a possible violation of a condition of <br />its permit. <br />REPORTING: The wording in the second paragraph also <br />speaks only of "exceedances" while it is values of <br />indicator parameters that lie outside the approved range <br />of Permit Conditions that require notices and <br />verification samples. The Division suggests revised <br />wording to make that clear. <br />REPORTING: Does BMRI want to include a commitment, as was <br />done at one point previously, to construct quarterly <br />"control charts" for parameters serving aS Permit <br />Conditions and to submit these along with the reports of <br />the quarterly monitoring? <br />REPORTING: The Division requires a commitment on the part <br />of BMRI to submit the reports of the quarterly monitoring <br />on a quarterly basis. <br />DEFINITION OF TERMS <br />Permit Condition Values: The Division suggests that the <br />wording of this definition be modified to acknowledge <br />