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<br />BMRI finds the progress and direction of the third p~rty <br />sampler unacceptable. RCG has represented themselves) as a <br />contractor desiring and capable of performing the third <br />party independent sampling within a monetary budget a~d a <br />specified time frame. RCG has failed in this effort, not <br />once, but twice. This situation cannot be allowed to <br />continue. <br />BMRI believes, though well-intended, the third party <br />sampling effort has not been substantiative in its fidings. <br />No new issues have been identified thrcugh the third arty <br />sampling program. This fact coupled with the contrac ual <br />breach of obligations by RCG suggests this program be <br />discontinued or at a minimum modified. BMRI believes there <br />exists a viable compromise position for resolution of the <br />third party sampling. <br />BMRI proposes that the next third party site visit be, <br />postponed until all outstanding site visit reports ha a been <br />finalized by RCG (trip reports three and four). It s ould <br />be noted that BMRI has already submitted analysis rep its to <br />the Division for these sampling events. BMRI should e <br />given the opportunity to respond to any issues of sub tance <br />included in the site visit reports prior to release. Then, <br />during the fourth time period, a final sampling visit will <br />take place. As per the contract and MOU, the third party <br />sampling program will be evaluated in October. <br />The resolution position maintains the intent and purp~se of <br />the third party sampling efforts to verify on-site sa pling <br />procedures and report laboratory results. A calendar year <br />period (October 1992 through October 1993) of samplin will <br />have occurred to verify data generated by BMRI and th <br />outside laboratory. The resolution will allow for a hrough <br />review of procedures and results and will provide for'any <br />potential concerns to be addressed. The third party <br />contract will be concluded in October 1993 and costs dill be <br />maintained within the revised budget. BMRI awaits th@ <br />Division's response co this matter. <br />Sincerely, <br />~~Uv~C ~ ~ ca~ <br />Alana L. Scott <br />Environmental Engineer <br />cc: Jim Pendleton <br />Larry Oehler <br />Anne Baldrige <br />Ken Kluksdahl <br />Mike Young <br />