1992-09-08_REVISION - M1988112 (2)

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~ ~ RESPONSE TO COMMENTS BY JAMES STEVENS BMRI's response indicates that the low level of flow, rather than lack of evidence of cyanide, is just~auion for maintaining the sampling frequency for the leak detection system on a monthly basis rather than increasing it to bi-weekly. The Division has not had any problem in securing adequate fluid from the system during the Division's bi-weekly sampling trips, so the Division does not feel that the flow is inadequate. If it is, then bi-weekly sampling and 4nalysis can be conditioned on the basis of there being insq~iciera sample avail461e. Since tJte leak detection system already shows evidence of cyanide, its monitoring on a more frequera basis is desirable in order to be able to better correlate any variations that it may show in cyanide content with those appearing at Otlter bi-weekly sampling sires. RESPONSE: BMR believes that bi-weekly sampling of the collection pond leak detection system is not necessary at this time because increased sampling frequency will not provide additional information concerning site water quality. The primary reason for sampling the collection pond leak detection system is to evalgate the pond's is < < structural integrity and not to establish process system or collection pond cyanide ~, ; concentrations. Bi-weekly sampling to determine cyanide concentration occurs ~wJ~ at five process system points (pre-detox, post-detox, upper impoundment area, ~~ lower impoundment area and the collection pond feeder ditch). An extensive ground water monitoring system is in place to detect the presegce of cyanide outside of the collection pond's containment area. BMR believes that bi-weekly sampling of these locations provides sufficient information regaQding cyanide concentrations in the process system and should allow BMR to respond in an appropriate manner to a release from the collection pond. Bi-weekly sampling of the leak detection system will not provide additional data that addresses either of these concerns. For this reason, BMR believes that bi-weekly sampling of the leak detection system is unnecessary. BMR acknowledges that if significant increased amounts of collection pond solution aze identified in the leak detection system, more frequent samp]ing may be necessary. 2. [No response required.) 3. [No response required.) RESPONSE TO COMMENTS BY DAVID HYATT (DRAFTED BY HARRY POSEY) [No response required.) 2. [No response required.) -ti-