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<br />RESPONSE TO COA'II~~NT BY JAMES PENDLETON <br />1. [PattialJ...lf BMR] intends to employ Core Laboratories to provide analytical <br />services for its required environmental monitoring program, the Division believes <br />it would be inappropriate to use Core Laboratories for the independenu third party <br />veriftcation analysis. BMRI should clarify its intentions if it desires <br />A reconsideration of Core Laboratories as a third party analytical contract. <br />~/1 ~ The Division concurs with BMRI's statemems relating to the completion of an <br />appropritue comractual arrangement with the selected third party sampling and <br />analytical contractors. The Division would appreciate any assistpnce BMRI can. <br />provide in this matter... However, the Division intends to imposes the completion <br />of the third party comract as a stipulation upon tJte approval. <br />...At the end of the first year [of the third parry sampling] the Diviision intends to <br />reassess tJte required frequency of independent sampling and analysis. <br />The Division concurs with BMRI's concerns regarding insurance verification by <br />the dtird parry contractors. In order to comrol cost, the Divisiot- proposes that <br />BMR/ conduct its required monitoring in unison wilt independent ver•ihcation <br />rounds. BMRI's normal sampling professionals nray conduct all sample collection <br />under the scrutiny of tJre third party. The tlrird party would contplQre an approval <br />document and chain-of-custody documentation for a split sample received from <br />BMRI's professional. This procedure should eliminate BMRI?s concern for <br />compromise or damage to any of BMRI's monitoring facilities. <br />The division imends to solicit professional fee schedules froth each of the <br />nominated professionals for the purposes of completing the contract for third <br />party services. <br />RESPONSE: The Division has selected Core Laboratories to perform the independent third <br />party verification ana]ysis. All samples obtained in the third party sampling <br />program will be coded by RCG/Hagler, Bailly, Inc. and delivered to Core in a <br />manner to ensure that the source of the samples is not known to Core. BMR <br />believes [hat this approach addresses the Division's concern that the use of Core <br />as a third party lab is inappropriate by eliminating any potential fqr bias. BMR <br />intends to continue to utilize Core for its ongoing analytical testing needs. <br />-7- <br />