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• Letter to Andre' Douchane, 6MRI Independent Sampling & Analysis page 3 (1) BMRI has expressed concern regarding third party access to its sampling facilities. The Division understands BMRI's concerns. We thirhk it appropriate for BMRI to restrict access to those facilities to itself and its contractors. The third party sampling contractor could observe BMRI complete the sampling. The independent party could then accep$ a split sample to preserve, ship and analyze. The independent contractor would observe entry into the monitoring facility, decontamination of ;all sampling equipment, bailing and sample collection. The third arty could complete an acceptance form for each sample, including an appraisal of the sampling technique. If the third party refused acceptance, stating a specific objection, BMRI could be required to repeat sampling up to some set maximum number of attempts. If concurrence can not be reac ed, the sample would be designated as "rejected" and would be in disput,. (2) The third party sampling contractor would be responsible for prpviding all necessary bottles, reagents, packing, coolers, preservation'; needs, custody forms, etc. The third party sampler would be responsible for sample preservation, transportation and delivery to the indepen erit analytical laboratory. All sampling, analysis and reporting mu,t comply with the approved TR-006 protocol. (3> Under the Board Order of May 28, 1992, BMRI is responsible for he cost of the independent monitoring program. The Contract would requ re the submittal of invoices to the Division's project manager (Harry osey, PhD.). Harry would review and approve the invoice, or return i to the contractor with comments for revision. Harry would forward app oved invoices to BMRI for payment. (4) As you observed in your cover letter of May 4, 1992, the Divisi n will direct the independent monitoring. The Division's project mono er will choose and schedule sampling with the independent contractor. MRI would be provided a minimum of two working days nctice in order to co rdinate the activity with its sampling personnel or contractor. (5) The purpose of the independent monitoring is to verify the monit ring data, not to be vindictive. In order to avoid duplicative effor s on the part of BMRI, split samples retained by BMRI will be deemed by t e Division to satisfy any normal required sampling effort schedule, to occur within two weeks of the independent sampling event. (6) As contained within the Division's TR-006 second technical adequ cy comment letter of June 30, 1992, the Division proposes that inde endent sampling and analysis be conducted no more than 6 times in the f rst quarter of the year following approval of TR-006, no more than 3 times in the second quarter of that year, and no more than 3 times in the second half of that year. At the completion of the first year's indepe dent monitoring the Division will assess the results of the independe t monitoring and propose a schedule for continued independent samp ing and analysis.