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• <br />Memo to Oehler <br />BMRI Abatement #8 Submittal <br />page 4 <br />lifts. This will provide an opportunity and the equipment with w <br />facilitate the sampling of the Lower Pond. If necessary, a tempor <br />earthen material could be temporarily placed on top of the beach <br />small hollow stem auger rig could then be employed to recover a <br />profile of tailings with appropriate in-situ fluid samples for comp <br />analysis. <br />PAES Comments <br />Page #1, Comment #3 <br />Subject of the above commentary. <br />Pages ttl & tt2, Comments #1 - tt2 and #4 - #9 <br />to <br />pad of <br />fines. A <br />These questions are primarily geochemical and were addres~ed by <br />Dr. Posey. <br />Page #2, Liner Integrity Comments <br />It should be evident by now that the Division has always co sidered <br />liner integrity to be an extremely important concern. The D vision <br />intends to require BMRI to continue to observe every appro riate <br />precaution to ensure liner integrity. Further, monitoring ha been <br />installed to ensure early detection of any loss of containment. No <br />evidence has been discerned to suggest any loss of containment. <br />Finally, Dr. Posey has also addressed the concern regarding t~otential <br />deterioration.of the synthetic liners due to unklnown "by-prbducts of <br />detoxification compounds". <br />Page #3, Increased Security and Monitoring Requirements <br />The Division will, as always, assign surety requirements as ~ <br />appropriate for the projected cost of reclamation of the facili y. <br />The Division will require the permit to be structured to prec ude <br />the occurrence of unforeseen degradation. It is not possible or the <br />Division to assign financial value to unforeseen occurrences. <br />