1992-10-19_REVISION - M1988112 - Laserfiche WebLink

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`' • • letter to Ms. Anne Baldrige, BMRI Comment on Amended TR-006 Protocol Document page 2 On October 6, 1942, BMRI submitted an amended version of the original permit application document, intended to satisfy Stipulation No. 3. Drs. Pendleton and Posey have reviewed the document and have identified one inadegwacy which should be remedied in order to satisfy Stipulation No. 3. Stipulation No. 1 has been properly incorporated on page 15, in Section 2.2.7, "Well Evacuation". However, we have been unable to find a reference to the reporting time limit of Stipulation No. 2 in the amended Protocol document. In light of the occurrence leading to the issuance of the March 31, 1992 violation, which resulted in the development of the amended Protocol, the Division considers the self reporting requirements of BMRI's permit very important. We suggest that BMRI amend the Document to specifically reference the self-reporting requirements, including the 5-day time limit impased by Stipulation No. 2. We suggest this requirement could be presented on page 4, as a subsection of the Introductory Section 1, and in Sections 5.5 and 6.6, which address reporting by the analytical laboratory. Section 1 would present BMRI's requirement to provide prompt notification to the Division. In the case of potentially non-compliant results, we also believe it important to direct the analytical laboratory to provide immediate notification to BMRI by telephone, which would be affected by modifying Sections 5.5 and 6.6. If you have any questions, please contact me at your convenience. Sincerel~i yours, Larry Cehler Reclamation Specialist cc: Andre' J. Douchane, Bt4RI Kan Kluksdahl, Bt4G Dean 14assev. Esq. Maclovio Martinez Nora Jacquez, Esq. Maria Valdez David Hyatt. PhD. Roger Flynn, Esq. Jane Kircher Mike Long, Dircetcr, DMG Bruce Humphries, DMG James Stevens, ahD., ~t•+G Harry Po52y, PhD., GMG James Pendleton, PhD., DMG Doc. No: 5132E LDO/jp