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<br />~~' <br /> <br /> <br /> <br /> <br /> <br /> <br />1 <br /> <br />1 <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />COMMENT BY JAMES PENDLETON <br />1. [ParlialJ... The third parry verbcation shall consist of sample collection and <br />analysis, by third party professionals, at BMG's expense, at a frequency <br />determined by the Division. 77re Division believes drat it is appropriate for BMG <br />and the odrer pat7ies to nomitate professionals to perforn the sample collcaiarr. <br />and labora[ory analysis tasks. T1re Division ituends to selec! appropriate <br />professionals front drese nominees. The Division will then direct the selected <br />professionals to complete the third party verification sanrplirrg analysis when the <br />Division deems it appropriate. The third parry sampling and analysis will be <br />corrduaed in accordmrce with the final protocol approved in Qonrpliance with <br />Abatement Requirement 1112. BMC will be offered splits of all spnrples collected <br />during third party sampling procedures. 77re Division intends ro order conduct <br />of the drird party verification on a rmrdom basis. <br />BMG should nominate professionals to perform dre third perry rgri~ication water <br />quality sampling and analysis, as a potion of its proposed sampling and <br />analytical protocol. BMG nrny include any additional specifications regarding the <br />conduct of drese drird parry ver~catiarrs whiclr it deems appropriate far the <br />Division's consideration. <br />RESPONSE: In its letter dated May 4, 1992, BMR nominated Water, Waste and Land, Inc., <br />a Fort Collins based consulting firm with considerable experience in water <br />sampling activities at similarly situated facilities involving cyanide constituents, <br />to conduct the sampling phase of the third party monitoring program. A <br />statement of WWL's qualifications and experience is attached for your review. <br />BMR would nominate Core Laboratories, Inc. to conduct the an>lytical phase of <br />the program. Both of these companies have considerable experience in dealing <br />with the issues presented by the third party monitoring program, are well known <br />and recognized as experts in their field and are located proximate to the Denver <br />area, which wold expedite contract administration. <br />As noted in its May 4 letter, BMR will insist that the third party monitoring be <br />conducted pursuant to a formal contractual arrangement with 1$MR as a party <br />which includes among other items, terms which adequately protect BMR from <br />liability and require the contractor to have adequate insurance. AS you may know <br />such third party contracts are relatively common and BMR believes lltat such an <br />arrangement can be readily negotiated. BMR also believes that the contract <br />should include a detailed scope of work which establishes lire sampling frequency, <br />specifies sampling locations and identifies the constituents for analysis. BMR <br />believes that the development of the contract and detailed scope pf work must be <br />-13- <br /> <br />