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<br />' latter essentially a derivative of the total method, are EPA-approved methods (see <br />USEPA Method 9010 and 9012, from SW-846 and USEPA Methods 335.2 and <br />335.3 from Methods Cor the Analysis of Waters and Wastewaters). <br />S. Bnttle Mounmin Gold (and the Division) should consider rite lime after which <br />third-party sampling will be eliminated or reduced to oversight-type,firquencies. <br />RESPONSE: BMR believes that the third party sampling and analysis required by Paragraph <br />No. 21 of the CMLRB Order is for purposes of "verification of pertinent data". <br />Upon approval of this technical revision and execution of the thud party contract, <br />BMR believes that such verification monitoring should be conducted at a <br />frequency of once every 60 days for the balance of 1992. ">rhereafter, BMR <br />' believes third party verification monitoring should be contracted on asemi-annual <br />basis. <br />6. The Division does not understand the utility of not measuring rttajor cations for <br />water quality (Table 4). At a nrinimm~r, BMG should explain why major cations <br />' arc not to be analyzed. <br />RESPONSE: The major cations (calcium, magnesium, potassium and sodium) are monitored <br />' on asemi-annual basis. These parameters were monitored on h quarterly basis <br />throughout the pre-mining period; however, based on the data derived from those <br />samples, which showed no significant variations in concentrations for these <br />' parameters, and since there are not MCLs for these param@ters, they were <br />reduced to semi-annual sampling. <br />' BMR believes that semi-annual sampling of these major cations is sufficient, with <br />more frequent sampling for metal ion analyses and cyanide analyses. <br />' 7. Appendix D is essentially indecipherable without a codesheet to describe the <br />headings. BMR should provide mt explanation of dte hepdings and any <br />abbreviated inforntatiott in this appendix. <br />' RESPONSE: Appendix D is a listing of quality assurance criteria for analytical acceptability <br />for given analytical methods, provided by Core Laboratories, Aprora, Colorado. <br />' Each of rite data table comprises, in order, the following: <br />' 1) Internal identification notation; <br />2) Title of method and detection limit; <br />_' -4- <br /> <br /> <br />