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. ~. <br />°MRi ~Jr-a`t NOV & Order <br />page 2 <br />randomly choose the times and direct the third parties to complete yampling <br />and analysis, in order to verify the reliability of BMG's normal mo#itoring <br />program. <br />I believe this distinction to be an important one. I suggest that e clarify <br />this point before the Board votes on approvinc the Draft NOV and Or er. <br />I further suggest that we propose the following amendment to the Bo rd Order, <br />as drafted: <br />" BMRI's application for a technical revision submit ed <br />in res onse to item (12) of the Abatement Requirements, entitl~d <br />"Modification of Monitor Sampling & Analysis Protocol", shall: <br />a. comply with all applicable statutes and regulation; <br />b. comply with the requirements specified in item (12 ){ of <br />the Abatement Requirements; <br />c. comply with the accelerated monitoring frequency ot# <br />every two weeks, until relaxation is approved by the <br />Division, as specified in item (3> of the Abatement <br />Requirements; and <br />d. provide for the completion of appropriate independent <br />sampling and analysis to verify the reliability of BMRI' <br />environmental monitoring, at BMRI's expense, as approved and <br />directed by the Division. <br />With your concurrence, we will need to provide copies of our propos~d <br />clarification and wording amendment to the members of the Board, th <br />parties to the hearing, and to Frank Johnson. <br />cc: Bruce Humphries <br />Larry Oehler <br />JP/7P <br />Doc. No: 3012F <br />