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accelerated to bi-weekly, commencing immedia ely and continuing until relaxation is approved by the ~ivision. The initial samples shall be submitted to an EPA certified laboratory for "rush" analysis. Subsequent samples may be processed normally. The results of each set of sample analyses, cov red with an appropriate brief summary letter report, hall be submitted to the Division within three days ollowing completion of the analyses by the laboratory. Discussion• Well M-9 was located downgradient of the tailings impound- ment specifically to detect potential leakage t ground- water beneath the impoundment. Lysimeters w re also installed downgradient of the impoundment area. Increased environmental monitoring conducted to date has shown no environmental impacts or changes as a esult of the recent tailings deposition. The results were ubmitted to the Division on April 10, 1992 in response to tem 2 of the Division's April 5, 1992 Abatement Requireme ts. This submittal discussed the total cyanide concentrati n at the detection limit in lysimeter L3W-4392. This re ding is believed to be invalid due to the sample size and analyti- cal interference. A complete discussion is contpined in the April 10, 1992 submittal. BMG proposes to continue reading the environmen 1 moni- toring facilities on a monthly basis unless a si ificant change in water quality is observed. Should a si ificant change in water quality be observed at any po nt, the Division will be notified and more frequent mo itoring implemented. The increased monitoring frequency will be based on the location and parameter(s) with demo strated change, but will be no less frequent than once a ery two weeks. BMG further believes that testing monthly for the full suite of parameters is excessive and unnecessary. instead, BMG proposes to test monthly for key indicator parameters which consistently exhibit the highest levels in the tailings water and would allow for early detecti~n of any changes in water quality. The primary key i dicator parameter to be monitored would be copper. Copper eadings for the tailings water are high and copper can be more easily analyzed than cyanide. Copper will provide early detection of leakage from the tailings and will be more easily and more reliably detected at leve ~ above background than the low levels of cyanide nd will continue to monitor monthly for total cyanide nd will ~ ~, ~ s ~'