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<br />Battle Mountain Gold <br />NOPV Abatement Requirements <br />page 6 <br />(12) <br /> <br />The description of each discrete abatement task element should include: <br />(a) Methodology and practices to be applied, <br />(b) Risk entailed, <br />(Is it proven technology, methodology perfection, researc etc?) <br />(Is it subject to seasonality, weather, equipment availability?) <br />(c) Criticality of the task element, <br />(Consequences of failure or delay for abatement progress) <br />(d) Decision points, <br />(e) Necessary relationship to other plan elements, <br />(Must it occur before or after other specific task elemenlts?) <br />(f) Alternative methodology or practices, <br />(To be substituted if failure or delay encountered) <br />(g) Required elapsed time, <br />(h) Name of the responsible staff member(s) or contractor(s), <br />Ci) Resources to be committed, <br />(BMG staff, consultants, equipment, lab>, <br />(j) Required agency response(s), and <br />(Review and approval, site visit, meeting, permit issuange, etc) <br />(k) Abatement plan deadlines. <br />Status: Satisfied - BMG has agreed to work with the Division >lo develop <br />a critical path management schedule follov~ing the <br />initial resolution of all abatement issues;, in a <br />letter of April 16, 1992. <br />Amendment of Monitor Sampling & Analysis Protocol: <br />During the implementation of the tailings cyanide detoxificatign project, <br />approved under item (4), question arose regarding the accuracy~of water <br />quality results generated by BMG in performing required sampling. The <br />Division requested that BMG verify the accuracy of their water quality <br />monitoring analysis. In response, BMG completed comparative analyses of <br />split samples using two independent EPA certified laboratories and their <br />own San Luis facilities. The results of these analyses demonsiJrated <br />significant discrepency between the three independent analyses. <br />BMG, in order to ensure accurate monitoring of water quality, shall <br />complete a comprehensive evaluation of the procedures used for sample <br />collection, preservation, transportation, analysis and reporting. At a <br />minimum, this evaluation shall include consideration of legal 'chain of <br />custody", prevention of contamination during sampling, preparaikion and <br />preservation of samples, appropriate transportation of samples to the <br />laboratory, "quality assurance/quality control" (QA/QC> methodology <br />within the laboratory, split sampling redundancy and verificat on of <br />monitoring accuracy. This evaluation, including a detailed sampling and <br />