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ENFORCE37226
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ENFORCE37226
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Last modified
8/24/2016 7:46:17 PM
Creation date
11/21/2007 3:27:47 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Enforcement
Doc Date
8/6/1992
Doc Name
BMR PN M-88-112 INDEPENDENT SAMPLING AND ANALYSIS
From
BATTLE MTN GOLD CO
To
MLRD
Media Type
D
Archive
No
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Page 3 • • <br />Dr. James A. Pendleton <br />August 5, 1992 <br />selected contractor, BMR and the MLRD to ensure ,that the <br />contract meets the needs of all contracting entities, <br />Miscellaneous Comments <br />1. BMR concurs generally with the concept set forth in <br />comment 1. <br />2. BMR concurs generally with the protocol contemplated <br />in comment 2 and believes that the thi~d party <br />sampler should be required to document c mpliance <br />with the approved protocol. <br />3. The procedures contemplated in commen~ 3 are <br />acceptable; however, BMR intends to res rve its <br />right to review and approve invoices rior to <br />payment and to challenge invoices which pit finds <br />inaccurate or otherwise not in compliance 'with the <br />terms of the contract. <br />4. BMR concurs with the proposed procedures. <br />5. BMR concurs with the statements in comment 5. <br />6. Depending upon the sampling locations identified for <br />third party review, the frequency of third party <br />sampling proposed in comment 6 would a~most be <br />totally redundant with the approved mc)nitoring <br />frequency for the facility. If the purpose of the <br />sampling is verification of the sample resglts, the <br />proposed frequency is excessive. BMR beli ves that <br />the sampling frequency suggested in its June 12 <br />response to MLRD comment 5 (i.e., once ever 60 days <br />during the first 6 months and twice a year ollowing <br />that period) is more than adequate. BMR does not <br />clearly understand the basis for the MLRD's <br />suggestion and would suggest that we meet to discuss <br />this issue in more detail. <br />BMR remains committed to achieving a full and final relsolution <br />to the third party sampling issue as soon as plossible. <br />Following our submission of the draft contract, we wq'uld <br />
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