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<br />wash solutions will be supplied by the third party samplers. <br />The Division further expects that access to monitoring wells <br />will be strictly controlled by BMG. <br />4. Comment partially answered. The Division has learned, partly <br />through this experience, that in order for cyanide analyses to <br />define accurately the actual concentrations of the cyanide <br />species reported, complementary analyses of interfering <br />components must also be reported and subtractec$ from the <br />cyanide measure. <br />Please indicate clearly what components will be analyzed, and <br />how the data will be reported. The Division encourages BMG to <br />report the data as simply as possible, to report b¢th the raw <br />values for metals and cyanide complexes, then report "free <br />cyanide-calculated" and "WAD cyanide-calculated," according to <br />the methods proposed by ASCI or other appropriate method. <br />5. The Division suggests that the permit, revisions to the permit <br />including this TR, and board imposed monitoring requirements <br />represent two levels of monitoring and sampling. 1: Routine <br />monitoring as required in the permit as modified lyy this TR. <br />2: Verification sampling to be conducted by a third party. <br />The Division understands that in order to p#otect the <br />integrity of wells and sampling stations, the cdmpany will <br />collect all samples required under routine monitoring. The <br />Division further understands that third party verification <br />sampling will be overseen by a third party, and tk)at samples <br />may be collected either by BMG or by the third part}, whatever <br />BMG proposes. <br />The Division proposes that third party verification sampling <br />be conducted no more than 6 times in the first qua#ter of the <br />year following approval of this TR, no more than 3 times in <br />the second quarter of that year, and no more than 3 times in <br />the second half of that year. BMG shall be notified 2 days <br />prior to the date of sampling. <br />6. The Division is not satisfied with the response. The reason <br />for monitoring major cations and anions is to detect changes <br />in water composition that may be related to mining. Measuring <br />one without the other is of very limited use, as ¢ne is more <br />or less matched with the other to check charge balance. If <br />there is a net negative (or positive) balance, tk~en, in all <br />likelihood, there is an analytical problem, and the labs need <br />to be told about it. <br />7. Comment answered. <br />8. Comment answered. <br />9. Comment answered. <br />