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<br />RESPONSE TO COMMENTS BY HARRY POSEY: <br />1. Respondent has correctly identified my mistake; to wit: RS-5 <br />is the station that should have been cited in this section. <br />BMRI and its consultants have surmised, without supporting <br />data, that the ground water gradient directly beneath the <br />tailings impoundments is westerly, on trend with the surface <br />topography. Though reasonable, this is not proven. The <br />Division is concerned about the fate of any release from the <br />tailings ponds. whether a release would flow into the Rito <br />Seco, the Culeubra, or to ground water unrelated to these <br />drainages is not known. <br />BMRI needs to identify the likely fate of a potential release <br />from the tailings ponds and establish routine sampling in that <br />area. <br />2. The Division expects that once the hydrologic gradient in the <br />vicinity of the tailing ponds is established, an alppropriate <br />number and appropriate types of sampling stations will be <br />established. <br />3. The Division expects that sample containers, reagents, and <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 BMRI. <br />4. Comment partially answered. The Division has learned, partly <br />through this experience, that in order for cyanide analyseq, <br />to define accurately the actual concentrations of 4he cyanide" <br />species reported, complementary analyses of interfering <br />components must also be reported and subtracted. 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 BMRI <br />to report the data as simply as possible, to report both the <br />raw value for metals and cyanide complexes, then re~iort "free <br />cyanide-calculated" and "WAD cyanide-calculated," aaCOrding to <br />the methods proposed by ASCI or other appropriate method. <br />5. The Division suggests that the permit, revision 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 by the TR. <br />2: Verification sampling to be conducted by a third party. <br />The Division understands that in order to protect the <br />integrity of wells and sampling stations, the company will <br />collect all samples required under routine monitoring. The <br />Division further understands that third party verification <br />