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<br />RESPONSE TO COMMENTS BY JAMES STEVENS: <br />1. BMRI's response indicates that the low level of flow, rather <br />than lack of evidence of cyanide, is justification for <br />maintaining the sampling frequency for the leak detection <br />system on a monthly basis rather than increasing it to bi- <br />weekly. The Division has not had any problem in securing <br />adequate fluid from the system during the Division's bi-weekly <br />sampling trips, so the Division does not feel the flow is <br />inadequate. If it is, then bi-weekly sampling and analysis <br />can be conditioned on the basis of there being insufficient <br />sample available. Since the leak detection systrem already <br />shows evidence of cyanide, its monitoring on a more frequent <br />basis is desirable in order to be able to better coYrelate any <br />variations that it may show in cyanide content with those <br />appearing at other bi-weekly sampling sites. <br />2. Comment answered. <br />3. Comment answered. <br />RESPONSE TO COMMENTS BY DAVID HYATT [Drafted by Harry Posey]: <br />1. No comment. <br />2. Comment answered. <br />3. Comment answered. <br />r <br />4. Because the MLRD regulates over 2,000 mines, it is <br />unreasonable to assume that all reports will be studied in a <br />timely way. BMRI should further its commiitment to <br />self-monitoring by indicating in this protocol dodument that <br />they will make a deliberate and timely effort to draw <br />anomalous values to the attention of MLRD. <br />Comment answered. <br />6. There is nothing in Dr. Hyatt's comments to indicatE he has an <br />academic interest in having BMRI characterize the conditions <br />of the ponds fully. If the compositions of the progess fluids <br />and local ground water were known fully, BMRI would be able to <br />evaluate analyses taken under adverse conditions (e.g. partial <br />samples or samples collected when indicator conditions such as <br />pH and conductivity were unstable - see Posey comments #9 and <br />#10) by comparing them with historical data. <br />This item should be re-addressed. If BMRI needs assistance in <br />assessing the need for fluid characterization, the Division <br />will assist them, if requested. <br />Comment answered. <br />