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<br />RESPONSE TO COMMENTS BY JAMES STEVENS <br />1. BMRI's response indicates that the low level offlow, rather than lack of evidence <br />of cyanide, is Justcfication for maintaining the sampling frequency for the leak <br />detection system on a monthly basis rather than increasing it to bi-weekly. The <br />Division has not had any problem in securing adequate fluid faom the system <br />during the Division's 6!-weekly sampling trips, so the Division does not feel that <br />the flow is inadequate. If it is, then bi-weekly sampling and analysis can be <br />conditioned on the basis of dtere being insu,~cient sample availal!ile. Since the <br />leak detection system already shows evidence of cyanide, its monitoring on a more <br />frequent basis is desirable in order to be able to better correlate any variations <br />that it may show in cyanide content with those appearing at ocher bi-weekly <br />sampling sites. <br />RESPONSE: BMR believes that bi-weekly sampling of the collection pond leak detection <br />system is not necessary at this time because increased sampling frequency will not <br />provide additional information concerning site water quality. The primary reason <br />for sampling the collection pond leak detection system is to evaluate the pond's <br />structural integrity and not to establish process system or collection pond cyanide <br />concentrations. Bi-weekly sampling to determine cyanide concedtration occurs <br />at five process system points (pre-detox, post-detox, upper impoundment area, <br />lower impoundment area and the collection pond feeder ditch). An extensive <br />ground water monitoring system is in place to detect the presence of cyanide <br />outside of the collection pond's containment area. BMR believes that bi-weekly <br />sampling of these locations provides sufficient information regatding cyanide <br />concentrations in the process system and should allow BMR to tespond in an <br />appropriate manner to a release from the collection pond. Bi-weakly sampling <br />of the leak detection system will not provide additional data that addresses either <br />of these concerns. For this reason, BMR believes that bi-weekly sampling of the <br />leak detection system is unnecessary. BMR acknowledges that if significant <br />increased amounts of collection pond solution are identified in the leak detection <br />system, more frequent sampling may be necessary. <br />2. [No response required.) <br />3. [No response required.) <br />RESPONSE TO COMMENTS BY DAVID IIYATT (DRAFTED BY HARRSf POSEY) <br />1. jNo response required.) <br />2. [No response required.) <br />-s- <br />