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<br /> <br />S. The Division suggests that the permit, revision to the permit including this TR, <br />and Board imposed monitoring requiremems represent nvo levels of monitoring <br />and sampling. 1: Routine monitoring as required in the pernzit as modified by <br />the TR. 2: Veriftcation sampling to 6e conducted by a third parry. <br />The Division understands that in order to protect the integrity of tivells and <br />sampling stations, the company will collect all samples required under routine <br />monitoring. The Division further understands that third parry verification <br />sampling will be overseen by a third parry, and that samples nray be collected <br />either by BMRI or by the third party, whatever BMRI proposed. <br />The Division proposed that third party verbcation sampling be conducted no <br />more than 6 times in the f+rst quaver of the year following approval of this TR, <br />no more than 3 times in the second quarter of that year, and no more than .3 <br />times in the second half of that year. BMRI steal! be notified 2 days prior to the <br />date o[satnpling. <br />RESPONSE: BMR has responded to this comment in a separate letter addressing third party <br />sampling, dated August 5, 1992. <br />6. The Division is not satisfied with the response. 77zc reason for rnotzitoring major <br />catior+s and unions is to detect changes in water composition that rtzay be related <br />to mining. Measuring one without the other is a of very limited use, as one is <br />more or less matched with the other to check the charge balance. If there is a <br />net negative (or positive) balance, then, in all likelihood, there is an analytical <br />problem, and the labs need to be told about it. <br />RESPONSE: The major cations and anions are being analyzed in the bi-weekly sampling and <br />also on asemi-annual basis from all of the surface water and ground water sites. <br />It was only during the quarterly sampling periods that the major cations were not <br />analyzed. BMR agrees that dte major cations and anions will continue to be <br />monitored on a bi-weekly and semi-annual basis and will add the anajor cations <br />to the quarterly water quality parameter list for analysis. <br />7. [No response required.] <br />8. [No response required.] <br />9. (No response required.) <br />10. [No response required.) <br />-3- <br />