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<br />RESPONSE TO COMMENT BY JAMES PENDLETON <br />I. [PanialJ...If BMRI intends to employ Core Laboratories to provide analytical <br />services for its required environmental monitoring program, the Division believes <br />it would be inappropriate to use Core Laboratories for the itdependent third parry <br />verification analysis. BMRI should clarify its intentions if it desires <br />reconsideration of Core Laboratories as a third parry analytical contract. <br />The Division concurs with BMRI's statements relating to the ccvnplerion of an <br />appropriate contractual arrangement with the selected third party sampling arui <br />analytical contractors. The Division would appreciate any assistdnce BMRI can. <br />provide in this matter... However, the Division intends to impose dre completion <br />of the third party contract as a stipulation upon the approval. <br />...At dre end of the first year jof the third parry sampling) tyre Division intends to <br />reassess the required frequency of independent sampling and analysis. <br />The Division concurs with BMRI's concerns regarding insurance verification by <br />the third parry contractors. In order to control cost, the Division proposes that <br />BMR! conduct its required monitoring in unison with independent verification <br />rounds. BMRI's normal sampling professionals may conduct all sahrple collection <br />under the scrutiny of the d7ird parry. The third party would conrpl4te an approval <br />document and chain-of-custody documentation for a. split smnple received from <br />BMRI's professional. This procedure should eliminate BMRI's concern for <br />compromise or damage to any of BMR/'s monitoring facilities. <br />The division intends to solicit professional fee schedules from each of the <br />nominated professionals for the purposes of completing the contract for third <br />parry services. <br />RESPONSE: The Division has selected Core Laboratories to perform the independent third <br />party verification analysis. All samples obtained in the third party sampling <br />program will be coded by RCG/Hagler, Bailly, Inc. and delivered to Core in a <br />manner to ensure that the source of the samples is not known to Core. BMR <br />believes that this approach addresses the Division's concern that the use of Core <br />as a third party lab is inappropriate by eliminating any potential fbr bias. BMR <br />intends to continue to utilize Core for its ongoing analytical testing needs. <br />-7- <br />