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<br />Comment by James Pend]eton <br />Third Party Verification Sampling & Analysis: <br />During the Mined Land Reclamation Board's consideration of the proposed NOV <br />abatement requirements on April 23, 1992, the Board imposed a requirement for <br />third party monitoring upon abatement requirement #12. On May 27, 1992, while <br />considering adoption of the final Board Order, the Board further clarified this <br />imposed condition. Paragraph 21.c. of the amended Board Order states that BMG <br />shall "provide for independent sampling and analysis, by a third party at BMG's <br />expense, at a frequency to be determined by the Mined Land Reclamation Division <br />to verify pertinent data". <br />During the discussion at the May 27, 1992 Board Meeting, the Board further clarified <br />its intention in regard to third party monitoring. The Board stated that the purpose <br />of the the third party monitoring shall be to verify the accuracy and reliability of <br />BMG's water quality monitoring results. It is not the intention of the Board to <br />replicate the environmental monitoring program required under the permit. Maxine <br />Stewart observed that the operator should offer to provide splits of all water quality <br />specimens to the parties, to be analyzed at the parties' expense. <br />The third party verification shall consist of sample collection and analysis, by third <br />parry professionals, at BMG's expense, at a frequency determined by the Division. <br />The Division believes it appropriate for BMG and the other parties to nominate <br />professonals to perform the sample collection and laboratory analysis tasks. The <br />Division intends to select appropriate professionals from these noaninees. The <br />Division will then direct the selected professionals to complete the third parry <br />verification sampling and analysis when the Division deems it approri2tte. The third <br />party sampling and analysis will be conducted in accordance with the final protocol <br />approved in compliance with abatement requirement #12. BMG vtill be offered <br />splits of all samples collected during third party sampling procedures. The Division <br />intends to order conduct of the third party verification on a random basis. <br />BMG should nominate professionals to perform the third party veri~'ication water <br />quality sampling and analysis, as a portion of its proposed sampling And analytical <br />protocol. BMG may include any additional specifications regarding the conduct of <br />these third party verifications which it deems appropriate for tIl~e Division's <br />consideration. <br />