REV91630 - Laserfiche WebLink

Home Browse Search

Page 2 • • Dr. James A. Pendleton July 31, 1992 be utilized as the method for determining compliance with the permit standards. Such a monthly average would be calculated on the basis of a minimum of four samples taken five to nine days apart. BMR would be allowed to perform analyses as often as one per day at BmR's discretion. All analyses would be performed in accordance with the approved sampling and analysis protocol and would be submitted to MLRD in the form of a monthly report no later than the last day of the following month. BMR may supplement the data base included in the monthly report in the event that laboratory turnaround times do not allow inclusion of all applicable data within the subsequent month. Paraaraoh 3 BMR concurs with the statements in paragraph 3. Paraaraoh 4 BMR concurs with the statements in paragraph 4 and reserves its option to propose alternate and/or reduced sampling methodology in the future. Paraaranhs 5 and 6 As noted in its response to paragraph 2, BMR believes that the permit standards should be applied as monthly averages in the tailings impoundment for the purposes of permit compliance. The purpose of monitoring the tailings exiting the Inco treatment facility is to provide for the operational feedback necessary to moderate and control the treatment process. Because of the inherent variability and potential for upset conditions, the tailings exiting the treatment facility is not an appropriate location for compliance testing. However, BMR recognizes the potential value to MLRD, particularly during the initial operation of the Inco treatment process, of utilizing the proposed 30 day rolling average procedures for the purposes of reviewing the operation of the treatment process and establishing intermediate response action requirements in the event such rolling average indicates the potential for excursions from the permit standards measured in the tailings ponds. Under such an approach, the permit standards would be enforced at the tailings ponds, as described in the response to paragraph 2 above. The permit standards would not be enforced on the basis of the rolling 30 day average of cyanide concentra- tions of tailings exiting the treatment plant. Rather, poten- tial excursions indicated by the rolling average determination would trigger the intermediate response action required in the conditions set forth below. BMR's permit obligation in this regard would be to conduct the required intermediate response action.