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<br />James Stevens, Bruce Humphries -2- November 9, 1995 <br />................................................................................................................................................................................................................................................ <br />5. Frequency of Sampling -BMRI proposes quarterly sampling. <br />6. Frequency of Monitoring -BMRI proposes monitoring the piezometers on a <br />monthly basis. <br />7. Commitment to Develop a Response Plan -BMRI committed to a cause - <br />specific plan. <br />Components of the proposal that still need to be addressed to satisfy the requirements of <br />Stipulation No. 7 are listed below: <br />1. Water Quality Monitoring -BMRI proposes to evaluate water quality based <br />on a statistical analysis. The proposed indicator parameters are pH, <br />specific conductance, iron, manganese, and sulphate. Currently, the <br />Division plans to establish the Rito Seco and Santa Fe monitoring wells as <br />points of compliance and set permit conditions as part of TR-015 so these <br />components will be addressed in TR-015. <br />2. Water Quality Monitoring -BMRI proposes to continue monitoring for a <br />minimum of 2 years after the hydraulic gradient has been re-established in <br />the West Pit. This time frame is based on projected seepage velocities of <br />695 ft/yr to 2045 ft/yr. The proposal does not say whether the seepage <br />velocities are in the Rito Seco, Santa Fe, or Precambrian gneiss. The <br />Division will need more information. <br />3. Reporting -BMRI proposes to submit annual reports for the c}uarterly <br />monitoring. This is unacceptable. BMRI must submit copies of all reports <br />to the Division as soon as they are received (monthly reports for monthly <br />monitoring and quarterly reports for quarterly monitoring). <br />Other requirements of Stipulation No. 7 (conditions that will trigger a remediation action <br />or a possible violation) will be covered under TR-015. <br />If you have any comments or suggestions let me know soon so I can notify BMRI of the <br />Division's concerns regarding the proposal. <br />M:\OSS~amm~nemo.ld <br />