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<br />latter essentially a derivative of the total method, are EPA-approved methods (see <br />USEPA Method 9010 and 9012, from SW-846 and USEPA M[etliods 335.2 and <br />335.3 from Methods for the Analysis of Waters and Wastewaters). <br />S. Battle Mountain Cold (and the Division) should consider the time after which <br />third-party sampling will be eliminated or reduced to oversight-type frequencies. <br />RESPONSE: BMR believes that the third party sampling and analysis required by Paragraph <br />No. 21 of the CMLRB Order is for purposes of "verification mf pertinent data". <br />Upon approval of this technical revision and execution of the third party contract, <br />BMR believes that such verification monitoring should b~ conducted at a <br />frequency of once every 60 days for the balance of 1992. Thereafter, BMR <br />believes third party verification monitoring should be contracted on asemi-annual <br />basis. <br />6. The Division does nor understand the utility of not treasuring major cations for <br />water quality (Table 4J. At a n:inirnurn, BMG should explain tivhy major catiwu <br />are not to be analyzed. <br />RESPONSE: The major cations (calcium, magnesium, potassium and sodiugn) are monitored <br />on asemi-annual basis. These parameters were tiwnitored on a quarterly basis <br />throughout the pre-mining period; however, based on the data d@rived from those <br />samples, which showed no significant variations in concentrations for these <br />parameters, and since there are not MCLs for these parameters, they were <br />reduced to semi-annual sampling. <br />BMR believes that semi-annual sampling of these major cations is sufficient, with <br />more frequent sampling for metal ion analyses and cyanide analyses. <br />7. Appendix D is essentially indecipherable without a codeslieet to describe the <br />)readings. BMR s/:ould provide an explanatiot: of the ltepdittgs and any <br />abbreviated information in this appendix. <br />RESPONSE: Appendix D is a listing of quality assurance criteria for analytical acceptability <br />for given analytical methods, provided by Core Laboratories, Aprora, Colorado. <br />Each of the data table comprises, in order, the following: <br />1) Internal identification notation; <br />2) Title of method and detection limit; <br />-4- <br /> <br /> <br />