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COMMENT BY JAMES PENDLETON <br />1. [ParrinlJ... The third party verification shall consist of smnple collection and <br />analysis, by third party professionals, at BMG's erperue, at a frequency <br />determined by the Division. 77re Division believes that it is appropriate for BMG <br />and the other parties ro naninate professionals to perform the sample collection <br />and laboratory analysis tasks. The Division intends tv select appropriate <br />professionals from these no»rinees. The Division will then direct tJre selected <br />professionals to complete tl~e third parry veriftcatior: sampling analysis when the <br />Division deerrrs it appropriate. T7re third parry san:plirtg and analysis will be <br />-~ conducted in accordance will: the Jinal protocol approved ir: compliance with <br />Abatenrerrt Requirement N12. BMG will be offered splits of all Sa»rples collected <br />during third parry sampling procedures. 7Tre Division: intends to order conduct <br />of !lre third party verification on a random basis. <br />BMG sJtould nominate professiorta/s to perform t/re third party ver•iftcatiort water <br />7 quality sampling and analysis, as a portion of its proposcti smnpling and <br />analytical protocol. BMG may include any additional specificntidns regarding the <br />conduct of these third party verifications rvlrid: it deems appropriate for the <br />Division's consideration. <br />RESPONSE: In its letter dated May 4, 1992, BMR nominated Water, Waste and Land, Inc., <br />7 a Fort Collins based consulting firm with considerable expgrience in water <br />sampling activities at similarly situated facilities involving cyanFde constituents, <br />to conduct the sampling phase of the third party monitoring program. A <br />statement of WWL's qualifications and experience is attached or your review. <br />BMR would nominate Core Laboratories, Inc. to conduct the analytical phase of <br />the program. Both of these companies have considerable expedience in dealing <br />with the issues presented by the third party monitoring program, are well lazown <br />and recognized as experts in their field and are located proximate to the Denver <br />area, which wold expedite contract administration. <br />As noted in its May 4 letter, BMR will insist that the third part monitoring be <br />conducted pursuant to a forma] contractual arrangement with 1~MR as a party <br />which includes among other items, terms which adequately prgtect BMR from <br />liability and require the contractor to have adequate insurance. Ag you may know <br />1 such third party contracts are relatively common and BMR believes that such an <br />_ arrangement can be readily negotiated. BMR also believes that the contract <br />should include a detailed scope of work which establishes the sampling frequency, <br />specifies sampling locations and identifies the constituents for analysis. BMR <br />1 -13- <br />1 <br />believes that the development of the contract and detailed scope mf work must be <br />J <br />