2023-07-12_PERMIT FILE - M2022048 (2)

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ENVIRONMENT, INC. PAGE 4 L.G. EVERIST, INC.-WEST FARM RESERVOIR ADEQUACY RESPONSE 02 JULY 10,2023 Report to be submitted as a TR when the data is collected and reviewed. If LGE wishes to reduce the list of analytes to an abbreviated set of"indicator parameters"upon review of the baseline data, this request can be made and justified in the Baseline Water Quality Summary Report submittal. 22g) Groundwater Sampling Plan (GSP) Section 4.3.4- Delete last sentence in second paragraph (Portions of the list will....)Also edit last sentence in this section with reference to section 4.2.1 (which does not exist in this plan) to 4.3.1 which discusses decontamination. 22h) Groundwater Sampling Plan (GSP) Section 4.4— Generally dissolved metals samples are preserved with HNO3 to pH<2 after filtering. It may be more useful to state something to the effect of-LGE will consult with the lab providing the containers and analysis prior to sampling events to determine the required containers and preservation for samples to be collected. LGE will preserve all samples in accordance with lab and method requirements. Preservation methods will be documented on held forms for all samples, as well as on the COC. 22i) Groundwater Sampling Plan (GSP) Section 4.6— Trip blanks may be omitted(see following comment on Appendix II), and Equipment(rinsate blanks are only required when non-dedicated sampling equipment is utilized. DRMS recommends that QA/QC samples focus on a Duplicate Sample to verify lab results unless there is reason to believe additional QA/QC is needed. 22j) Groundwater Sampling Plan (GSP) Section 5.0—Analytical Reporting Limits must be low enough to determine if standards for applicable analytes in Tables 1-4 of the Interim Narrative Standards have been exceeded. (See comment on Appendix 11) 22k) LGE will need to commit to retaining all completed field forms for submittal with the annual report, or upon request for DRMS review. LGE will commit to retaining all completed field forms for submittal with the annual report, or upon request for ORMS review. 221) Groundwater Sampling Plan (GSP)Appendix 11—Water Quality Parameter List— This appendix is titled Appendix Il on the divider sheet, and possibly as Appendix B in the TOC of this document. However, the materials in it are titled Appendix I- Tables Water Quality Parameter Lists. Please revise for consistency throughout. 22m) Groundwater Sampling Plan (GSP)Appendix 11—Water Quality Parameter List— Organic Parameters/Table 2—Although DRMS will review any organic parameters LGE wishes to sample to establish baseline data, collection of samples/data for organic parameters listed in Table 2, (or in Table A of Reg. 41) is generally not required by DRMS unless there is a specific reason to believe they may be present within the permit area in elevated levels. 22n) Groundwater Sampling Plan (GSP) Appendix II—Water Quality Parameter List—Tables 3 and 4— The analyte lists provided in these tables are inconsistent with the parameters contained in Tables 1-4 of Reg. 41 Interim Narrative Standards, and no benchmark levels have been provided. Several analytes included in Tables 1-4 were omitted. Please revise Tables 3 and 4 to include all analytes in Reg. 41 tables 1-4, and include the