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<br />Letter to Ken Kluksdahl <br />Third Party Monitoring Report #2 <br />Harry H. Posey - July 6, 1993 <br />Page 2 <br />RCG/HBI made four recommendations in the subject report as follows: <br />1. "Back-up parts or a second pump should be kept on $ite." <br />The Division concurs with this assessment. <br />2. "Differences between dissolved and total metal concentrations <br />warrant collection of matched (either filtered o~ unfiltered, <br />preferably unfiltered) samples for total and WA~ cyanide and <br />metals: determine cyanide on both filtered and unfi tered samples <br />from the process points for the next third-party m nitoring." <br />The Division understands that this recommendation was instituted during <br />the third and fourth sampling events. <br />3. " ..Two strategies are recommended for improvinc) the cyanide <br />determinations in the process-point samples: (1) se~hd the samples <br />to another laboratory or have Core Labs use alter ative cyanide <br />methods; and/or (2) have Core Labs or another lab pe form a series <br />of experiments (described in Section 3.3) to dete ine the cause <br />of the analytical problems." <br />The analytical reports for WAD and Total cyanide indicat~ clearly that <br />the values given in the analytical reports do not accu ately reflect <br />the actual amount of cyanide shown in the samples. WAD yanide values <br />are routinely higher than Total, which is impossible, and spike <br />recoveries are poor and indicate that a less than ade to amount of <br />the cyanide was recovered by the lab. <br />The Division is not in a position to evaluate the prob~ems with the <br />analytical method or with the laboratory. Battle Mountain must show <br />either through tests recommended by RCG/HBI or by anoth~r appropriate <br />set of tests that values reported to the Division fo purposes of <br />proving compliance with permit standards are indeed ac urate within <br />acceptable limits. <br />4. "Because of the poor spike recovery rates for ~otal and WAD <br />cyanide, always use one of the unfiltered process oint samples, <br />preferably the collection pond, for the laboratory q ality control <br />spike analysis." <br />As noted above, it is evident that the amounts of cyanid reporting to <br />the analytical methods employed are less than occur in the samples. <br />Thus, for purposes of demonstrating compliance with pe it standards, <br />it is appropriate that the process point with the h~hest ambient <br />cyanide levels should be used for the laboratory QC spikeanalysis. In <br />