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<br />sample is obtained from a well is that the field parameters have stabilized prior <br />to sampling, indicating that a fresh aquifer sample can be obtained. While non- <br />stabilization may be a result of a faulty meter, or erroneous readiggs, it may also <br />be due to the presence of perched water that is not part of a flow system or due <br />to the presence of stagnant water in the borehole. If, for whatever reason, field <br />water quality parameters have not stabilized at a sampling site, thhis information <br />'-~ ~ F ~ will be noted on the chain-0f-custody form and the sample taken according to the <br />,~ ~ sampling QAlQC protocols. However, the Division should understand that <br />samples taken in such a manner deviate from the QA/QC protocols and will be <br />non-representative under the QA/QC protocols and, therefore, will not provide <br />valid results. <br />11. [No response required.) <br />12. The Division does not accept the response. In a recent example, cYted in BMR1's <br />responses to comments in this section, BMRI sent identical samples to two <br />independem EPA labs. The labs reported dramatically different results, both <br />using standard methods. In a case like this, which value would you accept; would <br />you accept either? 7Tre Division itrsists tlurt responsibility for QA and QC reside <br />J both with the lab and with BMRI. Unless BMRI ltas some way to periodically <br />~!" monitor the quality of lab results, they must trust the lab explicitly. 77tis is not <br />~~p` good sampling procedure and will not be accepted a[sicJ part of this proposal. <br />' U 1 This section must be re-addressed. <br />S~~ ~„ <br />. ,J" _,y'PONSE: BMR is willing to prepare spike samples (with a docum@nted cyanide <br />V' r,~' ~ concentration known to BMR and not to the laboratory) and subirtit them to the <br />~~~'^ ~/'~/ analytical laboratory for periodic checks on lab QA/QC. BMR proposes Uiat no <br />~ more than four spike samples will be submitted in the first year. Based on the <br />~. ~ ~y~ lab's performance, the frequency of additional spike samples will be evaluated at <br />that time. <br />~ 13. The response does not make sense. This section must be re-addressed. <br />RESPONSE: In the original Adequacy Response to Comment No. 13., BMR stated that the <br />Division's comments regarding sampling, sample handling and salmple analysis <br />would be applied to both the ground water monitoring section add the surface <br />water monitoring section. <br />14. [No response required. j <br />-6- <br />