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<br />RESPONSE: The reference to a barrel filter apparatus can be deleted from this section; <br />however, the reference to a 0.45-micron filter is the determination between a total <br />analysis and a dissolved analysis. Therefore, BMR believes that this reference <br />needs to remain in this section. The procedures provided for in this section are <br />not based on what is required by the analytical lab; rather, they are procedures <br />that are required by the EPA. <br />12. Page 18, Section 2.3.1. Field duplicates should also be prepared and analyzed <br />1 by the same lab. In addition, samples containing known quantities of analyzes <br />should be prepared periodically to evaluate the lab's analytical perfonnnnce. <br />' RESPONSE: Field duplicates are currently analyzed by the same laboratory and, as part of the <br />lab's QA/QC protocols, spike analyses are done on a routine basis as part of the <br />lab's EPA protocols to maintain their EPA certification. <br />' 13. Page 20+, Section 3, Pages 20-25. Marry of t/re protocols in t/rLs section repeat <br />those described in Section 2. 77rerefore, all continents regarding sampling, <br />sample handling and sample analysis that were given previou.dy./br ground water <br />monitoring should be applied to this section, as appropriate. <br />RESPONSE: See Responses above to Section 2 Comments. <br />14. Page 28+, Section 4.2.6. Pond Sampling. Given the composition of the tailings <br />' fluid that enters the ponds and dre likelihood thot these fluids will stratify due to <br />density variatians, given die likelihood of preferential volntilizatiort of CN -front <br />the surface area of t/re pond due to wind agitation, acrd given the likclilrood of <br />preferential cyanide degradation by UV radiation in the upper surfaces of die <br />ponds, it is unrealistic to expect die pond to have uuifonn cyanidd concentrations <br />dtroughout. Funhennore, evaporation !s also likely to create spline fluids that <br />also would sink and stratify due to density differences. <br />Part of the abatement plan requires that BMG submit a "pond cllaracterizatiort" <br />study that will identify and quartz fy these vertical (and, possibly, lateral) <br />variations in material concentrations. 77re Division has yet to receive dre results <br />of dre pond characterization study, so the Division cmvrot realistically agree to <br />allow sampling as described in dris section. <br />1 <br /> <br /> <br />~' <br />Therefore, BMG should re-address this section after considering the resuhs of the <br />pond characterization study. <br />RESPONSE: The pond characterization study conducted by BEI was submittedi to the Division <br />on June 2, 1992. In the context of Technical Revision 007, BMf~ Itas committed <br />-11- <br />1 <br />