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1 <br />' COMMENTS ON BMR REPORT ON QA/QC PROTOCOLS FOR THE COLLECTION <br />OF SURFACE AND GROUND WATER QUALITY DATA, SAN LUIS GOLU PROJECT, <br />COSTILLA COUNTY, COLORADO (Comments by David E. Hyatt of ADA Technologies, <br />' Inc.) <br />' 1. 77re document deals only with the sampling and wnalysis aspects of the project and <br />concentrates on the cyanide mtalyses. 77~ere is no discussion of the response to <br />conditions detecting )tigh cyanide levels in any sa»tples. <br />RESPONSE: The protocol document is designed to identify quality assurance/quality control <br />measures that will be taken in the collection, sampling and handling of samples, <br />' and is not designed to be a remediation plan document. <br />2. Were on-site, real time, continuo[+s monitoring teclmigr+es for cyanide analyses <br />' (such as ion-specific electrode) considered as an option to slaver remote <br />analyses? /f so, wlty rejected? If not, what was reason. for not befng considered? <br />' RESPONSE: See Response to Harry Posey's Cotntnettt No. I1. <br />3. In general, the third party check mtalyses s/tordd he most fi•et/uerlt a! the start of <br />' dtc program and then raper njf to less frequent and/or rnndom drecks if sample <br />analyses credibility and validity warrant. 77tere is no provision for this in the <br />report. <br />RESPONSE: See BMR's Response to Harry Posey's Comtnent No. 5. Tltis should be revised <br />according to any agreement BMR has with CMLRD. <br />' 4. Wlrat is the mechanism for review of all of the analytical dma (cotnpnny nnnlyses <br />' and third party results) by the Division and by the consltltants for the <br />Conservancy District? What will assure minimum delay in obta(ning dntn after <br />sa»rples are taken? <br />' RESPONSE: Water quality data will be submitted to the CMLRD within five working days <br />after receipt by the analytical laboratory, where it will be incorporated into the <br />' CMRLD files and will be available for public review. The CMLRD review <br />process is a matter of regulatory policy and should be discussed with CMLRD. <br />' S. If out-of--spec data are indicated by the analyses, then the snrrrpliltg and annlysis <br />plan should incorporate more erlensive sampling and analysis during the recovery <br />to penrtitted operations. <br />' RESPONSE: See Response to Dr. Hyatt's Comment No. 1 above. <br />' -16- <br /> <br /> <br />