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• <br />COMMENTS ON BMR REPORT ON QA/QC PROTOCOLS <br />FOR THE COLLECTION OF SURFACE AND GROUND WATER <br />QUALITY DATA SAN LUIS GOLD PROJECT, COSTILLA COUNTY, COLORADO . <br />1. The document deals only with the sampling and analysis aspects of the <br />project and concentrates on caanide analyses. There is no discussion of <br />the response to conditions detecting high cyanide Ievels in any samples. <br />2. Were on-site, real time, continuous monitoring techniques for cyanide <br />analyses (such as ion specific electrode) considered as an option to slower <br />remote analyses? If so, why rejected? 1f not, what was reason for not <br />being considered? <br />3.. In general, the third party check analyses should be most frequent at <br />the start of the program and then taper off to less frequent and/or ralndom <br />checks if sample analyses credibility and validity warrant. There is no <br />provision for this in the report. <br />4. What is the mechanism for review of all of the analytical data <br />(company analyses and third party resulu) by the Division and >*y the <br />consultants for the Conservancy District? What will assure minimum <br />delay in obtaining data after samples are taken? <br />S. If out-of-spec data are indicated by the analyses. <br />analysis plan should incorporate more extensive <br />during the recovery to permitted operations. <br />then the sampHrlg and <br />sampling and apalysis <br />b. Page 2: In the initial samples from the process (pre-detox, post de-tox, <br />and both impoundment azeas as well as collection pond), it would be <br />valuable to have a complete suite of analyses {TABLE ]) to charagterize <br />the conditions fully as of the start of recovery to 4 ppm caanide jevels. <br />Following that, the sampling on a weekly rather than biweekly basis would <br />give a better picture of incremental rewvery progress. Ai the emd of <br />recovery, the analysis as per TABLE 1 would then give comparative data <br />relative to where the ponds and process waters should remain as outtgoing <br />activity under new operating conditions went forth (if this is 5nally <br />permitted). <br />7. Taking REPRESENTATIVE samples from the impoundments may <br />prove challenging and there is Little discussion of this issue in the rt:port. <br />1f stratification or short arcuiting occurs in the ponds, then a larger <br />number of replicate samples and analyses may be necessary. <br />8. Page 5: Who takes the samples? Will there be adequate training and <br />supervision to assure reliable adherence to a protocol for sample recovery, <br />preservation, labeling, and transport that is anything but trivial? Whiat are <br />the periodic checks on training to assure a high level of sample integtity? <br />