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<br />Agreement for Environmental Consulting Services between BMR and <br />RCG/Hagler, Bailly, Inc. ("Agreement") provides that RCG/Hagler, Bailly, Inc. <br />will provide sample containers, reagents and wash solutions. Access to the <br />monitoring wells is addressed in the third party verification sampling scope of <br />work. The procedures specified in the scope of work are intended to strictly limit <br />access to the monitoring wells. <br />4. [Comment Partially AnsweredJ. 77te Division has learned, portly through this <br />experience, that in order for cyanide analyses to define accurately the actual <br />concentrations of tl:e cyanide species reported, complememary analyses of <br />interfering components must also be reported and subtracted from the cyanide <br />measure. <br />Please indicate clearly what components will be analyzed, and hoW the data will <br />be reported. Tlie Division encourages BMRI to report the data as simply as <br />possible, to report the raw value for metals and cyanide complexes, then report <br />'free cyanide-calculated" and "WAD cyanide-calculated," according to the <br />metlrods proposed by ASCI or other appropriate method. <br />RESPONSE: BMR will analyze samples for the following parameters: <br />(1) total cyanide, by the manual cyanide distillation method (see <br />USEPA Method 9010); <br />(2) weak acid dissociable cyanide, by "Standard Methods of Analysis 1,-~, ~f <br />of Water and Wastewater", APHA/AWWA, 17th 1=,dition, 4500- ~Ir'~ <br />CN, Method I; and sk`~ ~ ~ ~ <br />k, ups ~~,5 <br />(3) copper, iron and zinc, by ICP method 200.7/601() (1,2) or similar. ~. <br />c ~ <br />BMR will report the data as analyzed by the laboratory, with the original ~^ ,•~~~S i <br />laboratory data sheets appended. BMR will also calculate the following: ~ ~ (~ <br />(1) the cyanide complexes due to the increase of copper and zinc in ` (~,~"~ <br />the samples, to give a calculated weak acid disso~iable cyanide ~~tf ~~S <br />value; and d <br />~jJ <br />(2) derive a maximum theoretical free cyanide value, based on the <br />methods described by ASCI (report dated June 192) using the i <br />calculated WAD cyanide value described above. <br />-2- <br />