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<br /> <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 readings, 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 wha[evor reason, field <br />water quality parameters have not stabilized at a sampling site, tlbis information <br />will be noted on the chain-of-custody form and the sample taken according to the <br />sampling QA/QC 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 />Il. [No response required.) <br />12. The Division does not accept the response. In a recent example, cued in BMRI's <br />responses to comments in this section, BMRI sent identical s4ntples ro nvn <br />independent EPA labs. The labs reported dramatically different results, bout <br />using standard methods. In a case like this, which value would you accept; would <br />you accept either? The Division insists that responsibility for QA pnd QC reside <br />both with the lab and with BMRI. Unless BMR/ has some way Ao periodically <br />monitor the quality of tab results, they must trust the lab explicitly. This is nor <br />good sampling procedure and will not be accepted a[sicJ part of this proposal. <br />77:is section mttst be re-addressed. <br />RESPONSE: BMR is willing to prepare spike samples (with a documented cyanide <br />concentration known to BMR and not to the laboratory) and submit them to the <br />analytical laboratory for periodic checks on lab QA/QC. BMR proposes that no <br />more than four spike samples will be submitted in the first year. Based on the <br />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 rrntst 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 sample analysis <br />would be applied to both the ground water monitoring section and the surface <br />water monitoring section. <br />14. [No response required.) <br />-6- <br />