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there are few provisions for assuring that the commercial labs (the Vendors) will supply consistently reliable analyses. Battle Mountain should prpvide for some degree of quality assurance from their vendors, either through their own lab personnel or through a third party who is familiar with these techniques. 10. Until the high cyanide levels in the ponds are brought down, all analyses for cyanide (all compounds) from down-gradient wells and surface waters should be sent through on "Rush" status. Turn-around should not exceed 10 days. Inability to meet this schedule should be described in writing by the independent lab or labs. Other analyses may be sent routine. 11. Dr. David E. Hyatt's comments. The comments and criticisms of Dr. Hyatt should be addressed along with those from the Division. With respect, Dr. Hyatt's comment Number 2 regarding use of the ion specific electrode technique should not be construed as an endorsement by the Division. The ISE technique is not an EPA recognized method except, perhaps, as used in conjunction with distillation. The Division has received cautionary information from both the Colorado Department of Health and from Accu-Labs regarding this technique. Use of the ISE for in-house monitoring may be useful, 64t the Division will not accept data from this technique without verification of the results using another EPA-accepted method. PAGE BY PAGE COMMENTS PAGE NO. COMMENT 1 Are there Monitor wells numbered M-3 or M-5? If so, where are they? 2 a. Exactly where is the sampling point mentioned in item (2) [top of page]? b. Where are the two off-site wells [item (3), top of page]? 3 Item (5) [top of page] does not agree with item (1) [bottom of page 2]. Furthermore, considering that the specific flow path of any leak from the tailings ponds to the Rito Seco is not known, other sampling points need to be established. Considering both these corrections and the need to establish more sampling points, It@m (5) should read: