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casing contaminants in the well. In these cases, the protocol should provide for collecting a sample prior to evaluating the productiveness of the well. The Division recommends that for ordinarily dry or low productivity collecting points, if any fluid is available, a reasonable amount of that fluid should first be taken, then the well should be purged according to the provisions in this section. If adequate sample is collected under the more ideal, three volume purging protocol, the primary sample should be discarded and not analyzed. Otherwise, the less ideally collected primary sample should be analyzed and the properties of the collecting medium properly noted. 16 First full paragraph. Three consecutive and consistent measurements tpf temperature, pH and conductivity falling within the error limits of the measurement method should be collected before the well is sampled. However, in no case should failure of the pH, conductivity, or temperature consistency tests compromise the ability to collect a sample adequate for chemical analysis. 17 Section 2.2.10. It is not essential, and it may eventually prove cumbersome, to lock the sampling protocol into specific techniques and equipment such as that identified in this section. The Division reconunends that the equipment amd techniques conform to those required by the analytical lab and that the language df the sampling protocol be open enough to allow for changes in recommended procedures or EPA Standard methods. 18 Section 2.3.1. Field duplicates should also be prepared and analyzed by the same lab. In addition, samples containing known quantities of analytes should be prepared periodically to evaluate the lab's analytical performance. 20+ Section 3. Pages 20-25. Many of the protocols in this section repeat []pose described in Section 2. Therefore, all comments regarding sampling, sample handling, and sample analysis that were given previously for ground water monitoting should be applied to this section, as appropriate. 28+ Section 4.2.6. Pond sampling. Given the composition of the tailings fluid that enters the ponds and the likelihood that these fluids will stratify due to density variations, given the likelihood of prefertial volatalization of CN- from the surface area of the pond due to wind agitation, and given the likelihood of prefer@ntial cyanide degradation by UV radiation in the upper surfaces of the ponds, it is. unrealistic to expect the pond to have uniform cyanide concentrations throughout. Furthermore, evaporation is also likely to create saline fluids that also would sink and stratify due to density differences. Part of the abatement plan requires that BMG submit a "pond charactelization" study that will identify and quantify these vertical (and, possibly, lateral) variations in material concentrations. The Division has yet to receive the results of the pond