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...uv ice. .. _ __ _. <br />• <br />• <br />COMMENTS ON B~IR REPORT ON QA/QC PROTOCOLS <br />I'OR THE COLLECTION OF SURFACE AND GROUND WATER <br />QUALITY DATA SA~~I LUIS GOLD PROJECT, COSTILLA COUNTY, COLORADO . <br />]. The document deals only with the sampling and analysis aspects of the <br />project and concentrates on ryanide analyses. There is no discussion of <br />the response to conditions detectrng high cyanide levels in any sampl@s. <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? If not, what was reason fdr not <br />being considered? <br />3. In general, the third parry check analyses should be most frequent at <br />the start of the program and then taper off to less frequent and/or ratrdom <br />checks if sample analyses credibility and va]idity 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 results) by the Division and t#y the <br />consultants for the Conservanry District? What will assure minimum <br />---~ delay in obtaining data after samples are taken? <br />5. If out-of--spec data are indicated by the analyses, then the sampling and <br />_ analysis plan should incorporate more extensive sampling and analysis <br />during the recovery to permitted operations. - - -- <br />6. Page 2; In the initial samples from the process (pre-dctox, post clc-tox, <br />and both impoundment areas as well as collection pond), it wot{ld be <br />valuable to have a complete suite of analyses (TABLE l) to eharac~terize <br />the conditions fully as of the start of recovery to 4 ppm ryanide levels. <br />Following that, the sampling on a weekly rather than biweekly basis would <br />- -- -- - - give a better picture of incremental recovery progress. At the qnd 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 on going <br />activity under new operating conditions went forth (if this is ~nally <br />permitted). <br />7. Taking REPRESENTATIVE samples from the impoundmcntls may <br />prove challenging and there is little discussion of this issue in the tteport. <br />1f stratification or shoe circuiting 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? WiII there be adequate trainitg and <br />supervision to assure reliabie adherence to a protocol for sample recovery, <br />preservation, labeling, and transport that is anything but trivial? W11at are <br />the periodic checks on training to assure a high ]eve! of sample integ~riry? <br />-- 1 <br />_ ~~ <br />