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~LO~~IE: ?^IC. TEL~305-~~a_-~r.=,- i•LSy 0 '__ F~.'~0 No.00~ P.03 <br />-, <br />9. Page 7: Procedural deviations should be noted directly noted on the <br />chain of custody form. <br />10. The preservation protocol for samples involves both acid (for metals) <br />- - - and base (for cyanide) and this is always a source of potential error since - - <br />acidification of samples for ryaNde analysis will invalidate their use. It <br />would be a useful error check to have the laboratories receiving the <br />samples for analysis run a pH check on them as a check•in adjunct to <br />assure no mix-up in preservation even before the analyses begin. Any <br />such errors would then be recorded immediately on the record sheets and <br />correct samples requested. <br />11. Page 8: Suggest that an additional copy of the chain of custody <br />paperwork also be attached to the outside of the cooler in a protective <br />envelope to guard against destruction of this document if the inside plastic <br />envelope leaks and admits ice water. <br />12. Is adequate delivery in place to get the samples from San Luis to the <br />lab sites as required? How will this transport be done? <br />13. Page 9: What "corrective measures" can be taken to bring s~mgle <br />'tivithin control limiu"? Will it impact the sample integrity (for ex le, if <br />the ryanide sample were inadvertently acidified and then treate with _ <br />caustic to give the "correct" pF3, the sample is no longer valid for cyanide <br />analyses even though "corrective measures" were taken to meet the tazget <br />pH in the sample)?. <br />14. Page 28: The tailing and collection pond samples may be the ones <br />where representative sampling is hardest to achieve and yet these ate the <br />most critical samples with respect to safety issues surrounding toxic; with <br />potential to leak into the surrounding environment. Maximum sample <br />frequenry and assurance of timely transmittal of these results to all <br />pertinent parties is critical to the intent of this plan. <br />15. Page 29: In taking samples for cyanide analyses, it is import t to <br />_--- . avoid aeration of the sample during collection and transfer in order to <br />- avoid volatilization losses of ryanide. This is not addressed spect6icsllly in <br />-- - the plan. <br />- 16. Page 34.: Who will see the reported analytical data and in what time <br />frame with respect to the time the samples were taken and analyses <br />performed? This is a central issue in the performance of BMR prior to <br />the NOV and should be fully resolved as a part of the sampling plan to <br />---.. - comply with Abasement Requirement 12. The transmission of data should <br />____ _ include the appropriate State authorities as well as Conservancy District <br />personnel and their consultants. <br />_ 17. TABLE 3: If there is any sign of leakage from the impoundrrlents, <br />then the frequency of sampling and analyses should increase immedlately <br />to monitor the conditions until recovery is demonstrated. <br /> <br />