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<br />Battle Mountain Gold (and the Division) should consider the utility and practicality <br />of analyzing for free cyanide. WAD cyanide analyses should include both the free <br />and weak acid dissociable components of cyanide, and thus a single analysis may be <br />more reasonable for both analytical and regulatory purposes. <br />5. Battle Mountain Gold (and the Division) should consider the time after which third- <br />party sampling will be either eliminated or reduced to oversight-type frequencies. <br />6. The Division does not understand the utility of not measuring major cations for water <br />quality (Table 4). At a minimum, BMG should explain why major cations are not <br />to be analyzed. <br />7. Appendix D is essentially indecipherable without a code sheet t4 describe the <br />headings. BMG should provide an explanation of the headings and ariy abbreviated <br />information in this appendix. <br />8. Please indicate the source of Appendix D, Appendix F, and Appendfe G. <br />9. In this protocol as in any, the operators should recognize that analytical labs need <br />to be checked periodically and to do so requires an established procedure. Battle <br />Mountain should have samples with known quantities of analytes and should submit <br />these periodically for analysis along with other analyses. In addition, the operator <br />should prepare samples for "Round Robin" analyses, intra-laboratory comparisons, <br />and routine sample duplication. Except for some provision for fielQl duplications, <br />there are few provisions for assuring that the commercial labs (the Vendors) will <br />supply consistently reliable analyses. Battle Mountain should provide for some <br />degree of quality assurance from their vendors, either through their own lab <br />personnel or through a third party who is familiar with these techniques. <br />10. Until the high cyanide levels in the ponds are brought down, all analyses for cyanide <br />(all compounds) from down-gradient wells and surface waters should ble sent through <br />on "Rush" status. Turn-around should not exceed 10 days. Inabili~}' to meet this <br />schedule should be described in writing by the independant lab or labs. <br />Other analyses may be sent routine. <br />11. Dr. David E. Hyatt's comments. <br />The comments and criticisms of Dr. Hyatt should be addressed along wiith those from <br />the Division (See attachment). <br />With respect, Dr. Hyatt's comment Number 2 regarding use of the ion specific <br />electrode technique should not be construed as an endorsement by the 'Division. The <br />ISE technique is not an EPA recognized method except, perhaps, as used in <br />conjunction with distillation. The Division has received cautionary information from <br />