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<br />17 Section 2.2.10. It is not essential, and it may eventually prove cumbersome, to lock <br />the sampling protocol into specific techniques and equipment such as that identified <br />in this section. The Division recommends that the equipment and techniques <br />conform to those required by the analytical lab and that the language of the sampling <br />protocol be open enough to allow for changes in recommended procedures or EPA <br />Standard methods. <br />18 Section 2.3.1. Field duplicates should also be prepared and analyzed by the same <br />lab. In addition, samples containing known quantities of analytes should be prepared <br />periodically to evaluate the lab's analytical performance. <br />20+ Section 3. Pages 20-25. Many of the protocols in this section repeat those described <br />in Section 2. Therefore, all comments regarding sampling, sample handling, and <br />sample analysis that were given previously for ground water monitoring should be <br />applied to this section, as appropriate. <br />28+ Section 4.2.6. Pond sampling. Given the composition of the tailings flluid that enters <br />the ponds and the likelihood that these fluids will stratify due to density variations, <br />given the likelihood of prefertial volatilization of CN" from the surface area of the <br />pond due to wind agitation, and given the likelihood of preferential cyanide <br />degradation by UV radiation in the upper surfaces of the ponds, it ig unrealistic to <br />expect the pond to have uniform cyanide concentrations throughout. Furthermore, <br />evaporation is also likely to create saline fluids that also would sink and stratify due <br />to density differences. <br />Part of the abatement plan requires that BMG submit a "pond characterization" study <br />that will identify and quantify these vertical (and, possibly, lateral) variations in <br />material concentrations. The Division has yet to receive the results of the pond <br />characterization study, so the Division cannot realistically agree to allow sampling as <br />described in this section. <br />Therefore, BMG should re-address this section after considering the results of the <br />pond characterization study. <br />