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Ms. Darcv O'Connor October 27, 1999 Page 4 • Filled sample containers were occasionally stored in the roadway that was variously dusty (pre-rain) and muddy (post-rain). Conditions during the sampling were characterized by variable gusting wind which generated substantial dust from the nearby county road. • The EPA inspection team processed the final two samples (one from a seep area and the field blank) concurrently, resulting in a period of time when two sets of urilabeled sample bottles were being handled by the EPA team. During that time:, sample labels were initially applied to the wrong bottles, which cast doubt on the integrity of the samples. Ms. Inman was emphatic about which samples were which, :utd directed the fmal labeling of the sample containers. Overall, these breaches in sampling protocol aze not consistent with the requirements of the approved sampling quality assurance/quality control protocol developed for the site, and could have invalidated the samples if taken by Respondents. Thus, these discrepancies c.eazly have the potential to adversely affect the subsequent analyses and, at a minimum, should have been noted in the EPA inspection report. Corrective Action Summary The inspection report requests the submittal of a summary of corrective actions.within 30 days of receipt of the report. As you know, Respondents have been actively intplemer.ting corrective actions at the San Luis Project to modify the hydrologic system in the vicinity of the West Pit in response to regulatory actions by the Colorado Division of Minerals and Geology (in the form of TR-26) and the Colorado Department of Public Health and Environment. On August 20, 1999, Respondents submitted to the Colorado Department of Put~lic Health and Environment (CDPHE) a CDPS permit application for the alleged discharges at issue. Subsequently, the CDPHE issued a Notice of Violation/Cease and Desist Ordet (NOV/CDO) to Respondents for alleged seepage associated with the flow of groundwater from the West Pit to ~ the adjacent alluvium at the San Luis Project, Costilla County, Colorado. Respondents provided i the CDPHE with a Response Plan on September 17, 1999 in reply to Item 2 of the CDO. The Response Plan (Attachment C) outlined the dtrect measures that have been, and will be, implemented to address the flow of groundwater from the West Pit to the adjacent alluvium. The measures described in the Response Plan also constitute a summary of the corrective actions that have been, and will be, taken by Respondents to address the flow of groundwater from the West Pit to the adjacent alluvium. Note that the Response Plan does not discuss the interim actions implemented by Respondents with regazd to interim water treatment. Specifically, Respondents initiated mobilization of a water treatment facility on August 24, 1999. As of September 3, 1999 Respondents have b~:en prepared to commission the interim water treatment facility for actual discharge. These actions have been authorized by and implemented in accordance with Amendment No. 1 (issued October 15, 1999) to the NOV/CDO issued on August 20, 1999. Active water treatment as authorized try Amendment No. 1 of the NOV/CDO began on October 18, 1999.