ENFORCE23394

• Permit No: M1988112
• IBM Index Class Name: Enforcement
• Doc Date: 12/31/1993
• Doc Name: REVIEW OF DRAFT SUMMARY REPORT FOR OCT 1993 THIRD PARTY MONITORING TRIP
• From: DMG
• To: RCG HAGLER BAILLY INC
• Media Type: D
• Archive: No

iii iiiiiiiiiiiiiiii •
STATE OF
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DIVISION OF MINERALS AND GEOLOGY
Depanment of Natural Resources
1313 Sherman 81., Room 215
Denver, CO 80203
Phone: [phone]
FAX:[phone]
December 31, 1993
Ann Maest, Ph.D
RCG/Hagler Bailly, Inc.
P.O. Drawer O
Boulder, CO 80306-1906
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Ray Romer
Governor
Michael B. Long
D rvision Director
RE: Review of Draft Summary Report for October 1993 ,Third-Party
Monitoring Trip
Dear Dr. Maest:
The Division received the above-cited report on December 2~. Prior to
releasing this report please consider addressing the f llowing few
discrepancies.
1. Acceptance criteria for duplicate analyses were not m t for total
cyanide analyses of samples from the upper and to er tailing
impoundments and re-analysis of these samples took pla a after the
EPA-recommended holding time.
If this situation has led to invalid results, it shou d be stated
so more directly in the conclusions, and recommendati n should be
made that new samples be collected and new analyses performed.
BMRI should not have to bear the cost of the new anal ses, except
as set forth in their contract with Core Labs. In the event these
points need to be re-sampled, RCG/HBI should discu s with the
Division and BMRI whether RCG/HBI will conduct the s pling.
2. Total cyanide analysis of Sample "Well M-9" was conduced two days
after the holding time.
If these results are invalid, the conclusions should state so
directly. If a new sample must be collected and ana yzed, that
too should be stated in the conclusions.
3. Table 3 should include a footnote under well M-9 si~ating that
analysis of total cyanide exceeding the holding time b}~ 2 days, in
keeping with the notes compiled for other out-of-spec'ianalyses.