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<br />RESPONSE: <br />Iv D~ j'\ <br />9 ~~ - <br />„- y t <br />j J~tiw ` ~~~~,. <br />y \C <br />~y1` ~ ~~ <br />~,p\ ,Y ~ <br />of concern throughout the plant. BMRI should be prepared to iddntify the source <br />of fluids found irs normally dry sampling stations using methods that require only <br />low volumes of fluid. If BMR/ needs assistance in devising such tests, the <br />Division will provide it if requested. There are many trace element or isotopic <br />or other techniques that may be employed. <br />BMR agrees that understanding the composition of fluids of concern at San Luis <br />is important. If a well which is ordinarily dry contains fluid at a scheduled <br />sampling event, BMR will immediately investigate the potential Source(s) of the <br />fluid and report its findings to the CMLRD. <br />BMR will also obtain a sample from the well for analysis to evaluate the source <br />of the water. However, as the Division recognizes, understanding the <br />composition of such fluids occurs within the context of analytical methods <br />performed in accordance with selected QA/QC protocols and the volume of <br />sample obtained can affect QA/QC protocols and the ability to conQuct a complete <br />{~ analysis. The analytical results for a sample which does not meett field QA/QC <br />~ d,r~~~n>~`' c`v ~ protocols will not be valid. Thus, BMR agrees that if water is tbund in a well <br />/~ • ~- ., ^, [~ ~ that is ordinarily dry, and insufficient sample is collected or insufficient purging <br />,vs o- ~ `'` ~ is conducted to meet all QA/QC protocols, the analytical results will be notated <br />~ .~ <br />, r_ that QA/QC protowls were not met and, therefore, the results are not valid. <br />~~^ BMR believes that the Division should recognize that while it is possible to <br />~~ .~(t~ r; `' K~,- analyze a small volume of fluid, the results of such an analysis may not meet all <br />~r ~ ~ t QA/QC protocols, thereby potentially rendering the results invalitl. <br />~,~, F -" ,~,n, <br />`d" f ,Yf •' f' .x~,./'''s {,,~"~ , In addition, the sampling and analysis of an ordinarily dry well may raise an issue <br />,~' t (- ~8 ~•~'"~ of representativeness associated with stagnant water and holding, time prior to <br />)c,~ ~ ~ analysis. Thus, BMR believes that even if an adequate sample amount is <br />c~"- ~~ obtained, such a sample may not meet QA/QC requirements ensuring sample <br />^~ ~- representativeness. <br />`~. <br />10. 71te Division does not accept the response. Fluids that fail to provide consistent <br />values on pH and conductivity meters do so for logical reasons, not the least of <br />which are faulty meters, operator error, or inliomogeneous infiltration rates into <br />the sampling site. Would you pump aloes-volume well dry wpiting for t17e <br />indicators to stabilize? /f your answer is yes, is that reasonably protective of <br />health and the environment? This section mtut be re-addressed. <br />RESPONSE: BMR believes that the collection and analysis of representative samples is <br />"reasonably protective of health and environment". To rely on non-tepresentative <br />samples invites error, which is not conducive to achieving the protectiveness <br />standard. An important QA/QC protocol for ensuring that a representative <br />-5- <br />