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<br /> <br /> <br /> <br /> <br />1 <br /> <br /> <br /> <br /> <br /> <br />1 <br />L~J <br />LJl <br /> <br /> <br /> <br /> <br /> <br />protocol, the primary sample should be discarded and not atralyzed. Ot/~etx~ise, <br />the less ideally collected primary smnple should 6e mmlyzed and tTre properties <br />of the collecting nrediu»r properly noted. <br />RESPONSE: While BMR agrees that the presence of fluid in a normally dry well could be of <br />significance, that is, no value in obtaining a sample for water quality analysis. <br />The sample would not meet any EPA-approved rnetlrods for collection of a <br />representative sample and, therefore, the results would not be considered valid. <br />It should be noted that in Section 2.2.7, there is a provision for sampling wells <br />with low recovery rates by bailing the well dry and then obtaining a sample from <br />water that Flows into the well. BMR believes that if this protocol cannot be met, <br />a sample should not be taken for analysis since the results will not be valid. <br />However, it will be noted that there appears to be a change in the water available <br />at this well, which may necessitate more frequent sampling ~t that point to <br />determine the source of this water. <br />10. Page 16, First frill paragraph. 7?uee consecutive and corrsistetV nreasurernenls <br />of tentperature, pH and corrductiriry falling within [he errot~ limits tf the <br />measurement medrod should be collected before the well is sampled. However, <br />in no case should faihtre of the pH, conductivity, or tentperature 4onsisrency tests <br />compromise dre ability to collect a sample adequate for chemical analysis. <br />RESPONSE: This comment appears to require the collection of samples wlri¢Ir might not be <br />representative, thereby questioning their validity. First, the comment states that <br />three consecutive and consistent measurements of temperature, pH and <br />conductivity should be obtained before the well is sampled to demonstrate <br />representativeness. However, the comment goes on say that if these consistency <br />tests are not demonstrated, a sample adequate for chemical analysis can still be <br />obtained. The reason that these tests are conducted is to detnonsGrate that a fresh <br />aquifer sample is being obtained and that the sample is representative. ]f these <br />values are not obtained, representativeness has not been demonstrated, and the <br />validity of the results becomes an issue. Therefore, BMR believes that it is <br />essential that the consistency of measurements be demonstrated before a sample <br />is obtained. <br />11. Page 17, Section 2.2.10. It is not essemia/, and it Wray eVemually prove <br />cranbersome, to lock the sampling protocol into specific techniques and equipment <br />such as that identified in this section. 77re Division reconrtnends tlral the <br />equipment and teclvriques catfonn to those required 6y the analytical lob and drat <br />the language of dre smnpling protocol be open enough to allow for changes in <br />reconunended procedures or EPA Standard medrods. <br />-10- <br /> <br />