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<br />10. Comment answered. <br />PAGE-BY-PAGE COMMENTS <br />1. Comment answered. <br />2. Comment answered. <br />3. Comment answered. <br /> <br />4. The Division expects that RS-5 and RS-6, M-2, M-6, M-7, M-8, <br />and M-9 will be monitored bi-weekly. <br />5. Comment answered. <br />6. It appears that BMG did not understand the intent of this <br />comment, perhaps because of my imprecision. <br />Ordinarily, all sample bottles sent to labs should be <br />completely full. Anything less than a full bottle should <br />indicate to the lab either leakage or low sample avAilability. <br />The sampling protocol should account for the disposition of <br />partial samples, and make the lab responsible for ~hoting such <br />samples. If partial samples are to be supplied t1o the lab, <br />BMG should evaluate the probable effects on the analyses of <br />agitation, in air, during shipment. <br />Comment answered. <br />Comment answered. <br />9. The Division does not accept the response. If wafter of any <br />sort is found in a well that ordinarily does not contain <br />fluid, BMG should immediately investigate the prgblem. BMG <br />must develop an adequate protocol for addressing phis issue. <br />It is careless and unreasonable to assume that a laboratory <br />method should be deemed more important than a field <br />observation. BMG should know the compositions of fluids of <br />concern throughout the plant. BMG should be prepared to <br />identify the source of fluids found in a normally d;y sampling <br />station using methods that require only low volume$ of fluid. <br />If BMG needs assistance in devising such tests, tl~e Division <br />will provide it if requested. There are many trace element or <br />isotopic or other techniques that may be employed. <br />10. The Division does not accept the response. Fluid3 that fail <br />to provide consistent values on pH and conductivity meters do <br />so for logical reasons, not the least of which are faulty <br />meters, operator error, or inhomogeneous infiltration rates <br />into the sampling site. Would you pump a low-volute well dry <br />waiting for the indicators to stabilize? If your answer is <br />yes, is that reasonably protective of healtY~ and the <br />environment? This section must be re-addressed. <br />