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<br />Comment answered <br />8. Comment answered <br />The Division does not accept the response. If water of any <br />sort is found in a well that ordinarily does not contain <br />fluid, BMRI should immediately investigate the problem. BMRI <br />must develop an adequate protocol for addressing this issue. <br />It is unreasonable to assume that a laboratory method should <br />be deemed more important than a field observation. BMRI <br />should know the compositions of fluids of concern throughout <br />the plant. BMRI should be prepared to identify the source of <br />fluids found in normally dry sampling stations using methods <br />that require only low volumes of fluid. If BMRI needs <br />assistance in devising such tests, the Division will provide <br />it if requested. There are many trace element or isotopic or <br />other techniques that may be employed. <br />10. The Division does not accept the response. Fluids 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-volume well dry <br />waiting for the indicators to stabilize? If your answer is <br />yes, is that reasonably protective of health and the <br />environment? This section must be re-addressed. <br />11. Comment answered <br />12. The Division does not accept the response. In a recent <br />example, cited in BMRI's responses to comments in this. <br />section, BMRI sent identical samples to two independent EPA <br />labs. The labs reported dramatically different redults, both <br />using standard methods. In a case like this, which value <br />would you accept; would you accept either? The Division <br />insists that responsibility for QA and QC reside both with the <br />lab and with BMRI. Unless BMRI has some way to periodically <br />monitor the quality of lab results, they must trust the lab <br />explicitly. This is not good sampling procedure and will not <br />be accepted a part of this protocol. This section must be <br />re-addressed. <br />13. The response does not make sense. This section must be <br />re-addressed. <br />14. Comment answered. <br />