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<br />of concern throughout the plant. BMRI should be prepared to idemify the sor+rce <br />of fluids found in normally dry sampling stations using methods that require arly <br />low volumes of fluid. /f BMRI needs assistance in devising such rests, the <br />Division will provide it if requested. There are marry trace clement or isotopic <br />or other techniques that may be employed. <br />RESPONSE: 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 evalutate 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 conduct a complete <br />analysis. The analytical results for a sample which does not meet field QA/QC <br />protocols will not be valid. Thus, BMR agrees that if water is found in a well <br />that is ordinarily dry, and insufficient sample is collected or insufficient purging <br />is conducted to meet all QA/QC protocols, the analytical results will be notated <br />that QA/QC protocols 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 />analyze a small volume of fluid, the results of such an analysis inay not meet all <br />QA/QC protocols, thereby potentially rendering the results invalid. <br />In addition, the sampling and analysis of an ordinarily dry well may raise an issue <br />of representativeness associated with stagnant water and holding time prior to <br />analysis. Thus, BMR believes that even if an adequate sample amount is <br />obtained, such a sample may not meet QA/QC requirements erUSUring sample <br />representativeness. <br />10. The Division does not accept the respwue. Fluids that fail to provide consistent <br />values on pH and conductivity meters do so for logical reasons, not the [cost of <br />which are faulty meters, operator error, or inhonrogcncous infiltrGtion rates into <br />the sampling site. Would you pump aloes-volume well dry tuairing for rlic <br />indicators to stabilize? If your answer is yes, is that reasonably protective of <br />health and the environment? This section must 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 nonlrepresentative <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 />