1992-09-08_REVISION - M1988112 (3)

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of concern throughout the plant. BMRI should be prepared to idemify the sor+rce of fluids found in normally dry sampling stations using methods that require arly low volumes of fluid. /f BMRI needs assistance in devising such rests, the Division will provide it if requested. There are marry trace clement or isotopic or other techniques that may be employed. RESPONSE: BMR agrees that understanding the composition of fluids of concern at San Luis is important. If a well which is ordinarily dry contains fluid at a scheduled sampling event, BMR will immediately investigate the potential source(s) of the fluid and report its findings to the CMLRD. BMR will also obtain a sample from the well for analysis to evalutate the source of the water. However, as the Division recognizes, understanding the composition of such fluids occurs within the context of analytical methods performed in accordance with selected QA/QC protocols and the volume of sample obtained can affect QA/QC protocols and the ability to conduct a complete analysis. The analytical results for a sample which does not meet field QA/QC protocols will not be valid. Thus, BMR agrees that if water is found in a well that is ordinarily dry, and insufficient sample is collected or insufficient purging is conducted to meet all QA/QC protocols, the analytical results will be notated that QA/QC protocols were not met and, therefore, the results are not valid. BMR believes that the Division should recognize that while it is possible to analyze a small volume of fluid, the results of such an analysis inay not meet all QA/QC protocols, thereby potentially rendering the results invalid. In addition, the sampling and analysis of an ordinarily dry well may raise an issue of representativeness associated with stagnant water and holding time prior to analysis. Thus, BMR believes that even if an adequate sample amount is obtained, such a sample may not meet QA/QC requirements erUSUring sample representativeness. 10. The Division does not accept the respwue. Fluids that fail to provide consistent values on pH and conductivity meters do so for logical reasons, not the [cost of which are faulty meters, operator error, or inhonrogcncous infiltrGtion rates into the sampling site. Would you pump aloes-volume well dry tuairing for rlic indicators to stabilize? If your answer is yes, is that reasonably protective of health and the environment? This section must be re-addressed. RESPONSE: BMR believes that the collection and analysis of representative samples is "reasonably protective of health and environment". To rely on nonlrepresentative samples invites error, which is not conducive to achieving the protectiveness standard. An important QA/QC protocol for ensuring that a representative -5-