2003-10-24_REVISION - M1999034

• Permit No: M1999034
• IBM Index Class Name: Revision
• Doc Date: 10/24/2003
• Doc Name: Copy of Karen Topper Letter dated 10/22/03
• From: DMG
• To: ADCO Consulting
• Type & Sequence: AM1
• Media Type: D
• Archive: No

Aggregate Industries - WClt, Inc.
Amendment No.l - Jeronimus Property
Permit # M-1999-034
Karen Topper
8120 E. 104t" Avenue
Henderson, CO 80640
[phone]
October 22, 2003
Division of Minerals and Geology /
1313 Sherman Street, Room 215
Denver, CO 80203
Attn. Larry D. Oehler
t/
RE: Permit No. M-1999-034, Amendment No. 1
Aggregate Industries - WRC, Inc.
Deaz Mr. Oehler:
RECEIVED
OCT 2 3 2003 r/
Division ~f Minerals and GeelogY
Thank you for forwazding to me a copy of the Division of Minerals and Geology letter of
September 25, 2003 to Mr. Mike Refer of Aggregate Industries. I have also received a copy of
Molen & Associates letter report dated September 18, 2003 discussing "sample results of DIMP
on Topper property and lake". I would like to comment on both of these documents and request
additional information.
On August 18, 2003, I submitted a letter to the Division requesting that Aggregate Industries
provide a sampling plan to assure wnsistency and quality ofthe data collected. In the Division's
letter of September 25, 2003 it was stated that Condition No. 1 of the MLRB Order states in part
"No de-watering or extraction activities will occur until Aggregate Industries develops a plan to
monitor the gravel pit pond water for diisopropylmethylphosphonate (DIMP) and obtains
approval of that plan from the Division of Minerals and Geology". That letter further indicates
that such a plan has not yet been submitted to the Division for approval. I would like to
emphasize that an appropriate monitoring plan should address the specific characteristics ofthe
chemical of concern. For example, what is the specific gravity of DIMP? Would you expect to
fmd it at the bottom of the water column or the top? What is the compound's potential for
volatilization? What personal protective equipment and precautions should sampling personnel
be using? A monitoring plan should address the monitoring pazameters, frequency of
monitoring, the sampling points, the method of sampling, the protocols for sample collection and
handling, the analytical method, the quality control protocols, the reporting requirements, etc.
The protocols should be appropriate for the chemicals of concern.
We believe that the consultant report submitted contains errors and deficiencies. The last
pazagraph of page 1 of Molen & Associates September 18, 2003 discusses the completion
specifications of the water well sampled on my property. The summation information on the
next page has a discrepancy in the well depth and a significant error in the well volume
calculation. The completion report for this well indicates that the well is 86 feet deep. Molen
measured a static water level of 34 feet deep, thus the water column is approximately 52 feet.