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Aggregate Industries - WCR, Inc. <br />Amendment No.l - Jeronimus Property <br />Permit # M-1999-034 <br />Since the borehole diameter was one foot, the calculated borehole volume is 305 gallons -not <br />20.7 gallons as stated! If 825 gallons were actually pumped from the well, this equates to less <br />than 3 borehole volumes, not the 40 well volumes stated. Also, how was the discharge <br />measured? A 3-horsepower pump may have a capacity of 150 gallons per minute, but that <br />capacity is dependent upon the pump depth setting, the amount of water over the pump, the age <br />and efficiency of the pump, friction losses, and other mechanical factors. To know the actual <br />purge volume of a well, a measuring device must be utilized. <br />Mr. Molen indicates that the CDPHE Water Quality Control Division ground-water permit <br />guidance document (date unknown) was utilized for monitoring well sampling protocol. That <br />document included as Attachment 2 discusses calibration of all test equipment, measurement and <br />recording of water quality field pazameters oftemperature, pH, conductivity, and dissolved <br />oxygen during the purging process to determine stability, and documentation in a field logbook. <br />The Molen report makes no mention of the types of testing equipment utilized, the calibration of <br />that equipment, or the results of the field pazameters measured. So that we can be assured that a <br />representative water quality sample was collected, I would like a copy of this data. The CDPHE <br />guidance document also discusses procedures for purging and sampling to minimize loss of any <br />volatile compounds. Clearly, the site-specific monitoring plan should address this issue. My <br />own reseazch indicates that DIMP is asemi-volatile organic compound. The Henry's law <br />constant for DIMP is estimated as 4.4x10-5 atm-cubic meters/mole, and suggests that DIMP is <br />expected to volatilize from water surfaces. Is a pump dischazge of 150 gallons per minute <br />consistent with sampling for this compound? <br />Clearly there aze deficiencies in the protocols and information submitted for this first round of <br />water quality samples. As the Division has pointed out and requested submission of asite- <br />specific monitoring plan, I look forwazd to receiving that document. Given the information <br />provided, I would ask the opinion ofthe Division's professional staffofthe representativeness <br />and validity ofthe sampling resuts presented. Is the Division satisfied with the data and <br />conclusions of the sampling report? As stated above, I would like a copy of the recorded field <br />data for the August 19, 2003 sampling event to further understand the quality of the ground <br />water. <br />Based on the number of errors that have been identified in the submitted documents for this <br />permit to date, I recommend that the Division staff conduct an extra thorough review of all future <br />documents submitted. Thank you for providing us this opportunity to comment. <br />Sincerely, <br />~J ~' ~~ ~~~rU ' <br />Karen & Ralf Topper <br />Cc: Mike Refer, Aggregate Industries <br />Chris La Rue, Adams County <br />Harry Posey, DMG <br />