2003-10-23_REVISION - M1999034 - Laserfiche WebLink

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