2003-06-12_REVISION - M1999034 (2)

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Topper Otry'ectioa Amendment No.l - Jeronimus Property Permit # M-99-034 lakes are partially dewatered, this will lower the water table in the surrounding alluvial aquifer. A lowered water table reduces the efficiency of my well's production and increases my pumping costs. If water levels in the cakes are reduced significantly, the resuhing water level decline in the surrounding aquifer may be such that my well would go dry when pumped. A decline of the natural water table produced by actions of the applicant would resuh in injury to my decreed water right in the irrigation well and the other exempt alluvial well. The applicant provides no hydrologic assessment ofthe potential impact to surrounding structures from dewatering oftbe pit Takes. In paragraph 4 of the mining notes and restrictions of Exhibit C-2 it is stated "Topsoil and overburden stockpiles that are temporarily stored on site..., have a maximum height of 30',..." Item #6 on page 3 of Exhibit D of the permit application also addresses topsoil and overburden excavation and stockpiling. In this item, stockpiles are cited to be a maximum of 20' in height. Cleazly, there is a 10-foot discrepancy between these two documents. The height of stockpiles will influence their runoff and erosion, slope stabilhy, airborne particulate generation, and creation of visual obstructions.- Interested patties-cannot articulate-objections So a mining plan when that.plan.contains. factual inconsistencies. My concerns regazding water quality include remobili7ation of existing contaminants, herbicide application, vehicular/equipment spills, and inadequate permit compliance. The Henderson area of Adams County is within a ground water contaminant plume attributed to historical waste disposal practices at the Rocky Mountain Arsenal The arsenal, established in 1942, was orn of the U.S. Army's last chemical weapons rnanu&icturing facilities to be built during World War II. The major types of wntaminants at the arsenal include pesticides, solvents, metals, and pesticide and chemical munitions breakdown products. According to the Tri-County Health Department, arsenal related contamination can be found both onpos[ and offpost. The majority of otfpost contamination is found in the shallow, unconfined aquifer. In the mid to late 1980x, an offsite contamination assessment was conducted and the Henderson area, among others, was identified as containing high levels of diisopmpylmethylphosphonate (DIMP), a chemical unique to the Army's manufacture of GB nerve gas, or sarin. In response to the findings of this investigation, the Water Quality Cotttrol Division of the State of Colorado established a Colorado ground water standard of 8 µg/L for DIMP. This class ofsemi-volatile organic compounds, though somewhat soluble, tends to adsorb on soil particles. Given the known contaminant plume in this area, excavation activities associated with removal of aggregate materials within the zone of water table fluctuation will remobilize contaminants that had adsorbed on the subsurface alluvial materials. This remobilization can produce an immediate threat to human health by ingestion ofcontaminated drinking water supplies. Potemial heahh impacts associated with remobilization of known comaminants in this area have not been addressed by the applicant. While the applicants permit documentation mentions the existence of a Storm Water Management Plan and permit in addition to a Spill Prevention Control Plan, these existing plans have not been modified to reflect the addition of the Jeronimus Property or proposed mining plan thereon. The mining plan, Exhibit D, indicates that piping will be installed to convey wash water back to the lake areas from the Plant Site. Such a structure constitutes a point discharge to ground water and would require issuance of a discharge permit from the Water Quality Control Division. Such a point discharge may further concentrate existing contaminants dissolved in the ground water. The applicant has not demonstrated the issuance or application for a Colorado Wastewater Discharge Permit for this property.