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Topper Objection Amendment No.l - Jeronimus Property Petmit # M-99-034 lakes aze 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 lakes are reduced significantly, the resulting 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 result 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 ofihe pit lakes. In pazagraph 4 of the mining notes and restrictions of Exhibit C-2 it is stated "Topsoil and overburden stockpiles that aze 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 stability, airborne particulate generation, and creation of visual obstructions.- Interested parties cannot articulate.objections 1o a mining plan-when that plan contains factual inconsistencies. My concerns regazding water quality include remobilization ofexisting contaminants, herbicide application, vehiculaz/equipment spills, and inadequate permit compliance. The Henderson azea of Adams County is within a ground water contaminant plume attributed to historical waste disposal practices at the Rocky Mountain Arsenal. The azsenal, established in 1942, was one of the U.S. Army's last chemical weapons manufacturing facilities to be built during World Waz II. The major types of contaminants at the azsenal include pesticides, solvents, metals, and pesticide and chemical munitions breakdown products. According to the Tri-County Health Department, azsenal related contamination can be found both onpost and offpost. The majority of offpost contamination is found in the shallow, unconfined aquifer. In the mid to late 1980s, an offsite contamination assessment was conducted and the Henderson azea, among others, was identified as containing high levels of diisopropylmethylphosphonate (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 Controi Division of the State of Colorado established a Colorado ground water standazd 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 azea, 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 of contaminated drinking water supplies. Potential health impacts associated with remobilization ofknown contaminants in this azea 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 azeas from the Plant Site. Such a structure constitutes a point discharge to ground water and would require issuance of a dischazge permit from the Watet 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 Dischazge Permit for this property. 2