2003-04-10_REVISION - M1999034 (2)

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Toppec Objection Amendment No.l - Jeronimua Property Permit # 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 aze 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 groduced 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 of the potential impact to surrounding structures from dewatering of the pit fakes. 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 stotikpIles will influence their runoff and erosion, slope stability, airborne particulate generation, and creation of visual obstructions. Interested parties can not articulate objections to a mining plan when that plan contains factual inconsistencies. My concerns regazding water quality include remobilization of existing contaminants, herbicide application, vehicular/equipment spills, and inadeguatepermit_compliance. The Fiendersoaarea of Adams County is wit~m a ground water cgntaminant plume attn'buted to historical waste disposal practices at the Rocky Mountain Arsenal. The arsenal, established in 1942, was one of the U. S. Army's last chemical weapons manufacturing facilities to be built during World Wat II.. The ma1or types o~co~~**,it,ants at the arsenal include pesticides, solvents, meta]s, and pesticide and chemical munitions breakdown products. According to the Tri-County Heahh Department, arsenal related contriminarion 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 area, among others, was identified as containing high levels of rliiennrnnvlmPth.~l.. O 11erVe---- - - - - ~ r ~ gas, or sarin. In response to the findings of this investigation, the Water Quality Control 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. Criven the known contaminAnt plume in this azea, excavation activities associated with removal of aggregate materials within the zone of water table fluctuation will remobilize COnt~nRrnc that had adsorbed on the subsurface alluvial materials. This remobilization can produce an immediate threat _ _ to humtln_health by ingestign_of Foptamirk~ted dcinki~ng water supplies. Potentiat healthimpacis associated with remobilizatitin of known contaminants 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 Dischazge Permit for this property.