2021-01-15_REVISION - M1977300 (2)

Home Browse Search

CITY OF AL UTILITIES DEPARTMENT JAN 15 2021 FACSIMILE: 720-898-7603 L TDD: 720-898-786OMSION OF RECLAMATION PHONE: 720-8 98-7760 MINING AND SAFETY January 14, 2021 Ms. Amy Eschberger Colorado Division of Reclamation, Mining and Safety 1313 Sherman Street Rm 215 Denver, Colorado 80203 Re: Colorado Legacy Land LLC, Request for Full or Partial Surety Reduction -SR09 Dear Ms. Eschberger, The City of Arvada ("City") has reviewed the request for surety reduction submitted by Colorado Legacy Land LLC for the Schwartzwalder Mine. We do not support this request and recommend it be denied. We appreciate the progress Colorado Legacy Land ("CLL") has made and continues to make with remediations at Schwartzwalder Mine. As you know,Schwartzwalder Mine discharges directly impact the drinking water supply to a large number of Colorado residents, including residents of the City.The City has a vested interest in the public health, safety and welfare of its citizens. Increased levels of uranium or other contaminants can harm public health as well as cause increased treatment and residual disposal costs due to TENORM. When the City is required to dispose of TENORM,the cost is 700% higher than our standard disposal cost. Accordingly, it is imperative that CLL maintain the appropriate treatment processes and continue to address any seepage or stormwater issues now and into the future. Although we acknowledge CLL's request to reduce the surety due to progress it has made so far, we need to ensure that all commitments from the Revised Approval of SO-01 dated Feb 20, 2018 between CLL and the Colorado Division of Reclamation, Mining and Safety are met before we can support this endeavor. To date, we are not aware of receiving any water quality data from CLL and were not aware that we were allowed to sample at the sampling taps at Schwartzwalder.Although we understand that this may have been due to changes in personnel at the City, we simply do not have enough information at this time to support the request. In addition, Denver Water and its consultants are currently evaluating water quality data obtained from the mine pool to determine if treatment processes are working. We would like several year's worth of data to substantiate any claims of improvement. In fulfilling its responsibilities to its citizens,the City prefers a conservative approach based on water quality data that our drinking water sources will be protected to the utmost. We are wary due to past experiences around Colorado which have had devastating impacts to water resources. In addition,we received notice this week of an increase in surety requirements for the site " associated with an amendment to the Schwartzwalder Mine permit. The amount of the 8401 RALSTON ROAD A ARVADA, COLORADO A 80002