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(--, I Ty OF "�Zc veo <br /> DASEp ' ;. .: <br /> DMS/Oy( <br /> UTILITIES DEPARTMENT M�N�NG, <br /> FACSIMILE: 720-898-7603 A TDD: 720-898-7869 <br /> PHONE: 720-898-7760 <br /> September 14, 2021 <br /> Ms. Amy Eschberger <br /> Colorado Division of Reclamation, Mining and Safety <br /> 1313 Sherman Street Rm 215 <br /> Denver, Colorado 80203 <br /> Re: Colorado Legacy Land, LLC — Permit M-1977-300 - Amendment Application <br /> (Amendment 6) <br /> Dear Ms. Eschberger, <br /> The City of Arvada ("City") has reviewed Application Amendment 6 for mine permit M- <br /> 1977-300 ("Amendment 6") submitted by Colorado Legacy Land LLC ("CLL") concerning <br /> the Schwartzwalder Mine in Golden, Colorado. The City believes the Division of <br /> Reclamation, Mining and Safety ("DRMS") should deem Amendment 6 deficient and <br /> require CLL to supplement with additional information. Additionally, we request that <br /> DRMS increase CLL's financial warranty due to the inability of CLL to stabilize the mine <br /> pool chemistry with its current method of operation. <br /> The City further requests DRMS consult with the Colorado Department of Public Health <br /> and Environment and the US Environmental Protection Agency, Region 8 on this <br /> amendment. The City has serious concerns about the approach CLL is taking to their <br /> management of the site. There is high concentration of uranium in the Mine Pool, the <br /> conceptual site model is inadequate, and there is general lack of data and analysis <br /> providing evidence that the uranium is not migrating in the groundwater. We also <br /> believe there is inadequate protection of the environment in case of a flood or wildfire <br /> emergency. <br /> These are all aspects of the site that have serious risk to public health and the <br /> environment. The City believes CDPHE and USEPA need to have a role in oversight of <br /> the Schwartzwalder Mine operation in the context of the Clean Water Act and state and <br /> federal regulatory authority related to radioactive contaminants. <br /> We do appreciate the progress CLL has made and continues to make with remediation <br /> at the Schwartzwalder Mine. As you know, Schwartzwalder Mine discharges directly <br /> impact the drinking water supply to a large number of Colorado residents, including <br /> residents of the City. The City has a vested interest in the public health, safety and <br /> welfare of its citizens. Increased levels of uranium or other contaminants can harm <br /> public health as well as cause increased treatment and residual disposal costs due to <br /> 8101 RALSTON ROAD A ARVADA, COLORADO A 80002 <br />