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Mr. David Berry <br />May 14, 2010 <br />Page 5 <br />reactivated to accomplish the Division's remediation requirements. In addition, financial <br />warranties should be required to address revised reclamation requirements and protection of <br />water resources. <br />During implementation of reclamation activities at the Schwartzwalder Mine, Denver <br />Water recommends that the Division, in conjunction with the CDPHE Water Quality Control <br />Division, develop a plan for inspections, investigations, third party review of data, modification <br />of the reclamation permit to reflect new data and reclamation requirements, and any other action <br />needed by Cotter. The Division should implement the Water Quality Control Commission's <br />groundwater standards and water quality standards for Ralston Creek (Clear Creek segment l7b) <br />and Ralston Reservoir (Clear Creek segment 23). Preliminary Effluent Limits through a <br />discharge permit should be determined by the Water Quality Control Division that will address <br />discharges to Ralston Creek and any discharges from pumps to groundwater. Routine <br />monitoring of the mine pool and reporting should also be required and made available to the <br />public. <br />Denver Water appreciates the opportunity to submit these comments to the Division. It is <br />critical that Denver Water be able to monitor the reclamation efforts at the Schwartzwalder Mine <br />in an effort to determine the impacts to Denver's water facilities. As mentioned previously, the <br />potential health risk to customers and employees could be significant if immediate action is not <br />required of Cotter Corporation. Inaction due to a prolonged debate between the Division and <br />Cotter over what remediation action is appropriate is not acceptable. In addition, Denver Water <br />customers should not have to bear the increased cost associated with water and sludge treatment <br />for a problem that is clearly being caused by another entity. Please keep me informed about the <br />Division's requirements for Cotter Corporation as well as the progress of remediation at the <br />Schwartzwalder Mine. <br />Sincerely, <br />, -? 7? , /?Z/ <br />Brian D. Good <br />Director of Operations and Maintenance <br />cc: Mr. Steve Gunderson, CDPHE Water Quality Control Division <br />Mr. Jim McCarthy, City of Arvada <br />Mr. Rick Jeschke, North Table Mountain WSD