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The City of Arvada's Request for Immediate Action <br />The EPP appears to be aimed at complying with DBMS requirements to decommission the license(s), <br />but is inadequate in terms of developing a plan to attain water quality standards for Ralston Creek--a <br />source of drinking water for three municipal water providers, including Arvada. <br />The uranium increases of which we have recently been made aware are alarming and of concern for our <br />water treatment operations. Water quality data referenced in a May 12, 2010, WQCD memo states that: <br />"Water Quality data for Ralston Creek at the Long Lake Headgate was assessed using data from 1/25/05 <br />to 3/10/10. The 85"' percentile of the data was a uranium concentration of 307 ug/l (the uranium water <br />quality standard is 30 ug/." Having the uranium concentrations in a state classified stream ten times the <br />standard is unacceptable. <br />While conventional water treatment is effective in reducing uranium in the concentrations which we <br />have seen to date, it is unknown how much more the City's water treatment process can remove. <br />Fortunately, the City is meeting State and Federal drinking water standards; however, what needs to take <br />place to ensure continued compliance with the Safe Drinking Water Act is an interim plan of action to <br />return Ralston Creek to a water supply that meets water quality standards. There are many options that <br />should be evaluated including in-situ uranium treatment or a pump and treatment system for the mine <br />pool and the reinstatement of the re-circulating hydraulic barrier between groundwater in the alluvial fill <br />and surface water in Ralston Creek. This plan should be developed within the next 30 days and <br />implemented within 60 days. <br />One advantage Cotter has is that there are cost recovery opportunities from the extracted uranium that <br />would occur with the treatment of the mine pool water. The opposite is true for the City of Arvada and <br />the negative impact on our water treatment residuals. While the City currently recycles our residuals--a <br />green and sustainable practice--the continued inaction and elevated uranium will most certainly lead to <br />dumping over 500 cubic yards per year into an industrial landfill. Given the required additional testing, <br />increased transportation costs, and increased disposal cost, our residuals cost will increase by an <br />unknown but significant amount. Not only will there be increased costs, but the City will forever have its <br />name associated with manifested waste in a landfill even while meeting water quality standards. Should <br />future clean-up of the landfill be necessary, the City would have to contribute to the clean-up cost. <br />Longer Term Action <br />The radiation license held by Cotter needs to be maintained and or expanded--not terminated-in order <br />that a long-term solution to safely reclaim the land can be developed and implemented. The City of <br />Arvada is looking to CDPHE to thoroughly evaluate the multitude of complicated technical and <br />regulatory issues, and apply them in a manner that is protective of both public health and the <br />environment. <br />I look forward to hearing of an action plan that will protect the City's water supply. <br />Sincerely, <br />Crai . K ian <br />City anage <br />C: City Council <br />Steve Gunderson, WQCD