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,Af - /,'77-3o o --- <br />CITY OF ARMADA <br />UTILITIES DEPARTMENT <br />FACSIMILE: 720-898-7603 ? TDD: 720-898-7869 <br />PHONE: 720-898-7760 <br />August 18, 2010 <br />Janet Kieler, Permits Section Manager . <br />Colorado Department of Public Health and Environment <br />Water Quality Control Division (WOCD) <br />4300 Cherry Creek Drive South <br />Denver, Colorado 80246-2530 <br />Auc ? 9 200 <br />owwon of <br />0 ing sand SAY <br />Subject: Public Notice No. CO-07-1- Permit No. 000001244, Cotter Corporation, <br />Schwartzwalder Mine WWTF <br />Dear Ms Kieler, <br />The City of Arvada values the opportunity to comment on the Public Notice No. CO-07-1- <br />Permit No. 000001244, Cotter Corporation, Schwartzwalder Mine WWTF. The rapid response <br />at which this very important permit was drafted is appreciated particularly considering that <br />Arvada's 105,000 drinking water customers receive their source water primarily from Ralston <br />Reservoir on Ralston Creek which is being negatively impacted by seepage, runoff, and drainage <br />from the Schwartzwalder Mine. <br />Arvada has identified five contaminants of concern from the Schwartzwalder mine: uranium, <br />radium 226, radium 228, gross alpha and gross beta. Arvada's water treatment plant is not <br />designed to remove these contaminants of concern and in fact our conventional water treatment <br />facility only partially removes or does not remove many of the co-constituents liberated from the <br />legacy uranium mining operation. <br />However, the incidental radioactive material that is removed does negatively impact our solids <br />hauling and disposal options. Currently, the residual solids from our water treatment process are <br />recycled through a composting operation. Failure to adequately reduce the contaminates from the <br />reclamation activity of the Schwartzwalder Mine will result in the disposal, in a hazardous waste <br />land fill with a radioactive materials license. Disposal at a hazardous waste land fill will <br />significant increase transportation and disposal cost, plus the potential long term liability of <br />having the City's name on manifested waste. <br />The draft Permit apparently was written based on a renewal process for an active mine site when <br />in fact the discharge is for groundwater remediation activities associated with failed or <br />inadequate reclamation. With Arvada's source water being negatively impacted from the <br />Swartzwalder Mine, Arvada is requesting that a revised draft permit be issued with an additional <br />opportunity to comment. <br />P.O. BOX 8101 A 8101 RALSTON ROAD A ARVADA, COLORADO A 80001-8101