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June 25, 2010 12 of 15 <br />The bedrock surrounding the mine has very low permeability, which prevents any significant movement of <br />groundwater. <br />Shaft Sinking. In the late 1950's, the shaft was being sunk from the Steve adit. No dewatering was <br />required until the shaft reached a depth of 250 feet below the Steve level. The first dewatering pump was <br />installed in September, 1958, when the total shaft depth was 285 feet and groundwater pumping was <br />required for the first time. The mine was dewatered by pumping for only two hours per day at 15 to 20 <br />gallons per minute (gpm), which is the equivalent of a sustained pumping rate of 1.25 to 1.67 gpm. If the <br />mine had been in hydraulic connection with the creek, pumping rates would have been significantly higher. <br />Underground Packer Tests. Packer permeability tests were conducted underground in 1999, before the <br />mine shut down. The results of all 22 tests gave a geometric mean hydraulic conductivity of 4.7 x 10.7 <br />cm/sec. The lowest packer test result was 9.9x10-8 cm/sec and the median value was 2.7x10-7 cm/sec. For <br />comparison, the EPA requires that municipal landfill covers have a hydraulic conductivity less than 1x10'5 <br />cm/sec. Soil barriers in hazardous waste landfills are typically compacted to no greater than 1x10"7 cm/sec. <br />Mine Inflow. At its total maximum depth of 2,200 feet, when the mine was fully dewatered groundwater <br />inflow to the Schwartzwalder mine was only 189 gpm. These very low flow rates indicate that rock mass <br />has very low permeability, and there are no high-permeability faults or conduits that could convey water to <br />(or from) the underground workings. If high-permeability conduits existed, then inflow to the mine would <br />have been significantly greater. <br />WRT Pilot Test. Sustained pumping rates during a pilot test in July and August, 2007 (with the pump set <br />at 27 ft below the collar of the #2 shaft in the Steve Level) were only 1.2 gpm. It should be noted that the <br />entire mine workings were in connection with the shaft, with no resistance to flow in the workings <br />themselves. Calculations that evaluated the mine pool as a 2,200 feet deep "large diameter well" show that <br />an overall bedrock permeability of 2.8x10-7 cm/sec would produce the observed 1.2 gpm pumping rate with <br />14.6 feet of drawdown (Whetstone, 2007). <br />Saturated Zone Above the Mine. Monitoring wells MW 10 and MW 11 are located on the hillside above <br />the mine (Figure 4) and contain water because the rock is too tight to drain into the unsaturated workings <br />below. The low permeability of the rock mass prevents groundwater from draining from near surface, <br />where the wells are located, downward into the unsaturated upper mine workings. The same process <br />prevents groundwater in the mine pool from draining toward Ralston Creek, or any other point. <br />Creek Flow. Ralston Creek was never drained during mining, although the mine was dewatered to nearly <br />2,200 feet below the creek level. If a strong hydraulic connection existed between the mine and the creek, <br />then the creek flow would have dried up as a result of mine dewatering during operations. Instead, no effect <br />on flow in the creek was discernable. <br />Mine pool dewatering and treatment at this time will preclude the opportunity to demonstrate that <br />treatment of the alluvial groundwater will address the Ralston Creek issues, and that mine dewatering and <br />treatment are not necessary. <br />Based on technical information compiled by Cotter and its consultants, Cotter believes that treatment of <br />groundwater in the alluvium and fill will be effective in reducing uranium concentrations in Ralston Creek. <br />Cotter is committed to pumping and treating from Sump 1 by July 31, 2010. Further, if pumping from <br />Sump 1 does not capture sufficient alluvial groundwater to meet drinking water standards in the creek, <br />Cotter is committed to pumping and treating groundwater from additional locations in the alluvium and fill. <br />Cotter needs the opportunity to demonstrate that this approach will be successful in lowering uranium