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Regulatory Compliance <br />An "Interim Measures" proposal pursuant to Paragraph 27 of the Order was submitted to the <br />WQCD on June 26, 2010. That proposal requested approval to temporarily operate a nominal <br />50-gpm water treatment unit at Sump Number One and to discharge the treated water at a nearby <br />temporary outfall location along Ralston Creek, which was approved by WQCD in a letter dated <br />June 30, 2010. <br />By submittal of this Technical Memorandum, Cotter is providing information requested by the <br />WQCD regarding the proposed installation and operation of a nominal 100-gpm water treatment <br />system (see Attachment 2) and an alternate treated water discharge outfall location along Ralston <br />Creek (versus the old location under CDPS Permit CO-0001244). The WQCD has indicated that <br />the daily discharge monitoring requirements of the Permit could be revised to permit a weekly <br />monitoring schedule for Radium 226+228. In addition, Cotter is requesting that the WQCD <br />accept the site-specific water hardness data and a related evaluation provided by Whetstone <br />Associates (see Attachment 3) when assessing and assigning discharge limits for interim water <br />treatment and for the new Pen-nit application. <br />Radioactive Materials Licensing to operate the proposed 100-gpm water treatment system is <br />being pursued separately with the Radiation Management Unit of the CDPHE. The Radiation <br />Management Unit indicated to Cotter and its water treatment contractor, Water Remediation <br />Technology ("WRT") in a conference call on June 22, 2010 that the temporary 50gpm water <br />treatment unit can operate under a General Radioactive Materials License ("RML") until <br />Specific RML.s can be obtained by Cotter and WRT to cover operation of the 100-gpm water <br />treatment unit (see Attachment 2). <br />The Division of Reclamation, Mining, and Safety ("DRMS") has also been notified of this <br />proposed water treatment, and an independent approval with DRMS is being sought. DRMS <br />has indicated that the appropriate regulatory mechanism by which such approval might be <br />granted is through partial approval of the Technical Revision 12 request which was submitted to <br />DRMS on June 1, 2010. The indicated request mechanism to move forward with alluvial fill <br />groundwater treatment through the 100-gpm water treatment system by July 31, 2010 was <br />submitted to DRMS on June 28, 2010. A separate Technical Revision 13 request for operation <br />of the temporary 50-gpm water treatment unit was approved by DRMS on July 2, 2010. <br />Pumping/Pioina/Dischar a System Design <br />Whetstone Associates has provided descriptions, specifications, engineering drawings and maps <br />detailing a proposed pumping/piping system, an alternate discharge location, and an outfall <br />structure design for conveying water to and from the nominal 100-gpm water treatment system <br />that will be located in the waste water treatment building ("WWTB"). This information is <br />submitted as Attachment I to this document.