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calculations provided in the [EPP] indicated that the flow from the mine pool to the alluvium <br />would represent, at most, 0.8% to 8% of the flow to the alluvium. If this were occurring, then <br />the logical and most effective place to circumvent it is by capturing and treating groundwater in <br />the alluvium and fill, thus preventing it from reaching Ralston Creek."). Moreover, Susan <br />Wyman clearly stated in the Rationale at page 1 "[t]here is no direct evidence that the mine pool <br />is contributing uranium to Ralston Creek." The Order never addresses one of the key points <br />advanced by Cotter - that if seepage from the mine pool was occurring, it would be treated in the <br />system that has already been installed. Because any such seepage would be addressed by the <br />existing treatment system, requiring mine dewatering and treatment does not bear a reasonable <br />relationship to economic benefits to be derived from such measures. See Colo. Rev. Stat. <br />§ 34-32-102(2). <br />The definition of reclamation as covering procedures reasonably designed to minimize as <br />much as practicable the disruption from the mining operation also supports allowing Cotter to <br />demonstrate that treatment of the alluvium (without mine dewatering and treatment) will achieve <br />stream standards. In fact, Cotter is currently treating more water than is required by the Order, <br />which requires treatment of all water that reports to Sump Number One. The treatment system is <br />now also treating water from Sump Number Four and Monitor Well Nine. <br />(B) Dewatering the Mine Pool and Treatment of Mine Pool Water Do Not Satisfy <br />the Reasonableness Requirement of Reclamation Procedures. <br />The Division had the burden at the hearing to prove that mine dewatering and treatment <br />is a procedure "reasonably designed to minimize as much as practicable the disruption from the <br />mining operation." (Emphasis added). See Colo. Rev. Stat. § 34-32-103(13) (definition of <br />"reclamation"). At the hearing, David Bird, on behalf of the Division, testified about Cotter's <br />11