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BEFORE THE MINED LAND RECLAMATION BOARD <br />STATE OF COLORADO <br />Notice of Violation No. MV-2010-018 <br />REPLY OF COTTER CORPORATION (N.S.L.) TO DIVISION OF RECLAMATION, <br />MINING AND SAFETY'S RESPONSE TO COTTER CORPORATION'S PETITION <br />FOR RECONSIDERATION OF FINDINGS OF FACT, CONCLUSIONS OF LAW, AND <br />ORDER CONCERNING COTTER'S PERMIT NO. M-1977-300 REGARDING THE <br />SCHWARTZWALDER MINE <br />IN THE MATTER OF COTTER CORPORATION'S POSSIBLE VIOLATIONS, CEASE AND <br />DESIST ORDER, CORRECTIVE ACTIONS, AND CIVIL PENALTIES, File No. M-1977-300 <br />Cotter Corporation (N.S.L.) ("Cotter") replies to the September 10, 2010 Division of <br />Reclamation, Mining and Safety's Response ("Division Response") to Cotter's Petition <br />("Cotter's Petition") for Reconsideration of Findings of Fact, Conclusions of Law, and Order <br />Concerning Cotter's Permit No. M-1977-300 Regarding the Schwartzwalder Mine ("Order") as <br />follows: <br />1. The Current Treatment of the Alluvial Groundwater Is Expected to Be Effective in <br />Reducing Uranium Concentrations. <br />Cotter has been devoting enormous resources to understanding and correcting water <br />quality problems in Ralston Creek. It procured, installed and started operating a 50-gallon per <br />minute ("gpm") water treatment system to treat water reporting to Sump No. 1 on July 2, 2010. <br />It procured, installed, and started operating a 100-gpm water treatment system to treat water <br />reporting to Sump No. 1 on July 30, 2010, which involved refurbishment of the water treatment <br />building and of electrical systems. For these systems, Cotter procured and installed nearly 4,000 <br />feet of pipe and pumping equipment to extract groundwater from across the site and deliver it to <br />the water treatment facility. This work involved applications to and approvals from several <br />#1493118 A den