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The Division ignores Cotter's addition of Sump No. 4 and MW 9 in stating that "Cotter's <br />plan to just treat water reporting to Sump Number One would not be sufficient since it would not <br />capture mine water discharges at other locations." Division Response at 6.1 With this expansion <br />of the system and allowance of lag time for the 100-gpm water treatment system to treat the <br />alluvial groundwater, Cotter expects that treatment of the alluvial groundwater will significantly <br />improve the quality of water in Ralston Creek. <br />Cotter has consistently stated that the enhanced monitoring now being conducted will <br />enable Cotter to better understand contaminant loading to Ralston Creek and to optimize its <br />water treatment system. Tr. of Hearing 77:11-13. Whetstone and Cotter have been assessing <br />new data since the 2010 reinitiation of sampling at historic surface water monitoring stations <br />along Ralston Creek adjacent to the alluvial fill. See Exhibit 1 at 4. This data, along with <br />comparative evaluations with the results of the 2008 electrical conductivity by Whetstone and <br />comparative assessments with previous groundwater sampling, identify a relatively discrete <br />portion of the alluvial fill as the primary source of uranium loading to Ralston Creek, which is in <br />the vicinity of SW-BOS. Id. This is significant new information not previously submitted to the <br />Mined Land Reclamation Board ("Board"). Historical groundwater concentrations in alluvial <br />monitoring wells indicate that the highest concentrations are found in MW 6, which is near SW- <br />BOS, followed by MW 7 and MW 9. Id. The onset of water quality impacts to Ralston Creek <br />near stream monitoring station SW-BOS occurs in the vicinity between groundwater monitoring <br />wells MW 9 and MW 6. Id. Years of historic data indicate that all stations downstream of the <br />alluvial fill, below SW-BPL, have essentially had constant or slightly decreasing uranium <br />1 Susan Wyman testified at the July 12, 2010 hearing that "[w]e have the ability to bring <br />Sump 4 and MW 9 on to the system if necessary, ..." Tr. of Hearing at 75:23-24. The Cotter <br />Petition at page I I also stated that the treatment system is now treating water from Sump No. 4 <br />and MW 9. <br />3 <br />tl1493118 vl den