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2010-09-14_ENFORCEMENT - M1977300 (2)
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2010-09-14_ENFORCEMENT - M1977300 (2)
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Last modified
8/24/2016 4:22:20 PM
Creation date
9/21/2010 8:03:53 AM
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
9/14/2010
Doc Name
Reply of Cotter Corporation/ Petition for Reconsideration.
From
Holme Roberts & Owen LLP
To
DRMS
Email Name
DB2
Media Type
D
Archive
No
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concentrations over time, demonstrating that there are no other locations along Ralston Creek <br />downstream of the alluvial fill where loading to Ralston Creek occurs. Id. at 4. This evaluation <br />shows that contaminant loading occurs solely in the alluvial fill where it can be treated before <br />reaching Ralston Creek, or alternatively, where it can be effectively isolated and diverted to <br />ensure capture and treatment. Id. at 4-5. Therefore, mine dewatering and treatment would be an <br />inefficient and likely ineffective means to achieve compliance with water quality standards that <br />can be achieved through treatment of groundwater in the alluvium and fill. Id. at 5. <br />II. The Recently Discovered Flow from a 2-Inch Diameter Pipe Is Consistent With <br />Whetstone's Conclusion That, If Any Conduits from the Mine Pool Exist, They Will <br />Be Treated by the Current Treatment System. <br />The Division Response includes information about a recently discovered flow from a 2- <br />inch diameter pipe. When Cotter discovered this flow, it took a sample and stopped the flow by <br />elevating the pipe. While the Division Response at page 2 states that John Hamrick initially told <br />Tony Waldron of the Division of Reclamation, Mining and Safety ("Division") that Mr. Hamrick <br />estimated the water flow to be about 10-gpm, Mr. Hamrick actually said that the water flow was <br />estimated to be below 10-gpm. At the time he spoke to Mr. Waldron, Mr. Hamrick did not recall <br />the estimated flow number calculated at the time of discovery, but did recall that the flow was <br />below 10-gpm. When he checked the estimated flow number; which was 1.95-gpm, he <br />communicated that information to the Division. <br />Cotter is still conducting an evaluation of whether the mine pool is the source of water in <br />the pipe. The analytical results of molybdenum and radium from the pipe flow are inconsistent <br />with concentrations from the mine pool. Id. at 3. The molybdenum concentrations in the pipe <br />flow are 18 percent of the concentration in the mine pool, and the radium concentrations in the <br />pipe flow are 0.6 percent of the concentration in the mine pool. Id. While uranium results are <br />somewhat more consistent with concentrations from the mine pool, there are still differences, <br />4 <br />#1493118 A den
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