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worsen water quality in the mine pool, and that the costs of the proposed scheme would be <br />unreasonable relative to the contemplated benefits (assuming such benefits even manifested). <br />25. On June 25, 2010, Cotter sent a letter to the Division with an attached expert <br />report prepared by Susan A. Wyman, P.E., P.G., of Whetstone Associates, entitled Rationale for <br />Not Conducting Mine Dewatering and Mine Water Treatment at the Schwartzwalder Mine <br />("Wyman Report"). The Wyman Report set forth in detail the reasons that dewatering the Mine <br />is not an appropriate solution. These included that (a) the sump system together with the planned <br />treatment system that Cotter had already agreed to install would be adequate for capturing any <br />minor amounts of water from the mine pool that might exit the Mine; (b) water quality studies <br />had established that the mine pool was most likely not the source of uranium in Ralston Creek; <br />(c) pumping water out of the mine pool would introduce oxygen to the Mine which would <br />mobilize the uranium in the mine pool that had been settling out of the water since the mine pool <br />was allowed to fill, actually increasing contamination levels in the mine pool; (d) mine flooding <br />is a recognized remedial strategy for stabilizing ground water chemistry; (e) dewatering the Mine <br />is highly problematic in light of the Mine's present sealed condition which would constrain both <br />drilling operations and the installation of other equipment necessary to accomplish the demanded <br />decrease in the level of the mine pool; (f) the bulkheads previously installed pursuant to the <br />Division's approval are adequate to contain water inside the Mine; (g) any historical coreholes <br />through the valley floor are likely sealed and would only slightly increase the permeability of the <br />surrounding rock which generally has very low permeability; and (h) commencing dewatering <br />operations would obscure the efficacy of Corrective Action No. 1. <br />26. In mid-June 2010, Cotter worked with a water treatment system provider to install <br />a temporary water treatment system 28 days before the deadline of July 31, 2010 in Corrective <br />Action No. 1. On June 26, 2010, Cotter sent a letter to the Division submitting Technical <br />Revision 13 to the Permit. The letter set forth Cotter's plans for the temporary system for <br />treating water reporting to Sump No. 1, effective July 3, 2010. This temporary system was <br />designed to start treating ground water in the alluvium and fill while Cotter undertook the permit <br />process and worked with the water treatment provider to install the larger water treatment system <br />to comply with the requirements of Corrective Action No. 1. <br />27. On June 28, 2010, Cotter sent a letter to the Division addressing comments dated <br />June 15, 2010 that the Division had provided on Technical Revision 12. The letter expressly <br />incorporated by reference the Wyman Report. In addition, it described the intensive monitoring <br />of Ralston Creek and ground water monitor wells that would be implemented. <br />28. On July 1, 2010, Cotter sent another letter to the Division. Attached to the letter <br />were copies of Susan Wyman's curriculum vitae, the June 26, 2010 and June 28, 2010 letters <br />from Cotter to the Division, and the United States Bureau of Land Management's description of <br />the remediation process used for the Dinero Tunnel (located in Colorado), which included the <br />construction of a bulkhead to seal the tunnel and allowing it to fill up with water, thereby <br />stabilizing the surrounding ground water chemistry. <br />6