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data also showed compliance with stream standards. AR:00974:4-8; 00531-00536; 00930:23-25; <br />00501. <br />The Mine had never been in violation of the Act before the determinations in the Order. <br />AR:00417. Cotter was in the process of working with the Division to select a remedy for the site <br />through the EPP process and of reclaiming the site. AR:00337; 00390. The EPP draft had <br />selected two long-term mitigation options to be carried forward to engineering studies, feasibility <br />evaluations, and potentially design and construction: an engineered wetland and a permeable <br />reactive barrier (funnel and gate) system. AR:00227. Cotter was engaged in remedial activities <br />toward ending the radioactive materials license issued by CDPHE Hazardous Materials and <br />Waste Management Division, Radiation Control Program. AR:00337. Cotter had plans for <br />significant additional reclamation in 2010. AR:00978:18-00979:3; 00542. These activities <br />included removal of concrete ponds and excavation of 5,000 cubic yards of contaminated alluvial <br />fill, but all these planned activities came to a halt with the start of the enforcement action. <br />AR:00965:3-25; 00530; 00978:18-00980:3. <br />Enforcement and Corrective Actions <br />The Division conducted an inspection of the Mine on May 18, 2010. AR:00336. An <br />inspection report, dated May 20, 2010 ("Inspection Report"), stated that "[t]wo [M]ine-related <br />events appear to have directly led to significantly increased levels [of uranium] in the receiving <br />stream. These events are the cessation of water treatment ... and the cessation of water <br />recirculation from Sump No. 1. AR:00337. These two events were distinguished from the <br />underground mine pool, which the Division stated "might also be a contributing factor." <br />AR:00337 (emphasis added); see AR:00408-09. <br />9