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On May 19, 2010, the Division wrote Cotter a letter, which was an "adequacy review" <br />("Adequacy Review") of the draft EPP submitted by Cotter on April 19, 2010. AR:00346-52. <br />The Adequacy Review contained the same language distinguishing between the two Mine- <br />related events that "appear to have led to significantly increased uranium levels in the receiving <br />stream" and the "the underground mine pool [that] may also be a contributing factor." AR:00346 <br />(emphasis added). In several places, the Adequacy Review indicated that further analysis needed <br />to be conducted to determine whether the mine pool was contributing to adverse impacts in <br />Ralston Creeks <br />On May 21, 2010, the Division Director, Loretta Pineda, issued a "Notice of a Reason to <br />Believe a Violation Exists at the Schwartzwalder Mine" ("RTB Notice") to Cotter resulting from <br />the Inspection and Adequacy Review. AR:00370-71. <br />On June 1, 2010, Cotter submitted (and the Division subsequently approved) a TR <br />request (TR-12) providing information for Division approval of Cotter's planned implementation <br />of Corrective Action No. 1. AR:00375; 00870:1-4; 00420; 00864:14-19. Corrective Action <br />No. 1 involved collecting groundwater at Sump No. 1, piping it through underground piping to a <br />new ion exchange water treatment facility in the existing water treatment building, and <br />discharging the treated water through underground piping from an engineered outfall on Ralston <br />5 See AR:00347 (the list of issues related to the flooded mine workings should include <br />"the possibility of potential ground water pathways in structural conduits such as the Schwartz <br />Trend and perhaps the West Rogers Fault" (emphasis added)); 00348 ("Please provide an <br />evaluation of possible seepage from the mine pool to the alluvium" (emphasis added)); 00348 <br />("This issue [of whether the mine pool is not contributing loading to Ralston Creek at this <br />location] requires further analysis to more thoroughly assess any connection between the mine <br />pool, the regional groundwater gradient and possible hydraulic communication along the <br />Schwartz Trend"); and 00351 ("Operator [Cotter] must include long-term plans in the EPP to <br />respond to the possibility of mine pool migration." (emphasis added)). <br />10