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2011-02-09_ENFORCEMENT - M1977300
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2011-02-09_ENFORCEMENT - M1977300
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Entry Properties
Last modified
8/24/2016 4:30:54 PM
Creation date
2/15/2011 7:55:34 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
2/9/2011
Doc Name
Opening Brief of Plaintiff Cotter Corporation
From
Cotter Corporation
To
District Court
Email Name
DB2
AJW
DAB
Media Type
D
Archive
No
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Ralston Creek and Reservoir. The benefits expected to result from dewatering the mine <br />outweigh the Operator's potential costs of carrying out the corrective action. AR:00851. <br />As the Board itself admitted in its Order, the Act requires that "the economic costs of <br />reclamation measures implemented will `bear a reasonable relationship to the [environmental] <br />benefits derived from such measures.' § 34-32-102(2), C.R.S.... The Board also considers the <br />economic reasonableness of the recommended action." Order ¶ 35, AR:00851. However, the <br />Board issued its Order without having substantial evidence in the record on the costs of <br />Corrective Action No. 2, and, as a result, the Order is contrary to law, arbitrary and capricious <br />and without substantial record support. The parts of the Order addressing the mine pool and <br />Corrective Action No. 2 therefore must be vacated, and their enforcement restrained. <br />1. Absence of Evidence of the Costs of the Mine Water Treatment Facility <br />These costs include the (a) design, (b) engineering, and (c) construction of a Mine water <br />treatment facility. They also include the capital costs of the highly-specialized treatment <br />equipment necessary to treat both uranium and the other constituents in the Mine water and a <br />new building for the treatment facility. Moreover, they include the need for a buried pipeline <br />inserted on the steep hillside leading to the water treatment plant. AR:00268. Further, the record <br />contains no evidence about the costs of constructing a large evaporative pond essential to <br />Corrective Action No. 2, nor does it contain evidence of the costs for either acquiring or <br />constructing a sufficiently large flat area (acres) for the location of the evaporation pond. <br />Nowhere in the record are any of these costs provided. <br />2. Absence of Evidence of the Costs for Subsurface Safe Access to the Mine <br />Both the Steve and the Pierce adits have been sealed with highly-engineered bulkheads to <br />ensure that no Mine water exits through those former access routes. If the Board intended for <br />15
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