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access to be through those routes, then the record had to contain the costs for the destruction of <br />the bulkheads. However, the record contains not a single reference to the cost of such demolition <br />and removal. <br />The only presently open access route into the Mine is the Sunshine adit, which was <br />historically used as a ventilation shaft and was not designed to allow access of people or <br />equipment. AR:00267; 00961:2-9. The Sunshine adit is a steeply sloping (>45°) adit and <br />earthen/rock ramp that leads from the hillside well above the valley floor down 150 to 200 feet to <br />the Steve Level. AR:00993:10-14. Heavy equipment, including a pump and discharge pipe <br />segments, would have to be carried down the Sunshine adit. AR:00268; 00961:9-24. <br />Hazards presented by the Sunshine adit include uneven surfaces, unstable footing, and <br />sudden drop-offs. AR:00271. At the bottom of the slope, all equipment and personnel would <br />have to pass through a small structural orifice (a metal framed hatch of perhaps 3 x 4 ft) designed <br />to control mine ventilation flows. Id. Finally, several hundred feet of curving narrow shafts <br />would have to be traversed to reach the mine pool collar at the former hoist station on the Steve <br />Level. Id. In addition to these challenges, a system would have to be designed and constructed <br />to hold the weight of (and lower) a pump, motor, discharge pipe, and electrical wire. AR:00268. <br />The record contains no evidence that the shaft has remained (or will remain) open to that depth. <br />Id. <br />Significant repairs and refurbishment of the Mine would have to be performed, including <br />installation of timber sets, roof bolting, debris/muck removal, and other measures. AR:00271. <br />Randy Whicker, a Cotter employee who is a health physicist with 15 years of experience in <br />radiation protection, AR:00990:11-14, testified that conditions in the Mine were unsafe to move <br />16