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2011-02-09_ENFORCEMENT - M1977300
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2011-02-09_ENFORCEMENT - M1977300
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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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to the BP blow-out in the Gulf Coast in 2010. AR:00487; 01007:12-20. Even then, the Division <br />provided neither the costs of the drilling efforts (and truly incredible challenges) to staunch the <br />flow of oil from the BP blow-out nor any information at all about the costs of such difficult <br />drilling for Corrective Action No. 2.8 <br />Again, the record contains no evidence about the costs of any of these activities. <br />4. Absence of Evidence of the Costs of Pumps and Piping <br />The record contains no information about these costs. <br />5. Operation and Maintenance for Mine Dewatering and Treatment <br />The record contains no information for the maintenance costs of Corrective Action No. 2. <br />The record does not contain any information about either annual costs or the number of years <br />that Corrective Action No. 2 would, if constructed, need to be maintained. Without knowing <br />either the annual maintenance costs nor the number of years that the system would be operating, <br />neither the Division nor the Board had the required information from which to calculate a net <br />present value for maintenance. The record contains no evidence at all on maintenance costs. <br />As to operating costs, the only information in the record is the following statement by the <br />Division: <br />We've heard the operator say it would be 5 million a year. We've heard them say <br />millions a year, and that's just pumping and treating. There would be - we <br />recognized there's refurbishing the mine, making it accessible, and installation of <br />ventilation, that's another cost. <br />8 The Division did not provide any information on whether any of the examples it used <br />were done in conditions even vaguely similar to those that would be encountered at the closed, <br />inactive and deteriorated Mine. <br />19
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