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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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AR:01019:5-11. A Division employee repeating a purported estimate made by an unidentified <br />employee of Cotter, especially without any information on the basis for that estimate, hardly <br />constitutes substantial evidence on operational costs, and without the number of years of <br />operation and a discount rate from which to calculate the present value of the operating costs, the <br />record contains no substantial evidence of these costs. <br />6. Absence of Evidence of the Costs of Financial Assurance for Corrective <br />Action No. 2 <br />The record contains no information on these costs. <br />Without substantial (indeed without any) evidence in the record of the costs of Corrective <br />Action No. 2, the Board's findings in paragraphs 32, 33, and 36 have no basis, cannot stand, and <br />must be set aside. Without having performed its required economic evaluation, the Board lacks <br />authority to have ordered Cotter to implement Corrective Action No. 2 and thus that corrective <br />action must be set aside and enforcement should be restrained. <br />B. No Substantial Evidence Exists in the Record of Any Costs That Denver <br />Water or Arvada Are Incurring Resulting from Uranium in Ralston Creek <br />or Reservoir, Any Costs That Either Entity Will Incur If Uranium <br />Concentrations in the Reservoir Increase, or Any Costs for Treating the <br />Creek and Reservoir. <br />The Order makes the following statements without substantial evidence in the record to <br />support them: <br />32. ... Also, Denver Water and Arvada Water are currently bearing the costs <br />of treating water contaminated by Cotter. The Division considers the cost of the <br />corrective actions less than the costs of cleaning the water in Ralston Creek and <br />Reservoir. AR:00850. <br />33. ... Dewatering the mine will be expensive. However, the benefit <br />(protecting Denver and Arvada's drinking water supply) justifies the expense. <br />AR:00850. <br />20
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