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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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116(7)(h) is to protect against damage associated with slides. Since the Order's discussion of the <br />mine pool and subsection 116(7)(h) has nothing to do with slides, no basis exists to find that the <br />mine pool supports a violation of subsection 116(7)(h). In fact, under these principles, no basis <br />exists to find any violation of subsection I I6(7)(h). <br />But even if subsection 116(7)(h) is sufficiently broad to cover damage unassociated with <br />slides, which it is not, the Board has not shown that the mine pool supports a violation of that <br />subsection. As explained above, the record before the Board does not establish that the mine <br />pool has increased uranium levels in Ralston Creek to any degree, and certainly not significantly. <br />Under these circumstances, a violation of subsection I I6(7)(h) based on a finding that the mine <br />pool has "significantly increased the uranium levels in Ralston Creek" is unsupported by <br />substantial evidence and should be set aside. <br />D. The Board Lacks Statutory Authority To Order Mine Dewatering and <br />Treatment Under These Circumstances. <br />As shown above, the record is without substantial evidence that the mine pool supports a <br />violation of the three statutes enumerated on page 9 of the Order - Colo. Rev. Stat. §§ 34-32- <br />116(7)(c), -116(7)(g), and -116(7)(h). See AR:00853. Under these circumstances, the Board <br />lacked statutory authority to order Mine Dewatering and Treatment. <br />In ordering Mine Dewatering and Treatment, the Board relied on the authority granted by <br />Colo. Rev. Stat. § 34-32-124. See Order ¶ 34, AR:00851. Subsection 2(a) of that statute <br />authorizes the Board to order corrective action to address specific violations at a site: "If the <br />board determines that there exists any violation of any provisions of this article ... the board <br />may issue a cease-and-desist order. Such order shall set forth the provisions alleged to be <br />violated, the facts alleged to constitute the violation, ... and may include the nature of any <br />34
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