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2011-06-14_ENFORCEMENT - M1977300
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2011-06-14_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:34:28 PM
Creation date
8/10/2011 2:35:47 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
6/14/2011
Doc Name
Opening Brief of Plaintiff Cotter Corporation (N.S.L.)
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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MR. PAULIN: For the board, I thought we decided — I thought <br />that we made it clear or I intended to make it clear, you know, that <br />Cotter's interpretation that it had to be down below the 500 foot <br />level below the Steve Level, you know, by the 3 1St And that <br />was — in all of our discussion and in our decision, that was never — <br />You know, the implementation, you know, must be started. <br />AR:0257:24- 00258:7. Then, Board Member Kraeger -Rovey (who signed the August 2010 <br />Order) explained that the August 2010 Order really meant that Cotter could "just do anything" <br />by August 31, 2010: <br />MS. KRAEGER - ROVEY: Well, I signed the board order, and I <br />read these things very carefully before I do, and I looked at the <br />wording, and it says "reinitiate," and if you had just done anything <br />like gone to get a permit from the health department, you know, or <br />any little thing, there are lots of first steps that could have been <br />taken. <br />AR:0259:25- 00260:6 (emphasis added). <br />In summary, based on the Division's and Board's own words, the conduct required by <br />Cotter to comply with the August 2010 Order ranged anywhere from completely "dewater[ing] <br />the mine down to the 500 foot level below the Steve Level" to "just do[ing] anything" — "any <br />little thing " — by August 31, 2010.' This hardly rises to the level of clarity and precision <br />6 If " j ust do[ing] anything" constituted compliance, Cotter did comply. Cotter's <br />representative, John Hamrick, testified at the Hearing that Cotter had conducted stratified <br />sampling of the mine pool, which is the first step necessary before any treatment system could be <br />installed to treat mine water. AR:0263:12- 0264:2. Cotter took that step before August 31, 2010. <br />AR:0264:4 -7. <br />Dur the Hearing, Mr. Hamrick also testified to the additional remediation that Cotter <br />had taken that was not required by Corrective Action No. 1 of the August 2010 Order. AR:0244- <br />50; 0142 -52. The additional remediation included a treatment system and a collection system for <br />Corrective Action No. 1 that was larger than the system required by the Board Order, and an <br />expanded monitoring system to better understand cause and effect. AR:0246:6 -12, 0246:19- <br />0248:21. Had Cotter implemented Corrective Action No. 1 as described in the August 2010 <br />Order, it would have treated only 2.4 million gallons of water and removed only 100 pounds of <br />23 <br />
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