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2011-05-26_ENFORCEMENT - M1977300
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2011-05-26_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:33:50 PM
Creation date
8/10/2011 2:35:59 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
5/26/2011
Doc Name
Reply 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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I. INTRODUCTION <br />This litigation' does not concern whether Cotter Corporation (N.S.L.) ( "Cotter ") should <br />undertake appropriate action to remediate those conditions from the Schwartzwalder Mine site <br />that are causing excessive uranium levels in Ralston Creek. Cotter has undertaken such actions, <br />such as collection and treatment of water reporting to Sump No. 1, and is undertaking other <br />investigation and remediation. The litigation instead is focused on whether a particular <br />corrective action ordered by the Mined Land Reclamation Board ( "Board ") in its August 11, <br />2010 Findings of Fact, Conclusions of Law and Order ( "Order ") — dewatering of the mine pool <br />to a level 500 feet below the Steve Level and treating that water above - ground ( "Corrective <br />Action No. 2" or "Mine Dewatering and Treatment ") — is unsupported by substantial evidence, <br />including whether there is a lack of substantial evidence that Corrective Action No. 2 is <br />economically reasonable, and whether there is a lack of substantial evidence to support the <br />findings in the Order. Corrective Action No. 2 will result in adverse environmental <br />consequences and will be very difficult to implement, while other practicable and effective <br />means are available to accomplish the goal of reducing uranium concentrations in Ralston Creek <br />to achieve stream standards. <br />The Defendants state incorrectly that Cotter initiated this matter on January 7, 2011 by <br />the filing of a Complaint. See Answer Brief at 7. Cotter filed the Complaint in this litigation <br />(Case Number 2010CV7609) on September 24, 2010. <br />2 The Defendants inaccurately suggest that other contaminants in Ralston Creek exceed <br />stream standard limits, particularly molybdenum. See Answer Brief at 18. In fact, there is no <br />molybdenum limit that applies to the segment of Ralston Creek adjacent to the Schwartzwalder <br />Mine Site. See 5 Colo. Code Regs. 1002 -38, Regulation 38 Numeric Standards Table, Region 3 <br />and 4, Clear Creek Basin Stream Segment 17b. While a "Table" value of 0.21 milligrams per <br />liter ( "mg /L ") for domestic water supply became effective on January 1, 2011, Regulation <br />No. 31, Table III at p.56, that value has not been applied in Segment 17b. Before applying <br />standards to specific segments, the Colorado Water Quality Control Commission takes into <br />account a variety of factors, including the availability, practicality, and technical and economic <br />feasibility of treatment techniques. Colo. Rev. Stat. § 25- 8- 204(4)(b). The Defendants are <br />1 <br />
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