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~ 4 ~' ~~ FLO00 P co ~, y Q 1. ~ Z D S O O ~ ~~ 2bet~n • io`ay Cazl B. Board of Directors Executive Committee: Cathy Reynolds o Chairman m city of Denver o a Untla Morton p Chairman Pro-Tam o City of Lakewood ° ri Chris Christensen > Secretary ~ Douglas County ° John Stone • Treasurer ~ Jefferson County ~ a Donald Hamstra i Member ;~ City of Brighton ~ 3 Members: Bruce Alexander m City of Denver e David A. Day Engineer 5 Guillermo DeHenera Atlams County o Joyce Foster m City of Denver Wayne Gaston o City of Aurora ~ Jana L. Mentlez '~ Boulder County John J. Nicholl Arapahoe County Deborah Ortega City of Denver o An Patton z Engineer Q a Mary Poe Town of Morrison ~ Dennis Reynolds City of Littleton Michael J. Romero City of Lafayette L. SCOtt Tucker, Execul~ve Director Mount Senior Environmental Protection Specialist Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, Colorado 80203 ~ III IIIIIIIIIIIIIIII 999 RECEIVED JUL 31 1995 July 28, 1995Division Di lwlrlerais a uBDiDy~; Subject: Ready Mixed Concrete Company, Bromley Ickes Pit, Permit No. M-87-049 Amendment Application AM-001 Dear Mr. Mount: Thank you for the notice concerning the above permit amendment and an opportunity to review the proposal. A the mining amendment request has been labeled by the applicants as a "minor revision". However, the fact that it adds over 20 acres to the already permitted site begs the question of what is considered minor? Also, the fact that the applicant has procceded with "dry mining" of the Bromley Ickes pit instead of following the approved "wet mining" process has to be of concern to the local governments, surrounding property owners and to the entire mining permit process of the State. At this time we have concerns with the increased mining area and its potential effects on the river berm stabilization measures imposed by the original permit application (ones that we tentatively concurred with, however never did finalize the exact details during the original permitting process). Also, the shift to a dry mining method may have significant impacts on the surrounding area's groundwater resources including the groundwater that will flow from South Platte River into the pit. This groundwater flow from the river to the pit also has potential to further destabilize the riverside berm separating the pit and the mine during the mining operation phase. We suggest that you further investigate all of these above stated concerns before approving this amendment. We continue to have concerns about the size of the berm between the South Platte River and the pit, and the type of berm protection facilities that were provided for in the original application and permit. Also, it appears that the ongoing mining operation has placed piles of over-burden materials in the fl wa of the South Platte River. This is a violation of the flood plain regulation of the Urban Drainage Flood Control District and the floodplain ordinance of City of Brighton. As a result, the City of Brighton may be at risk of not complying with its agreement with the Federal Emergency Management Agency to manage floodplains, which can put it at risk of being dropped from the flood insurance program by that agency.