2010-07-30_GENERAL DOCUMENTS - M1989120

• Permit No: M1989120
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 7/30/2010
• Doc Name: Comments
• From: CDPHE
• To: Broda's Inert Fill & DRMS
• Permit Index Doc Type: Gen. Correspondence
• Email Name: JLE
• Media Type: D
• Archive: No

44- / 9 99 1 120
STATE OF COLORADO
Bill Ritter, Jr., Governor
Martha E. Rudolph, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S. Laboratory Services Division
Denver, Colorado 80246-1530 8100 Lowry Blvd.
Phone [phone] Denver, Colorado 80230-6928
TDD Line [phone] [phone]
Located in Glendale, Colorado w"
http://www.cdphe.state.co.us w
JUL 3 0 2010
Certified Mail No:7009 1680 0000 2094 3940 piv*wfl et KCC,Wr, an,
Return Receipt Requested Minirx3 and S tY
July 26, 2010
Mr. Patrick Broda,
Broda's Inert Fill
P.O. Box 337
Henderson, CO 80604
OF COCO
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* 1876
Colorado Department
of Public Health
and Environment
RE: Comments on Broda's Notification to Beneficially Use Inert Solid Waste Materials as Structural
Fill
Dear Mr. Broda,
The Hazardous Materials and Waste Management Division (the Division) of the Colorado Department
of Public Health and Environment appreciates the opportunity to review Broda's Inert Fill (Broda's)
request to beneficially use inert materials as a structural fill material at the Aggregate Industries Platte
Valley Pit site (the Site) located at 1859 North Highway 85 in Brighton, CO. The proposed fill area is a
former gravel mine operated by Aggregate Industries, Inc with a mining and reclamation permit issued
by the Division of Reclamation and Mining Safety (DRMS). The Site is located within 250 linear feet
of the South Platte River channel and portions of the Site are within the 100 year floodplain.
- On June-222T20-10 the -Divi-sion-received-Broda's Recycling-and-Reuse ofNlaterials-aa-id--and-In-ert-
Filling Notification (the Notification) for the proposed structural fill at the Platte Valley Pit site. The fill
area is approximately 30 acres in size and is filled with groundwater. Groundwater appears to be
directly connected to the South Platte River alluvium and is approximately five (5') below ground
surface. Section 5.9, Section 7 and Appendix 6 of the Notification describe the placement of inert
materials into the mined area as part of the reclamation activities permitted by DRMS. Broda's
Notification states that compaction will occur from trucking and heavy equipment activities, surcharge
loading, and ultimately dynamic compaction, if necessary. Also, the concrete will be placed in water,
and there is no size reduction plan for concrete or other large materials in the fill area. Calculations of
the amount of weight, and depth of materials needed for surcharge loading were not included in the
Notification. The Notification does not include detailed material or placement specification, the
ultimate load bearing capacity of the soil or proposed future use. In addition, it does not include
frequency and method of measurement for the moisture, density, compaction or hydraulic conductivity
of the placed and compacted materials.