2010-11-17_GENERAL DOCUMENTS - M2001090

• Permit No: M2001090
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 11/17/2010
• Doc Name: Comments
• From: Colorado Department of Public Health and Environment
• To: Routt County Planning Department
• Email Name: DMC
• Media Type: D
• Archive: No

>-..-? • 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.
Denver, Colorado 80246-1530
Phone [phone]
TDD Line [phone] ,
Located in Glendale, Colorado
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
[phone]
http://www.cdphe.state.co.us
November 12, 2010
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Colorado Department
of Public Health
and Environment
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Rebecca Bussey, AICP
Routt County Planning Department
PO Box 773749 --- --_- _-, ---- -- _
136 6th Street
Steamboat Springs, CO 80477
Re: Use of multiple sources of clean soil as backfill material at a former mine site
Dear Ms. Bessey,
Per your October 13th, 2010 request, The Hazardous Materials and Waste Management Division of the
Colorado Department of Public Health and Environment (the "Division".) has reviewed the Steamboat
Sand and Gravel Mine (SSGM) Special Use Permit (SUP) to determine the Division's regulatory
authority over future mine reclamation activities. The SUP was drafted on behalf of Alpine Aggregates,
LLC ("the contractor").
Alpine Aggregates, LLC is seeking approval to continue gravel mining operations at the Steamboat
Sand and Gravel Mine, formerly the River Valley Resource gravel mine, in Routt County, Colorado.
The contractor seeks to commence reclamation efforts of an existing onsite gravel mine pit using onsite
mining waste and imported offsite inert material. The Division was contacted by Routt County due to
citizen concern over the use of "inert fill" as described in the SUP.
On October 18, 2010, the Division received a copy of the Steamboat Sand and Gravel Mine (SSGM)
SUP application via email. The Reclamation Plan, as described in Section V. of the SUP, includes
backfilling the mined areas with "inert fill." The Regulations Pertaining to Solid Waste Sites and
Facilities, 6 CCR 1007-2, Part I (the regulations) defines inert material as, "`Inert material' means non-
watersoluble and non-putrescible solids together with such minor amounts and types of other materials
as will not significantly affect the inert nature of such solids. The term includes, but is not limited to,
earth, sand, gravel rock, concrete which has been in a hardened state for at least sixty days, masonry,
asphalt paving fragments, and other inert solids."
Placing concrete, asphalt fragments, and. other types; of construction materials in a mine pit for final
disposal requires a Certificate of Designation (CD). However, Alpine Aggregates,, LLC (the contractor),
does not need to obtain a CD if they import clean soils for reclamation. This is strictly the Division's