2011-02-03_HYDROLOGY - M1989120

• Permit No: M1989120
• IBM Index Class Name: HYDROLOGY
• Doc Date: 2/3/2011
• Doc Name: Filling of Inert Materials
• From: CDPHE
• To: Broda's Inert Fill
• Permit Index Doc Type: Hydrology Report
• Email Name: JLE
• Media Type: D
• Archive: No

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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
x
http://www.cdphe.state.CO.US
February 1, 2011

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Colorado Department
of Public Health
and Environment
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Mr. Patrick Broda
? DBroda's Inert Fill
P.O._Box 337 _
Henderson, CO 80604
Re: Response to Molen & Associates, LLC's December 21, 2010 Letter Pertaining to Fillingof InertMaterials at
_
Aggregate Industries Platte Valley Operations
Dear Mr. Broda,
The Hazardous Materials Waste Management Division ("the Division") of the Colorado Department of Public
Health and Environment appreciates your December 21, 2010 response letter addressing the Division's concerns
regarding the submitted Recycling and Reuse of Materials and Land Inert:Filling Notification ("the Notification").
The Division still has one remaining concern regarding the Notification and subsequent response that shall be
addressed before the Division may grant a final approval for the landfilling of inert materials as a recycling
facility as defined by the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part 1 ("the
Regulations").
The Division concluded that the material screening plan for the Platte Valley Pit Site ("the Site") is incomplete at
this time. The Notification shall be updated to include a questionnaire and/or manifest for unknown sources of
material that will be signed by the driver of the delivery vehicles. The manifest shall verify the source location of
the material delivered to the site and that the material is free of potentially hazardous wastes. Additionally, all
supporting documentation shall be kept onsite for three (3) years after placement and saved for three (3) years
following completion of the site.
The Division finds that the inert materials delivered to the site for reuse will resemble mining overburden allowed
for placement under the Division of Reclamation Mining and Safety ("DRMS") permit. The environmental
impact of using the imported asphalt fragments, hardened concrete and directional drilling fluids will be relatively
similar those of using mining overburden as backfill as long as proper screening takes place, and as long as
asphalt fragments and directional drilling fluids are kept above the seasonally high water level. Also, the property
is in the flood plain which will limit the future uses of the property. Therefore, the structural standards for"
material placement are limited to the prevention of settlement and to the prevention of damming to allow for the
flow of groundwater.
The determination that the Site is a recycling facility is dependent upon the contractors (`Broda's") ability to
ensure the materials entering the fill area will not have a negative impact on groundwater. The Platte Valley Pit
site will, by definition of the Regulations, be a solid waste disposal site and facility if contamination is detected
through groundwater monitoring. Therefore, the above concern must be addressed prior to the Division's final
approval of the Platte Valley Pit as a recycling operation.