2012-10-03_ENFORCEMENT - M1982131

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BUCKLEN EQUIPMENT COMPANY I AGENDA Proposed Alternatives Preferred Alternative: Northern Pre -1981 Mined Area • This location is the preferred location, the ground is already above the water table, so concerns about non -inert material below the water table are less. • There is room next to the mined area to sort the material. • The US Army Corps should be contacted regarding repairing the bank in this location to determine any concerns from their standpoint. Second Alternative: Western Pre -1981 Mined Area • This would be a secondary alternative, sand or inert material could be placed in the pit to bring it above ground water level and the material removed from the pit sorted and placed no less than 1 -ft above ground water. Third Alternative: Remove from Site • This is not an economically feasible alternative. • A portion of the material can and most likely will be hauled to an off-site approved landfill, but the vast majority of the material should remain on -site. Other Alternatives: • The wood can be ground and sold as mulch, the Equipment Company would need to obtain a recycling license from the CDPHE, this is a relatively minor permit to obtain. Regulatory Agency Input • CDPHE: ■ Material placed on -site would need to meet the Weld County specification for backfill material, typical specifications usually allow for 5% organics, it is assumed that the Weld County specifications are similar. • Material should be processed for placement, concrete should be broken up into pieces meeting County specifications, exposed rebar should be removed and properly disposed of (at an approved landfill or recycling site). • Material placed below the groundwater table should only be concrete and soil. Asphalt can only be placed no less than 3 -ft above the groundwater table. • In order to obtain a Beneficial Use Permit a material screening plan should be in place, this would require statement from anyone bringing material in that it is from a clean site. Heavy Materials testing may be required for material already on site, any material that may be polluted should be disposed of at an approved facility, material passing the tests could be placed according to Weld County backfill requirements. • Recycling can't have a negative impact on groundwater. • A geotechnical engineer should provide a statement on the suitable placement of material from the pit. • Weld County: ■ No USR permits are currently in place for the portions of the site where material may be placed • A pre - application form should be submitted to Weld County to begin the permitting process and to determine what permits are required for the County. • The County will review the final plans and will refer the back to CDPHE if they feel that their input is required. Otherwise the statements in this meeting will be taken into consideration. Regulatory Agency Meeting October 3, 2012