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Home My WebLink About20103212.tiff • STATE OF COLORADO Bill Ritter,Jr.,Governor Martha E.Rudolph, Executive Director �F'°F cerpo Dedicated to protecting and improving the health and environment of the people of Colorado H��o 4300 Cherry Creek Dr.S. Laboratory Services Division * i� Denver,Colorado 80246-1530 8100 Lowry Blvd. �' ' _�* r. Phone(303)692-2000 Denver,Colorado 80230-6928 '�87s TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado P of Public Health http://www.cdphe.state.co.us and Environment Certified Mail No:7009 1680 0000 2094 3940 Return Receipt Requested RECEIVED July 26, 2010 JUL 21,9 2010 Mr. Patrick Broda, ENVIRONMENTAL HEgLTH Broda's Inert Fill SERVICES P.O. Box 337 Henderson, CO 80604 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 22, 2010 the Division received Broda's Recycling and Reuse of Materials and Land Inert 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. aolD- 3<))1a Structural fills involve placing structurally competent material in a fill area, moisture conditioning the fill material, and providing compaction. A schedule for testing for moisture and density to assess and document the efforts must also be included in the Notifications. Contractors should have a soils report dictating testing frequencies, placement methods, and acceptable practices. Also, there are gradation or size requirements limiting aggregate size that are prescribed in a soils report. Backfill methods described in Sections 5.9 and 7 of the Notification are similar to placement of waste materials in a landfill and are not acceptable as structural fills placement criteria. These methods do not provide geotechnical quality control during the filling operations and the site would be a partially filled inert landfill if the operations ceased at any point prior to completion. Base on the Division's review, it appears that the Notification to beneficially use inert solid waste does not meet the requirements established in Section 8.1(A) or(E) of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2 Part 1. The Division recommends the following practices, at a minimum, to meet the requirements of beneficially using inert material at Broda's Inert Fill as structural fill material: : • Remove water from the pit, and create a solid surface to place fill prior to fill placement, • Provide verifications and documentation that the soils/concrete do not contain constituent concentrations in excess of the Colorado Soil Evaluation Values for residential and groundwater protection, whichever is lowest; • Provide maximum uncompacted lift thickness; • Provide geotechnical moisture and density quality control monitoring during fill placement; • Provide a soils report and grading plan prepared by a licensed engineer; • Ensure that aggregate is sized to no more than 6"in diameter; and • Provide proper moisture conditioning to inert material during backfill. Broda may update the Notification with a complete geotechnical soils engineering plan describing future backfill and testing methods, or Broda may seek a Certificate of Designation to operate a solid waste site with the local governing authority. Please contact me at 303-692-3425 if you have any questions regarding this correspondence Sincerely, David Snapp Charles G. Jo so , nit Leader Environmental Protection Specialist Solid Waste and Material Management Unit Solid Waste and Materials Management Unit Solid and Hazardous Waste Program CC: Troy Swain, Weld County Jared Ebert, DRMS Mark Molen,Molen &Associates, LLC SW/WLD/PVP 7.1 MOLEN & ASSOCIATES, LLC ENVIRONMENTAL CONSULTANTS 2090 E. 104th Ave., Suite 202 • Thornton, Colorado 80233 Office 303-450-1600 ♦ Fax 303-452-4515 June 21, 2010 Mr. David Snapp Solid Waste and Material Management Unit Solid and Hazardous Waste Program 4300 Cherry Creek Drive South Denver, CO 80246 Mr. Tom Parko Weld County Planning 1555 N 17th Ave Greeley, CO 80631 Re: Recycling and Reuse of Materials and Land — Inert Filling Notification Plan Broda-AI Platte Valley Site, 1859 North Highway 85, Brighton, Colorado Dear Gentlemen: Enclosed with this letter are copies of the Recycling Operations Plan for the Broda Inert Fill on Aggregate Industries — Platte Valley Sand and Gravel (AI-PVSG) mine site. The plans are submitted to comply with the Colorado Department of Public Health and Environment — Regulations Pertaining to Solid Waste Sites and Facilities. The submittal of the plan was agreed to in the May 11, 2010 Compliance Conference related to a Compliance Advisory dated April 20, 2010. The Recycling Plan is not to be construed to be part of a Certificate of Designation application. The CDPHE regulations do not require a Certificate of Designation for a recycling operation such as the Broda Inert Fill site. Please review the plans and reply with a notice of completeness and/or a condition of approval. We look forward to hearing from you. Contact me with any questions or concerns. Yours y'/ Mark Molen cc Patrick Broda, Broda's Inert Fill Eugene Riordan,Vranesh and Raisch, LLP Connie Davis,Aggregate Industries —WRC, Inc MOLEN & ASSOCIATES, LLC ENVIRONMENTAL CONSULTANTS 2090 E. 104th Ave., Suite 202 • Thornton, Colorado 80233 Office 303-450-1600 ♦ Fax 303-452-4515 May 7, 2010 DRAFT LETTER Mr. Charles G. Johnson Mr. Darrell Dearborn Solid Waste and Material Management Unit Solid and Hazardous Waste Program 4300 Cherry Creek Drive South Denver, CO 80246 Mr.Trevor Jiricek Mr. Tom Parko Mr. Troy Swain Weld County Planning 1555 N 17th Ave Greeley, CO 80631 Re: DRAFT Response to Compliance Advisory dated April 20, 2010 Broda-AI Platte Valley Site, 1859 North Highway 85, Brighton, Colorado Colorado Division of Reclamation Mining and Safety Permit No. M-1989-120 Weld County Use By Special Review Permit AmUSR-905 Dear Gentlemen: This letter addresses the status of the permits for filling at the Broda Inert Fill located on Aggregate Industries — Platte Valley Sand and Gravel (AI-PVSG) mine site. The property has not been and is not being used as a solid waste disposal site. To the contrary, only clean inorganic, or inert, structural fill material has been placed on the site in accordance with the two permits referenced above. This activity has been conducted to comply with the requirements of the Reclamation Plan approved for a sand and gravel mine operated on the site by Aggregate Industries-WCR, Inc. That plan was approved by the Colorado Division of Reclamation Mining and Safety (DRMS), formerly known as the Colorado Division of Minerals and Geology (DMG), and the mine operator is legally obligated to comply with the plan. We have tried for quite some time to explain the approval process received allowing for the operations at this site. We hope, once again, to make this clear. The DRMS approved the filling of the site based upon information received from Weld County, Aggregate Industries and Broda's consultant Molen & Associates, LLC. The chronology of DRMS granting the approval is as follows: DRAFT LETTER June 2005: Preliminary meeting at DRMS regarding the importation of inert materials into the Aggregate Industries Platte Valley Sand and Gravel Operations under the permit No. M-1989-120. A discussion about whether a Certificate of Designation was needed resulted in the DRMS response that it would be up to Weld County. July 6, 2005: Weld County was contacted by Molen & Associates to determine whether a CD was required for inert filling at the AI-PVSG mine. A follow up fax was sent to Cindy Etcheverry at Weld County with attachments for the reclamation plan and the map showing the area to be filled. August 1, 2005: Molen & Associates contacted Cindy Etcheverry and her response was that the reclamation plan did not say anything about the fill material. She said she would send an informal request to use alternate material to Kim Ogle for an administrative amendment to allow the filling. She would follow up with an email describing the approval. August 2, 2005: Email from Cindy Etcheverry (with copies to Kim Ogle and Donald Carroll both with Weld County) noting that "It does appear that other sources of inert materials are approved for backfilling the site in the Reclamation Plan." The email also states, "However, the resolution and Amended Special Review Permit 905 does require the facility to comply with the requirements of the Division of Mineral and Geology Mind Land Reclamation Permit 112 to conduct surface extraction of construction materials and reclamation of the site." August to, 2005: A follow up letter from Molen & Associates to Cindy Etcheverry confirming the discussions of the importation of inert materials by an outside contractor to the AI-PVSG mining operations. The letter requested that any objections to the information should be addressed immediately so that progress could be made with DRMS on getting their approvals. September 20, 2005: A letter from Connie Davis of Aggregate Industries to Cindy Etcheverry described the understanding of the requirements for allowing Patrick Broda to import inert fill materials to the AI-PVSG mining operation. The letter further states, "Mr. Molen indicates that you advised that Weld County does not need any additional permits for such filling operations, however you requested that I provide you with a copy of the notice for such activity as required under the State Division of Minerals and Geology permit. I am therefore enclosing for Weld County records a copy of the Notice of Material to be Imported for Backfill and supporting Affidavit as referenced therein, which are being submitted to the State Division of Minerals and Geology." November 7, 2005: A letter from Connie Davis of Aggregate Industries to Tom Schreiner with DRMS concerning questions raised about adequate bonding for the proposed activity and stockpiling and/or placement of materials. DRAFT LETTER Broda Response to Compliance Advisory Page 2 of 5 November 15, 2005: A letter from Tom Schreiner, DRMS to Connie Davis, AI states that, "The Division approves your request to regarding your Inert Fill Backfill Notice, per Rule 3.1.5(9), received on September 21, 2005." May 15, 2007: A letter from Connie Davis, AI to Michelle Martin, Weld County Planner, discussing the planned Broda activities. The two primary items discussed were the small shed requested by Broda, and traffic issues. An additional suggestion by Kim Ogle was that Connie meets with Char Davis, Weld County Health Department to discuss concerns regarding sanitary facilities for employees. May 31, 2007: A letter from Weld County Department of Planning Services to Connie Davis,AI stating that the shed was not a substantial change to the original application so long as the applicant adheres to the development standards of AmUSR-905. May 31, 2007: Email correspondence from Charlotte Davis to Michelle Martin both with Weld County stating that, "I have conferred with Trevor Jiricek, Director EHS, about the use of M's bathroom. It has been determined that the back filling of the mine is part of the reclamation process and the use of AI's bathroom facilities is appropriate." June 6, 2007: Letter from Connie Davis, AI to Patrick Broda providing advise about the use of the temporary shed and the use of AI's bathroom facilities by employees. Based upon the above correspondence it was clear to Aggregate Industries and Patrick Broda that the importation of inert materials to backfill the mine was permissible. There is no communication suggesting the contrary. Broda began backfilling with imported materials in 2008 and has continued. After Broda was the winning bid for the Denver Water Board contract to receive their inert materials for fill the issue about permitting came up. Based upon complaints from other bidders to the Denver Water Board contract the Colorado Department of Public Health and Environment (CDPHE) inspected the activity on February 19, 2010. With the understanding that a Certificate of Designation for a Solid Waste Site or Facility must be obtained from the local governing agency, in this case Weld County, a meeting was scheduled with the County. It is reiterated here that Weld County had been contacted numerous times in 2005 and in 2007 and had given approval for the filling activities. CDPHE provides technical review of the CD applications and that the review is requested by the County not by the applicant. Therefore, CDPHE had not received any documents for review until such time that Weld County would be submitting them. February 24, 2010: A meeting was held at the Weld County Planning office with Kim Ogle, Chris Gathman, and Troy Swain all with Weld County, and Patrick Broda, Harrison Broda, and Mark Molen for Broda's Inert Fill, and Connie Davis with Aggregate Industries. In the meeting Weld County stated that they now believed that the Broda operations at AI-PVSG mine may require a Certificate of Designation. Alternative methods of obtaining permits or approvals were discussed. The notion that DRAFT LETTER Broda Response to Compliance Advisory Page 3 of 5 Aggregate Industries would have to amend the existing permit AmUSR-905 was staunchly opposed by Aggregate Industries. Connie Davis requested that Kim Ogle obtain a legal opinion from the Weld County Attorney about whether AmUSR-905 would need to be amended for the CD process. Aggregate Industries and Broda waited for the legal opinion before moving forward. A legal opinion has not been received to date. In the meeting it was discussed that Broda would be allowed to continue filling activities during the CD process, if it were pursued. Weld County personnel did not object to the continued filling activities during the CD process. The process for obtaining a CD is at least two months and often takes up to a year before it is issued. CDPHE has 3o days to provide a completeness review and 180 days to review the CD application after it has been submitted by the County. Clearly the CD process will take some time. Aggregate Industries is opposed to amending AmUSR-905 for several reasons, the primary one being that additional conditions might be imposed during the review. The permit as issued allowed for the inert filling from off site sources and that is what is being done. The cost for a CD application is large, $20,000 for the application fee, and would have to be paid by either AI or Broda, an expense neither one wants. Broda and AI were expecting a legal opinion about amending AmUSR-905 and did not want to move forward without one. March 30, 2010: An additional meeting was held with the Tom Parko, Weld County Planning Manager concerning the Broda filling activities. The meeting was primarily information for Weld County. It was followed up by an email from Tom Parko to Greg Stutz stating that they Weld County had informed Broda and AI in the February 24, 2010 meeting that the existing USR did not cover an inert landfill. The email stated that the County was still waiting for CDPHE to provide their position on whether or not Broda's required a CD. The County also needed information in the form of answering six questions included in the email. Responses to the questions are in the letter dated April 8, 2010 from Greg Stutz to Tom Parko. Since the last correspondence Broda and AI have awaited some notice from Weld County, either a response to the April 8, 2010 letter or the legal opinion on amending AmUSR-905. Instead CDPHE conducted an additional inspection on April 9, 2010 and issued a Compliance Advisory dated April 20, 2010. There are benefits associated with the inert filling approved by Weld County and DRMS. They include filling portions of the lake to minimize evaporative losses that require water augmentation rights, and providing solid ground surface for future site development along Highway 85 near Brighton, one of the faster growing communities in Colorado. Broda's customers have a need for placing the inert fill and travel considerable distances to reach the operation. The Denver Water Board would have saved nearly one million dollars by awarding the contract to Broda. DRAFT LETTER Broda Response to Compliance Advisory Page 4 of 5 The Regulations Pertaining to Solid Waste Disposal Sites and Facilities do not provide rules specific to inert filling operations. Section 4 of the regulations is reserved for Construction Debris and Inert Material Landfill Sites and Facilities. There have been no apparent attempts to develop the regulations for Section 4. Regulations for inert materials around the country vary and many States have no inert fill regulations at all. The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) conducted the 2006 Beneficial Use Survey Report (published in 2007 and available at http://www.astswmo.org/publications_solidwaste.htm). In the ATSVVMO report it describes the growing popularity of diverting inert materials from MSW landfills to save valuable permitted space. Consider that the materials we are discussing here is earth, the dirt, sand or rock in your back yard. The materials dug up on virgin ground, or developed ground for that matter, should not be assumed to be contaminated. The Colorado Department of Highways is possibly one of the largest single entities that moves earth from one location to another and does so without a disposal permit. The same is true for the US Army Corp of Engineers projects. Several other existing inert filling operations are actually permitted under recycling regulations by providing a beneficial use. Other construction and site development contractors commonly take inert materials to their own properties for placement or possible resale. The DRMS is believed by Broda and AI to be the primary technical review agency for the filling activities because it is being done according to the DRMS approved reclamation plan. Weld County is understood to have a primary review based upon the Use by Special Review AmUSR-905 permit. The DRMS has been and continues to be responsible for regulating technical aspects of the filling activity. We are planning to meet with CDPHE to discuss the Compliance Advisory on May 11, 2010 at 3:oo at CDPHE. Please contact Patrick Broda or myself with any comments or concerns. Yours truly, Mark Molen cc Patrick Broda, Broda's Inert Fill Eugene Riordan, Vranesh and Raisch, LLP Jason King, Attorney General's Office DRAFT LETTER Broda Response to Compliance Advisory Page 5 of 5 Michelle Martin From: Laurie Exby Sent: Thursday, April 29, 2010 1:32 PM To: Michelle Martin Cc: Lauren Light Subject: Tom Davidson Tom Davidson Temporary Seasonal Permit Review LOCATION: North of and adjacent to Hwy 7 and west of and adjacent to CR 3 Adequate water for the site shall be supplied using bottled water Adequate sewage disposal shall be provided by a portable toilet. A copy of a contract with Waste Management is attached to the application. Michelle Martin From: Laurie Exby Sent: Thursday, April 29, 2010 11:19 AM To: Michelle Martin Cc: Lauren Light Subject: Tom Davidson Fireworks stand Tom Davidson Temporary Seasonal Permit Review LOCATION: North of adjacent of Hwy 60 and 60 and east of and adjacent to CR 15 Adequate water for the site shall be supplied using bottled water Adequate sewage disposal shall be provided by a portable toilet. A copy of a contract with Waste Management is attached to the application. 1 STATE OF COLORADO Bill Ritter,Jr.,Governor Martha E.Rudolph,Executive Director of•cozo /�,®Dedicated to protecting and improving the health and environment of the people of Colorado F` r ° o., 4300 Cherry Creek Dr.S. Laboratory Services Division * Denver,Colorado 80246-1530 8100 Lowry Blvd. `� Phone(303)692-2000 Denver,Colorado 80230-6928 tape TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health hllp://www.cdphe.state.co.us and Environment April 20, 2010 Mr. Patrick Broda CERTIFIED MAIL #7007 0220 0001 0162 4284 Broda's Inert Fill Return Receipt Requested P.O. Box 337 I lende son, CO 80604 RE: Compliance Advisory,Broda's Inert Fill—Platt Valley Pit — Weld County, Colorado Dear Mr. Broda: This Compliance Advisory provides notice related to information gained during inspections conducted by the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division (the "Department") on February 19, 2010 and April 09, 2010. The Department conducted these inspections in response to a complaint of alleged illegal solid waste disposal at the above location, and to determine the property's compliance status relative to the Solid Waste Disposal Sites and Facilities Act, 30-20-100.5, et seq., C.R.S.("the Act"), and the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part I ("the Regulations"). The Department advises you that the information gained during the inspection indicates that you may have violated the Act, the Regulations and the approved Closure Plan for the facility. Department personnel will further review the established facts, which may result in a revision to this Compliance Advisory to include additions or clarifications as a result of that review. Please be aware that you are responsible for complying with the Act and Regulations and that there are civil penalties for failing to do so. The issuance of this Compliance Advisory does not limit or preclude the Department from pursuing its enforcement options concerning this inspection including issuance of a Compliance Order and/or seeking an assessment of civil penalties. The Department will take into consideration your response to the requested actions listed below for each cited deficiency in its consideration of enforcement options. Deficiency 1: The owner or operator has accepted and disposed of solid waste without a Certificate of Designation,which violates Sections 102 and 113 of the Act and Sections 1 of the Regulations. Requested Action 1: The owner or operator should immediately cease accepting any and all solid waste at the above referenced location until a Certificate of Designation is obtained from Weld County. All solid waste currently placed upon the former landfill and/or stored within the boundaries of said property should be removed and properly disposed of within thirty(30) calendar days of the receipt of this letter. April 20, 2010 CERTIFIED MAIL# 7007 0220 0001 0162 4284 Mr. Patrick Broda Page Two Requested Action 2: The owner or operator should provide all receipts related to the acceptance of materials placed upon the former landfill and/or stored within the boundaries of said property to the Division for the past seven(7)years. Additionally, you are requested to provide all receipts relative to the disposal of such wastes from the subject property to a permitted solid waste disposal facility. Requested Action 3: The owner/operators shall pay to the state the appropriate Solid Waste User Fee as defined in 25-16-104.5, C.R.S. To close out this Compliance Advisory, the Department encourages you to correct the deficiencies noted in this advisory and the enclosed inspection report within thirty(30) calendar days of the receipt of this advisory, unless otherwise noted above. Please respond to the Department in writing within forty-five (45) calendar days of receipt of this letter detailing how you have corrected the deficiency noted in this advisory and the enclosed inspection report. In addition, your response shall include documentation as requested in the aforementioned action items. Please contact this office by May 7, 2010 at the number listed below to schedule a meeting to: A. Discuss the Compliance Advisory and answer any questions that you may have; B. Develop an alternative schedule for correcting the deficiency noted above; or C. Submit information necessary to show that the deficiency is not a violation of Colorado's solid waste laws. A copy of the inspection report is enclosed with this Compliance Advisory. Please contact myself at 303.692.3349 or Charles Johnson at 303.692.3348 concerning the deficiency detailed under this Compliance Advisory and/or to set a meeting to discuss this Compliance Advisory. Sincerely, Darrell Dearborn Charles G. Johnson Solid Waste and Material Management Unit Solid Waste and Material Management Unit Leader Solid and Hazardous Waste Program Solid and Hazardous Waste Program Enclosure cc: Troy Swain, Weld County Dept. of Health and Environment Weld County Commissioners Office Tony Waldren, DBMS Jason King, Attorney General's Office SW Tracking: SW/ADM/GEN 1.6 SOLID WASTE INSPECTION WORKSHEET Agency: Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division Date: April 9, 2010 Times: 9:00 AM- 10:30AM Site: Broda's Inert Fill—Platt Valley Pit Operator: Patrick Broda Brighton, Weld County, Colorado Phone No.: (303) 808-2500 Inspector: Darrell Dearborn Inspection: Unannounced Complaint investigation On April 9, 2010, an unannounced inspection was conducted at Broda's Inert Fill — Platt Valley Pit located at 1859 North State Hwy. 85, in Brighton, Weld County, Colorado, by Darrell Dearborn, an inspector with the Colorado Department of Public Health and Environment's Hazardous Materials and Waste Management Division (the "Department"). The inspection was performed to assess the facility's compliance with the Solid Waste Disposal Sites and Facilities Act, 30-20-100.5, et seq., C.R.S. (the "Act"), and the implementing Regulations, 6 C.C.R. 1007-2 (the"Regulations"). The Platt Valley Pit is located north of Highway 85 and Weld County Road 6 in Brighton, Colorado. The site consists of 30 acres permitted for gravel mining by the state Division of Minerals and Geology (Permit No. M-1989-120) and Weld County Special Review Permit (AmUSR-905). These permits are issued to Aggregate Industries — WCR, Inc. Aggregate Industries owns the property and contracted with Mr. Patrick Broda to fill the pit with inert materials. This site has no Certificate of Designation and no Design and Operations Plan for the fill operations. Upon arrival to the site, the inspector met with Mr. Broda and explained the purpose of the inspection. Mr. Broda was visibly upset due to the unannounced nature of inspection but was cooperative. Mr. Broda stated that, beginning in 2007,he has filled the site with 85-88% dirt, 12% concrete and about 7% asphalt with the assumption that the permits listed above are the only regulatory requirements. He also stated that he has allowed the disposal of liquid directional drilling fluids. Drilling fluids are not listed as an acceptable waste stream for this facility under the two permits. The site is open Monday thru Friday from 7 AM until 5 PM. The site receives waste from offsite sources and is attended by an employee of Mr. Broda, who collects a fee for material disposal. A sign at the entrance describes materials suitable for disposal at this site and the hours of operation. Mr. Broda stated he is familiar with all the companies that dump at the site, and if an unfamiliar trucking company arrives seeking disposal, their waste is screened prior to filling. The entire site is fenced and has a locking gate to provide security and prevent unauthorized dumping. At the edge of the quarry was an area for the trucks to dump. Mr. Broda explained that all of the waste is observed and screened by the equipment operator prior to pushing the materials into the quarry. Several loads of rock,concrete, dirt and asphalt materials were observed by the inspector during the inspection. Very small amounts of organic material such as tree roots and branches were observed in the surrounding fill area. A vacuum truck was also observed dumping into a pit near the entrance to the facility. Mr. Broda told the inspector that the truck was unloading directional drilling fluids. Mr. Broda stated that, in response to Weld County's concerns raised during the February 19, 2010 inspection, he changed his process from dumping these fluids directly into the quarry to dumping into a small surface pit to allow the liquids to evaporate. Mr. Broda explained that he removes the "silt" remaining in the pit after evaporation and dumps it into the quarry FINDINGS STATUS This site is not in compliance with the Act and the Regulations. Based on the observations during the inspection, it appears that the facility is in violation with the following regulatory requirements: • Deficiency 1: The owner or operator has accepted and disposed of solid waste from offsite without a Certificate of Designation in violation of sections 30-20-102 and 113, C.R.S., and 6 C.C.R. 1007-2 § 1. • Deficiency 2: The owner has accepted waste for disposal without paying the appropriate solid Waste User Fees to the Department as required by 6 CCR 1007-2 § 1.7.4,pursuant to section 25- 16-104.5, C.R.S.. The Department will issue a Compliance Advisory to Mr. Broda informing him of the potential violations and providing an opportunity to schedule a compliance conference to further discuss the matter. File: SW Tracking: SW/WLD/GEN 1.2 STUTZ, MILLER& URTZ, LLC ATTORNEYS AT LAW 1660 LINCOLN STREET,SUITE 2850 105 EDWARDS VILLAGE BLVD.,SUITE C-210 DENVER,COLORADO 80264-2800 EDWARDS,COLORADO 81632 TELEPHONE 303 8611200 TELEPHONE 870 569 3300 FAX 303 830 0115 FAX 970 569 3301 rgstutz@earthlink.net POST OFFICE Box 65oo www.stutznlillerurtz,(0111 VAIL,COLORADO 81658-6500 April 8, 2010 Mr. Tom Parko Planning Manager Weld County Planning Services 1555 North 17th Avenue Greeley, CO 80631 Re: AmUSR-9o5,Aggregate Industries-WCR, Inc.Sand &Gravel Mine; Broda's LLC Dear Tom: We have received your email of April 5, 2010 and will deal with the questions raised after a few essential points are made. We appreciate your having met with us last week and look forward to resolving the issues which have arisen as soon as possible. The first and foremost point we would like to make is that the existing operations at the Platte Valley Site, 1859 U.S. Highway 85 in Weld County,are not an inert landfill operation and they never have been. The operations constitute reclamation required by the Colorado Division Of Reclamation, Mining & Safety (DRMS; formerly DMG) of a sand and gravel mining operation. The permit issued by the DBMS requires filling of the exposed lake on the property with inert structural fill from the property and other sites. Aggregate Industries (AI) is not free to leave the lake in its present condition,but must fill it in with inert structural fill or face serious liabilities and the loss of a substantial reclamation bond. Activities to comply with the State permit requirements have been going on for more than four years. Broda's LLC,which has lease with AI,has been conducting the reclamation activities. The Denver Water Board Contract provides for the same type of structural fill and nothing else. It presents a tremendous opportunity to move the reclamation ahead, something which would benefit any number of people, including Weld County(property improvement, additional tax base) and the Denver Water Board (which may otherwise have to pay an extra $1,obo,00.00 to place its structural fill elsewhere). Equally as important, the DRMS Reclamation Plan was submitted to Weld County when application was made for the Use By Special Review referred to above. Weld County thereafter issued its permit and the property is being reclaimed in the exact manner described in all of the permits. No solid waste is being placed on the property. In fact,any solid waste is screened and removed from the property during normal operations. The required notice for import structural fill was filed with DRMS, which has regulatory authority over technical matters relative to mining and reclamation operations. We have provided a copy of that notice and DRMS' approval of the fill which is being placed on the property. Section 3.1.5 Reclamation Measures - Material Handling, DRMS Construction Mr.Tom Parko Weld County Planning April 8,2010 Page 2 Materials Rules, provides for exactly the type of inert structural fill that is being used and the rule specifically contemplates the use of off-site materials. Having made these points, we want to address your questions. However, the questions appear to be premised on the assumption that a solid waste landfill is currently being operated or would be operated if materials the Denver Water Board were placed. Nothing could be further from the truth. Question#1. What type of materials have been accepted at this inert landfill? Include the type, source,and amount of material. Answer #1. The types of materials that have been accepted at the inert fill operation are inert materials: earth, dirt, soil, sand, gravel, rock, concrete(hardened for at least 6o days)and concrete pieces,asphalt paving fragments,top soil, masonry, and day-lighting mud. A list of these materials was provided to you at the March 30, 2010 meeting along with a list of the prohibited materials. The sources and amounts of the materials vary from one project to another. A typical load of fill would be from the installation of curb and gutter by a contractor. Question #2. How does the operation ensure that materials accepted are not a source of pollutants, which can impact groundwater quality? Answer #2. There are several methods used for ensuring that the materials accepted are not sources of pollutants: 1. The contractor contacts Broda prior to delivering the materials and is asked what the type of activities generated the inert materials. 2. Depending on whether the contractor is a new customer or is familiar with Broda's operations and knows what is acceptable and unacceptable,Broda will visit the site where the materials are being generated to make sure they comply with the requirements of only inert fill material. 3. There is on-site screening of the materials as they are delivered. This on-site screening is both visual and olfactory, and the materials are observed for debris(wood and other materials)and for irregularities that could possibly indicate the presence of unacceptable materials. Question# 3. What measures were taken,if any,to ensure the material accepted by the inert landfill operation was appropriate for use in the reclamation? Answer #3. The AI Platte Valley reclamation plan allows for the filling of inert materials from other sites, as stated on page 10 of the Platte Valley Operations DMG 112 Permit Amendment Reclamation Plan, based upon the following the Rules and Regulations of The Colorado Mined Land Reclamation Board for the Extraction of Construction Materials promulgated October 1995 (also known as Rule 3). Broda has signed an Affidavit stating that only inert materials will be placed in the fill as required by Rule 3. The process was approved in a letter dated November 15, 2005 from the DRMS (formerly DMG) after responding to the Division's written questions regarding this activity. Weld County was consulted on July 6, 2005 in a fax letter to Cindy Etcheverry with a response (sent via email) dated August 2, 2005. A follow up letter was sent to Cindy Etcheverry from Molen &Associates dated August 10, 2005 confirming the understandings and requesting that any objections to the plans be made immediately. AI also sent letters to Cindy Etcheverry dated September 20,2005 and November 8, 2005 reiterating the concept that no additional permits were needed. Subsequent to communications with Weld County in 2005 and 2006,letters were sent from Connie Davis, AI to Weld County referencing the inert filling plans. A response to one AI letter was dated May 31, 2007 and signed by Michelle Martin with Weld County. Based upon all the communication with DRMS and Weld County the inert filling was deemed appropriate and there were never any questions or objections to the plans. Mr.Tom Parko Weld County Planning April 8, 2010 Page 3 Question#4. Was the accepted material screened as to source? Was there any testing of the materials? If so, provide any results you may have. Answer #4. See Answer #2 above. In addition there has been testing of the soils for the possible presence of hydrocarbon impacts and a copy of the laboratory report is attached. One water sample was also taken of the lake and the laboratory report is attached. There were no contaminants detected in the samples. Question #5. Is there any on-site treatment or on-site processing of the materials accepted? Answer #5. The day-lighting mud is being processed by placing it into a pit and allowing the mud to dry. No other on-site processing is occurring. Question #6. Once received, was the material segregated based on type or engineering properties? Are there any plans followed for the placement of the material used for the reclamation? Answer #6. There is no segregation other than the separation of the day- lighting mud. Compaction is achieved on a regular basis by traveling over the placed inert materials with loaded trucks(typical weight is 8o,000 pounds)and a Caterpillar 980 loader (weighing 75,000 pounds). The compaction is done across the entire site. Additional compaction is achieved by the presence of water which is found approximately four to eight feet below the top of the fill. We are renewing our request for a letter from Weld County to Denver Water concerning the status of the Broda-AI inert fill. The letter needs to say nothing more than that the proposed placement of inert structural fill material received from the Denver Water Board is allowed under the permit that has been issued by Weld County. This issue needs immediate attention in that reclamation will be delayed if the structural fill from the D.W.B. cannot be placed on site. The letter needs to be sent within the next few days. In the interim we would at least like you to make a phone call to Roman Hernandez at Denver Water (303) 628-6515 to tell him that you are working on the issues and should have the answer soon. That should help delay Denver Water from terminating existing contractual relationships and rebidding the inert fill project. At the February 24, 2010 meeting Kim Ogle has stated to AI that the Weld County Attorney would be providing a legal opinion about the status of the AmUSR-905 permit. We have not heard about such an opinion and would like to know if the issue has been addressed by the County Attorney. Please contact me with questions or concerns. Yours truly, R. Gregory Stutz 1e• LABORATORY, I N C. 4640 Pecos Street Unit C Denver, Colorado 80211 303.433.1 322 Phone 303.265.9645 Fax July 29, 2009 Molen & Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Attached are the analytical results for Broda's received by Origins Laboratory, Inc. 7/23/2009 5:10:00PM. Please let us know if you have any questions, or if we can help with anything at all. The analytical results in the following report were analyzed under the guidlines of EPA Methods specified in SW-846. The analytical results apply specifically to the samples and analyses specified per the attached Chain of Custody. This (",f/�- laboratory report is intended solely for the above addressee and it is only to be used and or reproduced in its entireity. Noelle E Doyle Laboratory Manager 4640 Pecos Street Unit C v Denver, Colorado 80211 , 303.433.1322 Laboratory 0I, ° .+ I a ',t.' % 303.265.9645 Fax LABORATORY. I N C. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's CROSS REFERENCE REPORT Sample ID Laboratory ID Matrix Sampled Date Received Broda's E X907079-01 Soil 7/23/2009 9:30:00AM 07/23/2009 17:10 Broda's W X907079-02 Soil 7/23/2009 9:35:00AM 07/23/2009 17:10 Origins Laboratory, Inc. "1 rt Il The results in this report apply to the samples analyzed in �Q•G . accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 2 of 7 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 - v 303.433.1322 Laboratory D' (I° , l j 5 ' ., w^ 303.265.9645 Fax R. L A B O B A T 0 B Y. INC. , Molen &Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's 11. --- A I I a L; - 25 1 a ill_ E 014 0 o 0 n. r z _ m a c_ ., V b i o z E a { 9 _ is _ a. a_ v e ...imp _, _ ` a UNIT _. a �s >,� —1 at O 4. G t7 _i F F S. 1 1, ___ ______ ` W M _____ ftw. m„,a,..5 ____cml_ ..., I r ^ C N Ii .N r L ii CIC c 0 FG2 ca tillhiiti 4✓">e ‘,9.- ,..,. .o.:, [cv , , ,.,o I I [,/IR , I ,,.,.. a I o •�,.gn I ,g. L. 0. ,a,,._. : u✓9e Origins Laboratorgy, Inc. "�p !1 � The results in this report apply to the samples analyzed in VU.uV�'... accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 3 of 7 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 v 303.433.1322 Laboratory P ICI .S 0 tl. 303.265.9645 Fax I C :n w LABORATORY. I N C. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Broda's E X907079-01 (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. TPH-Carbon Chain by EPA Method 8015M Gasoline (C6-C10) ND 50.0 mg/kg I 9C24003 07/24/2009 07/24/2009 Diesel (C10-C28) ND 50.0 Residual Range Organics (C28-C36) ND 200 " TPH - Carbon Chain Total ND 50.0 " .. Surrogate:o-Terphenyl 83.5% 65-140 ., Origins Laboratory, Inc. --it tkogi.„....„ al. results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 4 of 7 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C a Denver, Colorado 80211 303.433.1322 Laboratory ellPtrig k_ •303.265.9645 Fax [# � ' /' w� LABORATORY, INC. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Broda's W X907079-02 (Soil) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. TPH-Carbon Chain by EPA Method 8015M Gasoline (C6-C10) ND 50.0 mg/kg 1 9624003 07/24/2009 07/24/2009 Diesel (C10-C28) ND 50.0 Residual Range Organics (C28-C36) ND 200 .. .. TPH -Carbon Chain Total ND 50.0 ,. ,. .. Surrogate o-Terphenyl 85.3% 65-140 Origins Laboratory, Inc//////��' (.di!1 The results danc in this report apply f custody to tdy docu es analysed in + accordance with the chain orthe document. This analytical report must be reproduced in its entirety. Page 5 of7 Noelle E Doyle, Laboratory Manager 'Y f 4640 Pecos Street Unit C Denver, Colorado 80211 - 303.433.1322 Laboratory 0. ° t ' /f' w;" 303.265.9645 Faxlr �+ LABORATORY, INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Brodas Extractable Petroleum Hydrocarbons by 8015M - Quality Control Origins Laboratory, Inc. Reporting Spike Source %REC RPD Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes Batch 9G24003 — Default Prep GC—Semi Blank(9624003—BLK1) Prepared: 07/24/2009 Analyzed: 07/24/2009 Gasoline(C6-C10) ND 500 mg/kg ii Diesel(Cl0-C26) ND 50.0 Residual Range Organics(C28-C36) ND 200 TPH-Carbon Chain Total ND 50.0 Surrogate:o-Terpheny/ 41.7 9 50.0 83.3 65-140 LCS(9G24003-BS1) Prepared: 07/24/2009 Analyzed: 07/24/2009 Gasoline(C6-C10) 655 50.0 mg/kg 500 131 65-140 Diesel(C10-C28) 65.1 50.0 60-140 Surrogate:o-Terpheny/ 41.3 9 50.0 82.7 65-140 Matrix Spike (9624003-MS1) Source:X907071-01 Prepared: 07/24/2009 Analyzed: 07/24/2009 Gasoline(C6-CI 01 613 500 mg/kg 500 ND 123 65-130 Diesel(C10-C28) 64.0 50.0 ND 60-140 Surrogate:o-Terpheny/ 41.1 9 50.0 82.2 65-140 Matrix Spike Dup(9G24003-MSD1) Source:X907071-01 Prepared: 07/24/2009 Analyzed: 07/24/2009 Gasoline(C6-CI 0) 650 50.0 mg/kg 500 ND 130 65-130 5.93 20 Diesel(C10-C28) 65.7 50.0 ND 60-140 2.64 25 Surrogate:o-Terphenyl 41.8 g 50.0 83.7 65-140 Origins Laboratory,r Inc. !! The results danc in this report apply to the samples analyzed in t£4••(U1�4.`,(',(�VVyI[_�•-~ accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 6017 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 N 303.433.1322 Laboratory a � t 1, , '�: ♦; 303.265.9645 Fax LAB 0 B A T 0 A Y. IN C. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project. Broda's Notes and Definitions ND Analyte NOT DETECTED at or above the reporting limit RPD Relative Percent Difference Origins Laboratory, Inc. The results danc in this echai apply f to the samples analyzed in VII\Uu•,•W,t�/r�`•(',(lrylyl[_�••^ accordance with the chain custodyo( document. This analytical report must be reproduced in its entirety. Page 7 of 7 Noelle E Doyle, Laboratory Manager y. *y*, k fi INS f LABORATORY, INC. 4640 Pecos Street Unit C Denver, Colorado 80211 303.4331 322 Phone 303.265.9645 Fax August 26, 2009 Molen & Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Attached are the analytical results for Broda's received by Origins Laboratory, Inc. 8/17/2009 5:15:00PM. Please let us know if you have any questions, or if we can help with anything at all. The analytical results in the following report were analyzed under the guidlines of �1 EPA Methods specified in SW-846. The analytical results apply specifically to the ` samples and analyses specified per the attached Chain of Custody. This R�L,(,ifC///J�., laboratory report is intended solely for the above addressee and it is only to be used and or reproduced in its entireity. Noelle E Doyle Laboratory Manager 4640 Pecos Street Unit C • • f Denver, Colorado 80211 303.433.1322 Laboratory 0 b +i• 303.265.9645 Fax L A B O B A T O A T, INC. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's CROSS REFERENCE REPORT Sample ID Laboratory ID Matrix Sampled Date Received Lake East#1 X908052-01 Water 8/17/2009 11:15:00AM 08/17/2009 17:15 Lake West#1 X908052-02 Water 8/17/2009 11:45:00AM 08/1 7/2009 17:15 Origins Laboratory, Inc. /1 � The results in this report apply to the samples analyzed in (lxWiV1Ll. accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 2 of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 _ Y 303.433.1322 Laboratory ° ''" I I tt 14. 303.265.9645 Fax C' w. LABORATORY. INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project. Broda's Ii" ` M F ' o 54 - a- _- • e � = € IV. > — i a i a - . g .5 —, E z 1. m V w A = � �. a TT t ON14 IJ11 -... _.-. Er .41 w u fltm_. a.-, O It Ina V q 9 - AC 43C 2 T3 irti 141 52 0 +.4 LLII y Y'l f. � i'.f}4. � 'LI=1'F.! L 1 � "' � ,J i I!(JS r J `�^�-��i J I.` 11 1 1 • ' I•. ' .] •rA ..•r+ orvr Origins Laboratory, Inc. The results danc in this report h apply f to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 3 of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit Cw' Denver, Colorado 80211 _ s'' . 303,433.1322 Laboratory a P_ 5 . i.' 303.265.9645 Fax LABORATORY. IBC. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake East#1 X908052-01 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B 1,1,1,2-Tetrachloroethane ND 1.0 ug/L 1 9118004 08/18/2009 08/19/2009 1,1,1—Trichloroethane ND 1.0 " 1,1,2,2-Tetrachloroethane ND 1.0 " 1,1,2-Trichloroethane ND 1.0 '' 1,1-Dichloroethane ND 1.0 1,1-Dichloroethane ND 1.0 " 1,1-Dichloropropene ND 1.0 1,2,3-Trichlorobenzene ND 1.0 .. 1,2,3-Trichloropropane ND 1.0 " " 1,2,4-Trichlorobenzene ND 1.0 1,2,4-Trimethylbenzene ND 1.0 1,2-Dibromo-3-chloropropane ND 1.0 1,2-Dibromoethane (EDB) ND 1.0 1,2-Dichlorobenzene ND 1.0 " 1,2-Dichloroethane ND 1.0 1,2-Dichloropropane ND 1.0 1,3,5-Trimethylbenzene ND 1.0 " 1,3-Dichlorobenzene ND 1.0 1,3-Dichloropropane ND 1.0 " 1,4-Dichlorobenzene ND 1.0 " 1-Butanol ND 100 " Origins Laboratory, Inc ni(adjilkCE The results an in this report apply custody st tde so es tnThised in accordance with the chain pplytohe document. This analytical report must be reproduced in its entirety. Page4ofM Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 .� " . 303.433.1322 Laboratory ln _ s • /1- 303.265.9645 Fax I 0. L A B B B A T 8 R Y. INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake East#1 X908052-01 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B 2,2-Dichloropropane ND 1.0 ug/L 1 91118004 08/18/2009 08/19/2009 2-Butanone ND 5.0 2-Chloroethyl vinyl ether ND 5.0 2-Chlorotoluene ND 1.0 2-Hexanone ND 1.0 " 4-Chlorotoluene ND 1.0 " 4-Isopropyltoluene ND 1.0 4-Methyl-2-pentanone ND 5.0 " " Acetone ND 4.0 Acetonitrile ND 25.0 " Benzene ND 1.0 Bromochloromethane ND 1.0 " Bromodichloromethane ND 1.0 " Bromoform ND 1.0 Bromomethane ND 1.0 " Carbon disulfide ND 1.0 " Carbon tetrachloride ND 1.0 Chlorobenzene ND 1.0 " " Chloroethane ND 1.0 Chloroform ND 1.0 Chloromethane ND 1.0 " " Origins Laboratory, Inc. ry, j The results danc in this report apply f to the samples analysed in �,(\�l�ll(�---• accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 5 of I6 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 v . 303.433.1322 Laboratory .0 ( _ �, c . di.:,. 303.265.9645 Fax LABORATORY. I N B. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake East#1 X908052-01 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B Dibromomethane ND 1.0 ug/L 1 91-118004 08/18/2009 08/19/2009 cis-1,2-Dichloroethene ND 1.0 ., . Dichlorodifluoromethane ND 1.0 " " ,, " ., cis-1,3-Dichloropropene ND 1.0 " " . " ., Ethylbenzene ND 1.0 " .. ,, " ., Cyclohexane ND 1.0 ,. " Dibromochloromethane ND 1.0 ,, .. .. ., Hexachlorobutadiene ND 1.0 ., .. .. . lodomethane ND 1.0 .. " " " " Isopropylbenzene ND 1.0 " , " . " m,p-Xylene ND 2.0 ., ., '. Methyl Acetate ND 5.0 Methyl tert-Butyl Ether ND 1.0 ,. " ,, ,, .. Methylcyclohexane ND 1.0 .. " . .. Naphthalene ND 1.0 ,. " " .. sec-Butylbenzene ND 1.0 " ,. . ,. n-Butylbenzene ND 1.0 " n-Propylbenzene ND 1.0 .. ., . ., ,, o-Xylene ND 1.0 ., " " " " Styrene ND 1.0 .. " ., .. Tetrachloroethene ND 1.0 ,. Origins LaboratorrQy, Inc.�itzccc/////��I� The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 6 of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 _ r am 303.433.1322 Laboratory .D I? �. I ' • 'J *',.- 303.265.9645 Fax I A B 0 8 A T 0 8 Y, INC. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake East#1 X908052-01 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B Toluene ND 1.0 ug/L I 9H18004 08/18/2009 08/19/2009 trans-1,2-Dichloroethene ND 1.0 " trans-1,3-Dichloropropene ND 1.0 Trichloroethene ND 1.0 Trichlorofluoromethane ND 1.0 Vinyl acetate ND 5.0 Vinyl chloride ND 1.0 Surrogate:1,2-oichloroethane-d4 103% 76.5-123 Surrogate:4-Bromofuorobenzene 116% 75.5-133 Surrogate:Toluene-d8 982% 71.1-113 " Origins Laboratory, Inc1411Sq ce results in this report apply f to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 7 of to Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C ' t Denver, Colorado 80211 " 303.433.1322 Laboratory ] ( ' . !pis ' tt'.w 303.265.9645 Fax rt' LABORATORY. INC. Molen&Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake West#1 X908052-02 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 82606 1,1,1,2-Tetrachloroethane ND 1.0 ug/L 1 9H18004 08/18/2009 08/19/2009 1,1,1-Trichloroethane ND 1.0 1,1,2,2-Tetrachloroethane ND 1.0 1,1,2-Trichloroethane ND 1.0 1,1-Dichloroethane ND 1.0 1,1-Dichloroethene ND 1.0 1,1-Dichloropropene ND I.0 ., .. 1,2,3-Trichlorobenzene ND 1.0 .. 1,2,3-Trichloropropane ND 1.0 1,2,4-Trichlorobenzene ND 1.0 1,2,4-Trimethylbenzene ND 1.0 1,2-Dibromo-3-chloropropane ND 1.0 .. " 1,2-Dibromoethane(EDB) ND 1.0 1,2-Dichlorobenzene ND 1.0 1,2-Dichloroethane ND 1.0 1,2-Dichloropropane ND 1.0 1,3,5-Trimethylbenzene ND 1.0 1,3-Dichlorobenzene ND 1.0 1,3-Dichloropropane ND 1.0 1,4-Dichlorobenzene ND 1.0 1-Butanol ND 100 " Origins Laboratory, //////��ty, Inc �I II The results in this report apply to the samples analyzed in C.L UA y accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 8 of I6 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C • Denver, Colorado 80211 v 303.433.1322 Laboratory ( n v' ' 303.265.9645 Fax " I0 B 0 Rawl,. INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake West#1 X908052-02 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B 2,2-Dichloropropane ND 1.0 ug/L 1 91118004 08/18/2009 08/19/2009 2-Butanone ND 5.0 " . 2-Chloroethyl vinyl ether ND 5.0 " ., " 2-Chlorotoluene ND 1.0 " " 2-Hexanone ND 1.0 4-Chlorotoluene ND 1.0 4-lsopropyltoluene ND 1.0 " " . 4-Methyl-2-pentanone ND 5.0 " " Acetone ND 4.0 " .. .. Acetonitrile ND 25.0 ,, Benzene ND 1.0 " ., Bromochloromethane ND 1.0 " . Bromodichloromethane ND 1.0 " .. Bromoform ND 1.0 " Bromomethane ND 1.0 " . Carbon disulfide ND 1.0 Carbon tetrachloride ND 1.0 " ,. .. Chlorobenzene ND 1.0 Chloroethane ND 1.0 Chloroform ND I.0 " Chloromethane ND 1.0 ,, ,. Origins Laboratory,g Inc. (1 ry, The results danc in this report apply c tocustody the samples analyzed in (•W6�JL+�`.t,t`�VJt 1/4--•—, accordance with the chain orcust document. This analytical report must be reproduced in its entirety. Page 9 of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 v. eitiliem 303.433.1322 Laboratory �' [i _ " �,Lr •.',../•!.r 303.265.9645 Fax LABORATORY, I N C, Molen&Associates, LLC Mark Molen 2090 East l U4the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake West#1 X908052-02 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B Dibromomethane ND 1.0 ug/L 1 91118004 08/18/2009 08/19/2009 cis-1,2-Dichloroethene ND 1.0 " Dichlorodifluoromethane ND 1.0 " " " " cis-1,3-Dichloropropene ND 1.0 " " " Ethylbenzene ND 1.0 " " " " Cyclohexane ND 1.0 Dibromochloromethane ND 1.0 " " Hexachlorobutadiene ND 1.0 " " " lodomethane ND 1.0 " " " Isopropylbenzene ND 1.0 " " . m,p-Xylene ND 2.0 ,. „ .. .. Methyl Acetate ND 5.0 " " " . Methyl tert-Butyl Ether ND 1.0 Methylcyclohexane ND 1.0 Naphthalene ND 1.0 " " " .. sec-Butylbenzene ND 1.0 ,, n-Butylbenzene ND 1.0 ., n-Propylbenzene ND 1.0 o-Xylene ND 1.0 " " " " Styrene ND 1.0 " " " Tetrachloroethene ND 1.0 " " Origins Laboratory, Inc.c ` !! ry, 1 The results danc in this report apply f to the samples analysed in G•eW+tV/K.'.(,L\�V111[ 1/2 accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Pagel°of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C V Denver, Colorado 80211 �yL 303.433.1322 Laboratory 0 ICI .s ,...c. 14: 303.265.9645 Fax LABORATORY. INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Lake West#1 X908052-02 (Water) Reporting Analyte Result Limit Units Dilution Batch Prepared Analyzed Notes Origins Laboratory, Inc. VOC by EPA 8260B Toluene ND 1.0 ug/L I 9H18004 08/18/2009 08/19/2009 trans-1,2-Dichloroethene ND 1.0 trans-1,3-Dichloropropene ND 1.0 Trichloroethene ND 1.0 Trichlorofluoromethane ND 1.0 Vinyl acetate ND 5.0 Vinyl chloride ND 1.0 _. Surrogate 1,2-0Ichloroethane-d4 103% 76.5-123 Surrogate:4-Bromorluorobenzene 1/8% 75.5-133 " Surrogate:Toluene-d8 987,% 71.1-1/3 " Origins Laboratory,tt Inc "m9 !1 The results in this report apply to the samples analyzed in L•tL4etV1L4. h accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Pagel'of It Noelle E Doyle, Laboratory Manager ,y t 4640 Pecos Street Unit C ` • Y Denver, Colorado 80211 /mil Ott 303.433.1322 Laboratory wt' 303'265.9645 Fax 444 777 LABORATORY. I R C. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Volatile Organic Compounds by EPA Method 8260B- Quality Control Origins Laboratory, Inc. Reporting Spike Source %REC RPD Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes Batch 9H18004- EPA 5030B Blank(9H18004-BLK1) Prepared: 08/18/2009 Analyzed: 08/19/2009 1,1,1,2-Tetrachloroethane ND 1.0 ug/L 1,1,1-Trichloroethane ND 1.0 1,l,2,2-Tetrachloroethane ND 1.0 1,1,2-Trichloroethane ND 1.0 1,1-oichloroethane ND 1.0 1,1-Dichloroethene ND 1.0 1,1-Dichloropropene ND 1.0 1,2,3-Trichlorobenzene ND 1.0 1,2,3-Trichloropropane ND 1.0 1,2,4-Trichlorobenzene ND 1,0 1,2,4-Trimethylbenzene ND 1.0 1,2-Dibromo-3-chloropropane ND 1.0 1,2-Dibromaethane(EDB) ND 1.0 1,2-Dichlorobenzene ND 1.0 1,2-Dichloroethane ND 1.0 1,2-Dichloropropane ND 1.0 1,3,5-Trimerhylbenzene ND 1.0 1,3-Dichlorobenzene ND 1.0 1,3-Dichloropropane ND 1.0 1,4-Dichlorobenzene ND 1,0 1-Butanol ND 100 2,2-Dichloropropane ND 1.0 2-Butanone ND 5.0 2-Chloroethyl vinyl ether ND 5.0 2-Chlorotoluene ND 1.0 2-Hexanone ND 1.0 4-Chlorotoluene ND 1.0 Origins Laboratory, Inc... --11(+ 1 V p I) � The results in this report apply to the samples analyzed in L�t•L••4tUJf�. accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page I2 of I 6 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 ['� 303.433.1 322 Laboratory �...r �+ at }� a ',.s:-. 303.265.9645 Fax CC...77 LA BO N BY 0 B Y. I II C. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Volatile Organic Compounds by EPA Method 8260B- Quality Control Origins Laboratory, Inc. Reporting Spike Source %REC RPD Analyze Result Limit Units Level Result %REC Limits RPD Limit Notes Batch 9H18004— EPA 5030B Blank(9H18004—BLK1) Prepared: 08/18/2009 Analyzed: 08/19/2009 4-Isopropyltoluene ND 1.0 ugL 4-Methyl-2-pentanone ND 5.0 Acetone ND 4.0 Acetonitrile ND 25.0 Benzene ND 1.0 Bromochloromethane ND 1.0 Bromodichloromethane ND 1.0 Bromoform ND 1.0 Bromomethane ND 1.0 Carbon disulfide ND 1.0 Carbon tetrachloride ND 1.0 Chlorobenzene ND 1.0 Chloroethane ND 1.0 Chloroform ND 1.0 Chloromethane ND 1.0 Dibromomethane ND 1.0 cis-1,2-Dichloroethene NO 1.0 Dichlorodifluoromethane ND 1.0 cis-1,3-Dichloroprope ne NO 1.0 Ethylbenzene ND 1.0 Cyclohexane ND 1.0 Dibromochloromethane ND 1.0 Hexachlorobutadiene ND 1.0 lodomethane ND 1.0 Isopropylbenzene ND 1.0 m,p-Xylene ND 2.0 Methyl Acetate ND 5.0 Origins Laboratory, e Inc !1 The results in this report apply to the samples analyzed in tiW„t�/1fY. accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 13o116 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C -. • v Denver, Colorado 80211 303.433.1322 Laboratory �, i - w 303.265.9645 Fax t k R 0 8 N T O ll Y. INC. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project. Broda's Volatile Organic Compounds by EPA Method 8260B - Quality Control Origins Laboratory, Inc. Reporting Spike Source %REC RPD Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes Batch 9H18004- EPA 50308 Blank(9H1 8004—BLK1) Prepared: 08/18/2009 Analyzed: 08/19/2009 Methyl tert-Butyl Ether ND 1.0 ug/L Methylcyclohexane ND 1.0 Naphthalene ND 1.0 sec-Butyl benzene ND 1.0 n-Butylbenzene ND 1.0 n-Propylbenzene ND 1.0 o..Xylene ND 1.0 Styrene ND 1.0 Tetrachloroethene ND 1.0 Toluene ND 1,0 trans-1,2-Dichloroethene ND 1.0 trans-1,3-Dichloropropene ND 1.0 Trichloroethene ND 1.0 Trichlorofluoromethane ND 1.0 Vinyl acetate ND 5.0 Vinyl chloride ND 1.0 Surrogate:1,2-Dichloroethane-d4 55.6 " 62.5 88.9 76.5-123 Surrogate:4-Bromofluorobenzene 110 62.5 176 75.5-133 5-CC Surrogate Toluene-d8 68.9 62.5 110 71.1-1/3 LCS(9H18004-BS1) Prepared: 08/18/2009 Analyzed.08/19/2009 Benzene 55.0 1.0 ug/L 50.0 110 81.7-130 Chlorobenzene 34.0 1.0 50.0 68.1 67.9-117 Toluene 36.6 1.0 50.0 73.3 72-121 Trichloroethene 49,4 1.0 50.0 98.8 74.7-139 Surrogate: 1,2-Dichloroethane-d4 68.2 62.5 109 76.5-123 -- Surrogate:4-Bromofluorobenzene 67.4 " 62.5 108 75.5-133 Surrogate:Toluene-d8 52.9 62.5 84.6 71.1-113 Origins Laboratory,p Inch ' 't ,l �+/ ' The results in this report apply to the samples analyzed in (•A•t0,tVlfi`.(`If Jty�_[/�.•1 accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Paee 14 of 16 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 /�N v 303.433.1322 Laboratory 0..0. 11. , Iris . . t - ww 303.265.9645 Fax x'17 LABORATORY. I N C. Molen &Associates, LLC Mark Molen 2090 East 104the Avenue -#205 Project Number: N/A Thornton CO 80233 Project: Broda's Volatile Organic Compounds by EPA Method 8260B - Quality Control Origins Laboratory, Inc. Reporting Spike Source %REC RPD Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes Batch 9H18004- EPA 5030B Matrix Spike(9H18004-MS1) Source:X908043-01 Prepared: 08/18/2009 Analyzed: 08/19/2009 Benzene 54.5 1.0 ug/L 50.0 ND 109 85.9-137 Chlorobenzene 33.3 1.0 50.0 ND 66.6 78-120 QM-07 Toluene 35.6 1.0 50.0 ND 71.2 71.9-133 QM-07 Trichloroethene 48.6 1 0 50.0 ND 97.2 78.2-146 Surrogate:1,2-Dlchloroethane-d4 69.8 62.5 112 76.5-123 Surrogate:4-Bromofluorobenzene 67.2 62.5 107 75.5-133 Surrogate:Toluene-88 52.2 62.5 83.5 71.1-113 Matrix Spike Dup(9H18004—MSD1) Source:X908043-01 Prepared: 08/18/2009 Analyzed: 08/19/2009 Benzene 52.7 1.0 ug/L 50.0 ND 105 85.9-137 3.45 25 Chlorobenzene 31.5 1.0 .. 50.0 ND 62.9 78-120 5.65 25 QM-07 Toluene 34.0 1.0 50.0 ND 67.9 71.9-133 4.80 25 QM-07 Trichloroethene 47.0 1.0 50.0 ND 93.9 78.2-146 3.41 25 Surrogate:1,2-Dlchloroethane-d4 60.5 62.5 96.8 76.5-723 Surrogate:4-Bromofluorobenzene 68.9 62.5 110 75.5-133 Surrogate:Toluene-d8 64.4 62.5 103 77.1-113 Origins Laboratory, Inc. "-. f! 1/4 The results in this report apply to the samples analyzed in tall IJ�. . accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page 15 or I6 Noelle E Doyle, Laboratory Manager 4640 Pecos Street Unit C Denver, Colorado 80211 _ Y •, 303.433.1322 Laboratory °,,i-■[�Ergs . ' f/ w` 303.265.9645 Fax - • LABORATORY. IBC, Molen &Associates, LLC Mark Molen 2090 East 104the Avenue - #205 Project Number: N/A Thornton CO 80233 Project: Broda's Notes and Definitions S-GC Surrogate recovery outside of control limits.The data was accepted based on valid recovery of the remaining surrogate. QM-07 The spike recovery was outside acceptance limits for the MS and/or MSD. The batch was accepted based on acceptable LCS recovery. ND Analyte NOT DETECTED at or above the reporting limit RPD Relative Percent Difference Origins Laboratory, Inc.//////�� `"1/ 11 The results in this report apply to the samples analyzed in 11( (l•W,IUJe�, accordance with the chain of custody document. This analytical report must be reproduced in its entirety. Page to of l6 Noelle E Doyle, Laboratory Manager Tom Parko From: Tom Parko Sent: Monday, April 05, 2010 9:32 AM To: 'Stutz R. Gregory' Cc: 'Connie.Davis@aggregate-us.com'; 'mmolen@gwest.net'; 'seanford66@comcast.net'; Trevor Jiricek; Kim Ogle; Troy Swain Subject: RE: Weld County AmUSR 905 (Broda Pit) Greg: I had a chance to review this case with the Planning Department and Environmental Health. Following my conversations the following information was provided to me. On February 24, 2010 Mr. Broda and Ms. Davis from Aggregate Industries were informed that the existing USR did not cover an inert landfill operation, and based on information gathered during an on-site inspection with the CDPHE Hazardous Materials and Waste Management Division on February 19, 2010 the operation required a Certificate of Designation (CD) from the local governing authority. During the February 24, 2010 meeting at the Weld County Planning Department, Mr. Broda was requested to submit a CD Application and an Engineered Design & Operations Plan for the facility. As previously discussed during the February 19, 2010 inspection, CDPHE said there was a possibility that Broda's Inert Landfill could continue to accept material and stockpile it until the CD is issued. Based on this, Mr. Broda was requested, in addition to submitting the CD Application and an Engineered Design & Operations Plan, to submit a waste screening plan for materials he wanted to continue to accept and stockpile for Department review. This may have allowed Mr. Broda to fulfill the Denver Water contract until the CD was issued. Based on my conversations, below are a few questions that need clarification. I am not in a position to write a letter per your request given the circumstances. However, I am willing to set up another meeting with key personnel on this end to talk about the particulars. If you have any questions please feel free to call or email me. Kind regards, Tom Parko Planning Manager Weld County As alluded to above, The County is still waiting for the CDPHE Hazardous Materials and Waste Management Division to provide us with their position on whether or not Broda's Inert Landfill requires a CD as a solid waste disposal facility per (30-20-102 CRS) . In order to review the facilities current operations for comparison with those allowed under the current land use, the County needs the following information in order to accurately access the nature of operations at the facility and any possible risks to human health and the environment: 1) What type of materials have been accepted at this inert landfill? Include the type, source, and amount of material. 2) How does the operation ensure that materials accepted are not a source of pollutants, which can impact groundwater quality? 3) What measures were taken, if any, to ensure the material accepted by the inert landfill operation was appropriate for use in the reclamation? 4) Was the accepted material screened as to source? Was there any testing of the materials? If so, provide any results you may have. 5) Is there any on-site treatment or on-site processing of the materials accepted? 1 6) Once received, was the material segregated based on type or engineering properties? Are there any plans followed for the placement of the material used for the reclamation? 2 RECYCLING AND REUSE OF MATERIALS AND LAND INERT FILLING NOTIFICATION 1 for 1 Broda's Inert Fill at Aggregate Industries — Platte Valley Pit 1859 North Hwy 85 at WCR 6 Brighton, Colorado 80603 Prepared for: ' Mr. Patrick Broda BRODA'S INERT FILL ' P.O. Box 337 Henderson, Colorado 80604 1 Prepared by: MOLEN & ASSOCIATES, LLC 2090 E 104th Ave, #205 Thornton, Colorado 80233 ' June 21, 2010 jtvo 1 I Platte Valley Broda Inert Fill ' 1 INTRODUCTION 1 2 GENERAL INFORMATION 2 I 2.1 RESPONSIBLE PARTY CONTACTS 3 2.2 SITE LEGAL DESCRIPTION 3 2.3 SITE ACCESS 3 ' 2.4 USE AND ZONING 3 3 SITE DESCRIPTION 4 3.1 PROPERTY DESCRIPTION 4 I 3.2 ADJACENT PROPERTIES 4 3.3 VICINITY PROPERTIES 4 3.4 SITE LIFE 5 I 3.5 SURROUNDING ZONING AND LAND USE 5 3.6 LOCATION RESTRICTIONS 5 3.6.1 Airports 5 I 3.6.2 Flood Plain 5 3.6.3 Wetlands 5 3.6.4 Seismic Impact Zones 6 I 3.6.5 Fault Zones 6 3.6.6 Unstable Areas 6 3.6.7 Protection Against Prevailing Winds 6 I 4 FACILITY DESCRIPTION 7 4.1 FINAL GRADES 7 4.2 SLOPE STABILITY 7 I 4.3 RECLAMATION PLAN 7 4.3.1 Revegetation 8 4.4 PLACEMENT OF INERT MATERIALS BELOW OR INTO SURFACE WATER OR IGROUNDWATER 8 4.5 EXISTING SITE TOPOGRAPHY 9 4.6 SURFACE WATER DRAINAGE 9 I4.7 NEARBY WELLS 9 4.8 GEOLOGY AND HYDROGEOLOGY 10 5 SITE MANAGEMENT 11 I 5.1 OPERATIONS SCHEDULE 11 5.2 PERSONNEL AND EQUIPMENT REQUIREMENTS 11 5.3 SITE LAYOUT 11 I 5.3.1 Buildings 12 5.3.2 Auxiliary Equipment and Services 12 I 5.3.3 Equipment 12 5.3.4 Site Security and Fencing 12 5.4 RUN-ON/RUNOFF CONTROL MEASURES 13 I 5.5 RECORD-KEEPING 13 5.6 MATERIAL ACCEPTANCE AND PLACEMENT 13 5.6.1 Acceptable Inert Materials 13 5.6.2 Prohibited materials 15 I 5.7 FILL VOLUMES AND SOURCES 15 ' 5.8 DELIVERY AND RECEIVING 15 5.9 FILL PLACEMENT 16 6 SCREENING FOR SUSPECTED CONTAMINANTS 17 6.1 PROACTIVE SCREENING 17 6.2 ON-SITE SCREENING 17 I 6.2.1 Petroleum hydrocarbon contamination 17 6.2.2 Other contamination 17 6.3 FIELD SCREENING METHODS 18 7 FINAL GRADES AND COVER MATERIALS 19 7.1 STOCKPILING 19 7.2 REVEGETATION AND RECLAMATION 20 , 8 ENVIRONMENTAL MONITORING AND HEALTH AND SAFETY CONTROLS 21 8.1 GROUNDWATER MONITORING 21 8.2 STORMWATER 21 I 8.3 AIR QUALITY 21 8.4 LITTER CONTROL 21 ' 8.5 FIRE SAFETY 22 8.6 HAZARDOUS MATERIALS EMERGENCY MANAGEMENT PLAN 22 8.7 NUISANCE CONDITIONS 23 ' 9 GROUNDWATER MONITORING PROGRAM 24 9.1 GROUNDWATER MONITORING 24 9.2 GROUNDWATER MONITORING NETWORK 24 ' 9.3 SCHEDULE,ANALYTES AND EVALUATION 25 9.4 SAMPLING AND ANALYSIS PLAN 25 9.4.1 Sampling Methods 25 9.4.2 Chain of Custody 26 9.4.3 Quality Assurance/Quality Control 27 9.5 MAINTENANCE 27 t 9.6 REPORTING 27 9.7 ASSESSMENT MONITORING 28 10 CLOSURE PLANS 29 t 10.1 NOTIFICATION OF CLOSURE 29 Appendices , Appendix 1 DRMS and Weld County Approvals Appendix 2 Site Location Map Appendix 3 Broda Fill Area Entrance and Exit ' Appendix 4 Topographic Map and Pre-Mining Conditions Appendix 5 Flood Plain Map Appendix 6 Geotechnical Report by Earth Engineering Consultants, Inc ' Appendix 7 Reclamation Plan and AmUSR-905 Permit Plans Appendix 8 Records of Nearby Wells ' Appendix 9 Groundwater Monitoring Well Locations Appendix 10 Typical Groundwater Monitoring Well I Recycling and Reuse of Materials and Land ' Broda's Inert Fill Aggregate Industries — Platte Valley Pit ' 1 INTRODUCTION Aggregate Industries— WRC, Inc. operates a sand and gravel mine, known as the Platte Valley Pit, at 1859 North Hwy 85 at WCR-6, Brighton, Colorado under permits from the Colorado Division of Reclamation, Mining and Safety (Permit M-1989-120) and Weld County (Permit AmUSR-905). Patrick Broda, operating under the name of Broda's Inert ' Fill (Broda), has been conducting a portion of the reclamation phase of the mining operation by backfilling certain mined areas of the property with imported inert fill material since 2008. Approval of this import inert fill activity was obtained from the ' Division of Reclamation, Mining and Safety (DRMS) on November 15, 2005 and acknowledged by Weld County in 2005 as part of the approved reclamation plan. Copies of the documents associated with obtaining the 2005 approvals are contained in Appendix 1. The inert filling operation is designed to accelerate the time line for achieving reclamation of the mine in accordance with the permits. ' The reclamation plan included with the Weld County and DRMS permits provide for backfilling the pit lake area created by mining with overburden and process fines generated from AI's Platte Valley operations and soils and other inert materials generated from AI's Wattenberg Lakes mine and other off site locations. To assure the area will be filled, and given the limited amount of gravel spoils available, the Broda activities were initiated to import clean inert material to fill the pit. The operations at Broda's Inert Fill will make the site suitable for future industrial use of the property, potentially providing future tax revenues for Weld County and the State of Colorado. Additionally, filling the pit reduces evaporative losses associated with exposed groundwater surface area, which have to be augmented with other water sources. ' This Plan for Recycling and Reuse of Materials and Land is designed to document Broda's program and it is believed to comply with all the current permits and approvals available. The Plan describes the methods used since the clean fill started and should not interrupt the current activities at the site. 1 ' Recycling Operations Plan Broda's Inert Fill Al— Platte Valley Operations 1 Revised June 16, 2010 1 U I 2 GENERAL INFORMATION Broda's Inert Fill is located within Aggregate Industries' Platte Valley sand and gravel mining operation at 1859 North Hwy 85 at WCR-6, Brighton, Colorado. The location of the clean inert fill site is shown on the map in Appendix 2. ' Clean inert filling has been used everywhere across the country and around the world. Most inert filling is done without permits where one person is digging up or mining out the earth and another person is receiving the earth to backfill a hole or re-grade property. The activity of using inert fill is a"beneficial use" shown in the November 2007 report by the Association of State and Territorial Solid Waste Management Officials. One primary advantage is to minimize the use of valuable Municipal Solid Waste landfill space. Using clean inert fill at this site modifies the mined cell grades and conditions to achieve the post-mining reclamation land form as approved under DRMS and Weld County permits for the mining and reclamation of AI's Platte Valley operation. The ground surface at the site currently is more than 5 feet below the surrounding ground elevations along Highway 85. Using inert fill in this area will bring the site to a usable grade, potentially allowing for future industrial use. Additional inert material will be backfilled into the central portions of the property to restore the land to elevations similar to those present prior to mining, reducing exposed groundwater surface area to minimize evaporative losses, and creating upland areas for future use. The benefits for using inert fill for recycling and reuse of materials and land at the Platte Valley site include: ' • Recycling of materials that may otherwise be disposed. • Restoring land forms for potential industrial uses. ' • Reducing evaporative losses of valuable water. • Providing private entities with clean inert fill use alternatives. • Revenue to Weld County, and the State in taxes from potential industrial establishments that could be located on the site after filling. • Increased employment opportunities created by the future development and by the Broda operations. • Diversion of materials from potential disposal at valuable permitted municipal solid waste landfills. Broda does comply with all the requirements, laws and regulations that apply to the inert filling operations under DRMS and Weld County permits governing the Platte Valley site and businesses in general. The rules and regulations for the State of Colorado that apply to the backfilling operation of the inert fill and the rules and regulations, and ordinances for Weld County will also be followed. Recycling Operations Plan Broda's Inert Fill AI —Platte Valley Operations 2 Revised June 16, 2010 1 2.1 Responsible Party Contacts The owner of the property is: Aggregate Industries—WRC, Inc 1707 Cole Blvd., #100 Golden, Colorado 80401 The operator of and 24-hour emergency contact for the Recycling Operation and Inert Fill is: Patrick Broda Broda's Inert Fill P.O. Box 337 Henderson, Colorado 80604 ' 2.2 Site Legal Description The site is located southwest of the intersection of Hwy 85 and WCR-6 on the outskirts of Brighton, Colorado as shown on the map in Appendix 3. The Aggregate Industries— I Platte Valley Pit is approximately 190 acres extending approximately one mile to the south of WCR-6 and is approximately 1800 feet from east to west. An aerial site map showing the Aggregate Industries— Platte Valley Broda fill operations area is in ' Appendix 3. The site is located in the central portion of Section 30, Township 1N, Range 66W. ' 2.3 Site Access The current entrance to the site is located along WCR-6 approximately 500 feet west of ' Hwy 85. A map showing the fill area at the Aggregate Industries—Platte Valley Pit site is found in Appendix 3. The entrance and exit to Broda's is through the main gate to the Aggregate Industries Platte Valley site is also shown on the map in Appendix 3. The ' roads are in good condition and are maintained, watered as necessary to control dust, and marked with speed limit signs indicating a maximum speed of 5 and 10 mph. ' 2.4 Use and Zoning The property is zoned industrial I-3 and is currently operated as a sand and gravel mine under Weld County special use permit AmUSR-905, which allows for the inert filling and recycling of materials and land. The zoning for the site will likely remain the same in the future depending on development. Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 3 Revised June 16, 2010 1 3 SITE DESCRIPTION The site is an excavated gravel mine cell used for the recycling of materials and land and the filling of clean inert materials only. Deliveries enter and exit the site off of WCR-6 approximately 500 feet west of the intersection with Hwy 85. The site is not open to the general public and is attended during business hours. Only inert materials from approved contractors are accepted. Truck drivers are required to check in with the on-site attendant with each delivery and are directed to a designated area to unload. , The materials received are screened for unacceptable materials as described in Section 6 of this recycling plan. After completing the screening and unloading, operations personnel will allow the trucks to exit the site. Unacceptable materials are loaded back on the truck and removed by the responsible party or by the operator. 3.1 Property Description The property is a sand and gravel mine. The area where the structural inert fill is being placed is a man made lake that was created as a result of mining the sand and gravel deposit. The fill area is approximately 30 acres in size. Placing inert structural fill in the area will reduce evaporative losses and bring the land elevations back to pre-mining conditions as specified in the approved reclamation plan to provide for potential future development. A map showing the pre-mining conditions is shown in Appendix 4. 3.2 Adjacent Properties Properties that are immediately adjacent to the Aggregate Industries— Platte Valley Operations are industrial and agricultural or open land. The surrounding property uses are a truck fabricating facility and other industrial properties to the south, a lake used for water skiing demonstration to the east, vacant land to the north, and the South Platte River and farming to the west. Commercial enterprises are located across Hwy 85 to the northeast. 3.3 Vicinity Properties The site is located west of Hwy 85, east of the South Platte River and south of Weld County Road 6 (WCR-6). The eastern most boundaries are along Hwy 85. The southern , boundary is immediately adjacent to light industrial property. The western boundary is along the South Platte River and Aggregate Industries' Wattenberg Lakes sand and gravel mine. The northern boundary is adjacent to open land with commercial operations. , There are no residential properties adjacent to the Broda fill area of the site. Some of the vicinity properties have been and are being mined for sand and gravel. Aggregate Industries operates the Wattenberg Lakes sand and gravel mine west of the South Platte River and the property east of US-85 was mined as well and is currently being used as a recreational lake for water skiing. Other operations in the area are light industry, open land or commercial. The closest residential development to the property is Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 4 Revised June 16, 2010 a mobile home trailer park located northeast of the intersection of US-85 and WCR-6 ' approximately 0.66 miles from the Broda fill area. The Weld County permit AmUSR- 905 application shows the land owners and uses that were current at the time of the permit application in 2004. ' 3.4 Site Life The anticipated site life of the inert filling operation is 7 to 20 years. This site life is ' estimated based upon the volumes of materials received at the site to date. The quantity of inert materials available is dependent upon the local economy and the location of other inert fill operations relative to where the inert materials are generated. An increase in ' economic activity, road construction or other general construction will increase the quantity of inert materials available. ' 3.5 Surrounding Zoning and Land Use The area the site located is currently zoned industrial and is owned by Aggregate ' Industries - WRC, Inc. The current zoning and mining permit allow for the inert materials filling at the site. The zoning in the area the site is located is industrial and will likely remain the same in the future as the site fills and there is greater potential for ' commercial development. 3.6 Location Restrictions ' 3.6.1 Airports Restrictions for airports are not required for the inert fill operations. Only non- ' putrescible materials are placed on site and there are not any concerns with birds. The site is located more than 10 miles from any public airport. ' 3.6.2 Flood Plain Portions of the site are located in a flood plain according to the Flood Insurance Rate Map for Weld County Panel 983 of 1075 dated September 28, 1982. Filling in the flood plain ' with inert materials is allowed and is consistent with the Weld County permit AmUSR- 905. The inert fill will restore the property to elevations similar to the pre-mining elevations and in compliance with the AmUSR-905 permit and rules for filling within the flood plain. A copy of the portion of Flood Insurance Rate Map for Weld County Panel 983 of 1075 is found in Appendix 5. ' 3.6.3 Wetlands Wetlands being created by Aggregate Industries as part of its approved reclamation plan ' on other areas within the site boundaries will not be impacted by the filling operations. The wetlands will be maintained and/or established by Aggregate Industries according to the reclamation plan. The wetlands will not be disturbed by the filling activities so long ' as the lake remains at its current elevation. Placement of the inert materials will be done outside the wetlands and gentle slopes no steeper than 3:1 will be used around the Recycling Operations Plan Broda's Inert Fill Al-Platte Valley Operations 5 Revised June 16, 2010 1 wetlands providing adequate access to waterfowl and wildlife. Portions of the wetlands are proposed for use as stormwater detention areas. 3.6.4 Seismic Impact Zones The United States Geologic Survey (USGS) Open-file Report was reviewed to determine if the site is in a seismic impact zone as defined in the current State and Federal Regulations. The report indicates that the site is not defined as a seismic impact zone. Placement of inert materials does not require a barrier layer of liner material either(clay or synthetic) and is not subject to seismic impact zone requirement. 3.6.5 Fault Zones The site boundary is not located within 200 feet of any fault experiencing displacement in the Holocene time. The nearest reported fault is the Rocky Mountain Arsenal Fault located over 10 miles to the south-southwest of the site. Placement of inert materials typically does not require a barrier layer of liner material either(clay or synthetic) and is not subject to the fault zone requirement. 3.6.6 Unstable Areas , There are no unstable geologic areas on the site. Man-made features on site will be maintained to be stable. Permanent constructed slopes will be a no steeper than 3:1. 3.6.7 Protection Against Prevailing Winds Operation of an inert material fill does not require specific protection from prevailing winds. The filling of inert materials does not create nuisance conditions of wind blown paper or debris. Only inert materials described in this recycling plan will be acceptable at the site. Additional operational practices for receiving and handling the inert materials in windy conditions are described in more detail in Section 8 of this recycling plan. Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 6 Revised June 16, 2010 1 I ' 4 FACILITY DESCRIPTION The facility is designed to utilize inert materials from off-site sources and recycle them by process and placement to restore the removed (excavated) land from the mining operations. The existing property elevations are not conducive to using the land for future development. Prior to mining, the property was above the water table and available for development. The inert materials will be sorted and placed in a fashion to allow for the recycling of some materials, the rebuilding of land for development, and the reduction of evaporative water losses and augmentation liability. By filling the area with the inert materials the land is reclaimed and the materials used are diverted from valuable municipal solid waste landfill airspace. ' Based upon the geotechnical report from Earth Engineering Consultants, Inc (EEC) in Appendix 6, building on fill areas is not uncommon and can be done with precautions. The EEC geotechnical report recommends surcharge loading on the fill as an efficient ' way to consolidate the in-place materials. Operations at Broda's will utilize temporary stockpiles of asphalt and/or concrete to provide some of the surcharge loading. Additionally AI is considering the stockpiling of aggregate on the filled areas to provide ' surcharge loading in the future. The temporary stockpiling of asphalt and/or concrete or aggregate product will be moved to areas that have not had a surcharge loading. By moving the surcharge loading to new areas, the majority of the fill site will eventually be consolidated. In the event that surcharge loading is not completed in certain areas, dynamic compaction can be used, or future buildings can be built on deep foundations that bear the loads on underlying bedrock. Future uses of the fill area will benefit from the surcharging and consolidation creating more useful property. 4.1 Final Grades Elevations of the final grades at the site are described in the mining Reclamation Plan as at least 2 feet above the estimated maximum local groundwater elevation, and near to the ' existing and surrounding ground elevations as possible. The final elevations are expected to be roughly the same as the pre-mining elevations as shown on the topographic map in Appendix 4. ' 4.2 Slope Stability The final slopes will be no steeper than 3:1. Stockpiled materials may have steeper slopes but will only be temporary. The fill area is generally flat with a mild slope of 1 to 2 percent. 4.3 Reclamation Plan The filling operations are on Aggregate Industries property that is mined for sand and gravel. The mining permit number is M-1989-120 approved by the State of Colorado Division of Reclamation, Mining and Safety— DRMS (formerly the Division of Minerals ' Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 7 Revised June 16, 2010 and Geology—DMG). The property has a Use by Special Review permit number AmUSR-905 with Weld County (portions shown in Appendix 7). A Reclamation Plan was filed with the DRMS and Weld County and will be followed and completed as the site is filled. A copy of the Reclamation Plan included in the DRMS permit is found in Appendix 7. The Reclamation Plan calls for the filling of the pit with soil, overburden, or other inert materials and revegetation. 4.3.1 Revegetation Once an area is backfilled to final elevations the property will be revegetated according to the reseeding plans outlined in the DRMS permit application narrative found in the Reclamation Plan (Appendix 7). 4.4 Placement of Inert Materials Below or Into Surface Water or Groundwater Portions of the site are pit lakes (estimated maximum depth of 10-20 feet) that will be filled with clean inert fill. Only clean inert materials are allowed in the pit lake water and will not contain large asphalt or asphalt pieces or direct placement of daylighting mud. Over the past two and one-half years of operation, efforts were made to have asphalt placed above the water table; however some asphalt pieces may be below the water table. Daylighting mud has been placed directly into the pit lake periodically although the placement changed after CDPHE and Weld County discussed concerns about the placement during their inspection. The placement of inert materials into the pit is necessary to bring the site to previous elevations prior to mining. Structural inert fill is unloaded near the water edge and is pushed into the water areas only after screening of the materials is complete. The ground surface prior to mining by Aggregate Industries— Platte Valley Pit was above the surface water elevation and the pit lake was non-existent. The created wetlands are in areas near the southwest portion of the pit lake, away from filling. Approximately 85-88% of the materials received are dirt or earth, 12% is hardened concrete and less than 7% is dry hardened asphalt fragments. Day-lighting mud is a mixture of clean water and dirt and is generated by using high pressure water and a vacuum pump to remove soils and expose utility lines. Drilling mud and fluids used in oil and gas operations are not included in day-lighting mud and is not an acceptable material. A track hoe mounted work tool (similar to a grappler) is currently being used to pull asphalt pieces from the loads received. The work tool is a hydraulic controlled attachment to a backhoe or track hoe that allows the operator to pick up heavy pieces of asphalt or concrete and remove them from the load of delivered inert fill. The separated pieces of asphalt will be stockpiled, providing surcharge loads, and be set aside for crushing and recycling or placed in areas of the fill that is at least one foot above the Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 8 Revised June 16, 2010 water table. The separated concrete pieces will be set aside for crushing or placed as any ' other inert materials in a manner that will minimize void spaces. The process of handling, stockpiling and placing large pieces of asphalt or concrete is consistent with the geotechnical report by EEC (Appendix 6). ' 4.5 Existing Site Topography ' The existing topography of the site is found on the aerial map (Appendix 3). The site is located along the South Platte Alluvium in an area that was previously mined for gravel and sand. Mining of the fill area was done according to permits with the DRMS (M- I 1989-120) and Weld County (AmUSR-905). The site elevations are primarily the surface of the pit lakes around the site. Most of the mined cells are approximately 10 feet lower in elevation than the neighboring properties to the east, south and north. The majority of the property has been disturbed in accordance with the mining permit. A major portion of the site is currently a pit lake. The elevation of the lake is 4930+ and ' is estimated to be approximately 10-20 feet deep. Filling activities raise the elevations to approximately 4940+ about 5-7 feet above the existing pit lake surface. The pit lake is being filled in conformance with the geotechnical report with clean inert materials, and will reduce evaporative losses and restore a solid surface and land that will be available for other uses in the future. ' 4.6 Surface Water Drainage ' Regional water flow patterns follow the path of the South Platte River located approximately 500 to 600 feet west of the filling operations. The fill areas will be sloped such that surface drainage will flow to pits that are part of the sand and gravel mining ' operations. A roadside ditch is located along the eastern boundary down the slope from Hwy 85. The nearest perennial body of water is the South Platte River located approximately 500 to 600 feet west of the fill operations. Aggregate Industries has a CDPS permit for its sand and gravel mining operation which incorporates a stormwater management plan for the property. 4.7 Nearby Wells ' A listing of all the recorded wells within a one-half mile radius is found in the report in Appendix 8. There are eight wells listed as being applied for in the site area with six of the eight wells actually issued or active. Fifteen additional wells are located within one- eighth mile from the site. A total of 160 wells are listed as being applied for or issued within one mile from the site. ' Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 9 Revised June 16, 2010 4.8 Geology and Hydrogeology The initial mining permits examined the geology and hydrogeology. The site is located in the South Platte River basin. It is underlain with sands and gravel from the surface to bedrock. Soils are described in the portion of the mining permit as Altavan loam, Aquolis and Aquants, Bankard sandy loam, Dacono clay, and Ustic Torriorthents. Additional geology and hydrogeology investigation is not necessary based upon the inert nature of the materials being placed at the site and the previous mining permits and approval to fill with sand, gravel spoils and other inert fill. The geology and hydrogeology is described on the permit plats for AmUSR-905 (Appendix7). 1 I 1 Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 10 Revised June 16, 2010 ' 5 SITE MANAGEMENT 5.1 Operations Schedule ' Broda's inert fill maintains normal operating hours of 7 AM to 5 PM, Monday through Friday. Under certain circumstances the site may remain open weekends or for extended hours during the week in response to incoming loads or emergency situations. Broda's inert fill will not normally be open weekends or holidays. The following holidays are the minimum holidays observed by Broda personnel. • New Years Day • Memorial Day • Fourth of July • Labor Day • Thanksgiving • Christmas Day ' 5.2 Personnel and Equipment Requirements Broda's inert filling operations normally have a minimum of three employees. The ' employees are equipment operators, laborers, and supervisors. Patrick Broda is the General Manager and questions and information requests should be directed through him. The Site Manager is Harrison Broda and he should be contacted in Patrick Broda's ' absence. At least one person employed at Broda's will be trained to screen for hazardous materials and for identification of asbestos containing materials. The person will be trained as soon as possible after the approval of this recycling plan. 5.3 Site Layout ' The inert material fill has three areas of operation, delivery—receiving, placement of materials, and ancillary activities including asphalt and/or concrete separation and surcharge loading with stockpiled materials. Loads of inert materials are directed to ' unload in an area in close proximity to the pit. After the load is inspected for unacceptable materials and asphalt pieces are removed, it is pushed to the edge of the fill ' along the interface with the pit. Asphalt pieces are stockpiled and will be crushed (typically off site) and recycled or placed in the pit area at least one-foot above the water table as described in Section 4.4 of this plan. Wetlands are located on the western and southern portions of the property and will not be disturbed. ' Recycling Operations Plan Broda's Inert Fill Al -Platte Valley Operations 11 Revised June 16, 2010 5.3.1 Buildings One temporary building is located on site as approved by Weld County regulations. The temporary building will be used for an office for personnel on site. The office will not be used as a"pay shack" or other type of daily collection area because customers using the Broda site are billed and pay by weekly or monthly invoice. 5.3.2 Auxiliary Equipment and Services Additional equipment and services on the site are: • 5 cubic yard dumpster All of the above will include service contracts for regular pick-up and clean-outs. 5.3.3 Equipment The following equipment is available and will either be kept on the site or located at an alternative location near the site. • Cat 980 Loader (2 each) • Cat D6 Dozer • Motor-grader 140H • Hydraulic work tool—picker ' • Water Truck (4000 gallon) • Pickup truck (2 each) Equipment will be utilized for the proper placement and grading of the inert materials being received. The equipment will also be used to maintain the grounds and move other soil as necessary at the site. 5.3.4 Site Security and Fencing Unauthorized access to the site is provided by fencing or other natural barriers (i.e. pit lakes). A security eight foot high fence surrounds the Aggregate Industries—Platte Valley Operations property. The fence gate is locked at all times when the site is not attended. The South Platte River and adjacent mining activities and pit lakes on the west provide sufficient natural barrier for unauthorized access from the west. Broda personnel monitor the site throughout the day by regular inspections or working onsite. Recycling Operations Plan Broda's Inert Fill Al -Platte Valley Operations 12 Revised June 16, 2010 5.4 Run-on/runoff Control Measures Surface water control measures will be maintained to manage run-on and run-off from the site operations. Current elevations at the site are lower than the surrounding properties, eliminating potential run-off from the site. Run-on is controlled by a roadside ditch along Hwy 85. Existing berms are located between the filling operations and other Aggregate Industries operations to the north and south. As the filling of the site proceeds drainage channels will be constructed to promote drainage to the Aggregate Industries pit lakes and wetlands along the western and ' southern boundaries. Wetlands located on the western portion of the site will serve as a storm water detention basin. Inert filling activities will be conducted in a manner that will control run-on and run-off. 5.5 Record-keeping ' Broda will maintain records of deliveries of materials to the site on a daily basis. Drivers are required to sign in and meet with on site personnel to check the location of the source of materials, and the types of inert materials (i.e. concrete, asphalt, dirt). ' Prior to granting approval for inert material acceptance, a verbal agreement is made between the company and Broda. The source location of materials is known and is ' typically checked by Broda personnel to verify the activities and screen for the potential of unacceptable or contaminated materials. ' All records will be maintained for at least two years and pertinent information will be saved for three years after the site is completed. Copies of the information will normally be kept on site with the originals kept in a safe location at an office. The documents are ' kept off-site at a location that is more secure and has less potential for documents being lost or misplaced. ' 5.6 Material Acceptance and Placement ' 5.6.1 Acceptable Inert Materials Only inert materials will be allowed at the site. The Colorado Department of Public ' Health and Environment (CDPHE) defines inert material as follows. "Inert material" means non-water-soluble 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 60 days, masonry, asphalt paving fragments, and other inert solids. ' Recycling Operations Plan Broda's Inert Fill Al-Platte Valley Operations 13 Revised June 16, 2010 1 The following list of inert materials is acceptable. Accepted inert materials must not be contaminated. 1. earth , 2. dirt 3. soil 4. sand 5. gravel 6. rock 7. concrete (hardened for at least 60 days) and concrete pieces 8. asphalt paving fragments 9. top soil 10. masonry 11. day-lighting mud Inert material may contain incidental amounts of wood and debris. The incidental materials are generally removed from the loads when they are unloaded and placed into the garbage dumpster located on site. Asphalt is removed using a hydraulic tool that picks them from the loads. The asphalt is stockpiled to provide static compaction and will be recycled or placed at least 1 foot above the water table. Over the past two and one-half years of operation, efforts were made to have asphalt placed above the water table; however some asphalt pieces may be below the water table. Daylighting mud has been placed directly into the pit lake periodically although the placement changed after CDPHE and Weld County discussed concerns about the placement during their inspection. Approximately 85-88% of the materials received are dirt or earth, 12% is hardened concrete and less than 7% is dry hardened asphalt fragments. Day-lighting mud is a mixture of clean water and dirt and is generated by using high pressure water and a vacuum pump to remove soils and expose utility lines. Drilling mud and fluids used in oil and gas operations are not included in day-lighting mud and is not an acceptable material. A track hoe mounted work tool (similar to a grappler) is currently being used to pull asphalt pieces from the loads received. The work tool is a hydraulic controlled attachment to a backhoe or track hoe that allows the operator to pick up heavy pieces of asphalt or concrete and remove them from the load of delivered inert fill. The separated pieces of asphalt will be stockpiled, providing surcharge loads, and be set aside for crushing and recycling or placed in areas of the fill that is at least one foot above the water table. The separated concrete pieces will be set aside for crushing or placed as any Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 14 Revised June 16, 2010 other inert materials in a manner that will minimize void spaces. The process of handling, stockpiling and placing large pieces of asphalt or concrete is consistent with the geotechnical report by EEC. ' 5.6.2 Prohibited materials Contaminated soils are NOT ACCEPTABLE at the Broda site. Contaminated soils ' include petroleum hydrocarbon contaminated materials, demolition debris, asbestos contaminated soils, excessive vegetation, and other non-inert materials. Additionally soils cannot be contaminated with asbestos, lead paint chips, or other potentially hazardous materials. 5.7 Fill Volumes and Sources ' The sources and amount of fill received on a daily basis will vary depending on construction activities in the Denver Metro area. Approximately 10-25 truckloads of inert ' material are received per day at Broda's operation. The sources of fill material range from excavation activities for construction of curbing and gutters, basements and buildings, land clearing, demolition projects, and road and highway construction. Current ' customers at the existing Broda site include trucking companies, curb and gutter contractors, asphalt and concrete paving companies, excavators, construction companies and government entities. ' The volume of air space available for fill is estimated to be 603,000 cubic yards. Based upon 20 truckloads of material received per day in an average of 15 cubic yards per ' truckloads the site should be filled and 6-10 years. The daily volume of 360 cubic yards will fluctuate overtime and it is anticipated that the site life could be as low as 6.5 years ' and as high as 20 years. 5.8 Delivery and receiving Transporters enter and exit the site through the entrance gate located on WCR-6. The gate is located along the fence line of the northern boundary of the Aggregate Industries— I Platte Valley operations. The size and speed limit of the onsite road and the traffic pattern is designed to minimize the potential for accidents on site. The map in Appendix 3 displays the entrance and exit to the site. A sign is located at the entrance displaying ' the materials accepted and the hours of operation. Traffic cones and signs are used at times to direct transporters to the daily-designated ' unloading area. ' Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 15 Revised June 16, 2010 I 5.9 Fill Placement Transporters will be directed to the unloading location by either on site personnel or with signs and/or traffic cones. The transporters typically deliver many loads of inert material on the same day and will be familiar with the unloading area. Asphalt pieces will be picked from the loads and will be stockpiled and recycled or placed on dry land at least ' one-foot above the water table. Concrete and asphalt pieces that are placed on the site will be done in a manner that minimizes void spaces. When unloading in the area of the pit, trucks will unload away from the edge of the pit to prevent the truck's rear tires from sinking or getting stuck. Once a sufficient amount of inert materials have been placed and screened, the area will be elevated with an additional , amount of inert materials to reach an elevation of 5 to 10 feet above the water surface. This will allow for unloading near the edge of the area and pushing of the inert materials over the 5 to 10 foot slope, building the unloading surface out across the pit area. Broda has previous experience with placement and unloading in areas of ponding water at other inert fill operations. Asphalt and/or concrete pieces that are picked from the loads will be stockpiled to provide a surcharge load on the fill area. The stockpiles will be placed in different areas across the site in an effort to provide the surcharge loads to a majority of the site. The stockpiling of asphalt and/or concrete pieces for a time period of approximately six months or more prior to recycling them or placing them above the water table, is consistent with the geotechnical report from EEC found in Appendix 6. Placement of daylighting mud will be done in a pit specifically constructed for this purpose. The pit will be located above the water table in areas of dry land. Mud will separate and the water will be pumped off and used for dust suppression on site, or allowed to evaporate. A random sample of the daylighting mud will be taken and analyzed for VOC's and eight heavy metals at least once per year. Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 16 Revised June 16, 2010 1 1 ' 6 SCREENING FOR SUSPECTED CONTAMINANTS 6.1 Proactive Screening ' Prior to granting permission to use the Broda AI-PVO site companies interested in delivering inert materials must make verbal agreements with Broda personnel. The ' verbal agreements include interviewing questions on the type of activity generating the inert materials, the location, whether any contamination is known to be generated at the source site, the approximate quantity, and any information available concerning the ' potential for encountering contamination. Broda has an approved list of companies that have a history of not delivering any unacceptable or contaminated materials. Companies that have been know to deliver materials that were not described initially or were found to be unacceptable or contaminated are taken off the approved list and will remain off the approved list until such time that they can demonstrate regular compliance with rules. ' Broda personnel will typically visit the source location of the inert fill being delivered to confirm the nature of the activities. Any observed abnormalities would need to be ' explained or an evaluation done prior to inert materials being delivered from the source site to the Broda site. ' 6.2 On-site Screening During inert materials delivery, soil stockpiling, or activities involving the inspection or ' movement of inert materials on the site at least 5% of the inert materials will be screened for suspected contamination using the following procedures: ' 6.2.1 Petroleum hydrocarbon contamination • visual observation of soil conditions looking for soil staining, soil discoloration, ' changes in moisture, or other unusual soil conditions. • visual observation for aggregate bedding materials commonly found around piping or underground storage tanks. ' • odor observation in the area of excavation indicating petroleum hydrocarbons. • odor observation of suspected soils picking up a handful of soil and using ' olfactory senses to determine suspicious soils might be contaminated. 6.2.2 Other contamination • visual observation for trash or debris possibly indicating the presence of uncontrolled-unauthorized or historical landfilling. ' • visual observation for non soil like materials including asbestos chips, asbestos piping, lead-based paint chips. Recycling Operations Plan Broda's Inert Fill AI-Platte Valley Operations 17 Revised June 16, 2010 • visual observation for other irregularities in the inert materials. Suspicious inert materials will be segregated for additional evaluation. A person or , persons familiar with inert materials contamination will evaluate the segregated suspicious soils further. During the evaluation, if it appears that contamination could be present, environmental sampling will be completed. Inert materials suspected to be contaminated would not be allowed to continue delivery to the Broda site until such time that a lack of contamination can be verified. A log of the screening activity will be made during the screening activity. The segregated inert materials will be separated from other work areas with barricades, caution tape, traffic cones, construction fencing or other means. The segregated inert material will have restricted access to the areas minimizing potential worker or public exposure and inadvertent handling of the potentially contaminated materials. 6.3 Field screening methods Field screening methods may be used to determine potential inert material contamination. , The field screening methods include headspace/PID screening, draeger tubes (or equivalent), color metric field kits, infrared (IR) analysis for TPH in soil, pH, conductivity, temperature, and other methods, depending on the known or suspected contaminants or purpose of screening. Field screening methods may be done independently or periodic laboratory testing may be employed to verify the field screening results. Field screening equipment will be calibrated according to the manufacturer specifications prior to and periodically during the field use. This applies to equipment used for on-site chemical measurements such as pH, electrical conductivity, and temperature. Instruments and equipment used to gather, generate, or measure environmental data in the field will be calibrated with sufficient frequency and in such a manner that accuracy and reproducibility of the results are consistent with the manufacturer specifications. 1 1 Recycling Operations Plan Broda's Inert Fill Al -Platte Valley Operations 18 Revised June 16, 2010 1 7 FINAL GRADES AND COVER MATERIALS The fill activity conducted by Broda's Inert Fill is an integral part of the DRMS approved ' reclamation plan for Aggregate Industries' Platte Valley Pit and has progressed, and will continue to progress, according to the approved plan under the jurisdiction of DRMS. Final grades at the site will be approximately the grades present prior to any mining ' operations. Topographic maps of the site prior to mining show the contours to be at an elevation of approximately 4930 to 4950 depending on the specific area. Six inches of soil will be placed on top of all filled materials as final cover. Fill materials will be ' compacted by regular truck and heavy equipment traffic over the site, and with surcharge loading by stockpiling asphalt pieces prior to recycling or other aggregate products. The Cat D 980 loader weighs approximately 75,000 pounds and loaded trucks entering the site ' weigh approximately 80,000 pounds. The weight of the trucks and equipment provide compaction of the upper portion of the fill area. Additional deeper compaction will be done as described in the geotechnical report by EEC, by providing a surcharge load in ' areas across the site. Cover soils are currently available at the site and additional cover soils delivered to the site will be stockpiled and used as final cover. ' During the filling activities efforts will be made to stockpile acceptable materials at different locations across the Broda fill area to provide static compaction as described in the EEC geotechnical report. After the Broda fill area is complete, arrangements will be ' made with parties interested in purchasing the property to determine their needs for compaction of the subsurface. Prospective purchasers will need to assess the suitability ' of the fill area for their proposed development and consider the building support alternatives, as outlined in the EEC report, appropriate to any proposed building construction. As noted in the EEC report, building in fill areas is not uncommon; ' however, specific borings will need to be completed by a developer prior to any proposed construction to provide specific recommendations for building support on the site. ' 7.1 Stockpiling Long term stockpiling of the inert materials is prohibited based upon the approvals for ' material acceptance with DRMS. Stockpiling of aggregate and recyclable materials is acceptable and will be used as much as possible to provide a static compaction on the Broda inert fill area. Generally, the inert materials will not be stockpiled and will be ' placed within 24 hours after being received unless the load is suspicious and additional testing or examination is being completed. Suspicious materials will only be stockpiled for as long as necessary to complete the evaluation, typically for less than one week. ' Asphalt pieces will be stockpiled for approximately six months at a time, done in different areas and in a manner consistent with the geotechnical report. ' Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 19 Revised June 16, 2010 1 7.2 Revegetation and Reclamation Revegetation of the site will be completed after the final cover is placed. The seed mixture is specified in the DRMS permit Reclamation Plan (Appendix 7). 1 Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 20 Revised June 16, 2010 1 8 ENVIRONMENTAL MONITORING AND HEALTH AND SAFETY CONTROLS 8.1 Groundwater monitoring A groundwater monitoring program will be implemented for detection monitoring at the site based upon the permit conditions applied. Samples will be taken of the groundwater and the analytical results will be monitored for site related statistically significant increase and ' comparisons to the Colorado groundwater standards. Current groundwater conditions will be defined by the data from eight sampling events; these samples will form the initial background pool for statistical evaluation. Up gradient well analyses will be compared to down gradient analyses using statistical evaluation method and a verification re-sampling procedure. Additional information concerning the monitoring is found in Section 9, Groundwater Monitoring Program. 8.2 Stormwater Stormwater does not currently runoff the site. The current elevations are higher at all points around the perimeter. As the site fills, stormwater will be diverted to flow to the wetlands on the south-western portion of the property. ' A stormwater management plan exists for the Aggregate Industries—Platte Valley Pit and will be amended as necessary for the activities at the site. The wetland area will be used for a stormwater detention area for the site. ' 8.3 Air Quality The only air quality issue at the site will be fugitive dust from truck and equipment traffic. Fugitive dust will be controlled by watering the site with a water truck or similar equipment of a water tank in the bed of a pick-up truck. Water from onsite pit lakes or stormwater detention ponds will be used as well as sources of clean water off-site. An air quality control permit exists for the Aggregate Industries—Platte Valley Pit site. Operations at the site will be shut down when winds exceed 35 mph. ' 8.4 Litter Control ' Litter at the site should be minimal because the site does not receive materials that would normally contain litter. Broda personnel, on site at all times when the site is open for business, will police the site for inadvertent litter and place it in appropriate receptacles ' located on site. A trash dumpster is located at the entrance and is available for on site use by transporters. Litter picked up at the site and the trash generated in the office trailer ' Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 21 Revised June 16, 2010 I 1 will be placed into the dumpster on site. Litter blown into the pit lake, typically from off- site along Hwy-85, is picked from the lake on a regular basis by using the small boat or along the shoreline. I 8.5 Fire Safety The potential for fire at the site is limited to trees and brush located on the boundaries or the temporary trailer. Due to the inert nature of the materials delivered to the site there will not be any materials that can sustain a fire. Each piece of equipment used on site has a fire extinguisher on it. A fire extinguisher is placed in the office trailer. The most likely fire to occur on site would be an equipment fire. All Broda personnel will be provided with fire safety training, including the proper use of fire extinguishers. Equipment fires should be extinguished rapidly. The site is located in the Brighton Fire Department district. The Brighton Fire Department phone number will be posted, along with other Emergency Contacts, where it is clearly visible in the temporary building on site. Broda personnel will have access to radios and/or a mobile phone for emergency contact purposes. 8.6 Hazardous Materials Emergency Management Plan Hazardous materials inadvertently received at the Broda site will be removed and placed in appropriate containers for temporary storage. If a transporter inadvertently delivered hazardous materials, the company will be contacted and will be held responsible to remove the materials. Companies that inadvertently deliver hazardous materials more , than once will be removed from the list of acceptable companies that can use the inert fill operation. A notification that the materials were found, including a description of what actions were taken will be submitted to CDPHE and Weld County Health Department within 30 days of the event. A solid new or reconditioned 55-gallon drum with a removable top will be readily available or be kept on site and used to temporarily store hazardous materials inadvertently delivered to the site. Broda personnel will place the hazardous materials into the container. Only one type of material is permitted to be placed into the container. No mixing (i.e. acid and bases, oxidizers and oils, or other incompatible materials) of two types of materials would be allowed in any one 55 gallon drum. Additional 55-gallon drums will be purchased if necessary. If necessary, a professional hazardous materials management company will be contracted to properly dispose of the materials. A phone number of a hazardous material emergency response company will be posted with other emergency numbers at the site. An emergency response company will be called when necessary to respond to hazardous materials inadvertently delivered to the site. Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 22 Revised June 16, 2010 I I 8.7 Nuisance Conditions Nuisance conditions at the site are limited to blowing dust (fugitive emissions) and blowing litter. Applying water to traffic areas and temporary roads will control blowing I dust. An air permit currently exists for the Al operations at the site and will be followed. Litter is addressed in other sections of this plan. I i I I I I I I I I I I I I Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 23 Revised June 16, 2010 I 1 I 9 GROUNDWATER MONITORING PROGRAM 9.1 Groundwater Monitoring The Broda site is located in the alluvial plain of the South Platte River. Alluvial deposits are approximately 30 feet in thickness. Portions of the property are within the 100-year tloodplain of the South Platte River located approximately 500-600 feet from the site. The site was mined for sands and gravel with the soil types listed in Section 5.7 of this report. Groundwater is found near the surface and the alluvial aquifer will be monitored. The pit lake has been sampled in specific locations in lieu of sampling groundwater wells. Groundwater wells will be installed as necessary to adequately sample the groundwater in the future. The pit lake has been sampled twice and the results do not show any impacts to the groundwater. The pit lake sample results are available for review by CDPHE and Weld County. The proposed groundwater monitoring wells are at the locations shown on the map in Appendix 9, one up-gradient and two down gradient. A commercial well drilling company will install the groundwater wells. Well permit applications will be submitted to the Colorado Division of Water Resources to obtain permits prior to drilling. The , additional wells will be installed as described in the well completion diagram found in Appendix 10. Patrick Broda or other personnel properly trained in groundwater sampling techniques can conduct sampling of the wells. Groundwater would be sampled on a quarterly basis for eight sampling events and analyzed for the following analytes. • Appendix IA and IB constituents The groundwater sampling will be done semi-annually after the first eight quarters of data is collected and may be reduced to annual sampling with the approvals from CDPHE and Weld County. Samples will be taken using standard groundwater sampling protocols with samples delivered to a commercial analytical laboratory capable of analyzing for the analytes. Samples will be delivered or shipped to the commercial analytical laboratory the same day of sampling using chain of custody procedures and custody seals. 9.2 Groundwater Monitoring Network The three proposed groundwater monitoring locations on the site are denoted on the map found in Appendix 9. Any additional wells will be drilled to monitor the alluvial aquifer at the site. A licensed drilling contractor will be used to drill and complete the well according to the specifications shown in Appendix 10 and after submitting well permit applications to the Colorado Division of Water Resources to obtain well permits. Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 24 Revised June 16, 2010 I 1 9.3 Schedule, Analytes and Evaluation ' Sampling of the groundwater will be done on a quarterly basis for at minimum of two years to obtain sufficient background water quality information. Regular groundwater ' sampling events will be scheduled quarterly for eight sampling events to obtain the background data then every six months, or at a reduced schedule approved by CDPHE and Weld County, and continuing for the life of the site. Groundwater samples will be ' analyzed for appendix IA and IB constituents as described in the CDPHE solid waste regulations. Analytical methods will be as specified in EPA SW-846 or other appropriate sources and the laboratory results will be validated using standard methods. After the collection of eight sample sets, the owner will submit a report summarizing the data. These data will serve as the background data, against which future results will be ' compared using a statistical evaluation. The owner can propose to reduce the analyte list as well as a statistical evaluation procedure consistent with one of the methods specified in the regulations. It is currently envisioned that a subset of the metals and chloride will be selected for statistical evaluation and that an upgradient-downgradient control chart statistical comparison will be used. ' 9.4 Sampling and Analysis Plan 9.4.1 Sampling Methods Depth to water will be measured prior to purging. The elevation and coordinates of the reference point from which water depths are measured will be established by survey of ' the groundwater monitoring wells. Samples from the wells may be taken using micro sampling techniques. A peristaltic ' pump will be used with polyethylene or Teflon tubing. The tubing will be purged prior to sampling with at least three tubing volumes being purged prior to sampling. The tubing will be inserted into the well to a minimum depth of five feet below the water surface(as measured prior to sampling) and no more than ten feet below the water surface. Samples will be taken directly from the tubing as the water is removed after purging. ' In the event that groundwater monitoring wells are not available or are not acceptable for micro sampling techniques, based upon the regulatory review, purging and sampling may be done using disposable polyethylene or PVC bailers or dedicated polyethylene, PVC or Teflon bailers or commercially available purge pumps (i.e. GeoTech Squirt Pumps or similar). Disposable bailers will be suspended on new polypropylene rope. Dedicated bailers may be suspended on dedicated polypropylene rope. Alternatively, at the owner's option, dedicated pumps may be installed in the wells and used for purging and sampling. 1 ' Recycling Operations Plan Broda's Inert Fill AI - Platte Valley Operations 25 Revised June 16, 2010 1 If bailers are used to purge and sample the wells, the wells will be purged of three wellbore storage volumes (the volume standing inside the casing at the start of purging) or to dryness, whichever occurs first. 1 Periodic field analysis of pH, temperature, and specific conductance will be taken and recorded prior to collecting the sample. Purging will continue until these parameters have stabilized to within 0.2 pH units, 2 degrees C or F, and 10 percent of the specific conductance reading. Samples will then be collected as soon as possible after purging, but no longer than 24 hours after purging. Purge waters will be disposed of on the ground ' by the well from which the fluid was purged. If dedicated pumps are used, the wells will be purged of three pump and tubing volumes at a flow rate of 100 milliliters per minute or less and sampled immediately after purging; the flow rate during sampling will also be 100 milliliters per minute or less. Samples will be transferred directly from the bailers or pump discharge tubing into , sample bottles provided by the laboratory. Sample bottles and preservation will be as specified in the analytical methods employed, except that VOC samples will be chilled but otherwise unpreserved (consistent with CDPHE policy). Sample bottles will be placed in a cooler or other shipping container and chilled as soon as possible after collection. 9.4.2 Chain of Custody Chain-of-custody procedures will be used to track the sample from the time of collection until it, or its derived data, is used. A chain-of-custody form will be initiated at the time that the samples leave the site. Field personnel will complete all applicable sections of the form. The chain-of-custody forms will be protected from moisture by encasing them in plastic (e.g., Ziplock plastic bags) and placed inside the shipping containers. The chain-of-custody forms will accompany the containers during shipment to the laboratory. The shipping containers will be sealed with custody seals. Field personnel collecting the samples will be responsible for custody until the samples are delivered to the laboratory or relinquished to a commercial shipping company. Sample transfer requires the individuals relinquishing and receiving the samples to sign, date, and note the time of transfer on the chain-of-custody forms. Common carriers (e.g., Federal Express) are not expected to sign the chain-of-custody forms. However, the bill of lading or air bill becomes part of the chain-of-custody record when a common carrier is used to transport the samples. The chain-of-custody is considered complete after the analytical laboratory accepts custody of the samples (acceptance of custody is indicated by signature on the chain-of-custody form). A copy of the chain-of-custody record will be maintained along with other field records. ' Recycling Operations Plan Broda's Inert Fill AI- Platte Valley Operations 26 Revised June 16, 2010 9.4.3 Quality Assurance/Quality Control ' The following quality assurance and quality control (QA/QC) actions will be implemented to minimize the potential for biasing the analytical results by laboratory ' preparation, sampling, and transport activities. • Fieldwork will be performed by qualified and trained personnel including the site owner or company personnel. Persons performing the sampling will be trained by a professional qualified in groundwater sampling. • Samples will be analyzed by a qualified laboratory. The laboratory will use appropriate chain of custody, analytical, and QA/QC procedures. ' • A trip blank for VOC analysis may be included in sampling events at a frequency of one trip blank per year depending on whether questions arise relative to the quality of the analytical data. ' • Equipment blanks and field duplicates will not be collected on a routine basis because disposable or dedicated sampling equipment will be used; however, they ' may be prepared and analyzed if questions arise relative to the quality of the analytical data. ' • The full laboratory report, including laboratory QC data, will be attached to the monitoring reports submitted by the operator or consultant. • The laboratory results will be validated using standard methods. 9.5 Maintenance The condition of the groundwater monitoring system will be inspected during each monitoring event. The results of the inspection will be documented and any deficiencies ' will be remedied within 60 days of the inspection or at a later date as approved by CDPHE. If deficiencies, malfunctions or deteriorations are observed at other times, such deficiencies will also be documented and remedied within 60 days of discovery or at a ' later date as approved by CDPHE. 9.6 Reporting Reports will be prepared periodically and no less than one per four sampling events, or a ' minimum of once per year. The report will include a tabulation of the data (including water level data), statistical evaluations as appropriate, the results of the system inspection, and a description of any maintenance performed. ' Recycling Operations Plan Broda's Inert Fill Al—Platte Valley Operations 27 Revised June 16, 2010 After eight data sets are available, the owner will provide a report summarizing the data. The report may propose a reduced analyte list, if appropriate based on the data. All reports and/or copies of data will be provided to CDPHE and Weld County Health Department by May lst of each year along with the Recycling Facility Annual Reporting Form. 9.7 Assessment Monitoring In the event that analytes are above the statistically significant increase over background or an analyte is detected that was not detected previously, a verification re-sampling may be completed within 30 days. The verification sample can replace the original sample event in detection monitoring. Up to four verification samples can be produced per well sampling event. When a statistically significant increase over background is detected in the verification re- , sampling using a statistical procedure approved by CDPHE, the notifications, actions and procedures contained in Appendices B3 through B8 of the Regulations Pertaining to Solid Waste Facilities will be implemented. 1 Recycling Operations Plan Broda's Inert Fill AI-Platte Valley Operations 28 Revised June 16, 2010 1 10 CLOSURE PLANS 10.1 Notification of Closure Weld County and CDPHE will be notified within sixty days (60) upon completion of the filling activities and the termination of Broda's inert filling operations. Facility customers will be notified sixty (60) days in advance of the proposed closure date by placing signs of a suitable size at the entrance to the facility. 1 ' Recycling Operations Plan Broda's Inert Fill Al- Platte Valley Operations 29 Revised June 16, 2010 1 I I I I I I I Appendix 1 ' DRMS and Weld County Approvals I I I I I I I DEC-1-20005 OS:11F FROM:ROGRELFATE flDJETFTE3 570-37^c-SBSE O'1DOD 1- a T_,.__. _�3z?5_� P._ STATE OF COLORADO I DIVISION OF MINERALS AND GEOLOGY Depa,tnnt of Natural Resources 1313 Sherman St,Room 215 COLORADO DIVISION OF [Denver,Colorado 80203 MI N.ERA L S I Phone: )3)866.3567 FAX:0003)8328106 CEO L O G Y EICiAMAlION•M IN INC SAFETT•SCIENCE I November 15,2005 Bill Owens Governor Russell George Connie N.Davis Executive Dildor I Aggregate Industries Ronald`"'Cary Division Dlreaor West Central Region, Inc. Nat al Resource Mamee 1707 Cole Blvd.,Suite 100 IGolden,CO 80401 RE:Baetifill Notice—Inert Materials,Platte Valley Operation,Permit No.M-1989-120 IDear Ms.Davis: I The Division approves your request to regarding your Inert Fill Backfill Notice,per Rule 3.1.5(9),received on September 21,2005. We appreciate your cooperation on this matter. Sincerely, J it IThomas A. Schreiner Environmental Protection Specialist ' Cc: Carl Mount,DMG(via E-Mail) I I I I I - Office of Colorado Office of Actve and Inactive Alines Geologiml Survey maw'land Re9arnation nEC-1-8225 OE:12P FROM:PGGRE P'E ?-IDI._7 FR?EB 972-572- Th5,6" T:13234524515 R1 P.0.Box 72.31 Greee: 9 Bt'6-e Pax: 3)78--9956 626 Fex: (970)areseass AGGREGATE ' INDUSTRIES Fax Tex Mark Molen Front Connie N.Davis Land Resources Assistant - Fare (303)452-4515 Pager 2 ' Pharr (303)450-1600 Dal•: 12/1/2005 RC Breda Landfill at Plaffe Valley CC: ❑Urgent O For Review O Please Comment O Please Reply O Please Recycle ' • Comments: Following is a copy of DMG's letter approving the request to allow badcfi8 of irnpori material at Platte Valley. 1 1 1 - 1 i • Certified Mail-Return. Receipt No. 7002 0860 0007 5578 7622, ' November 7,2005 AGGREGATE Mr. Tom Schreiner INDUSTRIES Environmental Protection Specialist ' Division of Minerals and Geology 1313 Sherman Street,Room 215 Denver, CO 80203 ' Re: Notice of Material to be Imported for Backfill Permit No.M-1989-120, Platte Valley Operation Dear Toni: This letter is in response to questions raised in your letter of September 26, 2005 regarding Aggregate I Industries' (Al)inert backfill notice dated September 20, 2005. The main concern expressed was % whether or not the site is adequately bonded for the proposed activity. The backfill cost estimate referenced in your letter,which addresses backfl fling 8066 cubic yards of overburden in a stripped area ' of Cell 4,is only a portion of the reclamation for which this site is bonded. The Division holds a total reclamation bond for this site in the amount of$754,732. This amount was based upon the Exhibit L calculation prepared by AI and submitted to the Division on December 1,2003. The calculation for Cell 4 includes a total of 344,232 cubic yards of backfrll. Enclosed for your convenience in reviewing this matter are reduced copies of the Exhibit C and Exhibit F drawings. It is Al's desire to increase the area to be back-filled in Cell 4 to facilitate a reduction in the final groundwater lake surface proposed in Cells 2 and 4. The import of a potential 603,000 cubic yards of fill material as proposed in the Notice would accommodate the originally proposed and the ' increased backfill area The.approved permit for Platte Valley already provides for a variance in groundwater lake size in Cells 2 and 4 by as much as 25%, which would be an increase or decrease of 33 acres, without requiring a technical revision. - ' The area to receive the imported fill material is shown on the Exhibit F Reclamation Plan as Phase 4 and will further extend to the north boundary of the groundwater lake area_ Barlcfilled areas will be ' reclaimed in accordance with Exhibit E of the permit, as follows: The backfill material for this area will be placed and compacted to provide adequate stability for the anticipated future use. The final elevation of the bacloilled area will be at least 2 feet ' Aggregate Industries West Central Region, Inc ' 1707 Cale Blvd., Suite 100 Golden,CO 80401 Teiephone:303-485-1070 An Equal Opportunity Employer 1 ' Mr.Tom Steiner,Division of Minerals and Geology AGGREGATE November 7,2005 -Page Two INDUSTRIES ' above the estimated maximum local groundwater elevation. In addition,the final backfill elevation in this area will be as near to the existing and susounding ground elevation as possible(depending on the availability of backfill material). Grading will create relatively flat ' surfaces appropriate for industrial uses. Any slopes remaining will be reclaimed to a minimum 3H:1V grade. As final slopes are graded, topsoil will be placed to provide a growing medium for the revegetation cover used to stabilize the area prior to the final land use. (p. 10, Exhibit E, Platte Valley Pit Regular 112 Operation Reclamation Permit Amendment,July,2003) Clarification regarding reclamation in this area was also provided in responses numbered 13 and 14 of ' Al's December 1,2003 response to the Division's adequacy review as follows: 13. The reclamation acreage has been clarified on the revised Exhibit F, Reclamation Plan map ' attached_ The groundwater lake to be created in Cells 2 and 4 will be approximately 55 acres in size, or include roughly 40 percent of the proposed mined area Other areas of the mining pits will be backfilled for wetland/upland and industrial uses. If the configuration of the proposed groundwater lake changes, or the size changes by more than 25 percent of the proposed mined area, the applicant will provide a technical revision to the Division with the final groundwater lake size and configuration. I 14. The proposed final land rise for the Platte Valley site includes future industrial use. However, it is not the intent of the operator to develop industrial use on the site. It is anticipated that these areas will ultimately provide for industrial use, because the areas are zoned industrial by ' Weld County. The proposed amendment areas zoned for industrial use will be backfilled and graded by the operator. The bacl-filling will include a cover of at least 6 inches of topsoil. The areas will be revegetated with native grasses to provide stability and minimize erosion until ' future industrial land uses are applied. In response to your question regarding the maximum amount of imported inert fill material that would be stockpiled,waiting to be pushed into the excavated pit area at any one time, it is anticipated that _ imported inert materials will be placed on the same day as they are received and not stockpiled. Placement of inert fill will occur in an approximate one acre area at any one time and will continue in ' such area until the elevation of the backfilled area is in accordance with the permit,as noted above. The original application materials for Amendment 1 indicated that inert materials would be used for backfill,and AI responded to the Division's adequacy comment on this matter in the December 1, 2003 letter as follows: "If applicable, the applicant agrees to provide to the Division with (sic) the appropriate notices and affidavit certifying that the material used for backfrll is clean and inert in i 1 1 Mr.Tom Schreiner,Division of Minerals and Geology AGGREGATE November 7,2005 INDUSTRIES Three ' accordance with Rile 3.1.5(9) of the Construction Rules and Regulations." AI's September 20, 2005 Notice was submitted to the Division in accordance with that commitment. ' Thank you again for your time and consideration in this matter. If you have any further questions, please do not hesitate to contact me. Very truly yours, ' Connie N. Davis - Land Resources ' cc: Mr.Patrick Broda,Broda's Inert Fill Ms. Cindi Etcheveny, Weld County Aggregate Industries-WCR,Inc.-File 1 1 1 1 1 "dnoi _Lid km-WA vid I r &alddy i Le1HX3 \1; Vs ili ! Eli 1 1Li S \ 4 ) _ s° °m i 1 �/-" � I a ' \a \ I' I a EgE'888 8 3 l ( 40 n n n &s a i l j, h II 'k 3sg ( - I � ,I Ai' a I,h a ed i I JI op �. i t lit 3 ' , x 011 nl I 1 t el s f III ' 1lIP P 7y n °'5s Pik II __ �. IA �" I�t 7 i `i3 ;tS �� I I t` �Se I, 1 ii ii 1 j ., gig 'gpgn i 1 II i I, <� Iq 1 I kr, t l 6n'l Nro'Y fi'" .+". I "g��l� �a_�-" e__ �r�' • I i i • r- , -c::,-,,b,;;; ;-,...„,,1 : g---1-:, L-'1_,,, 2. 1 s'su (/ II II j \ e s` I -F r 3 I, I °' I \ x 4-- Lv ' 5` ;E- I I z ' Lb---la== a it I I 4 tt i : —I ;y 2 .s ) III I u 1 �-G a li � \off (I \�( I� I a , s b 0 g = d Iinoivi a1dJy I y onsi x3.. 1qq i 1 luau li ! 6 G I A`. tee s� . 7a F o, "' k. 15 G it O .6. t 551 I e_ � `,,,tri 1 ►1 $ F E I5 .5 .. ;8 % r /°'� Il i-le W� L @ Z in E '621blily Pt a wR l 4, ® e 1 k % US ° ° [ 5 hr l 13" ° W , I 3 + y ' IO I Ili i I J / II IEgg i� f; 6 ` iI .Dad _ 1 9t Y I a8 � F' i r k o - j I� it 1 � t 11 h ® b 1 �3!,- 1 ° IHill i Ki 1 1 s i 0 \J ` W � �,1 at $5^ En' � In at Iie `� • Alt a . $ le; .51Fa k!al i 1 Oi I COMP I q 1 ► j I I 1 , kk h 11 • 11 I . 1 I� ?El- Q � � 1 vim. 1 1 qq T 0 e s 1 k � eA. ►•1 . I 11 j , {I. \ L 1 � I � r I ALL �_flit Il a \J\�.� 1 1 3 ;a'"._ jyy I t a 3 to 4 & ° }' j Y. f. 1l e 1 1 rT `(l. \OO ^� ,A: 7 4 a8 T8 i•••8 8 S a 33 gilt I. e p ""'� I r \S.. ob+� tJ �L-� w l $a7 °3 P11 f "al-ir's pi',al ird + +1 lvi ai E . i. ® ( r� o d al, 1 2s`:F ail An £ d 33,3 1 ;lint a' I _ _ I\ w 1 nT VQ � R -('flf � L, I Il ' Certified Mail-Ruturn Receipt No. 7005 0390 0003 1200 6497 ISeptember 20, 2005 Mr. Tom Schriner AGGREGATE Environmental Protection Specialist INDUSTRIES Division of Minerals and Geology I 1313 Sherman Street,Room 215 Denver, CO 80203 I Re: Notice of Material to be Imported for Backfill Permit No. M-1989-120, Platte Valley Operation ' Dear Tom: This letter is submitted as Notice to the Division of Minerals and Geology of Aggregate Industries-WCR, Inc.'s intent to backfill inert structural fill generated outside of the approved permit area into the excavated pit at the above-referenced operation. In accordance with DMG Construction Material Rule 3.1.5(9), the following information is provided in support of this INotice: (a) Inert fill material will be obtained from a variety of off-site sources ranging from I excavation activities for construction of basements and buildings, land clearing, demolition projects, and road and highway construction. This material will be incorporated into the reclamation of the sand and gravel mine site operated under MLRB I 112c Permit No.M-1989-120, located at 1859 N. U.S. Highway 85, Brighton, Colorado. (b) The approximate volume of inert material to be imported and bacltilled as set forth in(a) above is estimated to be a maximum of 603,000 cubic yards. I (c) Enclosed is an affidavit certifying that the material to be imported is clean and inert, as defined in Rule 1.1(20). (d) It is anticipated that hauling of import material to the site and baclilling with the I imported material would commence upon approval by the Division of this Notice or, if the Division does not respond, within thirty(30) days of the Division's receipt of this Notice. Importation is expected to continue for a minimum of 5 years after commencing I the backfilling operations. (e) The imported material will be temporarily stockpiled in excavated areas of the mine and will be backfilled in accordance with the approved reclamation plan. (f) The area to receive the imported material for backfill is already incorporated into the Ipost-mining configuration and will support the approved post-mining land use, as set Aggregate Industries I West Central Region, Inc 1707 Cole Blvd., Suite 100 Golden,CO 80401 ITeiephone:303-985-1070 An Equal Opportunity Employer 1 Mr.Tom Sclainer,Division of Minerals and Geology AGGREGATESeptember 20,2005 INDUSAIS Page Two ' forth in Exhibit F of the original permit application. (g) The material will be placed and stabilized in accordance with the approved reclamation plan as set forth in Exhibit E of the original permit application. ' Thank you for your consideration in this matter. If you have any questions,please call me at (970) 336-6526. Very truly yon, Connie N. Davis ' Land Resources Assistant Fn closure cc: Mr.Patrick Broda,Broda's Inert Fill Ms. Cindi Etcheverry, Weld County Aggregate Industries-WCR,Inc. -File • 1 1 I I ' -AFFIDAVIT AND INDEMNIFICATION STATEMENT I STALL OF COLORADO ) ) ss. County of Weld ) I The undersigned Affiant is importing inert structural fill materials from a variety of locations within the state of Colorado,to the Platte Valley sand and gravel mine operated by Aggregate Industries-WCR, Inc. (AI)under Division of Minerals and Geology Permit No.M-1989-120,and located at 1859 N.U.S. I Highway 85, Brighton,Colorado. Affiant hereby certifies and'affirms that said soils are clean and inert, and that there are no known materials contained in said soils that would-significantly affect the inert nature of these soils,nor are there any acid forming materials or toxic producing materials in said soils. I Furthermore,by signing this Statement,Affiant shall indemnify and hold harmless AI in the event it should be determined that any soil provided to AI is contaminated with any regulated pollutant and/or poses environmental harm. Affiant shall assume all liability and costs associated with the removal, Idisposal,and negative impactsof any contaminatedmaterial provided to Al. Dated this al/t1Lilay of (/�L(9 rat ,2005. I AFFIANT: ' - Broda's Inert Fill Company Name I By: 44jjfk, I Subscribed and sworn to before me this,this 4,0-eLday of at W'U L , 2002 by CJ &Dieu an (0/O/U P., , of B61 C aLLI:O"—iJ . '.._sg�r�\\.s nd and official seal. I :$ \ s CAROLINE D..i y • /I �� ( ! L)HULL �O ( C�J I �'4 �Q S Notary Public My --- p I �.�i�i r1� _' CoCon.: ues: 1 I . I . I I I September 20,2005 I . S • Ms. Cindi Etcheveny AGGREGATE I Environmental Health Supervisor - Weld County Department of Public Health &Environment INDUSTRIES 1555 North 17th Avenue IGreeley, CO 80631 - Re: Inert Fill Operation at Aggregate Industries' Platte Valley Operation I Weld County Use by Special Review Permit AmUSR-905 State Division of Minerals and Geology Permit No.M-1989-120 I Dear Cindi: Mr. Mark Molen of Molen& Associates has previously corresponded with you regarding an agreement between Aggregate Industries and Patrick Broda for the import of inert fill material to Aggregate Industries' Platte Valley sand and gravel mining operation as referenced above. Mr. Molen indicates that you advised that Weld County does not need any additional permits for such I filling operations, however he requested that I provide you with a copy of the notice for such activity as required under the State Division of Minerals and Geology permit. I am therefore enclosing for Weld County records a copy of the Notice of Material to be Imported for Bacicfll . I and supporting Affidavit as referenced therein,which are being submitted to the State Division of Minerals and Geology. ' Very truly yours, :�U h. al . IConnie N.Davis Land Resources Assistant IEnclosure . I cc: Mr. Patrick Broda Broda's Inert Fill Aggregate Industries-WCR,Inc- - File I , Aggregate Industries ' West Central Region, Inc 1707 Cole Blvd-, Suite 100 Golden, CO 80401 I An Equal Opportunity Employer Telephone:303-985-1070 1 1 September 20,2005 AGGREGATE 1 INDUSTRIE- Mr.Mark Molen Molen&Associates , 2090 E. 104th Avenue,Suite 202 Denver,CO 80233 ' Re: Inert Fill Operation at Aggregate Industries' Platte Valley Operation Weld County Use by Special Review Permit AmUSR-905 State Division of Minerals and Geology Permit No-M-1989-120 Dear Mark: Enclosed for your records is a copy of the Notice of Material to be Imported for Backfill and the supporting Affidavit as referenced therein. These documents are being submitted to the State today. A copy of the letter transmitting copies of the enclosed documents to Cindi Etcheverry at Weld County is also enclosed for your records. Thank you for faxing copies of your communications with her. Very truly yours, Connie N. Davis Land Resources Assistant Enclosures 1 I Aggregate Industries ' West Central Region,Inc 1707 Cole Blvd:, Suite 100 Golden,CO 80401 Telephone:303-985-1070 An Equal Opportunity Employer I I MOLEN & ASSOCIATES, LLC ENVIRONMENTAL CONSULTANTS I 2090 E. 104th Ave., Suite 202 4 Thornton, Colorado 80233 Office 303-450-1600 ♦ Fax 303-452-4515 IAugust 10,2005 IMs. Cindi Etcheverry Environmental Health Supervisor I Environmental Health Division Weld County Department of Public Health&Environment 1555 North 17th Avenue IGreeley, CO 80631 - Re: Aggregate Industries, Inc.Reclamation Plan , IInert Filling at Platte Valley Pit by Patrick Broda Dear Ms. Etcheverry: - IThis letter confirms discussions we have had concerning Aggregate Industries, Inc. Platte Valley Pit (AmURS-905)and the importation of inert materials by an outside contractor,Patrick Broda. The result of the conversations is that Aggregate Industries is allowed to import additional inert materials into the Platte Valley Pit acdording to the stipulations in the permit. Aggregate Industries, Ind. or Patrick Broda do not need any additional permits from Weld County to begin filling operations. I Patrick Broda has signed a lease agreement with Aggregate Industries to import inert materials into the • Platte Valley Pit. Mr. Broda is aware of your acknowledgement that the permit allows the importation I of inert materials as defined in the Regulations pertaining to Solid Waste Sites and Facilities. The attached copy of email I received from you on August 2,2005 describes that acknowledgement. The Division of Minerals and Geology will be contacted to confirm the importation of inert materials I by Patrick Broda is acceptable to them. Once the Division of Minerals and Geology acknowledges that the importation is allowed,filling of importation of inert materials will begin. It is expected that the importation will begin sometime in early September 2005. . IIf you have any objection to the information in this letter please contact me immediately. I Thank you for your assistance and immediate attention to this matter. Yours truly, I MOLEN & ASSOCIA1ES, LLC H " IMark A. Molen cc Mr. Patrick Broda 1 I I Jntitled Stationery mailbox:///Cl/WINDOWS/Application%20Data/MozillalProfilesldef... Subject: Aggregate Industries From: "Cindi Etcheverry" <cetcheverry@co.weld.co.us> I Date: Tue,2 Aug 2005 22:45:23 -0600 To: MMOLEN@gwest.net ICC: "Kim Ogle" <kogle@co.weld.co.us>, "Donald Carroll" <dcarroll@co.weld.co.us> • • Hi Mark, I have reviewed the aggregate industries, Inc. AmUSR-905 file and Reclamation Plan. It does appear other sources of inert materials are approved for backfilling the site in the Reclamation Plan. The map that you referred to as dated 2/27/04 and titled Platte Valley Pit AMUSR-905, Sheet 2,was not present in the file. However, the resolution and Amended Special Review Permit 905 does require the facility to comply with the I requirements of the Division of Mineral and Geology Minded Land Reclamation Permit 112 to conduct surface extraction of construction materials and reclamation of the site. I - Please also note in accordance with the Regulations pertaining to Solid Waste Sites and Facilities, inert material includes, but is not limited to, earth, sand, gravel rock, concrete which as been in a hardened state for at least sixty.days, masonry, asphalt paving fragments, and other inert solids. IAdditionally, if the site is expecting a change in traffic count, you may want to get a hold of Donald Carroll in Public Works to discuss whether if changes in the road agreement will be required. I . Cindi Etcheverry Environmental Health Supervisor Environmental Health Division I Weld County Department of Public Health& Environment , 1555 North 17th Avenue Greeley,CO 80631 Phone: (970) 304-6415 ext 2220 I Fax: (970) 304-6411 E-mail: cetcheverryPco.weld.co.us I • I I - • I ' 1 of 1 8/10/05 5:10 PM I 1 MOLEN & ASSOCIATES 2090 E. 104'" Ave., Suite 202 Denver, CO 80233 FAX COVER SHEET I `j70- 30` _ 6(05- DATE: 7/6/05 - TIME: , 11:54 AM — X277rr ' To: Cindy Etcheverry FAx: 970-304-6411 WELD COUNTY FROM: Mark Molen PHONE: 303-450-1600 I Molen &Associates FAx: 303-452-4515 RE: Inert Fill at Aggregate Industries Platte Valley Operations cc: INumber of pages including cover sheet: 7 IMessage Ms. Etcheverry: I talked with you earlier today concerning this site. I am sending the information on Reclamation Plan for the site with the particular area where it discusses the other sources of inert materials for backfilling the site. This information is underlined on page I 10 attached. Similar language is found on the maps dated 2/27/04 and titled Platte Valley Pit AMUSR-905, Sheet 2. I will get you the DMG permit number as soon as I can. I have contacted my client, Pat ' Broda, and Aggregate Industries to get the information and have yet to hear from anyone. Please let me know if you have any questions or concerns. Pat Broda would like to start I assisting with backfilling as soon as possible. Thank you. I • IMark Molen • I . . I I I - I I ',...IB Tel I � I I . IF \(I. - l L 1 K I ti I i , R / I Y i - / / seveneni ,a,° I - --- ---- 1 rimI rli 1 OE I 1 - •__ Si2g2 F— , I; 1 ern o o C••_ O co I inn � I . w En w , \._ 4 p 7 N 1 ua/ > c w A-SA ElArLSC'1P2.10-WA 1 I w,d S 1 1\ -k-.7 ' 1 : f ____________: ci, O,-_,#°\2---- --_, _ '_-- ;-1 I 1 a �� n aI/ i — -- 'vac`•'2'" _:I _ _ ' vens 2„_u asI— : N8 <?LE 311.3 _-_ _ __--- . I I I I I I I I I Appendix 2 Site Location Map I I I I I I I •7 (V L". r I Ef., ° ED .7.: I i Li., .. ED > _ ID C 6 U ._ r.., W 4' c_ c 1 a) d L _I S T. i in N a) cIE 2 M a) © 0 a) 0 I ° U 15 L J Pb AII!peold E Q c o CO iro- E a ( co .15 m ao w N C cp I Vii`; 18MOj E C a coa � Q iii 03d Cil O a Q 3 > c 0+--+ J N L!1 C J CD L Q Y Ca O aJ ` ~ r c I O _ ao �- E J — _x :. m .� m N -�. c ,...„1.___ ___1 0 _it - o m OW r _"`--_s_. O _ �'�} v ` -�`Q N— W c W Q ) -O: co CA CO I U to N N a w y al L.- CC) v„ N 1` J C u - L I \ NEB VIC 0° iLi t y r—` EE a ° a � U •EG I • Q F.- I > = z II UCO O t a) C y N o W —� r- -- p^I9 ope�ofo� a ° L _ y ma �` Q, a ci n c L N U.5. )1, r� ' 1 W I- _--- I 1S�uot6uluseM o Up Ql z= U_ ' � ° L N Huron St coi Q a � O > _ °_ 2 o LL 1 W C N o � L NN ...-• CS en QCO O cc V O1 O o . r -tr. N I @ E. m CO rn5, /2 1 P^f9 IlaMo i 0o 0O I I I I I I I Appendix 3 IBroda Fill Area Entrance and Exit I I I I I Topo USA® 8 I •• �� irr t ♦• 1 J j •. il N I . S.. " x" .a ' .. Enirance/Exi D GOO ;b Rp -r P 1 _ -iv, ��( it I t 6 • � . • ` c / 4r 1 !r 4f • . 1' t - T j•' ' I 1 .> �Y'lf.rt I - , y ,r T'1L-- P'. .Ill 1 • •• J� .t. `' _ 1 - -‘ t ter•• .... SI it • I' allig----• ' 14;1 Aggregate Industries Platte Valley Pit fir �tt .t T' ,` .j • ri` lQ• � .y , L. • t f ." rail '1, .,�,rs - . 1 + 'Y �R Mint. �-" S ; �, ' �?' 1 7 - 1 �' ►�_� g : �i- -�as� 4. ♦ 1 1 la f 1p' l y I _ I • • \ , p • r if I • I • r• I I. • • y 0: 1ailliy • I , , • • if I - 1 I . WELD cOJNTY_FED;.+ , ! , Ll.l c. irl t,. •t-ir- - r— — 4 �f'' t . . 6' ' ', • , ._• %.0 T• a r m` 1 ' . . >✓ 1 lit- Serb' , ♦ ♦ • 1 .1 t 't e . - 1 1 b . ' j I + r1 J. 1f 1 1 . - + ,. 1. I l 04....• a r er . . . . . .. , . - .,.... _ ..„_is; .- i 1.1 • ,i tie 4 II\ 4.de /). 1 SDI. Data use subject to license. tr, Scale 1 : 11,200 * 8 USA® iii -a 0 200 400 600 800 1000 © DeLorme. Topo . MN 0-E - r" _ _ 4 a 100 ?00 300 400 500 ' www.delorme.com 1" = 933.3 ft Data Zoom 14-2 1 t 1 Appendix 4 ' Topographic Map and ' Pre-Mining Conditions 1 1 °�e1 E CLi o 1. O av m o I-I= co o • n ilk . -gip, -� w.-I --\ co :,:;,.„-.-.,,,.„-.4...1!11 \- _. 6= r,- n r'. ryo h © �� ' w o oti it r dvnadle `/ tau c O -coal �- o, / osi� vi - tri ) m fl /— I's in f1 I ma ----II— � 51 _�N (� �s� b_ ..�. / I\I r/ \ _ ___1_ _ __ ___ i__S N JnU c, [_, L fl'.. 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C em „ �t�$,. z .ate. :afIl°'" ' 1 '-{.-7-'° f-ti� ''�n�'"{ �-at ' 'r L"' ' - xt.` 't c, xx,3- fi 1 n! * Ae p '"':e pVAS, eN s. t z d} ,'- '' - %.*.,-; *Sikh'µ,t. r T"v" kL�"f, t+ 'fi'": ' x I 1 �'". dz +e t . h' `.v''"3 _ '3 1;4'.f' #as h .- '* "x°' �s ,,,.t� ..4.:::.\•-.5:.Z a '''''''':k sill- r�,..+,-^ sue`)4--,. ,, :$ .Y. �k,-�?$e$.]�N Ul Fk 9 t 't -, �I<S g j I I I I I I 1 Appendix 6 Geotechnical Report ' by Earth Engineering Consultants, Inc. 1 1 1 t 1 June 10, 2010 EARTH ENGINEERING CONSULTANTS, INC. ' Molen and Associates, LLC 2090 E. 104th Avenue, #205 Thornton, Colorado 80233 Attn: Mr. Mark Molen ' Re: Broda Inert Fill U.S. Highway 85 and County Road 6 Weld County, Colorado ' EEC Project No. 1102028 Mr. Molen: ' On April 30, 2010, a senior project engineer from Earth Engineering Consultants, Inc., ' (EEC) observed fill operations at the Broda Inert Fill site at U.S. Highway 85 and Weld County Road 6 north of Brighton in Weld County, Colorado. At that time, Pat Broda explained the process used to place inert fill material over approximately 30 acres, in ' depths on the order of 30 feet, within a water filled manmade pit left from the extraction of aggregate from this area. It is expected that the reclaimed land area from the inert fill placement will be a possible building site at a future date. ' We understand the materials being placed at the Broda site consist of roughly 80% soil and 20% inert fill (which is typically concrete or similar/like materials). The materials ' are dumped onto the existing ground surface and placed in the impoundment by pushing the materials into the water, over the edge of embankment. It is anticipated that fill placement will continue for at least five years to fill the 30 acre parcel. We understand a ' portion of the lake will remain to the west of the fill area. ' ANALYSIS AND RECOMMENDATIONS ' Through placement of the inert fill material, potentially developable land area is being created in the former aggregate mining area. Although the near surface portions of the ' in-place fill materials are compacted through continual truck traffic to deliver additional fill materials, deeper fill materials would be expected to be in a relatively loose condition. 4396 GREENFIELD DRIVE WINDSOR, COLORADO 80550 (970) 545-3908 FAX (970) 663-0282 Earth Engineering Consultants,Inc. EEC Project No. 1102028 June 10,2010 Page 2 ' It is not expected that the materials placed in the outlined manner could be used for direct support of structure foundations. We believe that the alternatives for future support of buildings in the fill area may involve improving the placed material to provide suitable support for lightly loaded structures or may include the use of deep foundation extending to the underlying bedrock. Deep foundations would likely be needed for more heavily loaded structures. ' Improving support characteristics of the in-place fill materials, would in general, involve ' densifying the in-place materials. Surcharge loading of those materials could be an efficient way to densify and consolidate the in-place materials rendering them acceptable ' for support of lightly loaded structures. In general, the weight of the surcharge load should be greater than the anticipated increase in load from the building construction. ' Leaving those surcharge loads in-place on the order of 6 months or greater would be required to effectively consolidate of the underlying materials. We understand the adjacent aggregate mining operation could utilize the in-place fill area for stockpiling aggregates over a period of time. Stockpiling of aggregates in various ' areas on the fill site should be considered for surcharge loading. Care would be needed to rotate stock piles into "virgin" areas to effectively surcharge the entire site. An alternative densification procedure could involve use of deep dynamic compaction to densify the in-place materials. In general, deep dynamic compaction involves the ' repeated dropping of a large weight on the surface of the materials and thereby densifying in-place soils. Deep foundations including drilled piers, geopiers, driven piles or similar types of ' foundations could be used to extend building loads to bear on underlying bedrock. If preloading or surcharge loading is not used for the in-place materials, main floor levels should be supported on structural floors above the subgrades to reduce potential for settlement of the floor areas with settlement of surrounding fill materials. For this approach, some settlement of areas adjacent to the buildings and within pavement areas ' could occur over time with consolidation of the in-place fill materials. If surcharge I . Earth Engineering Consultants,Inc. EEC Project No. 1102028 ' June 10,2010 Page 3 ' loading is used and deep foundations utilized for support of heavier foundation loads, slab-on-grades could probably be used along with expected reduction in settlement in adjacent landscape and pavement areas. ' Specific borings completed at the time of construction will be needed to provide specific recommendations for building support on the site. It should be noted that building in fill areas is not uncommon. The inert fill placement on The Broda Site provides the land ' area for potential future development. ' We appreciate the opportunity to be of service to you on this project. If you have any questions concerning this report, or if we can be of further service to you in any other way,please do not hesitate to contact us. Very truly yours, ' Earth Engineering onsultants,Inc. • r.:38 al; st Er os. 1 ......... Ethan P. Wiechert, P.E. Senior Project Engineer EPW/dla 1 1 1 Appendix 7 ' Reclamation Plan and AmUSR-905 Permit Plans 1 1 1 1 1 1 I EXHIBIT E Reclamation Plan Final reclamation for the Platte Valley Operation will include creation of groundwater lakes and backfilling. The backfilled areas will include pastureland (with areas of created wetlands) and land for future industrial use (see the Reclamation Plan Map, Exhibit F). Some of the created ' wetland areas will provide mitigation for the adjacent Wattenberg Lakes site (Permit Number M2001008), while other areas may be used for wetland banking. The size of the groundwater lakes and backfilled areas will depend upon the availability of backfill materials, ' but the groundwater lakes will be no greater than 100 acres and no less than 10 acres. As backfilling occurs, the areas within the currently permitted site boundary will generally be backfilled for pastureland/wetlands while the mine cell within the proposed amendment area will be backfilled for future industrial use. The office and shop buildings and concrete batch plant will remain on the site following reclamation. ' In this area of Weld County, mining, water storage, and industrial businesses are predominant land uses along the State Highway 85 corridor. In addition, the western side of the mine site consists of riparian areas along the South Platte River. Therefore, the combination of proposed post mining uses is compatible with surrounding land uses. The remaining area within the proposed permit boundary will consist of access roads and reclaimed or otherwise undisturbed land. The approximate acreage of each of these areas is: ' Final Land Use Area(acres) Backfilled for wetland/upland areas 30 ' Backfilled for future industrial use 19 Groundwater lake and backfilled for 52 wetland/upland areas Groundwater lake and backfilled for future 32 industrial use Access roads 1 Reclaimed or undisturbed land 56 TOTAL 190 ' Some roads inside the proposed amendment area and existing permit boundary will remain for accessing and maintaining the wetland mitigation and banking areas and CCWCD wells. Conveyor systems will be removed from the site during final reclamation activities. Roads not ' necessary for future access and other disturbed areas associated with the conveyor system will be reclaimed with vegetative cover to stabilize the soil and minimize erosion. ' As mining progresses, overburden and process fines will become available and used for backfilling of the excavated mine cells. Additional overburden, process fines, and inert material from the Wattenberg Lakes mine site (Permit Number M2001008) and other sites will also become available for backfilling of the mine cell areas. ' plane Volley Operation DMG 112 Permit Amendment Page 8 Backfilled Areas In Phase 1 of the reclamation, mining Cell 1 will be backfilled to create intermixed wetland and upland pastureland as mining progresses. The created wetland areas will provide mitigation for ' the adjacent Wattenberg Lakes site (Permit Number M2001008) and a source for wetland banking. Created slopes will generally be shallow and flowing, but will be at a minimum 3H:1 V. The final elevation of the backfilled area will be determined by estimates of the local groundwater elevation. In general, the mine cell will be backfilled to a height approximately 2 feet above the average groundwater elevation. Although the backfilled ground elevation may be below the high groundwater elevation in the created wetland areas, backfilled elevations will ' still be high enough to prevent permanently exposed groundwater. It is anticipated that the majority of the backfill material for Cell 1 will be composed of fines from the on-site processing facility, but overburden material from the site and the adjacent Wattenberg Lakes site may also be used. For reclamation during Phase 5, overburden material will be available to backfill mining Cell 5 for industrial use, including the existing concrete batch plant. Additional overburden material ' will also be available from the adjacent Wattenberg Lakes site. The backfill material for this area will be placed and compacted to provide adequate stability for the anticipated future use. The final elevation of the backfilled area will be at least 2 feet above the estimated maximum ' local groundwater elevation. In addition, the final backfill elevation in this area will be as near to the existing and surrounding ground elevation as possible (depending on the availability of backfill material). Grading will create relatively flat surfaces appropriate for industrial uses. Any slopes remaining will be reclaimed to a minimum 3H:1 V grade. As final slopes are graded, topsoil will be placed to provide a growing medium for the vegetation cover used to stabilize the area prior to the final land use. ' Groundwater Lake and Backfilling ' During the concurrent reclamation in Phases 2, 3, and 4, the mining cells will be graded to create groundwater lakes. The combined surface area of the groundwater lakes will be no greater than 100 acres. Although reclamation during Phase 2 will create a groundwater lake within Cell 2, ' Phase 4 of the reclamation will likely create a groundwater lake that combines Cell 2 and Cell 4. During reclamation and creation of the groundwater lakes, areas of Phases 2, 3, and 4 may also be used as sedimentation basins for the on-site processing facility. ' Reclamation in Phases 2, 3, and 4 will include backfilling, grading, and seeding to create groundwater lakes from the mining pits. As grading and seeding is completed in each phase, the ' groundwater lakes will be allowed to fill, reducing the extent of disturbed area during the mining operation. However, the final size and extent of the groundwater lakes is not fixed. Although the groundwater lakes will be created and stabilized for final reclamation, they may be partially ' or completely backfilled to reduce their overall surface area. As overburden and other material becomes available from the site and the adjacent Wattenberg Lakes site, the lakes will be backfilled to create areas for either pastureland with created wetlands (Phases 2 and 3) or future ' industrial use (Phase 4). Since parts of Cells 2, 3, and 4 may also be used as sedimentation basins, it is likely that process fines will also compose a portion of the backfill material during ' Platte Valley Operation 0MG 112 Permit Amendment Page 9 1 reclamation Phases 2, 3, and 4. The final surface area of the groundwater lake will not be less than 10 acres. For the backfilled areas in Phases 2 and 3, the final ground surface will contain slopes that are ' generally shallow and flowing, but will be at a minimum 3H:1 V. The final elevation of these backfilled areas will be determined by estimates of the local groundwater elevation. In general, the backfill will be to a height approximately 2 feet above the average groundwater elevation. Although the backfilled ground elevation may be below the high groundwater elevation in the created wetland areas, backfilled elevations will still be high enough to prevent permanently exposed groundwater. ' Portions of the groundwater lake that are backfilled in Phase 4, including the proposed amendment area, will be backfilled for future industrial use. The backfill material for this area will be placed and compacted to provide adequate stability for the anticipated future use. The ' final elevation of the backfilled area will be at least 2 feet above the estimated maximum local groundwater elevation. In addition, the final backfill elevation in this area will be as near to the existing and surrounding ground elevation as possible (depending on the availability of backfill ' material). Grading will create relatively flat surfaces appropriate for industrial uses. Any slopes remaining will be reclaimed to a minimum 3H:1 V grade. As final slopes are graded, topsoil will be placed to provide a growing medium for the vegetation cover used to stabilize the area prior ' to the final land use. As groundwater lake slopes and backfilled areas are graded, topsoil will be used to provide a growing medium for vegetation. Depending on groundwater elevations, the final surface elevation of the backfilled cell may be below the existing and surrounding ground elevation. Any slopes remaining will be reclaimed to a minimum 3H:1 V grade. tReclamation Measures/Materials Handling ' The mining and backfilling will create the rough topography for the land uses. The backfilling and grading will be done to provide stabilized pastureland and future industrial areas and to r, uinimize erosion. The backfill material will consist of native bedrock claystone, process fines,. overburden, other inert materials, and topsoil. The material will be generated from the Platte Valley Operation, the adjacent Wattenberg Lakes site (Permit Number M2001008) and other sites. There will not be known toxic or hazardous materials in the backfill material. ' Additionally, it is not likely that acid forming or toxic materials will be encountered during mining. ' The mining will not leave highwalls on the property. There will be no auger holes, adits, or shafts left on the property. ' Topsoiling The top two to six inches of soil on the property and within the proposed amendment area is generally classified as topsoil. This layer includes the root zone of grasses and crops, which will ' be stripped and stockpiled separately. By using concurrent reclamation techniques,the topsoil is ' Platte Valley Operation DMG 112 Permit A mendment Page 10 1 not expected to remain in stockpiles for more than one to two years. If the stockpile remains more than one growing season, it will be seeded with a fast growing vegetative cover to prevent erosion. All topsoil will be retained on-site to reclaim the backfilled mine cell and other areas disturbed by mining activities. Where required, topsoil will be replaced to a depth of ' approximately four to six inches. When necessary, stripped topsoil will be stockpiled parallel to potential flood flows to reduce the risk of inhibiting the flow. Throughout the mining and reclamation phases, the amount of topsoil stockpiled will be limited by continuously using it to cap backfilled areas. Revegetation ' As mining operations are completed, areas for reclamation will be graded and shaped for revegetation. Runoff or excess water from adjacent areas will not be allowed to flow over slopes being graded and seeded. If needed, berms will be constructed to divert excess water and dispose of it in a safe and non-erosive manner. ' Upland Areas. For backfilled or disturbed upland areas, the reclamation plan includes revegetating with appropriate seed mixes to minimize erosion and reestablish natural terrain. The grass mixture below was selected to be long lasting and regenerating. The ground will be fine graded prior to seeding and fertilizers will be applied according to recommendations from the Soil Conservation Services: Groundwater lake side-slopes below the anticipated water level will not be seeded. Based on the soils in the area, the following upland seed mixture is ' recommended: Area Cover Application Rate' ' Upland Grass Seed (%) (#PLS/acre) 1 Vaughn Side Oats Grama 30% .35#PLS/ac. Grenville Switchgrass 20% 0.5 #PLS/ac ' Lovington Blue Grama 20% 0.3 #PLS/ac Barton Western Wheatgrass 30% 2.4 #PLS/ac Application rate is for drilling the seed. If seed is to be broadcast, the application rate will be doubled. ' Upland grass seed will be planted with a drill equipped with depth bands and press wheels. The seeded areas will then be covered with straw mulch at a rate of 2,000 pounds per acre. The straw will be crimped into the soil to control erosion until the grass becomes established. ' If a significant invasion of noxious weeds occurs after seeding, the weeds will be mowed before they can go to seed. The areas will be mowed periodically for additional control as needed. Mechanical control will be used as a first priority. Chemical methods will only be used if no other alternative produces acceptable results. ' Wetland Areas. The replacement wetland areas and areas to be used for future wetland banking will be planted and seeded with native wetland plants. A detailed revegetation plan for the ' Platte Valley Operation DING 112 Permit A mend/neat Page 11 1 I — . wetland areas is available in the Clean Water Act Section 404 permit application for the ' Wattenberg Lakes site (Permit Number M2001008) submitted to the Army Corps of Engineers. Water—General Requirement To minimize the effect on the prevailing hydrologic balance, the operator shall: ' a. comply with all applicable Colorado water laws, b. comply with all applicable Federal and State water quality laws and regulations, c. comply with all Federal and State requirements for dredge and fill, and d. regrade all sediment and siltation structures after mining is completed unless such ' structures are to be used for wetlands mitigation. Groundwater—Specific Requirements The operation will not affect groundwater quality on or off the site. The operation will comply with State groundwater quality standards. Due to the absence of sources of potential pollutants, groundwater quality monitoring is not required in this operation. Wildlife ' -- The proposed reclamation plan does not propose to create wildlife habitat. All activities will be planned considering the safety and protection of wildlife on the property. Some species may be temporarily displaced by the mining activities,but these species are expected to re-establish with no difficulty after the reclamation has been completed. The creation of the lake and wetlands may create additional opportunities for aquatic birds, mammals, and fish. ' Platte Valley Operation DUG 112 Permit A mendment Page/2 1 1 1 Appendix 7 AmUSR-905 Permit Plans • C,f61ie1311 - �^=� ti .nr o0lwvisalvm 31V031:16DY xouewx�o .ann .e u.o a+3 5i liri r CO+.0 Ur V «Ouvwri»n C OWNS,.1 m�w OM a.T�1�Vll�l.i�� ' eaili dV t cos-asnwd III d�li aie6e,ddr lid A3 1'VA 31171d , V 4 T^ tti t t` . ' - aawaao anw �- , — � t Ili;r� I Y r 3, �ycp K �. �+ ₹ ' `/• 't ty/' 1 1 i - `I E E i E l s i ii Q •y • . • 1X / f/ 11y ��` p j I. P La f i $ �, ' ,1 t i gI ! I l Ijr d }a ti s � i l "1 l lilt • •/ wwww_ww h, I -5: � il . . iiii 9i wo�� II .Gi1 ...... . ,. , i.- .0 0 �3, , -- r--te=_-�.--- '�1 �Yr , II i �';��i..�` fill =z: ---- _, �� 1I " h v . 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'� �• \9,9 � 9 3 F€1 P 1 3 F:O.° II ;, , , E₹ I y6 O Idry i. .i3. I ,_ - IL I l. mwa-CL`- ' �I;i is It' 1, �r \� li i V -1'I 411 \� ' III �\ I . ��sl i, € �� pli t j 11111 V I .�1� e, I 1'0 �H '1 v ill iES 0 • r`•--„,..1.1 '® e rIl I I b i �� d �.�I III® L si 4 • i 11..—\ 3 'r r s 1 .\ 1 .3 it t y �gg I I I 0 c., o 1 f 0 is I 'r II f � �1 i' Ta.�� 'IIII IL8 If .1 II s \ 1 I I ��A DS .1 II A� g ' . 11r'v. �,,' v - I(ff�\ eo a o 'dejig yi ! ii Ii ki i IS'� ifiit ii r 311 to ) IF q ( t n4 ba PE O 811 II1 3₹p7 F_€E AEI id?I d:$$31 5.3,3 d ® i tr: i. p \ DSO' p e p 17 i a 1\ r ! N. \\.. oo\_-,-: ` II Appendix 8 Records of Nearby Wells t 1 1 1 1 InfoMap Technologies Incorporated 1 T�` Environmental FirstSearch Report 1 1 Target Property: BRODAS AI-PVP 1859 N HWY 85 AND WCR 6 BRIGHTON CO 80603 Job Number: BRODA AI-PVP 1 PREPARED FOR: Molen & Associates, LLC ' 2090 E 104th Avenue, #205 Thornton, CO 80233 by Satisfi, Inc 720-200-9472 02-26-10 Env innin ere tat F_7 'x '42,. FIRSTS Tel: (610) 430-7530 Fax: (610) 430-7535 Environmental FirstSearch is a registered trademark of FirstSearch Technology Corporation.All rights reserved 1 I Environmental FirstSearch ' Site Information Report Request Date: 02-26-10 Search Type: AREA ' Requester Name: Brian Peterson 0.10 sq mile(s) Standard: WATER WELLS Job Number: BRODA AI-PVP Filtered Report Target Site: 1859 N HWY 85 AND WCR 6 BRIGHTON CO 80603 ' Demographics ' Sites: - 160 Non-Geocoded: 0 Population: NA Radon: NA • I Site Location Degrees (Decimal) Degrees (Min/Sec) UTMs Longitude: -104.820341 -104:49:13 Easting: 515331.744 I Latitude: 40.019224 40:1:9 Northing: 4429696.279 Elevation: N/A Zone: 13 Comment Comment: Additional Requests/Services ' Adjacent ZIP Codes: 1 Mile(s) Services: ZIP Code City Name ST Dist/Dir Sel Requested? Date ' 80621 FORT LUPTON CO 0.41 NE Y Fire Insurance Maps - No Aerial Photographs No Historical Topos No , City Directories No Title Search/Env Liens No Municipal Reports No Online Topos No II I 1 I II my Environmental Fir stSearch S$5earCri from Area 1 Mile Radius � ��FIRSTS Q, ,, )-� Single Map: i . s ue, ...,..„..„ :::.', 1.... 859 N ►1W`;i` &5 AND WCR 6 , BRIGHTON', CO- 80503 • 1 j / N.,.... 1 \ 3) '''' , i L --( r ``I , .\,\,...„ , , ,, . . otii, 4,,,, , . . _ \, F L 1.S9 11. j in !1' 1 ! __ 1 A 01 5 A •: 1t 44 71 Ax ti. I • - A 11 74 31 ,g E0 ,, AT k' ' La A A 664 ( 1428 ; A7--- 6 7,3 53 E 1V 1 29 13 % A tk" A fit` 2 4 1 4 I\ 20 ' 140 —I ___i � `r k Q. 45 b X143 �4 —� 1 r b 2 92 g 122 s A. 0 IOAi b12fi 4 I141 te61 �� A 43 4j, 2!03 466'=:?m� `\ I 67ADS'S t ci:( ' 136e A 1 ' `� 5 75 A 82,3 •�0 10 12k 10411 , 99 I 148 31 '815 u — _-1�/ I! / 0 / l r� #' � 'l / � I _ E158thAve _'^‘'fi, , E1 1 ,_ 1 1 ie , I Source:2005 U.S.Census TIGER Files _ ._-. Area Polygon r Public Water Supply,Zone H,Zone A.Interim Wellhead Protection Areas A fa i Federal Wells b. • �tiiied Site,Multiple Sites,Receptor................. .. t DEL.NPL,Brownfield,Solid Waste Landfill(SWL),Hazardous Waste i I it Zell and Railroads • 1 Environmental FirstSearch 1 .5 Mile Radius from Area �"ti �"i1 - " cw' wry FIRSTS° I '��'�y Single Map: FIRSTS','::::.;.:'''''-• 59 N HWY 55 AND ',NCR '-2 , 'Ec:ii i c 5 ON CO S'si6C3 i, 1 j 1� A 4 A 39 4F,�e, t / A �`�, 11 12' 33 15:< A ri 1�3 �1968d 135 1 l, 1 15 96 161 5 � b 44 71 ate. 11 74 31 $ 80 1347 ..-------___} A 142 { A I� At 8 A 56 A85 AA1 6 I b 53 84 11p7 .'". 29 48 - 60 - //f 9 . r © A © ` i 49 ; 4 5 20 140 , A _:i I , f 81 ;�y. ;A5 A 45 � � 43 A tY 4 d I 122 .,;, 12 60 ',�k; A 1 g 1z A A 17 a 51 ; A t 149 38 .t,,,s 631 1; A 46 A i 108 43 35 62 i A 64 ..5 2 338 -. �i3 1 8 5 2 34 5 7 6 8 8 9 /r 136 A 543 , I/ A 82 70 59 7'� 0 1071 A ! A A A �I .g/ 134 104 9 .-A doA & t 99 "` 1 14 1 157 ii / Source:2005 U.S. Census TIGER Files Area Polygon U I Identified Site,Multiple Sites,Receptor 2 i� NPL,DELNPL,Brownfield,Solid Waste Landfill(SWL),Hazardous Waste 0771 't Tribelland 1 Railroads , I i! Environmental FirstSearch Guam t� ,1-=� 25 Mile Radius from Area FIRSTS Single Map: 1 59 ] WY 8 AN� c„-7, 4. IC4 O W 8 60.: ti�V'm � �P{'u � 8� tial�� b� � y `r t 4 4`h COM aV5��a�tiL 145 :. lT 1 44 e. 771 1 i,.., 9{ F-' A saw` 7 7 4 113i A hi 31 c80 gs 3J 8 142 97 Il !1 5 a' t 49 87 a 56 d A X85 53 84 1 Itt, 6 23 'I la 1 29 18 1 11 �3 { ( 9� 48 %. sa J f 4 �g 4 k 20 1 1 44 i 4 5 �s + Ca I f lati ,/ ' 45 1331 14 $ A A b6 Z /• 121 �r ±s r b 1 AA 94 h ,7O ill , 3 I d .i AA 47 36 572 ! 1. 3 3 17 Iel 51 + r, 40 ` r t 41 36 13 18 .4 © A A @� 43 ri. 1 2 35 46 62 a`5 1 I �$ its.,74 2 ' 338 d ° T03 II Vii4 Afl• d 6e t 4 d ' 5 a5 k2 3 r'„ 42 _' 50 57 $ &9 J)r j AI a$3 tl .IOC I ' Source:2005 U.S. Census TIGER Files - Area PoiYdoo .. . . .. .... .. .'- . -- .. ..- I r 'ndfied Site,Multiple Sites,Receptor .--. .. El DBLNPL,Brownfield,Solid Waste Landfill(SWL),Hazardous Waste 5_,..d.. I I rrballand2a Railroads II of - Environmental FirstSearch � , 1 Mile Radius from Area FIRSTS 1 Few �`�` �'�-e Site Lacus Map: , - ,,'....7s.,i 859 N HWY 85 AND WCR 6 , aRiGH O CO1:0503 i �~ f I j _ 4 I � _ I Cu1 tii 1 „Oft � D QT1 f�3 :‘7, • 7--- t 1/`tl • f_ .: �. ________i , - • •/„,.....„ , ,A` ,'.' p__ _ii i , . „ i--1 1,,,:,,,,, /I / ' . i 01 \ _.. :.; ii I V f N. / sz r f f07.1 L U 1 } ' Iti i da St/ (CI 1f% 1Uth Ave \� YBa I 1 8t Ve 11 I r 1 �� il I Source:2005 U.S. Census TIGER Fifes Area Polygon_ r Identified Site,Multiple Sites,Receptor IN a NPL,DELNPL,Brownfield,Solid Waste Landfill(SWL),Hazardous Waste x Triballand.............._...-....---- D .I Railroads _ - I I Environmental FirstSearch ' Search Summary Report Target Site: 1859 N HWY 85 AND WCR 6 BRIGHTON CO 80603 FirstSearch Summary ' Database Sel Updated Radius Site 1/8 1/4 1/2 1/2> ZIP TOTALS -State Wells Y NA 0.50 8 15 22 90 0 135 Federal Wells Y 03-03.,08 0.50 0 0 6 19 - 0 25 il -TOTALS - 8 15 28 109 0 0 160 Notice of Disclaimer I Due to the limitations, constraints, inaccuracies and incompleteness of government information and computer mapping data currently available to InfoMap Technologies,certain conventions have been utilized in preparing the locations of all federal, state and local agency sites residing in InfoMap Technologies's databases.All EPA sites are depicted by a rectangle approximating their location and size.The boundaries of the rectangles represent NPL and state landfill the eastern and western most longitudes;the northern and southern most latitudes.As such,the mapped areas may exceed the actual areas and do not represent the I actual boundaries of these properties.All other sites are depicted by a point representing their approximate address location and make no attempt to represent the actual areas of the associated property.Actual boundaries and locations of individual properties can be found in the files residing at the agency responsible for such information. I Waiver of Liability Although InfoMap Technologies uses its best efforts to research the actual location of each site,InfoMap Technologies does not and can not warrant the accuracy of these sites with regard to exact location and size.All authorized users of InfoMap Technologies's services proceeding are signifying an understanding of InfoMap Technologies's searching and mapping conventions,and agree to waive any and all liability claims associated with search and map results showing ' incomplete and or inaccurate site locations. I I I I Environmental FirstSearch Sites Summary Report ' Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PV? BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GE0CODED: 0 SELECTED: 160 Map ID Dist/Dir DB Type Site Name/ID/Status Address ElevDiff Page No. ' 1 0.00- PWS ADAMS TRANSIT MIX CORP. NM 1 237267 BRIGHTON CO ' 2 0.00— PWS C and M SAND COMPANY - N/A 3 237884 BRIGHTON CO 3 0.00— PWS CAMAS AMERICA INC NM 4 237558 BRIGHTON CO 4 0.00— PWS CCWCD WELL I-019805F N/A 5 237503 BRIGHTON CO ' 5 0.00— PWS CCWCD WELL 2-019807F N/A 6 238169 BRIGHTON CO 6 0.00— PWS CCWCD WELL 4-020032-F N/A 8 238158 BRIGHTON CO 7 0.00— PWS CCWCD WELL 5-020033-F N/A 9 238174 BRIGHTON CO . 8 0.00— PWS DOUBLE B DEVELOPENT CORP NM 10 ' 237722 BRIGHTON CO 9 0.01 NW PWS WILHELMEN and MANCINEY N/A II � 237268 - BRIGHTON CO 10 0.02 S- PWS COWAN CONCRETE PRODUCTS NM 12 - 238067 BRIGHTON CO 11 0.03 S- PWS BAUMGARTNER WELL 2-6293 NM 13 ' 238183 BRIGHTON CO 12 0.04 SE PWS JONNSONR E NM 14 238514 BRIGHTON CO ' 13 0.04 SE PWS SINGLE EAGLE CO NM 15 237753 BRIGHTON CO 14 0.05 SE PWS COTTONWOOD WATER SKI CLUB LTD NM 16 238560 BRIGHTON CO 15 0.06 S- PWS BAUMGARTNER ROBERT and SHARON NM 17 237640 BRIGHTON CO 16 0.06 S- PWS BAUMGARTNER ROBERT L and SHARONA AM 18 237588 BRIGHTON CO 17 0.06-E PWS COWAN CONCRETE PRODUCTS NM 20 238065 BRIGHTON COI 18 0.06 SE PWS SINGLE EAGLE CO - NM 22 237969 BRIGHTON CO 19 0.10 SE PWS BURKE LLOYD NM 23 238594 BRIGHTON CO 20 0.10 SE PWS CCWCD WELL 6-020034-F NM 24 238765 BRIGHTON CO 21 0.70 SE PWS NATL FOOD WELL 16-103372 N/A 25 238186 BRIGHTON CO I I I I Environmental FirstSearch Sites Summary Report Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 IMap ID Dist/Dir DB Type Site Name/ID/Status - Address ElevDiff Page No. I 22 0.11 SE PWS BURKE LLOYD N/A 26 238642 BRIGHTON CO 23 0.11 SE PWS GODBY CARROLL DON and IVAN COLLINS NM 27 238792 BRIGHTON CO I 24 0.13 SE PWS BRENNING RALPH NM 28 238779 BRIGHTON CO I 25 0.13 SW PWS NATIONAL FOOD STORES NM 29 23 72 77 BRIGHTON CO 26 0.13 SE FEDWELLS SC00106630DBCI N/A 31 FW-CO-1206-12060/USGS GROUNDWATER CO I 27 0.14SE PWS FOSTER PROPERTIES N/A 32 238867 BRIGHTON CO 28 0.14 NE FEDWELLS SC001066I9DCD1 USGS 40013210449020 N/A 33 I FW-CO-1206-12199/USGS GROUNDWATER CO 29 0.14 SE FEDWELLS SC00106630AACI N/A 34 FW-CO-1206-12156/USGS GROUNDWATER CO 30 0.15 SW PWS AURORA CITY OF NM 35 236751 BRIGHTON CO i 31 0.I7NW FEDWELLS SB00106630ABCI NM 36 I 32 0.19 SW PWS FW-CO-1206-12205/USGS GROUNDWATER CO BA UMGARTNER HAROLD F NM 37 237281 BRIGHTON CO I 33 0.19 SE PWS BAUMGARTNER HAROLD F NM 38 238375 BRIGHTON CO 34 0.19 SE PWS BRENNING RALPH N/A 39 239135 BRIGHTON CO I 35 0.19 SE PWS FINLEY WELL 11620 N/A 41 138774 BRIGHTON CO 36 0.79 SE PWS FOSTER PROPERTIES NM 42 I 239125 BRIGHTON CO 37 0.19 S- PWS NATL FOOD WELL 14-1033 70 N/A 43 237518 BRIGHTON CO I 38 0.79 SE PWS RANCH KING MEAT PACKERS NM 46 238517 BRIGHTON CO 39 0.20 SE PWS BAUMGARTNER HAROLD F NM 48 I 238055 BRIGHTON CO 40 010 SE PWS FINLEY TONY and TODD and DAVID N/A 49 239039- BRIGHTON CO I 41 0.20SE PWS NATL FOOD WELL 10-103367 NM 51 238182 BRIGHTON CO i il Environmental FirstSearch Sites Summary Report Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 Map II) Dist/Dir DB Type Site Name/ID/Status Address ElevDiff Page No. ' 42 0.21 S- PWS BAUMGARTNER HAROLD F N/A 54 237533 BRIGHTON CO 43 0.21 SW PWS BAUMGARTNER WELL 1-6291 N/A 55 236538 BRIGHTON CO 44 0.22 N- PWS MANCINI WELL 1-13410-F N/A 56 238138 BRIGHTON CO 45 0.22 SE FED WELLS SB00106630DCA1 N/A 57 FW-CO-1206-12131/USGS GROUNDWATER CO 46 0.23 SE FEDWELLS SC00106630DAC1 N/A 58 FW-CO-12 0 6-12 0 71/USGS GROUNDWATER CO 47 0.14 SW PWS CLANAHAN DENIS B. N/A 59 237280 BRIGHTON CO 48 0.24 NW PWS LEHL ALEX NM 60 236275 BRIGHTON CO 49 0.25-N' PWS AGGREGATE INDUSTRIES WCR INC NM 62 236260 BRIGHTON CO 50 0.25 SE PWS BAUMGARTNER HAROLD F N/A 63 238521 BRIGHTON CO 1 J 51 0.25 SE PWS BRANCUCCI WELL 2-R01998 N/A 64 239345 BRIGHTON CO 52 0.27 SE PWS RITCHIE BROS AUCTIONEERS INC N/A 65 , 238870 BRIGHTON CO 53 0.27 SE PWS TRIPLE G WELL 5-5889 N/A 66 239474 BRIGHTON CO t 54 0.28 SW PWS BAURER PETER L/EIBERGER CARL F N/A 67 236441 BRIGHTON CO 55 0.28 SW PWS BAURER/EIBERGER W 49171 N/A 69 236536 BRIGHTON CO 56 0.28 NE PWS DEBETZ FRED NM 70 239584 BRIGHTON CO , 57 0.28 SE PWS NATL FOOD WELL 21-19173 N/A 72 238772 BRIGHTON CO 58 0.28 SE PWS RITCHIE BROS AUCTIONEERS INC NM 75 238491 BRIGHTON CO 59 0.29 SE PWS BAUMGARTNER HAROLD F N/A 76 237832 BRIGHTON CO 60 0.29 SE PWS HRAPSKI P N/A 78 t 239596 BRIGHTON CO 61 0.29 NE PWS MYSTROM INC NM 80 238472 BRIGHTON CO ' I I I I Environmental FirstSearch Sites Summary Report Target Property: 1859 N HY 85 AND VCR 6 JOB: BRODA AI-PVP ' �'BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 ' Map ID Dist/Dir DB Type Site Name/ID/Status _ Address ElevDiff Page No. I 62 0.29 SE PWS R T DEVELOPMENT N/A 82 239356 BRIGHTON CO 63 0.29 SE PWS RITCHIE BROS AUCTIONEERS INC N/A 83 238576 BRIGHTON CO I 64 0.29 SE PWS RITCHIE BROS AUCTIONEERS INC N/A 84 238891 BRIGHTON CO 65 0.30SW PWS BA URER PETER N/A 85 236284 BRIGHTON CO 66 0.30SE PWS FOSTER PROPERTIES INC N/A 87 239606 BRIGHTON CO I 67 0.30SW PWS SPENCER W. T. N/A 91 236285 BRIGHTON CO 68 0.31 NW PWS C-M CONCRETE N/A 92 I 237496 BRIGHTON CO 69 0.31 SE PWS CASE BRIAN NM 93 239624 BRIGHTON CO I 70 0.31 S- PWS NATL FOOD WELL 12-103368 N/A 95 237514 BRIGHTON CO _ i 71 0.31 NE PWS SASAKI WELL 3-18769 B N/A 97 I 2S93ZP BRIGHTON CO 72 0.32 SE PWS ELMS JEFFREY A N/A 98 239663 BRIGHTON CO I 73 032 SE PWS NATL FOOD WELL 11-32214 N/A 99 238181 BRIGHTON CO 74 0.32 NW FED WELLS SC00106619CCD1 USGS 40013410449290 N/A _ 101 FW-CO-1206-1221I/USGS GROUNDWATER CO I 75 0.33 SE PWS BAUMGARTNER HAROLD F N/A 102 238441 BRIGHTON CO 76 0.33 SE PWS FIELDS ENG.and FAB.CO.INC N/A 104 I 238941 BRIGHTON CO 77 0.33 SE PWS FINLEY TONY N/A 105 239551 BRIGHTON CO I 78 0.34 SE PWS FINLEY TONY DAVE TODD N/A 106 239548 BRIGHTON CO 79 0.34 SE PWS FINLEY TONY/DAVE/TODD N/A 107 I 80 239530 BRIGHTON CO 034 NE FEDWELLS 5300106630ADB1 N/A 108 FW-CO-1206-12204/HSGS GROUNDWATER CO I 81 0.34 SE FED WELLS SC00706630ADDI N/A 109 FW-CO-1206-12119/USGS GROUNDWATER CO I I Environmental FirstSearch Sites Summary Report ' Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 , TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 Map ID Dist/Dir DB Type Site Name/ID/Status Address E1evDiff Page No. 82 0.35 SW PWS AURORA CITY OF N/A 110 236690 BRIGHTON CO t 83 0.35 NW PWS MANCINI WELL 2-13409-F N/A III 237487 BRIGHTON CO 84 0.35 SE PWS SASAKI WELL 2-18769 N/A 112 239921 BRIGHTON CO 85 0-36 NE PWS ARNHEIMLLC - N/A 113 239995 BRIGHTON CO , 86 0.36 SE PWS BRANCUCCI WELL 1-R01997 N/A 114 239939 BRIGHTON CO 87 0.36 NW PWS CONSOLIDATED MUTUAL WATER COMPANY I N/A 115 236270 - BRIGHTON CO 88 0.36SE PWS FIELDS ENG.and FAB. CO.INC NM 716 239144 BRIGHTON CO ' 89 0.36 SE PWS NATL FOOD WELL 1-38779 N/A 117 239335 BRIGHTON CO 90 0.37 SE PWS R.T.DEVELOPMENT INC. NM 118 239608 BRIGHTON CO 91 0.37 SE FED WELLS SB00I06630DDCI N/A 120 FW-CO-12 0 6-1211 0/USGS GROUNDWATER CO 92 0.38 SE PWS BRANCUCCI STEPHAN N/A 121 240051 BRIGHTON CO 93 038 SE PWS BRANCUCCI WELL 3-810285 N/A 122 240040 BRIGHTON CO 94 0.38 SW PWS CHAMBERS JACK NM 123 237275 BRIGHTON CO 95 0.38 SE PWS HRAPSKI PETER and LAVINA M. NM 124 240069 BRIGHTON CO 96 0.38 NE PWS SW TKO JOINT VENTURE LLC NM 125 239369 BRIGHTON CO ' 97 0.39 NE FEDWELLS SB00106630ADA N/A 126 FW-CO-1 2 0 6-1 218 4/USGS GROUNDWATER CO 98 0.39 SE FED WELLS SB00106630ADD N/A 127 , FW-CO-1206-12147/USGS GROUNDWATER CO 99 0.40 SE PWS CHAMBERS S J NM 128 238508 BRIGHTON CO ' 100 0.40 S- PWS DAWSON JACOB J N/A 131 237479 BRIGHTON CO 101 0.40 NE PWS ODAYDON NM 132 239572 BRIGHTON CO I I I Environmental FirstSearch Sites Summary Report ' Target Property: 1859 N HWY 85 AND W CR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 Map ID Dist/Dir DB Type Site Name/ID/Status Address . E1evDiff Page No. I 102 0.40 SE PWS TRIPLE G WELL 4-6292 N/A 234 240186 BRIGHTON CO 103 0.40 SE FEDWELLS SB0010663IAACI N/A 135 I FW - 057/USGS GROUNDWATER CO I04 0.40 SW FEDWELLS SC007-CO-12060663OCDI2CI N/A 136 FW-CO-12 0 6-1 2 02 4/6SGS GROUNDWATER CO I 105 0.41 NW PWS CONSOLIDATED MUTUAL WATER CO NM 137 236506 BRIGHTON CO 106 0.41 SE PWS HALL IRWIN CONSTRUCTION NM 138 239251 BRIGHTON CO I 107 0.42 SE PWS RITCHIE ROS.AUCTIONERS INC N/A 139 239099 BRIGHTON CO 108 0.42 SE PWS THORPE HELEN NM 140 I 240153 BRIGHTON CO 109 0.42 SE PWS THORPE HELEN NM 141 240155 BRIGHTON CO I 110 0.42 S- FEDWELLS SC00106630CDD2 N/A 143 FW-CO-12 0 6-12 015/USGS GROUNDWATER CO 111 0.42-W FEDWELLS SC00106725ADD1 N/A 144 I 112 0.43 SE PWS FW-CO-12 0 6-1 21 2 7/USGS GROUNDWATER CO OIPRES MARY N/A 145 240450 BRIGHTON CO I 113 0.43 NW PWS CONSOLIDATED MUTUAL WATER CO THE NM 146 236101 BRIGHTON CO 114 0.43 N- PWS PATTERSON CHARLES and BARBARA N/A 147 I 238094 FORT LUPTONCO 115 0.43 SE PWS SIPRES MARY N/A 148 240385 BRIGHTON CO I 116 0.43 SE PWS SIPRES MARY NM 149 240451 BRIGHTON CO 117 0.43 SE PWS SIPRES MARY N/A 150 240386 BRIGHTON CO I 118 0.44NE PWS BROMLEY MINERAL HOLDINGS,LLC - NM 151 238942 FORT LUPTON CO 119 0.44 NW PWS CONSOLIDATED MUTUAL WATER CO - NM 152 I 236540 BRIGHTON CO 120 0.44 NE PWS SASAKI JOE N/A 153 240080 BRIGHTON CO I 121 0.44 NE PWS SW TKO JOINT VENTURE LLC NM 154 238751 FORT LUPTON CO I I I Environmental FirstSearch Sites Summary Report Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 , TOTAL: 160 GEOC0DED: 160 NON GEOCODED: 0 SELECTED: 160 Map ID Dist/Dir DB Type Site Name/ID/Status Address ElevDiff Page No. i 122 0.44 SE FEDWELLS SB00106630DDD1 N/A 155 FW-CO-1206-12118/USGS GROUNDWATER CO i 123 0.44-W FEDWELLS SC00106725ADD2 N/A 756 FW-CO-12 06-12 12 8/USGS GROUNDWATER CO 124 0.45 SE PWS LASSITU WELL 1-31977 N/A 157 i 238176 - BRIGHTON CO 125 0.45 SE PWS NATL FOOD WELL 2-18157 N/A 159 239334 BRIGHTON CO II 0.45 SE FEDWELLS SB00106629CCCl USGS 40005510448340 N/A 160 FW-CO-1206-12088/USGS GROUNDWATER CO 126 0.45 SE FEDWELLS SB00106629CCC N/A 161 i FW-CO-12 06-1 2 0 8 7/USGS GROUNDWATER CO 127 0.45 SE FED WELLS SB00106630ADDI N/A 162 FW-CO-12 0 6-1 21 6 7/USGS GROUNDWATER CO 128 0.46 SW PWS EIBERGER CARL N/A 163 i 236281 BRIGHTON CO 129 0.46S- PWS ELMS JEFFREYA N/A 164 237508 BRIGHTON CO i 130 0.46 NE PWS SASAKI JOE N/A 165 240113 BRIGHTON CO 131 0.46 SW PWS SPENCER W.T. N/A 166 i 236282 BRIGHTON CO 132 0.46 NE PWS STUTZ RICHARD N/A 168 240461 BRIGHTON CO i 133 0.46 NE FEDWELLS SB00106619DCDI USGS 40014710448530 N/A 170 FW-CO-1206-12237/USGS GROUNDWATER CO 134 0.46 NE FEDWELLS SB00I06630ADA1 N/A 171 i FW-CO-1 2 0 6-12 1 9 8/USGS GROUNDWATER CO 135 0.47 NW PWS CONSOLIDATED MUTUAL WATER COMPANY N/A 172 236263 BRIGHTON CO 136 0.47SW PWS HAI I IRWIN CONSTRUCTION N/A 174 235674 BRIGHTON CO 137 0.47 SE PWS SASAKI WELL 5-0571 2 N/A 175 i 240711 BRIGHTON CO 138 0.47SE PWS SHAFFER MAURICE B N/A 176 238246 BRIGHTON CO i 139 0.47NE FEDWELLS SB00106619DCCI N/A 177 FW-CO-1206-12246/USGS GROUNDWATER CO 140 0.47 SE FEDWELLS SB00I06630DADI N/A 178 i FW-CO-12 0 6-1 21 4 2/USGS GROUNDWATER CO I I I Environmental FirstSearch IISites Summary Report Target Property: 1859 N HWY 85 AND WCR 6 JOB: BRODA AI-PVP BRIGHTON CO 80603 TOTAL: 160 GEOCODED: 160 NON GEOCODED: 0 SELECTED: 160 Map ID Dist/Dir DB T Site Name/ID/Status Address ElevDiff Page No. 141 0.48 SW PWS AGGREGATEINDUSTRIES WCR INC N/A 179 ll 235342 BRIGHTON CO 142 0.48 NW PWS CONSOLIDATED MUTUAL WATER CO THE N/A 180 235791 BRIGHTON CO I 143 0.48 SE PWS KRAMER WELL 1-820988 N/A 181 240734 BRIGHTON CO 144 0.48 NE PWS YOKOOJI WELL 2819-F N/A 182 I 238745 FORT LIPTON CO 145 0.49 NE PWS BRANCUCCI WELL 4-10286 N/A 184 240191 BRIGHTON CO I 146 0.495- PWS ELMS JEFFREYA N/A 185 237521 BRIGHTON CO 147 0.49 NE PWS SHANNON KENNETH T and MARGARET N/A 186 240636 BRIGHTON CO ' 148 0.49 SW PWS STILLWATER SKI LK 47367 N/A 187 236534 BRIGHTON CO 149 0.50 SE PWS BAURER PETER L/EIBERGER CARL F N/A 188 237786 BRIGHTON CO 150 0.50 NE PWS BRANCUCCI STEPHAN N/A 189 239966 BRIGHTON CO II 151 0.50 NE PWS BRANCUCCI STEPHAN N/A 191 239967 BRIGHTON CO 152 0.50 NW PWS CONSOLIDATED MUTUAL WATER CO N/A 192 ' 236497 BRIGHTON CO 153 0.50 NW PWS CONSOLIDATED MUTUAL WATER CO THE N/A 193 236178 BRIGHTON CO ' 154 0.50 S- PWS ELMS JEFFREYA N/A 194 237519 BRIGHTON CO 155 0.50 S- PWS ELMS JEFFREYA N/A 195 II 237520 BRIGHTON CO 756 0.50 SE PWS LAMBERT JIM N/A 196 238589 BRIGHTON CO II 157 0.50 SE PWS LASATER JACK N/A 198 238270 BRIGHTON CO 158 0.50 SE PWS NATIONAL FOOD STORES N/A 200 237785 BRIGHTON CO Ill 159 0.50 NW PWS US GEOL SURVEY N/A 202 236885 FORT LUPTON CO 1 1 1 1 1 1 1 t Appendix 9 Groundwater Monitoring Well Locations 1 1 I 4DEL0RME I { Topo USA® 8 �; . ti 1 =:P ", ) r4 .4 = F n1 '4 'a ' IL I 1< ... ,rte +tr , t • A• • t -"�. ° � � �' . .a�R Jilt cirii-r.E.al , ... / i ->b. - WELD CDUNIY4RD 6 's _ . 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MN(8.9`E) alii - m A 0 60 160 240 220 400 www.delorme.com 1 1" = 733.3 ft Data Zoom 14-5 1 I I I I I I I I I Appendix 10 ITypical Groundwater Monitoring Well Construction ' I I I I I I I I ITYPICAL MONITORING WELL CONSTRUCTION DIAGRAM 1 Metal Well Casing Riser 'I IPVC Well Cap 0.0 �'t#4 ≥i:i iii ii ii:. ..... i'i'3i'i'I I Concrete Surface Seal Solid 1 or 2 inch PVC(0-14.5) 1 Soil or sand pack _-- •'•'•'• i .-.-.- Bentonite Chips(12-14) o Native or Backfill Materials o ----—. ll N LO in Water Level (seasonal high) - - o _ 10/20 Silica Sand(14-30) I - or native materials with similar properties v' N 0 1O 1 or 2 inch PVC, 0.010 perforations(14.5-29.5) Co LL Q U O in a I trot chm Cap(29.5-30) I co z Total Depth=30 feet O I2 Example of Groundwater Well Construction All depths are in feet Hello