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4.2. SR 02-24-1997City of River she bur ZONiNG [ ADMINISTRATION February 5, 1997 Mr. Bill Armstrong Senior Engineer Minnesota Pollution Control Agency Groundwater and Solid Waste Division 520 Lafayette Road St. Paul, MN 55155-4194 RE: Elk River Landfill - Draft MPCA Permit Dear Bill: Sherburne County and the City of Elk River have completed a review of the Draft MPCA solid waste facility permit for the Elk River Landfill, Inc. (ERLI) and offer the following comments. Proposed Final Elevations - General The Long Term Development Plan proposal to increase the height of the final elevation by more than 70 feet has not been evaluated by the City and County. The specific concerns relate to the: 1) impact on neighboring land use and values; 2).potential for extreme differential settlement; 3) aesthetic impact on a large radius around the site; and 4) nuisance effect relating to dust, blowing litter and noise. Plans which are currently approved restrict the development to the existing 40 acres and authorize waste placement to approximately elevation 1,100 NGVD. Corrective Action - General MPCA has embraced the concept of allowing ERLI three years to demonstrate that the LFG extraction system is having an effect on the VOC ground water quality. The MPCA proposed performance standard which is "no clear and significant decreasing trend" for VOCs is inadequate for enforcement purposes. Ideally, the permit should identify a number of VOC parameters which would be specifically evaluated. The data set would be evaluated using specific statistical methods identified in the permit. A 95 percent confidence interval would be used to evaluate the groundwater data to determine whether a statistically significant decrease in VOC concentration has occurred. 13880 Highway 10 P.O. Box 320 Elk River, MN 55330 1-800~438-0578 ~ 241-2900 13065 Orono Parkway · P.O. Box 490 · Elk River, MN 55330 · (612) 441-7420 · Fax: (612) 441-7425 Page 2 February 5, 1997 Compliance Bounda~ - General The main feature is that the compliance boundary represents a line on the map and does not include an adequate number of monitoring wells to assess the groundwater impact of facility. Wells must be located at the compliance boundary in order to generate data which can be used to determine compliance. Item Part III.B.3 of the draft permit identifies this condition and requires the installation of monitoring wells at the compliance boundary. The City and the County will closely evaluate the permittee submittals to ensure that appropriate well installation is accomplished under the requirements of the Phase III Water Monitoring System Work Plan implementation. The following items correspond to the draft permit directly. Comments are provided which could be used as a basis for language within the permit. Part I.C. - Facility Description. The permit authorizes disposal of municipal solid waste (MSW) in ceils 10 through 13. It is apparent that the lined cell 6 has not achieved final elevation. Cell 6 should therefore be added to the authorized area. The "effective date" of the authorized volumes should be identified. Part I.D. 1 - Liner and Leachate Collection System. The thickness of the drainage layer should be specified to maintain consistency with other requirements of the item. Part I.D.2 - Leak Detection System. Facility construction should include devices to detect potential leakage through the primary pipe of the leachate transmission line and potential leakage from leachate collection tanks. Part I.D.4 - Retention Ponds. The final design of the stormwater retention and sedimentation ponds should identify the allocation of volume per stage considering lost capacity from collected sediments. Part I.H. - Construction Certification. The certification report should include at a minimum the following items: 1) 2) 3) 4) 5) 6) 7) 8) 9) Ail relevant construction specifications; All shop drawings for prefabricated components; Photo documentation of all critical aspects of construction; Deflection testing results for leachate collection and transmission pipes; Narrative description of all as-built variances from the plans and/or specifications; As-built cross-sections of the liner subgrade; As-built elevations for all pipe inlets and outlets and pump-on/pump-off controls; Completed manufacturer warranties; All physical testing results. Part I.J. Buffer Zone (new item). A Buffer Zone of not less than 200 feet should be established within the perimeter of the Landfill Property around the waste disposal areas. Within this Buffer Zone, no waste disposal may occur. The permittee should place an earth berm, landscaped with evergreen trees and protected from erosion, at the outside perimeter of the Buffer Zone. Where the Buffer Zone contains heavily wooded areas, exception to installing the Page 3 February 5, 1997 berm and landscaping should be allowed. Evaluation of all current and future landfill operations should be included in the design of the buffer zone. A plan for establishment of the Buffer Zone should be submitted to MPCA no later than May 1, 1997 and should be implemented on a schedule as provided in the plan. Part II.A. - Personnel. The unloading of refuse should be continuously monitored at the working face at the Landfill to reduce the potential for the disposal of unacceptable wastes. Part 11.1.4 - Final Cover. The required thicknesses of all cover layers should be defined to be consistent with the selected format. If "demolition debris ceils" are underlain with MSW waste, the final cover must meet the requirements for MSW fill areas. Part ll.M. - Landfill Active Gas System. The active landfill gas system should be operated in accordance with the "LFG System Monitoring Plan" (Plan) dated May 1995 and subsequent amendments. A radius of influence test for LW-7 should be completed by May 1, 1997 as outlined in the Plan. Part II.N. - Resource Recovery Operations. The operations of the Resource Recovery Facilities should meet these additional requirements. 1) Si~nage Permittee shall maintain appropriate signage on the Landfill Property to direct citizens to the location of the recycling center. 2) Used Oil. Used oil recycling areas shall be within an enclosed building with an impermeable floor and containment area as approved by staff. 3) Batteries. Battery storage shall be within an enclosed building with an impermeable floor and containment area suitable for battery acid. 4) Fire Prevention. Battery, paper and oil storage areas shall be separated to reduce fire potential. 5) Appliance Removal. Permittee shall have a regular schedule for appliance pick- up approved by City staff. Part II.O. - Yard Waste Compostin~. (new item). The operation of a yard waste composting facility on the Landfill Property may be conducted, subject to the following conditions: 1) Yard Waste Compostin~ Plans. The yard waste composting facility shall be located and operated as shown on plans submitted by Permittee. 2) Plastics. All plastics shall be removed from yard waste brought to the facility before composting. 3) Municipal Solid Waste. All municipal solid waste must be immediately removed from yard waste and landfilled. Page 4 February 5, 1997 4) Odors. The yard waste composting facility must be operated in such a manner as to keep odors to a minimum. If odors becomes a problem staff may require more frequent turning of compost piles and/or watering to ensure that the compost remains aerobic and breaks down as quickly as possible. 5) Processin~ Volumes. The maximum amount of yard waste which may be accepted is 100,000 cubic yards per year. 6) Drainage. Positive drainage away from the compost area must be implemented. 7) Cover Prohibition. Yard waste and/or compost may not be used as daily cover for the landfill. Part III.P. - Litter Control (new item). The permittee must engage in a strict program for on- site and off-site litter control. 1) Temporary Fencing. Litter control fences shall be placed around the working area(s) of the Landfill to prevent the blowing of paper or other litter on or off site. The Permittee shall assign employees to engage in a regular and routine program to inspect the Site and clean up areas where littler accumulates on the Site. 2) Permanent Fencing. The Permittee shall install a minimum six-foot high fence around the perimeter of the site if and when necessary, based upon reasonable concerns regarding public safety or trespassing or uncontrolled dumping. 3) Small-Load Dumping Site. The Permittee shall, during all hours of operation, maintain and operate a separate suitable and safe disposal area for the dumping of small loads by pickup trucks, cars, and trailers from May 1 to October 31 each year. This separate site shall be located and operated with due regard for the nature of the vehicles bringing such loads, and the normal frequency of such dumping. 4) Off-Site Litter Control. The Permittee shall engage in a regular and routine litter maintenance and removal program extending one-half mile north and south of the entrance to the Landfill and to any other areas adversely impacted by debris related to Landfill operations. Litter shall be removed from these areas not less than once per week, and more often if necessary because of spills or complaints from neighboring property owners, and ensure that these areas are kept free of litter generated by truck traffic traveling to and from the Landfill. In addition, Perrnittee shall inspect all trucks leaving the Landfill to ensure that they are either fully enclosed or covered, and/or clean, and will not spread litter on surrounding streets and roadways as they leave. Part II.Q. Dust, Noise and Odor (new item). Fugitive dust emissions off-site shall be controlled at the Site as necessary by undertaking the following: road surfaces within the Site shall be wetted with water or an appropriate chemical whenever off-site dust levels become Page 5 February 5, 1997 unreasonable as determined by the MPCA. Dust pollutives shall be utilized to the extent necessary on cover material such as stockpiles to reduce wind erosion as well as on other exposed surfaces as appropriate. Cover compaction and revegetation activities shall be undertaken promptly on the completion of various fill areas and vegetative cover capable of quick growth shall be utilized. Planting of bushes and trees shall be installed if needed to buffer the Site and minimize wind erosion. An all-weather haul road shall be provided to the unloading area and watered on a regular basis. The Landfill shall pave the access roads from T.H. 169 to the scale and from T.H. 169 to the shop building by June 30, 1997 to reduce dust generation. All equipment and vehicles utilized at the Landfill Site shall be periodically inspected and maintained to minimize noise. Vegetative barriers along the boundaries of the Landfill Site shall be utilized to minimize off-site noise impacts. Applicable state standards for noise pollution shall not be exceeded by the Landfill operation, equipment, vehicles or machinery. The Permittee shall take reasonable actions to control odors from the Site. Part Ill.7. - Heavy Metal Contaminant Monitorina and Assessment (new item). Heavy metal contaminants for surface water and groundwater must be addressed in addition to VOC contaminants. Based on the need for additional monitoring to confirm exceedances and identify trends, the Landfill shall conduct monitoring and prepare an evaluation report which shall be submitted with the Phase IV Water Quality Monitoring Report. Part III. C. - Corrective Action. If heavy metal concentrations in groundwater and surface water exceed regulatory standards, the Permittee will be required to conduct a Feasibility Study and submit it to MPCA within six months of completing the Phase IV Water Quality Monitoring Report. Part IV.C.2. - Leak Detection Lvsimeters Leachate monitoring of the lysimeters should identify an acceptable leakage rate in consideration of the liner design and an allowable efficiency of 95 %. Leakage rates above this level should trigger sampling and subsequent remedial action. The requirement for 100% efficiency of the liner system is not consistent with other MPCA requirements. Part VI.A. - Closure The draft permit should include the requirement of a post-closure road for maintenance of the final cover. The road should extent to the highest elevation of the fill area. Overall, MPCA has developed a draft permit which incorporates many of the concerns that the City of Elk River has previously expressed. The inclusion of the above language in the draft permit will cover a broader perspective of the Landfill design and operation and may reduce the City's need for regulatory oversight in the future. Page 6 February 5, 1997 Please contact Sherburne County or the City of Elk River if you have any questions or comments regarding these matters. Sincerely, Dave Lucas Sherburne County Solid Waste Officer Stephen Rohlf City of Elk River Building and Zoning Administrator CC: Ms. Amy Hadiaris, MPCA Ms. Victoria Kreger, Elk River Landfill Mr. John Cannon, CDM Ms. Debra McDonald, USA Waste, Inc. Mr. Peter Beck, Doherty, Rumble & Butler Mr. Kevin Johnson, Doherty, Rumble & Butler Ms. Kathleen Heaney, Assistant Sherburne County Attorney Mr. Dave Loch, Sherburne County Administrator maw: LF/32003/lt970204. wp