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6.2 SR 10-03-2022Request for Action To Item Number Mayor and City Council 6.2 Agenda Section Meeting Date Prepared by Presentations, October 3, 2022 Suzanne Fischer, Environmental/Special Projects Director Awards, and Recognition Item Description Reviewed by Waste Management's Operational Status Matt Ledvina, Gestalt En r. & Peter Beck, City Attorney Reviewed by Cal Portner, City Administrator Action Requested Informational. Background/Discussion Waste Management submitted their Closure, Post Closure Contingency Action Plan, and Financial Assurance Plan in August of 2022. The documents are intended to fulfill the MPCA requirements for closure, post closure, and contingency action with financial assurance calculations. The plans are divided into the following sections: Section 2 is the closure plan for the facility which include MPCA notification, schedule, procedures, and certification. In addition, the closure costs are presented for purposes of establishing financial assurance needs. Section 3 defines a Post -Closure Care Plan for the facility and evaluates costs associated with post -closure care. It adjusts the costs to future dollars and summarizes a 20-year total for financial assurance purposes. Section 4 defines a Contingency Action Plan and evaluates costs associated with each contingency. The financial assurance evaluation includes proportional amounts reflecting the probability of each contingency, thereby allowing contingency costs to be included in the financial assurance calculations. Section 5 defines the financial assurance required for site closure, post -closure care, and contingency actions. Financial assurance calculations included in this application were prepared in January 2022 and included as part of the annual report. The financial assurance calculations are updated annually as part of the annual report. Financial Impact N/A Mission/Policy/Goal The Elk River Mission Attachments ■ Elk River Landfill Closure, Post Closure Contingency Action Plan & Financial Assurance Plan The Elk River Vision P 0 W E e E 0 0 V A welcoming community rvitb revolutionary and spirzted resourcefulness, exceptional NATURE service, and community engagement that encourages and inspires prosperz[ Updated. August 2020 6.2 at ® Stantec CLOSURE, POST -CLOSURE, CONTINGENCY ACTION PLAN AND FINANCIAL ASSURANCE PLAN Elk River Landfill, Inc. August 2022 Prepared for: Elk River Landfill, Inc. 224460 Highway 169 Northwest Elk River, MN 55330 Prepared by: Stantec Consulting Services Inc. 1800 Pioneer Creek Center PO Box 249 Maple Plain, MN 55359 Phone: 763-479-4200 Project Number: 227705133 Table of Contents 1 INTRODUCTION........................................................................................................ 1..................... 0 2 CLOSURE PLAN....................................................................................................... 2 ..................... 1 2.1 General.......................................................................................................................................2..................1 2.2 Notification Of Cell/Phase Closure............................................................................................. 2..................1 2.3 Notification Of Final Closure....................................................................................................... 2..................1 2.4 Closure Schedule....................................................................................................................... 2..................1 2.5 Closure Procedures.................................................................................................................... 2..................2 2.6 Certification Of Cell/Final Closure.............................................................................................. 2 ..................2 2.7 Deed Notation............................................................................................................................. 2 .................3 2.8 Amendment Of Closure Plan...................................................................................................... 2..................3 2.9 Closure Cost Estimate................................................................................................................ 2..................3 3 POST -CLOSURE PLAN............................................................................................ 3.1 3.1 General.......................................................................................................................................3.1 3.2 Inspection And Maintenance...................................................................................................... 3.1 3.3 Environmental Monitoring........................................................................................................... 3.1 3.3.1 Water Quality.............................................................................................................................. 3.1 3.3.2 Surface Water............................................................................................................................. 3.2 3.3.3 Leachate..................................................................................................................................... 3.2 3.3.4 Leak Detection............................................................................................................................ 3.2 3.4 Surface Water Runoff Control Facilities..................................................................................... 3.2 3.5 Final Cover Surface.................................................................................................................... 3.2 3.6 Leachate System Management.................................................................................................. 3.3 3.7 Gas Monitoring........................................................................................................................... 3.3 3.8 Reporting.................................................................................................................................... 3.4 3.9 Ultimate Land Use...................................................................................................................... 3.4 3.10 Amendment Of Post -Closure Plan............................................................................................. 3.4 3.11 Post -Closure Care Cost Estimate.............................................................................................. 3.4 4 CONTINGENCY ACTION PLAN ........ 4.1 General............................................................... Contingencies That May Need Corrective Action . Event -Triggered Contingencies ................................. 4.2.2 Inspection -Triggered Contingencies ............. 4.2.3 Monitoring -Triggered Contingencies ................ Corrective Actions ..................................................... 4.3.1 Emergency Actions ..................................... 4.3.2 Follow-up to Emergency Actions ..................... Events Not Requiring Emergency Action .................. 4.4 Action Levels ...................................................... Equipment Availability ............................................... 4.6 Amendment Of Contingency Plan .............. 4.7 Estimated Costs For Contingency Actions . 5 FINANCIAL ASSURANCE ................. .................................................................... 4.1 ..................................................................... 4.1 4.2 ................................................................. 4.1 4.2.1 .............................................................. 4.2 .................................................................... 5.1 BProject Number: 227705133 LIST OF TABLES 1 MSW Southern Development Area Design Volumes 2 Closure Cost Estimate 3 Post -Closure Costs 4A Event -Triggered Contingencies 413 Inspection -Triggered Contingencies 4C Monitoring -Triggered Contingencies 4D Contingency Action Cost Estimate 5 Post -Closure Cost Calculations Project Number: 227705133 Introduction This report consists of a Closure Plan, Post -Closure Plan, Contingency Action Plan, and the proposed financial assurance for the Elk River Landfill (the Landfill) in Elk River. This report is intended to fulfill the Minnesota Pollution Control Agency (MPCA) requirements for closure (Minnesota Rules (MR) 7035.2625), post -closure (MR 7035.2645 and 7035.2655), and contingency action (MR 7035.2615). Cost estimates for closure, post -closure, and contingency action are included for financial assurance calculations. Section 2.0 of this document presents the Closure Plan for the facility. This Closure Plan includes MPCA notification, schedule, procedures and certification. In addition, the closure costs are presented for purposes of establishing financial assurance needs. Section 3.0 of this document defines a Post -Closure Care Plan for the facility and evaluates costs associated with post -closure care. It adjusts the costs to future dollars and summarizes a 20-year total for financial assurance purposes. Section 4.0 of this document defines a Contingency Action Plan and evaluates costs associated with each contingency. The financial assurance evaluation includes proportional amounts reflecting the probability of each particular contingency, thereby allowing contingency costs to be included in the financial assurance calculations. Section 5.0 of this document defines the financial assurance required for site closure, post -closure care and contingency actions. Financial assurance calculations included in this application were prepared in January 2022 and included as part of the annual report. The financial assurance calculations are updated annually as part of the annual report. The objectives of the closure, post -closure, and contingency action plans are to establish procedures to be followed during each of the activities, and to establish a basis for determining the financial assurance appropriate for the Landfill. Financial assurance in the form of a surety bond has been established for actions on the property owned by Waste Management. In BProject Number: 227705133 2 Closure Plan 2.1 General Closure of filled areas for the MSW and demolition/construction (C&D) cells is the responsibility of the Landfill. Closure activities described below will take place sequentially as areas of the site are brought to final grades. Minnesota Rules for Municipal Solid Waste Part 7035.2625 are used as a guide to determine closure requirements. Contact after closure is: Elk River Landfill District Manager 22460 Hwy 169 NW Elk River, MN 55330 Phone: (763) 441-2464 A copy of the approved Closure Plan and all revisions to the Closure Plan will be kept at the facility until closure is completed and certified. This Closure Plan supersedes any previous closure plans prepared for this site. 2.2 Notification Of Cell/Phase Closure The MPCA will be notified of impending cell or phase closure at least two weeks prior to initiation of closure activities. Closure of the last currently permitted MSW cell (Cell 20 Phase 3) is anticipated to be completed in 2028. 2.3 Notification Of Final Closure Final closure at each area will begin within 30 days after receiving the last shipment of waste, weather permitting. Final closure will be preceded by the following: The MPCA Commissioner will be notified 90 days before closure activities begin. A closure notice will be posted 60 days prior to closing. Date of closure and alternate disposal sites will be indicated. A notice of closure will be published in a local newspaper 30 days prior to closure. A copy will be sent to the MPCA Commissioner. 2.4 Closure Schedule The closure schedule is dependent on the waste flows and facility design. Closure will be initiated in a phased approach, leaving only the operating cell(s) in an "open" condition. Independent cells, or portions thereof, will be closed once filled to final elevation. The facility is expected to reach final capacity in the MSW area in approximately the year 2028 given current projected MSW disposal rates. Per the Conditional Use Permit with the City of Elk River, no MSW waste will be disposed in the MSW area after December 31, 2030. All closure construction within the City of Elk River will be completed by December 31, 2031, unless an alternate schedule is agreed upon by both the City and the Landfill. BProject Number: 227705133 2.1 The facility is not expected to reach final capacity in the C&D area for more than 25 years. However, this projection is subject to change based on several factors. 2.5 Closure Procedures Closure of each cell in the MSW and C&D disposal areas will be initiated upon reaching final grade according to the closure requirements in the permit. Alternatively, a temporary cap may be installed with final closure activities at a later date. The closure area surface will be brought to final grade and benched, if not already done so, according to the design plans. Appropriate buffer layers to bring surface to final grade will be placed during site operations. A summary of closure procedures is as follows: Inspect soil buffer layer and supplement as necessary. Install minimum 40-mil synthetic flexible membrane liner. Install geonet drainage layer according to the design plans. Grading and placement of 18 inches of soil fill. Placement of 6 inches of vegetation supporting topsoil. Seed and mulch the final covered area. Landfill gas management features will be installed prior to or concurrently with the placement of final cover according to the Landfill Gas Management Plan. Any changes in the design will be incorporated into a re-evaluation of closure costs and the related financial assurance calculations at the time of final cover construction. At the time of final closure of the facility, all stored material, tires, appliances, etc. will be hauled to a facility for recycling or an operating permitted disposal facility as appropriate. On -site structures which will require removal upon closure will be evaluated as the site approaches final closure. All temporary and final cover materials will comply with the requirements of applicable rules at the time of construction (see construction specifications). 2.6 Certification Of Cell/Final Closure Upon completion of activities for final closure of any cell, a closure documentation report, signed by a professional engineer registered in the State of Minnesota, stating that the cell has been closed in accordance with approved plans and specifications will be submitted to the MPCA as required by the MPCA Solid Waste Rules Part 7035.2610. Testing of the various components of the cover will be conducted and documented in accordance with the Construction Quality Assurance/Quality Control Plan in effect at the time of final closure and in accordance with applicable rules. The final closure construction documentation will be submitted to the MPCA no later than 60 days following completion of final cell closure. The documentation will contain record drawings, testing data, description of the construction process, and photographs of the major aspects of the construction phase. In addition, upon final closure of the facility, a detailed description, including a plat, will be recorded with the Sherburne County Recorder. The description will include general types and location of wastes, depth of fill, and other information of interest to future landowners. A copy of record drawings will be submitted to the Sherburne County Recorder and the MPCA. BProject Number: 227705133 2.2 2.7 Deed Notation Sherburne County will record a notation on the deed to the property, or on some other instrument normally examined during a title search. The notation will, in perpetuity, notify any potential purchasers of the property of any special conditions or limitations for use of the site. The notation will include record drawings for the facility. A copy of the notation carrying the County Recorder's seal will be included with the final closure certification. 2.8 Amendment Of Closure Plan A modified closure plan will be prepared and submitted to the MPCA for approval within 60 days of any change or event that affects the Closure Plan. This applies to any change in the Operations and Maintenance Plan or facility design affecting closure procedures, or whenever the expected year of closure changes. In the case of this facility, the Closure Plan is reviewed on an annual basis during preparation of the annual report and will be updated at the time of re -permitting to incorporate any changes in operations, design or scheduling of closure. 2.9 Closure Cost Estimate MPCA Rules Part 7035.2685 requires that a cost estimate be prepared for closure of the largest area that may require closure. For purposes of financial assurance, it is assumed that 72 acres will require closure, which provides for the largest, most expensive closure activity, as required by the MPCA Rules. Table 2 presents the estimated closure costs and justification for the proposed closure. Prices reflect past project experience and those typical of construction projects in the area. Closure cost estimates will be updated by March 1 of each year to adjust for inflation, areas previously closed, and changes in design, closure plans, or site conditions which require changes in the cost estimates. BProject Number: 227705133 2.3 3 Post -Closure Plan 3.1 General Waste Management or any successor will be responsible for the post -closure care of the site. Minnesota Solid Waste Management Rules, Parts 7035.2645 and 7035.2655 are used as a guide to determine postclosure requirements. The post -closure period begins after final closure certification and continues for a period of at least 20 years from that date. A summary of the post -closure care program is provided in the following text. 3.2 Inspection And Maintenance Routine inspection of the site will occur at least four times a year (spring, summer, fall and winter). The inspections will include observations of cover integrity (e.g., erosion of the final cover or problems with vegetation quality); evaluation of settlement and surface water drainage; inspection of the leachate collection system; inspection of the landfill gas extraction system; and inspection of monitoring systems and site security features. Specific inspections of certain portions of the facility may be conducted on a more frequent basis as required by other permits (i.e. air permit). If a site inspection reveals any problems with leachate collection systems, landfill gas extraction system, monitoring systems, security systems, or the final cover, appropriate corrective measures will be taken as outlined in the Contingency Action Plan. In addition, routine maintenance, such as mowing to prevent tree growth, and maintaining drainage way flow capacity, will be performed as needed. Any features found to need repair or maintenance during the inspections will be promptly and properly repaired and maintained. This includes, but is not limited to, security fencing, monitoring wells, active gas collection systems, leachate collection systems, and surface water control structures. Other inspection, monitoring, and maintenance practices are defined in the following sections for specific facility features. 3.3 Environmental Monitoring Groundwater monitoring, surface water monitoring and leak detection monitoring will be performed according to the MPCA-approved environmental monitoring plan in place for the post -closure period. The current Site -Specific Sampling and Analysis Plan (SAP), Barr Engineering, February 2021 (Appendix G of the Operations and Maintenance Plan) should be referred to for a complete list of monitoring points, parameters and monitoring schedule currently in place. This SAP will be updated in the future in anticipation of closure and will outline the monitoring to be conducted during the post -closure period. 3.3.1 WATER QUALITY The current groundwater monitoring network at the Landfill includes monitoring wells located around the C&D and MSW areas. As the site is developed to both the north and south, additional monitoring wells may be installed and some may be removed. The groundwater monitoring network will be modified as needed, and will also be modified as the site enters the post -closure period. Currently, groundwater monitoring wells are sampled three times per year (spring, summer, fall). During the post -closure period, a set of groundwater monitoring wells will likely be monitored on a semi-annual to annual basis. MProject Number: 227705133 3.1 The Landfill also currently samples a network of 14 residential wells located around the Landfill on an annual basis. Monitoring of residential wells will likely be reviewed in the post -closure period. 3.3.2 SURFACE WATER Surface water monitoring is currently conducted at two existing monitoring points during the spring, summer, and fall monitoring events. The monitoring points are located in the Rice Lake wetland complex. During the post -closure period, surface water monitoring will likely either continue to be conducted on a semi-annual basis or switch to annual monitoring. 3.3.3 LEACHATE Leachate is currently monitored in accordance with the MCES and MPCA permits, a City of Elk River Industrial Wastewater Treatment Agreement, as well as the requirements for leachate recirculation (if applicable). The leachate monitoring events are currently conducted quarterly with additional monthly samples collected for compliance with some requirements of the MCES permit for off -site disposal and City of Elk River direct connection disposal. Leachate monitoring is anticipated to follow a similar schedule as long as leachate continues to be hauled or pumped off -site for treatment at a WWTF. 3.3.4 LEAK DETECTION The facility lysimeters are currently monitored three times per year to coincide with water quality monitoring. Leak detection lysimeters are currently located in existing cells 6 through 20. During the postclosure period, lysimeter monitoring will likely be reduced to coincide with other monitoring conducted onsite. 3.4 Surface Water Runoff Control Facilities During post -closure, on -site benches, drainage ditches, swales, downslope structures, downslope piping, and ponds will be inspected at least four times annually, and after major storm events, to determine any need of maintenance. Maintenance associated with sediment accumulations or erosion problems will be performed as needed. Sedimentation ponds will be cleaned as necessary (likely more often shortly after closure, and less frequently towards the end of the post -closure care period). 3.5 Final Cover Surface The final cover surface will be inspected at least four times annually for erosion and settlement. Surface repairs will be performed as needed. Supplemental cover soil will be placed when needed due to erosion and settlement. Seeding, fertilizing, and mulching of bare soil will be provided where required. MPCA will be kept informed of the scheduled repairs. Any and all areas that have been seeded, fertilized and mulched will be inspected quarterly to check for erosion, to make sure that sustained vegetative growth has been established and continues to survive. All erosion ruts or gullies, and general settlement areas of the final cover landfill area will be refilled with suitable earth, graded and reseeded accordingly. BProject Number: 227705133 3.2 3.6 Leachate System Management The leachate handling systems collect leachate and transfer it to one of the leachate storage tanks. Leachate is either recirculated through the waste in accordance with the recirculation plan or hauled to a WWTF for treatment. The leachate collection system pipes will continue to be cleaned at a minimum of once per year. Leachate will be sampled and analyzed in accordance with the SAP (Barr Engineering Feb. 2021, or as modified). The HELP model shows that after final closure, leachate generation approaches zero. This is due to the extremely efficient performance of the FML/geonet combination. However, the tremendous number of variables utilized in the HELP model usually allows only a gross approximation of leachate quantity. Therefore, an alternative method for estimating post -closure leachate generation will be used. The other method used to estimate leachate quantity is by direct comparison to existing landfills with leachate collection. Using this latter method the MPCA suggests that appropriate estimations can be obtained by expecting five percent of total precipitation which contacts a landfill final cover. Utilizing this method, the maximum average annual leachate production for the facility during post -closure is estimated to be 4,655,325 gallons. Based on experience, the volume of leachate produced will decrease over the postclosure period. Assuming the maximum leachate generated during the first year of post -closure is 4,655,325 gallons, the quantity generated decreases by 50% by year five (2,327,662 gallons), and leachate generation is negligible by the end of the post -closure period (year 20); the average annual volume of leachate produced during post -closure is 1,745,747 gallons. Landfill gas condensate and liquid from the gas extraction wells is also managed by the leachate collection system and hauled off -site for treatment at a WWTF. The quantity of condensate managed during post -closure for the purposes of deriving treatment costs was estimated at 4% of the leachate produced. The average annual condensate production is calculated as 69,830 gallons. Therefore, the average generation of leachate and condensate will be approximately 1,815,577 gallons/year (1,745,747 gallons leachate + 69,830 gallons condensate). Leachate may be recirculated back into the waste to maximize landfill gas production during landfill operation, however, for purposes of financial assurance cost estimation, it is assumed that leachate is discharged directly to Elk River WWTF for treatment. It should be noted that the Landfill continually reviews their options with regard to leachate management, both on- and off -site, and will continue to do so into the post -closure period. 3.7 Gas Monitoring During post -closure, landfill gas monitoring will be performed at minimum on a quarterly basis. Monitoring of certain aspects of the gas system will likely be conducted more frequently in accordance with other permits and regulations (i.e. air permit). A portable methane gas meter will be used to measure the gas concentrations at designated monitoring points. A portable meter will also be used for conducting surface scans. The in -place meters measuring flow and other parameters at the flares and gas plant will also likely continue to be used into the post -closure period. At the perimeter gas probes, the detection of methane above 25 percent of the LEL at any of the monitoring points will trigger an investigation as to the cause, and likely result in an adjustment of flow rate in the landfill gas wells associated with the area in question. MProject Number: 227705133 3.3 3.8 Reporting A report describing the inspection, conditions observed, corrective actions, maintenance activities and monitoring activities and results is prepared and transmitted to the MPCA annually on or before March 1. The corporate contact for the facility during the post -closure period will be: Elk River Landfill District Manager 22460 Hwy 169 NW Elk River, MN 55330 Phone: (763) 441-2464 3.9 Ultimate Land Use Waste Management will control uses of the site so there will not be disturbance to the final cap system, liner, leachate collection system, landfill gas management system, or monitoring system unless approval is obtained from the MPCA. If the property is sold, the deed will thoroughly document any required restrictions. If an alternative end use is planned, the proposal will be brought to the City, County and MPCA for approval. 3.10 Amendment Of Post -Closure Plan A modified Post -Closure Plan will be prepared and submitted to the MPCA for approval within 60 days of any change or event that affects the Post -Closure Plan. This applies to, but is not limited to, any change in the monitoring system or procedures. The Post -Closure Plan will be amended whenever the permit is renewed. 3.11 Post -Closure Care Cost Estimate Table 3 provides a summary of annual post -closure care costs. The long-term care cost projection for 20 years, based on the annual post -closure costs, will be used for financial assurance calculations. BProject Number: 227705133 3.4 4 Contingency Action Plan 4.1 General This section presents the Contingency Action Plan for the Landfill, prepared in accordance with Part 7035.2615 of the MPCA Solid Waste Rules. In addition to routine landfill contingency responses for the MSW and C&D disposal areas, this Plan also includes responses to events that may occur due to leachate recirculation. The purpose of this plan is to: • Identify occurrences at the facility such as natural disasters, vandalism, accidents or failure of constructed design features that could lead to release of solid waste or leachate and endanger human health and the environment. • Establish the sequence and timing of response actions that would minimize hazards to human health and the environment. • Identify equipment needed to remediate each occurrence. • Identify any possible prior arrangements to be made with contractors in order to assure timely and effective response action. • Estimate the costs associated with these response actions. Section 4.2 identifies potential occurrences, or contingencies, for this facility which may need corrective action. Section 4.3 describes contingent corrective action procedures, including the sequence and timetable, to be followed in case any of the events identified in Section 4.2 take place. Section 4.4 presents action levels for groundwater, surface water and air quality, whichever are included in the monitoring program. Section 4.5 discusses equipment availability. Section 4.6 presents estimated costs for the identified contingency actions. Section 4.7 discusses the need for amendment of this Contingency Action Plan. A copy of this plan will be kept at the Landfill office at all times for reference by on -site and operations personnel as well as regulatory inspection personnel. Each contingency set forth in this plan has a number of possible solutions and no contingency plan can directly address circumstances encountered. Therefore, the MPCA will be promptly notified of major incidents and regular discussions will be held on proposed actions and response status. 4.2 Contingencies That May Need Corrective Action Certain events that may occur at the Landfill could endanger human health or the environment. These events could be the result of natural disasters, accidents, vandalism or failure of constructed design features. Each of the tables listed in the following sections lists contingencies which may be triggered by events, inspections or monitoring, respectively; the possible result, effect, or cause of the contingency; and actions to be taken to evaluate and respond to the contingency. BProject Number: 227705133 4.1 4.2.1 EVENT -TRIGGERED CONTINGENCIES Table 4A lists potential event -triggered contingencies. Event -triggered contingencies may include severe rainfall, leachate spill, grass fire, or other sudden, unanticipated events. 4.2.2 INSPECTION -TRIGGERED CONTINGENCIES Table 4B lists potential inspection -triggered contingencies. Inspection -triggered contingencies may include signs of distress in the landfill cover (such as stressed vegetation), cover erosion, leachate head buildup on the liner beneath the waste, surface drainage problems and other findings associated with routine wear and aging of the facility and noticed during routine inspections. 4.2.3 MONITORING -TRIGGERED CONTINGENCIES Table 4C lists potential monitoring -triggered contingencies. Monitoring -triggered contingencies may include contamination of groundwater or surface water beyond action levels, leachate detected in the leak detection systems, detection of methane at gas monitoring points, and other findings discovered as a result of routine facility monitoring. 4.3 Corrective Actions 4.3.1 EMERGENCY ACTIONS Many of the event -triggered contingencies such as natural disasters, vandalism, fire, embankment failure or leachate spill may require an emergency response. Such responses typically need to be implemented immediately and may involve equipment and personnel beyond those routinely involved with facility operation. These additional resources could include city fire and police departments and additional contractor equipment and personnel. Table 4A summarizes, and the following paragraphs describe, the general emergency actions which may be necessary in response to each identified event -triggered contingency. 4.3.1.1 General In the event of emergencies at the site during operations or post -closure, Waste Management personnel must be contacted. The following is the key contact at Waste Management for site operation and design: Elk River Landfill District Manager 22460 Hwy 169 NW Elk River, MN 55330 Phone: (320) 510-5438 The District Manager will then contact the necessary safety, environmental, or management personnel within Waste Management to assist with the necessary corrective action. The District Manager will also be involved with the necessary notifications to regulatory personnel. The District Manager, or other Waste Management personnel as necessary, will contact any additional resources necessary, such as consultants, contractors or emergency responders, to assist with the needed efforts. If necessary, the BProject Number: 227705133 4.2 Landfill will submit a written report describing the emergency and the procedures followed to minimize potential hazards to the MPCA (typically within two weeks of the emergency). 4.3.1.2 Severe Rainfall As soon as weather permits, inspect the site to determine any damage to the vegetation, berms, cap, surface water controls, and monitoring systems. If damage is noticed, take measures to correct the damage. For instance, place temporary erosion controls, such as soil fill, erosion control blanket or mulch, to minimize further erosion. Place sand bags or riprap to stabilize facility features. Place sandbags and temporary piping to make runoff controls temporarily functional. Remove any excess sediment from runoff controls and outlets. 4.3.1.3 Flood The Landfill is not within the floodplain; thus flooding of the facility is improbable. 4.3.1.4 Leachate Spill Immediately retrieve any free liquid by pumping it into holding tanks, tank trucks or steel drums, and apply absorbent materials to absorb un-pumpable liquid. If the spill is greater than 5 gallons, immediately contact the State Duty Officer at (651) 296-8100. In such case, emergency actions will be implemented immediately. 4.3.1.5 Grass Fire Attempt to extinguish fire using water, fire extinguisher or soil. Contact the Elk River Fire Department for assistance if necessary. Clear all access roads of equipment to facilitate emergency vehicle access. If a fire affecting the site goes unreported during post -closure, the leachate tanker truck operator will notice any related damage during his site visits. He will move to address these issues immediately by notifying responsible Waste Management personnel of the damage. 4.3.1.6 Vandalism For acts of vandalism that create hazards to human health and the environment, appropriate temporary repairs should be performed as soon as possible to make the damaged system temporarily functional. If a vandalism affecting the site goes unreported during post -closure, the leachate tanker truck operator will notice any related damage during his site visits. He will move to address these issues immediately by notifying responsible Waste Management personnel of the damage. 4.3.2 FOLLOW-UP TO EMERGENCY ACTIONS As soon as possible following the occurrence and emergency response to an event requiring emergency actions, a detailed inspection of the affected areas will be performed. The site operation team will conduct the inspection. The purpose of the inspection will be to assess the degree and extent of damage, if any, to the final cover, surface water controls, landfill gas management system, leachate BProject Number: 227705133 4.3 collection system, monitoring systems, access roads, fencing, etc. The extent of any damage will be described in detailed inspection notes and photographed. Following the inspection, a brief report will be prepared by the operator's technical staff describing the emergency and effects of damage, if any, on the intended purposes of the engineering features of the facility. The report will also identify repair procedures that will restore the features to their intended function. The inspection report and proposed repair schedule will be submitted to the MPCA on a schedule agreed to by all parties. 4.3.3 EVENTS NOT REQUIRING EMERGENCY ACTION Inspection -triggered and monitoring -triggered contingencies such as small cracks in embankments or the cover, a gradual embankment or cover movement trend, cover settlement, leachate seeps, minor erosion, leachate head buildup, detects in leachate leak detection devices, surface drainage problems and water quality violations generally will not require an emergency response. These contingencies, however, may require interim response actions, continued or enhanced monitoring, assessment of the extent of the problem, and/or evaluation of the design prior to implementation of repairs or remedial actions. Action for inspection- and monitoring -triggered contingencies is summarized in Tables 4B and 4C, respectively. 4.3.3.1 Water Quality The following discussion describes the general procedures to follow for actions related to water quality problems. The procedure is divided into two steps. The first is verification of the problem. The second is the response to employ if the first step is indicative of a problem. Each problem has a number of possible solutions and no contingency plan of action can directly address all circumstances encountered. Therefore, this plan is conceptual and flexible, to be used as a preliminary guide by all those associated with the project. The initial steps identified here will help define the plan of action to be followed for specific contingency occurrences. • If a water quality action level defined by the current permitting document is exceeded, notify the MPCA in writing. • Check all sampling, sample handling and analytical procedures to verify that proper techniques were used. • Determine the potential implications of the elevated parameters, by examining background and historical data, reviewing regional and time variations in water quality and determining if all monitoring points are showing elevated levels or if the occurrence is localized. • If necessary, resample to verify results. • If similar results are found from resampling, evaluate the results for potential impact to human health and the environment. • Based on the significance of the results, determine if immediate action is needed or if continued or expanded monitoring is sufficient. Expanded monitoring may include increasing the frequency of sampling. • Meet with the MPCA staff to determine the need to implement assessment monitoring to comply with requirements for disposal sites. • Determine, if possible, the source of the problem. During the time period covering the above actions, routine water monitoring will also continue according to the regular schedule. MProject Number: 227705133 4.4 Once the above evaluation is complete and the conclusion is reached that a problem is occurring, the next step is to determine the nature and extent of that problem. This may be done by continuing to monitor the existing monitoring points or by installing additional monitoring points. The information gathered during this period of investigation will be submitted to the MPCA in a report. The result will then be used to complete a feasibility study that will determine the remedial action needed, if any, to correct the problem. Examples of remedial actions which might be selected individually or in combination are: • Continuing the monitoring of groundwater and surface water and, if necessary, expanding the monitoring system. • Repairing the final cover or surface drainage features these have been identified as the cause of the problems. • Repairing the leachate collection system if these have been identified as the cause of the problem. • Installation of a groundwater extraction system and/or groundwater flow barrier. • Installation or modification of landfill gas extraction wells. 4.4 Action Levels Water quality intervention levels have been established for the site, and are discussed in the Annual Reports prepared for the facility. These levels are for use in determining compliance for the facility, based on results from the environmental monitoring system. Note that these action levels are updated by MDH and MPCA periodically and thus may change through the operating life of the facility and the post - closure period. These changes will be noted in the annual reports due each February 1. In the event of action level exceedances, the MPCA will be notified by Landfill staff and a contingency plan of action will be discussed and implemented as necessary. 4.5 Equipment Availability The Landfill maintains several pieces of equipment at the site for operations during the active operating period of the Landfill. On -site equipment could be utilized for emergency actions at the facility. A partial list of available equipment (as of August 2022) is: • One CAT D6 Dozer • Two Kamatsu Dozers • One Hyundai 780 Loader • One Dresser 538 Loader • One CAT Grader • One CAT 740 Ejector Haul Truck • One CAT 973 Track Loader • One CAT Skid Loader • Two CAT 836 Compactors • One CAT 826 Compactor • One CAT Excavator • One Volvo A25G Water Truck MProject Number: 227705133 4.5 The types and amount of equipment available following closure of the Landfill will be greatly reduced. However, equipment is available on very short notice from a variety of local sources, including other Waste Management facilities, local contractors, or rental facilities. 4.6 Amendment Of Contingency Plan A modified contingency plan will be prepared and submitted to the MPCA whenever the facility permit is amended; the design, construction, operation or maintenance of the facility change; or when a release at or failure of the facility occurs which indicates revised procedures or costs are necessary. The Financial Assurance plan will be revised whenever amendment of the Contingency Action Plan requires such a change. 4.7 Estimated Costs For Contingency Actions Cost estimates for contingency actions are summarized in Table 4D. The actions included in the Contingency Action Plan cost estimates are considered to be occurrences above and beyond the routine maintenance performed during site operation and post -closure care. The cost estimates include the capital expenditure required to implement the contingency action, and where appropriate, the annual operation and maintenance costs of the contingency action. Operating and maintenance costs for subsequent years are included for the estimated period of operating time of the contingency action, or through the 20-year post -closure period. Cost estimates for contingency actions will be revised as necessary during the operating life of the facility, to account for inflation and other needed changes, such as those which would be addressed in an amended plan. BProject Number: 227705133 4.6 Closure, Post -Closure, Contingency Action Plan and Financial Assurance Plan 5 Financial Assurance 5 Financial Assurance Financial assurance for site closure, post -closure maintenance and monitoring and contingency action is provided by establishment of a Financial Guarantee Bond (Bond) in accordance with Part 7035.2735. The financial assurance cost estimate as calculated is $12,680,501.54, as detailed in Table 5. The Landfill currently has a Bond on file with the MPCA and it is adjusted annually based on the required review of the financial assurance for the annual report submittal. Upon approval of the revised cost estimates included in this report, the Landfill will revise the value of their Bond. The Bond value will also be revised with subsequent annual report submittals accordingly. In addition to the financial assurance established with the MPCA, the Landfill also has established financial assurance with both the City of Elk River ($300,000) and Sherburne County ($300,000). The financial assurance mechanism currently implemented with both the City and County is also held in the form of Bonds. MProject Number: 227705133 5.1 Closure, Post -Closure, Contingency Action Plan and Financial Assurance Plan TABLES MSW Southern Development Area Design Volumes Closure Cost Estimate 3 Post -Closure Cost Estimate 4A Event -Triggered Contingencies 4B Inspection -Triggered Contingencies 4C Monitoring -Triggered Contingencies 4D Contingency Action Cost Estimate 5 Post -Closure Cost Calculation MProject Number: 227705133 Airspace (CY)(3) Final Cover Area (acres)(4) Final Cover & Buffer Soils (CY) 12" Base Drainage Layer (CY) 24" Base Clay Liner (CY) HDPE Liner Quantity (SF) Operational Volume (CY)(5) Intermediate Cover Soils (CY) Airspace Waste Only (CY) Site Life (years)(') Open Date Close Date 1,573,697 16.4 66,308 8,398 18,715 252,648 1,507,389 188,424 1,318,965 3.0 2023 2028 1,573,697 16.4 66,308 8,398 18,715 252,648 1,507,389 188,424 1,318,965 3.0 2028 over sr soils. Ards per year Table 2 Closure Cost Estimate Elk River Landfill - Entire Facility Unit Unit Price Quantity Cost LS $25,000 1 $25,000 Mobilization Cover System LLDPE Liner SF $0.34 3,136,320 $1,066,349 Geocomposite SF $0.55 3,136,320 $1,724,976 Cover soils CY $3.25 174,240 $566,280 Topsoil CY $11.00 58,080 $638,880 Seed & Mulch Acre $700 72 $50,400 Buffer Soils CY $4.00 58,080 $232,320 Drainage Control Features MSW Erosion Control SF $0.11 679,536 $74,749 Demo Erosion Control SF $0.11 365,904 $40,249 CPEP drain pipe (4-inch) LF $4.00 12,040 $48,160 CPEP drain pipe (18 and 24-inch) LF $25.00 1,000 $25,000 CPEP drain pipe (36-inch) LF $30.00 2000 $60,000 Sedimentation ponds LS $200,000.00 1 $200,000 LFG System Mobilizations LS $25,000 1 $25,000 MSW Active System Condensate piping LF $5.00 1,625 $8,125 Subheader piping LF $32.00 3,000 $96,000 Header piping LF $87.00 950 $82,650 Condensate sump Each $16,500 4 $66,000 Wellheads Each $600 65 $39,000 Gas Wells VF $92.00 5,550 $510,600 Demo Passive System Piping LF $18.30 250 $4,575 Vents Each $224.00 3 $672 Trenching LF $42.75 250 $10,688 Granular Backfill CY $5.70 100 $570 SUBTOTAL (CONSTRUCTION) $5,596,243 Engineering (@10% of construction) LS $5,596,243 0.1 $559,624 2022 Costs TOTAL $6,155,900 U:\227705133\technical\CPCCAP\Elk River 2021 cost tables.final.xlsx Closure -facility Table 3 Post -Closure Costs Elk River Landfill - Entire Facility Unit Cost Unit Price Quantity Cost Totals Facility Inspection Costs $6,050 Landfill Supervisor hour $50 100 $5,000 Technician hour $35 30 $1,050 Routine Maintenance $49,060 Mowing acre $150 141.4 $21,210 Fertilizing acre $150 10 $1,500 Cover Revegetation acre $1,500 3 $4,500 Security and Building Repair LS $3,000 1 $3,000 Surface Water Management and Maintenance LS $6,000 1 $6,000 Access Road Maintenance LS $1,200 1 $1,200 Rodent Control hour $25 16 $400 Erosion Repair acre $7,500 1.5 $11,250 Leachate System Management $33,500 Collection System Cleaning (1x/year) LF $0.50 10,000 $5,000 Leachate Management (direct discharge to City) gallon $0.013 1,900,000 $24,700 Leachate Monitoring Monthly Sample Collection sample $75 12 $900 Monthly Analysis sample $50 12 $600 Quarterly Sample Collection sample $75 4 $300 Quarterly Analysis sample $500 4 $2,000 $30,100 Landfill Gas Management MSW Active System Blower Replacements LS $2,200 1 $2,200 Flare and Generator Maintenance LS $2,000 1 $2,000 System Operation and Inspection LS $7,500 1 $7,500 Collection System Replacement (1 well/5 years) LS $12,000 0.2 $2,400 Gas Management System LS $9,000 1 $9,000 Demo Passive System System Maintenance & Inspection LS $2,000 1 $2,000 Reporting LS $5,000 1 $5,000 Monitoring Water Sample Collection Monitoring Well Sample 11 Residential wells sampled 1x/year 4 Residential wells samples 1x/ 3 years Lysimeter Monitoring Lab Analysis Quarterly Analysis (spring) Quarterly Analysis (summer) Quarterly Analysis (fall) Residential Well Analysis Lysimeter Samples System Maintenance Monitoring Well Replacement (5 wells/10 years) Gas Monitoring (3x/year) Reporting Administrative and Reporting Services 2022 Costs $38,643 sample $120 98 $11,760 sample $120 11 $1,320 sample $120 1.333 $160 LS $800 2 $1,600 sample $100 29 $2,900 sample $140 43 $6,020 sample $100 26 $2,600 sample $100 12.333 $1,233 sample $75 4 $300 hour $50 10 $500 well $4,000 0.5 $2,000 LS $2,250 1 $2,250 LS $6,000 1 $6,000 LS $8,000 1 $8,000 TOTAL $165,400 U:\227705133\technical\CPCCAP\Elk River 2021 cost tables.final.xlsx Post -Closure -facility TABLE Event -Triggered Contingency 1. Severe Rainfall 2. Leachate or Fuel Spill 4A Event -Triggered Contingencies Elk River Landfill Result Threatened Embankment Stability Actin Report; immediately assess damage visually; within ten working days place sand bags, soil fill or riprap to temporarily stabilize embankment; check for cracking and differential movement; evaluate condition and design and prepare permanent repair procedures report; implement recommendations. Erosion Report; within fourteen working days place temporary erosion controls, such as hay bales, erosion control mats, silt fences, or mulch; assess damage; make permanent repairs. Damaged Surface Water Control Damaged Vegetation Report; within fourteen working days place sandbags, soil fill, and/or temporary piping to make surface water controls temporarily functional; remove sediments from outlets; evaluate and make permanent repairs. Report; assess damage; if necessary, within fourteen working days place temporary erosion controls; evaluate cause; re -vegetate Surface Water or Report; immediately contain Groundwater Contamination and collect retrievable leachate and absorb remaining leachate; monitor; evaluate impact; determine and implement appropriate follow-up actions. Soil Contamination Report; within fourteen working days collect saturated soil for disposal in lined cell; collect soil samples below excavation; evaluate impact; determine and implement appropriate follow-up actions. 3. Grass Fire Damaged Vegetation Report; immediately place soil over fire or use water to extinguish fire; contact City of Elk River Fire Department if necessary to extinguish fire; clear access roads for equipment access; extinguish fire; place temporary erosion controls; revegetate. 4. Subsurface Fire Waste Burning Reduce extraction rate from gas wells. Saturate surface with water to suffocate fire. 5. Explosion Report; contact Elk River Fire Department; if Event -Triggered Result Action Contingency necessary to extinguish fire, evaluate damage, determine and implement appropriate follow-up action. 6. Unacceptable Aesthetic Degradation This would most likely be Odors Developed identified by reports generated from WMI staff, regulators, or neighbors. If such a report occurs, ERL will notify the MPCA and take appropriate actions 7. Vandalism Damage to Facility Features Report; within fourteen working days assess impact; based on impact repair damage; assess site security. TABLE 4B Inspection -Triggered Contingencies Elk River Landfill Inspection -Triggered Contingency Result Action 1. Leachate Head Buildup Increased GroundwaterExtract and dispose or treat leachate; Contamination Potential monitor; evaluate cause of leachate head buildup; if necessary, increase leachate hauling frequency. 2. Erosion or Degradation of Cap Increased Leachate Report; immediately assess damage; within Generation, Potential fourteen working days place temporary Surface Water erosion controls; evaluate cause and Contamination design; make permanent repairs. 3. Clogged Surface Water Controls Erosion Report; within fourteen working days place temporary erosion controls; remove cause of clogs; assess damage; repair erosion; evaluate design and make any needed changes; clean pipes, ditches, and sedimentation ponds, as needed. 4. Leachate Detected in Leachate Increased GroundwaterReport; within seven working days extract Sump Leak Detection System Contamination Potential and dispose or treat leachate; monitor; evaluate quantity and rate of leakage; evaluate potential impacts on groundwater; if necessary, evaluate cause and determine potential remedial actions; implement remedial action. 5. Gas System Failure Increased Gas Migration Report; immediately isolate affected system Potential components and continue operation of unaffected portions of the gas system (if possible); evaluate cause and design; make permanent repairs 6. Leachate Seeps Damaged Vegetation Report; assess damage and evaluate cause; make permanent repairs and revegetate Surface Water or Report; immediately contain and collect Groundwater retrievable leachate and absorb remaining Contamination leachate; monitor; evaluate impact; determine and implement appropriate follow-up actions Soil Contamination Report; within fourteen working days collect saturated soil for disposal in lined cell; collect soil samples below excavation; evaluate impact; determine and implement 7. Leachate Collection System Failure Increased Groundwater Contamination Potential appropriate follow-up actions. Report; immediately assess damage; evaluate cause and design; make permanent repairs. 8. Leak in Leachate Tank or Increase Groundwater Report; immediately assess damage; Transmission Pipe Contamination Potential evaluate cause and design; make permanent repairs. TABLE 4C Monitoring -Triggered Contingencies Elk River Landfill Monitoring -Triggered Contingency Result 1. Exceedance of Groundwater Groundwater Standard Contamination Action Report; continue monitoring; within fourteen working days evaluate impact; complete feasibility study and determine remedial action; implement remedial action. 2. Exceedance of Surface Water Surface Water Report; continue monitoring; within Standard (in Sedimentation Contamination fourteen working days evaluate impact; Basins) complete feasibility study and determine remedial action; implement remedial action. 3. Exceedance of Allowable Levels Unacceptable Monitor; report, evaluate cause of for Leachate Discharge to Impact at MCES exceedance; design permanent Treatment Plant. Treatment Plant pretreatment actions or choose alternative disposal method, choose alterative and write repot; implement recommendations. 4. Leachate Detected in Leachate Increased Report; within seven working days Leak Detection System Groundwater extract and dispose or treat leachate; Contamination monitor; evaluate quantity and rate of Potential leakage; evaluate potential impact on groundwater; if necessary, evaluate cause and determine potential remedial actions; implement remedial action. 5. Detection of Methane Potential Explosive If exceedance is near an closed Concentrations Above Conditions structure, evacuate and ventilate Acceptable Limits at Gas structure, investigate whether methane Monitoring Points. is entering structure, propose repose to protect structure if needed; report; adjust flow rate at applicable extraction wells; continue monitoring. 6. Monitored Natural Attenuation Insufficient If the corrective actions are not judged (MNA) is Not Shown to be Corrective Action to be protective as part of the initial Protective as Part of the Initial MNA assessment (in accordance with MNA Assessment MPCA-approved Groundwater Corrective Action Work Plan, Barr, March 2021), ERL will provide a schedule and details for designing and implementing a groundwater extraction and treatment system. Table 4D Contingency Action Cost Estimate Elk River Landfill :hate Spill Cleanup (1,000 gallons, 100 cy soil) iquid Recovery isposal ontaminated Soil Excavation lean Soil Fill lobilization are Erosion/Embankment Repair (1 acre) over Fill evegetation lean Surface Water Controls leanup w Cover Damage Repair (1 acre) ;s Fire and Revegetation ire Fighting evegetation surface Fire/Explosion ire Fighting ework Cap (2 acres) :hate Collection System Repair roblem Assessment and Engineering igh Pressure Flushing of Collection Pipes eplace Collapsed Pipe xcavate and Replace Waste eplacement of 25 pumps damage is deep, install final cover indwater Extraction and Treatment lobilization ite Preparation Unit Unit Price Quantity Cost hour $250 6 $1,500 gal $0.013 1000 $13 CY $8.00 100 $800 CY $4.00 100 $400 LS $2,500 1 $2,500 CY $6.50 16133 $104,865 acre $800 5 $4,000 LF $0.50 2000 $1,000 LS $10,000 1 $10,000 acre $77,000 1 hour $500 8 $4,000 acre $800 2 $1,600 day $5,000 15 $75,000 acre $77,000 2 $154,000 LS $5,000 1 $5,000 LS $10,000 1 $10,000 LF $18.00 200 $3,600 CY $10.00 9000 $90,000 each $1,500 25 $37,500 acre $77,000 5 $385,000 LS $72,540 1 $72,540 LS $10,000 1 $10,000 Cost Totals $5,2' $119,91 $77,01 $5,6' $229,01 $531,11 $1,447,41 xtraction Well Installation - Mud Rotary Methods each $26,067 3 $78,200 iezometer Installation - Sonic Methods each $15,000 3 $45,000 rench Excavation and Backfill LF $20 1000 $20,000 tility Bedding Soil LF $2.00 1000 $2,000 DPE Forcemain - 2" Dia. SDR11 (Well lines) LF $3.50 1000 $3,500 irectional Drilling 4" Dia. Line 8' Deep LF $10.00 7700 $77,000 DPE Forcemain - 4" Dia. SDR11 (pipe around LF to east infilt. basin) LF $6.00 7700 $46,200 ressure Testing and Quality Control LS $20,000 1 $20,000 Jell Power and Conduit LF $11.00 1000 $11,000 orcemain Sheet Insulation LF $12.50 1000 $12,500 ✓ater Treatment Structure LS $58,000 1 $58,000 ✓ater Treatment Units LS $140,000 1 $140,000 ✓ater Treatment Plumbing LS $20,000 1 $20,000 qualization Tank, Controls, and Transfer Pumps LS $47,000 1 $47,000 xtraction Well Controls, Well Pumps, and Instrumenation LS $100,000 1 $100,000 apid Infiltration Basin LS $15,000 1 $15,000 tartup/Commissioning LS $20,000 1 $20,000 onstruction Contingency 25% $797,940 0.25 $199,485 ischarge Permitting LS $20,000 1 $20,000 lodel Application LS $20,000 1 $20,000 reatment Pilot Test LS $100,000 1 $100,000 esign Investigation LS $50,000 1 $50,000 ngineering and Construction Administration 26% $997,425 0.26 $260,000 TOTAL $2,415,21 2021 Expected Value (assumed @ 60%) $1,449,1; J:\227705133\technical\CPCCAP\Elk River 2021 cost tables.2022rev.xlsx Contingency Actior Table 5 Post -Closure Cost Calculations Elk River Landfill miMINNESOTA POLLUTION CONTROL AGENCY Payment rate estimate table 520 Lafayette Road North Solid Waste Permit Program St. Paul, MN 55155-4194 Doc Type: Permitting Annual Report w-sw7-26 (Revised 10127121) Submit Elk River Landfill with 74 Annual Report Facility name SW# 2021 approved closure cost estimate 2021 approved annual postclosure care cost estimate 2021 approved contingency action cost estimate Account balance on December 31, 2021 Value of guarantee on December 31, 2021 (Letter of Credit or Surety Bond) 84 Operating life in months (maximum 120) Projected costs over post -closure care period 2022 Annual postclosure care cost estimate Inflation factor = 4.026% Discount rate = 0.25% 6,155, 900.00 165,400.00 1,095,240.00 NA $ 11,460,785.00 $ 172,059.00 Year Inflated annual Inflated and discounted cost annual cost 2022 $172,059 $172,059 2023 $178,986 $178,540 2024 $186,192 $185,265 2025 $193,688 $192,243 2026 $201,486 $199,484 2027 $209,598 $206,997 2028 $218,036 $214,794 2029 $226,814 $222,885 2030 $235,946 $231,280 2031 $245,445 $239,991 2032 $255,327 $249,031 2033 $265,606 $258,410 2034 $276,300 $268,144 2035 $287,423 $278,244 2036 $298,995 $288,724 2037 $311,033 $299,599 2038 $323,555 $310,884 2039 $336,581 $322,593 2040 $350,132 $334,744 2041 $364,228 $347,352 Totals $5,137,431 (Current value - not discounted) Basis for this years payments 2022 Closure cost estimate 2022 Postclosure care cost estimate 2022 Contingency action cost estimate Total * Present value is only for Trust Funds and $5,001,261 (Current value - discounted) Current value Present value* $6,403,736.53 $6,292,783.45 $5,137,430.64 $5,001,260.84 $1,139,334.36 n/a $12,680,501.54 $12,433,378.65 Account balance on December 31, 2020 NA Value of guarantee on December 31, 2020 $11,460, 785.00 Operating life in months (never greater than 120 months) _ 84 Your monthly payment if not discounting = #VALUE! Your monthly payment if discounted = #VALUE! Dedicated Trust Fut https://www.pca.state.mn.us • 651-296-6300 • 800-657-3864 26 • 10127121 Use your preferred relay service • Available in alternative formats Page