4.3. SR 10-18-1993
r I ~(
( if'
fill River
ITEM 4.3.
TO:
MAYOR & CITY COUNCIL
FROM:
STEVE ROHLF, B & Z
ADMINISTRATOR SIi?
DATE: OCTOBER 12, 1993
SUBJECT: ENVIRONMENTAL UPDATE/LANDFILL
City staff and our environmental consultants have been working with Sherburne County
staff and their environmental consultants to gain a consistency in our regulatory efforts
regarding the Elk River Landfill. The result of that effort is a consistent stance on issues.
This united front from City and County staffhas been taken a step further by trying to also
be consistent with MPCA's regulation of the Landfill. Attached to this memo is a joint
letter from Dave Lucas and myself dated September 28, 1993, to MPCA staff regarding
outstanding issues at the Landfill.
City and County staffs had a very productive meeting on October 12, 1993, with MPCA
staff and the Elk River Landfill regarding these outstanding issues. Also attached to this
memo is an agenda from that meeting with MPCA.
e
Hopefully, the net result from this inner agency cooperation will be consistent permits
from the MPCA, County, and City so that the Landfill is not pulled in different directions.
The upcoming City permitting process for the Landfill should go smoothly. Staff wanted
to take this opportunity to inform the City Council of these events. Staff can also
elaborate on the outstanding issues at Monday night's meeting, if the Council desires.
e
P.O. Box 490 · 13065 Orono Parkway · Elk River, MN 55330 · (612) 441-7420 · Fax: (612) 441-7425
e
e
e
Sherburne County
ZONING
ADMINISTRA TION
September 28, 1993
741-001
Ms. Amy Radiaris
Solid Waste Section
Groundwater and Solid Waste Division
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
RE: Elk River Landfill Remedial Investigation
Dear Ms. Radiaris:
Sherburne County (County) and the City of Elk River (City) are presenting the following
concerns to the Minnesota Pollution Control Agency (MPCA) regarding remedial investigation
of the Elk River Landfill (ERL). The County and City are working together to address
environmental issues at ERL in an attempt to provide a consistent approach to local/county
regulation of ERL. This approach is being taken to expedite the remediation process, reduce
duplication of effort, and to minimize the economic burden on the landfill.
The following comments result from independent reviews of the Corrective Action Investigation
Report (CAIR) submitted to the MPCA by Camp Dresser and McKee (CDM), February 1993,
on behalf of the Elk River Landfill (ERL). The independent reviews were completed by
EnecoTech Midwest, Inc. (EnecoTech), representing Sherburne County and B. A. Liesch
Associates, Inc. (BAL), representing the City of Elk River. These reviews have previously been
sent to the MPCA for use in review of the CAIR. This letter presents common concerns of both
the City and the County. These comments/concerns were formulated at an August 5, 1993
meeting between Sherburne County and the City of Elk River, together with their respective
environmental consultants.
1.
A closer examination needs to be made of monitoring wells currently used to define the
south, west and northern extent of groundwater contamination from ERL. Monitoring
wells that exceeded water quality standards in relation to VOC's at respective site
boundaries were; P-19-A, P-43-B, 24-0WA, 18-0WA, 15-0WA, 26-0WA, P-17-C, 15-
OW A, 32-0W A, and 33-0W A. A careful examination of screen placement in monitoring
327 King
Elk River, MN 55330
1-800-433-5246 0 241-2860
e
e
e
Ms. Amy Hadiaris
Minnesota Pollution Control Agency
September 28, 1993
Page 2
wells downgradient of these wells, along with continued monitoring, needs to be
performed. Screen placement within downgradient wells, in relation to elevations of
detected upgradient contaminants, is not considered adequate for effective contaminant
monitoring. Prior to additional data collection, additional nested monitoring wells are
requested. These wells should be screened at sufficient depth to monitor contaminants
that are similar to or higher in density than water. These monitoring wells should be
located downgradient of three locations: 1) 18-0WA, 24-0WA and P-43-B to the
southwest; 2) P-17-C and 26-0WA to the west; and 3) 32-0WA and 33-0WA to the
north.
2.
At this time, the vertical gradients and surface recharge zones within the wetlands located
west and southwest of ERL are not fully understood. However, some recharge zones
north and northwest of ERL have been identified. It is therefore possible that surface
recharge zones exist within the wetlands. Also of concern are potential further
downgradient effects upon Rice Lake. Therefore, additional groundwater and surface
water monitoring within the wetlands together with monitoring of Rice Lake is requested.
Because background data is also missing from the wetlands study presented in the CAIR.,
locations that would produce background analytical information for comparison with
wetlands sample data should be described. Proposed monitoring locations and methods,
i.e. monitoring wells, surface grab samples, bomb sampler etc., should be defined in a
workplan addendum to the CAIR.
3. A single monitoring well network, as opposed to separate Environmental Monitoring
System (EMS) and Remedial Investigation (RI) networks now used, needs to be
established. This network should be determined based upon existing hydrogeologic and
analytical information and should be reduced from a combined EMS and RI monitoring
well network. For example, the criterion of an MPCA established total suspended solids
(TSS) concentration limit of 500 ppm for groundwater within monitoring wells, could be
used for eliminating wells screened solely within the till. Other criteria that could be used
for eliminating monitoring wells from this network include well materials and
construction techniques and screen placement in relation to strata to be monitored.
4. Additional monitoring should be conducted at ERL in conjunction with determination of
remedial alternatives. Three rounds of monitoring well and wetlands sampling should be
conducted in order to verify existing analytical data and to initiate a data base of chemical
analytical information that can be statistically analyzed for trends and migrational
relationships.
5.
Subsequent to additional monitoring at ERL, an addendum to the Corrective Action
Investigation Report (CAIR.) should be submitted that would discuss hydrogeological and
contaminant migration issues. However, in order to accurately address these issues,
.
Ms. Amy Hadiaris
Minnesota Pollution Control Agency
September 28, 1993
Page 3
geologic cross sections depicting the waste fill in relation to till and outwash units must
be constructed. In construction of these cross sections, till and outwash contact points,
as presented in the CAIR, may have to be modified. Attached to this letter, as
Attachment A, are errors and inconsistencies that BAL determined were made while
interpreting monitoring well boring and gamma logs for construction of soil boring cross
sections. These errors were found on soil boring cross sections presented in the CAIR.
The errata information in Attachment A should be used in redrawing waste/fill cross
sections.
The hydrogeological discussion should more specifically define velocity direction and
magnitude in three dimensions over the area of study. These velocities would be
calculated using a sufficient variance of horizontal and vertical hydraulic conductivity
values to effectively characterize the heterogeneous hydraulic conditions found at the site.
e
The contaminant migration discussion should contain an analysis of the types of
contaminants detected at the site including their physical/chemical properties and their
degradational and migrational characteristics, i.e. dispersive, diffusive and sorptive
behaviors of individual chemicals. Using this information, as well as geological and
hydrogeological interpretations, potential contaminant migration scenarios should be
discussed as a precursor to identifying feasible remedial alternatives.
6.
The CAIR addendum should also propose a residential well monitoring program.
Included in this program should be those wells that have the potential of being impacted
by off-site migration of contaminated groundwater based upon contaminant migration
study.
7.
At this juncture two options are being considered for remedial approach.
o
The City's consultant BAL is of the opinion that some interim groundwater
corrective actions should be pursued within a short time frame. MPCA
groundwater intervention limits have been continually exceeded for the past five
years. Exceedance of intervention limits at this site warrants the timely
implementation of corrective action. This has not occurred.
e
BAL proposes that ERL implement a groundwater pump and treat system in the
area of highest contaminant concentration immediately adjacent to the waste fill
boundary. An interim groundwater withdrawal and treatment system will have the
following beneficial effects:
e
e
e
Ms. Amy Hadiaris
Minnesota Pollution Control Agency
September 28, 1993
Page 4
a. Capture and treatment of groundwater which has the highest contaminant
concentration.
b. Hydraulic gradient control for the zone of high concentration contaminants
likely contributing to off-site migration and impacts.
c. Interim system performance monitoring will enable an enhanced degree of
understanding of site conditions which will be used in refining the final
design. Uncertainties regarding aquifer characteristics warrant an
"observational" approach to the final remedial design at this site. The
observational approach acknowledges that certainties exist and allows for
the development and implementation of contingency plans to accommodate
unexpected conditions.
d.
Reduction of the environmental impacts that will occur during the
preparation of the final remedial design. Considering previous schedule
adherence failures, BAL feels that a considerable time period may elapse
prior to implementation of the final remedial design.
e. By focusing on the area of highest groundwater contamination, the interim
remedial system should be able to be included as part of the final system
design.
It is the opinion of BAL that these interim corrective actions should be initiated
in the spring of 1994. This will provide ample time for design and construction
of the interim system.
o The County's consultant is of the opinion that, based on the presently available
data, implementation of interim corrective actions at this time is somewhat
premature. Although committed to rapid implementation of corrective actions,
EnecoTech suggests that resources associated with corrective actions be invested
in a remedial program which address both short term and long term remediation
requirements. Specifically, EnecoTech recommends that ERL be required to
develop a long term comprehensive remediation work plan and schedule prior to
implementing remedial actions at the site. The workplan and schedule should
encompass all environmental/engineering design programs including groundwater
remediation, landfill gas mitigation, landfill closure/capping, etc.
e
Ms. Amy Hadiaris
Minnesota Pollution Control Agency
September 28, 1993
Page 5
The comprehensive remedial approach should promote a cost effective and timely
remediation of the site and allow for appropriate long term budgeting. EnecoTech
suggests that ERL be required to submit the comprehensive work plan in short
order to assure delays do not develop.
The County and City request that ERL submit a workplan outlining the completion of tasks
presented in this letter as well as tasks required for the completion of the Feasibility Study (FS)
report. A Gantt chart should also be prepared showing task completion time frames and task
interrelationships. The time frame for the schedule and Gantt chart should be based on time
periods following critical events. The Gantt chart should be flexible in nature and allow for
modifications should uncontrollable schedule delays arise.
At this time, the County and City are reviewing ERL's landfill gas monitoring program and
would like to discuss that issue as well as the concerns outlined above with the MPCA. Per our
recent discussions, a meeting has been arranged with you at MPCA's office at 10:00 a.m. on
October 12, 1993 . We look forward to addressing these issues with you. Your time and
e consideration is appreciated.
Sincerely,
St~en Rohlf ~
City of Elk River
cc: Mr. Lanny Peissig, Minnesota Pollution Control Agency, St. Paul, MN
Ms. Kathleen Heaney, Sherburne County, Elk River, Minnesota
Mr. Steven McManamon, EnecoTech Midwest, Inc., Bloomington, MN
Mr. Matthew Ledvina, Bruce A. Liesch and Associates, Minneapolis, Minnesota
d\ 7 41-00 l.Itr
e
e
ATTACHMENT A
e
e
e
APPARENT ERRORS, INCONSISTENCIES AND SUGGESTED
INTERPRETATION CHANGFS FOR THE CORRECTIVE ACTION
INVESTIGATION REPORT
210-0W A:
The interpretation on Figures 9 A and 91 shows outwash in the upper sequence of the
boring with a soil classification of SM. The boring log indicates till throughout this
portion of the boring which is consistent with the criteria established in the Field
. Procedures Report. The cross sections should be corrected to be consistent. with the
boring log.
209-QW A:
The interpretation shown on Figures 9A and 91 does not match the boring log. It appears
that the till unit was inferred from the gamma log. If this is the case. additional till units
are suggested both above and below this interval. A revised interpretation results in the
two SM units classified as till and the remainder outwash with the exception of the till
at the base of the boring.
e
208-0W A:
The screened interval of this well is classified as SM. yet it is interpreted as outwash.
This is inconsistent with the criteria established in the Field Procedures Report.
206-0W A:
The SM unit present below the upper till unit is interpreted as outwash.
205-0W A:
The units classified as SP-SM above the well screen are shown as till while the boring
log indicates otherwise.
P-43C:
Cross section D-D' presents a different interpretation of the P-43C boring than is shown
on cross section J-J' .
202-0W A:
The interpretation presented on Figure 9D conflicts with the lithologic log for this boring.
A suggested interpretation revision shows the upper ML unit as the only upper till unit.
The lower till is continuous downward from the lean clay unit.
e
203-0W A:
On Figure 9D the poorly graded sand unit is shown as till an interpretation that conflicts
with the lithologic log and the criteria presented in the Field Procedures Report.
, .
e 20-0W A:
The lithologic log for this boring is of very poor quality. It is interpreted as SW from
a depth of 40 feet to the base although grain size distribution information conflicts with
this suggesting a till unit.
34-0W A:
On Figure 9F the SM d~posit is interpreted as outwash. Grain-size information suggests
that it is comprised of 45% silt and would be classified as till according to the criteria
established in the Field Procedures Report.
17-0WA:
The till unit begins at a considerably higher elevation than is shown on Figure 91 based
upon the log, grain size information and the association with 26-0WA.
26-0W A:
The till unit should occur at an elevation near to the surface, based upon the boring log
and hydraulic conductivity data for the well.
.
103-0WA:
Interpretation of the upper till unit does not match between Figures 9E and 9L. The'
lower till interpretation also shows a minor discrepancy of several feet.
106-0WA:
According to the boring log and well construction diagram, this boring is only 70 feet
deep. The interpretations for this boring must be shifted to. match the boring log and
reflect a depth of 70 feet. The ground elevation may also be in error by approximately
1.7 feet.
211-0W A: .
This well is shown to be 34 feet deep on Figure 9C while the log indicates that the boring
was advanced only to 30 feet.
e
40-0WA:
The boring log and well construction diagram indicate that this well is 25 feet deep and
screened from 15 to 25 feet. Table 3 suggests the well is 28 feet deep and screened from
16 to 26 feet. Figure 9M shows the well screen from 1 to 11 feet. An error is apparent
in illustrating the well and boring. The correct ground surface elevation for this well
should be 954.2 (NGVD) which is approximately 13.7 feet higher 'than shown on Figures
9H and 9M. Correct placement of the well screen shows the well situated in lean clay
of low hydraulic conductivity as is evident on Table 9.
Reinterpretation of the geology includes the SMIML unit within which P-40B is screened
as till. The corrected interpretation correlates much better with adjacent boring 39-0W A.
e
e
e
. .
The above suggested interpretive changes are derived to be consistent with the aiteria
established for this investigation. Liesch ~117.es that alternate interpretation methods
could be used but is providing this information so that a consistent means of interpreting
site geology is utilized.
":.. .'
tl.. W'I,.
TR1:i200J/"lDlerpl. wps
e
e
e
OCT 1 1 19n
Sherburne County
ZONING
A DMINISTRA TION
MEETING AGENDA
ELK RIVER LANDFILL REMEDIAL ACTIVITIES
10:00 AM, OCTOBER 12, 1993
MINNESOTA POLLUTION CONTROL AGENCY
520 LAFAYETTE ROAD, ST. PAUL
3rd FLOOR, CONFERENCE ROOM #2
PROJECTED ATTENDEES:
MPCA - Lanny Peissig, Amy Hadiaris
Sherburne County - Dave Lucas
City of Elk River - Steve Rholf
Elk River Landfill - Chris and vicky Kreger
Eneco Tech Midwest, Inc. - Steve McManamon
B.A. Liesch - Matt Ledvina
OVERVIEW: Elk River Sanitary Landfill (ERL) is an actively
operating mixed municipal waste landfill located in Elk River,
Minnesota. ERL is owned by Elk River Landfill, Inc., officers
include Lawrence Kreger, President and Chris Kreger, vice-
President. Governmental bodies which regulate ERL include the
Permits and Superfund Units of the Solid Waste Section of the
Minnesota Pollution Control Agency (MPCA), Sherburne County zoning
Administration (County) and the City of Elk River (City).
In February, 1993 ERL submitted a Corrective Action Investigation
Report (CAIR) to the MPCA, the County and the City. The CAIR
detailed information relating to investigation of environmental
contamination attributable- to ERL. To date, the County and the
City have reviewed the CAIR. Both the County and the City retained
the services of independent environmental consultants to provide
technical recommendations and formulate comments for submittal to
the MPCA. The comments to the CAIR were submitted to the MPCA
jointly by the County and the City on September 28, 1993.
At the present time, the County and the City are working together
to address the environmental issues at ERL. Specifically, the
County and the City have requested a meeting with the MPCA to
address the comments submitted on September 28, 1993.
327 King
Elk River, MN 55330
1-800-433-5246 0 241-2860
.
e
e
MEETING OBJECTIVES:
Provide a forum whereby all concerned parties have the
opportunity to express their concerns/issues.
Review the technical comments provided by the County and the
City and determine MPCA'a and ERL's positions.
Identify areas of redundancy in regulation and develop a
streamlined approach to the environmental investigation and
remediation.
Determine a general comprehensive approach and schedule for
further remedial actions at ERL.
Determine a required deadline for submittal of a work plan
detailing the comprehensive approach to remedial actions.
PROPOSED AGENDA:
1.0 Introductions
2.0 Review/modifications of meeting objectives and agenda
3.0 Review of CAIR technical issues
4.0 Determine general approach and schedule for future actions
5.0 Determine deadline for addendum workplan submittal
6.0 Additional comments and wrap up