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HomeMy WebLinkAbout6.a. SKB Environmental Request for Zoning Ordinance Text Amendment and IUP to Allow Composting ROSEI \4OUNT EXECUTIVE SUMMARY PLANNING COMMISSION Planning Commission Meeting Dates: April 24, 2012 Tentative City Council Meeting Date: May 15, 2012 AGENDA ITEM: Case 12- 06 -TA; 12- 07 -IUP Request by SKB Environmental to Allow Composting as an AGENDA SECTION: Interim Use in the Waste Management Public Hearing District and Amend the Existing Interim Use Permit to Include Composting AGENDA NO. PREPARED BY: Eric Zweber, Senior Planner to .a• ATTACHMENTS: Location Map; Application for Major Permit Modification. APPROVED BY RECOMMENDED ACTION: Motion to Recommend that the City Council Approve the Text Amendment of Section 11 -4 -17 B. Waste Management District Uses Permitted by Interim Use Permit to Add Composting. Motion to Recommend that the City Council Amend the Interim Use Permit for SKB Environmental to Allow Composting with the following ten (10) conditions: 1. Compliance with the Application for Major Permit Modification dated March 2012. 2. Sewage Sludge used in the composting shall not exceed the Minnesota Pollution Control Agency and Environmental Protection Agency Region 5 Soil Reference Values (SRVs) for perfluorocarbons (PFCs). 3. Only Industrial Sludges approved by Dakota County Environmental Management shall per used in composting. 4. Compliance with the Vector and Rodent Control Letter dated July 20, 2011. 5. The Applicant Conduct a Vector and Rodent Evaluation, which would in part be based upon trapping in May 2013 by a National Pest Management Association (NPMA) Certified Pest Control Firm. The Evaluation shall be submitted to the City by July 1, 2013 respectively, and include Recommendations for Vector and Rodent Control. The Community Development Director shall administratively approve the Vector and Rodent Control Plan that SKB shall implement based upon the Evaluation Report. 6. Approval and Compliance with MnPCA Major Permit Modification. 7. Approval and Compliance with DCEM Composting Variance. 8. The Rosemount City Council and SKB approve modifications to the Development Commitment by and Between SKB Environmental, Inc, and City of Rosemount. ISSUE SKB Environmental, Inc. (SKB) owns and operates an industrial, construction and demolition waste landfill at 13425 Courthouse Blvd. SKB has requested a text amendment to the WM Waste Management district to add composting as an interim use and to modify their existing interim use permit (IUP) to add composting to their operation. 2011 COMPOSTING REQUEST FROM SKB In June and July of 2011, the Planning Commission reviewed the SKB request for a text amendment to allow composting as an interim use in the WM Waste Management zoning district and a modification of their existing IUP to allow composting. Following the Planning Commission recommendation, the City Council and SKB could not come to an agreement to the development commitment and SKB withdrew their request on November 15, 2011. Earlier this year, SKB had been awarded part of a yard waste contract from the City of Minneapolis and have submitted a new request for a text amendment and IUP to permit composting on their site. The request is almost identical to the 2011 request. The only modifications made were to address previous Planning Commission concerns or comments from the Dakota County Environmental Management (DCEM) or Minnesota Pollution Control Agency (MnPCA) staff. June 28, 2011 Public Hearing The Planning Commission opened the public hearing and two residents provided testimony. Brenda Sugii, 13701 Courthouse Blvd., stated that the SKB landfill keeps growing and asked when it will stop. She stated that at first the landfill was supposed to last 20 years and that her and her husband could plan on selling their house after they retire. Now, the landfill will still be operating for more than 40 years and will be bigger and higher. She asked who would buy her house next to an operating landfill. Previous approvals said that food wastes that attract rodents would not be landfilled and now SKB is requesting food waste be brought to the landfill. She asked when enough will be enough. Bonnie Troska, 13650 Courthouse Blvd., stated that she is concerned that the compost would contaminate the soil or the water that her horses drink. She is also concerned that the rodents from the landfill will attract rats that will come onto her property and hurt her kittens. July 26, 2011 Planning Commission Meeting No residents spoke at the July Planning Commission meeting. The Planning Commission recommended approval of the text amendment to add composting to the WM Waste Management zoning district. The Planning Commission recommended approval of the IUP amendment with the removal of the sewage sludge because of concerns of PFCs within the sludge and with a requirement to notify the neighbors of the water monitoring results. SUMMARY Current SKB Operation The SKB landfill property has a Comprehensive Plan designation of WM -Waste Management and is also zoned WM Waste Management. In 2008, the City approved a five year IUP to dispose of industrial waste, construction and demolition waste, municipal solid waste (MSW) ash waste, and to operate a recycling /transfer facility. SKB does not currently have a recycling /transfer facility at their 2 site. SKB estimates that they have enough volume in the landfill to operate for approximately 40 years. The landfill has a synthetic clay liner that collects any leachate that is generated from the facility and is sent to the Metropolitan Council wastewater treatment plant for treatment. Ingress to the landfill is through a single access off of Minnesota Highway 55 (Mn Hwy 55) to direct incoming trucks to the scale before sending the trucks to the appropriate waste cell, while egress from the site is either from the access on Mn Hwy 55 or two accesses on 140 Street on the south side of the site. The landfill also has operational permits from the Minnesota Pollution Control Agency (MnPCA) and from Dakota County. Traditional Composting Composting is traditionally conducted by piling and turning yard waste (typically lawn clipping and chipped tree limbs) until the yard waste is naturally broken down into an organic soil additive. The final product, compost, is not typically classified as soil by itself but is often mixed with other soils or sand to make a mixture that is equivalent to black dirt. This type of compost, compose material plus an additive such as soil or sand, is defined as Class I compost by the MnPCA which could be sold to the general public and used anywhere. The MnPCA also has a Class II compost which is normally a combination of composted yard waste and contaminated soil which can be used as black dirt and cover at landfills or other environmental impacted properties. Class II compost cannot be sold to the general public. MnPCA has recently set up regulations for a new type of composting that uses both yard waste and source separated compostable materials. Source separated compost materials are organic material like spoiled food that has traditionally been throw away as municipal solid waste (MS' and either landfilled or burned. To reduce and reuse this organic material, the MnPCA allows food and other organic wastes to be separated and collected at specific locations like restaurants, school cafeterias, or public events and delivered to a composting facility. These regulations include requirements that the compost reach an elevated temperature for a period of days to kill any pathogens and testing of the final compost to make sure it does not contain contaminants. Source Separated Compostable Material Composting There is a composting facility in Empire Township operated by Resource Recovery Technologies, Inc. (RRT) on property owned by Dakota County that conducts composting with source separated compostable material. They take the source separated compostable material, mix it with yard waste, place it in windrows over a perforated pipe that they can blow air through to control the temperature to ensure that the pathogens are killed. The compost is screened when it is turned and they remove any garbage that mistakenly was not separated from the composted material. According to their fourth quarter 2010 report, this garbage is equivalent to about 5% of the total source separated compostable material. The composting is conducted over a clay liner so that stormwater or leachate can be collected into a pond instead of infiltrating into the groundwater. Their final product qualifies as a Class I compost and is sold in 3 forms: solely as compost; as 50% black dirt and 50% compost mix; or as 40% black dirt, 40% compost, and 20% sand mix. 3 Source Separated Compostable Material versus Mixed Municipal Solid Waste In 2008, the MnPCA had prepared a separate definition of source separated compostable material from the definition of mixed municipal solid waste (MSW) to encourage the reuse and recycling of the compostable material instead of landfilling or burning as the MSW would be. The State Statute definitions of source separated compostable material and MSW are provided below. Source separated compostable materials. "Source- separated compostable materials" means materials that: (1) are separated at the source by waste generators for the purpose of preparing them for use as compost; (2) are collected separately from mixed municipal solid waste, and are governed by the licensing provisions of section 115A.93; (3) are comprised of food wastes, fish and animal waste, plant materials, diapers, sanitary products, and paper that is not recyclable because the commissioner has determined that no other person is willing to accept the paper for recycling; (4) are delivered to a facility to undergo controlled microbial degradation to yield a humus -like product meeting the agency's class I or class II, or equivalent, compost standards and where process residues do not exceed 15 percent by weight of the total material delivered to the facility; and (5) may be delivered to a transfer station, mixed municipal solid waste processing facility, or recycling facility only for the purposes of composting or transfer to a composting facility, unless the commissioner determines that no other person is willing to accept the materials Mixed municipal solid waste. (a) "Mixed municipal solid waste" means garbage, refuse, and other solid waste from residential, commercial, industrial, and community activities that the generator of the waste aggregates for collection, except as provided in paragraph (b). (b) Mixed municipal solid waste does not include auto hulks, street sweepings, ash, construction debris, mining waste, sludges, tree and agricultural wastes, tires, lead acid batteries, motor and vehicle fluids and filters, and other materials collected, processed, and disposed of as separate waste streams. Approximately 25% of unseparated MSW can contain items that could be separated as compostable material including food and animal waste and dirty paper products that cannot be recycled otherwise. While the MnPCA has prepared different definitions for the compostable material and MSW, many of the nuisance and aesthetic issues exist for both waste streams. Both the compostable material and MSW can attract rodents and birds (vectors) that the other waste streams (including the traditional composting of yard wastes) processed at the SKB landfill may not attract. This issue was raised during public testimony at the June 28 Planning Commission meeting. SKB has provided additional information within the March 2012 application to address how they will process the compostable material to minimize vector and rodent issues. Staff has also prepared an additional condition that would require SKB hire a pest control firm to evaluate (including trapping) vectors and rodents as result of the compostable material. The condition would also allow the Community Development Director to require a pest control plan if the evaluation would recommend that pest control is needed. The City has had a long standing policy of not supported landfilling of MSW at the SKB site. Staff does not believe that policy has changed and therefore, the question is whether the introduction of source separated compostable material is too similar to MSW. Based upon the previous discussions of the Planning Commission which supported the amendment and IUP, there is no concern about MSW posed above. However, it should be made clear to the applicant that this should not be viewed as a change in policy regarding MSW landfilling. Staff is still not supportive of MSW landfilling within Rosemount, whether it is conducted by SKB or any other entity. 4 SKB Composting Request SKB is proposing to conduct composting over closed industrial waste cells so that any leachate or stormwater would be collected by their liner and treated the same as their landfill leachate. While individual cells, or subcells, might be closed, additional waste cells will be added on top of the closed cells until the landfill reaches its approved height. This will mean that the compost operation would relocate as other cells are started, filled, and closed, "riding" on the different closed cells. SKB has proposed to generate compost that would meet Class I compost standards and would be used as black dirt for cover at their landfills as well as possibly at their sister company (Carl Bolander and Sons) construction projects. The proposal would be for up to 50,000 tons of compostable material annually. Similar to the RRT facility, SKB is proposing to use source separated compostable material and yard waste in its compost, but unlike RRT, SKB had also requested to use material from its construction and demolition waste such as gypsum drywall and chipped waste wood; sewage sludge; and industrial sludge. Staff has concerned about the use of industrial sludge and at the July 2011 Planning Commission meeting, Commissioner Demuth had a concern with the possibility of PFCs in the sewage sludge. Staff is particularly concerned about industrial sludge which is normally treated and disposed of as an industrial or hazardous waste. Industrial sludge could be material like left over wood pulp from paper mills, which may make suitable compostable material. However, industrial sludge could also come from the Gopher lead smelter in Eagan. City staff had requested a professional opinion from Dakota County staff about using industrial sludge in Class I compost. SKB has prepared additional information regarding industrial sludge in their March 2012 application. They have included a proposed definition that would limit industrial waste to vegetative waste from human food or animal feed production, non hazardous industrial waste that is over 50% organic, or clean wood waste. SKB has also provided a list of standard industrial codes (SIC) indicating businesses whose sludge would be acceptable and a list of SIC businesses that would generate unacceptable industrial sludge. The professional opinion of Dakota County staff of the industrial sludge definition and SIC businesses is that those proposed for composting are appropriate. Based on the information provided within the March 2012 application that includes the discussion between SKB and Dakota County staff, staff is supportive of the use of industrial sludge in the composting provided that DCEM staff approved the source specific industrial sludge. During the July 2011 review, Commissioner Demuth raised a concern that there was no standard within the application for perfluorocarbons (PFCs) and that SKB's request for Class I compost may be problematic if they intend to use sewage sludges from the Metropolitan Council which have had elevated levels of PFCs. SKB has proposed to test the sewage sludges before they are mixed with the other compostable material and will not include any sewage sludge that exceed the PCA or EPA soil reference values (SRVs) for PFCs. By testing the material before it is included in the compost will ensure that the final product is less than the SRVs because of the dilution and mixing with the other compostable material. The SKB composting process will be similar to the RRT process in that they will mix the compostable material in windrows over perforated pipes with air blowing through them to keep the compost aerobic. SKB has stated that the worst odors from compost come from anaerobic processes. To further reduce the smell of the compost, SKB will cover the incomplete compost windrows with a 5 couple inches of finished compost to keep the smells within the windrow. After the compost has reached the appropriate temperature for the required days, the compost will be turned and screened and any garbage will be removed and disposed of as MSW. Any windblown trash will be collected in the same way as any other windblown material from the other waste streams on site. The compost will continue to be turned and screened until the compost has broken down to the appropriate size to qualify as Class I compost. The finished compost will be tested to ensure that it meets the standards for Class I compost. Any unfinished compost caught by the screen will be added back into the windrows until it completely breaks down. Text Amendment Composting is not currently permitted in any zoning district in Rosemount. In 2008, a text amendment was proposed to allow composting in the AG- Agricultural district to mix compost and sand at the Stonex Vesterra mine on Bonaire Path. Following testimony from Myron Napper against the proposal at the Public Hearing, the property owner withdrew the application. It is anticipated that there may be requests for composting in the future, likely either in an agricultural or industrial district. Staff believes that composting would be better sited in the WM Waste Management district than an agricultural or industrial district because of the liners and leachate systems required for landfills. These protective systems are not in place at an agricultural or industrial facility. Below is the staff recommended text amendment that would add composting as an interim use in the WM -Waste Management District. 11 -4 -17: WM WASTE MANAGEMENT DISTRICT: A. Purpose And Intent: This district is intended to accommodate waste industries and the inherent environmental problems associated with waste management. B. Uses Permitted By Interim Use Permit: Construction demolition waste facility subject to the following restrictions: 1. Facility construction debris does not exceed two hundred thousand (200,000) cubic yards of total permitted waste volume within the Rosemount corporate limits. Recycling operations subject to requirements of section 11 -10 -5 of this title. 2. The facility is developed, operated and maintained in accordance with an approved interim use permit by the city of Rosemount and all other applicable local, state and federal laws. 3. Permits for the facility by the state of Minnesota and Dakota County are pending or have received approval. Nonhazardous industrial waste containment facility. Composting Interim Use Permit SKB currently has an IUP effective through October 7, 2013 that allows for industrial waste, construction and demolition waste, MSW ash waste, and a recycling /transfer facility. The recycling /transfer facility does not currently exist. SKB is requesting to modify the IUP to add the ability to compost source separated compostable material, yard waste, gypsum, sewage sludge, and industrial sludge. Staff has prepared a recommendation to amend the IUP to allow composting with eight (8) conditions. 6 1. Compliance with the Application for Major Permit Modification dated March 2012. 2. Sewage Sludge used in the composting shall not exceed the Minnesota Pollution Control Agency and Environmental Protection Agency Region 5 Soil Reference Values for perfluorocarbons (PFCs). 3. Only Industrial Sludges approved by Dakota County Environmental Management shall per used in composting. 4. Compliance with the Vector and Rodent Control Letter dated July 20, 2011. 5. The Applicant Conduct a Vector and Rodent Evaluation, which would in part be based upon trapping in May 2013 by a National Pest Management Association (NPMA) Certified Pest Control Firm. The Evaluation shall be submitted to the City by July 1, 2013 respectively, and include Recommendations for Vector and Rodent Control. The Community Development Director shall administratively approve the Vector and Rodent Control Plan that SKB shall implement based upon the Evaluation Report. 6. Approval and Compliance with MnPCA Major Permit Modification. 7. Approval and Compliance with DCEM Composting Variance. 8. The Rosemount City Council and SKB approve modifications to the Development Commitment by and Between SKB Environmental, Inc, and City of Rosemount. RECOMMENDATION Based upon actions by the Planning Commission in July 2011, staff recommends approval of the text amendment and IUP for composting at the SKB facility. The application is similar to that recommended for approval by the Commission and addresses some of the concerns previously stated by some Commission members. 7 SKB Landfill v l i r °v z y T� -`•L i 0.4 j 4:iiiiiiH: 4,.1. r ash —W i `ti f rj F H i ,y r '''7" 7:: r r S K3 i,it"u 1- Ii..- L r t k ik .1, 1 F., lista it, 1 1 a I 4 1 It, t Disclaimer: Map and parcel data are believed L. oe ac rate, but accuracy is not Mao Scale guaranteed. This is not a legal document and should not be substituted for a title search, 1 inch 2000 feet appraisal, survey, or for zoning verifr.ation. ISIhri1511 ENVIRONMENTAL April 5, 2012 Mr. Eric Zweber Senior Planner City of Rosemount 2875 West 145 Street PO Box 510 Rosemount, MN 55068 RE: SKB Rosemount Industrial Waste Facility, SW -383 Application for Major Modification Compost Area Dear Mr. Zweber: In response to your March 28, 2012 letter, enclosed is a revised version of SKB's composting plan for the SKB Rosemount Industrial Waste Facility. The enclosed plan has been updated to reflect all the changes to the 2011 plan that SKB agreed to during the process from the original application in 2011 through now. Three appendices have been added to the plan. These appendices include all the correspondence from the 2011 applications between the Minnesota Pollution Control Agency and SKB, Dakota County and SKB, and the City of Rosemount and SKB. In your letter, you asked SKB to address the concerns that Commissioner Demuth raised during the 2011 application process. SKB met with Commissioner Demuth in 2011 to address her concerns. SKB is in the process of meeting with Commissioner Demuth to explore any remaining concerns she may have with PFCs in biosolids that SKB is proposing to accept at the facility. This submittal should address the concerns raised in your March 2012 letter. Should you have any additional questions on this application, please contact me at 651 224 -6329. Sincerely, Geoffrey D. Strack, P.E. Environmental Engineer Enclosure cc: Bob Criswell, MPCA Dave Magnuson, Dakota County Jon Penheiter, SKB Doc St. Clair, SKB 251 Starkey St. P.O. Box 7216 St: PauL VIN 55107 651 224 -6329 FAX 651 223 -5053 Printed on Recycled Paper. f SKB Rosemount Industrial Solid Waste Management Facility, SW -383 Application for Major Permit Modification 4 ENVIRONMENTAL Prepared By: SKB Environmental, Inc. 251 Starkey Street St. Paul, MN 55107 March 2012 SKB Rosemount Industrial Waste Facility, SW -383 Major Modification Application Distribution Number of Copies: Sent To: 1 Mr. Eric Zweber Senior Planner City of Rosemount 2875 West 145 Street PO Box 510 Rosemount, MN 55068 1 Mr. Bob Criswell Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 1 Mr. Dave Magnuson Dakota County 14955 Galaxie Avenue Apple Valley, MN 55124 -8579 1 Mr. Jon Penheiter SKB Rosemount Industrial Waste Facility 13425 Courthouse Boulevard Rosemount, MN 55068 2 Mr. Geoffrey Strack SKB Environmental, Inc. 251 Starkey Street St. Paul, MN 55107 ii Application for Major Permit Modification SKB Rosemount Industrial Solid Waste Management Facility MPCA Permit No. SW -383 Rosemount, Minnesota iii Table of Contents Background 1 1.1 Permit History 1 1.2 Existing Conditions 1 2 Proposed Modification 2 3 Engineering Design Report 4 3.1 Site Preparation 4 3.2 Access to the FaciILty 5 3.2.1 Traffic Routes 5 3.2.2 Access Control 5 3.3 Surface Water Management 5 3.4 Processing Areas 6 3.5 Contact Water Management 6 3.6 Materials Management 6 3.7 Odor Management 6 3.7.1 Compost Blanket 7 3.7.2 Active Aeration 7 3.7.3 Compost Pile Construction 7 4 Compost Operation and Maintenance Manual 8 4.1 Description of Material to be Composted 8 4.2 Secured Access 8 4.3 Personnel Training Program 8 4.4 Designated Delivery Area g 4.5 SalvageablefRecyclable Materials Management 9 4.6 Residual Management 10 4.7 Leachate Management 10 4.8 Odor Control 10 4.9 Wind Dispersion 11 4.10 PFRP Method 11 iv 4.11 Sampling and Testing Plan 11 4.11.1 Maturity 11 4.11.2 Metals Analysis 11 4.11.3 Percent Inert Material Analysis 12 4.11.4 pH, Moisture Content, Particle Size, NPK Ratio, and Soluble Salt Content 12 4.11.5 Sample Collection and Processing Techniques 12 4.11.6 Description of How Results will Determine Distribution 14 4.12 Operation Flow 14 4.13 Inspections 14 5 Compost Distribution Plan 15 6 Industrial Solid Waste Management Plan Compost Area 16 6.1 Procedure for Notifying Customers 16 6.2 Procedure for Evaluating Waste 16 6.3 Procedure for Inspecting Industrial Solid Waste 17 6.4 Acceptable Waste Types 17 6.4.1 Empty Pesticide Containers 17 6.4.2 Asbestos 17 6.4.3 Waste Containing PCBs 17 6.4.4 Spilled Nonhazardous Waste 17 6.4.5 Rendering and Slaughterhouse Waste 17 6.4.6 Wastes that Spontaneously Combust 17 6.4.7 Foundry Waste 17 6.4.8 Ash from Incinerators 18 6.4.9 Sludges 18 6.4.10 Fiberglass, Urethane, Polyurathane, and Epoxy Resin Waste 18 6.4.11 Spent Activated Carbon Filters 18 6.4.12 Other Wastes 18 6.5 Plan Modification 18 7 Closure and Post Closure Plan 19 8 Contingency Action Plan 20 v Appendix A MPCA Permit Application and Checklists Appendix B Correspondence with MPCA on applicability of the environmental review with this project Appendix C MPCA Program Management Decision Memo Appendix D Compost Area Drawings and Topographic Map Appendix E Bucket Test Appendix F 2011 Correspondence Between MPCA and SKB Appendix G 2011 Correspondence between Dakota County and SKB Appendix H 2011 Correspondence Between the City of Rosemount and SKB vi 1 Background SKB Environmental, Inc. (SKB) is submitting this application to the Minnesota Pollution Control Agency (MPCA) in accordance with Minn. R. Ch. 7001 and Minn. R. Ch. 7035 to modify its MPCA permit, SW -343, to add a solid waste composting area to the SKB Rosemount Industrial Solid Waste Facility (Facility). The Facility is located in the City of Rosemount, Dakota County, Minnesota. This application only addresses the addition of a compost area to the permit for the Facility, as this is the only proposed modification to the Facility's permit. SKB submitted an application in 2008, and received a modified permit in 2009 for the other permitted activities at the Facility. SKB is not proposing any changes to the currently permitted activities at the Facility, which includes a demolition disposal area (DD001), two industrial disposal areas (IL001 and IL002), a municipal SW combustor ash disposal area (MA001), a solid waste recycling area (RE001), and a solid waste transfer area (TR001). Section 1.2 of the 2009 MPCA permit, SW -383, references all the approved permit documents for the previously approved waste activity areas. 1.1 Permit History On January 8, 1992, the MPCA granted a solid waste permit to Union Pacific Railroad (USPCI) for the operation and construction of a lined industrial waste landfill. At the time, the landfill was called the Minnesota Industrial Containment Facility (MICF). In early 1995, USPCI sold the MICF to Laidlaw, Inc. To reflect this change, in August 1997, the name of the landfill was changed to Laidlaw Environmental Services (LES) Rosemount. In early 1998, Safety -Kleen bought the landfill, and changed the name of the landfill to Safety -Kleen (Rosemount). In June 2000, SKB purchased the landfill from Safety Kleen. Over the years, several modifications to the permit have been made. In 1998, the permit was modified authorizing the acceptance of municipal solid waste combustor ash in cell 4. In 2003, the permit was modified to add the construction and demolition disposal area, cell 5. The permit was modified in 2008 to authorize the construction of the 3M cell within cell 3B. This cell was designed, constructed and operated to take PFC containing wastes for 3M remediation jobs. The permit was again modified in 2009 to add cell 6 to the permit. 1.2 Existing Conditions SKB's 2009 MPCA permit for the Facility, SW -383, authorizes the construction and operation of Demolition Debris Disposal Areas, Industrial Debris Disposal Areas, MSW Combustor Ash Disposal Areas, and a Transfer Station Area. These activities are permitted to take place on a 236 acre site in Rosemount, Minnesota. Of the 236 acres, 151 acres will ultimately be occupied by landfill areas. The individual cell areas are as follows: Cell 1— Industrial Solid Waste: 5.1 acres Cell 2 Industrial Solid Waste: 17.1 acres CeII 3 Industrial Solid Waste: 39.3 acres CeII 4 MSW Combustor Ash: 12.3 acres Cell 5 Construction and Demolition Debris: 41.2 acres CeII 6 Industrial Solid Waste: 36.0 acres Transfer Station and Recycling Areas Not Constructed Based on the site survey conducted for the 2010 annual report, the expected remaining site life is: Construction and Demolition Debris: 24.7 years Industrial Solid Waste: 24.8 years MSW Combustor Ash: 34.0 years Below is a listing of the basic Facility information: Facility: SKB Rosemount Industrial Solid Waste Facility, SW -343 13425 Courthouse Boulevard Rosemount, MN 55068 Property Owner: SKB Environmental, Inc. (Private Company) 251 Starkey Street St. Paul, MN 55107 651 224 -6329 Facility Operator: SKB Environmental, Inc. 251 Starkey Street St. Paul, MN 55107 Facility Contact: Jon Penheiter Facility Manager 13425 Courthouse Boulevard Rosemount, MN 55068 651 438 -1500 jonp @skbinc.com 2 Proposed Modification With this application, SKB is applying for authorization to construct and operate a composting area(s) at the SKB Rosemount Industrial Waste Facility (Facility). The compost operation would be operated on a gravel pad, which will be constructed on top of a temporarily closed portion of the lined landfill, which SKB anticipates being originally constructed in cell 3C. However, SKB is seeking authorization to move the composting area to different portions of the landfill as needed to continue to facilitate landfill operations at the Facility and continued composting operations. This will entail moving the composting operations to a different location on the landfill when the composting area needs to be returned to an 2 active landfilling area. Additional composting areas may also be constructed by SKB if more space is needed to operate the composting area efficiently. Prior to moving the composting operation to a new area of the landfill, SKB would prepare the area in accordance with designs for operational pads as approved in the permit. SKB will construct any subsequent composting area at the site in the same fashion as the original area in Cell 3C. Upon completion of the construction of the new area, SKB would move the composting operation to the new area and remove the old composting area prior to returning the old composting area to an active landfilling operation. SKB is not proposing to compost Mixed Municipal Solid Waste as defined in Minnesota Statutes. Therefore, SKB sought an interpretation from the MPCA environmental review group as to the applicability of environmental review rules to this project. SKB received an April 8, 2011, letter from the MPCA confirming that this project is not subject to the mandatory environmental review categories outlined in Minn. R. Ch. 4410. A copy of SKB's letter to the MPCA and the MPCA's response can be found in Appendix B. 3 3 Engineering Design Report This section of the application is the engineering design report. This section covers the design details of the proposed compost area as required in Minn. R. 7035.2836, subp. 4 and Minn. R. 7001.3375. 3.1 Site Preparation Because the compost area will be constructed on top of a temporarily closed portion of the landfill, originally cell 3C, the site already has much of the infrastructure in place needed to support a composting operation. These items would include fencing, gates, interfacility roads, scale houses, etc. SKB will utilize this existing infrastructure to facilitate the operation of a composting area at the Facility. SKB is proposing to move the composting area(s) around the Facility as necessary in order to facilitate landfilling operations. However, the composting area will always be constructed over an area with a landfill liner. This liner will serve to meet the liner requirements of Minn. R. 7035.2836, subp. 4, item D. There are three liner designs that are used at the landfill. At a minimum, each of the liner designs has a synthetic geomembrane; which exceeds the 1x10 cm /sec liner requirements of Minn. R. 7035.2836. As part of the construction of the composting, curing, and storage area, SKB will cover a portion of the landfill cell(s) with intermediate cover. Intermediate cover requirements for each landfill area are outlined in the MPCA's permit for the Facility, SW -343. Once intermediate cover has been applied to the landfill area, a six -inch base consisting of 3 inch minus aggregate material will be applied over the intermediate cover to make an all weather rock surface. This all weather rock surface will be the place all composting, curing, and storage for immature compost will take place. A cross section of the composting pad can be found in the detail on the attached site drawing found in Appendix D. The composting area will be placed on top of a temporarily closed landfill cell. initially, the composting area will be constructed in a temporarily closed cell, 3C, which can be seen in the attached site drawing in Appendix D. The location of the next composting area would depend on waste volumes received at the Facility; however, SKB would place it in an area that would allow composting to happen in one location for a period of time. The attached drawing in Appendix D identifies a potential location for phase 2, which is over cells 3A /3B. The composting area would be of sufficient size to accommodate the volume of composting material accepted at the Facility. As mentioned above, the Facility will ultimately have 151 acres of lined landfill space at the Facility. SKB will have sufficient area to construct a composting area(s) to accommodate the composting operations and have the composting area over a portion of the lined landfill. The all weather pad described above, which will house all the composting operations, will also be graded to prevent run -off of contact water or leachate from leaving the composting area and entering the Facility's stormwater management system. In addition, SKB would construct a small ditch near the edges of the composting area to collect run -off and prevent run -off from leaving the composting area and entering the stormwater management system. This ditch will intercept the water and prevent the water from leaving the composting area. As stated above, as the Facility continues to progress, the location of the compost operation will be moved to alternate locations. However, at all times, the 4 location would be on top of a temporarily closed cell of the landfill. All cells of the landfill are Tined and the landfill liner would serve as the required liner found in Minn. R. 7035.2836, subp. 4, item D. 3.2 Access to the Facility The site is a current solid waste management facility and already has fences, gates, scales, and interfacility roads. The composting area would just be an additional activity at the Facility and would utilize the existing infrastructure as it relates to site access. 3.2.1 Traffic Routes All arriving traffic will enter the Facility's north gate off of Courthouse Boulevard. Currently, Courthouse Boulevard is also Minnesota Highway 55. The Minnesota Department of Transportation (MnDOT) commented on the last Environmental Assessment Worksheet done for the Facility. In this letter, MnDOT indicated that the landfill does not have a substantial impact of the capacity of the road and that Highway 55 is planned to be rerouted and will no longer pass in front of the landfill. This project is scheduled to be completed by MnDOT in the near future and would reduce the volume of traffic on Courthouse Boulevard further. 3.2.2 Access Control Arriving vehicles enter the gate off of Courthouse Boulevard /Highway 55. Vehicles are directed to one of two on -site scale houses. The scale house at the main administrative building is always open. The auxiliary scale is open depending on the time of the year and number of vehicles using the Facility. When all the scales are open, vehicles are directed to different scales depending on what type of material they are bringing to the Facility. All non -waste hauling visitors are directed to the administrative offices. Most vehicles leave the Facility through the same gate that they enter the Facility, Gate #1. However, there is another gate that leaves the Facility to the south onto 142 Street. A few vehicles may leave the Facility via this second gate. 3.3 Surface Water Management Stormwater management from the composting area will utilize the existing stormwater management infrastructure that has been constructed for the entire Facility. The composting area will be constructed to prevent stormwater from running outside the composting area onto the composting area. All contact water that is collected from the composting area will be managed according to the contact water management section of this application. The Facility currently has a stormwater infrastructure in place that consists of a series of stormwater retention areas with associated drainage ditches that are designed to manage run -off from the 100 year, 24 -hour storm event. Because the composting area will be constructed on top of a temporarily closed area of the landfill; there will not be any additional land area shedding stormwater into the stormwater system. Therefore, the existing stormwater system that has been constructed to handle the current stormwater at the Facility is adequately sized to handle the addition of a composting area. 5 3.4 Processing Areas Unloading of delivered materials, construction of the composting piles, active composting, curing of the compost, and screening and mixing compost into a saleable product will all take place on the composting area pad. The capacity of the composting area will be limited to 5,000 tons of compostable material per acre of prepared and approved composting area. However, SKB will not exceed an annual capacity of 50,000 tons of compostable material per year at the Facility. As described above, this pad will be constructed over the top of a temporarily closed portion of the landfill. The pad will consist of a six inch gravel pad over the top of intermediate cover; see design detail in the attached Facility drawings in Appendix D. The composting area(s) will have electricity drops into the area, which will enable the blower systems SKB will use to keep the compost piles aerobic to operate. The placement of the six inches of gravel over the top of the intermediate cover will ensure that the composting area is passable in all weather conditions. The composting area will also be graded to move all leachate and contact water to the Facility's leachate management system for proper treatment at an offsite wastewater treatment plant. 3.5 Contact Water Management As described above, the composting area will be graded in a manner that prevents contact water from leaving the composting area and entering the onsite stormwater management system. The composting area pad will be graded to promote the drainage of any leachate and contact water to the Facility's leachate management system. This may be done by infiltration into the leachate system, or by actively placing the water into the leachate system. In addition to the grading, a diversion ditch will be constructed near the edge of the composting pad as a second means of preventing contact water from leaving the composting area. 3.6 Materials Management All putrescible materials will be processed on the day they are received. This will entail mixing the material with the proper ratio of carbon sources and bulking agents. The processed material will then be added to the compost pile. Once the compost has met the appropriate temperature and time ratio for PFRP, procedure to further reduce pathogens, as outlined in Minn. R. 7035.2836, the material may be moved to a curing pile where the material will continue the compositing process until it is mature compost. Maturity, along with other parameters, will be measured using the methods outlined in Minn. R. 7035.2836. 3.7 Odor Management SKB will take all necessary precautions to prevent odor from becoming an issue at the Facility. These precautions, presented in more detail below, include but will not be limited to: covering the active compost pile with a layer of mulch or finished compost, actively aerating the compost pile, and introducing a sufficient amount of bulking agent in the construction of the compost pile. 6 3.7.1 Compost Blanket SKB will cover the active compost pile with a six -inch layer of finished compost or a six -inch layer of ground wood mulch, or other technique that may become available that achieves the same means. This layer will act as an oxidizing barrier reducing the chances that odors will emanate from the facility. 3.7.2 Active Aeration SKB will employ active aeration to keep the compost pile aerobic; as odors can become an issue at composting sites if composting piles become anaerobic. Initially, keeping the composting piles aerobic will be accomplished by actively aerating the compost piles with perforated pipes and electric blower fans to force air into the piles to keep them aerobic. Other methods exist to aerate compost piles, such as the use of a scarab windrow turner and the use of in- vessel composting technologies. While SKB will initially utilize a perforated pipe and blower system, SKB may implement another method at a future time. Regardless of the method employed, SKB will ensure that the compost pile remains aerobic; thereby minimizing odors at the Facility. 3.7.3 Compost Pile Construction SKB will add sufficient bulking agent to the mix when constructing the compost pile. Bulking agents create sufficient void spaces in the compost pile. These void spaces combined with the active aeration of the compost pile described above will keep the compost pile aerobic, reducing the chances of odor complaints. 7 4 Compost Operation and Maintenance Manual This section contains all the details on the how the composting area will be operated as required in Minn. R. 7035.2836, subp. 5. 4.1 Description of Material to be Composted The following materials would be accepted for composting at the Facility Source Separated Compostable Materials, as defined in Minn. Stat. Subd. 32a; Yard Waste, as defined in Minn. R. 7035.0300, subp. 121; Sewage Sludge (Biosolids) that has been treated to meet Class B pathogen reduction standards in Minn. R. Ch. 7041; Unused scraps of gypsum drywall and Other industrial sludges that meet the concentration values found in Minn. R. 7035.2836, subp. 6, Item A(1). These materials are described in greater details in 2011 correspondences with the MPCA, Dakota County, and the City of Rosemount. These letters and this further information can be found in Appendices F through H. 4.2 Secured Access The Facility has a fence with several locking gates. The gate is locked when the Facility is closed. When the Facility is open, vehicles can access the site through the gate and will be directed to one of the two scale houses. From the scale house, the trucks are checked in, which includes the first inspection of the waste, and then directed to the appropriate tipping area. To date, the existing security infrastructure has worked adequately to prevent unauthorized access to the Facility. 4.3 Personnel Training Program SKB will employ a combination of on -site classroom training and on- the -job training for all Facility personnel. Existing employees will be trained in the operation of the compost area prior to the site becoming operational. All new employees will be trained within six months of being hired. SKB has operated solid waste and yard waste composting facilities in Minnesota in the past. The training program will be conducted by existing personnel that are knowledgeable in composting from their past experience. The training shall include instruction on: Screening waste for unacceptable materials Processing acceptable materials Construction of compost pile Temperature readings to ensure PFRP has been met Turning piles Screening compost Sampling and testing procedures for finished compost, and Distribution plan for the finished compost. 8 In addition to the above operational procedures, Facility personnel are already trained on and will continue to be trained on: Using, inspecting, repairing, and replacing facility emergency and monitoring equipment; Activating communication and alarm systems; Activating automatic waste feed cutoff systems; Responding to fires; Responding to facility failures, including erosion and failure of liners or monitoring devices; Responding to groundwater or surface water pollution incidents; Accepting and managing waste; Rejecting unacceptable wastes; and Water sampling. 4.4 Designated Delivery Area All wastes delivered to the composting area will be tipped at a designated tipping area. In order to provide for efficient operation of the composting area, the tipping area will move around the designated and approved composting area. The tipping area will be moved each day to be near the area where the acceptable material will be processed and mixed prior to placing the material in the active composting piles. The tipping area and processing area will continue to move such that it is in close proximity to the area of the compost pile. This will reduce additional handling and other operational problems that can be associated with moving mixed compost feedstock across the composting area to be placed into the compost pile. All material delivered to the tipping area will be observed by a Facility operator. After observation by the scale house attendant, this check by the operator is the second check for unacceptable materials. All unacceptable materials will be removed from the compostable materials and be managed with all other residuals according to this operations plan. All tipped material will be processed into compost feedstock and placed into the compost pile by the end of each day to prevent nuisances such as odor and vector intrusion. 4.5 Salvageable /Recyclable Materials Management In addition to unacceptable materials, SKB will inspect loads for salvageable and recyclable materials that can easily be removed from the loads of incoming compostable materials. If easily extractable salvageable or recyclable materials are found in the incoming loads, the salvageable material will be removed and stockpiled in an area on the composting pad. The material will be stored in a manner that prevents odor, vector, or aesthetic degradation, or other nuisance conditions from forming. Once a sufficient quantity of salvageable and recyclable material has been stockpiled to make a truck load, SKB will transfer the material to the appropriate facility for processing. SKB may elect to combine recyclable materials separated from compostable material loads with other recyclable materials from other operations that are conducted at the Facility to enhance efficiencies of recycling operations at the Facility. 9 4.6 Residual Management Each Toad is inspected several times for the presence of unacceptable materials as described in greater detail in the ISWMP for the composting area included with this application. If unacceptable materials are identified, SKB will either reject the entire load or have the unacceptable material segregated from the load and have the unacceptable material removed from the Facility by the hauler delivering the material to the Facility. If the unacceptable material is discovered after the hauler has left the Facility and the hauler or generator cannot be identified, SKB will remove the unacceptable material from the composting feedstock and arrange for appropriate disposal at a facility that is authorized to accept that material. Through the screening of compost to make a final usable product, other residuals will be removed. These materials are typically uncompostable materials, such as plastic, rocks, metal, or other inert materials; or other materials that are slow to compost, such as larger chunks of wood. These materials will be disposed of in the industrial waste cell at the Facility. 4.7 Leachate Management As described throughout this application, the composting area will be done over a Tined portion of the landfill. Any leachate generated at the compost area will be directed to the existing leachate management system at the Facility. Leachate at the Facility is disposed of via a direct discharge pipe to a wastewater treatment facility owned and operated by the Metropolitan Council. 4.8 Odor Control Minn. R. 7035.2836, subp. 5, item G requires the Facility to comply with all MPCA odor rules. SKB is committed to operating the facility in a manner that odor nuisances do not exist. In order to control odor issues, the compost piles need to be kept aerobic. Keeping the compost piles aerobic is achieved via two techniques. The first is to construct the compost pile with sufficient airspace and the second is the use of forced aeration of the compost piles. In order to ensure that there is sufficient void space in the compost pile for air to circulate through the pile and thereby keeping the pile aerobic, requires proper construction of the compost pile. This is done by mixing sufficient bulking material (i.e. wood chips, leaves, etc.) with the other compostable materials in an appropriate ratio. The University of Minnesota Extension Service has developed a "bucket test" to measure if a compost pile has been constructed with sufficient void ratio. SKB is proposing to utilize the "bucket test which is described in Appendix E, to ensure that the compost pile is constructed with sufficient void ratio. Forced aeration will be the second technique that SKB will use to ensure that the compost pile remains aerobic. SKB will place the material to be actively composted over a perforated plastic pipe attached to a blower system. The blower system and perforated plastic pipe will push air through the material being actively composted to ensure that the compost pile remains aerobic. 10 4.9 Wind Dispersion All incoming materials, compost piles, and residuals will be managed in a manner that will control wind dispersion of materials from the composting operation. Additionally, SKB employs temporary workers to pick litter from the site on a continuous basis. These litter pickers will also pick any windblown debris that may come from the composting operation. Some of the practices that SKB intends to employ at the composting area are described in detail below. Incoming materials will be processed within 24 hours of when they are received. This includes removal of unacceptable materials and mixing the composting material in the appropriate ratio and with enough bulking material. All unacceptable materials removed from the incoming loads will be containerized. 4.10 PFRP Method The temperature of the constructed composting piles will be monitored and recorded each working day. Once a section of the compost pile reaches 55 degrees Celsius, retention time at that temperature will also be recorded to demonstrate the process to further reduce pathogens (PFRP) requirements have been met. PFRP will be met when the compost pile has been maintained at 55 degrees Celsius for at least seven days, as stated in Minn. R. 7035.2860, for a static aerated compost pile. If SKB changes the method of composting from the static aerated composting technique, SKB will use the time and temperature relationship listed in Minn. R. 7035.2836 for that method (i.e. windrow or in- vessel). 4.11 Sampling and Testing Plan In accordance with Minn. R. 7035.2836, this section outlines SKB's sampling and testing plan for finished compost. SKB will follow the procedures outlined below once each batch of compost matures. A screening event constitutes a batch of compost for testing purposes. A batch of compost will be kept separate from other unfinished compost and other batches of finished compost until all testing has been completed. Once the testing is completed, and the batch of compost has passed all the required testing; batches of finished compost may be combined into a larger stockpile prior to distribution. The pile of finished compost may be stored off of the compost pad. SKB will notify the MPCA prior to implementing any changes to this sampling and testing plan. 4.11.1 Maturity The maturity of the compost will be tested by the ignition -loss test and one of the other approved MPCA methods as required in Minn. R. 7035.2836, subp. 5, item 1 (1). The rules allow for the use of an alternative test as long as it is approved by the commissioner. Should SKB wish to use a test other than the five tests listed in Minn. R. 7035.2836, subp. 5, item 1; a request will be submitted to the commissioner for approval prior to use of the alternative test. 4.11.2 Metals Analysis Once the batch of compost has been determined to be mature, a sample will be taken and analyzed for metals and PCBs in accordance with Minn. R. 7035.2836. SKB will collect a sample using the sample collection and processing technique described in section 4.11.5 below. All analysis for metals and PCBs 11 will be conducted by a laboratory that has a current laboratory certification from the Minnesota Department of Health. The laboratory will use the sample preparation and analysis methods described in the most recent EPA SW -846. In the event that a batch of mature compost does not meet the above contaminant concentrations, SKB will blend the compost with other feedstocks to achieve the concentration in the above table. The blending practice will be done in accordance with MPCA's "Blending Class II Compost to Achieve Class I Standards and Produce Marketable Products" program management decision, which was signed in 2004. A copy of this decision memo can be found in Appendix C. 4.11.3 Percent Inert Material Analysis In the Facility's on -site laboratory, a representative sample will be oven dried in a 70 degree Celsius oven. The oven dried sample will be subdivided into four (4) 250 cubic centimeter subsamples. The subsamples will be weighed and passed through a four millimeter sieve. The material retained on the sieve will be visually inspected for inert materials including: glass, metal, and plastic. The separated inert material that was retained on the four millimeter sieve will be weighed. The weight of the inert material divided by the oven dried weight sample multiplied by 100 is the percent of inert material content. The results of the above testing will be compared to the Class I standard of 3% inert (Minn. R. 7035.2836). In the event that a batch of mature compost does not meet the 3% inert standard, SKB will blend the mature compost with other feedstocks to achieve the 3% standard as stated above in the metal analysis section. 4.11.4 pH, Moisture Content, Particle Size, NPK Ratio, and Soluble Salt Content SKB will submit a sample of the compost to a laboratory certified by the Minnesota Department of Health to be analyzed for all the above parameters as outlined in Minn. R. 7035.2836. 4.11.5 Sample Collection and Processing Techniques This section contains the sampling plan as required in Minn. R. 7035.2836. 4.11,5.1 Training and Experience Samples of the compost will be taken by SKB's on -site laboratory personnel. These personnel are trained in the proper sampling collection techniques and currently take samples of wastes delivered to the Facility, QA /QC samples for the shingle recycling program, and groundwater samples. The proper sampling procedures are part of their training program and these personnel will remain well versed in sampling techniques. 4.11.5.2 Equipment Samples will be taken with small hand shovels and buckets. The finished sample, once composited, will be placed in a sample container provided by the laboratory. 4.11.5.3 Equipment Decontamination All sampling equipment will be washed with laboratory detergent, rinsed with de- ionized water and then rinsed with acid to ensure all the sampling devices are adequately decontaminated, 12 4.11.5.4 Sample Locations The mature compost will be in a conical pile when it is ready to be sampled. SKB will utilize a system similar to the Minnesota Department of Agriculture's sampling plan for sampling agricultural lime to determine the locations for taking grab samples, which will ultimately be composited into one sample. 4.11.5.5 Grab Sample Procedures Grab samples will be collected at the sampling locations determined using the procedure outlined in the Minnesota Department of Agriculture's sampling of agricultural lime fact sheet, which is outlined below. The outside one -third of the pile will be divided into ten areas around the perimeter of the pile; referred to as "outer" areas. The next one -third of the pile from outside perimeter to the top middle will be divided into ten sub areas; referred to as "inter" shaded areas. The remaining one- third, which is the peak of the pile, is divided into two areas. When taking subsamples to be composited, the following ratio shall be used for determining where to collect the grab samples. 7 01,11 It 4 !ARIA H I 1 INNER INNER I N N E R 7 I.- 4 l t "II R 3 1 5 01 II i .111 t INNER I TOP, II!)E)1 1 I INNER ARC 10 LNNER I INNER I INNER _':I 9 10 I 6 I 9 ol: I R \RI.•\ 1 "Top/Middle" Area #'s 1 2): 2 "Inner" Shaded Areas of #'s 3,4,5,6,7,8,9,10) 2 "Outer" Areas of #'s 3, 4, 5, 6, 7, 8, 9, 10) These grab samples will then be composited using the procedure described below. 4.11.5.6 Composite Sample Procedures Ten grab samples, collected using the procedure above, will be combined to make a composite sample. The composited sample will be mixed thoroughly. Once the composite sample has been mixed thoroughly, the composite sample will be subdivided and put into sample containers for sending to the laboratory, and /or sent to the on -site laboratory for performing all required sample analysis. 4.11.5.7 Chain -of- custody and Storage Procedures SKB will use standard chain -of- custody forms for all samples collected related to the composting area. All samples will be stored as required by the analyzing laboratory to properly preserve the sample. When the sample is transferred to another individual, the chain -of- custody form will be signed by the recipient of the sample. A completed chain -of- custody form will be submitted with the laboratory results. 4.11.5.8 Sampling QA /QC SKB will take sample duplicates in order to perform QA /QC analysis on the sampling of the compost. 13 Additionally, the laboratory will follow its own internal QA /QC protocol for the sample analysis. The results of the laboratory QA /QC is provided with the laboratory results and will be reviewed by the laboratory staff and SKB staff. 4.11.6 Description of How Results will Determine Distribution Samples will be taken from each batch of finished compost prior to its distribution and /or on -site use. SKB will review the results of each batch samples and compare it against the Class I compost standards in Minn. R. 7035.2836, subp. 6. Should any mature compost be considered Class 11 compost by the standards listed in Minn. R. 7035.2836, subp. 6; SKB will either blend the mature compost with other feedstocks until it can reach Class I standards or use it, unblended, for on -site uses. For on -site uses of Class II compost, SKB will keep records in its Facility operating record as to the location and quantity of the compost that has been used. SKB will not allow the use of Class II compost on -site to exceed the cumulative or annual loading rates found in Minn. R. 7035.2836, subp. 6. 4.12 Operation Flow The material flow through the composting area is described in detail below. Compostable materials arrive at the site and will be checked into the Facility's system by crossing over one of the scales at the Facility. At this time, the received Toads are initially inspected for the presence of unacceptable materials by the scale house attendant. Once the material has been checked in and found to be acceptable based on the first inspection, it is directed to the composting area. Vehicles arriving at the composting area will be directed by the composting area operator as to where to tip the incoming load of compostable materials. The operator and the vehicle driver will observe the load for the presence of unacceptable materials. Once the material has been tipped, the operator will mix the delivered material with carbon sources, such as leaf waste, and other bulking materials at the appropriate ratios to make a suitable compost mix. This mix will have the appropriate ratio of carbon to nitrogen and air void space to ensure that the compost pile remains aerobic. Upon mixing the compost material, it will be placed in the active compost pile over a perforated pipe where air will actively be pumped through the pile. The compost will remain in the active compost pile until PFRP has been met as outlined above. Once PFRP has been obtained, the compost will be turned using a stacking conveyor into a curing pile. The compost will remain in the curing pile until the compost has met all the testing parameters listed in the sampling plan. Mature, tested compost will then be screened to remove any residual materials that may be in the finished compost. After it has been screened, the finished compost will be either used in that manner as compost or mixed with other soils to make topsoil for use. 4.13 Inspections The composting area will be inspected during SKB's inspection schedule for the Facility. 14 5 Compost Distribution Plan SKB plans to sell the finished compost to external parties or to use the finished compost for its own internal use on -site in turf establishment and management. SKB would mix the compost with other on- site material to make topsoil that is suitable for on -site uses. As required in its permit, SKB must place at least six inches of topsoil over the entire 150+ acre landfill when the landfill is closed. This requirement will require over 120,000 cubic yards of topsoil just for this Facility. SKB also owns another landfill located in Inver Grove Heights that will require at least six inches of topsoil when that facility is closed. At this time, SKB has no plans to sell the compost as a "fertilizer, specialty fertilizer, soil amendment, or plant amendment" as defined in Minn. Stat. 18C.005. If, in the future, SKB wishes to market the material as any of these products; SKB will apply to the Minnesota Department of Agriculture for the appropriate license(s); and will maintain a current copy of the appropriate MDA licenses on file at the MPCA. 15 6 Industrial Solid Waste Management Plan Compost Area This section contains the Industrial Solid Waste Management Plan (ISWMP) for the proposed composting area, as required in Minn. R. 7001.3300 and Minn. R. 7035.2535, subp. 5. SKB has prepared and the MPCA has approved another ISWMP for the other areas of the Facility. This ISWMP only pertains to the composting area. SKB will only use this ISWMP to determine what types of materials are acceptable at the composting area and SKB will continue to use the ISWMP in the 2008 application for the other permitted areas at the Facility. 6.1 Procedure for Notifying Customers SKB will inform all potential customers of the types of waste materials that will be acceptable at the Facility. SKB staff will meet with potential customers and conduct an audit of the generating facility or hauler as to where the materials that will be delivered to the Facility are generated. 6.2 Procedure for Evaluating Waste The waste evaluation program at SKB consists of several interlocking procedures that are described below. In summary, the purpose of these procedures is to provide a high level of confidence that only acceptable materials are managed at the composting area. Among the procedures involved are: proper personnel and personnel training, potential customer information disclosure, general knowledge and experience in waste management, sampling and testing of wastes where necessary, inspection of incoming loads, and repeat testing where needed. The Facility is a valuable asset for both SKB and the region surrounding the Facility, as it provides for environmentally safe management of non hazardous industrial wastes. In order to safeguard this asset, Facility management will use caution and care in accepting wastes, so as not to jeopardize the environmental security offered. There are several people involved in waste approval decisions at SKB Rosemount. Among these are personnel from SKB's management, sales, customer service, and Facility staff. SKB's sales and customer service personnel are trained in hazardous waste management as well as the non hazardous waste that the Facility will accept. Although the sales and customer service groups will generally make first contacts with the potential customer, the final decision on whether or not a waste may be accepted for management at the Facility will be made by the Facility Manager or his /her designee. To re- emphasize a major point, there are two types of waste "acceptance" to be used at the Facility. The first of these, and arguably the most important, is the "pre- approval procedure which is conducted prior to notifying a customer that its waste is acceptable. Once a waste stream has successfully passed through the pre approval process, an approval letter will be sent, which will specify any special conditions. Upon arrival at the Facility, the waste then goes through a second process, termed the "incoming load acceptance," to determine if the waste that was shipped matches the waste which was pre- approved. The "acceptance procedure" is the combination of the pre approval and incoming Toad acceptance procedures for evaluating a candidate waste stream. 16 6.3 Procedure for Inspecting Industrial Solid Waste Incoming materials are inspected several times. First, the materials are examined by sales and management staff at the Facility prior to giving approval for accepting a new waste stream at the Facility. Once the material has been approved for delivery, it is inspected several more times. The first is at the scale by the scale attendant. Next, it is inspected by the vehicle driver and site operator as it is tipped at the tipping area. Last, the operator continues to inspect the material as the compostable material is mixed and placed onto the active composting pile. 6.4 Acceptable Waste Types Source Separated Compostable Materials, as defined in Minn. Stat. Subd. 32a; Yard Waste, as defined in Minn. R. 7035.0300, subp. 121; Sewage Sludge (Biosolids) that has been treated to meet Class B pathogen reduction standards in Minn. R. Ch. 7041; Unused scraps of gypsum drywall and Other industrial sludges that meet the concentration values found in Minn. R. 7035.2836, subp. 6, Item A(1). These materials are described in greater details in 2011 correspondences with the MPCA, Dakota County, and the City of Rosemount. These letters and this further information can be found in Appendices F through H. 6.4.1 Empty Pesticide Containers SKB will not accept empty pesticide containers at the composting area. 6.4.2 Asbestos SKB will not accept wastes containing asbestos at the composting area. 6.4.3 Waste Containing PCBs SKB will not accept wastes containing PCBs at the composting area. 6.4.4 Spilled Nonhazardous Waste Only spilled nonhazardous wastes that are organic in nature and will compost will be accepted by SKB at the composting area. 6.4.5 Rendering and Slaughterhouse Waste SKB will accept rendering and slaughterhouse waste that can be composted at the composting area. 6.4.6 Wastes that Spontaneously Combust SKB will not accept wastes that can spontaneously combust at the composting area. 6.4.7 Foundry Waste Without prior approval or a case specific beneficial use determination from the MPCA, SKB will not accept foundry wastes at the composting area. The USEPA and the USDA have conducted many years of research on uses for foundry sands. One use of spent foundry sand is to mix the foundry sand with finished compost and other materials in the production of "manufactured soil At a future time, SKB may consider mixing foundry sands with finished compost to make "manufactured soils" or other usable 17 products. However, SKB will obtain all necessary approvals from the MPCA prior to conducting this activity. 6.4.8 Ash from Incinerators SKB will not accept ashes from incinerators at the composting area. 6.4.9 Sludges SKB will accept select sludges at the compost area. The sludges must be nonhazardous per the requirements of Minn. R. Ch. 7045. In addition to being nonhazardous, the SKB will only accept sludge materials from the industries outlined in the 2011 letters, one to the MPCA, one to Dakota County, and one to the City of Rosemount (See Appendix The sludges will be biodegradable and readily treatable in the composting process operated at the Facility. Initially, SKB will obtain approval from the MPCA and provide written notification to Dakota County prior to accepting the material at the Facility. 6.4.10 Fiberglass, Urethane, Polyurathane, and Epoxy Resin Waste SKB will not accept fiberglass, urethane, polyurethane, or epoxy resin waste at the composing area. 6.4.11 Spent Activated Carbon Filters SKB will not accept spent activated carbon filters at the compost area. 6.4.12 Other Wastes SKB may accept bleaching earth from the production of bio- diesel and vegetable oil at the composting area. 6.5 Plan Modification This plan shall be amended as needed. SKB will prepare a formal request to amend the ISWMP and submit the amendment proposal to the MPCA, Dakota County Environmental Management Department, and the City of Rosemount for approval. Once all necessary approvals have been obtained, SKB will then use the modified ISWMP. Example of changes could include, but are not limited to: newly identified waste types, changes to screening and testing of waste streams, and /or changes to inspection procedures. 18 7 Closure and Post Closure Plan Final closure of the entire Facility will follow the closure plan outlined in the previously approved closure and post closure plan submitted to, and approved by the MPCA during the 2009 issuance of the major permit modification. Should SKB wish to close just the compost area of the Facility, the following steps will be followed. 1. Notification of Customers and Units of Government Six months prior to stopping its composting operations, SKB will notify its regular customers and all units of government that permit this activity that the composting area at the Facility will be closing. This notification will offer alternative locations for the delivery of the compostable material that has been delivered to the Facility. 2. Removal of Materials SKB will finish composting all materials that have been delivered to the Facility in accordance with these plans and all facility permits and licenses. Once all the compostable material has been turned into compost, SKB will utilize or distribute all the compost in accordance with its approved compost distribution plan. 3. End Use The operations will be taking place on a temporarily closed portion of the landfill. The composting pad will be removed and the area will be restored to a landfill cell suitable for landfilling waste in accordance with all relevant permits and licenses. 19 8 Contingency Action Plan Minn. R. 7001.3300 and Minn. R. 7035.2615 require the preparation of a contingency action plan. No changes are necessary to the contingency action plan developed and approved by the MPCA during the 2009 issuance of the major permit modification. 20 Appendix B Correspondence with MPCA on applicability of the environmental review with this project 2 ENVIRONMENTAL March 21, 2011 Mr. Craig Affeldt Environmental Review Program Supervisor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 RE: Environmental Assessment Worksheet Determination Dear Mr. Affeldt: SKB Environmental, Inc. (SKB) is submitting this letter to the Minnesota Pollution Control Agency (MPCA) seeking a written determination on the applicability of Minn. R. 4410.4300, subp. 17, item E. This rule outlines when an Environmental Assessment Worksheet (EAW) is mandatory for a mixed municipal solid waste compost facility and a refuse derived fuel production facility. SKB is considering submitting a solid waste permit application for the construction and operation of a new compost facility, which would accept source separated compostable materials, yard waste, sewage sludge, and other industrial wastes as feedstock materials. SKB is of the opinion that an EAW is not mandatory for this project under Minn. R. 4410.4300, subp. 17, item E. Minn. R. 4410.4300, subp. 17, item E states an EAW is mandatory "for construction or expansion of a mixed municipal solid waste compost facility or a refuse derived fuel production facility with a capacity of 50 or more tons per day of input, the PCA is the RGU." Minn. R. 4410.0200 gives mixed municipal solid waste the same definition as Minn. Stat. 115A.03, subd. 21. In 2008, the Minnesota Legislature passed and the Governor signed into law S.F. No. 3056, which included a change to the definition of mixed municipal solid waste in Minn. Stat. 115A.03, subd. 21. This change specifically removed the reference to source- separated compostable materials from the definition of mixed municipal solid waste. The law also altered the definition of source separated compostable materials to remove any reference to mixed municipal solid waste in its definition. SKB will not be proposing to accept any mixed municipal solid waste at its facility. All proposed feedstocks are separately defined as something other than mixed municipal solid waste in Minn. Stat. 115A.03; therefore, none of the proposed feedstocks would meet the definition for mixed municipal solid waste in Minn. Stat. 115A.03. As such, an EAW would not be mandatory for this project, and SKB is asking the MPCA for its written concurrence with the SKB interpretation. 251 Starkey St. a P.Q. Box 7216 St. Paul, MN 55107 651-724-6329 FAX 651-223-5053 '=U ft d::f Reocied Pa,i6'e. Minnesota Pollution nt r of Y,ge c 520 Lafayette Road North I St. Paul, Minnesota 55155 -4194 1 651 -296 -6300 2,00 (55: 1.te, ■5 <,31 r April 8, 2011 Mr. Geoffrey D. Strack, P.D. SKB Environmental 251 Starkey Street P.O. Box 7216 St. Paul, MN 55107 RE: Environmental Assessment Worksheet Determination Dear Mr. Strack: In your letter of March 21, 2011, you state that SKB Environmental is considering constructing and operating a new compost facility, which would accept source separated compostable materials, yard waste, sewage sludge, and other industrial waste as feedstock materials. SKB Environmental is of the opinion that an Environmental Assessment Worksheet (EAW) is not mandatory for this type of project under Minn. R. 4410.4300, subp. 17, item E. The Minnesota Pollution Control Agency agrees that the project as described in your letter would not meet the mandatory category of the preparation of an EAW under Minn. R. 4410.4300, subp. 17., item E. If you have any questions regarding the letter, please contact me at 651 757 -2181. Sincerely, Craig Affeldt Supervisor, Environmental Review Unit St. Paul Office Regional Division CA: m bo Appendix C MPCA Program Management Decision Memo Blending Class II Compost to Achieve Class I Standards and Produce Marketable Products 3 MINNESOTA POLLUTION CONTROL AGENCY PROGRAM MANAGEMENT DECISION MEMO ISSUE: Blending Class II Compost to Achieve Class I Standards and Produce Marketable Products EFFECTIVE DATE: rf j zit DECISION The MPCA will allow the blending of Class II compost with other finished compost feedstocks (most likely yard waste or manure compost) for the purpose of creating a blended consumer soil/compost products meeting Class I standards so long as certain precautions, detailed below, are taken. RELEVANT STATUTES AND RULES 7035.2836 Compost Rules RATIONALE Current rules and statutes would allow the mixing and blending of MSW and other feedstock at the beginning of the compost process. While the current rules do not envision or mention the possibility of mixing or blending at the end of the process, some staff are apprehensive to allow this activity because it goes against the long standing notion in environmental regulation that you cannot allow "dilution as the solution to pollution This notion is in contrast to the new concept of "waste as a resource In cases where the goal is the utilization of waste products as a raw material in making new materials it is necessary to reexamine old ideas. After careful evaluation of the risks involved in this type of operation it became clear that if properly operated a permitted compost facility could create a marketable compost product from Class II compost that has been blended to meet Class I standards. Most risks can be averted if the end product will meet or exceed the Minnesota Department of Health's recommendation that any soil product contain 100ppm or less of lead. IMPLEMENTATION The compost sampling plan must be reevaluated and staff should have an opportunity to recommend a method that most consistently achieves a sample nearest to a representative sample. The plan should also consider sampling at various stages of the process (raw MSW compost, blended compost, and final product). The plan must also include a ceiling limit for lead, and a plan to remove from blending operations any compost that exceeds the ceiling limit. The sampling plan must also review technical information from composting industry organizations, compost facility permittees and compost experts on the existence of potential contaminants not now required for testing that should be considered for testing at various stages in the process. The plan should present a proposed testing plan including ceiling levels for any contaminants of concern. The compost distribution plan must reflect current practices. A facility proposing to blend Class II MSW compost as part of a blended product must submit an end product labeling strategy that is consistent with labeling guidance to be created by OEA staff for the purpose of better informing the public on the proper use and safe handling, of the blended compost products. The Solid Waste Program Lead should oversee the implementation of this decision. The Solid Waste Media Lead should develop a control plan for the implementation of the decision. This plan should include a reporting mechanism. APPROVAL I have reviewed this management decision and I concur. i Signed: ,_l j Sill ;t N u Date: ��Zb /()C/ Date: 3 J Name Gordon Wegwart Name Leo Raudy Title Assistant Commissioner Title REM 1 iv' io Director Signed: 3 foil Signe• .4 .0,-1 Date: i /J i„.. Date: Jr r Name Art Dunn Name Larry dh: Title Director, OEA Title Solid Waste Program Lead, MPCA Signed: Signed: i Ai Date: 313 (1Q� Date: Name David Thornton Name David Richfield Title Section Manager Title Supervisor Land Policy Unit Appendix D Compost Area Drawings and Topographic Map 4 1 'W: B Q LL 0 Ili; a w' w Q i ifil HH i 2 eL :.i.: Z t,/$ WF R j .t G A p. 1 2 S o i w 1 G uu W 05 x z a z O 2 LL_ ZU LL m O� U y a i 9 KUO S 3 U m A i a QQ ...1 F i Z lip It tl8 d u; m W 6 Q V a 1gd i g 4 V; r g o w aka N j S ow R _8 P 3 °S 3 O w W t, p W at o o �i i g iI 9pS '.fi N U '45: NQiiII Ui s 1�3a a 8 6 W $rc a w X62 a te °�w 1 o. a��ma c w 3 w w o 0 0 w w z y w E 0 8 -J 1 F I I I L L r a►—°d%?�9's s. o� L A A A O s A A 3 A O iii s 3 i ri 9-i I t f e a r i A A b i i i i i i®i••®i••.4 I .,;A- /a®. ®®®i®i®®•' iao:+® d�- AS4• e® e!: ®®®®!i3O4-o! ®s ❖p6�•�o ®i:i:Ai® 1 e i I: 1. rl 1 j juj>� A$ o o a a p s 0,4 .044 0..�. :o°mi� ®s 1 I s ®i ®i►4►iAii4•• see` evi®® vel i,►♦ vev iosi s�oi i••�i ®o, ►i�A ®i� r �IoO® 'A ®�iiiii °ii ®•i�Oiii ♦iiiiiA ®i i •�Ai� r i I ►iiiAAA i to LU a w •ii i♦Ai At I id,+► ♦iii•° I iiiii t• ♦i i Ai i i4Ai I i 4 1 0 4 i. 11 4 ii i s N N W a i i i 41 4 1 s i i l ►iiiiiiiliiiiii ►:i: iii iiiiiiiii I I +:i:• :®N�id :•i•:❖ :!i m i i i i i••• �D i O •i• ♦ii••• ♦i• r .4 N. i� I iiiii ♦iii►ii 1 i ♦iw••••iiiiii I I m I i i •iivA i i i .r •ii i ♦•iA O, •iA•AO 4 I aD :i i i W 4. •.4t4))j :.iil" 'isiifi ®_i j•i••i ♦ii ♦••�i♦• i4,44" I I c9 i t I I i i W m •i i I I U IMO i-�-i b -1 I 1 a Q O x a N i i J n z 1 g►•i♦♦ a o o •A• I I z ii; i Q •i♦i o" •i♦ see !I �i iii i o i 1 'i i 11.. i ii 1 i i 1 I s i i iii i A i i i I i i I I 1 I L a A 1 i474 i {'�4A=••A_:•iiiii•Aii ®d 1 f 1 1 I 1 p A i'iaii °i•O °if 1 1 i I I v {I {yi °i•;$92 I I II i 1 t ♦i P wa 6 ■a.s►�e ®i_I 6 B it II ow 1 U I 11 ®•si ®a�.� I I l I i i 1 1 N♦iA 9 U I I i t J 1 1 I r I T 1 1a tl35n 03iItlOMlli/t.l DI f0 1111.ISVJ 3tl 30 5 3x1 SI 35n ONOtldd tl1053NNI11 '1NnON3500 A1NM3 tl101tl0 31Y0 i. g g 1 IOV',, '.nv v3x1 95n 4 5 w a o...o r N nio e. isniu s... p. -...tl h ..o „N.,s»os �.n..o, >e ox..... o y 8 1 �I I £8£ MS AlillOb3 j >b w..ww r+;q�"✓ w ni°s 31SYM 1VI 1Sf GNl W 3 8 N TTI'3. °3°ngee.WlW i 1NfOW3SONSNS a y w.o �a w '°A 3H12iO3 S`JNIMb'2�4 I 7 I; w j NOI1VO131O a OIN 1011 01 v011d:.530 l.., ox !r Y, SNOISIM13tl I. a,$ly'.'g r,! a X i 8 8 b ,4 Y b gS° r m_� 'a 0i Lt 2� i 2 3 2 Y V W S 3 S 3 Ti W p v_� W W J� C a w w w W W W W w W W w w tj Z V H •i6o N; 2 1 gg w A i 1 1 �w� �R ti a a ea a O be» N z0_ if w Z m w J 0 “J'->" V Zw i 0_0 w o v Yz i i i i i t ii 3 •Y l i 5: X r M A w t s, vow i w -g ww 4 i In td i J J tlSN 00 C• :4,12 w X i wa •�'s clew. i p •7/ T W?X Iy 1 m i 14 I Z 1 Q r' V j J.6 1 Lu 1' Z a I• P JN� Wj I. i I 7F Oti. r'� 1 1 ZW SF ""aW I I\ r 1 f. V W 4 75 V 2. II 1 I I l: 3 o 'ti\ U .Z LL I z sue 1 ,1 .1 w I c w a x ,r p' W 1 I F V j _aZ \M i r r ,p�j 1 2� J V N: r l y J 1 II W p 7 wj i i/ :.c I 3 I I l'2, z a s N J NSF „.4;'‘:' Q I n °A Sl 3,7_ Y~ I �Vl i I/ o LL f 1 1 Sig w 8 I I U Iu Y P. J yy1 i.S{ I I i aa� 2 0 1 ii 1 I ii L y1 77 'I u 3 V\ h ig 1 1 z 5= Y B ,-.12,E 4. I o w r i I w z ow I I. r "'S3JIAN3S 1V1N3WNO2l!AN3 J 1 tip d0 7t341g03 13141 -Od06-13W Appendix E Bucket Test 5 Taken from the University of Minnesota Extension Service Website: How to measure free air space in your compost pile: The Five Gallon Bucket Test Materials needed: A five gallon pail A one gallon plastic milk jug Typical mix of materials added to the compost pile 1. Check the volume of your five- gallon pail by filling the one gallon jug and emptying it into the five- gallon pail five times. Mark the five- gallon "full line" on the pail. 2. Fill the five- gallon pail one -third full with a typical mix of compost materials and drop the pail ten times from a height of six inches onto a cement floor or sidewalk (being careful to keep all the material in the pail). 3. Add compost to fill the five- gallon pail two thirds full and drop the pail ten times from a height of six inches onto a cement floor or sidewalk. 4. Add compost to fill the five- gallon pail up to the "full line" and drop the pail ten times from a height of six inches onto a cement floor or sidewalk. 5. Add compost to fill the five gallon pail to the "full line." 6. Now add and keep track of the amount water you can add to the five gallon pail before it overflows. If you can add 2.75 to 3.25 gallons of water to the five- gallon pail without it spilling over the top, you have adequate free air space. Your initial free air space is correct. If you cannot add at least 2.75 gallons of water to the five gallon pail without it spilling over the top, you have inadequate free air space. Add more bulking material like straw, coarse wood chips, or shredded bark. If you can add more than 3.25 gallons of water to the five- gallon pail without it spilling over the top, you have too much free air space and you need to reduce the particle size. This can be done by grinding or shredding the materials or by adding finer materials to the mix. 7. Make the needed corrections and retest until the test shows the correct initial free air space. 6 Appendix F 2011 Correspondence Between MPCA and SKB ISA:5i ENVIRONMENTAL August 8, 2011 Mr. Bob Criswell Permit Engineer Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 RE: SKB Compost Application Response to Comments Dear Mr. Criswell: SKB Environmental, Inc. (SKB) received comments from the Minnesota Pollution Control Agency (MPCA) concerning SKB's application to add a composting area to its solid waste permit, SW -383. SKB has reviewed the MPCA's comments and offers the following responses: 1. Please describe the quality of leachate anticipated for the compost site in quantitative terms. Any leachate generated at SKB's compost area will be similar to the Empire Township Compost Site, SW- 601. The Empire Township Compost Site has sampled their pond since the inception of the facility. This pond receives all the run -off from the lined compost pad. Enclosed is a copy of the Empire Township Compost Site's pond sampling data from 2007 through 2010. 2. Please describe the effects of the compost leachate on facility leachate in quantitative terms. As mentioned above, the pond at the Empire Township Compost Site collects the leachate and contact water from the composting area. With respect to metals, the Empire Township Composting Site's concentrations are much lower than the concentrations of metals in the existing Facility leachate. The water coming from the compost area will have low concentrations, as seen in the Empire facility data, and the volume of water coming from the compost area will be small compared to the volume of leachate from the rest of the Rosemount facility. Therefore, SKB does not expect there to be much of an effect on the facility leachate due to adding the composting area to the facility. 3. To approve the use of oil contaminated soils for composting the MPCA will need quantitative data demonstrating the effectiveness of composting at reducing the levels of DRO, GRO and TPH. SKB has withdrawn its request to have petroleum contaminated soils as an acceptable feedstock at the proposed composting area. 251 Starkey St. P.O. Box 7216 St. Paul, MN 55107 651 224 -6329 FAX 651 223 -5053 Printed on Recycled Paper. 4. To approve the use of sewage sludge, the MPCA will need quantitative data demonstrating the levels of pathogen and data showing the compost site will not cause pathogen growth. SKB is enclosing several attachments with this response letter that address the addition of sewage sludge in compost. The first is an article published in Biocycle magazine, a compost industry publication, which shows that there are over 265 facilities in the United States that use biosolids (treated sewage sludge) as feedstocks. Additionally, SKB is enclosing a factsheet written by the US Environmental Protection Agency (USEPA) that shows composting is an acceptable and approvable treatment method for biosolids. Last, is a copy of frequently asked questions from the USEPA website. Question 16 on this website states that composting of biosolids is an acceptable treatment method and that the composted biosolids can safely be distributed for use on lawns and home gardens. Additionally, the USEPA's rules for making Class A biosolids and Minn. R. Ch. 7041 alternative five (5) for producing Class A biosolids include composting as an option for reducing pathogens to the appropriate level prior to distribution. Specifically, Minn. R. Ch. 7041 allows the use of a static aerated pile and requires the compost pile reach 55 degrees Celcius for three days. By meeting the Process to Further Reduce Pathogens (PFRP) requirements in MPCA composting rules, the PFRP for making Class A biosolids would also be met. 5. Please list the industrial sludges that you intend to use in the composting facility and include data demonstrating the effectiveness of the composting site at treating these sludges. The acceptance of industrial wastes and industrial sludges has also been addressed with Dakota County and the City of Rosemount. Below is a copy of the response that SKB submitted to Dakota County on this issue. "Industrial Waste and Sludges" means vegetative waste generated from an industrial or manufacturing process that prepares food for human or animal consumption. It also includes clean wood waste that may be used for bulking material in the composting process. Additionally, it includes non- hazardous industrial wastes and sludges that are organic in nature, which means it has an organic matter content 50 In a July 6th meeting with Dakota County and the City of Rosemount, SKB indicated that we have not entered into any agreements with any generators of compostable industrial waste. County staff indicated that SKB could list, by SIC code, industry categories that SKB would likely target for feedstock material. Below is a list of example waste streams that SKB would be pursuing. SIC Code Industry Title 100 Agricultural Production Crops 800 Forestry 2000 Food and Kindred Products 2030 Canned, Frozen Preserved Fruit, Vegetables Food Specialties 2033 Canned Fruits, Vegetables, Preserves, Jams and Jellies 2040 Grain Mill Products 2050 Bakery Products 2052 Cookies Crackers 2060 Sugar Confectionery Products 2090 Miscellaneous Food Preparations Kindred Products 2400 Lumber Wood Products 2421 Sawmills Planting Mills, General 2600 Papers Allied Products 2611 Pulp Mills 2621 Paper Mills 2631 Paperboard mills 2650 Paperboard Containers Boxes 2670 Converted Paper Paperboard Products County staff also asked SKB to identify sources of feedstocks that SKB would not be pursuing. Below is the list of example waste streams that would be unacceptable at the composting area. SKB reserves the right to obtain County staff approval for the use of a material from one of these industries as a reusable bulking material, such as ground off specification tires. SIC Code Industry Title 1311 Crude Petroleum Natural Gas 1381 Drilling Oil Gas Wells 1382 Oil Gas Field Exploration Services 1400 Mining Quarrying of Nonmetallic Minerals 1000 Metal Mining 2800 Chemicals Allied Products 2810 Industrial Inorganic Chemicals 2834 Pharmaceutical Preparations 2860 Industrial Organic Chemicals 2911 Petroleum Refining 2950 Asphalt Paving Roofing Materials 3011 Tires Inner Tubes 3021 Rubber Plastic Footwear 3341 Secondary Smelting Refining of Nonferrous Metals As indicated in the July meeting, a likely source of materials that SKB will pursue would be residuals from the manufacturing and recycling of paper products. As stated in the July meeting and earlier in this response, SKB does not have any contracts to receive any waste streams. Therefore, predicting quantity or quality of any waste stream is not possible at this time. Prior to accepting industrial feedstock materials other than food waste, SKB will follow the following procedure to address the quality of the feedstock material, which also addresses the County's comment about the proposed testing procedure. In addition to the parameters listed in SKB's application (Arsenic, Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Zinc, and PCB's), SKB will also have industrial feedstocks sampled for Chromium (total), pH, and nitrogen species as outlined in section 13.05 of the Dakota County Ordinance 110. In addition to the above list of parameters, SKB will also review the industrial process from which the material is generated. Based on this review, SKB will require generators to sample additional parameters that are likely to be present based on that process. This is similar to SKB's current acceptance procedure for the landfill. Should SKB identify a feedstock material that is outside the definition or SIC codes listed above, SKB will seek approval from Dakota County staff for the waste material. 6. In regard to composting petroleum contaminated soils, the MPCA requests any human health guidance or standards which may be applicable or should be considered when this type of waste is being considered (ie. OSHA standards, guidance or like kind of information). SKB has withdrawn its request to have petroleum contaminated soils as an acceptable feedstock at the proposed composting area. If you have any questions concerning this letter, contact me at GeoffrevPskbinc.com or 651 251 -6203. Sincerely, .1/4 /9 kr 7 Geoffrey D. Strack, P.E. Environmental Engineer Enclosures cc: Eric Zweber, City of Rosemount Dave Magnuson, Dakota County Doc St. Clair, SKB Environmental J 0 N J 0 0 J 0 0 J 0 0 0 1.4 N X goV O O 0000000 p y T D O1 J ti 3 0. 2 c d 2 z z 2 Z z Z z z ca r 0 Y1 ry a O' f $O O ON p. G •G $00 C 2 O 2 O Z 2 Z 2 2 Z Z O N O n 1/§111E12 00 000000 Z yN C 0000000 m zzzzzzz nyt. S 0 O N N O N 0 0 J r {pO� c a yy 1 N 8 O O O O Z O Z ON N N 00 0 D N O O W q 0 D N 0 Slit 0 0 0 0 0 N '...0 arZ 02 Z 0 0 Z Z ZZ 2 CO C NNV D g p Q� O �3 a+ �88 z g8 °z b zz zz y� (y 0 O O d O i Lr s p 0 N 0 05 0000000 U C N O O 0 2 p d 2 c:, 2 0 2 Z Z 2 Z z z woi 0 0 A N h h N N -1.. ggd °d °d zoi zzz yN A g ao N -8§ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 U R .t 2222 Z 22 Z ZZ 222 2 N a 00 N 8 8 z 8$ z z 8 z z 0 z z z z zz zzzz z U 00 0 0 y� A 8 ng� N N N J N7 S 8 ZOOZ z 0000000 zzzz w Oo 00 0 0 O 0 0 0 N .r� g�� qz O 0000000 8Z 0225 Z ZZZZZZZ y V d 66 0 �dd� d G O 6 y i Q c °N c N ,1 c f c rEI m a z 2 0 0.�b5.6a� V 0o 0 n Q� N O E O 0 mG 4 IL b I y r Z e U a E V a a Appendix G 2011 Correspondence between Dakota County and SKB 8 (2°4 C O U N T Y Physical Development Division Lynn Thompson, Director June 30, 2011 Dakota County Western Service Center 14955 Galaxie Avenue Geoffrey D. Strack Apple Valley, MN 55124 -8579 SKB Environmental, Inc. 952.891.7000 Fax 952.891.7031 251 Starkey Street www.dakotacounty.us St. Paul, MN 55107 Environmental Mgmt. Department Office of GIS Dear Mr. Strack: Parks and Open Space Department Surveyor's Office Transit Office Dakota County Environmental Management Department staff has reviewed Transportation Department the compost facility license application submitted on May 16, 2011, by SKB Water Resources Department Environmental, Inc. (SKB) and determined the application is not complete. For the Department to process your license application, an amended application must be submitted that includes the additional information identified below. Additional Information Required 1. Dakota County Ordinance No. 110 (Ord. 110), Sect. 13.01 C. 4: the operations plan shall include as a minimum: the procedures for facility start-up and scheduled and unscheduled shut -down operations. The start-up procedure is missing from the application and must be provided. 2. Ord. 110, Sect. 13.01 C. 10: the operations plan shall include as a minimum; the total capacity of the site including proposed storage and processing capacity for the incoming waste, residuals, compost in progress, curing compost, and finished compost. SKB's proposed operations plan does not include the above information. Include details of the annual capacity, on -site capacity, and amount of space required for each category listed above. 3. Ord 110 Sect. 13.05 A: the facility operator must provide a detailed description, including appropriate chemical and physical analysis, as determined by the Department, of the sources(s), quality, and P,inted on recycled paper with 3C% post mnsumer wage. AN EQUAL OFPOg1U TY EMPLOYS quantities of the solid waste(s) to be composted or used as bulking agents. SKB proposes to accept industrial sludges that meet the concentration values found in Minn. R. 7035.2836, subp. 6, Item A (1). The referenced rule is used to determine if the finished compost meets the Class I Compost classification and by itself is insufficient to determine if industrial sludge is appropriate for composting. SKB must propose additional parameters that will be used to determine if the sludge is an appropriate solid waste for composting. Suggested parameters include, but should not be limited to: percentage of organic material, the parameters outlined in Ordinance 110 Section 13.05 H, and any other potential contaminants not outlined in the above rules, but which have the potential to be in the waste stream. In addition, please provide a preliminary list of specific industrial sludges SKB is proposing to accept. Include in that list: type, source, and quantity of waste. 4. Ord 110, Sect. 13.05 B: the waste storage areas and the waste processing, composting, curing, and compost storage areas must be constructed of a water impermeable surface such as concrete or asphalt, and designed to control leachate and surface water run -off. SKB's proposal does not meet this requirement; SKB must either meet this requirement or apply for an exemption, in accordance with Ord 110, Sect. 13.06. 5. Ord 110, Sect. 13.05 C: the tipping, processing, curing, and active composting activities must be conducted within an enclosed building. SKB's proposal does not meet this requirement; SKB must either meet this requirement or apply for an exemption, in accordance with Ord 110, Sect. 13.06. 6. Ord. 110, Sect. 13.05 G: daily operational records must be maintained for the facility that include temperature monitoring date, and operational data, such as quantity and types of waste processed. Please provide a description of how SKB will meet this requirement. 7. Ord 110, Sect. 13.05 I: a quarterly operational report must be submitted to the Department within 30 days of the end of the calendar quarter and must include; all information and analyses specified in the license application, including copies of laboratory reports; the origin, types, and quantities of solid waste and bulking agents composted at the facility; the quantity of compost and residuals produced; sampling and monitoring locations and protocol used to obtain representative conditions and samples; operational information including temperature monitoring data and facility operational problems; and a description of the ultimate use and distribution of the finished compost. Please provide a detailed description of how SKB will meet this requirement. If you have any questions about the additional information required in this letter, please call me at (952) 891 -7551. Sincerely, Dave Magnuson Dakota County Environmental Management Department C: Eric Zweber, City of Rosemount Geoffrey Strack From: Lynn, Michael [Michael.Lynn @CO.DAKOTA.MN.US] Sent: Thursday, July 07, 2011 9:44 AM To: Geoffrey Strack Cc: John Domke; Mike Fullerton; 'Eric Zweber eric .zweber @ci.rosemount.mn.us)'; Magnuson, Dave; Harthun, Jeff Subject: Notes from the July 6th Meeting Between Dakota County Staff, SKB, and the City of Rosemount Geoff, With respect to industrial sludge, Dakota County needs, among other items in the comment letter, a percent organics specification for the incoming feed stock. We talked about what "primarily organic" means; greater than 50 SKB staff mentioned that there is a carbon shortage and wanted some flexibility in their marketing efforts and the ability to adjust their feed -stock "recipe so Dakota County staff agreed that SKB could propose seeking Departmental approvals under the license for wastes that were not on the preliminary list, or had an organic content less than 50 Bulking agents were also discussed, and I was OK with the example referenced, tire chips, as long as they were re- usable and had that function. Dakota staff also needs SKB to complete the permit application with a list of industrial sludge that is detailed enough to allow for their evaluation. Dakota County would allow some flexibility by using SIC codes to denote sludge from certain industry types, as SKB said they did not know which accounts they would go after right now for feed stock. The City of Rosemount had concerns with certain types of sludge from the refining of petroleum. There should also be a list for unacceptable wastes. We also discussed excluding from the acceptable feedstock untreated sewage sludge. SKB said they wanted to provide for the health of the end user and their employees, and was focusing on meeting the Class B standard for sewage sludge. As a sidelight, SKB staff said that landfill operations and closure would not be affected by the operations of the proposed compost facility. This is my re- collection of the meeting. If there is anything to add for clarification, or I missed something altogether, I will consider adding it to these meeting minutes. Please let me know. Thanks, Mike L. Lynn, P.E. Waste Regulation Supervisor Environmental Management Department Dakota County Voice: 952 891 -7025 Fax: 952 891 -7588 E -mail: michael.lynnna.co.dakota.mn.us 1 E VIR'ON !ENTAL July 14, 2011 Mr. Dave Magnuson Dakota County Environmental Management Department 14955 Galaxie Avenue Apple Valley, MN 55124 -8579 RE: SKB Environmental, Inc.'s Compost Proposal Dear Mr. Magnuson: SKB Environmental, Inc. (SKB) received a Dakota County (County) comment letter dated June 30, 2011. This letter outlined seven (7) comments County Staff had concerning SKB's 2011 solid waste composting proposal. Below are SKB's responses and additional information to the seven comments. 1. Dakota County Ordinance No. 110 (Ord. 110), Sect. 13.01 C. 4: the operations plan shall include as a minimum: the procedures for facility start-up and scheduled and unscheduled shut -down operations. The start-up procedure is missing from the application and must be provided. Start-up of the compost area would begin by temporarily closing an area of the landfill. The area will be graded in accordance with the design details outlined in SKB's initial application. Once the area has been graded, intermediate cover will be applied to the area in accordance with all permits and licenses for the landfill cell. On top of the intermediate cover, six inches of three -inch minus gravel will be placed to make a pad. After preparing the gravel pad, the active composting area will be equipped with an electrical supply that will be used by the active aeration blowers. Perforated HDPE pipes will be set on the compost pad and connected to blower fans. Bulking materials and other carbon sources will be brought to the composting area and stockpiled for mixing with other incoming materials. Once there is an adequate supply of bulking material, SKB will begin to accept compost feedstock materials and begin operating the composting area per the SKB operations plan in the compost application. 2. Ord. 110, Sect. 13.01 C. 10: the operations plan shall include as a minimum; the total capacity of the site including proposed storage and processing capacity for the incoming waste, residuals, compost in progress, curing compost, and finished compost. 251 Starkey St. P.O. Box 7216 St. Paul, MN 55107 SKB's proposed operations plan does not include the above information. Include details of the annual capacity, on -site capacity, and amount of space required for each category listed above. As stated in SKB's application, SKB is proposing to move the composting operation around the site as the landfill develops with the operation always conducted over a Tined portion of the landfill. This will utilize the landfill liner as the liner for the compost operation. Because the operation will move around the site, the acreage that can be devoted to the composting operation will be different at each location and change each time a new area is constructed or an old area is taken out of service and returned to Iandfilling. As such, the capacity will continuously change. This can be seen in the drawing in the application. This drawing indicates that the first phase would likely have around six acres of land; however, when the entire landfill is up to grade, there would be over 50 acres of land that could be used for composting. SKB is asking that the capacity of the composting operation be based on a per acre basis with an annual maximum capacity of 50,000 tons per year of compostable materials. SKB proposes to accept 5000 tons of compostable material per acre of composting area. This amount is similar to the capacity listed for the Empire site and other sites around the Country that SKB found in a quick survey of facilities. 3. Ord. 110 Sect. 13.05 A: the facility operator must provide a detailed description, including appropriate chemical and physical analysis, as determined by the Department, of the source(s), quality, and quantities of the solid waste(s) to be composted or used as bulking agents. SKB proposes to accept industrial sludges that meet the concentration values found in Minn. R. 7035.2836, subp. 6, Item A (1). The referenced rule is used to determine if the finished compost meets the Class I Compost classification and by itself is insufficient to determine if industrial sludge is appropriate for composting. SKB must propose additional parameters that will be used to determine if the sludge is an appropriate solid waste for composting. Suggested parameters include, but should not be limited to: percentage of organic material, the parameters outlined in Ordinance 110 Section 13.05 H, and any other potential contaminants not outlined in the above rules, but which have the potential to be in the waste stream. In addition, please provide a preliminary list of specific industrial sludges SKB is proposing to accept. Include in that list: type, source, and quality of waste. The acceptance of industrial wastes and industrial sludges was discussed with County staff and the City of Rosemount staff in a meeting on July 6, 2011. In this meeting, SKB offered the following term and definition to help address the types of materials that SKB intends to accept at the compost area. "Industrial Waste and Sludges" means vegetative waste generated from an industrial or manufacturing process that prepares food for human or animal consumption. It also includes clean wood waste that may be used for bulking material in the composting process. Additionally, it includes non hazardous industrial wastes and sludges that are organic in nature, which means it has an organic matter content 50 In the July 6 meeting, SKB indicated that they have not entered into any agreements with any generators of compostable industrial waste. County staff indicated that SKB could list, by SIC code, industry categories that SKB would likely target for feedstock material. Below is a list of example waste streams that SKB would be pursuing. SIC Code Industry Title 100 Agricultural Production Crops 800 Forestry 2000 Food and Kindred Products 2030 Canned, Frozen Preserved Fruit, Vegetables Food Specialties 2033 Canned Fruits, Vegetables, Preserves, Jams and Jellies 2040 Grain Mill Products 2050 Bakery Products 2052 Cookies Crackers 2060 Sugar Confectionery Products 2090 Miscellaneous Food Preparations Kindred Products 2400 Lumber Wood Products 2421 Sawmills Planting Mills, General 2600 Papers Allied Products. 2611 Pulp Mills 2621 Paper Mills 2631 Paperboard mills 2650 Paperboard Containers Boxes 2670 Converted Paper Paperboard Products County staff also asked SKB to identify sources of feedstocks that SKB would not be pursuing. Below is the list of example waste streams that would be unacceptable at the composting area. SKB reserves the right to obtain County staff approval for the use of a material from one of these industries as a reusable bulking material, such as ground off specification tires. SIC Code Industry Title 1311 Crude Petroleum Natural Gas 1381 Drilling Oil Gas Wells 1382 Oil Gas Field Exploration Services 1400 Mining Quarrying of Nonmetallic Minerals 1000 Metal Mining 2800 Chemicals Allied Products 2810 Industrial Inorganic Chemicals 2834 Pharmaceutical Preparations 2860 Industrial Organic Chemicals 2911 Petroleum Refining 2950 Asphalt Paving Roofing Materials 3011 Tires Inner Tubes 3021 Rubber Plastic Footwear 3341 Secondary Smelting Refining of Nonferrous Metals As indicated in the July meeting, a likely source of materials that SKB will pursue would be residuals from the manufacturing and recycling of paper products. As stated in the July meeting and earlier in this response, SKB does not have any contracts to receive any waste streams. Therefore, predicting quantity or quality of any waste stream is not possible at this time. Prior to accepting industrial feedstock materials other than food waste, SKB will follow the following procedure to address the quality of the feedstock material, which also addresses the County's comment about the proposed testing procedure. In addition to the parameter listed in SKB's application (Arsenic, Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Zinc, and PCB's), SKB will also have industrial feedstocks sampled for Chromium (total), pH, and nitrogen species as outlined in section 13.05 of the Dakota County Ordinance 110. In addition to the above list of parameters, SKB will also review the industrial process from which the material is generated. Based on this review, SKB will require generators to sample additional parameters that are likely to be present based on that process. This is similar to SKB's current acceptance procedure for the landfill. Should SKB identify a feedstock material that is outside the definition or SIC codes listed above, SKB will seek approval from Dakota County staff for the waste material. 4. Ord. 110, Sect. 13.05 B: the waste storage areas and the waste processing, composting, curing, and compost storage areas must be constructed of a water impermeable surface such as concrete or asphalt, as designed to control leachate and surface water run -off. SKB's proposal does not meet this requirement; SKB must either meet this requirement or apply for an exemption, in accordance with Ord. 110, Sect. 13.06. In accordance with Dakota County Ordinance 110, Section 13.06; SKB requests an exemption from the requirement in Dakota County Ordinance 110, Section 13.05, Item B. This requires the storage, processing, composting, curing and compost storage areas to be constructed of an impermeable surface. SKB will be conducting feedstock storage, feedstock processing, active composting, and compost curing on top of a temporarily closed Tined landfill cell. While these activities will be conducted on a gravel pad, all these operations will take place over a landfill liner. This liner is impervious with a leachate collection system. This system would meet the intention of the requirement in Dakota County Ordinance 110, Section 13.05, Item B. In addition to the liner exemption, SKB has proposed to store finished compost that meets Class I standards, and is suitable for unrestricted use, be allowed to be stored at any location on the facility property. While this proposal may meet the intent of the ordinance, it is also for good cause as composting generates a beneficial product from a material that would otherwise be landfilled. This proposal will result in the material being managed at higher level on the waste management hierarchy. SKB's proposal will provide a better use of the material; benefiting Dakota County and the State of Minnesota. 5. Ord. 110, Sect. 13.05 C: the tipping, processing, curing, and active composting activities must be conducted within an enclosed building. SKB's proposal does not meet this requirement; SKB must either meet this requirement or apply for an exemption, in accordance with Ord. 110, Sect. 13.06. In accordance with Dakota County Ordinance 110, Sect. 13.06, Sect. 17.01, and Sect. 17.02; SKB requests a continuing exemption to the composting ordinance to authorize SKB to conduct all operations associated with composting outdoors. SKB is proposing to tip, process, compost and cure outdoors. Each of these operations will be done over a temporarily closed portion of the Tined landfill. SKB is proposing to move the composting operation around the site as the landfill develops. SKB believes moving the operation around the site, makes the requirement of constructing a building for all of these operations burdensome. Constructing a building and then demolishing the building to move the operation to its next location would be unnecessary for a process that generates a beneficial product from a material that would otherwise be landfilled. 6. Ord. 110, Sect. 13.05 G: daily operational records must be maintained for the facility that includes temperature monitoring date, and operational data, such as quantity and types of waste processed. Please provide a description of how SKB will meet this requirement. SKB will continue to utilize its current waste check -in process for incoming loads of waste materials. This includes directing incoming Toads of materials to one of the two scale houses. Once at the scale house, the scale attendant will conduct an initial inspection of the material, enter the weight and material type into the computerized ticketing system, print a hard copy of the ticket, have the truck driver sign the ticket, and then direct the load of acceptable materials to the composting area. With this system, SKB is able to track quantities and types of waste materials processed. The same system is used for the finished compost. The finished compost will be scaled out of the system with the customer noted on the scale ticket. In addition to the above tracking system, operators will enter operational data onto daily operating reports. These reports will record temperature data and any other operational data that is pertinent to the operation of the composting facility. Copies of this information will be kept at the facility for up to three years. 7. Ord. 110, Sect. 13.05 I: a quarterly operational report must be submitted to the Department within 30 days of the end of the calendar quarter and must include; all information and analyses specified in the license application, including copies of laboratory reports; the origin, types, and quantities of solid waste and bulking agents composted at the facility, the quantity of compost and residuals produced, sampling and monitoring locations and protocol used to obtain representative conditions and samples; operational information including temperature monitoring data and facility operational problems; and a description of the ultimate use and distribution of the finished compost. Please provide a detailed description of how SKB will meet this requirement. SKB currently submits a quarterly report to Dakota County on all the current activities at the facility. It is SKB's intention to add all the required information for the composting operation to the quarterly report already submitted to the County. A section on the composting area would be added to the report and would include all the information above: laboratory results, origin of materials delivered, quantities of materials delivered, amount of residuals removed from the compost, sampling and monitoring locations, time and temperature data collected, a summary of any operational issues and SKB's response to the issues, and information on the distribution of the finished compost. If you have any questions about the responses in this letter, please contact me via e-mail at Geoffrev@skbinc.com or telephone at 651 251 -6203. Sincerely, 7 1/1 Geoffrey D. Strack, P.E. Environmental Engineer cc: Robert Criswell, MPCA Eric Zweber, City of Rosemount Doc St. Clair, SKB Environmental Geoffrey Strack From: Lynn, Michael [Michael. Lynn @CO.DAKOTA. MN. US] Sent: Wednesday, July 20, 2011 3:08 PM To: Magnuson, Dave Cc: Geoffrey Strack; 'Eric Zweber eric .zweber @ci.rosemount.mn.us)' Subject: RE: SKB Response to Dakota County Comments Compost Application July 2011.docx Dave, I talked to Geoff Strack this afternoon, and I said you would be in contact with Eric Zweber by the EOD tomorrow concerning the acceptability of certain feed stocks, i.e., the sewage sludge and the industrial waste sludges. By that time you should have had the chance of reviewing both the SKB and MPCA responses. According to Geoff, the City has a concern of recommending approval of these waste types for purposes of the Planning Commission meeting and then subsequently, have either the County or MPCA have a problem with a certain type or types. Please advise when you have completed this portion of your review Thanks, Mike From: Magnuson, Dave Sent: Tuesday, July 19, 2011 3:04 PM To: 'Geoffrey Strack'; Lynn, Michael Subject: RE: SKB Response to Dakota County Comments Compost Application July 2011.docx Geoff, can you please fax the MPCA's comment letter to us? We cannot open the attachment that was emailed. Thanks, Dave Dave Magnuson Environmental Specialist Dakota County Environmental Management 14955 Galaxie Ave Apple Valley, MN 55124 phone: (952) 891 -7551 fax: (952) 891 -7588 dave.maonusonaco.dakota.mn.us From: Geoffrey Strack [mailto:geoffrey@skbinc.com] Sent: Tuesday, July 19, 2011 2:22 PM To: Lynn, Michael; Magnuson, Dave Subject: SKB Response to Dakota County Comments Compost Application July 2011.docx Dave and Mike, I have mailed you a copy of the attached letter. We talked to Eric today about our composting project. He asked us about a professional opinion from the County. He stated that he discussed what he is looking for with Mike. I will give you a call tomorrow morning to discuss our response and the City's desire to have a correspondence from the County (e- mail or letter). Thanks. Geoffrey D. Strack, P.E. SKB Environmental St. Paul, MN 651 251 -6203 desk 612 490 -1175 cell 2 Geoffrey Strack From: Geoffrey Strack Sent: Wednesday, July 20, 2011 9:19 AM To: 'Magnuson, Dave'; Lynn, Michael (michael.lynn @co.dakota.mn.us) Subject: MPCA Comments.docx Attachments: MPCA Comments.docx Dave, As promised, attached are the MPCA comments. I can view this on my phone because it is an apple product and it was written using apple software. I was unable to get it converted to word, so I just re -typed it. This is the second e-mail that Bob sent. The difference is that he added comment #6. Geoff 1 Re -typed by Geoff Strack Comments SKB composting application: June 29, 2011 1. Please describe the quality of leachate anticipated for the compost site in quantitative terms. 2. Please describe the affects of the compost leachate on facility leachate in quantitative terms. 3. To approve the use oil contaminated soils for composting the MPCA will need quantitative data demonstrating the effectiveness of composting at reducing the levels of DRO, GRO and TPH. 4. To approve the use of sewage sludge the MPCA will need quantitative data demonstrating the levels of pathogen and data showing the compost site will not cause pathogen growth. 5. Please list the industrial sludges that you intend to use in the composting facility and include data demonstrating the effectiveness of the composting site at treating these sludges. 6. In regard to composting petroleum contaminated soils, the MPCA requests any human health guidance or standards which may be applicable or should be considered when this type of waste is being considered (ie. OSHA standards, guidance or like kind of information). Geoffrey Strack From: Magnuson, Dave [Dave.Magnuson @CO.DAKOTA.MN.US] Sent: Thursday, July 21, 2011 1:59 PM To: 'Eric Zweber (eric.zweber @ci.rosemount.mn.us)' Cc: Geoffrey Strack; Lynn, Michael Subject: RE: SKB Response to Dakota County Comments Compost Application July 2011.docx Eric, I have reviewed Section 3 of SKB's letter dated July 14, 2011, in which they further define the industrial waste sludges they want to accept for composting. We are comfortable that the new definition, the testing parameters outlined, and the restrictions based on SIC codes, should result in industrial sludges that are appropriate for composting. Since composting industrial sludges is new to Dakota County, and since SKB is not able to give us specific waste streams at this time, we plan on asking SKB to submit their waste evaluations to us prior to accepting the waste for composting. This will not be a formal approval process, just a notification so we can see the specific industrial sludges they are accepting. Dave Dave Magnuson Environmental Specialist Dakota County Environmental Management 14955 Galaxie Ave Apple Valley, MN 55124 phone: (952) 891 -7551 fax: (952) 891 -7588 dave.magnusonOco.dakota.mn.us From: Lynn, Michael Sent: Wednesday, July 20, 2011 3:08 PM To: Magnuson, Dave Cc: 'P. E. Geoffrey D. Strack (Geoffrey@ skbinc.com)'; 'Eric Zweber (eric.zweber@ ci.rosemount.mn.us)' Subject: RE: SKB Response to Dakota County Comments Compost Application July 2011.docx Dave, I talked to Geoff Strack this afternoon, and I said you would be in contact with Eric Zweber by the EOD tomorrow concerning the acceptability of certain feed stocks, i.e., the sewage sludge and the industrial waste sludges. By that time you should have had the chance of reviewing both the SKB and MPCA responses. According to Geoff, the City has a concern of recommending approval of these waste types for purposes of the Planning Commission meeting and then subsequently, have either the County or MPCA have a problem with a certain type or types. Please advise when you have completed this portion of your review Thanks, Mike From: Magnuson, Dave Sent: Tuesday, July 19, 2011 3:04 PM 1 To: 'Geoffrey Strack'; Lynn, Michael Subject: RE: SKB Response to Dakota County Comments Compost Application July 2011.docx Geoff, can you please fax the MPCA's comment letter to us? We cannot open the attachment that was emailed. Thanks, Dave Dave Magnuson Environmental Specialist Dakota County Environmental Management 14955 Galaxie Ave Apple Valley, MN 55124 phone: (952) 891 -7551 fax: (952) 891 -7588 dave.macnuson4co.dakota.mn.us From: Geoffrey Strack [mailto:geoffrey(askbinc.com] Sent: Tuesday, July 19, 2011 2:22 PM To: Lynn, Michael; Magnuson, Dave Subject: SKB Response to Dakota County Comments Compost Application July 2011.docx Dave and Mike, I have mailed you a copy of the attached letter. We talked to Eric today about our composting project. He asked us about a professional opinion from the County. He stated that he discussed what he is looking for with Mike. I will give you a call tomorrow morning to discuss our response and the City's desire to have a correspondence from the County (e- mail or letter). Thanks. Geoffrey D. Strack, P.E. SKB Environmental St. Paul, MN 651 251 -6203 desk 612 490 -1175 cell 2 C O U N T Y Physical Development Division August 17, 2011 Lynn Thompson, Director Dakota County Western Service Center 14955 Galaxie Avenue Geoffrey D. Strack Apple Valley, MN 55124 -8579 SKB Environmental, Inc. x52.2.891.7 0 031 Fax 952.891.7031 251 Starkey Street .891.7 y www.dakotacounty.us St. Paul, MN 55107 Environmental Mgmt. Department Office of GIS Dear Mr. Strack: Parks and Open Space Department Surveyor's Office D akota County Environmental Management Department (Department) Transit Office Y 9 P P staff Transportation Department has reviewed the compost facility license application submitted on May 16, Water Resources Department 2011, by SKB Environmental, Inc. (SKB) as well as the follow -up letter dated July 14, 2011, and has determined additional information is still required, prior to approving the application. Once the application is amended to the Department's satisfaction, SKB will also need to submit an updated application which incorporates all of the changes to the original May 16, 2011, application. The Department will not be able to specifically schedule a Physical Development Committee date until an updated application is submitted, and approved, the City of Rosemount approves an amended Interim Use Permit, and the Minnesota Pollution Control Agency places a draft permit on public notice. Additional Information Required 1. Ord. 110, Sect. 13.01 C. 10: the operations plan shall include as a minimum; the total capacity of the site including proposed storage and processing capacity for the incoming waste, residuals, compost in progress, curing compost, and finished compost. While SKB has proposed a total capacity of 5,000 tons per available acre per year, the detail described above is missing. Provide the on- site capacity, with supporting calculations, for incoming waste, residuals, compost in progress, curing compost and finished compost. Also, provide a plan map of the layout of the composting area, showing which areas will be dedicated for each activity. If the approved facility layout needs to be modified after the license is Panted on rec paper «rth 30% posi- conwmer wzs[e Anl EiUAL OPPORTUNN]T EFIPLO'ER issued, the County will entertain any proposal by SKB to amend the operations plan. 2. Add to Section 4.6 of the application, the maximum amount of residual storage on -site and the maximum length of the storage. 3. Add to section 5 of the application, the maximum amount of finished compost storage and the location of the storage. If you have any questions about the additional information required in this letter, please call me at (952) 891 -7551. Sincerely, Dave Magnuson Dakota County Environmental Management Department C: Eric Zweber, City of Rosemount John Domke, SKB Robert Criswell, MPCA EIYYJROIYMEIYTAL April 5, 2012 Mr. Dave Magnuson Dakota County 14955 Galaxie Avenue Apple Valley, MN 55124 -8579 RE: SKB Compost Application Response to August 17, 2011 Letter Dear Mr. Magnuson, This letter is in response to your letter dated August 17, 2011. In this letter, Dakota County indicated that three additional pieces of information from SKB are needed in order to complete the County's review of SKB's application. Below are SKB's responses to the County's comments (retyped in bold): 1) Ord. 110, Sect. 13.01 C. 10: the operations plan shall include as a minimum; the total capacity of the site including proposed storage and processing capacity for the incoming waste, residuals, compost in progress, curing compost, and finished compost. While SKB has proposed a total capacity of 5,000 tons per available acre per year, the detail described above is missing. Provide the on -site capacity, with supporting calculations, for incoming waste, residuals, compost in progress, curing compost and finished compost. Also, provide a plan map of the layout of the composting area, showing which areas will be dedicated for each activity. If the approved facility layout needs to be modified after the license is issued, the County will entertain any proposal by SKB to amend the operations plan. Enclosed is a drawing that SKB shared with Dakota County and the City of Rosemount in a meeting in 2011. The drawing is a representation of the Phase 1 composting area in the drawing attached to the application. The schematic is actually 5.6 acres versus the 6.3 acres shown on the drawing, but it was simplified into a rectangle for illustration purposes. The drawing show four 400 foot by 30 foot windrows with 30 foot driving lanes between composting piles. In these windrows, one could fit 24 cubic yards /yard of pile of compost. Using a bulk density of 0.3 tons /cubic yard and using six acres with a residence time in the compost pile of 45 days, one would need 513.7 yards of windrow. The drawing shows adequate space for 533.3 yards of windrows. Using a 45 days residence time in the curing pile, the drawing shows a pile the can be made with a 90 foot long radial stacker. to that pile, one could store 7,982 cubic yards of compost. Using a 0.5 tons /cubic yard unit weight for the compost in the curing pile the curing pile would need to be 7398 cubic yards for the six acre site. This shows that the curing pile shown on the drawing is of sufficient size. 251 Starkey St. P.O. Box 7216 St. Paul, MN 55107 Printed on Recycled Paper. 651 224 -6329 FAX 651 223 -5053 i As discussed below, there is still adequate space to stockpile finished compost on the other corner of the composting pad. However, since the finished compost will be suitable for unrestricted use there is adequate space to move the stockpile of finished compost around the site and create stockpiles as SKB does with other resources (i.e. topsoil and aggregates) at the site currently. 2) Add to Section 4.6 of the application, the maximum amount of residual storage on -site and the maximum length of the storage. SKB will stage two 40 yard dumpsters for the collection and storage of residuals removed during the process. SKB will empty each 40 yard box as soon as possible after one is full. The second dumpster will serve as a place for residuals once the first dumpster is full and is being transported to the appropriate disposal location. SKB will store residuals in the dumpster until it is full, but will empty the residual dumpster even if it is not full should they become a nuisance. It is anticipated that the dumpster would need to be emptied at least once every two months at a maximum. 3) Add to Section 5 of the application, the maximum amount of finished compost storage and the location of the storage. Finished Compost will be stored in a pile on the composting pad next to the curing pile. Should this space not be adequate, SKB will move the finished compost to a stockpile to be readied for use or sale elsewhere on the site. The finished compost will be class I compost suitable for unrestricted use thus stockpiling elsewhere on the site will not be problematic from an environmental standpoint. SKB often has large stockpiles of soil and aggregate on site for operational purposes, which shows that there is adequate room on -site for stockpiles of finished compost. If you have any additional questions concerning these responses, please contact me at 651 224 -6329 or Geoffrev(skbinc.com. Sincerely, eoffrey D. Strack, P.E. Environmental Engineer Enclosure cc: Eric Zweber, City of Rosemount Bob Criswell, MPCA Jon Penheiter, SKB Doc St. Clair, SKB 1 Volume of Curing Pile V r2H (0.039) +90 *(H2R /1160) For 30 foot high pile and 37 degree angle of repose Volume 7,982 cubic yards r 40 feet Stacker Length 90 feet Arc 90 degrees H 30 feet R 87.5 feet Density of Finished Compost 0.5 tons /yd3 Tons in Windrow at any one time 5000 tons /acre /year Time in Curing Pile 45 days 0.123288 years 616.4383562 tons /acre Volume in one acre 1232.876712 yd3 Volume in 6 acres 7397.260274 yd3 Volume of 90 foot radial stacker pile is larger than volume of compost Cross Sectional Area of Static Aerated Pile A= 0.5 *(L1 L2) *H A 0.5 *pi *HA2 Trapizoid Semi circle Area 24 yd Area 39.25 yd Ll 2 yards L2 10 yards L2 10 yd H 4 yards H 5 yd Unit Volume Volume 24 yd /yd Volume 39.25 yd /yd Time in Active Composting 45 days 0.123288 years Bulk Density 0.3 tons /yd3 Tons /Unit Legth 7.2 tons /yd Tons in Windrow at any one time 30000 tons /acre /year 6 acres developed 3698.63 tons /acre Length of Windrow needed 513.6986 yards of windrows With 10 yard driving lane 2.122722 acres for windrows Appendix H 2011 Correspondence Between the City of Rosemount and SKB 9 I SK13 1 ENVIRONMENTAL June 7, 2011 Mr. Eric Zweber Senior Planner City of Rosemount Rosemount, MN RE: SKB Rosemount Industrial Solid Waste Management Facility, SW -383 Compost Application Dear Mr. Zweber: On June 1, 2011, you called with a few questions about SKB Environmental, Inc.'s (SKB's) May 2011 application to add a compost area to the SKB Rosemount Industrial Solid Waste Management Facility (Facility). The first question concerned a process flow description for the proposed composting operation that was discussed in a meeting prior to SKB submitting the application to the City of Rosemount. SKB initially addressed this request by adding section 4.12 to the application. In our June 1, 2011, conversation you requested a more descriptive flow diagram. Enclosed with this letter is a copy of this flow diagram. The second question concerned the list of materials to be composted at the facility. A listing and description of these materials can be found in section 4.1 and 6.4 of the application. SKB has further described these materials that were specifically asked about in the phone conversation below. Sewage Sludge that has been treated to meet Class B pathogen reduction standards in Minn. R. Ch. 7041 With this item, SKB is asking to accept dewatered, treated sewage sludge from a domestic wastewater treatment plant. This material does not include pumped septage. This material may also be referred to as biosolids. These materials have been land applied by domestic wastewater treatment plants. However, these materials are organic in nature and will readably compost at a composting facility and are sources of nitrogen and carbon that is needed at a composting facility that SKB has proposed. As required by Minnesota Rules, SKB will only accept sewage sludge from domestic wastewater treatment plants that have been through a process to reduce pathogens. The specific requirement can be found in Minn. R. Ch. 7041. •r� nA n_.. 711.ln na n_..I 1alt cr. /17 mom. Petroleum contaminated soil SKB has proposed possibly accepting petroleum contaminated soil at it compost site. There are facilities in Minnesota that successfully compost petroleum contaminated soil. These facilities use the microbiological process of the composting process to metabolize the petroleum fractions of the soil and successfully return the soil to productive use. SKB has reviewed the past two annual reports for one of these facilities, Lamb's Limited Liability Co. in Cook County. In these annual reports, there were not any indications that they produce substandard composted soil that is unable to be used. Other industrial sludges that meet the concentration values found in Minn. R. 7035.2836, subd. 6, item (A)1 SKB has proposed to accept sludge materials from industrial sources. These materials would be limited to sludges that do not have concentrations of parameters listed in Minn. R. 7035.2836, the class I compost standards. In addition, these materials would need to be organic in nature that would readably be able to be composted. Examples of these sludges may be the sludge materials that come from an industrial wastewater treatment plant, paper mill sludge, or short paper fiber sludge from recycling paper products, etc. As stated above, these materials will be organic in nature, be a source of nitrogen and /or carbon, and have contaminant concentrations less than those listed in the class I compost standards. If you have any further questions concerning this letter or compost application, please contact me at 651 251 -6203 or Geoffrey @skbinc.com. Sincerely, %//fj) J7k7 Geoffrey D. Strack, P.E. Environmental Engineer Enclosure cc: Mike Fullerton, SKB Environmental Doc St. Clair, SKB Environmental Robert Criswell, MPCA Dave Magnuson, Dakota County Load Tip Inspection Load Construct Pile Bulking Agent (wood, leaves) Odor Management (Compost Cover) Actively Aerated Pile 55 C 7days Turn Pile Curing Pile (Passive Aeration) Landfill 4 R e j ec t s Finish Pile Class I r Blend Compost to 4 Use on Site achieve Class II Class I J 1 45 411° ENVIRONMENTAL July 20, 2011 Mr. Eric Zweber Senior Planner City of Rosemount 2875 145th Street West Rosemount, MN 55068 RE: SKB Compost Application Vector and Rodent Control Dear Mr. Zweber: SKB Environmental, Inc. (SKB) is submitting this letter in response to comments raised during the June 28, 2011 Planning Commission meeting. During the public hearing portion of the June meeting comments were raised about vector and rodent issues. In SKB's application, SKB describes several management practices that will be followed at the compost area. Below is an outline of these management practices; along with further discussion on how the management practices will address, among other items, vector and rodents. Incoming feedstocks will be processed within 24 hours of receiving the material. This operational practice will address many possible nuisance conditions: windblown material, odor, and vectors and rodents. In the act of processing, blending, and placing the material into the compost pile, the source separated compostable materials will be size reduced. In addition to the reduction in size, they are "diluted" by mixing with bulking materials and other carbon sources. This process reduces the likelihood that vectors and rodents will find the material a suitable food source. This fact has been noted in the enclosed Biocycle article that "...immediate bulking and grinding of food waste with shredded wood was a deterrent to attracting birds and mammals" (i.e. vectors and rodents). The compost pile will be covered with a compost blanket. SKB will cover the compost pile with a layer of finished compost or ground wood mulch. In addition to aiding in the control of odors, this management technique will cover the processed compost material; which will reduce the availability of the material to vectors and rodents. The compost pad will be graded. Grading the pad will prevent stormwater from running onto the compost area and will prevent contact water from leaving the composting area. It will also prevent water from ponding on the compost pad. The elimination of a water source is important in deterring vectors and rodents. Some vectors, such as gulls, need a water source present to be able to eat. Last, SKB is committed to running the site in a nuisance free manner. This would include regularly looking for nuisance conditions present at the site including vector and rodents. In the unlikely 251 Starkey St. P.O. Box 7216 St. Paul, MN 55107 event that vector or rodents are found at the site, SKB would hire a service or implement other operational techniques to eliminate vectors and /or rodents from the facility. If you have any questions concerning this letter, please contact me at Geoffrev@skbinc.com or 651- 251 -6203. Sincerely, It Gffrey D. Strack, P.E. Environmental Engineer Enclosure cc: Dave Magnuson, Dakota County Bob Criswell, MPCA Doc St. Clair, SKB Food Scraps Composting And Vector Control BioCycle, Advancing Composting, Orga... Page 1 of 3 TURN Search BioCycle et1' 34 1, 6 Search Sign up here to 0 receive BioCycle c. electronic bulletin. t -+l. A-- -.,ss- SUBSCRIBE NOW! ADVANCING COMPOSTING, ORGANICS RECYCLING RENEWABLE ENERGY Home Share I Subscribe Current Issue Renew Contents by Issue Food Scraps Composting And Vector Address Change Article Access Contact Us Article Database Control About BioCycle Advertise Writer Guidelines BioCycle June 2008, Vol. 49, No. 6, p. 35 Books Reports In a USDA study, it appeared that immediate bulking and grinding of food waste with E S y stems shredded wood was a deterrent in attracting birds and mammals. BioCycle Conferences Resources Links BioCycle Advertisers Bradley F. Blackwell and Thomas W. Seamans Renewable Energy 2011 Compost Science NONTRADITIONAL waste management facilities, particularly new projects to compost food BioCycle Global 2011 In Business scraps, are becoming more common because of national and state initiatives to promote recycling and extend landfill capacities. In fact, food waste is the third largest component of Events Calendar findacomposter.com generated waste by weight, following yard trimmings and corrugated boxes. The U.S. Department of Agriculture (USDA) estimates that each American disposes of 1.3 pounds of food waste daily or nearly 474 pounds annually. While there is a clear need to recycle food American Biogas waste, the location of waste management facilities and national initiatives on waste Le— Council management are increasingly controversial, partly because of potential wildlife related c., 1l., A. „e impacts. Responsible development of the industry must include management of facilities to COOL 2012 minimize waste material serving as attractants to vectors such as birds and mammals that pose hazards to human health and safety. l �7 For example, traditional putrescible waste landfills often attract large numbers of gulls and BACKPIUS other bird species that can pose a significant risk to air traffic, if the facility is located near North Arneriea an airport. In response to the concern over bird aircraft collisions, the Federal Aviation Administration (FAA) issued Order 5200.5A in 1990 to recommend that putrescible waste landfills and other waste management facilities not be located within one mile of runways used by piston powered aircraft or within two miles of runways used by turbine powered SUM satmt. aircraft. Order 5200.5A also recommends against locating any waste management facility within two p� Q E4 to five miles of an airport if the facility "attracts or sustains hazardous bird movements from C a feeding, water or roosting areas into, or across the runways and /or approach and departure patterns of aircraft.” In August 2007, the FAA published Advisory Circular No: 150/5200- 338, Hazardous wildlife attractants on or near airports, which includes the recommendations �a g� from Order 5200.5A. In addition to potential bird aircraft collisions, bird use of waste management facilities can also pose other problems for the surrounding community. Specifically, foraging opportunities at these facilities can enhance survival and productivity of problem bird species that adapt readily to human -based resources. For example, several species of gulls are known to nest on flat roofs in proximity to putrescible waste landfills. Roof nesting gulls are often ft�ir considered a nuisance and economic liability because they damage roofs, attack pedestrians aa and defecate on cars and buildings. Further, feathers, nest material and food remains can plug drains on buildings. Gulls also carry bacteria (e.g., Eschericia coli, Salmonella, Campylobacter and Listeria) that cause enteric disease in humans. In addition, there is evidence that the water quality of reservoirs can be degraded by large]e numbers of roosting gulls that are benefiting from both roof -top nesting areas and waste facilities. Other nuisance birds often associated with landfills (rock pigeons [Columba livia], European starlings [Sturnus vulgaris] and house sparrows [Passer domesticus]) are reported to carry more than 60 diseases transmissible to humans and domestic animals. Finally, there is the factor of attraction of rodents at waste management facilities. Small mammals are prey to many bird species, particularly raptors, which can be a threat to air traffic because of their large size and soaring behavior. Also, the presence of commensal rodents such as Norway rats (Rattus norvegicus) and house mice (Mus musculus) is an issue because of the possibility of transmitting disease to humans (e.g., hantavirus pulmonary syndrome, the bacterial diseases, leptospirosis and plague), causing structural damage to buildings, and strong public aversion to these species. COMMUNICATION AND COLLABORATION A key component in developing food waste composting operations in a manner that is environmentally safe is communication and collaboration with local, state and federal Food Scraps Composting And Vector Control BioCycle, Advancing Composting, Orga... Page 2 of 3 agencies responsible for human health and safety, and management of wildlife. As little data exist on bird and rodent use of the various types of nontraditional waste management facilities, particularly those processing food waste, a collaborative approach to assess wildlife hazards provides information critical not only to the business and management agencies, but also to the surrounding community. In some cases, funding agencies involved in the development of this industry will request that businesses work with consultants on wildlife issues. For example, Barnes Nursery, Inc. in Huron, Ohio, received a grant in 2007 from the Ohio Department of Natural Resources and logistic support from the Ohio Environmental Protection Agency (EPA) and the U.S. EPA to pursue new methodologies in food waste composting and energy recovery. These agencies encouraged the owners to document potential wildlife hazards at this initial phase in the development of their food waste composting business. In April 2007, Barnes initiated a cooperative service agreement with the USDA Animal and Plant Health Inspection Service (APHIS), Wildlife Services, National Wildlife Research Center's Ohio Field Station to design and conduct a wildlife hazard assessment. FACILITY BACKGROUND The Barnes composting facility opened in May 1991 on a 25 -acre property less than one mile south of Lake Erie and two miles west of Huron, in Erie County. The facility is in a rural area surrounded by farmland, a tree nursery, a four -lane highway and a general aviation airport within one mile. Although yard waste (i.e., grass, leaves and woody debris) is the primary type of material received at the site, Barnes also accepts soils, manure, sludges, woodchips and, recently, food waste. For the purposes of this article, food waste is defined as including, but not restricted to, fruit and vegetable trimmings, outdated bakery goods and dough, dairy products, seafood (including shells), plate scraps (including meat) and leftover prepared foods, coffee grounds and filters, tea bags, floral waste, egg shells, slurry from pulpers, beverages and liquids such as vinegar. In addition, food waste might contain soiled napkins, tissues, compostable bags, plates, cups and packaging. At the Barnes facility, the food feedstock area and the other waste areas (hereafter, yard waste) are contiguous, but proportionate areas are not constant because of intake of material, processing and storage changes. From June through October 2007, the Barnes facility received a monthly average of 821 tons of yard trimmings and 50 tons of food waste. Food waste was tipped and placed next to a shredded woodpile (Figure 1). Upon delivery, the food waste was immediately bulked with shredded wood, a process intended to control odors and the emission of free water from the waste. The mixture was then ground in a Fecon 250 Wood Hog Shredder (Figure 2), and distributed in windrows (15 feet wide by 8 feet high by 150 feet long) in an area between other yard trimmings collection points (Figure 3). The windrowed material (Figure 4) remains in thermophilic decomposition (105 °F to 155 until packaging material is broken down and the mixture is stable (i.e., heating due to the decomposition processes ceases). Each windrow was turned on a 7- to 10 -day interval (via KW Straddle Type Windrow Turner) to add porosity to the material, thereby maintaining maximum oxygen levels for aerobic decomposition and moisture levels at approximately 50 percent by weight. When the mixture was stable, it was screened to remove noncompostables, cured and tested relative to the U.S. Composting Council Seal of Testing Assurance Program standards. THE WILDLIFE HAZARD ASSESSMENT The USDA objective was to quantify relative use of food and yard waste operation areas at the Barnes facility by bird and mammal species from June through October 2007. Biologists used snap traps for small mammals, placed systematically during two consecutive trapping nights per month, and conducted point counts twice weekly of birds using the facility. Notably, the biologists captured no small mammals in the food waste area, nor observed mammals using the material. Further, only 17 individuals, representing 5 small mammal species, were captured in the yard trimmings area (predominantly deer mice or white footed mice; Peromyscus sp.). In addition, there was no indication, based on observations of predators, tracks, carcasses of prey items and absence of predator fecal material, that population levels of small mammals using the facility were sufficient to attract larger mammalian carnivores (e.g., coyotes, Canis latrans) or raptors. In contrast, the biologists observed 27 bird species on or aerial foraging over the yard waste area, predominated by mourning doves (Zenaida macroura), killdeer (Charadrius vociferous) and bank swallows (Riparia riparia). However, only 6 of the 27 bird species, primarily mourning doves and killdeer, were observed landing on, foraging on, or aerial foraging over the food waste. Notably, bank swallows nested in the face of a large soil pile on the facility and were frequently observed over the site through the second week of July. Barnes Nursery, Inc. personnel were aware of the nesting cavities and, in deference to the Migratory Bird Treaty Act, did not disturb the soil pile. Also, gulls, European starlings and turkey vultures (Cathartes aura) were rarely observed, and observations of species foraging on the yard waste materials were uncommon. Large flocks of gulls, mixed flocks of blackbirds and European starlings (during late summer and fall) and flocks of Canada geese (Branta canadensis) were observed flying over the facility on routes from Lake Erie to nearby agricultural fields and back. These flock movements were, however, unrelated to the yard or food waste at the Barnes facility. Ultimately, weekly counts of individual birds across all species yielded only 9 to 13 birds /acre of the facility. Biologically, there was no differential use of food waste and yard waste areas by birds, and captures of small mammals using the yard waste were few. Though specific data on relative availability of food resources between food and yard waste areas were not collected, nor were data on odor emissions, the inference from the USDA study is that the immediate bulking of food waste with shredded wood upon delivery, and subsequent grinding of the mixture, was effective in reducing the attractiveness of the material to birds and mammals. Further, indices of bird and mammal use of the processed food waste windrowed an site indicated that the material did not serve as a significant Food Scraps Composting And Vector Control BioCycle, Advancing Composting, Orga... Page 3 of 3 attractant to wildlife. However, the USDA assessment was based solely on the tonnage of waste delivered and processing methods used during the 21 weeks of observation. Subsequently, the biologists encouraged Barnes Nursery, Inc. to consider additional site assessment by USDA/ APHIS Wildlife Services personnel as operational capacity changes and new processing protocols are developed. SUMMARY The communication by Barnes Nursery, Inc. with local, state and federal officials about potential wildlife hazards posed by the development of their food waste composting business created an atmosphere of collaboration. We suggest a similar approach for others considering food waste composting operations. However, for those operations proposed within FAA siting criteria for certificated airports under Part 139 of the Code of Federal Regulations, or other airports receiving FAA funding, a Wildlife Hazard Assessment might be deemed mandatory. As noted earlier, good communication with the public and government agencies charged with the safety of the public will benefit your business. Bradley F. Blackwell And Thomas W. Seamans are with the National Wildlife Research Center in Sandusky, Ohio. Copyright 2008, The JG Press, Inc. Previous Article: Measurement Of Volumes At Ohio Class IV Composting Facilities 1 Next Article: Waste Wise In Calgary Search Article Archives 1 BioCycle 1 In Business 1 Compost Science Conferences 1 Books 1 Suscribe I Advertise Links Contact Us 1 About Us 1 Home findacomposter.com www.jgpress.com Copyright Trademark Notice IS t ENVIRONMENTAL September 8, 2011 Kim Lindquist City of Rosemount 2875 145th St. W. Rosemount, MN 55068 -4997 RE: Extension of Permit Approval Deadline Dear Ms. Lindquist, As you are aware, SKB Environmental, Inc. (SKB) has been working closely with the City of Rosemount staff to resolve some remaining issues pertaining to our permit modification allowing organics composting operations at our Rosemount facility. Given that we are still in the process of resolving these issues, we are requesting extending the permit approval deadline to November 2 "d 2011 in order to give ourselves and City staff more time to appropriately address these remaining issues. Please contact me if you have any questions at 651 224 -6329. Sincerely, k- ohn Domke Vice President