HomeMy WebLinkAbout9.b. Request by SKB Environmental to Allow Composting as an Interim Use in the Waste Management District and an Interim Use Permit for Composting, Case 12-06-TA, 12-07-IUP ROSEMOUNT EXECUTIVE SUMMARY
CITY COUNCIL
City Council Meeting Date: June 5, 2012
AGENDA ITEM: Case 12- 06 -TA; 12 -07 -IUP Request by
SKB Environmental to Allow Composting as AGENDA SECTION:
an Interim Use in the Waste Management
District and an Interim Use Permit for New Business
Composting
PREPARED BY: Eric Zweber, Senior Planner, AGENDA NO
Kim Lindquist, Community Development
Director 6 1-19'
ATTACHMENTS: Location Map; Ordinance; Resolutions; APPROVED BY:
Development Commitment; Application for
Major Permit Modification; Excerpt from
the April 24 Planning Commission
Minutes. 0 nJ
RECOMMENDED ACTION: Motion to adopt Ordinance B -224 amending the City of
Rosemount Zoning Ordinance B adding composting to the interim uses allowed in the
WM -Waste Management zoning district.
Motion to adopt a Resolution approving the Interim Use Permit to SKB Environmental,
Inc. for composting.
Motion to approve the Amended and Restated Development Commitment and
authorize the Mayor and City Clerk to enter into the Commitment.
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 an interim use permit (IUP) for
composting.
APRIL 24 PLANNING COMMISSION MEETING
The Planning Commission conducted a public hearing for the SKB request during their April 24
meeting. Two residents, Frank Knoll and Myron Napper, spoke during the public hearing. Both
residents live along County Road 42. Mr. Knoll expressed concern that the SKB landfill is continually
expanding and has concerns about odors from the compost. Mr. Napper stated that he believes the
SKB landfill is an appropriate location for composting.
Richard O'Gara, representing SKB, gave a brief explanation of his Rosemount landfill operations and
stated that his firm has had a number of composting operations over the years in other communities
and that there is not an odor issue when it is conducted properly.
Commissioner Powell asked how the neighbors will be notified of the operations and testing results
from the landfill. Mr. O'Gara stated that SKB does groundwater testing three times a year and will
notify the neighbors when the test results are available.
Commissioner DiNella asked if there would be methane gas generated similar to MSW landfills. Mr.
O'Gara stated that the composting will be an open air operation on top of the landfill. Methane at
traditional MSW landfills is because the waste is buried.
Following the Public Hearing, Commissioner Miller stated if the soil reference value requirement for
sewage sludge should be specified to be the residential soil reference value. The Planning Commission
unanimously recommended approval of the text amendment and the IUP with the clarification that
the sewage sludge must meet the residential soil reference value.
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 an IUP for
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.
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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
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 (MSW) 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
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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.
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
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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.
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
g 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.
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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
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 an IUP to allow the composting
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of source separated compostable material, yard waste, gypsum, sewage sludge, and industrial sludge.
The expiration of the permit is October 7, 2013. SKB can request a renewal of the composting IUP
and during the review of the renewal, the City can determine an appropriate time limit for the
composting activity. Staff has prepared a recommendation to amend the IUP to allow composting
p g t3' P P p g
with 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 Residential Soil Reference
Values fox erfluorocarbons (PFCs).
(P Cs).
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 including 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. Provide notification to the landfill neighbors when the periodic groundwater monitoring
reports are available.
9. The Rosemount City Council and SKB approve modifications to the Development
Commitment by and Between SKB Environmental, Inc, and City of Rosemount.
10. The Interim Use Permit shall expire on October 7, 2013, the same date as the existing
SKB Landfill Interim Use Permit. SKB can request a renewal of the Interim Use Permit
and the City may determine the appropriate time limit during the review of the renewal.
Development Commitment (i.e. Host Fee Agreement)
SKB has a Development Commitment with City that includes Service Charges for the three waste
streams that are currently approved: MSW Ash, Industrial Waste, and Construction and Demolition
Debris. Staff has prepared a modification to the Development Commitment that includes service
charges for the compostable material brought into the facility at a rate of $0.50 per ton of material.
The full text for this modification is provided below.
9. City Service Charge.
h. Compost Operation Service Charge. To offset the City Service costs, SKB will, for each ton of
material used for compost production at the Facility, pay the City a Compost Operation Service Charge. The
Compost Operation Service Charge that shall initially be imposed, commencing with the first day the Facility accepts
material for the propose of composting, shall be computed at the rate of $'0.50 per ton of yard waste, source separated
compostable material, appropriate construction & demolition debris, sewage sludge, industrial sludge, and /or any other
material approved by the City and Dakota County to be used in the composting process. The Compost Operation
Service Charge shall be paid monthly on actual tonnage delivered. Payments shall be made monthly to the Ci
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y g y at �
2875 145 t Street West, Rosemount, Minnesota 55068, or such other location designated in writing by the City.
Payment for each month shall be due by the 15t day of the following month.
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i. Compost Operation Service Charge Adjustment. The Compost Operation Service Charge is not
subject to the Generator Charge Adjustment described in Section 9.c. of this commitment. Beginning on January 1,
2012 and occurring annual on January 1 of each following year that composting is permitted at the facility, the
Compost Operation Service Change shall be adjusted annual at a rate of 5% inflation, rounded to the nearest cent.
The adjustment shall occur on all material delivered or recycled at the facility for composting on or after January 1g of
that year.
RECOMMENDATION
Staff recommends that the City Council approve the Text Amendment to allow Composting as an
Interim Use in the WM- Waste Management zoning district; approve the modification to the SKB
IUP to allow composting; and approve the modified Development Commitment to include a service
charge for composting.
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SKB Landfill
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Disclaimer: Map and parcel data are believed to be aocunate, but accuracy is not
guaranteed. This is not a legal document and should not be substituted for a title search Map Scale
appraisal, nuwey.or for zoning verification. ' 1 inuh=2OOUfee�
City of Rosemount
Ordinance No. B- 224
AN ORDINANCE AMENDING THE
CITY OF ROSEMOUNT ZONING ORDINANCE B
ADDING COMPOSTING TO THE INTERIM USES ALLOWED IN THE
WM: WASTE MANAGEMENT ZONING DISTRICT
THE CITY COUNCIL OF THE CITY OF ROSEMOUNT, MINNESOTA, ORDAINS that Ordinance
B, adopted September 19, 1989, entitled "City of Rosemount Zoning Ordinance," is hereby amended as
follows:
Section 1. Rosemount Zoning Ordinance B, Section 11 -4 -17 B. Uses Permitted by Interim
Use Permit: Composting
Section 2. EFFECTIVE DATE. This Ordinance shall be in full force and effect from and
after its passage and publication according to law.
ENACTED AND ORDAINED into an Ordinance this 5 day of June, 2012.
CITY OF ROSEMOUNT
William H. Droste, Mayor
ATTEST:
Amy Domeier, City Clerk
Published in the Rosemount Town Pages this day of , 2012.
CITY OF ROSEMOUNT
DAKOTA COUNTY, MINNESOTA
RESOLUTION 2012 -
A RESOLUTION APPROVING THE INTERIM USE PERMIT FOR COMPOSTING AT
THE SKB ENVIRONMENTAL, INC. LANDFILL.
WHEREAS, the City of Rosemount received an application from SKB Environmental, Inc. (SKB)
for an Interim Use Permit (IUP) to allow composting including source separated compostable
material at their waste facility located at 13425 Courthouse Boulevard, Rosemount, Minnesota; and
WHEREAS, the IUP is requested to allow the composting of yard waste, source separated
compostable material, sewage sludge, industrial sludge, and suitable recycled material from the
construction and demolish debris; and
WHEREAS, on April 24, 2012, the Planning Commission of the City of Rosemount held a public
hearing to review the text amendment and IUP request from SKB to allow composting; and
WHEREAS, the Planning Commission adopted a motion recommending that the City Council
approve the Zoning Ordinance Text Amendment to allow Composting; and
WHEREAS, the Planning Commission adopted a motion recommending that the City Council
approve the Interim Use Permit subject to conditions; and
WHEREAS, on June 5, 2012, the City Council of the City of Rosemount reviewed the Planning
Commission's recommendations; and
WHEREAS, on June 5, 2012, the City Council of the City of Rosemount approved the Zoning
Ordinance Text Amendment for Composting; and
NOW, THEREFORE, BE IT RESOLVED, the Council of the City of Rosemount hereby
approves the IUP for SKB to allow composting at their waste facility located at 13425 Courthouse
Boulevard, Rosemount, Minnesota, subject to the following 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 Residential 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 including 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.
RESOLUTION 2012-
6. Approval and Compliance with MnPCA Major Permit Modification.
7. Approval and Compliance with DCEM Composting Variance.
8. Provide notification to the landfill neighbors when the periodic groundwater monitoring
reports are available.
9. The Rosemount City Council and SKB approve modifications to the Development
Commitment by and Between SKB Environmental, Inc, and City of Rosemount.
10. The Interim Use Permit shall expire on October 7, 2013, the same date as the existing
SKB Landfill Interim Use Permit. SKB can request a renewal of the Interim Use Permit
and the City may determine the appropriate time limit during the review of the renewal.
ADOPTED this 5t day of June, 2012 by the City Council of the City of Rosemount.
William H. Droste, Mayor
ATTEST:
Amy Domeier, City Clerk
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AMENDED AND RESTATED
DEVELOPMENT COMMITMENT
BY AND BETWEEN
SKB ENVIRONMENTAL, INC.
AND
CITY OF ROSEMOUNT
SKB ENVIRONMENTAL, INC., a corporation organized under the laws of the State
of Minnesota (hereinafter referred to as "SKB "), makes the following amended and restated
representations and commitments to the CITY OF ROSEMOUNT, a Minnesota municipal
corporation located in Dakota County, Minnesota (hereinafter referred to as "City "), as of the
date of execution hereof by both parties.
WITNESSETH:
1. Project - Facility. SKB proposes to locate in the City a non - hazardous industrial
waste containment facility (the "Facility" or the "Project ") as generally described in both the
Environmental Assessment Report dated November 28, 1988, prepared by Environmental
Engineering and Management, Ltd., a copy of which Environmental Assessment Report (herein
referred to "EAR ") has been provided to the City as well as the Preliminary Permit Application
dated April, 1989 which was also prepared by Environmental Engineering and Management,
Ltd. The Facility will be located on approximately 240 acres of land (the "Property ") as is more
specifically described on the attached Exhibit A, which is incorporated herein by reference. The
proposed Facility is a "state of the art" project and will allow containing of non - hazardous waste
in a manner vastly superior to the way these wastes are presently being disposed of in Dakota
County.
2. Approvals. It is understood that various governmental approvals are required
for the Project including approvals at the federal, state, and regional as well as local level.
3. Economic Benefits. The Facility, in addition to providing a "state of the art"
facility for the handling of non - hazardous industrial waste, will also provide economic incentives
from SKB as delineated in this Commitment to the City as required in conjunction with permits
and approvals required under the City Zoning Ordinance.
NOW, THEREFORE, SKB hereby represents and commits to the City as follows:
4. City Approval. The commitments herein contained are subject to SKB obtaining
all governmental approvals required for the Project, including but not limited to all permits,
authorizations and approvals from the City required to allow construction, operation and
maintenance of the Facility. The commitments are further conditioned upon the issuance,
existence and continuance of all permits, approvals and authorizations required to allow
construction, operation and maintenance of said Facility.
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5. SKB to Proceed. SKB agrees to construct, operate and maintain the Facility on
all or a portion of the Property, as outlined in the EAR, subject to obtaining all necessary
approvals and subject to such modification, if any, as may be required, and agreed to by SKB
resulting from reasonable mandates from other approving authorities.
6. Tax Increment Financing. SKB understands the capabilities of the City or its
Port Authority to establish and operate TAX INCREMENT DISTRICTS in their program to
expand industrial and commercial development in the City. In an effort to assist in this effort
SKB will not object to the City or its Port Authority in establishment of such a district to include
the Property.
7. Park Dedication Fees. SKB recognized the City of Rosemount's Park and
Recreation development program and the methods the City uses to fund this program by
collection of "Park Dedication Fees ". SKB also recognized the equivalent payment which
would be required to be paid if their Project would be required to go through a platting process.
Because the City could require this platting and a specific park dedication fee would be required,
although the City is not requiring that the Property be platted, SKB voluntarily made a non-
refundable payment of $85,000 in lieu of the park dedication fee. This was the amount of ten
(10) acres equivalent dedication or ten (10) times the current per acre value for this purpose.
(1989 value of $8,500 per acre = $85,000). The payment was made in five (5) equal annual
installments of $17,000 each. The first installment was due on the date the City issues a permit
for the Project and subsequent installments were due annually thereafter on the same day each
year for the next four (4) years. If SKB had decided to pay the fee in installments, it agreed to
furnish the City an irrevocable letter of credit to guarantee payment of the unpaid portion of the
fee. The bank issuing the letter of credit and the form of the letter of credit was approved by
the City. The City acknowledges that this condition has been met.
8. Option to Purchase. At such time as the storage cells are completed and closed,
and the Facility will no longer be accepting waste, the City will have an option for a period of 12
months immediately subsequent to closing of the last cell, to purchase that portion of the
Property not required for closure and maintenance of the Facility. Said option right will
terminate, if not exercised prior thereto, 12 months after closure of the last cell. The purchase
price will be an amount equal to 85 percent of the value of the Property being purchased, as said
value is determined by appraisal. SKB shall select one appraiser familiar with real estate values in
Dakota County and the City shall select one appraiser familiar with the real estate values in
Dakota County. The two appraisers shall select a third appraiser and the three appraisers shall
proceed to determine the fair market value of the Property. If the two appraisers selected by the
City and SKB are unable to agree to the third appraiser, they shall apply to the Chief Judge of
the District Court in Dakota County, Minnesota and the Chief Judge shall select the third
appraiser. Any valuation agreed upon by a majority of the appraisers shall be accepted as final
by both SKB and the City. Payment shall be in cash, at closing, unless otherwise agreed by the
parties with the Property being sold in an "as is" condition, free of all encumbrances and with
real estate taxes due in the year of closing pro -rated to date of closing. SKB shall provide to the
City an Abstract of Title or Registered Property Certificate, evidencing marketable tide, or tide
insurance from a title insurance company acceptable to the City. SKB shall have the right to
determine which acreage is not required for closure and maintenance and is therefore subject to
the terms of this option, which determination shall be made at the time of closure of the last cell.
Upon closure of the last cell, SKB shall notify the City in writing of this event, receipt of which
2
notice shall commence the 12 month option period. Notice of exercise of the option, during the
option term shall be in writing delivered to SKB. Closing shall be within 90 days of notice of
exercise of the option. The City may, during the term of the option, exercise same and purchase
the Property, but shall not be under any obligation to do so. If requested by the City, SKB will
execute and deliver to the City a real estate option in standard recordable form, setting forth the
terms of this option.
9. City Service Charge.
a. Basis for Charge. SKB recognizes certain aspects of the prior- approval
review, placement and operation of a Facility of the nature proposed in a residential /rural type
city has required and will further require the City to expend funds for the pre - approval review
and the ongoing monitoring of the operation of the Facility, the administration of the permit for
the Facility and interaction with SKB and state, county and federal agencies. The City may incur
other costs associated with the Facility and its impact on the City.
b. Base Service Charge. To offset those costs, SKB will, for each ton of
waste deposited into the Facility, pay the City a City Service Charge. The City Service Charge
that shall initially be imposed, commencing with the first day the Facility accepts waste, shall be
computed at the rate of $2.75 per ton for all industrial waste except municipal solid waste
(MSW) incinerator ash and $3.25 per ton for MSW incinerator ash, for each ton accepted and
disposed of in the Facility. Tonnage computation for the City Service Charge shall be the same
as for the Waste Generation Charge. This City Service Charge shall be subject to adjustment,
from time to time, and offset, as hereinafter provided. In addition, SKB will pay a City Service
Charge of $.85 per cubic yard of construction and demolition waste deposited in the Facility.
The $.85 City Service Charge shall be paid monthly on an estimated in place volume, and
verified and adjusted based upon a certified annual survey (the certified survey is a component
of the annual report required by the Minnesota Pollution Control Agency). Payments shall be
made monthly to the City at 2875 145 Street West, Rosemount, Minnesota 55068, or such
other location designated in writing by the City. Payment for each month shall be due by the
15` day of the following month.
c. Generator Charge Adjustment. At the present time, it is anticipated that
the initial per ton fee charged by SKB to waste generators ( "Waste Generator Charge ") will be
$75.00 per ton, and the City Service Charge payable to the City, is predicated on that anticipated
Waste Generator Charge. If the Waste Generator Charge is increased or decreased by SKB
(other than as a result of an increase in amounts due governmental entities after the Facility
commences operation, such as special taxes, permit fees, etc., which governmentally required
increases shall not impact the per ton charge due the City pursuant to this paragraph) then the
City Service Charge shall be adjusted prorate. Accordingly and by way of example, if there is a
ten (10) percent increase in the Waste Generator Charge (other than governmentally mandated)
then the City Service Charge shall likewise be increased by ten (10) percent. Adjustment based
on this subparagraph (c) shall be applied to the previously existing City Service Charge, before
the following adjustments or offsets.
d. Adjustment for Future Required, Legislatively Imposed, or Negotiated
Payments. If there are future required, negotiated or legislatively mandated payments due to the
City by SKB (other than as provided herein) the intent of which is to respond to impacts
3
resulting from the Facility, such payments shall be an offset against and a reduction of the
amounts due the City pursuant to this paragraph. Accordingly and by way of example if the
Minnesota Legislature or other governmental entity with authority to do so mandates that SKB
shall pay the City a tax, or other imposition, the amount of said tax or imposition shall reduce
the City Service Charge, dollar for dollar, due pursuant to this paragraph.
e. Consultant Offset. To assist the City in evaluating the Application of
SKB for necessary rezoning and permit issuance, the City has, and will hereafter retain outside
consultants (e.g. legal, environmental, etc.) to assist it. SKB has agreed to reimburse the City for
these outside consultant expenses, pursuant to a letter agreement dated in August 1989.
Pursuant to said letter agreement, SKB has deposited funds with the City and may hereafter
deposit additional funds with the City, to reimburse the City for outside consultant expenses. At
the time of City issuance of the last permit required by SKB to construct the Facility, the amount
of the outside consultant expense incurred by the City will be determined and will be paid by
SKB to the City unless these funds advanced by SKB to the City exceed said amount, in which
case said excess shall be returned to SKB. The total amount expended or incurred by the City
up to the time of issuance of the last permit (the "Consultant Offset" amount) will be an offset
against the City Service Charge due the City by SKB pursuant to the preceding provisions of this
paragraph. Said Consultant Offset amount will reduce the per ton City Service Charge at the
rate of 25 cents per ton, until the total Consultant Offset amount has been eliminated.
Accordingly and by way of example if the total consultant charge amount is $50,000, the amount
due by SKB to the City for the first 200,000 tons deposited in the Facility, determined in
accordance with the foregoing subparagraphs, shall be reduced by 25 cents per ton.
f. The City agrees that the funds provided pursuant to this paragraph will
not be used in any manner directly competitive to the business operations of SKB at the Facility.
Nothing in this provision shall be construed to limit the City of Rosemount's participation in
recycling efforts.
g. SKB will pay to the City the amount of $25,000 per year for 10 years
commencing on July 1, 2004, to be used by the City for landscaping and natural resource
projects.
h. Compost Operation Service Charge. To offset the City Service costs,
SKB will, for each ton of material used for compost production at the Facility, pay the City a
Compost Operation Service Charge. The Compost Operation Service Charge that shall initially
be imposed, commencing with the first day the Facility accepts material for the propose of
composting, shall be computed at the rate of $0.50 per ton of yard waste, source separated
compostable material, appropriate construction & demolition debris, sewage sludge, industrial
sludge, and /or any other material approved by the City and Dakota County to be used in the
composting process. The Compost Operation Service Charge shall be paid monthly on actual
tonnage delivered. Payments shall be made monthly to the City at 2875 145`'' Street West,
Rosemount, Minnesota 55068, or such other location designated in writing by the City. Payment
for each month shall be due by the 15` day of the following month.
i. Compost Operation Service Charge Adjustment. The Compost
Operation Service Charge is not subject to the Generator Charge Adjustment described in
Section 9.c. of this commitment. Beginning on January 1, 2012 and occurring annual on January
4
1 of each following year that composting is permitted at the facility, the Compost Operation
Service Change shall be adjusted annual at a rate of 5% inflation, rounded to the nearest cent.
The adjustment shall occur on all material delivered or recycled at the facility for composting on
or after January 1st of that year.
10. City of Rosemount — SKB Environmental Trust Fund.
a. Establishment. SKB in conjunction with the City will establish a Trust
Fund which shall be known as the "City of Rosemount — SKB Environmental Trust Fund ".
The Trust Fund will be administered by a board of trustees made up of five (5) persons, three
(3) of whom will be designated by the City and two (2) by SKB. SKB will make a payment of
$4.00 per ton (subject to adjustment as hereinafter provided) for each ton of waste accepted and
disposed of in the Facility during the years that the Facility is accepting waste to the Trust Fund
and to the City as hereinafter provided (the "Trust /City Payment "). Tonnage computation for
the Trust /City Payment shall be the same as for the Waste Generator Charge. Payments to the
Trust and the City shall be made monthly at such place designated in writing by City and the
Trustees. Payments for each month shall be due by the 15`" day of the following month.
b. Use. The principal and income of the Trust may only be used at the
determination of the trustees as set out in the Trust agreement. Detailed activity of the Trust
Fund shall be set forth on the Trust document, a copy of which is attached hereto as Exhibit B
and incorporated herein by reference. Payments made to the City may be used for any lawful
public purpose.
c. Adjustment Based on Waste Generator Charge. At the present time, it is
e" "
anticipated that the initial per ton fee charged to waste generators ("Waste Generator Charge")
p g g ( g)
will be $75.00 per ton, and the Trust /City Payment payable to the Trust and the City, is
predicated on that anticipated Waste Generator Charge. If the Waste Generator Charge is
increased or decreased by SKB (other than a result of an increase in amounts due governmental
entities after the Facility commences operation, such as permit fees, etc., which governmentally
required increases shall not impact the per ton charge due the City pursuant to this paragraph)
then the Trust /City Payment shall be adjusted pro -rata. Accordingly, and by way of example, if
there is a ten (10) percent increase in the Waste Generator Charge (other than governmentally
mandated) then the Trust /City Payment shall likewise be increased by ten (10) percent.
Adjustment based on this subparagraph (c) shall be applied to the previously existing Trust /City
Payment, before the following adjustments or offsets.
d. The City agrees that the funds provided pursuant to this paragraph will
not be used in any manner directly competitive to the business operations of SKB at the Facility.
Nothing in this provision shall be construed to limit the City of Rosemount's participation in
recycling efforts.
e. Prior to January 1, 2009, the Trust /City Payment shall be paid to the
Trust. On and after January 1, 2009, 50% of the Trust /City Payment shall be paid to the City
and 50% of the Trust /City Payment shall be paid to the Trust until payments to the Trust are
terminated as follows: Commencing on the first January first occurring after the value of the
Trust assets equals or exceeds One Million Five Hundred Thousand Dollars ($1,500,000) and
5
thereafter, payments of the Trust /City Payment to the Trust shall cease and 100% of the
Trust /City Payment shall be paid to the City. Payments made under this Section 10 to the Trust
fund before that date will be used by the trustees in accordance with the Trust Agreement.
£ After December 31, 2011, representatives of the City and SKB will meet
to consider whether the allocation of the Trust /City Payment continues to best meet the needs
of the community; however, the payment of the Trust /City Payments will not be changed
without the mutual consent of the City and SKB.
11. Miscellaneous.
a. The City will be given access to operating records of SKB for the
purpose of verifying the accuracy of the amounts reported to have been accepted at the Facility.
b. SKB agrees that any permit issued by the City for the Project may
incorporate the provisions of this Commitment.
c. SKB agrees not to sell, assign, or transfer its interest in the Facility or
Property without the prior consent of the City. It is further understood that the City may not
assign rights or obligations of the City hereunder without prior written consent of SKB.
d. SKB will continue to honor the commitment made in this Development
Commitment as long as the Project continues to operate in the City of Rosemount.
12. Summary. SKB feels it is in the best interest of the City as well as the region and
the state that a Facility be constructed consistent with "state of the art" technical knowledge to
accommodate non - hazardous industrial waste. The proposed Facility is a "state of the art"
project and will allow containment of said non - hazardous waste in a manner vastly superior to
the manner in which said wastes are presently being disposed of in Dakota County. Portions of
the Property have been designated by the Minnesota Pollution Control Agency as "intrinsically
suitable" for such a Facility. Thus, SKB agrees to use their best efforts to accomplish all
necessary steps to allow the construction and operation of the Facility for the good of all
persons concerned.
This Development Commitment is executed by SKB Environmental, Inc. this
day of , 2012.
SKB ENVIRONMENTAL, INC.
By
Its
6
Subject to the above provisions, the City will cooperate with SKB in the permit
application process and provide reasonable assistance to SKB in seeking all necessary approvals.
Accepted and agreed to this _ day of , 2012.
CITY OF ROSEMOUNT
By
Its
And By
Its
7
15117 3 . 1
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 -MN 55107
651 - 224 - 6329 • FAX 651 - 223 - 5053 Printed on Recycled Paper.
J
SKB Rosemount Industrial Solid Waste
Management Facility, SW -383
Application for Major Permit Modification
/NMI/
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
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 Facility 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 9
4.5 Salvageable /Recyclable 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
CeII 2 — Industrial Solid Waste: 17.1 acres
Cell 3 — Industrial Solid Waste: 39.3 acres
CeII 4 — MSW Combustor Ash: 12.3 acres
CeII 5 — Construction and Demolition Debris: 41.2 acres
Cell 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
lonp@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 dosed 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 dosed cell of the landfill. All cells of the landfill are lined 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
c compost has met
the appropriate tem erature and p p an 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 Toads 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 lined 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 J (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 J; 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. FI-.Il .1 !: \IiliA N I
INNER L iN'NER 1 INNER :1
I. 7 1 4 1 -..: 8 -1
■l)l' 11 It t l: 1 i '
I1kl':1 i INNER :I TUI'i \I11)D1.1'� LN\
1 , 5 \I(I \ t
i ER
3 1 5-
10 - INNER
I INNER 1 6 SANER ." `I 9
10 1 I
1)1 11 11 \121
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 II 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 loads 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 dosed. 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 load
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
i t s _
ENVIRON1rENTAL
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. ° P.O. Box 7216 St. Paul, MN 55107
651- 2.24 -6329 FAX 651- 223 - 5053 4_ . ' i„ac.; .,.„ >. 1 -_f; .>;,
A y y _ 7 ��``
-
i i Minnesota 3 oflu _tam Vi P';genc
f �
520 Lafayette Road North 1 St. Paul, Minnesota 55155 -4194 1 651 -296 -6300
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.
S incerely,
Craig Affeldt
Supervisor, Environmental Review Unit
St. Paul Office
Regional Division
CA:mbo
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: ( j
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 ntanagentent decision and I concur.
: ill: t . � - 1 Si �..- -- �•�
Signed:
V v U
Date: 3) Z6 /O c( Date: 3
Name Gordon Wegwart Name Leo Raudy
Title Assistant Commissioner Title REM t iv' io ' Director
Signed: .V f '/ Sipe•
Date: - 7 r
Date:
Name Art Dunn Name Larry . dh:
Title Director, OEA Title Solid Waste Program Lead, MPCA
Signed: ,'�__._ Signed: 1 MINIPA,,
�1
Date: 3 `31I Date:
Name David Thorntoh Name David Richfield
Title Section Manager Title Supervisor Land Policy Unit
Appendix D - Compost Area Drawings and Topographic Map
4
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Appendix E - Bucket Test
S
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
7
I 5,113 r i
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 M
PP p g e PCA 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 t 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 fist 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 6 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 MiII 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,
/7/4 / -P
Geoffrey D. Strack, P.E.
Environmental Engineer
Enclosures
cc: Eric Zweber, City of Rosemount
Dave Magnuson, Dakota County
Doc St. Clair, SKB Environmental
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Appendix G - 2011 Correspondence between Dakota County and SKB
8
.
C O U N T Y c„.4#0,' / -
Physical Development Division June 30, 2011
Lynn Thompson, Director
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
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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
1
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.lynn(cr�co.dakota.mn.us
1
1
ENVIRONMENTAL
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.
9 Starkav St • Pn Rnx 721F + St Paid MN cc,1f17
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
landfilling. 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 d e t erm i ne d b the D 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 lined 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 lined 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 Toads of waste materials. This
includes directing incoming loads 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
Geoffrey@'skbinc.com or telephone at 651- 251 -6203.
Sincerely,
�,..j , f 1 ) < �
I
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 1 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.magnuson
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.maqnuson an co.dakota.mn.us
From: Lynn, Michael
Sent: Wednesday, July 20, 2011 3:08 PM
To: Magnuson, Dave
Cc: 'P. E. Geoffrey D. Strack (GeoffreyPskbinc.com)'; 'Eric Zweber ( eric .zweberCc�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.maonuson anco.dakota.mn.us
From: Geoffrey Strack [maiito: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
' ‘ta°444111‘
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.
952.891.7000 251 Starkey Street
Fax 952.891.7031 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 County Environmental Management Department (Department) Transit Office Y g 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
L_9
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
ENVIRONMENTAL
April 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 ton
g y s /cubic and and using ng 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. In that pile, one could store 7,982 cubic yards of compost. Using a 0.5
tons cubic and unit / y n t 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
651 - 224 -6329 • FAX 651- 223 -5053 Printed on Recycled Paper.
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
I
1
1
e
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
L1 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
EJYVJRONMENTAL
June7,2011
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.
• 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 1 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 Geoffrev@skbinc.com.
Sincerely,
/ / f
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
/ 1
Load Tip
Inspection Load
Construct
Pile
i
Bulking
Agent
(wood, leaves)
a Odor Management
(Compost Cover)
Actively
Aerated
Pile 55 C 7days
Turn
Pile
Curing
Pile
(Passive
Aeration)
•
Landfill i
Rejects
Finish
Pile a
Class I 40*
Blend
Compost to 4 Use on Site
achieve
Class II
Class I
i
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
nra nz�_I _,, - C'1 n,...l n del CC-107
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 GeoffreyPskbinc.com or 651-
251 -6203.
Sincerely,
0 4'4> 4..,,,---____
Geoffrey D. Strack, P.E.
Environmental Engineer
Enclosure
cc: Dave Magnuson, Dakota County
Bob Criswell, MPCA
Doc St. Clair, SKB
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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
Equipment /Systems 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 nation& 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 Sieges waste, the location of waste management facilities and national initiatives on waste IIILLut
Council management are increasingly controversial, partly because of potential wildlife related Cat VI; Aft*.
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.
For example, traditional putrescible waste landfills often attract large numbers of gulls and BACKHLS
other bird species that can pose a significant risk to air traffic, if the facility is located near rtiarsh Ar:.rs
an airport. In response to the concern over bird- aircraft collisions, the Federal Aviation
Administration (FM) 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 ;l -% t ti 7 u�
used by piston powered aircraft or within two miles of runways used by turbine - powered smut& sciucxsi:xio.
aircraft.
Order 5200.5A also recommends against locating any waste management facility within two - ' - ' '
to five miles of an airport if the facility "attracts or sustains hazardous bird movements from ROTO r
feeding, water or roosting areas into, or across the runways and /or approach and departure
patterns of aircraft." In August 2007, the FM published Advisory Circular No: 150/5200 -
33B, Hazardous wildlife attractants on or near airports, which includes the recommendations fy+��{ A �
from Order 5200.5A. SCARAB'
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 t
at these facilities can enhance survival and productivity of problem bird species that adapt _ ____ __ A_ _
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 *
considered a nuisance and economic liability because they damage roofs, attack pedestrians Vermeer .
and defecate on cars and buildings. Further, feathers, nest material and food remains can t.IiYiiE
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
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 Iivia],
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 V c,,tor Control :: BioCycle, Advancing Con.posting, 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 on site indicated that the material did not serve as a significant
Food Scraps Composting And V tor Control :: BioCycle, Advancing Co11 posting, 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.
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Copyright & Trademark Notice
EJY J OIYI EIV AL
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 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,
Nitt
John Domke
Vice President
EXCERPT OF DRAFT MINUTES
PLANNING COMMISSION REGULAR MEETING
APRIL 24, 2012
6.a. SKB Environmental Request for Zoning Ordinance Text Amendment and Interim Use Permit to
Allow Composting (12 - 06 - IUP, 12 07 - TA). 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. Senior Planner
Zweber reviewed the staff report.
The public hearing was opened at 7:23p.m.
Frank Knoll, 4322 145` Street East, expressed his frustration with SKB in the beginning telling
residents that the landfill would not be visible and now there exists a mound. He is further frustrated
with SKB expanding with a composting site and he wonders what will be next. Mr. Knoll stated the
City does not need another compost site.
Myron Napper, 3381 145 Street East, stated that SKB discussed doing this about three years ago but
proposed enclosing the area. He stated there has been about 3 -4 compost sites in the city over the
years. If the site will be enclosed and varmit proof, Mr. Napper stated he does not have a problem
with the operation.
Rick O'Gara, SKB Environmental, approached the Commission and addressed the concerns of the
residents. He explained that compost is made up of leaves, grass and brush that will be ground up and
will also include some organic waste such as tomatoes and lettuce from restaurants, hospitals, and
schools. He further stated it will contain some organic sludges that are highly fibrous and do not
contain contaminants. Mr. O'Gara stated that the landfill and his operation at Bolander & Sons would
use the topsoil created by the compost, but SKB will not sell it to the public. He stated that the
operation Mr. Napper mentioned was a project to recycle MSW and SKB has since reconsidered
taking on that project. With respect to the varmit and vector issue, SKB has agreed to have a study
done and submit it to the City and County for review.
Chairperson Powell asked about the previous request to make testing reports and information
available to the public. Mr. O'Gara stated that SKB agreed to perform tests three times a year and
they will inform concerned neighbors when the studies are available to view.
Commissioner DiNella asked if the landfills with composting have methane gas. Mr. O'Gara replied
that the composting will all be above ground and never buried which is what creates methane gas.
Frank Knoll, 4322 145 Street East, approached the Commission again and asked how much odor
there will be from the site. Mr. O'Gara replied that SKB has experience operating compost site in
different locations and they have never had a violation. He stated that if you process the compost
correctly, there will be no smell, and SKB plans on operating correctly.
There were no further public comments.
MOTION by Irving to close the public hearing.
Second by Ege.
Ayes: 7. Nays: None. Motion approved. Public hearing was closed at 7:37p.m.
Mr. Zweber stated in response to the public comments that all of the times that SKB requested
expansion of the landfill were approved through a public hearing. He further stated that what Mr.
Napper was referring to was a few years ago, the City approved a request by SKB to construct a
recycling building that would allow MSW in an interim use permit. SKB has not constructed the
building yet but it does allow MSW. Mr. Zweber stated he was not aware of any other composting
sites within Rosemount, and in fact, the property owned by SKB would be the only location in
Rosemount zoned WM — Waste Management and therefore the only location that composting would
be permitted if this text amendment is approved.
MOTION by Miller 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.
Second by Ege.
Ayes: 7. Nays: None. Motion approved.
MOTION by Miller to Recommend that the City Council Amend the Interim Use Permit
for SKB Environmental to Allow Composting with the following ten (10) conditions, editing
Condition #2 to specify "residential" soil reference values:
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 Residential 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.
Second by Ege.
Ayes: 7. Nays: None. Motion approved.