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5.a. Request by SKB Environmental for an IUP Including an Expansion to their Landfill
4ROSEMOUNT PLANNING COMMISSION Planning Commission Meeting Dates: Tentative City Council Meeting Date: EXECUTIVE SUMMARY August 27 and September 10, 2013 October 1, 2013 AGENDA ITEM: Case 13- 16 -EAW and 13- 17 -IUP; Request by SKB Environmental, Inc. for an Interim AGENDA SECTION: Use Permit Including an Expansion to their Public Hearing Landfill which would Fill Wetlands PREPARED BY: Eric Zweber, Senior Planner AGENDA NO. �� a ATTACHMENTS: Location Map; Interim Use Permit; Environmental Assessment Worksheet; APPROVED BY: Wetland Replacement Plan; Email from Jon Penheiter describing SKB Permit Revisions; Permit Renewal Application; Permit Figures; Permit Engineering Report; Waste I Acceptance Plan; City Engineer's Memorandum RECOMMENDED ACTION: Motion to Recommend that the City Council Approve the Interim Use Permit, Environmental Assessment, and Wetland Replacement Plan to Allow SKB Environmental, Inc. to Expand their Landfill by 8,475,814 Cubic Yards, subject to the following Conditions: 1. Any MSW brought to the recycling and transfer facility shall be stored indoors during the entire time that it is on site. 2. A vermin control plan for the composting site and the recycling and transfer facility shall be prepared and approved by City staff that may include the plan being prepared by a pest and vermin control professional and periodic inspections of the facility by a pest or vermin control professional. 3. The recycling and transfer facility shall be constructed of 100% masonry for any side facing the boundary of the facility and 40% masonry for the remaining sides. 4. Stormwater Basins 6A, 613, 6C and associated grading shall be removed from within 50 feet of the 140th Street East centerline. 5. A replacement plan for groundwater monitoring wells U -2S, U -2D, U -6D, U -7S, and U -7D that has been approved by the Minnesota Pollution Control Agency shall be submitted to the City. 6. Petroleum Contaminated Soil shall not be used in the composting operation. 7. 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). 8. The Industrial Waste deposited in the saddle area of Cell 3F /5D shall not exceed the contamination limits set in the Dakota County Solid Waste Ordinance Variance. 9. City Engineer's Memorandum dated August 21, 2013. ISSUE SKB Environmental, Inc. (SKB) is requesting a revision to their Interim Use Permit (IUP) to allow an expansion to their facility at 13425 Courthouse Boulevard from 151 acres of disposal area to 167 acres of disposal area. The proposal includes an expansion in total disposal volume from almost 27 million cubic yards to a little more than 35 million cubic yards, representing a 32% increase in volume. The increased volume is accomplished by expanding the footprint of the landfill by 16 acres and an increase in the finished height of the landfill by 50 feet. Increasing the footprint of the landfill will require filling 9.19 acres of wetlands. SKB had agreed to process an Environmental Assessment Worksheet (EAW) for review of their proposed expansion including the filling of the 9.19 acres of wetlands. The responses received regarding the EAW are attached to this Executive Summary. The agency comments received are addressed within the recommended conditions of approval and are discussed in more detail below. BACKGROUND In 1992, Union Pacific Railroad ( USPCI) was approved to construct and operate an industrial solid waste land disposal facility (landfill). The landfill was designed with ten containment cells with a total capacity of 2,520,000 cubic yards. In 1995, USPCI sold the landfill to Laidlaw, Inc. and in 1998 Laidlaw combined with Safety Kleen Corporation. In 1997, municipal solid waste (MSW) ash from the Hennepin County incinerator was permitted to be accepted at the landfill. In 2000, SKB purchased the landfill from Safety Kleen. At that time, the landfill was permitted to accept industrial waste and MSW ash with a total landfill capacity of 6,037,983 cubic yards covering approximately 70 acres of area with a permitted finish grade to the 930 foot elevation (100 feet measured from 140`h Street East). In 2003, SKB requested and was approved for an expansion of their facility to add construction and demolition debris to their approved fill material and an additional 9,320,608 cubic yards of waste (154% increase) for a total permitted capacity of 15,358,591 cubic yards of waste. The approved expansion permitted a total disposal area of 112 acres (60% increase) and finish grade to the 970 foot elevation (40% increase). In 2008, SKB requested and was approved to increase the disposal capacity by 11,515,512 cubic yards (75% increase) to a total capacity of 26,874,103 cubic yards. The expansion will also increase the permitted disposal area to 151 acres (35% increase) and a finish grade of 1,010 foot elevation (29% increase). The approved finish elevation is about 40 feet taller than the power lines on the site. In 2012, SKB requested and was approved to accept source separated compostable material and process that material with yard waste into compost. Earlier in 2013, SKB requested and was approved to deposit low level industrial waste in their construction & demolition debris landfill cell. Currently, SKB is requesting to increase the disposal capacity of the landfill by 8,475,814 cubic yards (32% increase) to a total capacity of 35,349,917 cubic yards. The expansion will also increase the permitted disposal area to 167.1 acres (11% increase) and a finish grade of 1,060 foot elevation (28% increase). The approved finish elevation is about 90 feet taller than the power lines on the site and 130 feet taller than the approved finish grade when they bought the site in 2000. 2 Surrounding Land Uses: North: General Industrial (Spectro Alloys and Endres) East: Agriculture South: Agriculture West: Public /Institutional (Rosemount Wastewater Treatment Plant) and Agriculture Planned Land Uses: North: General Industrial East: Light Industrial South: Light Industrial West: Public/ Institutional and General Industrial Existing Zoning District: VIM: Waste Management Site Area: 236 Acres Approved Disposal Area: 151 Acres Proposed Disposal Area: 167.1 Acres Approved Disposal Capacity: 26,874,103 Cubic Yards Proposed Disposal Capacity: 35,349,917 Cubic Yards Approved Height: 1010 foot elevation (180 feet, measured from 140t' Street East) Proposed Height: 1060 foot elevation (230 feet, measured from 140`" Street East) SUMMARY Landfill Configuration The SKB landfill proposal is divided into six (6) different cells that accept three (3) different types of waste. Cells 1, 2, 3, and 6 are designed to accept industrial waste. Cells 1, 2, and 3 have a double liner. Cells 1, 2, and 3 are approved as designed while Cell 6 will be expanded by 16 acres based upon the 2008 approval. Additionally, SKB is proposing a different liner construction for Cell 6 from the double liner constructed in Cells 1, 2, and 3. The PCA and Dakota County will be reviewing and approving cell liner construction. Dakota County staff has indicated that they would not recommend approval of a liner design that is less protective than the existing double liner design. Cell 3 contains a sub -cell (Cell 3M) that contains industrial waste containing PFCs from the 3M landfill clean up in Washington County. The Cell 3M was approved by Dakota County and the Minnesota Pollution Control Agency (MPCA) with its own liner and leachate collection system. The leachate collected from Cell 3M is transported to the 3M Chemlite incinerator in Cottage Grove and burned. Cell 3M is now closed and being covered with traditional industrial waste. Cell 4 is designed to accept mixed municipal waste (MSW) ash from the Hennepin Energy Recovery Center (HERC) MSW incinerator in Minneapolis. The liner for Cell 4 is identical to that installed in Cells 1, 2, and 3. The operation of Cell 4 is similar to Cells 1, 2, and 3 other than that SKB is removing and recycling metals from the MSW ash. Cell 5 is designed to accept construction & demolition (C &D) debris. Cell 5 has a single liner unlike the industrial waste and MSW ash cells that have a double liner. Earlier this year, SKB received approval from the City and Dakota County to deposit industrial waste in Cell 5 that is no more than 25% of the hazardous waste level for the specific material. The MPCA allows industrial waste to be deposited into C &D cell provided that the industrial waste does not exceed 50% of the total cell volume. SKB has proposed one change to their vertical configuration. The area between Cell 3 and Cell 5 (referred to as a "saddle ") was approved in 2008 to accept C &D waste. SKB proposes within the 2013 application that there is an imaginary vertical line between Cells 3 and 5 and industrial waste is placed on the Cell 3 side of the line and C &D and low level industrial waste on the Cell 5 side of this line. SKB's rationale is that the 3 industrial waste leachate will drain straight down into the Cell 3 collection system and the C &D leachate will drain straight down into the Cell 5 collection system. City and Dakota County staff have some concerns about this design because appropriate implementation would require identical amounts of industrial and C &D waste to be accepted and deposited at the same rate and a concern that leachate may not drain straight down. Leachate would more likely flow to the area of more permeability (i.e. less compacted) which is normally the C &D waste. Dakota County staff stated that they are unlikely to approve this design without significant modeling and proof that this design will not allow industrial waste leachate to flow toward the single liner Cell 5 leachate collection system. Additional information from SKB was requested. The City will be looking to the County for their opinions on this issue after additional modeling information is made available. Horizontal Proposed Expansion /Wetland FiUing To facilitate the 39 acre expansion, SKB is proposing to develop the southwestern corner of their property. The area is currently occupied by high tension power lines, a pipeline that leads to the Flint Hills Refinery, and two wetlands. There are a number of trees on the site previously approved for removal in the 2008. Tree replacement requirements are carried forward within this IUP conditions. To construct their landfill Cell 6, SKB is proposing to move the power lines to the south of their expansion, move the pipeline to the south side of 140`" Street East within an existing pipeline easement, and fill both wetlands. There are three wetlands located on the site, the first (Wetland A) is 0.33 acres, the second (Wetland B) is 9.49 acres, and a third wetland, to the north of the second, that is approximately 0.5 acres in size. In the 2008 IUP, SKB had received approval to fill the third wetland and the north 0.3 acres of Wetland B and required wetland mitigation for the 2008 approval has been fulfilled. With this 2013 IUP request, the applicant is proposing to fill the remaining two wetlands for a total of 9.49 acres. As part of the City process to review and permit wetland impacts, the City administers wetland permits in accordance with the Wetland Conservation Act (WCA) rules. The WCA rules stipulate the completion of a sequencing process to evaluate options associated with the proposed impacts. The sequencing process requires as a first step the evaluation of the feasibility of developing a project without impact to the wetland, or "avoid ". If it is determined that complete avoidance of wetland impacts is not feasible, the sequencing process then requires the evaluation of options to minimize to the greatest extent possible the impact to the wetland. This step includes a review of the proposed project and consideration of feasible modifications to the plan to minimize wetland impacts. The WCA requires that a technical evaluation panel (TEP) of environmental and water resource experts from neighboring agencies, such as the watershed management organizations, soil and water conservation districts, Department of Natural Resources (DNR), Board of Soil and Water Resources (BWSR), assemble and evaluate the proposed wetland impacts. The TEP provides technical comments and recommendations to the City for consideration when evaluating project impacts. The TEP panel will convene before the City Council could approve the WCA permit. The City of Rosemount does not have a lot of wetlands, primarily due to its sandy soils. For this reason the City updated the Comprehensive Wetland Management Plan (CWMP) in December 2005. This update included the development of wetland management and protection goals and strategies. The attached table IX -I highlights the wetland management class and strategy. In the city's wetland management plan, both wetlands proposed to be filled are classified as Manage I, the second highest classification behind the 0 highest Preserve classification, which means it is more desirable from a floral diversity, water quality, and wildlife habitat standpoint. In the City's adopted wetland management plan the Management Strategy for Manage I is "sequencing is applicable ". Sequencing is the process to determine how the wetland mitigation is to be fulfilled. The four steps sequencing within the City's plan is: 1. Avoid impact /filling the wetland. 2. Mitigate for the impact on the proposed site. 3. Mitigate through wetland creation or wetland credit purchase within the City. 4. Mitigate through wetland credit purchase outside the City. Each step of the sequencing must be evaluated before next step can be considered. If SKB were to avoid filling the wetlands while expanding their landfill, adjacent property to the landfill would need to be purchased, receive a Comprehensive Plan amendment to increase the amount of land within Rosemount allowed for waste management, and rezone the newly purchased property to WM- Waste Management. In other words, there isn't any other available land owned by the applicant which is zoned and guided for waste management except for the area currently designated for landfill expansion. Staff is opposed to expanding the amount of area planned for waste management and the 2030 Comprehensive Plan states that "(i)t is the public interest to explore all available options of waste management before expanding the waste management district for additional landfilling ". Therefore, staff is supportive of maximizing the landfilling on the property owned by SKB and planned for waste management and recommends evaluating the third sequencing step. To determine an appropriate area for mitigation within the City, City staff, our engineering consultant WSB, SKB, and their consultant Wenck evaluated a variety of sites within Rosemount that appeared more likely suitable for wetland creation. Following that evaluation, SKB contacted five different landowners about purchasing land or easements to create a wetland. Only one of the five landowners was interested in selling their property, the 54 acre property currently for sale on the northwest corner of South Robert Trail and McAndrews Road. Wenck performed a wetland delination of the property and a soil evaluation for the suitability of wetland creation. The property has three wetlands and a lake. The northern two wetlands have an elevation of about 950 feet, the southern wetland has an elevation of 938 feet, and the lake on the far west side of the property has an elevation of about 930 feet. Wenck determined that the wetlands were groundwater fed and any new wetland would need to depend on groundwater for hydrology. Wenck conducted five soil borings (one near the southern wetland and four near the northern wetlands) to determine soil composition and groundwater level. The southern soil boring determined soil with some clay and groundwater within one vertical foot of the wetland, but this site would likely produce less than ' /z acre of new wetland. The four borings near the northern wetlands had mixed results. The middle boring of the four showed soil with some loam and groundwater about six inches below the wetland. The eastern boring showed clay in the soil but the groundwater was about 2.5 feet below the wetland and the clay soils. The western two borings showed sandy soil with some loam but groundwater about 2 and 3 feet below the wetlands respectively. Wenck concluded that this site is not suitable to construct wetlands. Wenck's analysis was reviewed by Andi Moffatt and Jeff Broberg of WSB. Mr. Broberg is a soil scientist with approximately 25 years of experience. Ms. Moffatt and Mr. Broberg both concurred with Wenck's conclusion. Mr. Broberg stated that the hill between the wetlands is likely a glacial deposit of sand and gravel between the two glacial ice chunks that produced the wetlands. Mr. Broberg believes that removing 5 the hill between the two wetlands could create a conduit that would drain the northern wetland into the southern wetland that is about 12 feet lower. Also, lining the new wetland with a clay bottom would be unproductive because it would prevent the groundwater from providing the hydrology necessary to sustain a wetland. Based on this analysis, staff does not recommend constructing wetland mitigation at this site and supports SKB submitting a wetland replacement plan using the fourth sequencing step: purchasing wetland credits from outside the City. Wetland Mitigation SKB has submitted a wetland replacement plan that mitigates the 9.49 acres of wetland being filled by purchasing 18.98 acres of existing wetland credits. SKB is proposing to purchase 17.84 acres of wetland credits from the Bachman Wetland Bank in Eureka Township adjacent to the Vermillion River. Unfortunately, this is the 17.84 acres is all that remain in the Bachman wetland bank. Following that purchase, the only remaining wetland credits in the Vermillion River watershed are owned by the Goodhue County Transportation Department. Goodhue County has these credits to accommodate future wetland impact for road construction project and they are not interested in selling their credits. The remaining 1.14 acres of wetland credit are proposed to be purchased from Wetland Bank No. 1475 in Jackson County. Staff is supportive of this wetland replacement plan and will conduct a TEP panel before City Council action on the WCA permit. Vertical Expansion The landfill that was originally proposed by USPCI had a finish elevation of the 930 feet, which is approximately 100 feet above 140`h Street East. The original design had ten individual cells that were all pyramid shaped that ended at the 930 foot elevation. When SKB purchased the landfill, some expansion had been approved although the permitted height had remained at the 930 foot. In 2003, SKB received an expansion to the landfill to include filling the areas between the berms and trapezoids (these areas are referred to as saddles) as well as building a new cell to the southeast for construction and demolition debris. The result of this expansion was a final grading plan that was roughly pyramidal in shape with a finish elevation of 970 feet, a 40 foot increase in height. To soften the aesthetic appearance of the finished landfill, the final grade included undulation to have ridges, valleys, and trees planted on the sides of the landfill. Shortly after the 2003 approval, SKB requested and received a modification to the finished grade to remove the undulation and the trees in exchange for a payment to the City to plant trees in other locations within the City. The currently approved finish grade is a pyramid with even sides that has a maximum height of 970 feet, which is approximately 140 feet above 140`h Street East and approximately equal to the height of the existing power lines on the south side of the site. In 2008, SKB received an expansion to the landfill that increased the height to the 1,010 foot elevation. That approval will result in a berm 180 feet higher than 140`h Street East. This is also be 40 feet taller than the existing power lines and 80 feet taller (2.6 times) than the landfill that was permitted for when SKB purchased the landfill in 2000. Some of the increase in height is due to a change in the shape of the landfill. Instead of a pyramid with the peak in the center of the landfill that slopes equally in all directions, the proposed landfill creates a ridge 180 feet tall along 140`h Street East that slopes over the entire landfill to the north. This design is significantly taller than a pyramid design where the tallest part of the landfill would be at the center. D With their current request, SKB is proposing an expansion to the landfill that increased the height to the 1,060 foot elevation. The current request will result in a berm 230 feet higher than 140`h Street East. This will also be 90 feet taller than the existing power lines and 130 feet taller (3.6 times) than the landfill that was permitted for when SKB purchased the landfill in 2000. The proposed landfill creates a ridge 230 feet tall along 140`'' Street East that slopes over the entire landfill to the north. This design is significantly taller than a pyramid design in 2003 where the tallest part of the landfill would be at the center. There will continue to be some vegetation installed along the berm adjacent to the landfill which will mitigate some of the height. However due to the construction methods for landfills, no significant vegetation can be installed along the closed cells. Distance from County Road 42 will also mitigate some of the effects of the land height. However, it will be, upon finishing, a very imposing land structure. Grading /Future 14e Street The grading plan proposes stormwater basins 6A, 613, 6C and associated grading within a 17 foot wide area identified as needed on the north side of 140`h Street East for future street expansion. 140``' Street is designated as a collector road, which would require 100 feet of total right of way or 50 feet of half right -of- way north of the street centerline. The current right -of -way has 33 feet north of the street centerline resulting in the 17 feet of additional right -of -way needed on the north side of 140`h Street East. This was also an issue in the initial 2008 expansion application and those plans were revised to remove all grading and infrastructure from the 17 feet of additional right -of -way. Similarly, staff has recommended that the 2013 plans be revised to remove stormwater basins 6A, 613, 6C and associated grading from the 17 feet north of the existing 140`' street right -of -way. The applicant is exploring a variety of options, with the final decision most likely occurring after the Planning Commission meeting. However, final resolution must occur prior to the City Council taking final action. Until an acceptable solution is determined the recommended condition of approval requires compliance with the City Engineering memo which requires removal of activity and infrastructure within the future right of way. Environmental Assessment Worksheet SKB had volunteered to conduct an Environmental Assessment Worksheet (EAW) in which the City of Rosemount was the responsible unit of government (RGU). SKB had preformed a voluntary EAW during their 2003 expansion with the Minnesota Pollution Control Administration (PCA) serving as the RGU. In 2008, SKB has volunteered to conduct an EAW in which the City of Rosemount was the responsible unit of government (RGU). An EAW is an environmental review process in which the impacts to the environment, transportation, and land use from the proposed landfill expansion are described and distributed to all agencies that have pertinent regulations, including Dakota County, the Department of Natural Resources (DNR), the Metropolitan (Met) Council and the PCA. The agencies have 30 days to submit their responses and concerns regarding the proposed expansion, following which, the City works with SKB to provide revisions to the proposal or responses to the agencies' concerns. After reviewing the results of the EAW, the City determines if all the issues within the EAW are addressed or if an Environmental Impact Statement (EIS) needed. An EIS provides additional and more detailed environmental review for issues that are not resolved in the EAW. If the City deems that the EAW is sufficient and an EIS is not needed, the City can review and either approve or deny the IUP for the expansion. 7 The City received comments from Dakota County, the DNR, the Metropolitan Council and the PCA. Dakota County's letter expresses concern about the 140`'' Street East (Ehlers Path) right -of -way for a regional greenway, mitigation of the existing wetland, and various technical issues regarding landfills. The City shares the concern regarding the right -of -way and the wetland as was discussed in the previous sections of this Executive Summary. Dakota County has a Solid Waste Ordinance and SKB will need to receive a license from Dakota County that will address their technical issues. The DNR comments regard the presence of loggerhead shrikes and requests the use of wildlife - friendly erosion control methods. SKB will need to contact the DNR and conduct nest searches for any grading performed during breeding season. The Met Council raised issues regarding the wetland and surrounding ecology, the regional greenway, and their wastewater system. The Met Council staff states that the wetlands on site are Preserve, which is incorrect. The wetland delineation and analysis performed this year determined that the two wetlands are classified as Manage 1 wetlands, a lower classification than the Preserve status stated in the Met Council letter. As described in the wetland section of the Memorandum above, SKB will be purchasing existing wetland bank credits to mitigation for the wetland impacts caused by the landfill expansion. The regional greenway issue is identical to the Dakota County concern raised above and the staff recommendation to remove the stormwater basins and associated grading from the 17 feet directly north of 140'h Street East. SKB works with the Met Council on sanitary sewer issues due to their effluent and there are no proposed modifications to the northeast where the Empire wastewater treatment plant effluent line is located. The PCA provided comments regarding the permit process, stormwater, effluent, geology, odors and dust. Most of the comments are informational regarding the permits that SKB needs to receive from the PCA or points out minor errors. SKB has applied for a ten year permit from the PCA and City staff is meeting with the PCA and Dakota County staff on Friday, September 6 to discuss the technical elements of the application. All issued raised by the PCA will be addressed during their permit approval process. Recycling /Transfer Facility During the 2003 expansion, SKB had received approval within the IUP to construct a recycling /transfer facility on the site. The facility does not exist today, but SKB is requesting that the approval remain in the 2013 IUP. In reviewing the IUP submittal, staff believes there are additional conditions that shall be required of the facility. The recycling facility will allow a number of waste products to be brought into the site that have value. These recycling products will be removed from the waste and the remaining wastes disposed of. The waste products to be recycled include waste approved to be disposed within the landfill, such as construction and demolition waste, industrial waste, and ash. The waste products to be recycled also include waste that cannot be disposed of on site, such as mixed municipal waste (MSW). MSW is a different waste product than the others because it includes food wastes that can attract rats, insects, birds, or other vermin that the other waste products do not attract. To address the vermin attraction issue, staff requests two additional conditions be placed on the IUP. First, any MSW brought to the facility shall be stored indoors during the entire time that it is on site. Second, that a vermin control plan is prepared and approved by City staff that may include the plan being prepared by a pest and vermin control professional and periodic inspections of the facility be a pest or vermin control professional. E:3 The second issue regards the building material used in the facility. SKB has proposed that the facility would be constructed of metal. In 2006, the City had revised its GI — General Industrial standards to require that the side(s) of a building that face the public right -of -way shall be constructed completely of masonry and that the remaining sides of the building be constructed of 40% masonry. Since SKB is surrounding by lands that are designated either for general or light industrial uses, staff recommends that the same GI — General Industrial apply to the SKB facility. Since staff does not know the future layout of street on the adjacent properties, staff recommends that the recycling /transfer facility is construct of 100% masonry for any side facing the boundary of the facility, and 40% masonry for the remaining sides. Source Separated Compostable Material Composting Site On June 5, 2012, the City Council approved a modification to the SKB IUP to allow composting of source separated compostable material, which is material removed from the MSW waste stream. To date, SKB has not begun composting but SKB is requesting the ability to compost source separated compostable material within the 2013 -2018 IUP. The request within the IUP waste acceptance plan is different from the 2012 approval. First, SKB is requesting to use petroleum contaminated soil in the compost. During the 2012 discussion, Dakota County rejected the use of petroleum contaminated soil in compost. Second, then- Commissioner Demuth added a condition that the sewage sludge used in the compost must not exceed EPA levels for PFCs. Staff has proposed conditions within the approval of this IUP to prohibit petroleum contaminated soils and to limit PFCs level to the EPA standard. Staff is also recommending that a vermin control plan is required for the composting site the same as is recommended at the transfer facility. RECOMMENDATION Staff recommends that the Planning Commission recommend approval of the Interim Use Permit, Environmental Assessment Worksheet, and Wetland Replacement Plan to SKB to expand their landfill with the conditions provided in the motion. D SKB Landfill Disclaimer: Map and parcel data are believed to be accurate, but accuracy is not guaranteed. This is not Map Scale a legal document and should not be substituted for a title search,appraisal, survey, or for zoning 1 inch = 2001 feet verification. Dakota County assumes no legal responsibility for the information contained in this data. 9/4/2013 INTERIM USE PERMIT AGREEMENT REISSUANCE to SKB, INC. MINNESOTA INDUSTRIAL CONTAINMENT FACILITY THIS AGREEMENT, is made this day of , 2013 by and between SKB Environmental Inc. (hereinafter "SKB ") and the City of Rosemount, a Minnesota municipal corporation (hereinafter the "City "). 1. Interim Use Permit. SKB assumed the obligations of an Interim Use Permit (IUP) originally granted by the City on March 19, 1992 (Resolution 2000 -29) for the construction, operation, and maintenance of the Minnesota Industrial Containment Facility (MICF). The execution of this Agreement by the parties shall constitute approval and reissuance of the IUP by the City subject to the provision of this Agreement. This Agreement constitutes the reissued IUP, as amended. Compliance with Minnesota Pollution Control Agency Permit No. SW -383, dated March 2013 (MPCA Permit) as renewed and amended, and Dakota County Solid Waste License associated with SW -383 (DC License) as renewed and amended, which are incorporated herein by reference, and conformance with the application of SKB to the City as amended by the plan for finished design approved by the MPCA and Dakota County, are conditions of the IUP. This IUP is issued by the City in accordance with Ordinance B, City of Rosemount Zoning Ordinance, adopted September 19,1996, as amended, including Section 11.3. 2. Term. The MICF Permit Renewal Application for Permit No. 393 Minnesota Industrial Containment Facility, prepared by Conestoga Rovers and Associates, dated April 2013, (the "MICF Permit Application ") and revised plan sheets dated March, 2013 in response to the Planning Commission review, details the revised design, construction, operation, closure, corrective actions, and revisions thereto, and financial assurances for a six cell non- hazardous industrial waste containment and construction and demolition facility, with an anticipated operating life of forty (40) years. Construction, operation, and closure of the individual cells will be phased throughout the operating life of the facility. Consistent with the term of MPCA Permit and the provisions of Ordinance B, this IUP is valid for five years from the effective date of this agreement, or until terminated or amended by the City. Prior to expiration of the IUP, or to apply for an amended IUP, SKB shall request that the City review and reissue the IUP. To avoid possible termination of the IUP at the time the IUP expires, an application for reissuance of the permit must be submitted no later than 180 calendar days before the expiration date of the permit. The reissuance of the IUP may, at the option of the City, be approved without modification to this Agreement, or the City may require SKB to modify this Agreement. 3. MICF Description. MICF is located on property legally described on attached Exhibit A. The 236 -acre site is located between TH55 and 140th Street East, lying easterly of the Chicago and Northwestern Railroad. The location of MICF is illustrated on attached Exhibit B. MICF consists of six (6) containment cells, each occupying a surface area and waste volume capacity as follows: (a) Cell 1 contains 5.1 acres and 341,454 cubic yards; (b) Cell 2 contains 17.1 acres and 1,458,507 cubic yards; (c) Cell 3 contains 39.4 acres and 10,592,188 cubic yards; and (d) Cell 3M contains 158,300 cubic yards; and (e) Cell 4 contains 12.5 acres and 2,648,950 cubic yards; and (f) Cell 5 contains 41.2 acres and 7,490,591 cubic yards; and (g) Cell 6 contains 51.8 acres and 12,659,927 cubic yards. The anticipated operating life of MICF is (40) years based on a total capacity of 35,191,617 cubic yards. The facility also consists of an office /laboratory building, a container management building, rail and truck unloading facilities, leachate storage tanks and on -site stormwater retention areas. The general site plan is illustrated on attached Exhibit C. 2 This Agreement allows for the construction and maintenance of all the roadways, railways, buildings, leachate storage tanks, stormwater retention structures, sanitary sewer, berming, landscaping, and other ancillary components of MICE Such construction and maintenance is subject to the provisions of this Agreement, compliance with City ordinances and issuance of necessary permits. Subject to the provisions of Section 14, this Agreement also allows for the construction, operation, closure and post- closure care of cells 1, 2, 3, 4, 5, and 6 and all related earth work and excavation, subject to the provisions of this Agreement, compliance with City ordinances and issuance of necessary permits. Wetland mitigation for filling 9.19 acres of wetlands has been accomplished through the purchase of 18.28 acres of wetland credit in accordance with the Wetland Conservation Act and the Rosemount Wetland Management Plan. 4. Environmental Assessment Worksheet (EAW). The City, as the Responsible Unit of Government (RGU), conducted on EAW in accordance with State Rules for the proposed landfill expansion to create Cell 6. On October 1, 2013, the City Council found that the proposed expansion does not have the potential for significant environmental effects and issued a negative declaration of need for an Environmental Impact Statement (EIS). 5. Design Plans and Specifications. SKB shall construct MICF in accordance with plans, specifications and procedures approved by the Minnesota Pollution Control Agency (MPCA), Dakota County (DC) and the City. Landscaping shall be completed in accordance with the plan for finished design approved by the MPCA, DC and the City. Any exceptions to the approved plans and specifications made during construction shall be listed in the Construction Certification provided pursuant to Section 9. SKB shall not make any alteration or addition to MICF that would materially alter the method or effect of disposal without first obtaining the written approval of the City Administrator. 3 6. Tree Replacement. SKB has provided a landscape and tree replacement plan that meets the Ordinance requirement of 769 replacement trees. The landscaping and tree replacement plans approved are intended to serve as a guideline and not the exact location of all the replacement trees. The city recognizes that this plan may represent an instance where the total amount of tree replacement required cannot occur on site..In this instance, the city may, at its option, accept a fee in lieu of tree placement or allow the planting of replacement trees in public areas. Tree replacement is encouraged to happen on site as much as possible and replacement in public areas will be considered after the site has been re- vegetated to a reasonable extent. A revised tree replacement plan which includes some tree installation off -site must be approved by the City Council. Until approval of the revised plan the currently approved tree replacement plan is in effect. 7. Quality Assurance /Quality Control. SKB shall construct, operate, and monitor MICF in accordance with the quality assurance /quality control plan(s) approved by MPCA. Any modifications to the quality assurance /quality control plan(s) require the written approval of the City Administrator. 8. Additional Construction Permits. SKB shall obtain all required construction permits, such as grading, excavation, building, plumbing, heating, electrical, and occupancy permits, in accordance with the adopted standards, procedures, and requirements of the City. All construction permits for improvements identified in Section 3 and authorized by Issuance of the IUP are administratively issued and administered. 9. Construction Inspection. SKB shall instruct its contractors and subcontractors to contact the City at least two (2) working days in advance of routine inspections (building, plumbing, electrical, etc.) required by the City. SKB shall contact the City at least ten (10) working days in advance of the commencement of construction of liner installations, leachate collection systems, and final cell cover. During hours of construction, SKB shall grant the City and its agent, upon presentation of proper credentials, access to MICF for the purpose of inspections and enforcement related to construction. 10. Sanitary Sewer Connection. MICF shall remain connected to the MCES Interceptor. SKB will be responsible for all costs resulting from the sewer connection including, but not limited to, the City's engineering, construction, permitting, easement, and legal costs. 11. Construction Certification. Within thirty (30) days of construction completion, SKB shall submit to the City a copy of the construction certification as required by MPCA. 12. Soil Protective Cover. The City acknowledges the ongoing nature of soil cover placement and will not require notice for inspections. The City and its agents may make random inspections throughout the life of MICF. 13. Operations and Maintenance. SKB shall operate and maintain MICF in accordance with the "Operational Plans" (Tab 4, 2013 MICF Permit Application), MPCA Permit, and DC License. No amendments may be made to the "Operational Plans" without the written approval of the City Administrator. 14. Waste Acceptance. SKB shall accept reject, and manage wastes according to the approved "Waste Acceptance Plan" (Tab 3, 2013 MICF Permit Application). SKB shall not dispose of any wastes identified as unacceptable wastes in the "Waste Acceptance Plan ", City Zoning Ordinance, DC License or MPCA Permit. No amendments may be made to the "Waste Acceptance Plan" without the written approval of the City Administrator. 5 A. Disposal of Ash/Conditions. Despite the provision of Section 12 above, SKB may dispose of ash at MICF, but only pursuant to the following conditions: 1) SKB shall not use ash as cover over waste when fill heights exceed the height of the perimeter berm at the MICF. 2) During transport of all ash to the MICF, trucks carrying ash must be covered with tarpaulins adequate to limit dusting. 3) SKB shall take adequate steps to prevent dust migration from ash disposal at the MICF. SKB may utilize, but is not limited to, one or more of the following methods for dust control: a) conditioning the ash by addition of moisture; b) handling ash when wind conditions are calm; c) immediately covering ash with cover materials. All methods utilized must be in conformance with all other provisions of the permit. 4) Ash disposal at MICF must not result in leachate discharges to the Empire Waste Water Treatment Plant (WWTP) that fail to comply with Industrial Discharge Permit requirements of the MWCC. 5) SKB shall submit with its annual report a summary of the quantity (in tons and cubic yards), type and source of ash deposited into MICF and shall provide an evaluation of the effects of ash on the chemical composition of leachate discharged from the MICF to the Rosemount WWTP. 0 6) Any ash disposal that requires an Environmental Assessment Worksheet (EAW) and /or an Environmental Impact Statement (EIS) shall not be permitted under this permit without first securing approval by the City Council following completion of the environmental review process. 15. Recycling/ Transfer Facility. SKB shall operate and maintain the Recycling/Transfer Facility in accordance with Section 14, Tab 4, 2013 MICF Permit Application, subject to the following conditions: A. Any MSW brought to the recycling and transfer facility shall be stored indoors during the entire time that it is on site. B. A vermin control plan for the recycling and transfer facility shall be prepared and approved by City staff that may include the plan being prepared by a pest and vermin control professional and periodic inspections of the facility by a pest or vermin control professional. C. The recycling and transfer facility shall be constructed of a minimum of 40% masonry for each side of the facility. 16. Wetland Mitigation. Wetland mitigation shall comply with the conditions and standards Minnesota Wetland Conservation Act Notice of Wetland Conservation Act Decision/Findings and Conclusions dated October 1, 2013. 17. Personnel Training. All SKB personnel involved in the operations and maintenance of MICF shall be trained, qualified, and certified as identified in the "Operational Plans ". 7 18. Incident Reporting. For any incident during operations at MICF resulting in emergency shutdown, release, explosion or fire, SKB shall notify the City's Police Department by telephone within two (2) hours of the detection of the incident; emergencies shall require immediate notification. SKB shall promptly furnish the City with written reports of the incident, as specified in the plans. 19. General inspections, Records, Reporting, Enforcement. SKB shall, during normal operating hours, grant the City and its agents, upon presentation of proper credentials, access to MICF for the purpose of inspections and enforcement of this agreement. Except for information deemed privileged in accordance with state law, SKB shall allow the City to inspect written documentation pertaining to compliance by SKB with the terms of this IUP. Records pertaining to compliance at MICF shall include but are not limited to, operating records as described in the "Operational Plans ", the "Corrective Action Plan", and MPCA Permit; inspection records; monitoring, investigation and modeling data; personnel training records, reports and plans required by regulatory agencies; correspondence with regulatory agencies; and records and correspondence regarding waste characterization, evaluation, management, inspection and acceptance /rejection. All information obtained during the course of inspections shall be used solely by the City or its agents for matters pertaining to this IUP. SKB shall simultaneously submit to the City an electronic copy of annual reports required to be submitted to the MPCA, Dakota County, and any other governmental regulatory agencies, unless such submission is waived in writing by the City Administrator. 20. Contingency Actions. SKB shall implement contingency and/or corrective actions as specified in the permit application and MPCA Permit and DC License. SKB shall furnish the City with a copy of the remedial 8 measures report or remedial measures plan, according to the timetable specified in MPCA Permit. No amendments may be made to the Corrective Action Plan" or the "Postclosure Contingency Action Plan" without the written approval of the City Administrator. 21. Monitoring/Reporting. SKB shall monitor MICF in accordance with MPCA Permit. Nothing shall be construed to prevent SKB from exceeding MPCA Permit requirements. 22. Closure. SKB shall close MICF in accordance with the Requirements of MPCA Permit. SKB shall notify the City at least ten (10) working days prior to the date closure activities for each cell are scheduled to begin. SKB shall notify the City at least ninety (90) days prior to the date final closure activities for MICF are scheduled to begin. Upon completion of closure of a cell or MICF, SKB shall notify the City to provide the opportunity for a final inspection. A copy of the closure certification and supporting documentation that is required by MPCA Permit shall be submitted to the City upon submittal to the MPCA. No amendment may be made to the "Closure Plan" (Tab 5, 2013 MICF Permit Application), as amended by Exhibit E of this Agreement, without the written approval of the City Administrator. 23. Postclosure. SKB shall provide postclosure care of MICF in accordance with the requirements of MPCA Permit. No amendments may be made to the "Postclosure Plan" (Tab 5, 2013 MICF Permit Application) without the written approval of the City Administrator. 24. Financial Assurances. SKB shall comply with the financial assurance requirements of the MPCA and DC. No reduction in the financial assurance requirements may be made without the written approval of the City Administrator. 9 25. Development Commitment. The provisions of the Development Commitment, approved by the City Council on October 1, 2013 are incorporated by reference as conditions of the IUP and attached as Exhibit D. The provisions of this Section and Section 11 of Exhibit D shall survive the termination of the Agreement and shall remain in effect for one year following closure of the MICF. Notwithstanding any provision of Section 2 of this Agreement, the City will not require any amendment of the Development Commitment for 5 years from the date of this Agreement. 26. Responsibility for Costs. SKB and the City agree to fund the out -of- pocket expenses incurred by the City in the review and issuance of the reissued IUP, according to the provisions of the Development Commitment. Costs incurred by the City for ongoing monitoring of the operation of MICF and administration of the IUP shall be paid by the City. Notwithstanding any provision of Section 2 of this Agreement, the City will not require any amendment of the Development Commitment for 5 years from the date of this Agreement. 27. Hours of Operation and Traffic Control. MICF operations are restricted to the hours of 6: 00 a. m. to 8: 00 p. m., Monday through Saturday. The hours of operation may be amended to accommodate special projects by the City Council. The City Council may impose traffic circulation and routing requirements on the operation of MICF at any time it deems such requirements necessary or convenient in the public interest. Such requirements, which may include restricting trucks entering or leaving MICF to right -in and right -out turning movements to and from CR 42 and TH 55, shall be given in writing and shall specify the days, times or circumstances during which such 10 requirements apply. 28. Indemnification. SKB shall defend, indemnify and save the City, its officers, and employees harmless from and against any and all claims, suits, demands, actions, fines, damages and liabilities, and all costs and expenses related thereto (including, without limitation, reasonable attorneys' fees) arising out of or in any way related to MICF. The provisions of the Section shall survive the termination of this Agreement and shall remain in effect until final resolution of any and all of the various claims and actions made as defined in this Section. 29. Other Laws and regulations. SKB agrees to comply with all other laws, regulations, permits, or licenses that apply to MICF. 30. Severability. If any provision of this Agreement is found to be invalid, such finding shall have no effect on the validity of the remainder of this Agreement. 31. Notice of Violation. Notice of violation of any provision of the IUP shall be given to SKB by the City in writing. Such written notice shall specify the violation and request that the violation be corrected. SKB shall have ten (10) days after receipt of notice to correct the violation. Upon evidence that the health, safety, and welfare of the public is not in jeopardy and upon evidence of diligent cooperation by SKB to correct the violation, the City Administrator may agree in writing to extend the ten -day period. 32. Termination. This IUP shall terminate on the happening of any of the following events, whichever first occurs: (1) five (5) years effective date of this agreement; 11 (2) Upon change in the City's zoning regulation that renders the use nonconforming; (3) By the City Council (Council) for violation of any provisions of the IUP, in accordance with the following procedures: Termination shall not occur earlier than ten (10) working days from the time the written notice of termination is served on SKB or, if a hearing is requested, until written notice of the Council action has been served on SKB. Notice to SKB shall be served personally or by registered or certified mail at the address designated in the IUP. Such written notice of termination, the nature of the violation or violations constituting the basis for the termination, the facts that support the conclusion that a violation or violations has occurred and a statement that if SKB desires to appeal, it must within ten (10) working days, exclusive of the day of service, file a request for a hearing. The hearing request shall be in writing stating the grounds for appeal and be served personally or by registered or certified mail on the City by midnight of the tenth (10th) working day following service. Following receipt of a request for a hearing, the City shall set a time and a place for the hearing. HEARINGS: A. If SKB properly requests a hearing on termination of the IUP, such hearing shall be held before the Council, or a hearing examiner as provided below, and shall be open to the public. B. Unless an extension of time is requested by SKB in writing directed to the City and is granted, the hearing will be held no later than forty -five (45) calendar days after the date of service of request for a hearing, exclusive of the date of such service. In any event, 12 such hearing shall be held no later than sixty (60) calendar days after the date of service of request for a hearing, exclusive of the date of such service. C. The city shall mail notice of the hearing to SKB at least fifteen (15) working days prior to the hearing. Such notice shall include a statement of time, place, and nature of hearing. D. Hearing Examiner. The Council may by resolution appoint an individual, to be known as the hearing examiner, to conduct the hearing and to make findings of fact, conclusions, and recommendations to the Council. The hearing examiner shall submit the findings of fact, conclusions and recommendations to the Council in written report, and the Council may adopt, modify, or reject the report. E. Conduct of the Hearing. SKB may be represented by counsel. The City, SKB, and additional parties, as determined by the Council or hearing examiner, in that order, shall present evidence. All testimony shall be sworn under oath. All parties shall have full opportunity to respond to and present evidence, cross examine witnesses, and present argument. The Council or hearing examiner may also examine witnesses. F. The City shall have the burden of proving its position by a preponderance of the evidence, unless a different burden is provided by substantive law, and all findings of fact, conclusions, and decisions by the Council shall be based on evidence presented and matters officially noticed. G. All evidence that possesses probative value, including hearsay, 13 may be admitted if it is the type people are accustomed to rely on in the conduct of their serious affairs. Evidence that is incompetent, irrelevant, immaterial, or unduly repetitious may be excluded. The hearing shall be confined to matters raised in the City's written notice of termination or in SKB's written request for a hearing. H. At the request of the City, SKB, or the hearing examiner, a pre - hearing conference shall be conducted by the hearing examiner, if the Council has chosen to use one, or by a designated representative of the Council. The pre - hearing conference shall be held no later than five (5) working days before the hearing. The purpose of the pre- hearing conference is to: (1) Clarify the issues to be determined at the hearing. (2) Provide an opportunity for discovery of all relevant documentary, photographic, or other demonstrative evidence in the possession of each party. The hearing examiner or City's representative may require each party to supply a reasonable number of copies of relevant evidence capable of reproduction. (3) Provide an opportunity for discovery of the full name and address of all witnesses who will be called at the hearing and a brief description of the facts and opinions to which each is expected to testify. If the names and addresses are not known, the party shall describe them thoroughly by job duties and involvement with the facts at issue. I. If a pre - hearing conference is held, evidence not divulged as provided above may be excluded at the hearing. J. If SKB fails to appear at the hearing, it shall forfeit any right to a hearing before the Council or hearing examiner. 14 33. Amendments. Any changes in the provisions of this Agreement requested by SKB require the express written consent of the City. The City may at its option impose addition requirements for the IUP when changes or amendments in waste management rules, laws, or technology are in the best interest of public health, safety, and welfare, or if there are changes in the MPCA Permit or DC License. The procedure to amend the IUP shall be the same as the procedure required to issue the IUP. 34. Enforcement. SKB shall reimburse the City for its reasonable costs (including without limitation engineering and legal fees) incurred in the enforcement of the IUP, that results in a City Council decision to terminate the IUP. Payment of these costs will be in addition to the City Service Charge, provided for in the Development Commitment. 35. Interpretation. In any challenge of the provisions of this Agreement, the interpretation of the provisions shall be liberally construed to protect the public health, safety, and welfare. 36. Assignment. The IUP is not assignable or transferable without the express written consent of the City. In the event an assignment of the IUP is proposed, the City may at its option impose additional requirements to this Agreement or may require a new agreement. 37. Notice. Notices given pursuant to this Agreement shall be personally delivered or sent by certified mail to City of Rosemount, 2875 145th St. W., Rosemount, Minnesota 55068 -0510 and to SKB, Inc., 13425 Courthouse Boulevard, Rosemount, Minnesota 55068. All notices shall be effective upon receipt. 15 38. Recording. This Agreement shall run with the subject land and may be recorded in the Dakota County Recorder's Office. SKB ENVIRONMENTAL, INC. Its: Andby: Its: STATE OF MINNESOTA ) ss. COUNTY OF ) The foregoing instrument was acknowledged before me this day of 2013, by and , the and , respectively, of SKB Environmental, Inc., a Minnesota corporation, on behalf of the corporation. Notary Public 17 CITY OF ROSEMOUNT By: Its: Mayor Andby: Its: Clerk STATE OF MINNESOTA ) ) ss. COUNTY OF DAKOTA ) The foregoing instrument was acknowledged before me this day of 2013, by William Droste and Amy Domeier, the Mayor and Clerk, respectively, of the City of Rosemount, a Minnesota municipal corporation, on behalf of the corporation. Notary Public 18 Wenck File #3503 -03 Wetland Replacement Plan SKB Rosemount Landfill Expansion Project Prepared for: SKB Environmental 13425 Court House Boulevard, Rosemount, MN Prepared by: WENCK ASSOCIATES, INC. 1802 Wooddale Drive Suite 100 Woodbury, Minnesota 55125 -2937 (651) 294 -4580 Minnesota Local /State /Federal Application for Water /Wetland Proiects Applicant: SKB Environmental, Inc. Project: SKB Rosemount Landfill WCA Local Gov't Unit: City of Rosemount WETLAND IMPACT APPLICATION Table of Contents • Permit Application Form • Appendix A: Type of Project • Appendix B: Project Description • Appendix C: Project Alternatives • Appendix D: Status of Other Approvals • Appendix E: Wetland Delineation Report • Appendix F: Wetland Boundary Concurrence from City • Appendix G: 2008 Permit Documentation • Appendix H: Site Location Map • Appendix I: Construction Plans • Appendix J: Adjoining Landowners Prepared by: WENCK ASSOCIATES, INC. 1802 Wooddale Drive Suite 100 Woodbury, Minnesota 55125 (651) 294 -4580 September 3, 2013 Wenck NA- 026620 -03B (V.2.02 for MS WORD) 9/172007 Minnesota Local /State /Federal Application Form for Water/Wetland Projects For Internal Use Only Application No. Field Office Code Date Initial Application Received Date initial Application Deemed Complete PART I: BASIC APPLICATION "See HELP" directs you to important additional information and assistance in instructions. Page 1. 1. LANDOWNER/APPLICANT CONTACT INFORMATION (See Help 1) Name: SKB Environmental, Inc. Attn: John Domke Phone: 612 - 366 -4353 E -mail: JohnDo @WasteConnections.com Complete mailing address: 13425 Court House Blvd., Rosemount, MN 55068 IA. AUTHORIZED AGENT (See Help 1A) (Only ij'applicable; an agent is not required) Name: Mike Graham, Wenck Associates Phone: 651- 395 -5229 E -mail: mgraham @wenck.com Complete mailing address: 1802 Wooddale Drive, Woodbury, MN 55125 2. NAME, TYPE AND SIZE OF PUBLIC WATERS or WETLANDS IMPACTED (Attach Additional Project Area sheets if needed) Name or I. D. # of Waters Impacted (if applicable; if known): (Check all that apply): ❑ Lake ❑ River x Circular 39 Wetland type: ❑ 1, ❑ I L, 2, x 3, ❑ 4, ❑ 5, ❑ 6, [17, ❑ 8 Wetland plant community types: x shallow open water, ❑ deep marsh, ❑ shallow marsh, ❑ sedge meadow, fresh meadow, ❑ wet to wet -mesic prairie, ❑ calcareous fen, ❑ open bog or coniferous bog, ❑ shrub -cart /alder thicket, ❑ hardwood swamp or coniferous swamp, ❑ floodplain forest, ❑ seasonally flooded basin indicate size of entire lake or wetland (check one): X Less than 10 acres (indicate size: 9.49 ac.- Wetlands A and B) ❑ 10 to 40 acres ❑ Greater than 40 acres 3. PROJECT LOCATION (Information can be found on property tax statement, property title or title insurance): Project street address: Fire 0: City (if applicable): Rosemount ,i Section: SW Section: 20 Township #: 115N Range #: 18W County: Dakota Lot #: Block: Subdivision: Watershed (name or #) 38 UTM location: N E Attach a simple site locator map. If needed, include on the map written directions to the site from a known location or landmark. and provide distances from known locations. Label the sheet SiTE LOCATOR MAP, 4. TYPE OF PROJECT: Describe the type of proposed work. Attach TYPE OFPROJECT shcet if needed. See attached narrative. 5. PROJECT PURPOSE, DESCRIPTION AND DIMENSIONS: Describe what you plan to do and why it is needed, how you plan to construct the project with dimensions (length, width, depth), area of impact, and when you propose to construct the project. This is the most important part of your application. See HELP 5 before completing this section; see What To Include on Plans (Instructions, page 1). Attach PROJECT DESCRIPTION sheet. See attached narrative. Footprint of project: 9.49 acres or 413,384 square feet drained, filled or excavated. 6. PROJECT ALTERNATIVES: What altematives to this proposed project have you considered that would avoid or minimize impacts to wetlands or waters? List at least TWO additional alternatives to your project in Section 5 that avoid wetlands (one of which may be "no build" or "do nothing "), and explain why you chose to pursue the option described in this application over these alternatives. Attach PROJECT ALTERNATIVES sheet if needed. See attached narrative. 7. ADJOINING PROPERTY OWNERS: For projects that impact more than 10,000 square feet of water or wetlands, list the complete mailing addresses of adjacent property owners on an attached separate sheet. (See HELP 7) 8. PORTION OF WORK COM PLETED: Is any portion of the work in wetland or water areas already completed? ❑ Yes X No. If yes, describe the completed work on a separate sheet of paper labeled WORK ALREADY COMPLETED. (See HELP 8) 9. STATUS OF OTHER APPROVALS: List any other permits, reviews or approvals related to this proposed project that are either pending or have already been approved or denied on a separate attached sheet. See HELP 9. 10. 1 am applying for state and local authorization to conduct the work described in this application. I am familiar with the information contained in this application. To the best of my knowledge and belief, all information in Part I is true, complete, and accurate. I possess the authority to &M%ke the work described, or I am acting as the duly authorized agent of the applicant. applicant (Landowner) Date Signature ol'agent (f applicable) Date This block must be signed by the person who desires to undertake the proposed activity and has the necessary property rights to do so It* only the Agent has signed, please attach a separate sheet signed by the landowner, giving necessary authorization to the Agent. 'See Wettand Plants and Plant Coin atunities oj'Minnesota and Wisconsin (Eggers and Reed, 1997) as modified by the Board of Water and Soil Resources, United States Army Corps of Engineers. Minnesota Local/State/Federal Application Fonns for Water /Wetland Projects Page 1 APPLICA'T'ION FOR DEPARTMENT OF TILE ARMY PERMIT 33 CFR 325) ONIB APPROVAL NO. 0710-003 Expires Dec 31, 2004 i'he public burden for this collection of inibnnatiou is esiiinated to average 10 hours per response, allhnugh the majority ofapplications should require 5 boors or less, This includes the tittle for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of infbr iatiun, fiend comment, regarding this burden estimate or any other aspect of this collection of information. including suggestions for reducing this burden. to f),apartment of Defense, Washington Ileadquarters Service Directorate of hilbrmation Operations and Reports, 1215 Jetlerson Davis Highway, Suite 1204, Arlington. VA 22202 -4302; and to the 011f ice ofN4anagemenl and nudge[, Paperwork Reduction Project (0710 - 0003), Washinghnt. DC: 20503 Respondeols should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it dues not display a currently valid OMB control number, Please DO NO 'r RI -1 I lRN your limn to either of these addresses:. (completed application must be subtitled to the District engineer having jurisdiction over the location of the proposed activity, PRIVACY ACT STATEMENT: Authorities- River and Harbors Act. Section Ill, 33 IJSC 403; Clean water Act, Section 404, 33 USC 1344; Marine Protection, Research and Sanctunries Act. 33 IJSC 1413, Section 103. Principal pugrose: Information provider) na this form will be used in evaluating the application Ibra permit. Routine uses: This information may be shared with the Dcpttrhnenl ol'Justice and other Federal, state, and local govcrmnent agencies. Submission ofrequcsted informatioa is voluntary; however. if information is not grovided. the perinit application cannot be evaluated nor can a aerinit be issued, ITEMS 1 THROUGH 4 TO BE FILLED IN BY THE CORPS I. APPLICATION NO, I 2. FIELD OFFICE CODE 1 3, DATE. RECEIVED ( 4. DATE APPLICATION COMPLETED YOU DO NOT NEED TO COMPLETE ITEMS 6 -10 and 12 -25 in the SHADED AREAS. A!/ applicants must complete non - shaded items 5 and 26. If an agent is used, also complete items 3 and 11, This optional Federal form is valid for use vvn! when included as parl of this entire state aeplication packet. 5. APPLICANT'S NAME 8, AUTHORIZED AGENT'S NAME AND TITLE (an agent is not required) SKB Environmental, Inc. Attn: John Domke Mike Graham, Wenck Associates 11. STATEMENT OF AUTHORIZATION I hereby authorize Mike Graham to act onI support of this permit application. Jr' <, complete only if'nuthorizing an agent) my agent in the pmcessing of this application amd to furnish, upon reriuist, supplemental information in 26. Application is hereby matte for a permit or permits to authorize the work described in this application. I certify that the infornation in this app) icatio ornplete and accurate. I further certify that I possess the authority to undertake the work described herein or tun acting as the duly auth4z ag4nt of the applicant. Oat Signature agent Date 5gtu rent t:ppli<ttni g g Y TTtc 4 licution must be signed by the. person who desires to undertake the proposed activity (applicant), or it may be signed by a duly authoriZCd agent if' thus agent in Block I l has been filled out and signed. 18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any departincnt or agency of the United Suites knowingly and willfully falsifies, conceals, or covers up with any trick, scheme, or disguises a material factor makes any false, fictitious or laudulent statements or representations or makes ,117 uses any false writing or document knowing same to contain any false, fictitious or fraudulent statements or ottry, shall be fined not more than S 1(1,000 or imprisoned not more than five year% or both. ENO FORM 4345, Jul 97 EDITION OF FEB 94 IS OBSOLETE, (Proponent: CECW-OR) Minnesota Local ?StatclFederal Application Forms for Water'Wetland Projects Page 2 FOR LGU USE ONLY: Determination for Part 1: ❑ No WCA Jurisdiction ❑ Exempt: No. _ (per MN Rule 8420.0122) ❑ No Loss: _ (A,B,...G, per MN Rule 8420.0220) ❑ Wetland Boundary or type ❑ Replacement required -- applicant must complete Part If COMPLETE THE SECTION BELOW ONLY IF REPLACEMENT IS NOT REQUIRED: Application is (check one): ❑ Approved []Approved with conditions (conditions attached) ❑ Denied Comments/Findings: LGU ojicial signature Date Name and Title For Agricultural and Drainage exemptions (MN Rule 8420.0122 Subps. 1 and 2B), LGU has received proof of recording of restrictions (per MN Rule 8420.0115): County where recorded bate Document d assigned by recorder LGU ojficial signature Date Minnesota Local/StateiFedefal Application Forms for Wateo'Wetland Prujects Page 3 PART II: REPLACEMENT PLAN SUPPLEMENT For assistance in completing Part 11, contact your Local Government Unit or a professional consultant 11. DESCRIPTION OF WETLAND IMPACTS: Complete the chart below: [)Use one row of boxes for each wetland impact; 2) If your project has more than one wetland impact, reference your overhead view (part of Section 5) to this chart by identifying and labeling "first impact" and "second impact" on your overhead view; 3) If you arc identifying only one wetland type within a given wetland impact area, use the first dotted line and leave the others blank; 4) if you have chosen to identity more than one wetland type within a given wetland impact area, use the extra dotted lines to indicate each wetland type, and identify predominant vegetation and size of impacted area for each separate wetland type within that impact area; 5) If you do not have access to some of this information, call your LGU or SWCD office for assistance. (Photocopy chart for more impacts, ifneeded.) i1FSCRIPTInN OF WETLAND IMPACTS Wetland impact (as noted on overhead view) Watershed name or number (if known) Watershed and Bank Service Wetland plant community type' Predominant vegetation in impacted wetland area Size of area impacted (in acres or square feet) Existing land use In project area (check all that apply) 38 8 Seasonally Stinging nettle, 0.33 ac. Housing flooded basin thistle, goldenrod El Commercial First _....... a.A y .... y x Industrial Impact - Wetland ❑ Parks /recreation areas A X Highways and associated rights -of -way Forested x Farmsteadslagricultural ❑ Vacant lands ❑ Public and semi - public Reed canary 38 8 Shallow marsh grass, cattail, 9.16 ac. (schools /govt facilities) goldenrod ❑ Airports Second ........................... ...................:..,,._..... ❑ Extractive (gravel Impact - Wetland pits /quarries) B ❑ Other: 'if you are identifying only one wettand type within a given wetland impact area, use the first dotted line and leave the others blank. If you have chosen to identify more than one wetland type within a given wetland impact area, use the extra clotted lines to indicate each separate welland type, and identify predominant vegetation and size of impacted area for each separate wetland type with that impact area. TOTALS OF AREA(S) IMPACTED FOR EACH WETLAND TYPE ON CHART (indicate acres ❑ orsquare feet ❑) Wetland plant community type t: Shallow open water: Deep marsh: Shallow Marsh: 9.16 Sedge meadow: Fresh wet meadow: Wet to wet mesic prairie: Calcareous fen: Open bog or coniferous bog: Sit rub Carr or alder thicket: Hardwood swamp or coniferous swamp: Floodplain forest Seasonally flooded basin 0.33 12. SPECIAL CONSIDERATIONS: Are you aware of any special considerations that apply to either the impact site(s) or the replacement site(s)? ❑ Yes X No (Examples: the presence of endangered species, special fish and wildlife resources, sensitive surface waters, or waste disposal site.) if YES, list and describe briefly. 13. SHORELAND IMPACT ZONE: Please identify each wetland impact site noted in Section t 5 drat is within 1000 feet of a lake or 300 feet of a river r See Wetland Plants and Plant Communities of Minnesota and Wisconsin (Eggers and Reed, 1997) as modified by the Board of Water and Soil Resources, United States Army Corps of Engineers. Minnesota LocallStatelFederal Application Forms for Water: Wetland Projects Page 4 14. HOW PROPOSED REPLACEMENT WILL BE ACCOMPLISHED: Indicate how proposed replacement will be accomplished (check only one box below and continue as indicated): X A. Wetland banking credits only Complete Application for Withdrawal of Wetland Credits Form and include with your application. Copies of this form are available from your LOU, or download a copy from www.bwsr state.mn.us Skip to Section 19, page 6 (You do not need to complete Sections 15 -18). ❑ B Project- specific replacement only Continue with Section 15 below, ❑ C. A Combination of wetiand banking and project - specific replacement. If using project specific replacement that will result in surplus wetland credits that you propose to deposit in the state wetland bank for future use, then you must submit a wetland banking application directly to your LOU before or concurrently with submittal of this form. Also, Complete Application for Withdrawal of 11'etland Credits Form and include with your application. Copies of this form and the wetland banking application is available from your LOU, or download a copy from www.bwsr.stale.mu,us Continue with Section 15 below. 15. DESCRIPTION OF REPLACEMENT WETLAND(S) CONSTRUCTION (Complete this section only if you marked Box B or Box C in Section 14 above): Describe in detail how replacement wetland(s) will beconstructed. Ifseveral methods will be used, describe each method. Details should include dte following: 1) type of construction (such as excavated in upland, restored by the break, restored by ditch block or revegtwted); 2) type, size and specifications of outlet structures; 3) elevations relative to Mean Sea Level or established benchmarks or key features (such as sill, emergency overflow or structure height): 4) what best management practices will be implemented to prevent erosions or site degradation; 5) proposed timetable for starting and ending the project; and 6) a vegetation management plan. Write this description on a separate sheet of paper labeled DESCRIPTION OFREPLACEMENT WETLAND CONSTRUCTION. lb. SURPLUS WETLAND CREDITS: If using project - specific replacement (Box B or Box C in Section 14 above), will the replacement result in any surplus wetland credits that you wish to have deposited in the State Wetland Bank for future use? ❑ Yes ❑ No. If yes, submit a Wetland Banking Application directly to your LGU before or concurrently with submittal of ilus form Copies are available from your LOU, or download a copy from www.bwsr. state.ntn,.us 17. DESCRIPTION OF REPLACEMENT WETLANDS: Complete the chap below: 1) Use one row of boxes for each wetland replacement site; 2) If your project has more that one wetland replacement site, reference your overhead view (part of Section 5) to this chart by identifying and labeling "first replacement site' and "second replacement site" on your overhead view; 3) If you are identifying only one wetland type within a given replacement site, use the first dotted line(s) and leave the others blank; 4) It' you have chosen to identify more than one wetland type in a given replacement site, use the extra dotted lines to indicate each separate wetland type, and identify type(s) of replacement credits and "restored or created" for each separate wetland type with that replacement site; 5) If you do not have access to some of the information, or if you do not know your replacement ratio, call your LGU or S WCD office for assistance. Photocopy chartfor more wetland replacements, ifneeded.l nFSCRIPTInN nF RFPI_ACFMENT WETLANDS Identify Watershed County Section, Wetland Type(s) of replacement credits Restored Wetland name or Township, Plant (in acres or square feet) or replacement number Community created? site (if known) Range Type' New Wetland Public Value Indicate (as noted on Bank Service Credits (NWC) Credits (PVC) R or C overhead view) Area Name of First��_ ___._a -,_ ____..___ ......... ....» ........ replacement --- ___- __- site Name of Second__.,___ -. .___- _ a. ............ ...�.. replacement site�d.__._ ------- -- - ---- -- ---- ---. -. if you are identifying only one wetland type within a given wetland impact area, use the first dotted line and leave the others blank if you have chosen to identify more than one TOTAL NWC TOTAL PVC wetland type within a given wetland impact area, use the extra dotted lines to indicate each separate wetland type, and identify predominant vegetation and size of impacted area for REQUIRED REPLACEMENT RATIO: each separate wetland type within that impact area. (If known) Wetland plant community type: Shallow open water: Deep marsh: Shallow Marsh: Sedge meadow: Fresh wet meadow: Wet to wet mesic prairie: Calcareous fen: Open bog or coniferous bog: Shrub Carr or alder thicket: Hardwood swamp or coniferous swamp: Floodplain forest Seasonally Flooded basin * See Wetland Plants and Plant Communities of Minnesota and Wisconsin (Eggers and Reed, 1997) as modified by the Board of Water and Soil Resources, United States Army Corps of Engineers. Minnesota LocaliState/Federal Application Forms for Water /Wetland Projects Page 5 18. ADDITIONAL INFORMATION REQUIRED FOR PROJECT- SPECIFIC REPLACEMENT (Required only if you marked Box B or Box C in Section 14): For projects involving at least some project - specific replacement, include the following additional information: ❑ Two drawings to scale of the replacement wetland. Include both overhead view and profile (side view or cross - sectional view). See What to Include on Plans (instructions, Page 3) for a detailed description of what should be included in these drawings Without drawings, your application will be considered incomplete. ❑ For created replacement wetlands, include additional soils information (if available) that indicates the capability of the site to produce and maintain wetland characteristics. Note 1: For replacement wetlands located on pipeline easements, you need to receive endorsement of your project from both the easement holder and the Minnesota Department of Public Safety's Office of Pipeline Safety. Before start of construction, the owner of any utilities must be notified. The landowner or contractor is responsible for giving this notice by calling "Gopher State One -Call" at 652 --454 -0002 (Twin Cities Metro Area) or 1 -800 -252 -1166 (all other locations). Note 2: For extensive or complex projects supplementary information may be requested at a later dated front one or more of the responding agencies. Such information may include (but not be limited to) die following: topographic snap, water table map, soil borings, depth soundings, aerial photographs, environmental assessment and/or engineering reports. 19. SIGNED AFFIRMATION: FOR PROJECTS INVOLVING REPLACEMENT BY WETLAND BANKING ONLY. To the best of my knowledge nod belief, all information in Part It is true, complete and accurate; and I affirm that the wetland losses will be replaced via withdrawal from an account in the State Wetland Bank. FOR PROJECTS INVOLVING EITHER PROJECT - SPECIFIC REPLACEMENT ONLY OR A COMBINATION OF WETLAND BANKING AND PROJECT- SPECIFIC REPLACEMENT: Part A: The replacement wetland. I affirm that the replacement wetland was not: Previously restored or created under a prior approved replacement plan or permit; AND Drained or filled under an exemption during the previous 10 years; AND Restored with financial assistance from public conservation programs; AND Restored using private funds, other than landowner funds, unless the funds are paid back with interest to the individual or organization that funded the restoration; and the individual or organization notifies the local government unit in writing that the restored wetland may be considered for replacement. Part B: Additional assurances (check all that apply): ❑ The wetland will be replaced before or concurrent with the actual draining or tilling of a wetland. ❑ An irrevocable bank letter of credit, performance bond, or other acceptable security has been provided to guarantee successful completion of the wetland replacement. X The wetland losses will be replaced via withdrawal from an account in the State Wetland Bank. Part C. For projects involving any project- specific replacement: Within 30 days of either receiving approval of this application or beginning work on the project, I will record the Declaration of Restrictions and Covenants on the deed for the property on which the replacement wetland(s) will be located; and I will at the same time submit proof of such recording to due LGU. To the �1 nftpy knowledge and belief, all information in Pan 11 is true, complete and accurate; and I affirm all statements in Pan A and C, as well as checked - •u �} in Part B. .,1 rrt rt` o applirant or agent [kite FOR LGU USE ONLY Replacement plan is (check one): ❑ Approved ❑Approved with conditions (conditions attached) ❑ Denied LGU official signature Date LGU has receive evidence of title and proof of recording of Declaration of Restrictions and Covenants for Replacement Wedand: County where recorded Date Document # assigned by recorder LGU ojjlcial signature Date Minnesota LocaUStatelFederal Application Forms for Water/Welland Projects Page 6 Appendix A - Background The applicant, SKB Environmental, is proposing an expansion of its existing landfill facility in Rosemount, Minnesota. The site is located in a portion of the SE % SE Section 19 and a portion of the SW % SW % Section 20, T115N, R18W, City of Rosemount, Dakota County, Minnesota (Figure 1). The site is bordered on the north by Minnesota State Highway 55, on the south by 140th Street, on the west by railroad right - of -way and on the east by undeveloped agricultural land. Currently, the landfill property consists of approximately 238 acres of which 151 acres are dedicated to the active landfilling operations. The current landfill contains about 26,866,046 cubic yards of permitted waste volume and there is approximately 19,218,972 cubic yards of remaining air space as of November 2012 which, at 2012 tonnages, would be filled in 18 years. Looking at the longer historical trend from 2009 — 2012, the current landfill space would be filled in seven to eight years. The landfill principally serves the Twin Cities Metropolitan Area; however, the landfill provides management services for industries throughout the state of Minnesota as well as some industries in western Wisconsin. On -Site Wetlands The site was delineated for jurisdictional wetlands by Wenck Associates, Inc. on April 30, 2013. The City of Rosemount issued its Notice of Decision concurring with the wetland delineation on August 19, 2013 (see Appendix F). There are two wetlands within the project footprint, identified as Wetland A and Wetland B, per the wetland delineation report (attached as Appendix E). Both wetlands are located along the south property boundary and measure 0.33 acres (Wetland A) and 9.46 acres (Wetland B). A previous permit (Appendix G) allowed 0.30 acre of the north tip of Wetland B to be filled; therefore the remaining unpermitted area of Wetland B is 9.16 acres. Wetland A is dominated by stinging nettle (Urtica dioica), Canada thistle (Cirsium arvense) and giant goldenrod (Solidago gigantea). Wetland B is dominated by reed canary grass (Phalaris arundinacea) and giant goldenrod with narrow - leaved cattail (Typha angustifolia) dominant in the center of the basin. Wetland Jurisdiction USACE A request for an Approved Jurisdictional Determination was submitted to the U.S. Army Corps of Engineers ( USACE) on March 19, 2013. As of the time of this permit application, the Corps had not yet made decision regarding its jurisdiction. MnDNR There are no wetlands or other waterbodies present within or near the site that are regulated as Protected Waters by the Minnesota Department of Natural Resources (see Figure 4 in Wetland Delineation Report — Appendix E). 11 Appendix A City of Rosemount (Wetland Conservation Act) Any draining or filling of the wetlands on the site is regulated under the Wetland Conservation Act, which is administered for the site by the City of Rosemount. Also, excavation in the permanently and semi - permanently flooded areas of Type 3, 4 and 5 wetlands or in any wetland type if the excavation results in filling, draining or conversion to nonwetland is regulated under the WCA (Minnesota Rules 8420.0105 Subp. 1). The City also has a Comprehensive Wetland Management Plan that was adopted in 1998 and was most recently amended in February 2013. This Management Plan includes an inventory and classification of the City's wetlands. Wetland A per the delineation report is identified as Wetland 438 in the City's inventory and is classified as Manage 1. Wetland B per the delineation report is not included on the City's inventory. The City is currently evaluating the Minnesota Rapid Assessment Method evaluation that was done for Wetland B to determine its management classification. Historic Land Use The site has been used as a landfill since 1992 when it began operations under the ownership of Union Pacific Railroad. Prior to 1992, the site had been part of a farm and was in agricultural use. Historic aerial photograph of the site are presented in Appendix C of the delineation report (Appendix E). As seen in the historic aerials, landfill operations are not evident in the 1991 photo but are clearly underway in the 1997 photo. Wetland B appears to become wetter and expand in size over time. A significant expansion of the basin is evident between 1997 and 2003. A minor landfill expansion was permitted in 2008 which allowed the filling of the northern tip of Wetland B and another wetland north of Wetland B. Service Area of Landfill /Types of Waste Managed The service area is principally the metropolitan area. However, management services are also provided for industries throughout the State of Minnesota as well as some industries in western Wisconsin. SKB provides construction and demolition (C &D) debris processing /disposal services as well as industrial solid waste disposal services to industries. The expansion area would primarily manage industrial waste, but will also be permitted to accept construction and demolition debris. 21Appendix A Appendix B - Project Description Project Need and Purpose The purpose of the project is to provide additional waste disposal capacity for solid waste management in the Twin Cities Metropolitan Area. There is a continuing need for construction and demolition (C &D) debris processing /disposal services as well as industrial solid waste disposal services by those industries served by the landfill. The most recent Metropolitan Area data in a 2007 Solid Waste Management Coordinating Board (SWMCB) report estimates that a total of 2.3 million tons of industrial and C &D are disposed of in landfills serving the Metropolitan Area each year (1.1 million tons of Industrial; 1.2 million tons of C &D) (Minnesota Construction, Demolition, and Industrial Waste Study, Solid Waste Management Coordinating Board, July 2007). That number has increased steadily since 2007. In 2012, SKB alone managed nearly 1 million tons of industrial waste. While the industrial waste disposal totals of other facilities serving the area are not known, these numbers clearly show a dramatic increase in the amount of industrial waste being disposed of in the Metropolitan Area. Given the tonnages and increases in waste generation, the remaining existing capacity at the landfill will be rapidly dwindling without an expansion. The trends shown in the table below demonstrate the dramatic increase in both industrial and C &D waste managed at the SKB facility. Table 1. Disposal Rates — SKB Landfill 2009 — 2012 Waste Type 2009 tons 2010 tons 2011 tons 2012 tons Industrial 411,646 625,205 883,158 962,316 C &D 189,422 212,761 209,350 249,992 It is important to recognize that the vast majority of industrial waste is not recyclable or is already the residual of a previous recycling process. Also, the 2007 SWMCB report estimated that as much as 68% of industrial waste is contaminated soil, for which there is really no viable beneficial use apart from use as landfill daily cover. 1I Append ix B The project being proposed would expand the landfill into vacant land owned by SKB Environmental, Inc. southwest of its active operations area. This new expansion would be used for the disposal of industrial and C &D wastes and would provide the landfill with 8,325,571 cubic yards of additional disposal volume. Proposed Wetland Impact The proposed expansion project would impact all of Wetland A (0.33 acre) and all of the remaining unpermitted area of Wetland B (9.16 acres). The impact to Wetland B primarily includes filling for the expanded landfill. A small area along the south boundary of the wetland would be partially excavated and managed as a storm water basin. The storm water basin would be used to provide storm water storage for water that would be directed to this location from the landfill and other ancillary lands in the southwest portion of the facility property. The storm water basin is designed to match the existing elevation of the lowest part of Wetland B; only the southern fringe of the wetland on the slope along the road would be excavated. Mite Wetland Impacts Over the past few years, land uses surrounding the SKB facility appear to be having an effect on the hydrology of the existing wetlands at the site. These impacts are difficult to measure; however, the source of the hydrologic impacts is believed to be increased water usage by the Flint Hills Refinery and by Rich Acres Golf Club. The Flint Hills Refinery lies approximately mile from the SKB site and Rich Acres is directly southwest of the SKB property. SKB staff have noticed a marked drop in the normal water level of Wetland B in recent years which is validated by the historic aerial photographs in Appendix C of the Wetland Delineation Report. The 1991 aerial photograph shows the wetland with some standing water whereas the wetland appeared to rarely have standing water in any of the previous photos. In the 1997 photo, Wetland B appears to be completely filled with water which is the result of the newly constructed landfill directing water to it and an above - normal year in terms of precipitation. In 2003, another very wet year, the wetland is again full of water and appears to be without emergent vegetation in most of the basin. In the 2006 photo, most of the central portion of the wetland appears to be grown -in with emergent vegetation and there are open water areas on the east and west sides of the basin. In the 2008 and 2010 photos, the wetland does not have standing water and is completely covered with emergent vegetation. The landfill has not made any changes in how storm water is directed since the landfill opened 21 years ago. Precipitation from 2003 to 2010 has generally been in the normal range. Therefore, it is possible that these off -site influences have caused a decrease in the hydrology of the wetlands on the SKB property. Because of the sandy nature of the soils in this area, groundwater is very sensitive to increased appropriations and draw -down responses are relatively rapid. It is possible that the change in hydrology of Wetland B is a response to a change in the regional groundwater table. If that is the case, the wetlands proposed to be 2JAp pen dix B impacted by SKB may be lost or diminished over time regardless of whether or not the landfill expansion takes place. 31Appendix I3 Appendix C - Project Alternatives and Mitigation Alternative 1: NO BUILD The no build alternative is considered neither feasible nor prudent since not expanding the existing facility means that the landfill would be at its disposal life in 8 —18 years based on current projections. If the project is not done, either a new landfill site would need to be identified and developed or an existing landfill with the same or similar service area as the SKB facility would need to be expanded. These options are discussed below under "Alternative 2 ". As discussed there, these other alternatives either are not capable of being done or would not be able to replace the landfill capacity proposed for the project. Therefore, the no build alternative would force reliance on another alternative, all of which are demonstrated to be infeasible in the following sections. For these reasons, the no build alternative does not fulfill the project need and purpose. Alternative 2: ALTERNATIVE SITES Alternative sites that might avoid or minimize wetland impact include the following: 1) expand existing facility in another direction, 2) expand another landfill, or 3) identify a new landfill site. These options are explored in depth below. Option 1— Expand Existing Facility in Another Direction This option makes several assumptions, namely that: 1) adjoining properties not owned by SKB can be obtained, 2) an expansion in a different direction would involve less wetland impact or impact to wetlands of lower function /value, 3) an expansion in another direction would allow the landfill to be operationally efficient and 4) zoning on adjacent property would allow use of the property as a landfill. As discussed in the paragraphs that follow, one or more of these assumptions cannot be overcome to make Option 1 feasible. With regards to the possibility of adjoining properties being available for purchase by SKB, none of the adjoining land is currently for sale and none is zoned appropriately. The property to the north and west is owned by Flint Hills Resources, is zoned General Industrial and is mostly developed with existing industries. Given the site ownership and use and the fact that the current zoning would not allow landfill use, these sites are not viable. Additionally, those areas are separated from the SKB facility by railroad tracks and Minnesota State Highway 55, effectively eliminating any possibility of expansion in those areas. The zoning of the adjoining property to the south is Agricultural and is owned by Great River Energy. The land to the east is also zoned Agricultural and includes some residences. The Agricultural Zoning District does not allow landfilling as an allowed use 11Appendix C or as a conditional use and rezoning any of the adjacent land to allow for landfilling is highly unlikely. With regard to wetland impacts, an expansion of the landfill to the east would appear to involve farmland, none of which contains any mapped wetlands or mapped hydric soils. From a purely wetland impact standpoint, an expansion in this direction would probably have no impacts. Operationally, expansion to the east is the only potentially viable option other than the proposed project because roads and railroads abut the landfill property on the north, south and west. However, even if it were possible to acquire the property to the east, the aforementioned zoning problems would make landfill expansion on this site highly improbable. An expansion to the northwest would similarly appear to have no wetland impacts; however, the current ownership and zoning considerations make this option infeasible. Expanding to the south would necessitate the filling of a wetland identified as #679 on the City's inventory and would appear to have wetland impacts of similar magnitude as the proposed project. Although wetlands south of the property have not been delineated as part of this project, wetland #679 appears to be of similar size as the wetland proposed to be filled. However, it is designated as "Manage II" and, therefore, is classified in a category of lower function /value than #438 (Wetland B). Even if wetland impacts would be comparable or reduced by expanding to the south, zoning considerations make this option infeasible as discussed above. Also, landfill operations and systems would not function efficiently since this option assumes that the proposed expansion area would be left intact which would require a separated landfill area to be developed south of 140th Street. Such an expansion would not be feasible or operationally practicable. Option 2: Expand Another Landfill As described in Appendix B, the need for additional disposal capacity of industrial waste and C &D continues to increase as the available disposal capacity in the area served by SKB decreases. As previously explained, SKB services primarily industrial customers in the Metropolitan Area. The proposed expansion area would primarily manage industrial waste but would also be permitted to accept C &D. The only other landfills that compete somewhat with SKB in similar or adjoining market areas are Advanced Disposal Services in Monticello Township (Wright County), Veit in Becker (Sherburne County), Waste Management in Glencoe (McLeod County) and Dem -Con in Louisville Township (Scott County). Even without the SKB expansion, these other landfills also have limited disposal volumes and may likely also need to expand to service their customers in the near future. Option 3: Identify a New Landfill Site In 2004, Burnsville Sanitary Landfill applied for wetland permits to allow an expansion of its demolition /construction landfill. During that permit process, the U.S. Army Corps of Engineers requested a study of non - metallic mine sites in Dakota County under the 21 Appendix C presumption that such sites might be a viable alternative that would have less wetland impact than expansion at their existing facility. A comprehensive study of 101 mining sites was completed. Besides several fatal flaws (such as conflicting end use plans, inadequate size, etc.), the primary issue with these sites was the inability to obtain local zoning approval for a new landfill. After this study, the Corps concluded that, for those reasons stated, there were no alternative sites available for that project. This conclusion is considered valid for the proposed SKB expansion since its findings are relatively recent and cover nearly an identical service area. To further this point, from 1980 to 1992 the Metropolitan Council and seven metropolitan counties conducted a $20 million dollar search for candidate MSW (municipal solid waste) landfill sites. Eight sites were eventually identified, ranging from 150 to 400 acres in size. All were located in rural, agricultural areas. Development moratoriums were imposed on all of these properties that lasted for years. For these and other reasons, this siting process was ultimately terminated by the state Legislature. The difficulty in siting a new landfill, as evidenced by the time and expense of the Metropolitan Council siting study and the moratoriums which were issued in response to the study, is due primarily to public /governmental policy and the "not in my backyard" attitude of residents that would be affected by a new landfill. The results of the Metropolitan Council landfill siting process are still valid today. Practicable alternatives did not exist previously and do not exist today. This determination is based upon the conclusion that the predominant cause of failure of the previous study, (i.e., local opposition resulting in failure to obtain local zoning approval), is as prevalent today as it was when the previous study was terminated 21 years ago. The SKB site does have zoning approval from the City of Rosemount for the intended future use as a landfill (Waste Management District). Alternative 3: ALTERNATIVE CONFIGURATIONS The proposed project would occupy the remaining property owned by SKB Environmental, Inc. at this location; therefore wetland impacts cannot be further reduced through an alternative design. The added disposal capacity that would be provided by the proposed project is limited by the property boundaries but also by the allowable vertical limits of the landfill. Allowable height of the landfill is not only limiting in terms of elevation but also dictates the disposal capacity that is possible with the proposed expansion. The project plan conforms with the property boundary setback requirements. Even with these constraints, only a portion of the projected landfill capacity need can be provided at SKB regardless of the development configuration. 31 Appendix C Alternative 4: ALTERNATIVE TECHNOLOGIES In the 2007 SWMCB report (see Appendix B), it is estimated that as much as 68% of industrial waste is contaminated soil for which there is no viable beneficial use apart from use as landfill daily cover. As previously stated, the vast majority of industrial waste is not recyclable or is already the residual of a previous recycling process. For most of the materials taken at the SKB landfill, there are no other viable means of disposal other than to place them in a landfill approved for such materials. Even with current and foreseeable technologies, there will be wastes for which no other disposal method is available other than to place them in landfills like the SKB facility. COMPENSATORY MITIGATION PLAN The total wetland impacts for the project are 9.49 acres (Wetland A = 0.33 acre; Wetland B = 9.16 acres). At a 2:1 ratio, this equates to a total of 18.98 acres of compensatory mitigation credit needed per the Wetland Conservation Act. No on -site compensatory mitigation is proposed since the project would occupy the remaining property owned by SKB. SKB worked with the City of Rosemount for several months in an attempt to locate a suitable wetland mitigation site within the city but was unsuccessful. For these reason, wetland bank credits are proposed as the means to replace unavoidable wetland impacts. The primary bank proposed to be used is the Bachman Wetland Bank, Account #1144, which is located near Farmington and is in the same watershed ( #38- Mississippi River Red Wing /Lake Pepin) and in the same Bank Service Area (8) as the project site. SKB is currently working on a Purchase Agreement with the bank owner to purchase the remaining balance of the bank (minus two transactions currently underway). The balance of the Bachman Bank that will reamin after these two transactions take place will be 17.8373 acres. The credits to be purchased include Type 3 and 4 wetlands as well as upland buffer; however, all of these credits are listed in the bank as Standard Wetland Credits (SWC). A second wetland bank purchase of 1.14 acres will be necessary to provide the total of 18.98 acres for the impacts at a 2:1 ratio. Wetland banks in the same major watershed ( #38) were first considered; however, only one other bank (Goodhue County) exists in this watershed. Wenck contacted Mr. John Schuler, Deputy Director of Construction for Goodhue County Highway Department, on August 29, 2013 and was told that their credits were not for sale. Banks in the same Wetland Bank Service Area ( #8) were then explored. The criteria for bank selection was that they had to have Corps approval (in case the Corps assumes jurisdiction on the project) and needed to be of sufficient size. Only two banks were identified (Account No. 1475 and 1473) that met these criteria although there were two other banks that appeared to meet the criteria that we were unable to contact. Based on these criteria, Bank Account No. 1475 in Jackson County was identified as the source for the balance of the credits. SKB has been in contact with this bank owner and is pursuing a Purchase Agreement for 1.14 acres of credit. 41 Append ix C Appendix D - Status of Other Approvals 1. City of Rosemount — Construction Permit (to be applied for) 2. Metropolitan Council Waste Water Discharge Permit — issued 3. MPCA Industrial Stormwater Permit — issued 4. MPCA Solid Waste Permit —issued with modification and renewal pending 5. Dakota County Solid Waste License — issued with modification and renewal pending 6. Rosemount IUP —issued with modification and renewal pending 1JAppendix D Appendix E — Wetland Delineation Report 1JAppe❑dix D ��A j���t Wenck File #03053 -01 ry K Julv 2013 Engineers • Scientists Business Professionals Wetland Delineation Report Prepared for: SKB ENVIRONMENTAL WENCK ASSOCIATES, INC. 1802 Wooddale Drive Suite 100 Woodbury, Minnesota 55125 (651) 294 -4580 Table of Contents 1.0 INTRODUCTION ............................................................................ ............................1 -1 2.0 SITE DESCRIPTION ......................................................................... ............................2 -1 3.0 METHODS ..................................................................................... ............................3 -1 4.0 RESULTS ....................................................................................... ............................4 -1 4.1 Wetland A ............................................................................... ............................4 -1 4.2 Wetland B ............................................................................... ............................4 -3 5.0 CONCLUSION ................................................................................ ............................5 -1 N: \Technical \3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.doa July 2013 Wenck Table of Contents (Cont.) FIGURES 1 Site Location Map 2 National Wetlands Inventory Map 3 Soil Survey Map 4 DNR Public Waters Inventory 5 Delineated Wetland Location Map 6 City of Rosemount Wetland Inventory Map APPENDICES A Field Data Sheets B Photographs C Historic Aerial Photographs N: \Technical \3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Table of contents pg 2.docx July 2013 Wenck 1.0 Introduction Wenck Associates, Inc. ( Wenck) staff conducted a wetland delineation on the subject property in Rosemount, Minnesota. This report documents findings from a site visit conducted on April 30, 2013. Wetlands are defined in the Federal Register (1982) as "areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas." An area must have three characteristics to be delineated as a wetland (unless considered an "Atypical Situation" or a "Problem Area ") per the 1987 Corps of Engineers Wetlands Delineation Manual: 1) Greater than 50% dominance of hydrophytic plant species. 2) Hydric soils per the "Field Indicators of Hydric Soils in the United States ", Version 7.0 3) Indicators of wetland hydrology during the growing season. 1 -1 N: \Technical \3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.docx ��July 2013 Yoe r 1c \ J 2.0 Site Description The subject site is located immediately north of 140th Street and approximately one mile west of U.S. Highway 52. The legal description of the site is a portion of the SE % SE % Section 19 and a portion of the SW' /< SW % Section 20, T115N, R18W, City of Rosemount, Dakota County, Minnesota (Figure 1). The area reviewed is in the southwest corner of the existing SKB Environmental facility. Topography of the area reviewed is rolling with wetlands occupying lower landscape positions and uplands typically characterized by red cedar (luniperus virginiona), upland hardwoods and old field. Climatic conditions leading up to the delineation had been unseasonably cool and precipitation was above normal. Growing season was documented by the presence of actively growing vegetation throughout most of the site. Species noted that were actively growing included Kentucky bluegrass (Poo pratensis), stinging nettle (Urtica dioica), and willows (Salix spp.) that had just started breaking bud. 2 -1 NATechnicaN3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\New section 2.0.docx ��S July J /u ll y�'"20013 3.0 Methods The wetland investigation was conducted by Wenck staff using the on -site methodology set forth in the 1987 U.S. Army Corps of Engineers Wetlands Delineation Manual and the 2012 U.S. Army Corps of Engineers Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Midwest Region. Potential wetland areas were examined according to guidelines set forth in these documents and wetland boundaries were determined through analysis of the vegetation, soils, and hydrology. Plant species at both wetland and upland transect points were identified and assigned a wetland indicator status according to the North American Digital Flora: National Wetland Plant List, version 2.4.0 U.S. Army Corps of Engineers, Engineer Research and Development Center, Cold Regions Research and Engineering Laboratory, Hanover, NH, and BONAP, Chapel Hill, NC. (2012). In the text of this report and on the enclosed data forms, the plant indicator status follows the plant's scientific or common name unless a status has not been assigned. According to the 1987 Manual and "Regional Supplement" cited above, the hydrophytic plant criteria are met when more than 50% of the dominant species within all vegetative strata are assigned an obligate (OBL), facultative wet (FACW), or facultative (FAC) wetland status. The presence of wetland hydrology was determined through direct observation of primary and /or secondary wetland hydrology indicators. The presence of a single primary indicator such as surface water is sufficient to conclude that the wetland hydrology parameter is met. The direct observation of two or more secondary wetland hydrology indicators such as surface soil cracks is required to conclude that the wetland hydrology criteria is met. Hydric soil properties described follow Field Indicators of Hydric Soils in the United States (Untied States Department of Agriculture, Natural Resources Conservation Service. 2010. Field Indicators of Hydric Soils in the United States, Version 7.0 G.W. Hurt and C.V. Noble (eds.). USDA, NRCS, in cooperation with the National Technical Committee for Hydric Soils). Soils were examined and characterized by digging soil pits at sample points along designated transects. If the soils exhibited indicators of hydric soils per the "Field Indicators" manual cited above, they were determined to be hydric. Soil colors described herein follow Munsell Soil Color Charts. Wenck classified the wetlands under the U.S. Fish and Wildlife Service (FWS) Cowardin system, Circular 39 and Eggers and Reed methodologies. 3 -1 N: \Technical \3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.docx July 2013 __ Wend 4.0 Results The National Wetlands Inventory (NWI) (Figure 2) indicates two wetlands within the undeveloped southwestern portion of the property. The NWI wetland to the north was permitted to be filled in a previous permit application. The larger wetland on the site (Wetland B) is mapped as Type 3 (shallow marsh) by the NWI. The Dakota County Soil Survey map (Figure 3) identifies Marshan soils in the larger wetland and Estherville soils in the other wetland (Wetland A) to the east that was delineated by Wenck. The Minnesota DNR Inventory of Public Waters (Figure 4) does not indicate any MN DNR Public Waters within the subject property. The boundaries of two wetlands were delineated on the subject property. Field notes were taken at wetland and upland transect points and investigation points along the boundary of the wetlands, and information was recorded on field data forms (Appendix A). The delineated wetland boundaries were located with an SX Blue GPS unit with sub -meter accuracy and are shown on Figure 5. Ground photographs were taken and are shown in Appendix B. The City of Rosemount's wetland inventory map (Figure 6) indicates a wetland boundary consistent with that delineated for Wetland B. The City inventory maps the same wetland to the north of Wetland B that is also maped on the NWI that was previously permitted. Wetland A is not indicated on the City inventory but had been identified in a previous delineation done in 2006. Another basin identified in the City inventory as 682 had been evaluated during the 2006 delineation and was determined to be non - wetland. This conclusion was apparently agreed to by the City as its listed Management classification is NJ (Non - Jurisdictional). 4.1 WETLAND A Wetland A is located in the southeastern corner of the property adjacent the north side of 140th Street. It is a small, isolated basin of 0.33 acres and is very marginal as far as quality. We would classify the basin as seasonally flooded, palustrine (Circular 39 Type 1, Cowardin Type PEMA, Eggers and Reed Seasonally Flooded Basin). The wetland appears to rely primarly on surface drainage from the surrounding area. The basin was investigated along a transect on its northwest boundary as indicated in Figure 5. Secondary indicators of wetland hydrology indicators included geomorphic position (Indicator D2) and surface soil cracks (Indicator 136). No primary hydrology indicators were present. The upland did not exhibit any wetland hydrology indicators. Wetland soils investigated at the transect location revealed 10YR 2/1 silt loam with 10YR 5/8 redoximorphic features over 10YR 3/1 fine sandy loam with 10YR 5/8 redoximorphic features. Hydric soil indicator F6 (Redox Dark Surface) was present in the wetland soil profile. The upland soil pit at the transect did not exhibit any hydric indicators and the soil is characterized as 10YR 2/2 loamy fine sand over 10YR 3/2 loamy fine sand. 4 -1 N: \Technical \3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report \Wetland Delineation Report.docz July /(4 i 2(0133 Y Y nck The dominant vegetation in the wetland includes stinging nettle (Urtica dioica, FACW), Canada thistle (Cirsium arvense, FACU) and giant goldenrod (Solidago gigantea, FACW) (Appendix A). Dominant upland vegetation includes red cedar (Juniperus virginiano, FACU), a species of hawthorn (probably downy hawthorn, Crataegus mollis, FAC), and Kentucky bluegrass (Poa pratensis, FAC). The wetland boundary was delineated along a fairly distinct change in vegetation, a transition from loamy to sandy soils and where the adjacent upland slope met the edge of the basin. 4 -2 N: \Technical\3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.docx ��JJjuly 200`1�J3 Y M enck 4.2 WETLAND B Wetland B is located just west of Wetland A immediately north of 140th Street and is classified as a complex of saturated, palustrine, emergent and seasonally flooded, palustrine, emergent (Circular 39 Type 2 /Type 3, Cowardin Type PEMB /PEMC, Eggers and Reed Fresh (Wet) Meadow /Shallow Marsh). This basin appears to have grown significantly in size between 1997 and 2003 (see historical aerials in Appendix C), possibly due to stormwater management changes. The basin boundaries are fairly consistent in the historical aerials from 1937 to 1997 and then the basin appears to nearly double in size. Further investigation would be required to determine whether a portion of it may be excluded from the Wetland Conservation Act rules as since it may be an "incidental wetland "(MN Rules 8420.0105 Subp. 2 D). Much of the basin is mapped within non - hydric soils (Wadena, Kennebec, Estherville, Hawick). It was not within the scope of this effort to determine the historic character or jurisdictional status of Wetland B; however, further investigation may be necessary. The basin was investigated along a transect on its southwestern boundary. Primary indicators of wetland hydrology observed in the wetland included shallow surface water (Indicator Al) in the interior of the wetland as well as aquatic fauna (snail shells). Geomorphic position (indicator D2) is also present as a secondary indicator. Wetland soils investigated at the transect location revealed 10YR 2/1 silt loam with 10YR 4/6 redoximorphic features over 10YR 4/2 silty clay loam with 10YR 5/6 redoximorphic features. Hydric soil indicator Al2 (Thick Dark Surface) was present in the wetland soil profile. The upland soil pit at the transect did not exhibit any hydric indicators and the soil is characterized as 10YR 3/1 loamy fine sand over 10YR 2/2 fine sandy loam. The dominant vegetation in Wetland B includes reed canary grass (Phalaris arundinacea, FACW) and giant goldenrod. Dominant upland vegetation includes red osier dogwood (Cornus alba, FACW), Kentucky bluegrass and Canada goldenrod (Solidago canadensis, FACU). 4 -3 N: \Technical\3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.doa ��July 2013 5.0 Conclusion The boundaries of two wetlands were identified and delineated per the scope of this report. Activities which impact or potentially impact wetlands are currently regulated at several levels of government. No grading, draining or filling in wetland basins should commence until all necessary permits have been obtained. This wetland delineation meets the standards and criteria described in the 1987 U.S. Army Corps of Engineers Wetlands Delineation Manual and the results represent the conditions present at the time of the field investigation. I certify that this plan, document or report was prepared by me and that I am a Certified Wetland Delineator under the laws of the State of Minnesota. If you have any questions, please feel free to call me at (651) 395 -5229. Sincerely, f j if July 3, 2013 Mike Graham, MN C.W.D. #1179 Date 5 -1 N: \Technical\3053 Waste Connections \01 Rosemount Wetland Delineation \Delineation Report\Wetland Delineation Report.docx July 2013 Figures s • . r • d ., .. .,. Spring �- Lake 7 \ � i ff" e • ��4 v A t • r f � c � O t -w , G. r *wk is er P. .... _ .... i V �� a - 41! nom, �'^...✓'."" �j���j t.^� �`a.i.. f 4 � ��; � /�„ M.. ,., ,... _ ously, Approved Fill Area re v P i 24 _ alley 11 TM o .,BYRE.. s "° ;mod WetlandA Wetland B— 6551 R „=' ''/`; �`�,` �,„� �`"'`"..,) �� v° -'"``, Jai- ��•�,� ��' . ;, ;�' "tea �, .� ,o,•s+EU esz Ramsey • A • �_ �.- `�'" _'' -... County . Ct Hennepin \ A'•� County Washington County Inver Grove Heights 7.5 Minute Quadrangle (USGS: 1993) ice^ tom,f St. Paul Pakr 7.5 Minute Quadrangle (USGS: 1993) ( - ❑ Coates 7.5 Minute Quadrangle (USGS: 1993) �''`_ J\ Dakota Vermillion 7.5 Minute Quadrangle (USGS: 1993) N County 2,000 1,000 0 2,000 A Scott ' County !. Goodhue Rice County ath:L0dtS lte Location Map.mxd Feet Copyright: ©2011 N Count ate: 7 /8/:132013 7im53\01\mxeAA2:13AM User: ShuJCO243 SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Site Location Map Business Professionals Maple Plain, MN 55359-0429 Figure 1 www.wenck.com - .,,' I �a c <, E 4� Aerial Photograph (Source: Bing Maps) N 300 150 0 300 n Feet N ath: L\3053 \01 \mxd \National Wetland Inventory.mxd ate: 7 /8/2013 Time: 8:12.06 AM User: Sh.JCO243 Legend Wetland Boundaries National Wetland Inventory Circular 39 Seasonally Flooded (Type 1) Wet Meadow (Type 2) Shallow Marsh (Type 3) Deep Marsh (Type 4) Shallow Open Water (Type 5) Shrub Swamp (Type 6) Wooded Swamp (Type 7) Bogs (Type 8) Municipal and Industrial Activities Riverine Systems SKB ENVIRONMENTAL Wenck JULY 2013 [:Engineers - scientists 1800 Pioneer Creek Center National Wetland Inventory s Professionals Maple Plain, MN 55359 -0429 Figure 2 nck.com SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Public Waters Inventory Business Professionals Maple Plain, MN 55359 -0429 Figure 4 www.wenck.com Legend 7 o GPS Points +" - Transect Locations Wetland Boundaries" 4 *$ �! i • ,. tai x > a ep s � L lss i st Yc Q O C U C C: U VtAetland B O 9.t6ac. �. C 4CAGv�' .'v , f Aerial Photograph (Source: Bing Maps) N 300 150 0 300 n Feet N ath: L: \3053\01\mxd\Wellands.mxd ate: 7/8/2073 Time; 8:13:11 AM User. Shu JCO243 �d Y x F. C` e yy.�6 Oct", 0 �xO, * >. i�1q X44 O O O SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Approximate Wetland Boundaries Business Professionals Maple Plain, MN 55359 -0429 Figure 5 www.wenck.com c s�. ` E E E C'') O N i LL m � N dv c 4 U � Y � Z N o � N A, C l0 N W s a V o g m 0 � � E m m o N O U d � d m d 3 w m J C Q N Z _ w � c z O z � W 0 0 m E Y a) o Appendix C Historic Aerial Photographs Legend Approximate Subject Area 1940 Aerial Photograph (Source:HIG) 1,000 500 0 1,000 A ath: L: \3053V031mxd \Historic Aerials.mxd Feet SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 1940 Business Professionals Maple Plain, MN 55359 -0429 Appendix C www.wenck.com SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 1964 Business Professionals Maple Plain, MN 55359 -0429 Appendix C www.wenck.com 1-800-472-2232 —1 w 1979 Aerial Photograph (Source:H]G) 1,000 500 0 1,000 N N=MNq Feet lath: L:\3053k03\mxdkHist,,i,Aerials.mxd )ate: 71812013 Time:8:44,29AM U—ShWCO243 Legend Approximate Subject Area pit SK13 ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 1979 Business Professionals Maple Plain, MN 55359-0429 Appendix C d www.wenck.com 1-800-47)-99-A9 I I wv N R 1979 Aerial Photograph (Source:H]G) 1,000 500 0 1,000 N N=MNq Feet lath: L:\3053k03\mxdkHist,,i,Aerials.mxd )ate: 71812013 Time:8:44,29AM U—ShWCO243 Legend Approximate Subject Area pit SK13 ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 1979 Business Professionals Maple Plain, MN 55359-0429 Appendix C d www.wenck.com 1-800-47)-99-A9 I I "f Legend Approximate Subject Area 1997 Aerial Photograph (Source: Mn GEO) 1,000 500 0 1,000 N Feet TMWI Path: L: \3053 \03 \mxdlFiistoric Aer als mxd } .)ate: 7/812013 Time. 8:46 :45 AM User: ShWCO243 old SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 1997 Business Professionals Maple Plain, MN 55359 -0429 Appendix C www.wenck.com 71 Legend 11 � Approximate Subject Area ,., "bt'" 2003 Aerial Photograph (Source: Mn GEO) 1,000 500 0 1,000 N Feet ' e L/: 053\03\mxdHsoic Aerialsmd ) 78/2013 Time: 8:48:18 AM User: Sh,JCO243 SKB ENVIRONMENTAL 2003 Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Business Professionals Maple Plain, MN 55359-0429 Appendix C www.wenck.com M Legend Approximate Subject Area w A All y. '• r.w SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 2008 Business Professionals Maple Plain, MN 55359 -0429 Appendix C www.wenck.com 1-800-472 - SKB ENVIRONMENTAL Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center 2012 Business Professionals Maple Plain, MN 55359 -0429 Appendix C www.wenck.com Minnesota Wetland Conservation Act Notice of Decision Local Government Unit (LGU) Address City of Rosemount 2875145th St W Rosemount, MN 55068 1 PRnTF. T INFORMATION Applicant Name Project Name Date of Application Waste Connections /SKB SKB Site Application Number July 31, 1916 -780 2013 ® Attach site locator map. Type of Decision: ® Wetland Boundary or Type ❑ No -Loss ❑ Exemption ❑ Sequencing ❑ Replacement Plan ❑ Banking Plan Technical Evaluation Panel ❑ Approve and Recommendation ❑ Approve with conditions ❑ Deny Summary (or attach): Dennis Rodacker (BWSR) and Dave Holmen (SWCD) were contacted during the comment period and they did not have any comments on the wetland delineation. 2. LOCAL GOVERNMENT UNIT DECISION Date of Decision: August 19, 2013 ® Approved ❑ Approved with conditions (include below) ❑ Denied LGU Findings and Conclusions (attach additional sheets as necessary): Waste Connections /SKB submitted a wetland delineation and MnRAM assessment for Wetland A and B. Wetland A is a 0.33 acre Type 1, PEMA wetland. Wetland B is a 9.16 acre Type 2/3, PEMB /C wetland. The wetland delineation was reviewed in the field by Andi Moffatt (WSB & Associates) on behalf of the City of Rosemount on July 3, 2013. The wetland delineation is approved. Any review of MnRAM data and associated weland classification will be made by City Staff or City Council outside the formal WCA process. BWSR Forms 7 -1 -10 Pagel of 3 I . rm -__ - - -A:4.- 4___ +U- Q +� +n \xla +land Rang ror iCC li1GG1iLG11L r1Z111J Bank Account # UAUl vaouaw uvaaa as Bank Service Area County Credits Approved for NA NA NA Withdrawal (sq. ft. or nearest .01 Signature Date Phone Number and E-mail acre) 8/21/13 NA Replacement Plan Approval Conditions. In addition to any conditions specified by the LGU, the approval of a Wetland Replacement Plan is conditional upon the following: ❑ Financial Assurance: For project - specific replacement that is not in- advance, a financial assurance specified by the LGU must be submitted to the LGU in accordance with MN Rule 8420.0522, Subp. 9 (List amount and type in LGU Findings). ❑ Deed Recording: For project - specific replacement, evidence must be provided to the LGU that the BWSR "Declaration of Restrictions and Covenants" and "Consent to Replacement Wetland" forms have been filed with the county recorder's office in which the replacement wetland is located. ❑ Credit Withdrawal: For replacement consisting of wetland bank credits, confirmation that BWSR has withdrawn the credits from the state wetland bank as specified in the approved replacement plan. Wetlands may not be impacted until all applicable conditions have been met! -- n. LVU L-1UU1v 1LGU al uawlw. Signing and mailing of this completed form to the appropriate recipients in accordance with 8420.025.5, _ Subp. 5 provides notice that a decision was made by the LGU under the Wetland Conservation Act as specified above. If additional details on the decision exist, they have been provided to the landowner and are available from the LGU upon request. Name Title Andrea Moffatt, WSB & Associates Principal Signature Date Phone Number and E-mail / 8/21/13 amoffatt@wsbeng.com amoffatt@wsbeng.com THIS DECISION ONLY .APPLIES TO THE MINNESOTA WETLAND CONSERVATION ACT....: Additional approvals or. permits from local, state, and federal agencies may be required.. Check with all appropriate authorities before commencing work in or near wetlands. Applicants proceed at their own risk if work authorized by this decision is started before the time period for appeal (30 days) has expired. If this decision is reversed or revised under appeal, the applicant may be responsible for restoring or replacing all wetland impacts. This decision is valid for three years from the date of decision unless a longer period is advised by the TEP and specified in this notice of decision. 3. APPEAL OF THIS DECISION Pursuant to MN Rule 8420.0905, any appeal of this decision can only be commenced by mailing a petition for appeal, including applicable fee, within thirty (30) calendar days of the date of the mailing of this Notice to the following as indicated: vaavv....a.... - ® Appeal of an LGU staff decision. Send ❑ Appeal of LGU governing body decision. Send petition and $500 fee (if applicable) to: petition and $500 filing fee to: Eric Zweber Executive Director City of Rosemount Minnesota Board of Water and Soil Resources 2875145`h St W 520 Lafayette Road North Rosemount, MN 55068 St. Paul, MN 55155 BWSR Forms 7 -1 -10 Page 2 of 3 4. LIST OF ADDRESSEES ® SWCD TEP member: David Holmen ® BWSR TEP member: Dennis Rodacker ® LGU TEP member (if different than LGU Contact): Eric Zweber ® DNR TEP member: Melissa Doperalski, Jennie Skancke ❑ DNR Regional Office (if different than DNR TEP member) ® WD or WMO (if applicable): Mark Zabel, Vermillion JPO ® Applicant and Landowner (if different) ❑ Members of the public who requested notice: ® Corps of Engineers Project Manager ❑ BWSR Wetland Bank Coordinator (wetland bank plan decisions only) 5. MAILING INFORMATION ➢For a list of BWSR TEP representatives: www.bwsr.state.mn.us/aboutbwsr/workareas/WCA areas.pdf ➢For a list of DNR TEP representatives: www.bwsr.state.mn.us/wetlands/wca/I)NR TEP contacts.Ddf DnPnnrtmP.nt nfNat,►ral 1 escrurces Regional Offices: NW Region: NE Region: Central Region: Southern Region: Reg. Env. Assess. Ecol. Reg. Env. Assess. Ecol. Reg. Env. Assess. Ecol. Reg. Env. Assess. Ecol. Div. Ecol. Resources Div. Ecol. Resources Div. Ecol. Resources Div. Ecol. Resources 2115 Birchmont Beach Rd. 1201 E. Hwy. 2 1200 Warner Road 261 Hwy. 15 South NE Grand Rapids, MN 55744 St. Paul, MN 55106 New Ulm, MN 56073 Bemidji MN 56601 For a map of DNR Administrative Regions, see: bm:Hfiles.dnr.state.mn.us/aboutdnr/dnr reaions.ndf ➢For a list of Corps of Project Managers: www.mvl2.usace.g=.mil/regu—latoU,/�dcfauft.asp?pageid=687 or send to: US Army Corps of Engineers St. Paul District, ATTN: OP -R 180 Fifth St. East, Suite 700 St. Paul, MN 55101 -1678 ➢For Wetland Bank Plan applications, also send a copy of the application to: Minnesota Board of Water and Soil Resources Wetland Bank Coordinator 520 Lafayette Road North St. Paul, MN 55155 6. ATTACHMENTS In addition to the site locator map, list any other attachments: ® Location figure and Wetland delineation map BWSR Forms 7 -1 -10 Page 3 of 3 • i e � i `� .� • � : � , }} }999''' • r j �n 1 `n r ' jjj5j\ Spring ..�, �. Lake 17 61 C.-`` , , { R , Gra e,.P�,� p.1 ' a , Previously- Approved Fill Area chy 1L07H SIRE $48 .f .._.. .:..._..._. \_,WetlandA CoursPWetland`B z { ti " ;. M , M • r .w ' p TREE 145Ik ST act �.`. °29 � o r R U S E x Ramsey • t w r, �,s' �„r r — County Hennepin County Washington r County Inver Grove Heights 7.5 Minute Quadrangle (USGS: 1993) `y St. Paul Pakr7.5 Minute Quadrangle (USGS: 1993) Coates 7.5 Minute Quadrangle (USGS: 1993) Dakota Vermillion 7.5 Minute Quadrangle (USGS: 1993) Nf County Scott 2,000 1,000 0 2,000 k County Goodhue Feet Rice County Path: 02 /20/305 ime:9x13Site Location - Map.mxd ShuJC0 Ctlpyflg ht.© 2013 N Date: 7l2 /2D13 Time: 9:'13:47 PM User. ShuJC 0243 County WASTE CONNECTIONS Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Site Location Map Business Professionals Maple Plain, MN 55359 -0429 Figure 1 www.wenck.com x ,w. r Aerial Photograph (Source: Bing Maps) N 300 150 0 300 Feet N ath: C:\o SM53101\mzd\Wetlands.mzd ate: 712/2013 Ti— 9:07:16 PM User: ShuJCO243 WASTE CONNECTIONS Approximate Wetland Boundaries 0 f3 O o s1r, o t W a ♦ x o q O 0 ' . °,,° x w. � ao Oa O ^a. O O 2 Wenck JULY 2013 Engineers - Scientists 1800 Pioneer Creek Center Business Professionals Maple Plain, MN 55359 -0429 Figure 5 www.wenck.com s� ENVIRONMENTAL July 23, 2013 Dwight Johnson City Administrator Rosemount City Hall 2875 145th St. W. Rosemount, MN 55068 -4997 RE: SKB Environmental Wetland Mitigation Potential Sites Mr. Johnson, After receiving clear direction from the City Council and Staff at the July 10th Workshop to explore all possible opportunities for sites to construct wetlands within the City, SKB Environmental (SKB) met with City Staff and representatives from WSB & Associates and Wenck Associates. At this follow up meeting, five potential sites were identified that had not been previously explored. SKB has contacted all of the site owners /representatives to assess their level of interest in selling or making their land available for the construction of a new wetland. The results of our discussions are summarized below: Private Land Currently for Sale at Dodd Road and MN Hwy 3 We spoke with Sheila Lange, a realtor with Coldwell Banker Burnet who represents the property. Ms. Lange indicated that their intent was to sell the 55 -acre property as a single property to a developer and had no interest in parceling out smaller parcels for wetland construction. She also indicated that the construction of a new wetland would not be advantageous for a future developer. Private Land Owned by Great River Energy (Located South of SKB) We spoke with Tim Steinbeck with Great River Energy (GRE). Mr. Steinbeck indicated that GRE is not interested in selling or making their land available for wetland construction. The primary reason cited was that construction of a new wetland may hinder future development or sale of the property. Private Land Owned by CF Industries (Located North of SKB) We spoke with Pete Dutchak with CF Industries. Mr. Dutchak inquired with their Corporate Office and CF Industries is not interested in selling or making their land available for the construction of a new wetland. 251 Starkey St. • P.O. Box 7216 • St. Paul, MN 55107 Printed on Recycled Paper. 651 - 224 -6329 • FAX 651 - 223 -5053 Public Park Land Owned by Dakota County We spoke with Steve Sullivan, Director of the Dakota County Parks Department. Mr. Sullivan indicated that there were no sites available at this time that would work for new wetland construction. Private Land Owned by Yocum Oil (Located East of US Hwy 52) We spoke with Tony Yocum with Yocum Oil. Mr. Yocum indicated that Yocum Oil is not interested in selling or making the land available for new wetland construction. The primary reason cited was that construction of a new wetland may hinder future development or sale of the property. Having explored and exhausted all potential opportunities for constructing new wetlands, it is unfortunate that there no viable opportunities at this point time. If the City would like to now pursue the option of SKB purchasing wetland bank credits, please let us know as soon as possible, as these credits are not currently secured. SKB would again like to thank the City and Staff for all of their effort and assistance in this process. yincerely, Jo n Domke Divisional Vice President CC 4- TECHNICAL MEMORANDUM TO: Eric Zweber, Andi Moffatt, City of Rosemount FROM: Mike Graham, Wenck Associates, Inc. Copy: John Domke, Geoff Strack, SKB Environmental DATE: August 9, 2013 SUBJECT: Wetland Mitigation Potential of McAndrews Road Site On July 19, 2013, Wenck and SKB staff met with City staff in regards to a proposed expansion of the SKB Environmental Rosemount Landfill facility and, specifically, to discuss potential sites for replacing wetland impacts should a Wetland Conservation Act (WCA) replacement plan be ultimately approved. At the direction of the City, Wenck Associates, Inc. conducted a delineation of existing wetlands and evaluated the above - referenced site for potential wetland mitigation credit as part of the ongoing review of SKB Environmental's proposed facility expansion. Prior to field work, the City provided a sketch indicating three areas on the site where they thought there might be potential to create wetland from upland adjacent to existing wetlands. The wetland delineation /mitigation evaluation was conducted on August 6, 2013. The site is located immediately north of McAndrews Road, immediately west of South Robert Trail (Hwy. 3) and immediately east of Dodd Road near the north boundary of Rosemount. Three wetlands were identified and their on -site boundaries delineated per the 1987 Corps of Engineers Wetlands Delineation Manual (including the Midwest Regional Supplement) (see attached figure). The purpose of this memorandum is to provide a brief synopsis of the on -site wetlands and an evaluation of the site's potential for generating wetland mitigation credits per WCA. This memorandum is not intended to be a complete wetland delineation report. Wetland A is located in the southwestern portion of the site and is predominantly a shallow marsh (Type 3) wetland with a fringe of floodplain forest (Type 1). There are a few small interior areas that are scrub - shrub (Type 6) dominated by willows (Salix spp.). The wetland encroaches, on some areas along the the west side, into areas that are currently planted to corn. Overall the wetland is dominated by narrow- leaved cattail (Typho angustifolia). The City's sketch indicated a potential mitigation area on the west side of Wetland A. The wetland delineation appears to indicate the existing wetland is somewhat larger than the boundary assumed in the City's sketch which may make the potential size of the wetland smaller than that assumed. Soils in the upland area /potential mitigation area are mapped by the Web Soil Survey as Mahtomedi loamy sand and Crystal Lake silt loam. Mahtomedi loamy sands are well drained loamy sands and sands with a depth to water table exceeding 80 inches according to the soil survey. The soil survey indicates slopes to C:\ Users \ehz \AppData \Local \Microsoft \Windows \Temporary Internet Files\ Content .Outlook \U016HPLQ \Technical Memo.docx Wenck Associates, Inc. We n c k 1802 Wooddale Drive Suite 100 Engineers •Scientists Woodbury, MN 55125 -2937 Business Professionals (651)294 -4580 Fax(651)228 -1969 wenckmp @wenck.com www.wenck.com TECHNICAL MEMORANDUM TO: Eric Zweber, Andi Moffatt, City of Rosemount FROM: Mike Graham, Wenck Associates, Inc. Copy: John Domke, Geoff Strack, SKB Environmental DATE: August 9, 2013 SUBJECT: Wetland Mitigation Potential of McAndrews Road Site On July 19, 2013, Wenck and SKB staff met with City staff in regards to a proposed expansion of the SKB Environmental Rosemount Landfill facility and, specifically, to discuss potential sites for replacing wetland impacts should a Wetland Conservation Act (WCA) replacement plan be ultimately approved. At the direction of the City, Wenck Associates, Inc. conducted a delineation of existing wetlands and evaluated the above - referenced site for potential wetland mitigation credit as part of the ongoing review of SKB Environmental's proposed facility expansion. Prior to field work, the City provided a sketch indicating three areas on the site where they thought there might be potential to create wetland from upland adjacent to existing wetlands. The wetland delineation /mitigation evaluation was conducted on August 6, 2013. The site is located immediately north of McAndrews Road, immediately west of South Robert Trail (Hwy. 3) and immediately east of Dodd Road near the north boundary of Rosemount. Three wetlands were identified and their on -site boundaries delineated per the 1987 Corps of Engineers Wetlands Delineation Manual (including the Midwest Regional Supplement) (see attached figure). The purpose of this memorandum is to provide a brief synopsis of the on -site wetlands and an evaluation of the site's potential for generating wetland mitigation credits per WCA. This memorandum is not intended to be a complete wetland delineation report. Wetland A is located in the southwestern portion of the site and is predominantly a shallow marsh (Type 3) wetland with a fringe of floodplain forest (Type 1). There are a few small interior areas that are scrub - shrub (Type 6) dominated by willows (Salix spp.). The wetland encroaches, on some areas along the the west side, into areas that are currently planted to corn. Overall the wetland is dominated by narrow- leaved cattail (Typho angustifolia). The City's sketch indicated a potential mitigation area on the west side of Wetland A. The wetland delineation appears to indicate the existing wetland is somewhat larger than the boundary assumed in the City's sketch which may make the potential size of the wetland smaller than that assumed. Soils in the upland area /potential mitigation area are mapped by the Web Soil Survey as Mahtomedi loamy sand and Crystal Lake silt loam. Mahtomedi loamy sands are well drained loamy sands and sands with a depth to water table exceeding 80 inches according to the soil survey. The soil survey indicates slopes to C:\ Users \ehz \AppData \Local \Microsoft \Windows \Temporary Internet Files\ Content .Outlook \U016HPLQ \Technical Memo.docx Technical Memo Wetland Analysis — McAndrews Road Site SKB Environmental August 9, 2013 be 3 -8 %. Wenck's field investigation confirms sandy soils in this area that would not lend themselves well to creating wetland. Groundwater would need to be the assumed hydrology source and, with a watertable exceeding 80 inches, creating wetland in this area is not advisable and would be risky. In these sandy soils, groundwater would need to be reliable to create wetland conditions and should be within six inches of the surface for at least 14 consecutive days during the growing season at a minimum. Even if this level of hydrology could be achieved, it would not represent "in- kind" replacement of the proposed wetland impacts which are Type 3 shallow marsh. It may be possible, however, to expand the existing wetland boundary to create Type 3 wetland in the proposed mitigation area if the groundwater table is somewhat above the proposed bottom elevation of the mitigation wetland. The biggest risk of this site would be the unknown /unreliable nature of the groundwater that would be necessary to create the wetland. If the City's sketch of a proposed mitigation wetland boundary were followed, up to four feet of existing soils would need to be removed to create the wetland. A significant amount of hydric topsoil would need to be imported from an unknown source to topdress the sandy soils in the mitigation wetland. The City's sketch indicated two other potential mitigation areas — one that would join Wetlands B and C and another that would be created along the southern boundary of wetland C. The western proposed mitigation area appears to fairly accurately follow the field delineation but it does not appear that the more eastern proposed mitigation area would be able to be constructed as large as indicated on the sketch. Soils in both of these upland /potential mitigation areas are mapped by the Web Soil Survey as Kingsley - Mahtomedi- Spencer complex. This soil complex is well drained and is composed of sandy loam, loamy sands, sands, silt loams and sandy foams with a depth to water table exceeding 80 inches according to the soil survey. The soil survey indicates slopes to be 3 -8 %. Wenck's field investigation confirms sandy loam and loamy sand soils in this area that would not lend themselves well to creating wetland. Groundwater would need to be the assumed hydrology source and, with a watertable exceeding 80 inches, creating wetland in this area is not advisable and would be risky. In these sandy soils, groundwater would need to be reliable to create wetland conditions and should be within six inches of the surface for at least 14 consecutive days during the growing season at a minimum. Even if this level of hydrology could be achieved, it would not represent "in- kind" replacement of the proposed wetland impacts which are Type 3 shallow marsh. It may be possible, however, to expand the existing wetland boundary to create Type 3 wetland in the proposed mitigation area if the groundwater table is somewhat above the proposed bottom elevation of the mitigation wetland. The biggest risk of this site would be the unknown /unreliable nature of the groundwater that would be necessary to create the wetland. If the City's sketch of a proposed mitigation wetland boundary were followed, more than 10 feet of existing soils would need to be removed in some locatoins to create the wetland basins. A significant amount of hydric topsoil would need to be imported from an unknown source to topdress the sandy soils in these mitigation wetlands. While the City's desire to replace at least some of the proposed impacts of the project (again, assuming it ultimately is granted WCA approval) within the City is recognized, this site has several problems with soil types, unknowns with groundwater, high slopes, etc. that make it a less than desirable candidate for creating wetland credits. Minnesota Rules 8420.0522 Subp. 5 generally states that wetland restoration is preferred over creation and that mitigation sites should take advantage of naturally occurring 2 C:\ Users \ehz \AppData \Local \Microsoft \Windows \Temporary Internet Files \Content.Outlook \UOI6HPLQ \Technical Memo.docx Technical Memo Wetland Analysis — McAndrews Road Site SKB Environmental August 9, 2013 hydrogeomorphic conditions with minimal landscape alterations. It is recognized that wetland creations, if designed, implemented and managed well can be ecologically successful. However, the amount of credit that could be generated at this site when taking into account costs, site conditions and soil corrections makes it infeasible and unpractical. It is our recommendation that the McAndrews Road site be dropped from consideration as part of a mitigation plan for the SKB Environmental Rosemount Landfill project. C:\ Users \ehz \AppData \Local \Microsoft \Windows \Temporary Internet Files\ Content .Outlook \UOI6HPLQ \Technical Memo.docx o � N c� _m Q � N C U � �✓ a a °oa m� N `o J Q U) F- v Z W � N Z 0_ N Z W Zweber, Eric From: Michael J. Graham [mgraham @wenck.com] Sent: Monday, August 12, 2013 8:23 AM To: Zweber, Eric Cc: Geoff Strack; John Domke Subject: Soil Profiles Eric, I understand you were interested in the soil descriptions for the delineation work I did on the McAndrews Road site. Please see the attached graphic showing the delineated wetland boundaries and soil pit locations and the soil descriptions below: Wetland A Pit 1— wetland (furthest east pit in cattails): 0 -14" 10YR 2/1 silt loam; 14 -24" 10YR 3/1 silt loam w 10YR 4/6 redox 10% and 10YR 3/6 redox 10 %. Free water in pit was 10" below surface. Pit 2 — (just inside wetland boundary): 0 -5" 2.5Y 3/2 loamy sand; 5 -20" 2.5Y 3/2 loamy sand with 10YR 3/6 redox 10 %. Pit 3 — upland: 0 -9" 10YR 3/3 loamy sand; 9 -13" 10Yr 3/3 loamy sand with 10YR 3/6 redox 8 %; 13 -18" 10YR 5/4 sand with 10YR 3/6 redox 10 %. WPtlanrl R Pit 1— wetland: 0 -4" 2.5Y 4/2 silt loam (eroded overwash from upland); 4 -18" 2.5Y 4/1 silt loam with 10YR 4/6 redox 15 %; 18 -20" 10YR 5/1 silt loam with 10YR 4/6 redox 15 %. Free water in pit was 8" below surface. Pit 2 — upland: 0 -17" 10YR 4/4 sandy loam; 17 -20" 10YR 3/3 loamy sand Wetland C Pit 1— wetland: 0 -16" N 2/0 mucky silt loam; 16 -20" 10YR 2/1 silt loam with 10YR 3/6 redox 8 %. Free water in pit was 2" below surface. Pit 2 — upland: 0 -12" 10YR 3/2 sandy loam; 12 -18" 10YR 4/3 sandy loam Mike Mike Graham, P.W.S., M.W.D.C., Associate Wenck Associates Inc., 1802 Wooddale Drive, Suite 100, Woodbury, MN 55125 -2937 www.wenck.com I mgraham @wenck.com I D 651.395.5229 1 F 651.228.1969 1 G 651.294.4580 1 C 612.670.4209 TECHNICAL MEMORANDUM TO: Eric Zweber, Andi Moffatt, City of Rosemount FROM: Mike Graham, Wenck Associates, Inc. Copy: John Domke, Geoff Strack, SKB Environmental DATE: August 22, 2013 SUBJECT: Additional Soils Investigation - McAndrews Road Site During our conference call on August 14, 2013, one of the main issues discussed was the lack of hydrology information at the potential wetland creation site. A conceptual drawing had previously been supplied depicting three potential mitigation sites adjacent to existing wetlands (Appendix A) that were delineated by Wenck on August 6, 2013. The purpose of evaluating this site for mitigation potential is that SKB is proposing an expansion of its Rosemount Landfill facility and is considering potential sites for replacing wetland impacts should a Wetland Conservation Act (WCA) replacement plan be ultimately approved. In response to gathering additional hydrology and soil property data discussed in the phone conference, Wenck hand - augered five soil pits on the site as shown in Figure 1. The original plan had been to evaluate six soil pits; however, many upland areas on the site are very rocky which prevents hand - augering. In several cases, soil pits were partially excavated only to hit impenetrable rock at various depths. These depths were not adequate to properly assess the hydrology and soil conditions. In these cases, the originally - proposed soil pit locations were moved downslope to areas with less rock. Figure 2 shows the locations of the soil pits and existing edge of water /edge of Type 3 wetlands as well as wetland boundaries and transect locations from the wetland delineation work. Elevations of the delineation transect soil points, proposed mitigation soil pits, actual and projected groundwater at soil pit locations as well as edge of Type 3 /edge of water at existing wetlands is also shown. Following is an analysis of what was found in the soil pits, the relationship of this data to existing on -site wetlands and the implications this data may have in creating wetlands on the site. Soil Pit 1 Soil Pit 1 was excavated in the southwestern part of the site west of the west boundary of Wetland A. The elevation of the soil pit is 942.1'. The soil profile is described as: 0 -14" 10YR 5/4 sandy loam 14 -19" 10YR 5/4 clay loam 19 -23" 10YR 4/4 clay loam w/ 7.5YR 4/4 redox 23 -30" 10YR 5/3 clay loam w/ 10YR 5/6 redox N: \Technical\30S3 Waste Connections \06 McAndrews Delineation \Memo 8_21 13\Memo 08 22 13 \Technical Memo 08 22 13.docx Wenck Inc. �V 1802 Wooddal Dr 1802 Wooddale Drive �— \✓ i Suite 100 Engineers Scientists Woodbury, MN 55125 -2937 Business Professionals (651) 294 -4580 Fax(651)228 -1969 wenckmp @wenck.com www.wenck.com TECHNICAL MEMORANDUM TO: Eric Zweber, Andi Moffatt, City of Rosemount FROM: Mike Graham, Wenck Associates, Inc. Copy: John Domke, Geoff Strack, SKB Environmental DATE: August 22, 2013 SUBJECT: Additional Soils Investigation - McAndrews Road Site During our conference call on August 14, 2013, one of the main issues discussed was the lack of hydrology information at the potential wetland creation site. A conceptual drawing had previously been supplied depicting three potential mitigation sites adjacent to existing wetlands (Appendix A) that were delineated by Wenck on August 6, 2013. The purpose of evaluating this site for mitigation potential is that SKB is proposing an expansion of its Rosemount Landfill facility and is considering potential sites for replacing wetland impacts should a Wetland Conservation Act (WCA) replacement plan be ultimately approved. In response to gathering additional hydrology and soil property data discussed in the phone conference, Wenck hand - augered five soil pits on the site as shown in Figure 1. The original plan had been to evaluate six soil pits; however, many upland areas on the site are very rocky which prevents hand - augering. In several cases, soil pits were partially excavated only to hit impenetrable rock at various depths. These depths were not adequate to properly assess the hydrology and soil conditions. In these cases, the originally - proposed soil pit locations were moved downslope to areas with less rock. Figure 2 shows the locations of the soil pits and existing edge of water /edge of Type 3 wetlands as well as wetland boundaries and transect locations from the wetland delineation work. Elevations of the delineation transect soil points, proposed mitigation soil pits, actual and projected groundwater at soil pit locations as well as edge of Type 3 /edge of water at existing wetlands is also shown. Following is an analysis of what was found in the soil pits, the relationship of this data to existing on -site wetlands and the implications this data may have in creating wetlands on the site. Soil Pit 1 Soil Pit 1 was excavated in the southwestern part of the site west of the west boundary of Wetland A. The elevation of the soil pit is 942.1'. The soil profile is described as: 0 -14" 10YR 5/4 sandy loam 14 -19" 10YR 5/4 clay loam 19 -23" 10YR 4/4 clay loam w/ 7.5YR 4/4 redox 23 -30" 10YR 5/3 clay loam w/ 10YR 5/6 redox N: \Technical\30S3 Waste Connections \06 McAndrews Delineation \Memo 8_21 13\Memo 08 22 13 \Technical Memo 08 22 13.docx Technical Memo Additional Soils Investigation — McAndrews Road Site SKB Environmental August 22, 2013 30 -43" 10YR 6/2 silt loam w/ 10YR 5/6 redox 43 -44" 10YR 5/6 sand 44 -54" 10YR 5/3 clay (60% of matrix) and 10YR 5/6 sand (40% of matrix) 54 -64" 10YR 5/3 silt w/ 10YR 5/8 redox Free water was encountered at 62" (approx. 5.2 feet) below the surface. This would equate to a groundwater elevation of 936.9' at the soil pit location. The existing edge of standing water at Wetland A was located at elevation 937.8' so the groundwater is approximately one foot lower at the pit location than the standing water in the existing wetland. This would have to be taken into account when designing mitigation wetland in this area. Soil Pit 2 Soil Pit 2 was excavated in the north- central part of the site between Wetlands B and C. The elevation of the soil pit is 958.0'. The soil profile is described as: 0 -37" 10YR 5/6 silt loam 37 -44" 10YR 5/4 sandy loam w/ 7.5YR 4/6 redox 44 -66" 7.5YR 4/6 sand w/ cobble and rock up to 2" in diameter 66 -83" 10YR 5/4 silt loam (75% of matrix) and 7.5YR 4/6 sand (25% of matrix) 83 -90" 10YR 5/4 sand 90 -95" 10YR 6/6 sand At 95 ", rock was encountered and further penetration was not possible. Sands were damp from 79" and deeper. Based on soil moisture near the bottom of the pit, the water table is estimated to be within one foot of the pit bottom (107 "). Adding this foot would equate to a groundwater elevation of 949.1' at the soil pit location. The existing wetland edge of the Type 3 wetland in Wetland C is 949.6' which is fairly consistent with the estimated groundwater table at the soil pit location. Based on this data, groundwater appears to be reliable to provide suitable hydrology for a created wetland basin at this location. Soil Pit 3 Soil Pit 3 was excavated in the north- central part of the site near the east boundary of Wetland B. The elevation of the soil pit is 952.1'. The soil profile is described as: 0 -11" 10YR 4/3 sandy loam 11 -24" 10YR 5/6 silt loam 24 -41" 10YR 5/6 sandy loam (50% of matrix) and 10YR 5/4 silt loam (50% of matrix) w/ 10YR 5/8 redox 41 -47" sandy silt loam w/ 10YR 5/8 redox At 47 ", rock was encountered and further penetration was not possible. Soils were somewhat damp at 47 ". Depth to groundwater is difficult to estimate at this pit but would be expected to be at least a foot lower than the pit bottom which would put it at an approximate elevation of 947.2'. The existing edge of water in Wetland B is 950.1' which seems to indicate that the groundwater table drops approximately N:\ Technical \3053 Waste Connections \06 McAndrews Delineation \Memo 8_21 13\Memo 08 22 13 \Technical Memo 08 22 13.docx Technical Memo Additional Soils Investigation — McAndrews Road Site SKB Environmental August 22, 2013 three feet between Wetland B and Soil Pit 3 (a distance of about 50 feet). Even if groundwater in the pit was assumed to be present at the bottom of the soil pit (47" below the surface), which it was not, the groundwater would still be two feet lower than the existing water level in Wetland B. Based on this data, groundwater appears to be at an inconsistent elevation in this area which could make wetland creation problematic. Soil Pit 4 Soil Pit 4 was excavated in the north- central part of the site southwest of Wetland B. The elevation of the soil pit is 957.4'. The soil profile is described as: 0 -10" 10YR 6/4 loamy sand 10 -78" 10YR 5/6 sand 78 -91" 10YR 5/3 sandy silt w/ 10YR 5/6 redox 91 -113" 10YR 5/6 sand Free water was encountered at 110.5" (approx. 9.2 feet) below the surface. This would equate to a groundwater elevation of 948.2' at the soil pit location. The existing wetland edge of water at Wetland B was located at elevation 950.1' so the groundwater is approximately two feet lower at the pit location than the standing water in the existing wetland (a distance of about 90 feet). Based on this data, groundwater appears to be at an inconsistent elevation in this area which could make wetland creation problematic. Soil Pit 5 Soil Pit 5 was excavated in the southeastern part of the site south of the Wetland C boundary. The elevation of the soil pit is 952.5'. The soil profile is described as: 0 -10" 10YR 4/3 sandy loam 10 -21" 10YR 5/3 loamy sand 21 -33" 10YR 5/3 sandy clay w/ 10YR 5/8 redox 33 -41" 10YR 5/4 sandy clay w/ 10YR 5/8 redox 41 -54" Gley 16/10Y clay w/ 10YR 5/8 redox (80% of matrix) and 10YR 4/3 sandy clay (20% of matrix) 54 -64" 2.5Y 5/3 sand w/ 10YR 5/6 redox Free water was encountered at 61" ( approx. 5.1 feet) below the surface. This would equate to a groundwater elevation of 947.4' at the soil pit location. The existing edge of Type 3 wetland at Wetland C nearest the soil pit was located at elevation 949.9' so the groundwater is approximately 2.5 feet lower at the pit location than the edge of Type 3 in the existing wetland (a distance of about 45 feet). Based or this data, groundwater appears to be at an inconsistent elevation in this area which could make wetland creation problematic. N: \Technical3053 Waste Connections \06 McAndrews Delineation \Memo 8_21 13\Memo 08 22 13 \Technical Memo 08 22 13.docx Technical Memo Additional Soils Investigation — McAndrews Road Site SKB Environmental August 22, 2013 Summary The data from the five soil pits shows that groundwater is not at a consistent elevation across the site. This is readily apparent from the 10 feet of elevation difference between Wetland A (approximate elevation 940') and Wetlands B and C (approximate elevation 950'). This difference in elevation between the wetland systems is not inherently problematic since the proposed mitigation areas would be expansions of one or the other system. However, groundwater elevations at every soil pit location are lower than the elevations of standing water or Type 3 boundary in the adjacent wetland. Of the five soil pits dug on the site, three (Soil Pits 3, 4 and 5) show a substantial drop in groundwater elevation compared to the existing wetlands over a relatively short distance. This is concerning for the creation of a successful self- sustaining wetland since groundwater would have to be the primary hydrology source of mitigation wetlands constructed at the locations proposed by the City. There is not a reliable source of hydrology (i.e. groundwater) and the existing soils are not appropriate for wetland construction. Due to the difficulty with soil correction and due to the unreliable hydrology of the site, the use of this property to create a self- sustaining wetland is far too risky. As it is, this site is not conducive to wetland creation due to the impracticality of site construction and of capital and future management necessary to establish viable, self- sustaining wetlands. Furthermore, due to the unreliable hydrology at the site, the creation of additional wetland could have adverse effects on the existing wetlands. It is our recommendation that the McAndrews Road site be dropped from consideration as part of a mitigation plan for the SKB Environmental Rosemount Landfill project. 4 N:\ Technical \3053 Waste Connect ions \06 McAndrews Delineation \Memo 8_21 13 \Memo 08 22 13 \Technical Memo 08 22 13.docx N 974 m g96�A 016 °gs 9L6 9C6 c ,fFZL6 ! 996 976 q�b C � a o o CL rn > ❑ w _ = Sys 99s Jpa�nn • • o V V \�`_ 9g6 Z 05 969 956 p \ \ 996 096 ZS6y6 960 966 m 6 0 6b • 096 916 8L6 "���Cj � •—� �� 964 P/( �• g66 r' 66 9 (_i 950 6p q66 9 C C9$5 ( 660 666 � 1 ✓• a 956 958 966 m p9C6� °ys 096 966 91b m Sy Og6 m n u _ 6� 996 °9s t 9L6 966 996 6 096 3'� `tom Z96 96b = _ 9 960 Z96 96 e9e (a 960 i/ r n6 a Aec "6 938 Aa x 56 H i�9ss446a 969 m 9 ; _ 'O m 936 m`o ,n m m °y °w • a " 930 _^ w of E � e ° � 0 QggA C °0@9F6 � //J 99fi e 969 g c 96fi 9 U 'o O N N O Q � V _ yi Eo ul o J Z w NZ LL � Z w C co Y 0 U) Version 8 /08rev ENVIRONMENTALAsSESSMENT WORKSHEET Note to preparers: This form and EAW Guidelines are available at the Environmental Quality Board's website at: httn: / /www.ecib. state. mn. us /EnvRevGuidanceDocuments.htm. The Environmental Assessment Worksheet provides information about a project that may have the potential for significant environmental effects. The EAW is prepared by the Responsible Governmental Unit or its agents to determine whether an Environmental Impact Statement should be prepared. The project proposer must supply any reasonably accessible data for — but should not complete — the final worksheet. The complete question as well as the answer must be included if the EAW is prepared electronically. Note to reviewers: Comments must be submitted to the RGU during the 30 -day comment period following notice of the EAW in the EQB Monitor. Comments should address the accuracy and completeness of information, potential impacts that warrant further investigation and the need for an EIS. 1. Project title SKB Rosemount Industrial Waste Facility Expansion 2. Proposer SKB Environmental, Inc. Contact person John Domke Title Division Landfill Manager Address 251 Starkey Street City, state, ZIP St. Paul, Minnesota, 55107 Phone 651- 224 -6329 Fax 651- 223 -5053 E -mail johndo@wasteconnections.com 3. RGU City of Rosemount Contact person Eric Zweber AICP Title Senior Planner Address 2875 145`h Street West City, state, ZIP Rosemount, MN, 55068 Phone 651- 322 -2052 Fax 651- 423 -4424 E -mail eric.zweber @ci.rosemount.mn.us 4. Reason for EAW preparation (check one) _EIS scoping X_ Mandatory EAW _Citizen petition _ RGU discretion _Proposer volunteered If EAW or EIS is mandatory give EQB rule category subpart number and subpart name: Minn. R. 4410.4300, subp. 27 5. Project location County Dakota SE '/4 '/4 Sections 19, 20, 29 City /Township City of Rosemount Township 115 N Range 18W GPS Coordinates 44.4449 N 93.0059 W Tax Parcel Number 34- 01900 -75 -012 Attach each of the following to the EAW: • County map showing the general location of the project; • U.S. Geological Survey 7.5 minute, 1:24,000 scale map indicating project boundaries (photocopy acceptable); • Site plan showing all significant project and natural features. Tables, Figures, and Appendices attached to the EAW Figure 1: Location Map Figure 2: United States Geological Survey 7.5 Minute, 1:24,000 scale map including project boundaries Figure 3: Aerial Photo Figure 4: Natural features within the site Figure 5: Existing Conditions and Environmental Monitoring Locations Figure 6: Base Grades Cells 1 -6 Figure 7: Base Grades Cell 6 Figure 8: Groundwater Contour Map Figure 9: Zoning Map Figure 10: Proposed Wetland Impact Figure 11: PWUNWI Map Figure 12A: Surface Geology Figure 12B: Bedrock Geology Figure 13: Soils Attachment 1: Copy of Letter from the Minnesota Department of Natural Resources (DNR) Natural Heritage Program. 6. Description a. Provide a project summary of 50 words or less to be published in the EQB Monitor. SKB Environmental Inc. is proposing to expand its Rosemount, Minnesota landfill (the SKB Rosemount Industrial Waste Facility) by permitting a 50 foot vertical expansion and a 15 acre horizontal expansion of the currently permitted Cell 6. With this expansion, SKB is applying for additional disposal capacity for industrial solid waste, construction and demolition debris. b. Give a complete description of the proposed project and related new construction. Attach additional sheets as necessary. Emphasize construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes. Include modifications to existing equipment or industrial processes and significant demolition, removal or remodeling of existing structures. Indicate the timing and duration of construction activities. SKB Environmental, Inc. (SKB) is located in northeast Rosemount (Figures 1 -3) on 1401h Street E, east of US52. SKB is proposing an expansion for the SKB Rosemount Industrial Waste Facility (Facility) (Figure 6 -7). As part of the expansion, SKB is applying for additional permitted capacity for industrial solid waste and construction and demolition (C &D) debris. The proposed expansion will add 50 feet to the height of the landfill and add approximately 15 acres to the currently permitted Cell 6 footprint. SKB is requesting an increase in its industrial waste from its currently permitted capacity of 15,464,483 cubic yards to 25,052,076 cubic yards. Additionally, SKB is proposing to co- dispose of C &D debris within the permitted industrial waste disposal areas. Because of changes of co- disposal of C &D within the industrial waste disposal areas and changing the phasing boundary between the C &D disposal area and the industrial waste disposal area, SKB is proposing to lower the permitted capacity of the C &D cell from 8,752,613 cubic yards to 7,490,591 cubic yards. SKB is not proposing to change the permitted capacity of the Municipal Solid Waste combustor ash disposal area. The expanded Cell 6 would be located to the project south of the currently permitted footprint of Cell 6 (see Figure 3). Cell 6 will accept both industrial solid waste and construction and demolition debris. The cell will be lined with one of two liner profiles. The first would consist, from the bottom to the top, of a geosynthetic clay liner (GCL), 60 -mil high density polyethylene (HDPE) liner, drainage composite, 80 -mil HDPE liner, drainage composite, and at least one foot of protective sand. This is the liner profile that has been constructed at the site for the most recent liner construction projects. SKB has also proposed an alternate liner profile. This liner profile, from the bottom to the top, would consist of 60- mil HDPE liner, GCL, 80 -mil HDPE liner, drainage composite, and at least one -foot of protective sand. After reaching final elevations, the expanded landfill and Cell 6 would be capped with a 40 -mil linear low density polyethylene (LLDPE) liner and two feet of soils. The final determination on the type of liner will be based on permitting. The expansion of Cell 6 will also involve filling the wetland within the site (Figure 10). A wetland delineation will be required to be completed and submitted to the City as the Local Government Unit (LGU) for approval. Conservatively, this wetland is estimated at 9.35 acres. This wetland impact is required to be reviewed under the Wetland Conservation Act and the City of Rosemount's Wetland Management Plan. Avoidance and minimization ( "sequencing ") will be required to be provided by the applicant. However, it is anticipated for this environmental review that all of the wetland will be impacted for this project. If sequencing is met, mitigation will be provided off -site in conformance with the City's Wetland Management Plan. This wetland has also been noted by the DNR as, in the past, used by a variety of birds. This area has also been noted on the Central Region Regionally Significant Ecological Area (RSEA) and is ranked high (Figure 4). An RSEA information was developed by the DNR to identify ecologically significant areas based on aerial photo interpretation and Minnesota Land Cover Classification System Data. The expansion of Cell 6 would result in the conversion of this area from wetland and grassland to eventual grassland as part of the reclamation process for the Facility. As part of the wetland delineation and permitting process, this area will be reviewed by the City and the Technical Evaluation Panel. If this area is high quality, this will be taken into consideration of the wetland replacement plan. The Facility will continue to be expanded and filled in phases. Once areas of the landfill have reached final grades, those areas will be closed. In general, Cell 6 will be constructed once Cell 3 has been completed. Based on existing capacity of the Facility, this phasing could occur within 7 -11 years. c. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The purpose of this project is to provide for continued regional disposal services such as waste processing, recycling, and disposal for the region as part of an integrated waste management system. The Facility provides disposal of C &D waste, along with non - hazardous industrial waste and municipal solid waste combustor ash. Expanding to use more onsite land and increasing the final permitted elevation would maximize capacity within the existing property, thus utilizing an existing resource rather than sighting a new landfill at a new location. The design is intended to enhance the end use capabilities and create grassland and scattered tree habitat for wildlife. The final cover will utilize grasses on the four to one slopes. The cover will have better erosion control features after closure and will be maintained as part of post - closure. Some of the potential end uses for the property include open space, grasslands or recreational. d. Are future stages of this development including development on any other property planned or likely to happen? _Yes _X_No If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review. There are no plans for future development at this time e. Is this project a subsequent stage of an earlier project? X Yes _No If yes, briefly describe the past development, timeline and any past environmental review. The Facility has prepared a number of environmental review documents since the project started. Each time, the outcome of the review was approval of the project based on a negative declaration of need for an Environmental Impact Statement. LANDFILL HISTORY On January 8, 1992, Union Pacific Railroad (UPRR) was granted by the State of Minnesota a "Permit for the Construction and Operation of an Industrial Waste Land Disposal Facility ". The facility was named "Minnesota Industrial Containment Facility, SW -383" (MICF). The MPCA issued its five -year permit on January 8, 1992. The original design consisted of ten cells. Each six -acre cell had a capacity of 252,000 cubic yards with a total site life of 30 years. The City of Rosemount granted an Interim Use Permit (IUP) in 1992, which has also continued to be reissued. In December 1992, the Metropolitan Council, as the RGU, completed an environmental review of the MICF, now referred to as SKB Rosemount Industrial Waste Facility, according to Minn. Stat. 116D.04 and 116D.045 and Minn. R. 4410.0200 through 4410.7800. The initial permit authorized construction and operation of Cells 1 -3. In early 1995, UPRR sold the "Minnesota Industrial Containment Facility, SW -383" to Laidlaw, Inc. of South Carolina. In August of 1997, the name of the facility was changed to "Laidlaw Environmental Services (Rosemount), Inc., SW -383" (LES). A Dakota County license was also granted by in 1997 and has continued to be reissued. In 1996, in conjunction with Laidlaw's five -year permit renewal, a permit modification was submitted by the MPCA. For this permit renewal and modification, nine of the ten original cells were combined to form Cells 2 through 4, with each cell being divided into sub - cells. Since Cell 1 has been operational for the previous five years, the permit conditions for that cell were modified to increase the cell capacity by 86,442 CY to 338,442 CY. In 1997, LES submitted a permit application to the MPCA that allowed the Facility to accept MSW incinerator ash for disposal in a monocell in Cell 4. This action was initiated after Hennepin County identified Laidlaw as the low bidder to provide transportation and disposal services for ash produced at the Hennepin County Resource Company (HERC) facility. HERC is a municipal solid waste -to- energy plant located in Minneapolis. It provides approximately 90,000 tons per year of MSW combustor ash. Because LES Rosemount requested a permit modification to allow for MSW incinerator ash disposal, which was not considered in the original EIS, representatives of Laidlaw and the MPCA indicated that supplemental environmental review would be required. The supplement to the original LES was completed in 1997 for the addition of MSW combustor ash to the LES Rosemount facility. In early 1998, Laidlaw, Inc. purchased the Safety Kleen Corporation and in August of 1998 changed the name to "Safety Kleen (Rosemount), Inc., SW- 383." In June of 2000, Safety Kleen Corporation sold the facility to SKB Environmental, Inc. of St. Paul, Minnesota. SKB changed the name of the facility to "SKB Rosemount Industrial Waste Facility, SW- 383." The permit was reissued by MPCA to SKB, reflecting the change in ownership, on August 2, 2000. In 2003, SKB submitted an EAW for the Facility with the MPCA as the RGU. The project under review was the horizontal expansion for Cell 5 and the vertical expansion to fill saddle areas between the existing waste cells. The environmental review was approved based on negative declaration of need. The permit was modified in April 2003, an MPCA Facility Permit Reissuance Application was submitted in November 2007. In 2008, SKB submitted an EAW for the Facility with the MPCA as the RGU. The environmental review occurred in conjunction with the 2007 Major Modification Permit Application for the Facility. The project under review was the horizontal and vertical expansion of the Facility to include an additional Cell (Cell 6) and increase the Facility waste capacity to 15,434,853 CY. The environmental review was approved based on negative declaration of need. The permit was reissued on October 3, 2008. In April 2008, SKB submitted an Application for Major Modification which was subsequently approved and issued by MPCA on April 22, 2009. Under the current permit the Facility is currently accepts demolition debris, industrial waste, municipal solid waste combustor ash and, a not yet constructed solid waste recycling and transfer station. 7. Project magnitude data Total project acreage 236 Number of residential units: unattached attached maximum units per building Commercial, industrial or institutional building area (gross floor space): total square feet Indicate areas of specific uses (in square feet): Office 2500 (existing) Manufacturing 0 Retail 0 Other industrial 0 Warehouse 2500 (existing) Institutional 0 Light industrial 30,000 (future — reviewed under previous 2008 EAW) Agricultural 0 Other commercial (specify) 0 Building height 30 feet (previously reviewed in 2008 EAW) If over 2 stories, compare to heights of nearby buildings No additional buildings are required with the proposed Cell 6 expansion. 8. Permits and approvals required. List all known local, state and federal permits, approvals and financial assistance for the project. Include modifications of any existing permits, governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minnesota Rules, Chapter 4410.3100. Unit of Government Type of Aaalication Status MPCA Solid Waste Permit Issued/expires October, 2013/a lication in-process MPCA Industrial Stormwater Permit Issued Dakota County Operators License Issued/expires 2014 City of Rosemount Interim Use Permit Issued /expires October, 2013 /in process City of Rosemount Wetland Conservation Act Approval Pending 9. Land use. Describe current and recent past land use and development on the site and on adjacent lands. Discuss project compatibility with adjacent and nearby land uses. Indicate whether any potential conflicts involve environmental matters. Identify any potential environmental hazards due to past site uses, such as soil contamination or abandoned storage tanks, or proximity to nearby hazardous liquid or gas pipelines. The land the Facility is located on is currently zoned as Waste Management District by the City of Rosemount (Figure 9). The Facility is located in an area of heavy industrial land uses. This industrial area is known as the Pine Bend Industrial Area. Within this industrial area, the Facility is surrounded by heavy industrial facilities, such as an aluminum smelter, a wastewater lift station, a food waste processing plant, an asphalt hot mix plant, and an oil refinery among others. There are also agricultural areas surrounding the Facility as well. The Facility expansion is totally within the current property boundary and is compatible with the surrounding areas. Land uses adjacent to the north and northwest are industrial; land uses to the west are public /institutional; land uses to the east and south are golf courses and agricultural. The City of Rosemount's 2030 Comprehensive Guide Plan identifies the site as Waste Management, areas to the north and west as General Industrial, and areas to the south and east as Industrial/Mixed land uses. Further, the City's Zoning Ordinance identifies the Facility as Waste Management Districts and areas to the north and west of the site as Industrial Districts. Based on the historical pattern of industrial development moving southeastward through the Pine Bend Area, the types of future development anticipated by the City of Rosemount, as stated in the Comprehensive Guide Plan and the City's Zoning Ordinance, will continue to be industrial and waste management uses. 10. Cover types. Estimate the acreage of the site with each of the following cover types before and after development: Before After Before After Types 1 -8 wetlands 9.35 0.0 Wooded /forest 0.0 0.0 Brush/Grassland 61.79 46.84 Cropland 0.0 0.0 TOTAL 237.8 237.8 If Before and After totals are not equal, explain why: Lawn /landscaping 0.0 0.0 Impervious surfaces 10 10 Stormwater Pond 4.85 14.36 Permitted Landfill 151.81 166.6 11. Fish, wildlife and ecologically sensitive resources a. Identify fish and wildlife resources and habitats on or near the site and describe how they would be affected by the project. Describe any measures to be taken to minimize or avoid impacts. The site is currently brush/grassland and approximately 9 acres of wetland (Figure 10). The project will involve the excavation and filling of the area and upon restoration, will be replaced with open grassland with some trees and shrubs throughout the site. The grasslands would be constructed in phases as the cells reach final grades and the final cover is constructed. Therefore, the total acreage of existing grasslands at the Facility would not significantly change during the operation and would increase after closure of the Facility. The landfill cells are filled in succession which, upon reaching final waste grades; the final cover will be constructed. The phasing plan illustrating the proposed filling succession will be submitted with the MPCA Permit Renewal Application. A wetland delineation will be required to be completed and submitted to the City as the Local Government Unit (LGU) for approval. The proposed horizontal expansion of Cell 6 would result in impact of the remaining wetland in the area (approximately 9.35 acres). This wetland impact is required to be reviewed under the Wetland Conservation Act and the City of Rosemount's Wetland Management Plan. Avoidance and minimization ( "sequencing ") will be required to be provided by the applicant. However, it is anticipated for this environmental review that all of the wetland will be impacted for this project. If sequencing is met, mitigation will be provided off -site in conformance with the City's Wetland Management Plan. This wetland has also been noted by the DNR as, in the past, used by a variety of birds. This area has also been noted on the Central Region Regionally Significant Ecological Area (RSEA) and is ranked high (Figure 4). An RSEA information was developed by the DNR to identify ecologically significant areas based on aerial photo interpretation and Minnesota Land Cover Classification System Data. The expansion of Cell 6 would result in the conversion of this area from wetland and grassland to eventual grassland as part of the reclamation process for the Facility. As part of the wetland delineation and permitting process, this area will be reviewed by the City and the Technical Evaluation Panel. If this area is high quality, this will be taken into consideration of the wetland replacement plan. b. Are any state - listed (endangered, threatened or special concern) species, rare plant communities or other sensitive ecological resources on or near the site? X Yes _No If yes, describe the resource and how it would be affected by the project. Describe any measures that will be taken to minimize or avoid adverse impacts. Provide the license agreement number (LA -__) and /or Division of Ecological Resources contact number (ERDB 20130220) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources. Indicate if any additional survey work has been conducted within the site and describe the results. The DNR was contacted to obtain information about threatened and endangered species (see Attachment 1). The information from the DNR indicates that the Loggerhead Shrike, a threatened species, was documented within the project boundary. SKB has taken actions to maintain and improve shrike habitat within their property. The perimeter fence will be left in place and available for shrikes to use. The final end use will provide some trees and shrubs, but primarily grassland. The project will also be constructed in phases so that as new cells are opened during operations, another one is closed and vegetated. This will continue to provide shrike habitat areas even during facility operations. Following final closure, the overall habitat will be enhanced. SKB also plans to minimize the use of pesticides on the final cover vegetation. The final end use will provide trees, shrubs, grasslands, and storm water ponds per the approved closure plan. The final cover will be planted with grasses and the tree planting may include hawthorn plum trees. The cells at the Facility will be filled in phases which, upon reaching final waste grades, will be covered in accordance with the phased filling plan and will be submitted with the MPCA Permit Renewal Application. This will allow shrike habitat areas even during facility operations. Following final closure, the overall habitat will be enhanced. SKB also plans to minimize the use of pesticides on the final cover vegetation. If the Facility expansion will result in the construction or disturbance of suitable nesting habitat during the breeding season of April — July, SKB will be required to contact DNR to determine if additional study is needed. 12. Physical impacts on water resources. Will the project involve the physical or hydrologic alteration — dredging, filling, stream diversion, outfall structure, diking, and impoundment of any surface waters such as a lake, pond, wetland, stream or drainage ditch? _X—Yes _No If yes, identify water resource affected and give the DNR Public Waters Inventory number(s) if the water resources affected are on the PWI: NA Describe alternatives considered and proposed mitigation measures to minimize impacts. The DNR PWI and the National Inventory Wetland (NWI) maps were reviewed. There are no PWI or water bodies are within 800 feet of the property boundary. Figure 11 depicts the PWI and NWI water bodies in relation to the Landfill property. The expansion of Cell 6 is anticipated to impact all of the 9.35 acres of the wetland at the site (Figure 10). SKB is will be working with the City of Rosemount through the Wetland Conservation Act (WCA) and the City's Wetland Management Plan permitting process to address sequencing and mitigation for the wetland that are on -site. SKB has hired a consultant to update the wetland delineation that was done in the past. Mitigation will be provided off -site in conformance with the City's Wetland Management Plan. The project does include the construction of storm water ponds to treat and store surface water from the Facility. Existing drainage ditches will be redesigned and constructed to prevent the runoff of site sediment during construction, operation and after final closure. 13. Water use. Will the project involve installation or abandonment of any water wells, connection to or changes in any public water supply or appropriation of any ground or surface water (including dewatering)? _Yes _X_No If yes, as applicable, give location and purpose of any new wells; public supply affected, changes to be made, and water quantities to be used; the source, duration, quantity and purpose of any appropriations; and unique well numbers and DNR appropriation permit numbers, if known. Identify any existing and new wells on the site map. If there are no wells known on site, explain methodology used to determine. This project does not involve installation or abandonment of any water wells. Nor does the project involve any connections or changes to connections to public water supply or appropriations of either ground or surface water. 14. Water - related land use management district. Does any part of the project involve a shoreland zoning district, a delineated 100 -year flood plain, or a state or federally designated wild or scenic river land use district? _Yes _X—No If yes, identify the district and discuss project compatibility with district land use restrictions. The Facility is not in a shoreland zoning district, 100 -year flood plain, or a state or federally designated wild or scenic river land use district. 15. Water surface use. Will the project change the number or type of watercraft on any water body? _Yes _X—No If yes, indicate the current and projected watercraft usage and discuss any potential overcrowding or conflicts with other uses. 16. Erosion and sedimentation. Give the acreage to be graded or excavated and the cubic yards of soil to be moved: 15 acres; cubic yards Total excavation: 967,417 cy; Total fill: 770,302. Describe any steep slopes or highly erodible soils and identify them on the site map. Describe any erosion and sedimentation control measures to be used during and after project construction. No naturally- occurring steep slopes, or highly erodible soils are present on the proposed Project site. However, upon closure of the Facility there will be some upper side slopes designed with maximum 25 percent grades and 2:1 slope ratios on the lower portion of berm along the south property line of the Facility. The final slopes will have storm water benches and downchutes to control and direct storm water to the sedimentation basins. To mitigate any potential erosion, erosion control practices may include the use of silt fencing, drainage channels, erosion control berms, and infiltration ponds. Construction and operation of the landfill area will disturb only a limited area of the overall site and in a phased manner. At the conclusion of landfilling, a final cover will be constructed over any remaining open landfill cells. All final cover will be seeded. Storm water controls are incorporated on the final cover slopes including, but not limited to: berms and drainage diversion ditches to reduce the potential for erosion of the side slopes. 17. Water quality: surface water runoff a. Compare the quantity and quality of site runoff before and after the project. Describe permanent controls to manage or treat runoff. Describe any storm water pollution prevention plans. Storm water management at the Facility provides for the control of surface water drainage resulting from precipitation events both on the SKB property and areas that drain onto the Facility. Storm water drainage facilities are constructed for the following purposes: (1) to modify existing storm water infiltration areas to increase capacity to assure that downstream flow from the Facility is not increased; (2) to construct control facilities to convey runoff from areas outside of the disposal cells to the storm water infiltration areas; and (3) to collect precipitation falling on an open cell to prevent release of this storm water from the cell. The storm water management plan for the Facility consists of facilities to control runoff inside and outside of the cells. The control facilities outside of the cells control runoff from precipitation that falls outside of the cells whereas the control system inside of the cells controls runoff from precipitation which falls inside of the cells. The control facilities outside of the cells consist of a series of storm water basins with accompanying drainage ditches designed to hold runoff from a 100 -year, 24 hour precipitation event occurring over the site area, plus the NURP storage volume from a 2.5 year storm, as required by the city of Rosemount. Control of storm water inside the cells consists of providing sufficient storage to totally contain storm water within the cell from a 100 year, 24 hour precipitation event. Storm water that comes in contact with waste will be treated as leachate. As the cells are constructed, the storm water management ditches will be constructed to adequately manage and convey runoff to the storm water basins. Storm water drainage ditches and retention/infiltration basins will be modified and constructed as needed during the construction of each sub cell to provide storm water management during the ongoing development of the Facility. b. Identify routes and receiving water bodies for runoff from the site; include major downstream water bodies as well as the immediate receiving waters. Estimate impact runoff on the quality of receiving waters. Currently, there are three on -site retention and infiltration ponds to accommodate the storm water that is generated on -site. These three ponds manage the storm water generated on -site and there are no direct storm water discharges to water bodies. At the completion of the Facility there will be a total of six storm water basins. 18. Water quality: wastewaters a. Describe sources, composition and quantities of all sanitary, municipal and industrial wastewater produced or treated at the site. SANITARY WASTEWATER The Facility discharges sanitary wastewater in quantities typical of a 2,500 square foot office to the Metropolitan Council Environmental Services Empire Waste Water Treatment Facility (MCES). INDUSTRIAL WASTEWATER (LEACHATE) Leachate is produced when precipitation comes into contact and percolates through the wastes in the landfill cells. The leachate generated at the Facility is collected by a series of pipes, which drain to the sumps in the landfill cells. The leachate is then pumped from the sumps into a gravity leachate line. The collected leachate will either be stored in the on -site storage tanks before being sent off -site for treatment, or will be piped directly to the Empire Wastewater Treatment Plant, which is owned and operated by the Metropolitan Council. b. Describe waste treatment methods or pollution prevention efforts and give estimates of composition after treatment. Identify receiving waters, including major downstream water bodies (identifying any impaired waters), and estimate the discharge impact on the quality of receiving waters. If the project involves onsite sewage systems, discuss the suitability of site conditions for such systems. Treatment of wastewater does not occur on -site and there is not discharge of wastewater to local water bodies. c. If wastes will be discharged into a publicly owned treatment facility, identify the facility, describe any pretreatment provisions and discuss the facility's ability to handle the volume and composition of wastes, identifying any improvements necessary. The wastewater discharged from the Facility is treated at the Empire Wastewater Treatment Facility, which is owned and operated by the Metropolitan Council. The industrial wastewater is discharged from the Facility per SKB's MCES Discharge Permit (Permit No. 2133). The Facility expansion will not increase the overall volume or change the parameters in the leachate. The current discharge permit has volume and concentration limits. The Facility is able to meet the discharge limits without any on- site pretreatment. The proposed project will not change SKB's compliance with its current discharge permit with the Metropolitan Council. 19. Geologic hazards and soil conditions a. Approximate depth (in feet) to ground water: 10 minimum 70 average; to bedrock: 30 minimum 113 average. Describe any of the following geologic site hazards to ground water and also identify them on the site map: sinkholes, shallow limestone formations or karst conditions. Describe measures to avoid or minimize environmental problems due to any of these hazards. A hydrogeological evaluation of the Facility was prepared by Environmental Engineering Management and submitted to the MPCA as Volume III of the January, 1991 Permit Application. Supplemental hydrologic data has been obtained through numerous soil borings performed during the operating life of the Landfill. Previous investigations at the Facility indicate the first bedrock unit encountered is the Prairie Du Chien (Figures 12A and B). The Prairie du Chien is composed of dolomite and sandy dolomite. The upper bedrock unit ranges in elevation from 795 feet above mean sea level (ft. msl) to just below 680 ft. relative to the National Geodetic Datum of 1929 (NGVD). This corresponds to an approximate depth below ground surface of 30 to 190 feet. The average depth to the upper bedrock unit is approximately 113 ft. The Prairie du Chien is hydraulically connected to the overlying glacial sediments and to the underlying Jordan Sandstone. Underlying the Jordan Sandstone is the St. Lawrence Formation which is underlain by the Franconia Formation. The St. Lawrence Formation is predominantly composed of sandy dolomite and dolomitic siltstone. The St. Lawrence Formation is predominantly composed of interbedded sandstone, siltstone and shale. The upper Franconia is a minor aquifer in this area of Dakota County. The lower Franconia and St. Lawrence act as regional confining units. The sandstone and dolomite bedrock units can provide significant quantities of groundwater for use by municipalities, industries and farmsteads. Groundwater generally flows to the northeast toward the Mississippi River, which acts as a minor discharge zone for the upper bedrock aquifers. Valleys have developed in the bedrock due to pre - glacial erosion. A major bedrock valley is located north of the Facility. This valley trends west - northwest to east - southeast and is approximately two and one -half miles wide. This valley has cut through the Prairie du Chien and Jordan units to an elevation of approximately 500 ft. NGVD. Smaller bedrock valleys have also been identified near the Facility. However, no geologic hazards such as sinkholes or other karst features have been identified beneath, or near the Facility. b. Describe the soils on the site, giving NRCS (SCS) classifications, if known. Discuss soil texture and potential for groundwater contamination from wastes or chemicals spread or spilled onto the soils. Discuss any mitigation measures to prevent such contamination. The soils at the Facility range from silty clay loam to sandy loam, with sandier soils predominating the area (Figure 13). Boring logs indicate the following American Society for Testing Materials (ASTM) classifications: SM, SP, SP -SM, ML, CL -ML and CH -ML. Specific soil series at the Facility include Hawick coarse sandy loam, Easterville sandy loam, Dickenson sandy loam, Kennebec silt loam, Marsham silty clay loam and Kato silty clay loam. These soils develop on glacial outwash, such as the sediments that underlay the Facility. Field information collected at the Facility indicates there is 30 to 130 feet of glacial sediments. These sediments were deposited by the Superior lobe glacial advances. Superior lobe outwash overlies a relatively thin Superior lobe sandy loam till. Minor lenses of finer- grained silts and clay have been noted in the outwash. The outwash unit is described as sand and gravel with cobbles. The underlying till is described as reddish -brown sandy loam with cobbles and boulders commonly encountered. The first groundwater is encountered within the outwash sand. Groundwater generally flows from the southwest to the northeast. Figure 8 shows the groundwater flow information. Due to the sandy nature of soils of at the Facility, the risk of groundwater contamination is present should liquid waste or chemicals be spilled or spread onto the soils. However, environmental monitoring, landfill cell design, which includes a liner with three barrier layers, liquid handling, and waste acceptance and handling plans minimize any risk of contamination to the underlying soil at the Facility. 20. Solid wastes, hazardous wastes, storage tanks a. Describe types, amounts and compositions of solid or hazardous wastes, including solid animal manure, sludge and ash, produced during construction and operation. Identify method and location of disposal. For projects generating municipal solid waste, indicate if there is a source separation plan; describe how the project will be modified for recycling. If hazardous waste is generated, indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments. The full Facility is designed and currently accepts non - hazardous industrial waste, municipal solid waste combustor ash and C &D debris. In addition to these waste types that are currently accepted, the Facility is currently permitted to accept mixed municipal solid waste, source separated compostable materials, yard waste, and various other recyclable materials. Each of the operating and permitted activities takes place or will take place in a state of the art waste management facility. These facilities exceed the requirements in Minnesota Rules. This includes a liner system with three barrier layers in the industrial solid waste disposal areas, thicker liner components in the mixed municipal solid waste combustor ash disposal area and the presence of a liner in the C &D debris disposal area. The compost area will also take place over these lined areas. Transfer operations will take place within a building. Recycling operations will take place either within a lined area of the Facility or within a structure. During construction excavated materials will be reused /recompacted for the exterior berm of the cell where possible. If there are any excess excavated soils not used for berm construction, they will be stockpiled onsite and used as cover materials for intermittent or final cover. Waste generated during construction of the landfill cell includes; geosynthetic liner material, geosynthetic fabric, and geosynthetic membrane remnants. Waste or scrap generated during construction will be disposed of within the active landfill cell. The permitted operations that may generate a waste product would be the composting operation and some of the recycling operations. The disposal areas of the Facility are able to manage residuals from these types of recycling operations. The landfill cell design employed by the Facility exceeds the MPCA guidance for Industrial Landfill Cell Design. b. Identify any toxic or hazardous materials to be used or present at the site and identify measures to be used to prevent them from contaminating groundwater. If the use of toxic or hazardous materials will lead to a regulated waste, discharge or emission, discuss any alternatives considered to minimize or eliminate the waste, discharge or emission. The Facility does not accept any toxic or hazardous materials and has a MPCA and Dakota County approved Waste Acceptance Plan that provides a detailed process for evaluating waste before it is accepted for disposal or processing. As outlined elsewhere in this document, the Facility is permitted to accept non - hazardous industrial solid waste, municipal solid waste combustor ash, C &D debris, mixed municipal solid waste, source separated compostable materials, yard waste, and source separated compostable material. The waste loads are sorted for recyclable materials prior to disposal. Unacceptable materials are rejected if found during load inspections. On site personnel will be responsible for visually inspecting all loads to ensure that prohibited materials are not unloaded on site. c. Indicate the number, location, size and use of any above or below ground tanks to store petroleum products or other materials, except water. Describe any emergency response containment plans. ABOVE GROUND STORAGE TANKS Currently, the Facility has four (4) aboveground storage tanks (ASTs) utilized for diesel fuel and three (3) stationary ASTs utilized for leachate storage. The diesel fuel storage ASTs are mobile tanks and are moved near the working face in each of the active landfill Cells (3, 4 and 5) for the purpose of fueling site equipment. The leachate ASTs do not contain petroleum products and are dedicated storage for leachate prior to offsite treatment. The total capacity of the three leachate ASTs is approximately 750,000 gallons. The secondary containment area for the leachate AST is constructed concrete basin, with a volume of 417,225 gallons. The secondary containment area volume can contain the contents of one AST plus volume generated by a 25 -year, 24 -hour rain event with enough freeboard to prevent leakage from the containment area. Each of the leachate ASTs was field constructed in 1991. Currently, one tank is operational and the remaining two can easily be readied as required. The leachate from the site is discharged to the MCES facility through leachate gravity pipeline. The expansion of the site does not require any additional AST's as part of operation. BELOW GROUND STORAGE TANKS Although the Facility does not have any below ground storage tanks, the Facility utilizes below ground leachate pipes used to transport leachate from each landfill cell off -site to the MCES sanitary sewer line. The underground pipelines are all double walled and placed sufficiently deep (-6 feet) to prevent damage due to freeze -thaw. PORTABLE CONTAINERS The Facility has two totes that are stored in the container management building. One tote is 300 gallons and contains 15W/40 Oil and the other is a 325- gallon tote containing 10W hydraulic oil. The totes are located indoors and do not require secondary containment. There are also twenty (20) 55- gallon drums that contain various petroleum products and /or used petroleum products. All 55- gallon drums are stored in the Container Management Building. The Facility currently has these container and no additional containers are needed for the proposed expansion EMERGENCY RESPONSE CONTAINMENT PLAN The Facility maintains a Spill Prevention Control and Countermeasure Plan (SPCC) onsite in the event a spill occurs as required by the Code of Federal Regulations, Title 40, Part 112 (40 CFR 112) and Minnesota Statute 115. All spills at the Facility will be contained by on site containment and reported according to regulations. In the event a containment measure fails, actions will be taken to minimize the impact of the spill and expedite any clean -up required. Details on procedures and spill response are outlined in the Facility SPCC Plan. 21. Traffic. Parking spaces added: 0 Existing spaces (if project involves expansion):20 Estimated total average daily traffic generated: 672 total trips per day, with 336 entering trips and 336 existing trips Estimated maximum peak hour traffic generated and time of occurrence: 83 trips during a.m. peak hour (7:00 — 8:00 a.m.) and 83 trips during p.m. peak hour (4:00 — 5:00 p.m.) Indicate source of trip generation rates used in the estimates. Data from the project owner regarding existing truck, employee, and visitor usage If the peak hour traffic generated exceeds 250 vehicles or the total daily trips exceeds 2,500, a traffic impact study must be prepared as part of the EA W. Using the format and procedures described in the Minnesota Department of Transportation's Traffic Impact Study Guidance (available at. http: / /www.oim. dot state. mn. us /access /pdfs/Cltayter %205.p or a similar local guidance, provide an estimate of the impact on traffic congestion on affected roads and describe any traffic improvements necessary. The analysis must discuss the project's impact on the regional transportation system. The proposed project is not expected to increase the existing number of trips generated by the facility. The proposed expansion increases the disposal capacity of the facility but does not add any additional services. It is expected that the current level of traffic would continue for a longer period into the future. The existing facility accommodates approximately 1,725 trucks per week, which averages to 314 trucks per day. The site is open 5.5 days per week. There are 17 full time employees on site each day. There are approximately two deliveries and visitors that visit the site on an average weekday. Based on this information, the site is estimated to generate 672 trips per day, with 336 entering and 336 exiting trips. During the weekday peak hours, the site is estimated to generate 83 trips during a.m. peak hour (7:00 — 8:00 a.m.) and 83 trips during p.m. peak hour (4:00 — 5:00 p.m.). As stated above, the proposed project is not expected to increase these numbers. The vast majority of trips generated access the site via TH 55. The predominant movement is to and from the west on TH 55. The site also has access to 140th Street on the south side of the site, but use of this access is very minor. Data from MnDOT shows the current volume on TH 55 at 14,000 vehicles per day. This volume includes the existing trips generated by the site. Since the project is not expected to increase the number of trips generated, the proposed project will not impact the volume on TH 55. In addition, MnDOT has a long -range plan to eliminate the current TH 52 /TH 55 interchange and relocate TH 55 south to the current Highway 42 alignment. This future project would create a new full interchange at the existing TH 52/Highway 42 interchange location. After this relocation is complete, the traffic volumes on Courthouse Boulevard on the north side of the landfill would be significantly reduced. Overall, the proposed project is not expected to increase the number of trips generated by the proposed facility. Therefore, the proposed project will have minimal impact on the traffic operations of the surrounding roadway system. 22. Vehicle - related air emissions. Estimate the effect of the project's traffic generation on air quality, including carbon monoxide levels. Discuss the effect of traffic improvements or other mitigation measures on air quality impacts. Existing operations at the Facility include the use of dozers, loaders, and similar equipment for material processing, placement, and compaction. Because operations for the proposed Project are expected to be similar to current operations, no significant changes in vehicle related emissions are expected. The effect on local and regional air quality resulting from vehicle related air emissions associated with the proposed project is not anticipated to cause significant impacts. 23. Stationary source air emissions. Describe the type, sources, quantities and compositions of any emissions from stationary sources of air emissions such as boilers, exhaust stacks or fugitive dust sources. Include any hazardous air pollutants (consult EAW Guidelines for a listing) and any greenhouse gases (such as carbon dioxide, methane, nitrous oxide) and ozone- depleting chemicals (chloro- fluorocarbons, hydrofluorocarbons, perfluorocarbons or sulfur hexafluoride). Also describe any proposed pollution prevention techniques and proposed air pollution control devices. Describe the impacts on air quality. Dust control for the Facility is performed by maintaining pavement on many of the access roads to the waste disposal cells. Those roads which are not paved are watered regularly during dry weather to prevent dust generation. Due to the nature of the waste, the potential to create landfill gas (methane) is minimal. The Environmental Monitoring Plan approved by the MPCA included installing monitoring points around the Facility to monitor for methane gas. The monitoring points are sampled three times per year. To date, methane has not been found to be present in any of the perimeter monitoring probes. 24. Odors, noise and dust. Will the project generate odors, noise or dust during construction or during operation? _X Yes _No If yes, describe sources, characteristics, duration, quantities or intensity and any proposed measures to mitigate adverse impacts. Also identify locations of nearby sensitive receptors and estimate impacts on them. Discuss potential impacts on human health or quality of life. (Note: fugitive dust generated by operations may be discussed at item 23 instead of here.) ODOR Industrial waste and ash landfills do not typically generate significant odors because there is very little organic material present in the waste stream. The Facility has been in operation since 1992 and odor has not been a problem. NOISE The current landfill operations generate noise from trucks and heavy equipment used to haul and move waste. The facility currently uses the following motorized equipment: 4 cy front -end loader, Caterpillar Motor Grader, 4000 gal. water Truck, 15 ton compactor and a skid loader. The number of vehicles on site will change with the proposed project. Noise is also currently generated by trucks hauling waste to the Facility. These vehicles produce noise from their engines, back -up warning devices, and tailgates. The expansion is not anticipated to increase vehicle traffic at the Facility. Therefore significant increases in noise levels are not expected. DUST Existing operations at the Facility include the use of dozers, loaders, and similar equipment for material processing, placement, and compaction. Because operations for the proposed Project are expected to be similar to current operations, no significant changes in dust emissions are expected. The effect on local and regional air quality resulting from vehicle related air emissions associated with the proposed project is not anticipated to cause significant impacts. 25. Nearby resources. Are any of the following resources on or in proximity to the site? Archaeological, historical or architectural resources? _Yes _X—No Prime or unique farmlands or land within an agricultural preserve? _Yes _X—No Designated parks, recreation areas or trails? _Yes _X—No Scenic views and vistas? _Yes X No Other unique resources? _Yes _X_No If yes, describe the resource and identify any project- related impacts on the resource. Describe any measures to minimize or avoid adverse impacts. 26. Visual impacts. Will the project create adverse visual impacts during construction or operation? Such as glare from intense lights, lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks? _Yes _X No If yes, explain. The proposed expansion of the Facility will not create adverse visual impacts such as glare from lights, plumes from cooling towers or exhaust stacks. Once the landfill is closed, it will be a tall, grassy hill; which will mitigate the visual impact of exhaust stacks from nearby local industrial areas as viewed from the south. The vertical expansion will be visually negligible compared to the currently permitted height due to the relatively small vertical increase (50 feet) over a relatively wide horizon (4000 feet). The final elevation of the vertical expansion will be 1060 feet, which is approximately 230 feet above 140`h Street and 170 feet above Minnesota Trunk Highway 55. 27. Compatibility with plans and land use regulations. Is the project subject to an adopted local comprehensive plan, land use plan or regulation, or other applicable land use, water, or resource management plan of a local, regional, state or federal agency? _X_Yes — No. If yes, describe the plan, discuss its compatibility with the project and explain how any conflicts will be resolved. If no, explain. The Facility is zoned as Waste Management District in the City of Rosemount's IUP. The Facility maintains an MPCA, Dakota County and City of Rosemount solid waste operating permit. 28. Impact on infrastructure and public services. Will new or expanded utilities, roads, other infrastructure or public services be required to serve the project? _ _Yes X No. If yes, describe the new or additional infrastructure or services needed. (Note: any infrastructure that is a connected action with respect to the project must be assessed in the EAW; see EAW Guidelines for details.) No additional utilities, roads, other infrastructure or public service will be required to serve the project. The previously approved expansion included relocating the power poles on site, but that was previously reviewed and approved. 29. Cumulative potential effects. Minnesota Rule part 4410.1700, subpart 7, item B requires that the RGU consider the "cumulative potential effects of related or anticipated future projects" when determining the need for an environmental impact statement. Identify any past, present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects. (Such future projects would be those that are actually planned or for which a basis of expectation has been laid.) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative potential effect under appropriate item(s) elsewhere on this form). No past, present or planned project is known that may interact with the proposed project to cause a cumulative impact. 30. Other potential environmental impacts. If the project may cause any adverse environmental impacts not addressed by items 1 to 28, identify and discuss them here, along with any proposed mitigation. No other impacts are anticipated. 31. Summary of issues. Do not complete this section if the EAW is being done for EIS scoping, instead, address relevant issues in the draft Scoping Decision document, which must accompany the EAW. List any impacts and issues identified above that may require further investigation before the project is begun. Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues, including those that have been or may be ordered as permit conditions. None. RGU CERTIFICATION. (The Environmental Quality Board will only accept SIGNED Environmental Assessment Worksheets for public notice in the EQB Monitor.) I hereby certify that: • The information contained in this document is accurate and complete to the best of my knowledge. • The EAW describes the complete project; there are no other projects, stages or components other than those described in this document, which are related to the project as connected actions or phased actions, as defined at Minnesota Rules, parts 4410.0200, subparts 9b and 60, respectively. • Copies of this EAW are being sent to the entire EQB distribution list. Signature Title Date Environmental Assessment Worksheet was prepared by the staff of the Environmental Quality Board at the Minnesota Department of Administration, Office of Geographic and Demographic Analysis. For additional information, worksheets or for EAW Guidelines, contact: Environmental Quality Board, 658 Cedar St., St. Paul, MN 55155, 651- 201 -2492, or http: / /www.egb.state.mn.us r f Me- Physical Development Division Re: PROJECT NAME SKB Rosemount Industrial Waste Expansion Land Conservation June 26. 2013 Dakota County 1. The recently adopted Rosemount Greenway is located adjacent to Western Service Center Mr.Zweber, 14955 Galaxie Avenue Eric Zweber Apple Valley, MN 55124 -8579 City of Rosemount Surveyor's Office 2875 145th Street West 952.891.7000 greenway trail. Native trees and grasses could be used to create this Fax 952.891.7031 Rosemount, MN 55068 www.dakotacounty.us greenway. Environmental Resources Re: PROJECT NAME SKB Rosemount Industrial Waste Expansion Land Conservation Groundwater Protection 1. The recently adopted Rosemount Greenway is located adjacent to Surface Water Mr.Zweber, Waste Regulation follows Ehlers Path, nearest landfill expansion cell #6. Dakota County Environmental Initiatives Thank you for the opportunity to comment on the Environmental Assessment Worksheet Surveyor's Office (EAW) for the Industrial Waste Expansion proposed at the SKB Rosemount site. Office of Planning greenway trail. Native trees and grasses could be used to create this Operations Management Dakota County staff have the following comments: Facilities Management Fleet Management 1. The recently adopted Rosemount Greenway is located adjacent to Parks the SKB landfill. The trail alignment for the Rosemount Greenway Transportation follows Ehlers Path, nearest landfill expansion cell #6. Dakota County Highways suggests that the landfill expansion be designed with an adequate Surveyor's Office buffer to screen landfill activities from people using the future Transit Office greenway trail. Native trees and grasses could be used to create this buffer and would be consistent with the character of the nearby greenway. 2. Page 3, Section 6 Description (b): This section proposes two different liner designs for the expanded Cell 6. One design contains a leak detection layer consistent with the current liner system being ;utilized in the industrial waste cells. The other proposed liner does not contain a leak detection layer. SKB Industrial Waste Facility has a continuing variance from Dakota County Ordinance 110 "Solid Waste Management ", Section 5.02(A), Section 5.02(B) and Section 5.02(C)(2, except for c) which is contingent upon the existing liner design. This continuing variance would not extend to an alternative liner design. If SKB chooses to construct the alternative liner, a new variance request would have to be presented to the Dakota County Board. 3. Page 8, Section 12 Physical Impacts on Water Resources: This section indicates that the entire 9.35 acre wetland currently located at the site will be impacted, and that mitigation will be provided off -site. Historic citizen complaints related to this wetland have indicated that the condition of the wetland has changed overtime and that the n Punted - recycled paper ,Rh 30% polt -1--, wane. AN EQUAL OPPORTLNRY EMPLOYER 2 1 Dakota County comments: SKB Rosemount Industrial Waste Facility Expansion - June 2013 wetland is no longer providing the same wildlife benefit as it did in previous years. There was an access and viewing platform that was added at the west end of the wetland as a public amenity. The loss of this wetland will require mitigation replacement as per the Minnesota Wetland Conservation Act. However, that mitigation will likely be based on its existing condition and a new delineation. We suggest that consideration be given to the wetlands previous higher functioning condition. Page 8, Section 12 Physical Impacts on Water Resources: This section indicates that existing drainage ditches will be redesigned and constructed to prevent the runoff of site sediment during construction, operation and after final closure." The development must meet stormwater management and erosion /sediment control requirements as per ordinances of the City of Rosemount that are commensurate to the Vermillion River Watershed JPO Standards. 5. Page 8, Section 13 Water Use: County records indicate that there are five sealed wells within the project area. County well inspection staff (Bill Olsen at 952 - 891 -7549) can provide specific location information for these wells, if needed. In addition, the project area may have an additional, unsealed farm well adjacent to a house that is visible on historical aerial photos from 1937 until the mid- 1970s. Excavators should be instructed to watch for an unsealed well in this vicinity. Dakota County well inspection staff can help evaluate any well that is found. Staff may also be able to perform a magnetometer survey if requested. In addition to the known sealed wells, there are 3 active monitoring wells inside the project boundary, and a number of active monitoring wells along the edges of the project boundary. It is likely that some of these will have to be sealed as part of this project. Wells must be sealed by a licensed well and boring sealing contractor, and that the contractor must obtain Well Sealing Permits from Dakota County. 6. Page 12, Section 19 Geologic Hazards and Soil Conditions (b): This section references Figure 8 that depicts groundwater contour elevations within the expanded Cell 6 at 815 and 810, cross - referencing Figure 7 that details the proposed base grades for the expanded Cell 6 there is a low elevation of 811. Based on the elevations to groundwater and base grade, the SKB Industrial Waste Facility Expansion would require a variance from Dakota County Ordinance 110 "Solid Waste Management ", Section 6.01(8) which requires landfills to not be located within five feet of the high historical groundwater table. Page 12, Section 20 Solid Wastes, Hazardous Waste, Storage Tanks (a) and (b): These sections do not clearly define the acceptable wastes for the industrial waste land disposal facility. The industrial waste land disposal facility cannot accept mixed municipal solid waste, sources separated compostable materials, yard waste and source separated compostable materials — SKB does have separate Solid Waste Facility licenses for the transfer of mixed municipal solid waste and composting of compostable materials. 3 1 Dakota County comments: SKB Rosemount Industrial Waste Facility Expansion - June 2013 Thank you again for the opportunity to review the EAW. If you have questions or concerns regarding Dakota County's comments, please contact Kurt Chatfield in the County Office of Planning and Analysis by phone at 952 - 891 -7022 or by email at kurt.chatfield(@co.dakota.mn.us or myself by phone at 952 - 891 -7554 or georg.fischer@co.dakota.mn.us Sincerely, 7 G rg T. Fischer Id rector, Dakota County Environmental Resources CC: Commissioner Nancy Schouweiler, District 4 Brandt Richardson, County Administrator Zweber, Eric From: Doperalski, Melissa (DNR) [melissa.doperalski @state.mn.us] Sent: Tuesday, June 25, 2013 8:03 AM To: Zweber, Eric Subject: Re: SKB Rosemount Industrial Waste Facility Expansion EAW - DNR Comments Attachments: Wildlife Friendly Erosion Control(acc).pdf Mr. Zweber, The Department of Natural Resources (DNR) has reviewed the environmental assessment worksheet (EAW) for the SKB Rosemount Industrial Waste Facility Expansion project located in the City of Rosemount, Dakota County. The DNR offers the following comments for your consideration. As noted within the EAW, the DNR provided a Natural Heritage Review letter dated April 18, 2013 that identified that loggerhead shrikes , a state - listed threatened bird, had been documented in the vicinity of the proposed project. The EAW did not include the important comment regarding nest searches. Lisa Joyal, DNR Endangered Species Coordinator, should be contacted if disturbance activities will occur during the breeding season (April — July). Ms. Joyal can be reached at lisa.loyal @state.mn.us or by phone at 651 - 259 -5109. The DNR encourages SKB facility to use wildlife - friendly erosion control mesh where erosion control methods may need to be used during all site activities. Traditional mesh is known to cause injury or can be fatal to wildlife species, particularly reptiles and amphibians. Please refer to the attached flyer for more information. Thank you for the opportunity to review this EAW. We look forward to receiving your record of decision and responses to comments at the conclusion of environmental review. Minnesota Rules part 4410.1700, subparts 4 and 5, require you to send us your Record of Decision within five days of deciding on this action. Sincerely, Melissa Melissa Doperalski Regional Environmental Assessment Ecologist Department of Natural Resources, Central Region 1200 Warner Road Saint Paul, Minnesota 55106 651.259.5738 melissa .doperalski(aDstate.mn.us Wildlife Friendly Erosion Control Wildlife entanglement in, and death from, plastic netting and other man -made plastic materials has been documented in birds (Johnson, 1990; Fuller - Perrine and Tobin, 1993), fish (Johnson, 1990), mammals (Derraik, 2002), and reptiles (Barton and Kinkead, 2005; Kapfer and Paloski, 2011). Yet the use of these materials continues in many cases, without consideration for wildlife impacts. Plastic netting is frequently used for erosion control during construction and landscape projects and can negatively impact terrestrial and aquatic wildlife populations as well as snag in maintenance machinery resulting in costly repairs and delays. However, wildlife friendly erosion control materials do exist, and are sold by several large erosion control material companies. Below are a few key considerations before starting a project. Know Your Options • Remember to consult with local natural resource authorities (DNR, USFWS, etc.) before starting a project. They can help you identify sensitive areas and rare species. • When erosion control is necessary, select products with biodegradable netting (natural fiber, biodegradable polyesters, etc.). • DO NOT use products that require UV -light to biodegrade (also called, "photodegradable "). These do not biodegrade properly when shaded by vegetation. • Use netting with rectangular shaped mesh (not square mesh). • Use netting with flexible (non - welded) mesh. Know the Landscape • It is especially important to use wildlife friendly erosion control around: • Areas with threatened or endangered species. • Wetlands, rivers, lakes, and other watercourses. • Habitat transition zones (prairie — woodland edges, rocky outcrop — woodland edges, steep rocky slopes, etc.). • Areas with threatened or endangered species. • Use erosion mesh wisely, not all areas with disturbed ground necessitate its use. Do not use plastic mesh unless it is specifically required. Other erosion control options exist (open weave textile (OWT), rolled erosion control products (RECPs) with woven natural fiber netting). WFEC Fact -sheet - MN DNR 2013 (acc. Protect Wildlife • Avoid photodegradable erosion control materials where possible. • Use only biodegradable materials (typically made from natural fibers), preferably those that will biodegrade under a variety of conditions. • Wildlife friendly erosion control material costs are often similar to conventional plastic netting. Minnesota DEPARTMENT OF NATURAL RESOURCES OO �• G • ij• I F WFEC Fact -sheet — MN DNR 2013 (acc Literature Referenced Barton, C. and K. Kinkead. 2005. Do erosion control and snakes mesh? Soil and Water Conservation Society 60:33A -35A. Derraik, J.G.B. 2002. The pollution of the marine environment by plastic debris: a aeview. Marine Pollution Bulletin 44:842 -852. Fuller - Perrine, L.D., and M.E. Tobin. 1993. A method for applying and removing bird - exclusion netting in commercial vineyards. Wildlife Society Bulletin 21:47 -51. Johnson, S.W. 1990. Distribution, abundance, and source of entanglement debris and other plastics on Alaskan beaches, 1982 -1988. Proceedings of the Second International Conference on Marine Debris 331 -348. Kapfer, J. M., and R. A. Paloski. 2011. On the threat to snakes of mesh deployed for erosion control and wildlife exclusion. Herpetological Conservation and Biology 6:1 -9. it Metropolitan Council June 26, 2013 Eric Zweber AICP, Senior Planner City of Rosemount 2875 145th Street West Rosemount, MN 55068 Re: City of Rosemount Environmental Assessment Worksheet (EAW) SKB Environmental, Inc. Metropolitan Council Review No. 21128 -1 Metropolitan Council District 15 (Steven T. Chavez) Metropolitan Council District 16 (Wendy Wulfi) Dear Mr. Zweber: The Metropolitan Council received the EAW for the SKB Environmental, Inc. proposed industrial waste facility expansion on May 23, 2013. The proposed project is located at the company's existing facility at 13425 Court House Boulevard in Rosemont. The EAW proposes additional disposal capacity for industrial solid waste, construction, and demolition debris within Cell 6 in the existing permitted area and in a proposed expansion of Cell 6 on adjacent land directly to the south of the current facility. The proposed expansion of Cell 6 would involve filling an existing 9.35 -acre high - quality wetland within an area designated as high quality Regionally Significant Ecological Area by the Minnesota Department of Natural Resources (MDNR) and regionally significant natural area by the Metropolitan Council's (Council) Natural Resource Inventory and Assessment (NRI /A). Efforts were undertaken by the proposer to preserve this wetland following preparation and review of a previous EAW dated July 2008 that evaluated expansion of the facility for construction of current Cell 6. Additionally, the 2008 EAW stated that there were no plans for future stages of development on outlots at the facility. The Council's review finds that the EAW is complete and accurate for regional purposes, but raises issues of consistency with Council policies. While an EIS is not necessary for regional purposes, the Council finds that it cannot concur with the proposed facility expansion as presented in the EAW. Staff requests that the City consider the following comments. Item 11— Fish, Wildlife, and Ecologically Sensitive Resources The document indicates that the entire proposed Cell 6 expansion area has been identified by the MDNR as Regionally Significant Ecological Area (RSEA), which has been assessed to be of high quality. This same RSEA data set makes up much of the geographic data set similarly mapped by the Council as "regionally significant natural areas" in its NRI /A. NRI /A lands within the seven - county metropolitan area were so- classified using existing information, including Minnesota County Biological Survey data, to provide a comprehensive look at natural resources. The NRI/A database documented valuable land and water resources that perform significant ecological functions, contain important habitat for animals that are sensitive to habitat fragmentation and destruction, and provide opportunities for people to experience nature and the region's historical landscapes. It is also a tool that the Council and local governments can use to accommodate growth while protecting the environment through implementation of effective land protection, conservation, and restoration tools. Item 12 — Physical Impacts on Water Resources The City's Comprehensive Wetland Management Plan (Plan), as amended in December 2007, identifies the 9.35 -acre wetland on the southern portion of this proposed project site as wetland basin 438. While www.metrocouncil.org 390 Robert Street North • St. Paul, MN 55101 -1805 • (651) 602 -1000 • Fax (651) 602 -1550 • TTY (651) 291 -0904 An Equal Opportunity Employer June 26, 2013 Eric Zweber, Senior Planner Page 2 both the Wetland Inventory Map and Assessment Result Table in the Plan classify the basin as a "Manage 1" basin, its field- assessment -based function and value score of 470 in the Plan actually places it within the Wetland Management Class ranking of "Preserve ", as having a function and value score of 425 and above. The stated Management Strategy for wetlands scoring in the "Preserve" Management Class is to maintain their wetland and existing functions, values, and wildlife habitat, and apply strict avoidance standards. Those avoidance standards require in part, 3:1 replacement for mitigation of any potential impacts. However, the Plan also indicates that wetlands determined in the field to rate within the "Preserve" category "shall receive the maximum amount of protection under this plan" and that "impacts will be allowed only under extreme hardship." Council staff strongly urges the City to work with the proposer to avoid the proposed impacts to this on- site wetland complex. As an alternative, Council staff recommend the proposer work with adjacent landowners to evaluate options to acquire adjacent lands for expansion from their landowners to allow continued expansion of the facility without the loss of high quality RSEA and NRI /A habitat, and resultant costly wetland mitigation expense. Item 18 — Water Quality — Wastewaters The Metropolitan Council's Empire Wastewater Treatment Plant Effluent Outfall (8009) is located northwest of this proposed project. The Outfall was built in 2008 and is a 78 inch RCP pipe at a depth of approximately 52 feet. To assess the potential impacts to our interceptor system, prior to initiating this project, preliminary plans should be sent to Scott Dentz, Interceptor Engineering Manager (651 -602- 4503) at the Metropolitan Council Environmental Services for review and comment Item 25 — Nearby Resources — Designated Parks, Recreation Areas, or Trails Although not acknowledged in the EAW, the general alignment of the planned Rosemount Greenway Regional Trail is adjacent to the SKB Industrial Waste Facility site on the south and the east. The exact alignment of the regional trail will be determined through future planning studies conducted by Dakota County. The expansion of Cell 6 as proposed in the EAW is not anticipated to impact planning for the regional trail. Future closure of the landfill may provide opportunities to enhance the regional trail corridor. Item 27— Compatibility with Plans and Land Use Regulations The City's Comprehensive Plan Update adopted in November 2009 states in part, in its Environment and Natural Resources Plan component, the following two goals: • To preserve, protect and restore the natural environment with emphasis on conservation of needed and useful natural resources for the present and future benefit of the community, with the objective being to protect wetlands and natural resources identified in the Natural Resource Assessment from environmentally insensitive development. • Utilize natural resource areas to provide an overall open space system that satisfies the physiological and psychological needs of both individuals and the community, with the objective being to encourage through development incentives, the preservation and management of all natural resource amenities (emphasis added). This proposed project is inconsistent with the goals and objectives contained in the City's 2009 Comprehensive Plan Update. Council Regional Development Framework Policy 4 directs staff to work with local and regional partners to reclaim, conserve, protect, and enhance the regionally important natural resources identified as unprotected in the NRI /A. Council staff strongly urges the City to work with the proposer to avoid the June 26, 2013 Eric Zweber, Senior Planner Page 3 proposed impacts to this on -site wetland complex. As an alternative we recommend the proposer work with adjacent landowners to evaluate options to acquire adjacent lands for expansion from their landowners to allow continued expansion of the facility without the loss of high quality RSEA and NRI /A habitat, and costly wetland mitigation expense. The Council will take no formal action on the EAW. If you have any questions or need further information, please contact Jim Larsen PE, Principal Reviewer, at 651 602 -1159. Sincerely, LisaBeth Barajas, M pager Local Planning Assistance CC: Steven T. Chavez, Metropolitan Council District 15 Wendy Wulff, Metropolitan Council District 16 Patrick Boylan, Sector Representative Kyle Colvin, MCES Engineering Services Assistant Manager Judy Sventek, Water Resources Assessment Manager Raya Esmaeili, Reviews Coordinator N:\ CommDev \LPA \Communities\Rosemount \Letters \Rosemount 2013 EAW SKB Facility Expansion 21128 -1.doc Minnesota Pollution Control Agency 520 Lafayette Road North I St. Paul, Minnesota 55155 -4194 1 651- 296 -6300 800 - 657 -3864 1 651- 282 -5332 TTY I www.pca.state.mn.us I Equal Opportunity Employer June 26, 2013 Mr. Eric Zweber Senior Planner City of Rosemount 2875145 th Street West Rosemount, MN 55068 Re: SKB Rosemount Industrial Waste Facility Expansion Environmental Assessment Worksheet Dear Mr. Zweber: Thank you for the opportunity to review and comment on the Environmental Assessment Worksheet (EAW) for the SKB Rosemount Industrial Waste Facility Expansion project (Project) located in the city of Rosemount, Minnesota. The Project consists of a 50 foot vertical and 15 acre horizontal expansion of Cell 6. Regarding matters for which the Minnesota Pollution Control Agency (MPCA) has regulatory responsibility and other interests, the MPCA staff has the following comments for your consideration. Permits and Approvals Required (item 8) If the project will disturb a total of one acre or more of land, a National Pollutant Discharge Elimination System /State Disposal System (NPDES /SDS) Construction Stormwater Permit (CSW Permit) is required from the MPCA. The owner and operator (usually the general contractor) are jointly responsible for obtaining and complying with the conditions of the CSW Permit. A detailed Stormwater Pollution Prevention Plan (SWPPP), containing stormwater management requirements both during and post construction, as well as erosion control and sediment control requirements during construction, must be prepared prior to submitting a CSW Permit application. CSW Permit coverage is required prior to commencing land disturbing activities (i.e., clearing, grading, filling, or excavating) relating to the project. For an overview of this permit and program, please refer to the following factsheet: http: / /www.pca. state. mn. us /publications /wq- strm2- 05.pdf. Questions regarding CSW Permit requirements should be directed to Roberta Getman at 507 - 206 -2629. Water Quality: Surface Water Runoff (Item 17) Please note that the Stormwater Pollution Prevention Plan (SWPPP) for the facility will need to be updated to reflect the new acreage and potential new best management practices (BMPs). Water Quality: Wastewaters (Item 18) This section of the EAW states "The facility expansion will not increase the overall volume or change the parameters in the leachate." Please clarify how this statement is accurate when the expansion will increase the footprint of the facility with an additional cell which would seem to indicate an increase in the volume of leachate. Also, the EAW should indicate if the Empire Wastewater Treatment Plant has the capacity to treat the increase in wastewater. Mr. Eric Zweber Page 2 June 26. 2013 Geologic Hazards and Soil Conditions (Item 19) The third paragraph of this section discusses the geology of the area but mentions the St. Lawrence Formation twice, in the third and fourth sentences. It appears the third sentence is actually describing the Jordan Sandstone. Odors, Noise and Dust (Item 24) • This section of the EAW states that industrial waste and ash landfills do not typically generate odors. However, Item 20 of the EAW (Solid Wastes, Hazardous Wastes, Storage Tanks) states that the facility is now permitted to accept mixed municipal solid waste, source separated compostable materials, and yard waste. The EAW should discuss the potential for odors from these types of wastes and how they will be mitigated. • The EAW should discuss the potential for dust issues due to mud being tracked out of the working areas onto paved roads and how it will be mitigated. We appreciate the opportunity to review this Project. Please provide your specific responses to our comments and notice of decision on the need for an Environmental Impact Statement. Please be aware that this letter does not constitute approval by the MPCA of any or all elements of the Project for the purpose of pending or future permit action(s) by the MPCA. Ultimately, it is the responsibility of the Project proposer to secure any required permits and to comply with any requisite permit conditions. If you have any questions concerning our review of this EAW please contact me at 651 - 757 -2508. Sincerely, VNVM ✓ Karen Kromar Planner Principal Environmental Review Unit Resource Management and Assistance Division KK:bt cc: Craig Affeldt, MPCA, St. Paul Doug Wetzstein, MPCA, St. Paul Melissa Wenzel, MPCA, St. Paul Steve Sommer, MPCA, St. Paul Scott Parr, MPCA, St. Paul From: Jon Penheiter [ mailto :JonPCa)WasteConnections.com] Sent: Tuesday, September 03, 2013 10:29 AM To: Lindquist, Kim Cc: Geoff Strack; John Domke Subject: Updates to SKB Permit Application Kim, I have prepared the following summary of items we updated in our permit application. This was the same list that we shared with Dakota County several months ago. The resulting 8/21/13 Dakota County letter to Dan Aamodt from Dave Magnuson deals with some of these items. • Horizontal expansion (15 acres), vertical (50 feet) expansion, and lowered basegrade of Cell 6, which will add a total of 8,325,571 cubic yards of airspace to the landfill. However, no increase in permitted volume of MSW combustor ash is sought. The horizontal expansion requires mitigation of an on -site wetland. • Change the liner in the 3/5 & 2/5 saddle area to the approved industrial waste liner system. • Change the delineation of Cell 5 to coincide with the high point of the liner in the 3/5 & 2/5 saddle areas. • Alternate liner design for industrial cells. This liner consists of, from the bottom to the top, geomembrane, geosynthetic clay liner, geomembrane, drainage composite, protective sand. • Larger and more stormwater ponds. • Cleaned -up ISWMP. (I have listed 7 specific items that we updated in the ISWMP below) • Up -dated all plans to be all inclusive of all permitted activities (i.e. added composting operations to all plans). The following list are items that were "clean -up" of the ISWMP. 1. Requested pH limit changes 2. Included a section for MPCA Cell 4 Co- Disposal Requests Section 6.20. 3. Included a policy for managing ash from training burns Section 6.19. 4. Included a section for managing storm water pond sediment. Section 6.21. 5. Included a section for management of Sewage Treatment plant waste section 6.18. 6. Sections 6.5 and 6.11 were updated to allow management of these non - hazardous wastes in some limited situations. 7. Appendix G of the WAP was amended to reflect the new Cell 5 standards approved by Dakota County Jon Penheiter 612 - 366 -4834 PERMIT RENEWAL APPLICATION REPORT SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY, SW -383 13425 COURTHOUSE BOULEVARD ROSEMOUNT, MINNESOTA 55068 Prepared For: SKB Environmental, Inc. 251 Starkey Street St. Paul, Minnesota 55107 MARCH 2013 REF. NO. 075704 (27) Prepared by: Conestoga- Rovers & Associates 1801 Old Highway 8 Suite 114 St. Paul, Minnesota 55112 Office: (651) 639 -0913 Fax: (651) 639 -0923 web: http: \ \www.CRAworld.com Worldwide Engineering, Environmental, Construction, and IT Services TAB 1. PERMIT APPLICATION FORM PERMIT CHECKLISTS 075704 (2n 1100, Minnesota Pollution Control Agency 520 Lafayette Road St.Paul,MN 55155 -4194 Permit Application for Construction and Operation Solid Waste Permit Program Doc Type: Permit Application MPCA Public Notice Number: Print or type application: Before submitting, make a photocopy for your records. The Minnesota Pollution Control Agency (MPCA) will review the application for completeness and provide an official response to the permittees within 30 business days of receipt of the application. Permit Application Assembly: To expedite the processing and review of your application, put this form at the beginning of your submittal package. Please place all checklists directly behind this application form in order by the number found on the bottom left hand corner of each checklist. Do not place forms and checklist in an appendix as this makes it difficult and time consuming for staff to locate them. Completeness instructions: Without properly completed forms, an application cannot be processed and will be determined to be incomplete. All sections of this form must be completed. If portions do not apply to this facility, please indicate so with "n /a ". The completed form is to be returned to: Solid Waste Permit Document Coordinator Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 -4194 Facility name: SKB Rosemount Industrial Waste Facility Permit No.: SW -383 Application is for (check appropriately): ❑ New permit ® Permit reissuance ❑ Major modification ❑ Minor modification ❑ Resubmittal of 'Incomplete' application originally submitted on: Variance request(s) included (check appropriately): ❑ Yes ®No If yes, please describe: (mm/dd/yyyy) Checklists Required (Please check all that are included with this application.) All applicable checklists must be completed and submitted with this application. The MPCA will not process an application that does not include all of the required checklists. All checklists can be found at: http: / /www pca state.mn.us /enza8a9. All Solid Waste Facilities ® Solid Waste Facility Application Checklist Mixed Municipal Solid Waste (MSW) Landfill ❑ MSW Landfill Application Checklist MSW Combustor Ash Landfill ® MSW Combustor Ash Landfill Application Checklist Demolition Debris Landfill ® Demolition Debris Landfill Application Checklist Industrial Solid Waste Landfill M Industrial Solid Waste Landfill Application Checklist Transfer Station ® Solid Waste Transfer Station Application Checklist Solid Waste Compost Facility ® Solid Waste Compost Facility Application Checklist Refuse - Derived Fuel Processing Facility ❑ Refuse - Derived Fuel Processing Facilities Application Checklist www.pca.state.mn.us • 651 - 296 -6300 • 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 1 of 7 I. Local Acknowledgment /Permission for Other Solid Waste Facilities This section is primarily meant to notify the county and local authorities of the applicants intent so that all county and local ordinances and plans can be met. It is intended to validate that counties and local authorities were properly notified of this permit application for construction and operation. Signature by the county or local authority is not meant to imply approval. A. County Acknowledgment /Permission (to be completed by County Solid Waste Administrator or County Zoning Administrator) Signature: Print name: Title: E -mail: Director Date: Phone: Fax: 952 - 891 -7588 Organization: Dakota County Environmental Management Department Address: 14955 Galaxie Drive City: Apple Valley State: MN Zip: 55124 B. Local Acknowledgment/Permission (to be completed by local building or zoning office) Signature: lo. ,_.,,r,,tr,1 t Date: 3-27-4-1-3 Print name,(f .t- )A�.,, r Phone: 322_Zo6,4 Title: City Administrator Fax: E -mail: 1d%d.q AAMSA rz:. Organization: City of Rosemount Address: 2875 West 145' Street, P.O Box 510 City: Rosemount State: MN Zip: 55068 In lieu of completion of this part of the application, the applicant may submit documentation that the applicant has sent appropriate notification to the county and local authorities. Documentation must consist of copies of letters sent to the county and local authorities via certified mail, return receipt requested and copies of the signed return receipt. Solid Waste Transfer Facilities If this application is for a transfer facility, the applicant must attach copies of all required municipal licenseslapprovals. The MPCA will not process an application without these approvals. See Minn. R. 7001.3075, subp. C, for more details. If no municipal approvals are required the owner or operator must sign the statement below stating that no municipal approvals are required. Have all local licenses /approvals been acquired? ® Yes ❑ No If yes, please list all approvals, include issuances and expiration dates (please include copies of the approvals in the permit application: If no, please sign the following line confirming no municipal approvals are required: Signature: Date: Print name: Title: Facility Information A. General Information Permit number Facility name: SKB Rosemount Industrial Waste Facility. (for modification/ reissuances only) SW -383 Address: 13425 Courthouse Blvd. City: Rosemount State: MN Zip: 55068 MPCA Region (check one): ❑ Brainerd ❑ Detroit Lakes ❑ Duluth ❑ MarshalINVilimar ® Metro ❑ Rochester www.pca.srate.mn.us • 651- 296 -6300 • 800- 657 -3864 TTY 651 - 282 -5332 or 800- 657 -3864 Available in alternative formats w- sw3 -33 • 11/27/12 Page 2 of 6 I. Local Acknowledgment /Permission for Other Solid Waste Facilities This section is primarily meant to notify the county and local authorities of the applicant's intent so that all county and local ordinances and plans can be met. It is intended to validate that counties and local authorities were properly notified of this permit application for construction and operation. Signature by the county or local authority is not meant to imply approval. A. County Acknowledgrnent/Permiission (to be completed by County Solid Waste Administrator or County Zoning Administrator) Signature: Date: a-a Print name: petr±hv Phone: 5Z� Title: Director Fax: 952- 891 -7588 E- mail: . �j X1,1 N _t o _ILA —Lrfq . Mk)- y 5 Organization. Dakota County Environmental Management Department Address: 14955 Galaxie Drive City: A Ipp a Valley State: MN Zip: 55124 B. Local Acknowledgment/Permission (to be completed by local building or zoning office) Signature: Date: Print name: Phone: Title: City Administrator Fax: E -mail: Organization- City of Rosemount Address: 2875 West 145' Street, P.O Box 510 City: Rosemount State: MN Zip: 55068 In lieu of completion of this part of the application, the applicant may submit documentation that the applicant has sent appropriate notification to the county and local authorities. Documentation must consist of copies of letters sent to the county and local authorities via certified mail, return receipt requested and copies of the signed return receipt. Solid Waste Transfer Facilities If this application is for a transfer facility, the applicant must attach copies of all required municipal licenses /approvals. The MPCA will not process an application without these approvals. See Minn. R. 7001.3075, subp. C, for more details. If no municipal approvals are required the owner or operator must sign the statement below stating that no municipal approvals are required. Have all local licenses /approvals been acquired? ® Yes ❑ No If yes, please list all approvals, include Issuances and expiration dates (please include copies of the approvals in the permit application: If no, please sign the following line confirming no municipal approvals are required: Signature: Date: Print name: Title: II. Facility Information A. General information Permit number Facility name: SKB Rosemount Industrial Waste Facility (for modification/ reissuances only) SW -383 Address: 13425 Courthouse Blvd. City: Rosemount State: MN Zip: 55068 MPCA Region (check one): ❑ Brainerd ❑ Detroit Lakes ❑ Duluth ❑ Marshall/Willmar ® Metro ❑ Rochester www.pca.state.mn.us * 651 - 296 -6300 * 800 -657 -3864 * TTY 651.282 -5332 or 800- 657 -3864 * Available in alternative formats w- sw3 -33 * 11127112 Page 2 of 6 B. Legal description of property (acreage includes the entire area of the facility) 238 Acres SE % Township name: Rosemount County: Dakota Latitude: 44 Deg 45 Min 05 Sec North Longitude: 93 Deg 00 Min 43 Sec West Section 19,20,29 T 115 N R 18 W MN Legislative District: 37A - check this 1. Directions to the facility (physical location): Take Highway 55 South from St Paul /Minneapolis turn left at the Hastings exit. Follow to landfill entrance immediately after railroad crossing at 13425 Courthouse Blvd. 2. Current land use: Industrial Solid Waste Mixed Municipal Solid Waste Combustor Ash C &D Landfill and Recycling and Transfer Station 3. Current zoning designation of the site and the surrounding areas within a quarter mile radius: General Industrial, Waste Management Public Institutional and agricultural 4. Describe the key topographic features at and around the facility: Rolling topography; highs and lows where the lows hold water intermittent) 5. Environmental Assessment Worksheet (EAW) or Environmental Impact Statement (EIS) required? ® Yes ❑ No Explain: An EAW is required to address impacts to the wetlands on the south side of the landfill property Irlentifv the fnllnwina features within a one mile radius of the site Feature Name of feature Distance Current and former water supply or monitoring wells See attached Figure 2.1 in the engineering report Table 2.2 list off Wells within a 1 mile radius of the Facility Onsite ® Solid Waste Composting None ® Solid Waste Transfer Station -Airports Lakes or ponds Spring Lake 3000 ft Rivers, streams orsprings Mississi i River 3100 ft Wetlands unnamed onsite Flood tans Mississippi/Spring Lake 3000 ft Karst features sinkholes, caves None Parks or wildlife refuges SDrina Lake Regional Park 4000 ft Present or proposed access and major haul roads, and their weight restrictions St Hwy 52 - 40 tons State Hwy 55 - 40 tons Adjacent to Facility Easements or right -of -way Overhead power lines; MCES Empire Outfall Line; Onsite Recreational areas None Historical or archeological areas None III. Waste Activity Information A. Type(s) of Waste Activity(s) to occur at the facility (check all boxes that apply) Disposal activity Processing activity ❑ Mixed Municipal Solid Waste ® Solid Waste Composting ® Industrial Solid Waste ® Solid Waste Transfer Station ® Demolition Debris ® Solid Waste Recycling ® Municipal Solid Waste Combustor Ash ❑ Solid Waste Processing (prior to mass burn) ❑ Other: ❑ Solid Waste Storage ❑ Refuse - Derived -Fuel (RDF) ❑ Other: www.pca.state.mn.us 651 - 296 -6300 • 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 3 of 7 B. Describe the capacity of each waste activity area and the total facility capacity in the tables below. Provide information for each type of activity selected above. Disposal activity areas Caoacitv (vd3) Disposal area Ultimate design capacity Proposed additional capacity Current in-place volume Remaining ermitted ca aci Certificate of Need MSW only) tons/day tons/ ear tons/day tons/ ear tons/day Solid Waste Composting Mixed Municipal Solid Waste (MSW) 0 0 0 0 700,000 Solid Waste Transfer Station 808,080 808,080 cy 808,080 cy Industrial Waste 15,464,483 9,587,593 4,927,648 4,078,246 - 1,262,022 for See DD001 NOT C &D below Demolition Debris 8,752,613 waste capacity 2,543,775 4,946,816 Municipal Solid Waste Combustor Ash 2,648,950 nochange 838,516 1,810,434 (prior to mass burn Other: 0 0 0 Total 26,866,046 8,325,571 8,309,939 10,831,238 Drnrcccinn 2rfivity araac Processing area Proposed capacity Permitted capacity Design ca acit Solid Waste tons/ ear tons/day tons/ ear tons/day tons/ ear tons/day Solid Waste Composting 50,000 358,000 50,000 Dis osaI 50,000 700,000 Solid Waste Transfer Station 808,080 808,080 cy 808,080 cy c /ear Solid Waste Recycling See below Solid Waste Processing (prior to mass burn Solid Waste Storage Refuse - Derived -Fuel RDF Other: Recyclables wood, concrete, asphalt, 346,320 cy /year 346,320 cy /year 346,320 cy /year cardboard, shredder fluff, source separated recyclables Shingles, and metals Total 1,154,400 1,154,400 1,154,400cy cy /yr and 50,000 cy /yr and 50,000 /yr and 50,000 ton/ ear ton/ ear ton/ ear IV. Operational Information A. List the solid waste and waste by- products to be managed at the facility according to the waste type, quantity, and management method (collect, transfer, store, process, convert, compost, treat, or disposal). Waste Type Quantity Unit (tons, tons /day, tons /year, cubic yards, PTE's, items ) Mana ement Method Solid Waste 808,080 Cubic Yards/Year Transfer -Municipal MSW Combustor Ash 60,000 Cubic Yards/Year Disposal Demolition Debris 358,000 Cubic Yards/Year Dis osaI Industrial Waste 700,000 Cubic Yards/Year Disposal www.pca.state.mn.us • 651 - 296 -6300 • 800- 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 4 of 7 Asbestos no limit CY as delievered for disposal Dis osal Appliances MSW Combustor Ash, Industrial, C &D Debris Transfer Trailer 110 -115 CY or 20 ton Electronics Trailer 30 -50 CY MSW Combustor Ash, Industrial, C &D Debris Yard Waste partof Com ost below Compost Bulking Agent Tires 500 tires recycle Household Hazardous Waste Rec clables list See below see below See below Other: Compost 50,000 Tons/Year SSCM process onsite Other: Recyclables wood, concrete, asphalt, cardboard,sh redder fluff, source separated recyclables Shingles, and metals 346,320 c / ear onsite processing or offsite transfer. B. The facility will have capacity to receive 300 vehicles per day and expects to receive an average of 200 vehicles per day. List the vehicle types (i.e., packer trucks, roll -off boxes, private citizen vehicles) using the facility including those that transport special wastes, such as tires or white goods. Vehicle Type Vehicle Capacity Waste Type Transported Roll -off boxes 10 -50 CY MSW Combustor Ash, Industrial, C &D Debris Transfer Trailer 110 -115 CY or 20 ton MSW Combustor Ash, Industrial, C &D Debris Trailer 30 -50 CY MSW Combustor Ash, Industrial, C &D Debris —End-Dump Dump 20-40 CY MSW Combustor Ash, Industrial, C &D Debris —Straight Private Vehicles 1 -5 CY C &D C. Describe the equipment to be located and used on site at the facility, or the availability and arrangement for use of equipment kept off -site, managing the waste: See Table 13.1 of the Operations Plan section of the Permit Application Report V. Signature and Certification I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. Engineer (Consultant) Signature: Print name Title: E -mail: ret A. Zuckwei Project Manager mzuckweiler @craworld com Organization: Conestoga-Rovers & Associates Address: 1801 Old Highway 8 Suite 114 Date: License Number: State licensed: 46652 Minnesota www.pca.state.mn.us 651 - 296 -6300 • 800- 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 5 of 7 City: Phone: New Brighton State: MN 651 - 639 -0913 ext322 Fax: 651 - 639 -0923 Zip: 55112 I certify under penalty of law that this document and all attachments were prepared under my direction or supervision to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I further certify that the construction and operation of the above described facility will be in accordance with the plans, specifications, reports and related communications accepted by the Minnesota Pollution Control Agency (MPCA) and on file in its office; and in accordance with conditions imposed in the permit issued by the MPCA. I certify that the facility is consistent with local solid waste management plans. I am aware an MPCA permit must be obtained before construction or operation of the facility may begin and all local permits, licenses or other government approval must be obtained before an MPCA permit can be issued. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment. Landowner Signature: Date: Print name: Richard O'Gara Phone: 651 - 224 -6329 Title: Division Vice President Fax: 651 - 223 -5053 Email: ricko @wasteconnections.com Phone: 651 - 438 -1500 Organization: SKB Environmental, Inc. Fax: 651 - 438 -1549 Address: 251 Starkey Street City: St. Paul State: MN Zip: 55107 Phone: 651 - 224 -6329 Fax: Owner (Applicant) Signature: Date: Print name: John Domke Phone: 651 - 224 -6329 Title: Division Landfill Manager Fax: 651 - 223 -5053 E -mail: johndo @wasteconnections.com Organization: SKB Environmental, Inc. Address: 251 Starkey Street City: St. Paul State: MN Zip: 55107 Operator* Signature: Date: Print name: Jon Penheiter Certification No: 52097302 Title: Facility Manager Expiration Date: 3/19/2015 E -mail: jonp @wasteconnections.com Phone: 651 - 438 -1500 Organization: SKB Environmental, Inc. Fax: 651 - 438 -1549 Address: 13425 Courthouse Blvd. City: Rosemount State: MN Zip: 55068 *Provide the same information for other certified operators. VI. Solid Waste Annual Report Contact Print name: Jon Penheiter Phone: 651 - 438 -1500 Title: SKB Rosemount Facility Manager Fax: 651 - 438 -1549 E -mail: jonp @wasteconnections.com www.pca.state.mn.us 651 - 296 -6300 • 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 6 of 7 Organization: SKB Environmental, Inc Address: 13425 Courthouse Blvd. City: Rosemount State: MN Zip: 55068 www.pca.state.mn.us 651 - 296 -6300 • 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats w- sw3 -33 • 11127112 Page 7 of 7 i azaa��aa�aa�eraa��aaaaa�a���z�� p4p; Sri£ RRm��LA2 t$�$d �` m )rl �r r SJjIfS1 mFF�6`.�— �'K Xr C. Z Mf'TP� m rn Cl) vXI a Oo -I 0 rnO>v a Z c j) n <� a >O�rnr ma =�zca V is O MIL Z5 cl) z Z r Z mn �a> O ° a a_vrn Z zrn rn P a 0 � � r � a r � r - -� \� � , qm�\§ :m� -,� ®$k /2§ " 9mkZ ° )! §) ■ 222 ! L-JI t 2| § ? ! | .� 00 |,| ! 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NO. 075704 (27) ER Prepared by: Conestoga- Rovers & Associates 1801 Old Highway 8 Suite 114 St. Paul, Minnesota 55112 Office: (651) 639 -0913 Fax: (651) 639 -0923 web: htto: \ \www.CRAworld.com Worldwide Engineering, Environmental, Construction, and IT Services DISTRIBUTION No. of Copies Sent To g Mr. Daniel Aamodt Minnesota Pollution Control Agency Industrial Land Permits 520 Lafayette Road North St. Paul, Minnesota 55155 g Mr. Geoff Strack, P.E. SKB Environmental, Inc. 251 Starkey Street St. Paul, Minnesota 55107 1 Mr. Jeff Harthun Environmental Director Dakota County Environmental Management Western Service Center 14955 Galaxy Avenue Apple Valley, Minnesota 55124 1 Mr. Dwight Johnson City Administrator City of Rosemount 2875 West 145th Street Rosemount, Minnesota 55068 1 Ms. Margaret Zuckweiler, PE Conestoga- Rovers & Associates 1801 Old Highway 8, Suite 114 St. Paul, Minnesota 55112 076704 (27) ER CONESTOGA- ROVERS $ ASSOCIATES PERMIT APPLICATION CONTENTS TAB 1 FACILITY PERMIT APPLICATION FACILITY PERMIT CHECKLISTS TAB 2 ENGINEERING REPORT TAB 3 WASTE ACCEPTANCE PLAN TAB 4 OPERATIONS PLAN TAB 5 CLOSURE, POST - CLOSURE AND CONTINGENCY ACTION PLAN TAB 6 DRAWINGS FOR PERMIT APPLICATION RENEWAL (11x17) 075704 (27) ER CONESTOGA - ROVERS & ASSOCIATES DRAWINGS LIST (22X36 PLAN SET UNDER SEPARATE COVER) CI -01A MARCH 2013 CI -01B MARCH 2013 CI -02 MARCH 2013 CI -03 MARCH 2013 CI -04 MARCH 2013 CI -05 MARCH 2013 CI -06 MARCH 2013 CI -07 MARCH 2013 CI -08 MARCH 2013 CI -09 CI -10 CI -11 MARCH 2013 MARCH 2013 MARCH 2013 CI -12 MARCH 2013 CI -13 MARCH 2013 CI -14 MARCH 2013 CI -15 MARCH 2013 CI -16 MARCH 2013 CI -17 MARCH 2013 EXISTING CONDITIONS AND ENVIRONMENTAL MONITORING LOCATIONS EXISTING CONDITIONS AND ENVIRONMENTAL MONITORING LOCATIONS GROUNDWATER CONTOUR MAP OCTOBER 23, 2012 BASE GRADES CELLS 1 -6 BASE GRADES CELL 6 LEACHATE COLLECTION SYSTEM TOP OF FINAL COVER STORMWATER MANAGEMENT PLAN PHASING PLAN (2013 -2018) PHASING PLAN (2018 -2026) ENGINEERING CROSS SECTIONS (1 OF 3) ENGINEERING CROSS SECTION (2 OF 3) ENGINEERING CROSS SECTION (3 OF 3) INTERIOR BERM AND SADDLE AREA DETAILS (1 OF 2) INTERIOR BERM AND SADDLE AREA DETAILS (2 OF 2) SADDLE AREA AND LEACHATE COLLECTION TRENCH DETAILS LEACHATE HEADER PLAN AND PROFILE CELL 6 LEACHATE HEADER PLAN AND PROFILE CELLS 1,2, 4 AND 6 075704 (27) ER CONESTOGA - ROVERS & ASSOCIATES DRAWINGS LIST 075704 (27) ER CONESTOGA- ROVERS & ASSOCIATES (22X36 PLAN SET UNDER SEPARATE COVER) CI -18 MARCH 2013 LEACHATE HEADER PLAN AND PROFILE CELLS 2 AND 6 CI -19 MARCH 2013 LINER AND LEACHATE COLLECTION DETAILS (1 OF 3) CI 20 MARCH 2013 LINER AND LEACHATE COLLECTION DETAILS (2 OF 3) CI -21 MARCH 2013 LINER AND LEACHATE COLLECTION DETAILS (3 OF 3) CI -22 MARCH 2013 DETAILS LEACHATE SUMPS CI -23 MARCH 2013 RECYCLING/ TRANSFER FACILITY PLAN CI -24 MARCH 2013 STORMWATER BASIN PLAN, BASINS 4 AND 5 CI -25 MARCH 2013 STORMWATER BASIN PLAN, BASINS 6A, 6B, AND 6C CI -26 MARCH 2013 STORMWATER DETAILS (1 OF 2) CI -27 MARCH 2013 STORMWATER DETAILS (2 OF 2) CI -28 MARCH 2013 PERIMETER BERM AND FINAL COVER DETAILS CI -29 MARCH 2013 PHASE DELINEATION BERM AND DITCH DETAILS 075704 (27) ER CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS Page 1.0 INTRODUCTION ..................................................................................... ..............................1 1.1 SCOPE OF SUBMITTAL ...................................................... ..............................1 1.2 GENERAL SITE DESCRIPTION ......................................... ..............................4 1.3 PERMIT HISTORY ................................................................ ..............................7 2.0 SITE ANALYSIS ........................................................................................ ..............................8 2.1 LOCATIONAL CRITERIA ................................................... ..............................8 2.2 HYDROGEOLOGIC AND GEOLOGIC ASSESSMENT .. ..............................8 2.2.1 BEDROCK HYDROGEOLOGY AND GEOLOGY ........... ..............................8 2.2.2 SURFICIAL HYDROGEOLOGY AND GEOLOGY .......... ..............................9 2.2.3 SOILS ....................................................................................... ..............................9 2.2.4 ENVIRONMENTAL MONITORING PLAN .................... .............................10 2.2.5 CLIMATE .............................................................................. .............................11 2.3 SURFACE WATER MANAGEMENT PLAN ................... .............................11 2.3.1 STORMWATER MANAGEMENT ANALYSIS ............... .............................12 2.4 VEHICULAR FLOW AND ACCESS CONTROL ............ .............................13 3.0 FACILITY DESIGN REPORT ................................................................. .............................15 3.1 EXISTING CONDITIONS ................................................... .............................15 3.2 WASTE FILL STABILITY .................................................... .............................16 3.2.1 GLOBAL STABILITY ANALYSIS ...................................... .............................16 3.2.2 VENEER STABILITY ANALYSIS ...................................... .............................17 3.3 BASEGRADES ...................................................................... .............................17 3.4 LINER DESIGNS .................................................................. .............................18 3.4.1 INDUSTRIAL WASTE LINERS .......................................... .............................19 3.4.1.1 INDUSTRIAL CELL PROTECTIVE SAND LAYER ........ .............................21 3.4.2 MSW COMBUSTOR ASH LINER ...................................... .............................21 3.4.3 C &D LINER ........................................................................... .............................22 3.5 LEACHATE COLLECTION & STORAGE SYSTEMS ..... .............................22 3.5.1 LEACHATE GENERATION AND SAMPLING .............. .............................22 3.5.2 LEACHATE HEAD AND LINER EFFICIENCY .............. .............................23 3.5.3 LEACHATE COLLECTION SYSTEM PIPE STRENGTH ............................24 3.5.4 LEACHATE COLLECTION SYSTEM ............................... .............................25 3.5.4.3 INDUSTRIAL CELLS LEACHATE COLLECTION ........ .............................26 3.5.4.4 ASH CELL LEACHATE COLLECTION ........................... .............................27 3.5.5 LEACHATE GRAVITY LINE ............................................. .............................27 3.5.6 STORAGE TANKS ............................................................... .............................27 3.6 INTERMITTENT AND INTERMEDIATE COVER ......... .............................27 3.6.1 FINAL COVER DESIGN ..................................................... .............................28 3.6.2 SEED MIX .............................................................................. .............................29 4.0 SITE DEVELOPMENT PLAN ................................................................ .............................30 4.1 INTRODUCTION ................................................................. .............................30 075704 (27) ER CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS Pale 4.2 PHASED CONSTRUCTION ............................................... .............................30 4.2.1 CELL 1 DEVELOPMENT .................................................... .............................31 4.2.2 CELL 2 DEVELOPMENT .................................................... .............................31 4.2.3 CELL 3 DEVELOPMENT .................................................... .............................32 4.2.4 CELL 4 DEVELOPMENT .................................................... .............................32 4.2.5 CELL 5 DEVELOPMENT .................................................... .............................33 4.2.6 CELL 6 DEVELOPMENT .................................................... .............................33 4.3 FILL PROGRESSION ........................................................... .............................34 5.0 LANDFILL GAS MANAGEMENT ....................................................... .............................35 5.1 INDUSTRIAL AND ASH FACILITY ................................. .............................35 5.2 C &D WASTE FACILITY ..................................................... .............................35 5.3 MONITORING POINTS ...................................................... .............................35 5.4 HYDROGEN SULFIDE MONITORING ........................... .............................36 6.0 RECYCLING CENTER & TRANSFER FACILITY .............................. .............................37 .............................41 6.1 INTRODUCTION ................................................................. .............................37 .............................41 6.2 DESIGN INFORMATION ................................................... .............................37 .............................42 6.2.1 ROAD DESIGN INFORMATION FOR RECYCLING .............................42 7.2.2 FACILITY /TRANSFER FACILITY .................................... .............................37 .............................42 6.2.2 BUILDING DESIGN FOR .............................43 7.4 RECYCLING FACILITY /TRANSFER FACILITY ........... .............................38 .............................43 6.2.3 FLOOR DESIGN FOR RECYCLING FACILITY /TRANSFER .............................44 7.6 FACILITY.............................................................................. .............................39 .............................44 6.2.4 SCALE AND SCALE OFFICE DESIGN FOR RECYCLING .............................44 7.7.1 FACILITY /TRANSFER FACILITY .................................... .............................39 7.7.2 6.2.5 FACILITY CONSTRUCTION DOCUMENTATION COMPOST PILE CONSTRUCTION .................................. .............................45 FOR RECYCLING FACILITY/ TRANSFER FACILITY .. .............................39 7.0 COMPOST AREA .................................................................................... .............................41 7.1 SITE PREPARATION ........................................................... .............................41 7.2 ACCESS TO THE FACILITY .............................................. .............................42 7.2.1 TRAFFIC ROUTES ............................................................... .............................42 7.2.2 ACCESS CONTROL ............................................................. .............................42 7.3 SURFACE WATER MANAGEMENT ............................... .............................43 7.4 PROCESSING AREAS ......................................................... .............................43 7.5 CONTACT WATER MANAGEMENT ............................. .............................44 7.6 MATERIALS MANAGEMENT .......................................... .............................44 7.7 ODOR MANAGEMENT ..................................................... .............................44 7.7.1 COMPOST BLANKET ......................................................... .............................45 7.7.2 ACTIVE AERATION ........................................................... .............................45 7.7.3 COMPOST PILE CONSTRUCTION .................................. .............................45 075704 (27) ER CONESTOGA- ROVERS & ASSOCIATES LIST OF FIGURES (Following Text) FIGURE 1.1 ADJACENT PROPERTY OWNERS FIGURE 2.1 WELLS WITHIN 1 MILE LIST OF TABLES (Following Text) TABLE 1.1 ADJACENT PROPERTY OWNERS TABLE 1.2 FACILITY WASTE CAPACITY SUMMARY TABLE 2.1 LOCATIONAL CRITERIA SUMMARY TABLE 2.2 ENVIRONMENTAL MONITORING PLAN TABLE 2.3 ENVIRONMENTAL MONITORING PLAN GROUNDWATER ANALYTE LIST TABLE 2.4 ENVIRONMENTAL MONITORING PLAN LEACHATE ANALYTE LIST TABLE 3.1 SUMMARY OF LINER COMPONENTS TABLE 4.1 FACILITY CELL PHASING SUMMARY 075704 (27) ER CONESTOGA- ROVERS & ASSOCIATES LIST OF APPENDICES APPENDIX A STORMWATER MEMO & CALCULATIONS APPENDIX B SLOPE STABILITY MEMO & CALCULATIONS APPENDIX C CONSTRUCTION QUALITY ASSURANCE PLAN APPENDIX D HELP MODELING / WATER BALANCE MEMO & CALCULATIONS APPENDIX E PIPE STRENGTH MEMO & CALCULATIONS APPENDIX F PIPE SIZING/ PUMP SIZING MEMO & CALCULATIONS 075704 (27) ER CONESTOGA — ROVERS He ASSOCIATES 1.0 INTRODUCTION 1.1 SCOPE OF SUBMITTAL This Report serves as the Engineering Reports for SKB Rosemount Industrial Waste Facility (Facility), which is permitted by the Minnesota Pollution Control Agency (MPCA) with permit number SW -383. The last MPCA permit for this Facility is PER008 and was issued on May 10, 2012. Currently, the permit contains seven permitted areas: DD001, I1,001, IL002, MA001, MC001, RE001, and TR001. Area DD001 is a class III demolition debris disposal area according to the standards set out in the 2005 Demo Guidance document. This area is permitted to accept for disposal: construction debris, demolition debris and industrial waste in accordance with the Facility's approved Industrial Solid Waste Management Plan (Tab 3 - Waste Acceptance Plan or WAP). DD001 is also referred to as Cell 5 (Cells 5A through 5D) in the Facility drawings. Area IL001 is an industrial waste disposal area. This area is permitted to accept for disposal wastes that meet the criteria under the Facility's approved Industrial Waste Management Plan (Tab 3 - WAP). IL001 is also referred to as Cells 1, 2, 3, and 6 in the Facility drawings. Area IL002 is an industrial waste disposal area that was designated to accept PFC contaminated wastes and other materials from the clean-up of 3M sites. This area is referred to as the 3M cell on Facility drawings. This cell was constructed totally within the boundary of Cell 3B. IL002 was closed in the fall of 2012 with the construction certification receiving approval from the MPCA on March 15, 2013. Area MA001 is a municipal solid waste combustor ash disposal area. This area is permitted to accept MSW combustor ash. Additionally, SKB has received several co- disposal approvals from the MPCA for a few additional industrial waste streams to be disposed of in this area. This area is referred to as Cell 4 in the Facility drawings. Area MC001 is a source separated compost area. This area is permitted, but not constructed. This area is permitted to accept source separated organics, sewage sludge that has been treated to meet Class B pathogen reduction standards in Minn. R. 7041, unused scraps of gypsum drywall, and limited types of organic industrial waste as outlined in the approved industrial solid waste management plan. This area is permitted to be constructed, operated, and moved around the Facility within the landfill 075704 (27) ER 1 CONESTOGA- ROVERS & ASSOCIATES footprint as outlined in the permit as needed to facilitate landfilling activities at the Facility. Area RE001 is a solid waste recycling area. There are two currently active recycling operations within the disposal areas of the Facility and another permitted but not yet constructed recycling area. First, SKB processes and readies for the recycling market post -burn metal that comes from the HERC incinerator. This recycling operation takes place on the working face of the MSW combustor ash disposal area (MA001). The second operation is a C &D recycling operation. In this recycling operation SKB processes and removes materials that can be recycled from select loads of C &D and removes metal from the C &D working face. In addition, SKB also processes shingle waste and readies the shingles for sale to the asphalt pavement market. Throughout the life of the Facility, SKB may move these operations within the permitted boundaries of the disposal areas. Last, SKB intends to construct and operate other recycling activities associated with this permit and the transfer station building operation. These other activities may include but are not limited to: single sort recycling operation, processing shredder fluff, processing ash, and processing C &D. Area TRO01 is a solid waste transfer area. This area is also permitted, but not constructed. This area is permitted to accept Construction and Demolition Debris, Industrial Waste (excluding asbestos), MSW Ash, Shredder Fluff, MSW, source separated recyclable materials, and source separated compostable materials. This Engineering Report includes information for the above referenced areas, which together make up the SKB Rosemount Industrial Waste Facility. In this application, the site will be referred to as either the "Facility" or "SKB Rosemount ". As part of the Facility's Permit Renewal Application, SKB proposes to increase the currently permitted footprint of Cell 6 by moving the waste limit within 185 feet of the southern property boundary along Ehler's Path, which will add 15 acres to the footprint of the landfill. This proposed increase will require removal of a portion of the unnamed wetlands currently located in this area and utilize a 2:1 soil berm. A draft EAW has been prepared in regard to removing the portion of the wetland and SKB is working with the City of Rosemount to ensure environmental concerns are addressed. And as part of the process, a wetland delineation and wetland application to the City of Rosemount as the entity with jurisdiction over the wetland is also in process. Additionally, with this permit renewal application SKB is proposing to increase the final height of the landfill to 1060 feet elevation from the currently permitted 1010 feet elevation. With the vertical expansion, SKB Rosemount is proposing additional capacity 075704 (27) ER 2 CONESTOGA - ROVERS & ASSOCIATES for Industrial and C &D Wastes only. A cover will be constructed on the MSW combustor ash waste cell (Cell 4) when it reaches the permitted capacity and industrial and /or C &D waste cells will be constructed on top of the closed MSW combustor ash disposal area to bring the landfill up to final grades. Last, with this application, SKB is proposing to alter the liner design from the previously permitted design in the saddle area between Cells 2/3 and 5. SKB proposes to replace the saddle sideslope liner and install the more stout approved industrial waste liner in these saddle areas. To the greatest extent possible, the leachate within the saddle cell will be directed to the industrial waste leachate management system. The saddle area will then be filled with a combination of C &D and industrial waste. Detail 7 on Drawing CI -15 shows a typical cross - section of this saddle area. An operational separation between the two areas will be maintained by SKB and industrial waste will be disposed on the industrial side of the high point in the saddle area and C &D will be disposed on the C &D side of the high point. Refer to In addition, when the C &D cell reaches capacity or when it is suitable for efficient operation of the Facility, SKB will also co- dispose of C &D debris within the industrial cell. However, only limited amounts and types of industrial waste, as approved by Dakota County and the City of Rosemount, will be co- disposed in the C &D cell. With the horizontal and vertical expansion to the Facility and additional proposed changes, SKB proposes to increase the total disposal capacity of the landfill by 8,325,571 cubic yards to 35,191,617 cubic yards. The total capacity in MA001 is not proposed to expand and remains as 2,648,950 cubic yards. The total volume of DD001 (Cell 5 and referenced in the permit app form as C &D wastes) is 7,490,591 cubic yards of C &D and approved industrial waste per the Waste Acceptance Plan (WAP) and 25,056,334 cubic yards for industrial waste and C &D wastes for IL001 (Cells 1,2,3 and 6) However, only industrial wastes have been placed in Cells 1,2 and existing portions of Cell 3. The permit renewal application submittal includes five (5) parts as follows: • Permit Application Form & Checklists for SKB Rosemount • Engineering Report - includes site analysis, hydrogeologic summary, site development plan, and engineering design for all the permitted areas at the Facility. • Industrial Solid Waste Management Plan also referred to as the Waste Acceptance Plan (WAP) - for all permitted areas of the Facility • Operations Plan - for all permitted areas of the Facility • Closure, Post - Closure, & Contingency Action Plan - for all permitted areas of the Facility 075704 (27) ER 3 CONESTOGA — ROVERS He ASSOCIATES Each document includes the appropriate information for each of the permitted areas at the Facility. The Engineering Report provides a discussion of the data and logic to facilitate the MPCA review of the Facility design, drawings, and hydrogeology. The Waste Acceptance Plan, or Industrial Solid Waste Management Plan, provides information on the waste acceptance at each area of the Facility. The Operations Plan provides information on the operation, cell development, leachate collection, storm water management, inspection and maintenance program, reports and recordkeeping, personnel training, health and safety plan, and closure and post - closure care for the permit renewal of the Facility. The Contingency Action Plan provides information on what will happen in the event that an emergency situation occurs. Each of these plans has been prepared in accordance with the MPCA Solid Waste Management Rules, Dakota County Solid Waste Management Ordinance 110, and the City of Rosemount Zoning Ordinance. The data developed for the various design discussions and the development of operational plans are provided in the text and appendices. Data and information used to prepare this report were prepared by SKB Environmental, Inc. (SKB) and Conestoga- Rovers & Associates, Inc. (CRA). Previously submitted materials are provided electronically in a CD included in this permit application. A site location map is provided on the title page of the Drawing Set. The existing conditions for the site, as per a topographical map generated from the November 9, 2012 aerial survey are shown as Drawings CI -01A and CI -01B. Adjacent property owners are shown on Figure 1.1 and a table summarizing the property owner's addresses is Table 1.1 1.2 GENERAL SITE DESCRIPTION Facility: SKB Rosemount Industrial Waste Facility, SW -383 13425 Courthouse Boulevard Rosemount, MN 55068 Site Permittee Owner and Operator: SKB Environmental, Inc. 251 Starkey Street St. Paul, MN 55107 (651) 224 -6329 075704 (27) ER 4 CONESTOGA- ROVERS & ASSOCIATES Primary Contacts: John Domke, Division Landfill Manager Geoff Strack, P.E., Environmental Engineer Jon Penheiter, Facility Manager Land Owner: Engineering Consultant: SKB Environmental, Inc. 251 Starkey Street St. Paul, MN 55107 (651) 224 -6329 Conestoga- Rovers & Associates 1801 Old Hwy. 8 NW, Suite 114 St. Paul, MN 55112 (651) 639 -0913 Contact: Margaret Zuckweiler, P.E., Project Manager Ron Frehner, P.E., Principal (651) 639 -0913 Area Served: The Facility principally serves Minnesota, primarily the seven county Metropolitan Area. Zoning: Waste Types: Non - hazardous industrial, municipal solid waste (MSW) combustor ash, C & D debris, recyclables such as; wood, concrete, asphalt, tires, cardboard, MSW (for transfer), shredder fluff, source - separated recyclable materials, yard waste, and source - separated compostable materials. Waste Management District - as per the City of Rosemount zoning ordinance. Facility Size: The Facility is located on a 237.8 -acre site. Approximately 237.8 acres will be developed of which approximately 167.1 acres will be disposal areas. The individual cell areas are as follows: 075704 (27) ER 5 CONESTOGA - ROVERS & ASSOCIATES Cell 1- Industrial - 5.1 acres Cell 2 - Industrial -17.1 acres Cell 3 - Industrial - 39.4 acres Cell 4 - Ash -12.5 acres Cell 5 - C &D - 41.2 acres Cell 6 - Industrial - 51.8 acres Total disposal area - 167.1 acres Transfer Station - 808,080 cy /year Recycling Area - 346,320 cy /year Composting Area - 50,000 tons of source separated compost material (SSCM) /year Note: These areas are based on actual waste limits for each cell. The cell limits are larger than the waste limits. Cells 3, 4, and 5, include space for the interior berms used in the "saddle" cells or piggyback cell for Cell 6. Table 1.2 presents a summary of waste capacities for the Facility. General Location: Southwest Quarter of Section 20 and Southeast Quarter of Section 19 Township 115 North, Range 18 West Rosemount, Dakota County Site Life: The disposal facilities on the site are expected to accept waste for the next 40 years. The composting, recycling and transfer areas may be open indefinitely. Ultimate Disposal Capacity: Cell 1 - Industrial - 341,454 cubic yards - Closed Cell 2 - Industrial - 1,458,507 cubic yards - Inactive Cell 3 - Industrial - 10,592,188, cubic yards - Active 3M cell (w/ in Cell 3) - 158,300 Cubic Yards- Closed Cell 4 - Ash - 2,648,950 cubic yards - Active Cell 5 - C &D - 7,490,591 cubic yards - Active Cell 6 - Industrial - 12,659,927 cubic yards - Not Constructed 075704 (27) ER 6 CONESTOGA - ROVERS & ASSOCIATES Estimated Annual Waste Volume: Industrial - 700,000 cubic yards per year Ash - 60,000 cubic yards per year C &D - 358,000 cubic yards per year 1.3 PERMIT HISTORY On January 8, 1992, Union Pacific Railroad (UPRR) was granted, by the state of Minnesota, a "Permit for the Construction and Operation of an Industrial Solid Waste Land Disposal Facility ". The facility was named "Minnesota Industrial Containment Facility, SW- 383 ". In early 1995, UPRR sold the "Minnesota Industrial Containment Facility, SW -383" to Laidlaw, Inc. of South Carolina. In August of 1997, the name of the facility was changed to "Laidlaw Environmental Services (Rosemount), Inc., SW- 383 ". In early 1998, Laidlaw, Inc. purchased Safety Kleen Corporation. In August 1998, Laidlaw, Inc. changed the name of the facility to "Safety Kleen (Rosemount), Inc., SW- 383." In June of 2000, Safety Kleen Corporation sold the facility to SKB Environmental, Inc. of St. Paul, Minnesota. SKB Environmental Inc. changed the name of the facility to "SKB Rosemount Industrial Waste Facility, SW- 383." The permit was reissued by MPCA to SKB, reflecting the change in ownership, on August 2, 2000. The permit was modified in April of 2003, 2008 and again in 2012. In 2003, SKB submitted an application for a major modification to add Cell 5, the C &D cell to the design of the Facility. In 2008, SKB submitted an application for a major modification to add Cell 6 to the design of the Facility. In May of 2011, SKB submitted an application for a major modification to add source separated composting to the permit. The MPCA issued the modified permit on May 10, 2012 to allow SKB to conduct source separated composting within the confines of the permitted landfill footprint and the in accordance with the conditions of SW -383. 075704 (27) ER 7 CONESTOGA- ROVERS & ASSOCIATES 2.0 SITE ANALYSIS 2.1 LOCATIONAL CRITERIA SKB Rosemount Industrial Waste Facility, SW -383 complies with the siting regulations outlined in Minnesota Rules 7035.1600, 7035.2555 and 7035.2885. A description of how the development of the SKB Rosemount Industrial Waste Facility complies with these regulations is provided in Table 2.1. Figure 2.1 presents the locations of groundwater wells within a 1 mile radius of the Facility. 2.2 HYDROGEOLOGIC AND GEOLOGIC ASSESSMENT A hydrogeological evaluation of the Facility was prepared by Environmental Engineering Management and submitted to the MPCA as Volume III of the January, 1991 Permit Application of the hydrogeologic and geologic conditions. A copy of the soil borings performed in 1991 can be found in the attached CD. Additional soil borings and monitoring wells have been performed and installed. The data obtained from these investigations are also included in the attached CD. 2.2.1 BEDROCK HYDROGEOLOGY AND GEOLOGY Previous investigations at the Facility indicate the first bedrock unit encountered is the Prairie Du Chien. The Prairie du Chien is composed of dolomite and sandy dolomite. The upper bedrock unit ranges in elevation from 795 feet above mean sea level to 680 ft. relative to the National Geodetic Datum of 1929 (NGVD). The overburden thickness ranges from approximately 60 to 190 feet. The average depth to the upper bedrock unit is more than 100 ft. The Prairie du Chien is hydraulically connected to the overlying glacial sediments and to the underlying Jordan Sandstone. Underlying the Jordan Sandstone is the St. Lawrence Formation which is underlain by the Franconia Formation. The St. Lawrence Formation is predominantly composed of sandy dolomite and dolomitic siltstone. The St. Lawrence Formation is predominantly composed of interbedded sandstone, siltstone and shale. The upper Franconia is a minor aquifer in this area of Dakota County. The lower Franconia and St. Lawrence act as regional leaky- confining units. The sandstone and dolomite bedrock units can provide significant quantities of groundwater for use by municipalities, industries and farmsteads. During 2012, groundwater elevations for the Prairie du Chien at the Facility ranged from 770 ft. to 815 ft. NGVD. Groundwater 075704 (27) ER 8 CONESTOGA - ROVERS & ASSOCIATES generally flows to the northeast toward the Mississippi River which acts as a discharge zone for the upper bedrock aquifers. Valleys have developed in the bedrock due to periods of glacial runoff during the Wisconsin and previous glacial periods. A major bedrock valley is located north of the Facility. This valley trends west - northwest to east - southeast and is approximately two miles wide. This valley has cut through the Prairie du Chien and Jordan units to an elevation of approximately 350 ft. NGVD. Smaller bedrock valleys have also been identified near the Facility. However, no geologic hazards such as sinkholes or other karst features have been identified beneath or near the Facility. 2.2.2 SURFICIAL HYDROGEOLOGY AND GEOLOGY Overburden sediments beneath the Facility are characterized predominantly by fine to coarse grained sand and gravel alluvial sediments deposited during the Wisconsin glacial period. Thin layers of silt and clay were encountered within the sand at a few locations. These sediments were deposited by the Superior lobe glacial advances and have been mapped as the Cromwell Formation. A silty till layer was encountered at the base of the sand unit in some Site borings. However, this silt unit is not continuous beneath the Facility and the sand and Prairie du Chien bedrock are hydraulically connected. The shallow water table is encountered within the overburden sand and gravel. During 2012, the water table elevation at the Facility ranged from 771 ft. to 820 ft. NGVD. Groundwater generally flows from the southwest to the northeast. Drawing CI -02 presents 2012 groundwater contours. 2.2.3 SOILS Soil formation from the United States Department of Agriculture - Natural Resources Conservation Service (USDA -NRCS) indicates that soils at the Facility range from silty clay loam to sandy loam, with sandy soils predominating the area. Specific soil series at the Landfill include Hawick coarse sandy loam, Easterville sandy loam, Dickenson sandy loam, Kennebee silt loam, Marsham silty clay loam and Kato silty clay loam. These soils develop on glacial outwash such as the sediments that underlay the Facility. 075704 (27) ER 9 CONESTOGA - ROVERS & ASSOCIATES 2.2.4 ENVIRONMENTAL MONITORING PLAN The groundwater monitoring network at SKB Rosemount was designed based on the analysis of local and regional hydrogeologic conditions. Groundwater beneath the site generally moves from southwest (upgradient) to northeast ( downgradient). Currently the Facility has a total of 27 monitoring wells. However, the approved sampling and analysis plan only requires monitoring at 17 of these wells. Drawings CI -01A and CI- 01B depict the locations of Monitoring Points. The current Sampling and Analysis Plan is included on the reference CD -ROM. Water levels are measured on a quarterly basis as required by the MPCA permit. Table 2.2 presents a summary of the Groundwater Monitoring Plan and Table 2.3 presents the analyte list for groundwater. The monitoring wells used as data collection points have been divided into four (4) groups. • Shallow Upgradient Monitoring Points (designated U #S). The shallow upgradient monitoring points consist of monitoring wells that are completed in the shallow water table aquifer south (upgradient) of the compliance boundary. • Deep Upgradient Monitoring Points (designated U #D). The deep upgradient monitoring points consist of monitoring wells that are completed in the lower sand/ Prairie du Chien aquifer south of the compliance boundary. • Shallow Downgradient Monitoring points (designated D #S). The shallow downgradient monitoring points are wells that are completed in the shallow water table aquifer along the northern (downgradient) compliance boundary. • Deep Downgradient Monitoring Points (designated D #D). The deep downgradient monitoring points are monitoring wells that are completed in the lower sand /Prairie du Chien aquifer along the northern compliance boundary. Leachate samples are collected from seven (7) locations. The leachate sampling sites at SKB Rosemount consist of a composite of sumps for Industrial Cell 1, composite of sumps for Industrial Cell 2, composite of sumps for Ash Cell 4, sump of Construction and Demolition Cell 5, composite of sumps for Industrial Cell 3, and the lift station sump. The 3M leachate, which is trucked off site and treated at the 3M facility in Cottage Grove, is sampled off site. Leachate samples are analyzed in accordance to SKB Rosemount's permits. Leachate production is tracked daily, and quarterly reports are submitted to MCES and MPCA. Table 2.4 presents the analyte list for leachate. The leachate historically contains small quantities of all the metals analyzed, well within acceptable limits. The most commonly detected organic compounds are Acetone, 075704 (27) ER 10 CONESTOGA - ROVERS & ASSOCIATES Benzene, Cresol, Ethylbenzene, Methyl Ethyl Ketone (MEK), Methylene Chloride, Methyl -Tert -Butyl Ether (MTBE), Phenol, Tetrahydrofuran, Toluene, and Xylene. The methane monitoring network at SKB Rosemount consists of fifteen (15) monitoring points at this time. One (1) is located on the top of Cell 1, three (3) monitoring points are evenly spaced on the west slope of Cell 2A, and twelve (12) monitoring points are located along the perimeter of the site. Methane has been monitored since October 17, 2000. It was monitored three (3) times per week until April 29, 2004 when it was revised to Quarterly. No methane has been detected outside of the cells. 2.2.5 CLIMATE The average annual prescription for Rosemount, Minnesota is 26.2 inches per year. The 25 -year, 24 -hour duration storm is 4.03 inches. 2.3 SURFACE WATER MANAGEMENT PLAN Storm water management at SKB Rosemount provides for the control of surface water resulting from precipitation events on the landfill area and Facility property. The Surface Water Management Plan following site closure is shown on Drawing CI -07. Stormwater analysis for the stormwater management plan is detailed in Appendix A. Storm water drainage facilities are constructed for the following purposes: (1) to modify existing storm water retention areas to increase capacity and assure management of the 100 -yr 24 -hr storm event, (2) to construct control facilities to convey runoff from the landfill to retention and infiltration areas, (3) to collect and manage precipitation falling on the covered area of the cell. The existing and future storm water management plans for SKB Rosemount consists of structures and practices to control runoff inside and outside of the cells. The control facilities outside of the cells manage storm water from precipitation that falls outside of the cells whereas the control system inside of the cells controls storm water from precipitation which falls inside of the cells. Storm water that contacts wastes is called contact water and is treated as leachate. The management of the contact water and leachate is discussed in Section 3.6 of this Report. Delineation berms provide separation from the constructed disposal area from the outside of the landfill. These berms keep storm water that contacts the waste inside the 075704 (27) ER 11 CONESTOGA - ROVERS & ASSOCIATES cell from leaving the cell. It also keeps storm water from outside the cell from running into the cell. The phase delineation berm details are shown on Drawing Cl- 28. In addition to the delineation berms, SKB implements operation practices to prevent contact water from running off of the active disposal area and to prevent storm water from outside the cell from running onto the active disposal area. The storm water control structures consist of a series of storm water infiltration basins connected by a drainage ditch network designed to manage runoff from a 100 -year, 24- hour precipitation event occurring over the landfill property, as required by the City of Rosemount. The existing constructed and other natural storm water retention areas provide a storage and treatment capacity of equal or greater volume than that which existed historically at the site. As the new cells are constructed, the storm water management ditches will be constructed to adequately manage and convey runoff to the stormwater infiltration basins. Storm water drainage ditches will be modified and constructed to provide storm water management as needed during ongoing development of the Facility. 2.3.1 STORMWATER MANAGEMENT ANALYSIS The stormwater management improvements are designed in conformance with the requirements set forth in the Comprehensive Surface Water Management Plan for the City of Rosemount, Minnesota. The method of analysis included USDA TR -55 and Minnesota State guidance's to estimate rainfall intensity, flow rates, and storage requirements. A hydrologic model was created using Hydraflow software package (Autodesk, Inc. Version 8) to redefine runoff rates and to develop stormwater management improvements given the proposed site grading modifications. Details and additional assumptions are discussed in detail in Appendix A. A combination of drainage facilities are employed to control runoff under various design storm events from tributary areas which include those areas on the landfill cells, outside the cells and offsite areas. Stormwater management facilities are designed, in accordance with the City of Rosemount Comprehensive Surface Water Management Plan, to retain all surface water runoff that is resulting from the 100 year 24- hour design storm event (6 inches of rainfall) under landfill final closure condition. The MPCA only requires managing the 25 -year 24 -hour storm event (4.85 inches of rainfall). A hydraulic analysis was completed using Hydroflow to adequately size the diversion berms, downchutes, and perimeter ditches. The stormwater management 075704 (27) ER 12 CONESTOGA - ROVERS & ASSOCIATES improvements have been designed to contain flows up to the 100 -year, 24 hour storm event (6 inches of rainfall) while keeping the post development discharge less than the contributing offsite flows coming from the northwest under the 25 -year and 100 year 24- hour design storm event scenarios. An analysis of the 100 -year, 24 -hour storm was also completed to evaluate the performance of the stormwater ditches, downchutes, and culverts. Calculated channel depths and velocities were then used to establish appropriate erosion control measures. Runoff from the perimeter ditches are ultimately routed southerly to Basin 6A, prior to discharging offsite via a control structure that outlet to an existing 6 feet x 3 feet box culvert. Drawings Cl- 23 through CI -26 show details of the stormwater basins and stormwater control structures based on the results of the stormwater analysis. Any storm water contacting wastes is not included in the stormwater analysis as it is collected and treated as leachate. Runoff from the onsite tributary areas either discharge to the perimeter ditch system via diversion berms located per MPCA slope guidance, on the landfill side slopes and downchutes, or drain directly to a perimeter collection ditch or one of the perimeter basins. 2.4 VEHICULAR FLOW AND ACCESS CONTROL All incoming traffic comes in the main gate off Courthouse Boulevard, which is currently Minnesota State Highway 55. The majority of the traffic that is accessing the Facility will access Courthouse Boulevard via US Highway 52. The site has a second gate south of the site off 140th Street. The Minnesota Department of Transportation has plans to move Minnesota State Highway 55/ US Highway 52 interchange to the south to the current location of County Road 42 interchange. When this takes place, the road in front of the landfill will turn into a frontage road to access the industries in the area. Vehicles of all types utilize the Facility. The site is mostly utilized by large vehicles such as: roll -off trucks, semi tractors with various types of trailers (i.e. end dump trailers, walking floor trailers, side dump trailers, belly dump trailers), dump trucks of various sizes, and pick -up trucks. The Facility has two scalehouses and four scales on -site. During the busier months, all four scales are open for receiving acceptable materials. When all of the scales are open, vehicles are directed to different scales depending on the type of waste material and the required check in procedures per the Facility's approved Waste Acceptance Plan (WAP). 075704 (27) ER 13 CONESTOGA- ROVERS & ASSOCIATES During the less busy months, all traffic is directed to the scalehouse next to the main administrative office building. Traffic routed within the landfill will utilize the site access roads. Vehicles entering the landfill will check in and be inspected at the industrial scale or C &D scalehouse prior to disposal. They will then be routed to the waste specific working face where they will off -load while being inspected. Once empty, the vehicle will typically exit the site via gate #1. However, SKB does allow a few trucks to exit the Facility using gate #2. Limited parking, as needed, is available adjacent to the office. 075704 (27) ER 14 CONESTOGA- ROVERS $ ASSOCIATES 3.0 FACILITY DESIGN REPORT The following subsections present major design features for the three waste cell types: Industrial Waste Disposal Area (Cells 1, 2, 3 & 6), Municipal Solid Waste Combustor Ash Disposal Area (Cell 4) and Demolition Debris Disposal Area (Cell 5). The following discussion includes an overview of the existing conditions of the entire site, the waste flow /capacity /phasing designs, the basegrade designs, the liner designs, the leachate collection system designs, and the cover designs. Additionally, SKB Rosemount is proposing changes to the design of the land disposal areas of the Facility. The first change is to increase the currently permitted footprint of Cell 6 of the Industrial Waste Disposal Area so that the waste limit is approximately 185 feet from the southern property line. This change would add 15 acres of disposal footprint to the currently approved design for Cell 6. The second change is to increase the height of the landfill by 50 feet. These two changes together would add 8,325,571 cubic yards of capacity to the total permitted volume of the landfill. All of the additional capacity will be either industrial solid waste or C &D debris. SKB is not proposing to increase the permitted capacity of the MSW combustor ash disposal area. The last change is to alter the liner design in the saddle area between Cells 3/2 and Cell 5 where an approved industrial waste liner profile will be constructed and the saddle area will receive a mixture of industrial waste and C &D debris. As shown on the detail on drawing CI -07 wastes approved to go into IL001 will go on the Cell 2/3 side of the high point and wastes approved to go into DD001 will go on the Cell 5 side of the high point of the saddle area. These proposed design changes and details are included in this engineering report. 3.1 EXISTING CONDITIONS The original design was submitted to the MPCA in the 1992 permit application. The design was modified by SKB with the Design Modification document dated April 6, 2001. The MPCA approved the minor modifications in a letter dated May 16, 2001. The MPCA approved the Major Modification Application, permit issued May 29, 2003. Also submitted was an MPCA Facility Permit Reissuance Application in November 2007 as well as an additional Major Modification Application dated October 3, 2008. The MPCA also approved a modification to the permit in 2012 to approve a composting area to be constructed and operated at the Facility. . Drawing CI -01 shows the existing site conditions and topography of the Landfill as of November 8, 2012. The MPCA reissued the current permit May 10, 2012. The current 075704 (27) ER 15 CONESTOGA- ROVERS & ASSOCIATES design of the landfill includes Cells 1, 2, 3 and 6 as disposal areas for industrial waste, Cell 4 as disposal area for MSW combustor ash, and cell 5 as disposal area for the disposal of C &D debris. The liner systems for Cells 1, 2, 3A, 313, 3C, 31), 3M, 2A, 213, 2C, 21), 4A, 413, 4C, 5A, 513, and 5C are already constructed. These areas have had construction certifications submitted and approved by the MPCA. This Report will not discuss the design of these areas in any great detail as they are already constructed with waste already in place in these areas. This Report will focus on the design of the areas yet to be constructed and how the proposed modifications will affect the areas already constructed. The 3M dedicated waste cell was constructed in 2009 within a portion of Cell 313, and was utilized to dispose of impacted soils and demolition debris from the clean -up of 3M related PFC clean-up. The 3M waste cell cover construction was completed in December 2012 and approved by the MPCA on March 15, 2013. The 3M SubCell cover design for 3M waste, from bottom to top, is a 1 foot Fill Layer, an 80 MIL HDPE Liner, a Geocomposite Drainage Material, and a 2 foot Protective Sand Layer. Additional Industrial Waste will be deposited on top of the 3M SubCell as part of Cell 3B. The 3M SubCell location is shown in Drawing CI -01. Cell 6 is not yet constructed. SKB Rosemount is proposing to increase the currently permitted footprint of Cell 6 by increasing the footprint by 15 acres. 3.2 WASTE FILL STABILITY A slope stability analysis was performed for Cells 1 -6 by Inspec -Sol, Inc. a subsidiary of CRA, for the Facility to confirm that the factor of safety for the proposed facility design exceeds 1.5 for all conditions, which is the industry standard. The factor of safety is defined as the ratio of soil shear resistance to driving shear forces along an assumed sliding surface. A value of 1 theoretically implies imminent failure. Supporting calculations, geometry, and material property assumptions can be found in the Inspec- Sol report in Appendix B. A summary of the analysis that were performed are summarized in the following sections. 3.2.1 GLOBAL STABILITY ANALYSIS Global slope stability analysis were performed for the proposed expansions using the Morgenstern & Price Method using the module Slope/ W of the computer software Geo- 075704 (27) ER 16 CONESTOGA - ROVERS & ASSOCIATES Studio 2007, Version 7.21, developed and distributed by Geo -Slope International Ltd. The computer program conducts the slope stability analysis on many potential failure surfaces and by iteration moves in on the critical failure surface (i.e. the failure surface with the lowest factor of safety). This iterative process is done by searching different parts of the banks for instability, (i.e. shallow and deep slides). The analysis program provides the factor of safety associated with each failure surface analyzed. The lowest calculated factor of safety is 1.58 occurs assuming saturated conditions in the exterior berm. This worse case condition is unlikely to occur as the berm will be constructed to minimize holding water within its bank, the 2:1 berm is shown to be stable. A review of the results of all the analyses shows that the targeted minimum factor of safety of 1.5 has been achieved for the proposed 4H:1V at all the cross - sections locations and along all critical slip planes either user specified or found by computer using the estimated lower -bound soil shear strength properties. The proposed landfill side slopes at 4H:1V at the height of 1060 feet in elevation and the toe berms with side slopes at 2H:1V are considered to be stable. 3.2.2 VENEER STABILITY ANALYSIS The cover system sliding stability analyses were performed using the infinite slope methodology. This analysis was completed for the critical interfaces between the geosynthetic layers and between geosynthetic layers and landfill soils or cover system soils. The interface shear strength parameters have been assumed based on the literature review and past experience with similar components. The interface shear strength parameters used and the results of the analyses are presented in Appendix B. The minimum factor of safety calculated is 2.06 and shows that for the assumed interface -shear strength parameters and conditions, the calculated factors of safety exceed 1.5 for the 4H:1V side slopes. 3.3 BASEGRADES Basegrade elevations for the site are presented in Drawing CI -03 (Subgrade). As stated above much of the liner system for Cells 1 -5 have already been constructed. However, many of the saddle areas between these cells are yet to be constructed along with the 075704 (27) ER 17 CONESTOGA - ROVERS & ASSOCIATES entirety of Cell 6. The bottom the liner contours for the redesigned and expanded Cell 6 has been designed to keep at least a one foot separation from the water table for Cell 6. Basegrades for the entire Facility shown on CI -03 and a blow up of the basegrades of Cell 6 are shown on CI -04. These basegrades are the basegrades discussed with the MPCA, Dakota County, and the City of Rosemount in a meeting on February 14, 2013. The construction of the base grades for Cell 6 will include excavation of the existing soil and construction of perimeter berm. Excavation will take place as soil is needed either for landfill operations or as the need for the new cell approaches. The perimeter berm will be constructed by placing and compacting of the general fill soil. Once the overburden soils are excavated and perimeter berm is constructed the area will be finish graded to match the basegrade elevations depicted in Drawing CI -04. Basegrades in the saddle areas, which are currently used as on -site roads, will require some reconstruction prior to liner installation to direct leachate to flow toward the leachate collection systems suited to manage the leachate. The road between Cell 2/3 and Cell 5 for the saddle Cell 5D will be re- graded to allow leachate flow to enter Cell 2 or 3 liner systems. All the basegrades have at least a 2% grade and the maximum grade is 33 %. While the requirements of Minn. R. 7035.2815 do not pertain to the liner construction of industrial solid waste disposal areas, SKB has designed the base grades to meet these requirements. 3.4 LINER DESIGNS Many liner profiles have been constructed over the life of the Facility. A summary of what liner types that have been constructed can be found in Table 3.1. The remaining liners that are to be constructed at the Facility are either for the MSW combustor ash disposal area (MA001) or the industrial waste disposal area (I1,001). Details of these liner profiles can be found on Drawings CI -19, CI -20 and CI -21. Prior to placing the liner within the cells, a registered professional engineer or qualified representative under the direction of the engineer, will inspect the ground surface to ensure that the construction crew has removed all stones, protruding objects and other debris that could potentially damage the liners. If applicable, clay compaction test results and field quality control records will be prepared and certified in accordance with the Construction Quality Assurance Plan included in Appendix B of this Report. 075704 (27) ER 18 CONESTOGA - ROVERS & ASSOCIATES The synthetic HDPE liner system will extend along the entire cell floor and side slopes. Full width liner panels will be used to minimize the number of seams in the completed cell. Seams will be oriented to run along the slope whenever possible and all of the seams will be tested for soundness in accordance with the Construction Quality Assurance Plan for the Facility. Any seam or portion of the liner that appears damaged or inferior in any way will be repaired or replaced as directed by the field engineer. 3.4.1 INDUSTRIAL WASTE LINERS Cells 1, 2A, 2B, 2C, 2D, 3A, 313, 3C, and 3D are already constructed and consist of various versions of the same design with three layers. They are designed with a clay component (either recompacted clay or geosynthetic clay liner) and two high- density polyethylene (HDPE) synthetic liners. Details for liners previously installed are shown on previously submitted drawings. These drawings are included in section CD -ROM reference. SKB is proposing to construct the remaining areas of IL001 (Cells 6A, 6B, 6C, 6D, and the saddle areas that have not yet been constructed) with a liner with a total of three (3) barrier layers. Details of the proposed liner profiles for the remaining portions of IL001 can be found on Drawings CI -14, CI -15, CI -19, CI -20 and CI -21. Below is a further discussion of the liner profiles to be constructed. SKB is proposing to have one of the approved liner profiles for the remainder of IL001 to be the liner profile that has been constructed the last few liner projects. This liner profile consists of, from the top to the bottom: • Primary drainage composite or one foot of drainage sand • Primary liner, which consists of a 80 mil HDPE geomembrane • Secondary drainage collection layer • Secondary composite liner, which consists of - 60 mil HDPE geomembrane - Geosynthetic Clay Liner (GCL) or two feet of 1E -7 cm /s recompacted soil liner If a GCL is used and it will intersect an area already constructed using a recompacted clay liner an overlap between the clay and GCL will be implemented. GCL is utilized as a substitute soil barrier that consists of bentonite clay pressed between two geotextile fabrics (needled, stitched or unbound). For areas of low slope, a GCL with minimal 075704 (27) ER 19 CONESTOGA - ROVERS He ASSOCIATES needle punching will be utilized. However, on the sideslope of the landfill, a GCL with needle punching will be utilized to increase the internal shear strength of the liner. The liner components are summarized in Table 3.1. The base grades are shown on Drawings CI -03 and CI -04 SKB is proposing an alternate liner profile for construction in IL001. This liner profile still consists of three barrier layers. This liner profile has been described and analyzed in an article authored by Richard Erickson, Richard Thiel, and Gregory Richardson. A copy of this article can be found in GFR Magazine; Designer Forum: GCL Design Series - Part 1: GCL Performance as a fluid barrier, June /July 2002. This proposed liner profile is a triple composite liner and would consist of, from the top down: • Primary drainage composite or one foot of drainage sand • 80 mil HDPE geomembrane liner • Geosynthetic clay liner (GCL) • 60 mil HDPE geomembrane liner This liner is referred to as an encapsulated GCL liner in the article. As discussed in the journal article this liner profile exhibits a 100 to 10,000 times lower leakage rate through assumed defects in the liner that that of the liner profile prescribe by subtitle D. As lining technologies advance, SKB may substitute, with MPCA approval, an item in the approved liner profile with the equivalent or superior alternative. Cells 3E and 3F fill saddle areas over the existing cells mentioned above. They will not have additional liner systems except over the berm road to connect the existing liner. Prior to the liner construction between Cells 3 and 5, the road will be removed and regraded to allow as much leachate as is possible to flow into Cell 3. The grade leachate divide in the Cell 2/3 and Cell 5 will be the delineation between the C &D cell and the industrial cell. The area east of the divide will be C &D debris and the limited low level industrial waste approved by Dakota County and the City of Rosemount. To the west of the divide, SKB will dispose of industrial waste as outlined in the waste acceptance plan. When Cells 6A and 6D are constructed - the liner systems will be connects to the liner systems in Cell 2 as the current existing road on the south side of Cell 2 will be lined. 075704 (27) ER 20 CONESTOGA— ROVERS He ASSOCIATES 3.4.1.1 INDUSTRIAL CELL PROTECTIVE SAND LAYER If the constructed liner profile for IL001 incorporates a drainage composite as part of the leachate collection and drainage system, SKB will place a minimum of a one -foot protective soil layer will be installed to protect the liner system for industrial waste cells. 3.4.2 MSW COMBUSTOR ASH LINER The primary source of the ash is from Hennepin County and their Hennepin Energy Resource Co. (HERC) incinerator, located in Minneapolis, Minnesota. The ash is a combination fly ash and bottom ash from the combustion of MSW. The fly ash is mixed with a lime - slurry spray injected into the exhaust of the plant. The bottom ash contains oversized metallic materials and some unburned combustibles. The disposed ash is approximately 15 percent is fly ash and 85 percent is bottom ash. The primary contaminants are heavy metals. The ash is tested quarterly using the testing protocol established under Minnesota Rules part 7035.2910. As required in Minn. Rule 7001.3480, Subpart C, the original application for the Facility included a leachate data comparison to the MLCLs. The MLCLs in Minn. Rule 7035.2885 Subpart 5 were compared with the ash leachate and manganese was the only chemical constituent that exceeded the MLCLs. Therefore when the ash landfill liner was constructed, the ash leachate analysis indicated that the ash required a "P" liner. The liner design for constructed portions of Cell 4 exceed the MPCA requirements for a "P" liner as shown in Minn. Rule 7035.2885, Subpart 11, P. The "P" liner is the most stringent liner system in the ash rules. The liner design of a 60 -mil and 80 -mil synthetic membrane used in Cell 4 exceeds the requirement of a 30 -mil and a 60 -mil synthetic liner. Analysis on the constituents in current combustor ash leachate analysis was performed and no chemicals exceeded the MLCLs. Therefore any new combustor ash liners constructed are required to meet the criteria to construct an "N" liner as detailed in Minn Rule 7035.2885 Suppart 11, N. The final cover design also exceeds the requirements in Minn. Rule 7035.2885 Subpart 10 by using a 40 -mil synthetic membrane as opposed to the required 30 -mil synthetic membrane. The design for constructed portions of Cell 4 is composed of three layers. The two synthetic liners overlying the cell side slopes and cell floor will be composed of HDPE. 075704 (27) ER 21 CONESTOGA- ROVERS & ASSOCIATES The primary liner, nearest the waste, is 80 -mil HDPE. The secondary liner is a 60 -mil HDPE liner. The third, or lowest, liner consists of a 3 -foot compacted clay liner. The liner components are summarized in Table 3.1. The base grades are shown on Drawings CI -03 and CI -04. The Cell 4D saddle area has already been constructed by SKB and approved by the MPCA. For this saddle area, the MPCA approved a substitution of a GCL for the two feet of clay. SKB will construct the saddle area for Cell 4E using the same profile constructed in the 4D saddle area, which is, from the bottom up: GCL, 80 mil HDPE geomembrane, drainage composite, one foot of protective soil. The detail for the remainder of the MA001 liner can be found on Drawings CI -13 and CI -14. 3.4.3 C &D LINER Because SKB is proposing to change the liner type in the Cell 2/3 and Cell 5 saddle area to the industrial waste liner and accept industrial waste in the area of the saddle where the leachate will drain to the industrial waste liner system, all of the C &D liner system is now constructed. Cells 5A, 5B, and 5C have already been constructed and approved by the MPCA. These areas have several different liner profiles that were approved and constructed. The liner profile for each cell can be found in Table 3.1. 3.5 LEACHATE COLLECTION & STORAGE SYSTEMS The SKB leachate collection system consists of geocomposite drainage layer. The geocomposite layer, along with the leachate pipes and aggregate, drain the leachate to the collection sump. The sumps incorporate side -slope risers to eliminate penetration of the liners. 3.5.1 LEACHATE GENERATION AND SAMPLING The existing MPCA and MCES permit requires leachate produced from the facility to be sampled quarterly. In spring, summer, autumn and winter, the samples are analyzed using the Minn. R 7035.2885, Subp. 16 item B(1), and additional compounds as required by MCES permit (see March 10, 2004 Sampling Analysis and Sampling Protocol). The MCES also requires monthly sampling. The MCES sampling is done at the sump or tank on mixed leachate and samples are analyzed. 075704 (27) ER 22 CONESTOGA- ROVERS & ASSOCIATES The HELP model was utilized to estimate the landfill's leachate generation rates. Several open conditions were modeled and utilized in estimating the theoretical maximum leachate generation rate from the facility. The maximum predicted leachate volume is 33,800,000 gallons /year when Cells 1 -5 are open and the first phase of Cell 6 is constructed. Leachate generation for the last 3 years, and model calculations are provided in Appendix D. The comparison between the HELP model predictions and recorded leachate generation rates indicates that the HELP model overestimates the volume of leachate generated at SKB Rosemount by a factor of at least 1.6 times. The leachate generation rate for the same condition is likely to be closer to 21 million gallons/ year. Post closure leachate generation rates from the 161.5 acres of landfill predicted by the HELP model, is less than 150 gallons /year. This leachate generation rate when compared to the known volume of leachate produced from closed areas at SKB Rosemount is lower than what is expected to be generated. A more realistic generation rate based on current generation rates is approximately 130,000 gallons /year. 3.5.2 LEACHATE HEAD AND LINER EFFICIENCY Two models were utilized to show that head on the liner in Cell 6 will remain below the maximum of 12 inches. The Hydrologic Evaluation of Landfill Performance (HELP) model and the Giroud equations utilizing two slopes were utilized to determine the maximum head. The HELP model does not allow for basegrade changes that are present in the design of Cell 6. In order to account for slope changes the Giroud equations were utilized to show that the design will maintain head less than the maximum allowed head of 12 inches on the basegrade liner and on the geomembrane in the final cover system. Appendix C provides additional discussion why two models were used and details on the HELP and Giroud equation analyses. The maximum head predicted by the HELP model on the liner is 0.077 inches when 10 feet of waste is modeled on the liner. It should be noted that the geonet thickness within the geocomposite is 0.2 inches. The Giroud method predicts a maximum of 0.017 inches of head within the geonet on the 2% basegrade. The difference in maximum head on the basegrade calculated by the HELP model and the Giroud equations is due to the differences in how the HELP model generates the head with the 2% basegrade geometry. 075704 (27) ER 23 CONESTOGA - ROVERS & ASSOCIATES Efficiency of the liner and cover systems exceeds the efficiency design requirements in the Minnesota Rules; greater than 99% for the liner, and greater than 90% for the final cover. The efficiency of the liner and cover designs is predicted by the HELP model to be greater than 99.9 3.5.3 LEACHATE COLLECTION SYSTEM PIPE STRENGTH Leachate pipe strength calculations were performed to determine the factor of safety in terms of wall crush and deflection given the anticipated future conditions for Cell 6 and the vertical expansion over existing cells. A minimum factor of safety of 2 was considered adequate since the calculations incorporate several partial factors of safety. Based on the anticipated future conditions and the assumptions made during calculations for pipe strength factors of safety, the use of SDR 11 HDPE pipe in Cells 6 is acceptable. Please refer to the support documentation in Appendix F. Additionally, pipe strength calculations show that the pipe installed in Cells 1 -5 exceeds the factor of safety of 2 for wall crushing, deflection and buckling when an additional 50 feet of waste is added. The collection pipes in future phases will be 6 -inch diameter, perforated, SDR -11, HDPE pipe. Collection pipe installed in Cells 1 -5 is comprised of the same piping materials. Pipe strength calculations are presented in Appendix E and were completed using a material thickness of maximum of 250 feet, which exceeds the final cover grades which equate to 236 feet. Ring deflection is the normal response of flexible pipes to soil pressure. It is also a beneficial response in that it leads to the redistribution of soil stress and the initiation of arching. Ring deflection can be controlled with acceptable limits by the selection of appropriate pipe embedment materials, compaction levels, trench width, in some cases, the pipe itself. A target factor of safety of 2 or greater was achieved for Wall Compression and Ring Buckling calculations to ensure system performance reliability. Ring deflections under maximum loading for all piping applications were below the recommended 5% for pressurized piping for the forcemain from MI-19 to MH8 as shown on CI -05 and 7.5% for non - pressurized piping. All leachate piping to be used in the design has been sized and evaluated to withstand the loading scenarios and longevity stress resistance requirements to perform without structural failure for 50 years. HDPE pipe and geotextile, if necessary, will be placed in the pipe trenches as specified in the Technical Specifications attached to the Construction Quality Assurance Plan included as Appendix B. A layer of coarse aggregate will be placed in the trench and the 075704 (27) ER 24 CONESTOGA — ROVERS He ASSOCIATES pipe will be placed and aligned. The remaining coarse aggregate will be placed after the pipe is fully installed. An one -foot thick layer of pea gravel will then be placed over the coarse aggregate to provide a filter. This pea gravel will help stop migration of particles that might otherwise clog the collection pipe. The granular drainage layer material will then be placed over the trench. 3.5.4 LEACHATE COLLECTION SYSTEM The leachate collection system is designed to handle all of the leachate generated in a cell. The system will collect and remove all rainfall that falls on the waste (minus evaporation and moisture stored in the waste as soil moisture storage inside the cells). Leachate is typically removed, tested and disposed of at a municipal wastewater treatment facility without the need for prior treatment. Additional discussion of leachate testing and distribution is included in the Operations Plan included in Tab 4 of this permit application. Leachate generated within a cell is directed to the sump area on the cell floor by the leachate collection pipes as shown on Drawing CI -05. The leachate in the sump is withdrawn through a side slope riser (SSR) pipe. See the details provided in Drawing CI -19, CI -20 and CI -21. Leachate collection pipes are proposed to be installed at 200 foot intervals across the base of Cell 6 and convey leachate to the collection header pipe which is located on the west and south side of the Cell. Each collection pipe slopes at a minimum 1.5% toward the leachate collection header pipe or sump. The leachate header pipe flows at a minimum of 1.5% grade to each leachate sump. The Cell 6 design included two sumps; Sump 1 located in the north corner of the cell and Sump 2 located in the south east corner of the cell. Sump 1 collects drainage from approximately 65% of the proposed Cell 6 basegrade. Sump 2 collects drainage from the remaining 35% of drainage area of the Cell 6 basegrade. Leachate that collects in each respective sump is pumped out of the sump by a submersible pump to a lift station manhole (MH) or gravity drain line. The gravity drain line and MH9 service Sump 1 and Sump 2 respectively. Leachate from MH9 is pumped to the gravity drain line. Leachate from the gravity drain line will flow to an existing gravity line and ultimately flows into SKB Rosemount's existing gravity leachate line located near the southwest corner of Cell 2. Pipe flow and pump sizing calculations are shown in Appendix F. The leachate collection lines are cleaned each year by jetting the lines. Access to the lines will be from two ends of the pipe. A local company has consistently jetted up to 1,300 075704 (27) ER 25 CONESTOGA - ROVERS & ASSOCIATES feet of pipe one way. The jetting company indicated that the limiting factor in jetting the any length of pipe is ultimately the length of the hose between the water source and the jetting nozzle. The jetting company has jetted lines 1,800 feet in one direction. Leachate collection pipeline lengths have been limited to 2,600 in order to stay within the limits of what the jetting company has completed in the past. A leachate gravity line is utilized to transfer leachate from sumps to the connection to the MCES pipeline for Cells 1 -5. The second sump in Cell 6 will require a lift station to pump the leachate to the connection to the MCES pipeline. Lift station details are shown on Drawing CI -21. Leachate storage tanks are located near the MCES pipeline connection and one tank is readily available for storage. The remaining two tanks require minimal work to initiate their availability. 3.5.4.3 INDUSTRIAL CELLS LEACHATE COLLECTION The primary leachate collection system, which is the one placed closest to the waste materials, includes a 200 mil geocomposite drainage composite layer with a transmissivity of 10 cm /s. This geocomposite drainage layer is overlain by a 12 -inch protective layer. This protective layer consists of on -site sand. The liner is graded toward collection trenches with a leachate collection pipe (perforated) surrounded by an aggregate filter. The 80 -mil HDPE liner is directly under the drainage and protective layers. The secondary leachate collection system, which is the one placed directly below the primary liner, consists of a geocomposite material across the side slopes and geonet on the base of the landfill. The annular space above the secondary 60 -mil HDPE liner acts as a leak detection system for the entire landfill. Leachate will be withdrawn from the secondary system independently from leachate withdrawn from the primary system (Drawing CI- 21). The leak detection system will be tested for the presence of water by activating the dedicated pumps in the side slope riser pipes for the secondary leachate collection system. If water is found to be present, it is pumped out and the quantity measured. If 40 gallons per acre per day of water are found, item A -9 of the Contingency Action Plan will be implemented. The sump locations are provided on Drawings CI -04 and CI -05. The alternate liner profile proposed in this application by SKB consists of only one leachate collection system. This system is identical to the primary leachate collection system described above. 075704 (27) ER 26 CONESTOGA - ROVERS & ASSOCIATES 3.5.4.4 ASH CELL LEACHATE COLLECTION The sideslope to be constructed over subcells 3B and 3D will consist of 2 feet of clay or GCL overlain by 80 mil HDPE liner, geocomposite or 1 -foot drainage layer and 1 -foot protective layer or a 12 -inch drainage layer with a permeability of at least 1x10 -2 cm/ sec across the base and side slopes of the landfill. 3.5.5 LEACHATE GRAVITY LINE An underground double walled leachate gravity line has been installed to transfer leachate automatically pumped from the cell sumps to the storage tanks. This design for Cells 1, 2, 3, 4, and 5 was submitted to the MPCA in the February 28, 2001 Design Modifications document. The MPCA approved the design as part of the modification approval in the letter dated May 16, 2001. The system was installed during the 2002 and 2004 construction seasons. Leachate gravity line profiles are presented as Drawing Nos. CI -16, CI -17, and CI -18. When Cell 6 is constructed, it will also be connected to the existing gravity line as shown in Drawing No. CI -17. 3.5.6 STORAGE TANKS Three leachate storage tanks are located near the access road to the west of Cell 1. The tank design includes a secondary containment structure which is a concrete, bermed pad capable of containing the capacity of one of the tanks plus the 25 -year, 24 -hour storm event and freeboard (Drawing CI -01). Each tank has a capacity of approximately 250,000 gallons. All three tanks are currently not used. If necessary, SKB Rosemount can utilize the insulated tank. 3.6 INTERMITTENT AND INTERMEDIATE COVER Intermittent cover will be placed in all areas that receive waste. Intermittent cover will consist of at least 6 inches compacted soils or approved alternative cover system. Intermediate cover will be placed on any cell or phase, which is not part of the active working face of the Landfill and will not be covered by a subsequent layer of waste within 120 days. Intermediate cover will consist of at least 12 inches of compacted soils which includes the 6 inches of intermittent cover. 075704 (27) ER 27 CONESTOGA - ROVERS & ASSOCIATES 3.6.1 FINAL COVER DESIGN The placement of final cover for the landfill phases will be in accordance with the final contour plan shown on Drawing CI -06. As the closure and post closure care operating experience dictates, adjustment and amendments may be made to future closure designs and activities. The final cover profile for the Cells 1 -6 is detailed on several drawings in the plan set, e.g., Drawings, CI -13, CI -19 and CI -28. A typical cross section of the completed final cover consists of the following: • A layer of unclassified compacted soil 1 -foot thick (intermediate cover) • 40 -mil Linear -Low Density Polyethylene ( LLDPE) liner • A geocomposite drainage net • A soil layer 2.5 feet thick • A 6 -inch layer of topsoil and vegetative cover As landfill cover technologies advance, SKB may, with MPCA approval, substitute layer(s) within the cover profile with equivalent or superior items. The 1 -foot soil layer will be placed and compacted over the waste surface of the final cover sub grade, progressively, so that run off is contained within the cell /subcell confines. If ponding or surface water is retained on intermediate cover areas soils will be placed and compacted, as needed to correct the surface from the effects of any settlement or subsidence. The 40 -mil LLDPE liner will then be installed as operations require. A geocomposite drainage net (i.e. drainage net with geotextile filter fabric on one or both sides) will be placed atop the LLDPE liner. A layer of soil 2.5 feet thick will be placed over the drainage layer and will be contoured to avoid forming any depressions that might pond water. A 6 -inch layer of topsoil will be placed over the 2.5 feet of soil cover and seeded, mulched and fertilized to promote the vegetative cover. 075704 (27) ER 28 CONESTOGA- ROVERS & ASSOCIATES The final cover is designed to contain and divert precipitation over filled areas of the site, thus reducing infiltration into the waste. A typical section for the final cover is shown on Drawing CI -28. Perimeter berms of the final cover are also shown on Drawing CI -28. Slopes on the final cover of the facility will range from 2 percent on top to 25 percent on the side slopes. Typically, 25 percent (4:1) slopes will be constructed. The highest elevation will be 1060 feet. The final contours are presented on Drawing CI -06. Run -off is designed to flow overland. Erosion will be controlled by limiting the slopes to 25 percent and by strategic placement of drainage berms, downslope structures, erosion control blanket and riprap. Run -off will be directed by the final cover drainage berms and downchustes to proposed sedimentation ponds throughout the site. The drainage swales are sloped at 1 to 2 percent and lined with an erosion control blanket. Run -off from off -site and undeveloped areas will follow natural drainage pathways. Cell 1 has been closed. The Cell cover design for industrial waste, from bottom to top, is a 1 foot Protective Layer, a 40 MIL LLDPE Liner, a Geocomposite Drainage Material, and a 1 foot Soil Layer. The Cell 1 final cover design consists of a 1.5 foot Soil Layer and a 6 inch Topsoil Layer. Final cover may be removed as needed for saddle cell construction. Cell 1 cover and final cover are shown in Drawing CI -06. 3.6.2 SEED MIX The seed mix will be based on approved mixes at the time of closure. Intermediate soil layers will be seeded with typical shallow- rooted, drought - resistant, grasses. 075704 (27) ER 29 CONESTOGA - ROVERS & ASSOCIATES 4.0 SITE DEVELOPMENT PLAN 4.1 INTRODUCTION The objectives of the landfill development are to (1) Provide a logical sequence of filling that will bring the areas to final grade as soon as possible, (2) Minimize problems associated with access to the working face, and (3) Provide for adequate surface water drainage during the filling process. The waste disposal cells will be a continuously lined landfill that will operate as a series of individual subcells built progressively. The Facility started with the construction of Cell 1 in 1991 for industrial waste. Cell 2 began accepting industrial waste in April 1999 and stopped excepting waste in May 2006. Cell 4A began accepting MSW combustor ash in the fall of 1999. Cell 3A began accepting industrial waste in November 2005. Cell 5 started accepting C &D waste in July 2004. Planned Cell 6 and the saddle areas between the cells will also be lined for future disposal areas. 4.2 PHASED CONSTRUCTION This plan provides for the operation of only multiple subcells of each waste type at any given time due to volumes of waste accepted at the Facility. Multiple subcells will be open so that the landfill may continue to fill and accommodate all the volume accepted. At the latter stage of filling, two subcells will be open to allow the Facility to select wastes that are a suitable base for the final cover. Consequently, it will be necessary to have a second subcell operating at this time to take waste that is unsuitable for a base layer for the cap. Further, it is important to construct the subcells when weather conditions accommodate the placement of liners, and leachate collection systems. A projected schedule for the construction, operation and closure of all Cells and their subcells is shown in Table 4.1. Additional discussion and illustrations are included in Tab 4 of the Permit Renewal Application. Phasing Plans are provided for the years 2013 -2018 (Drawing CI -08) and years 2019 -2026 (Drawing CI -09). Cross - sections are provided on Drawing CI -10 through CI -12. Current construction plans anticipate the following sequence of events (Note: It is likely that the timing or sequence of these events may change to accommodate business needs or seasonal construction. This schedule is only intended as a guide.): 075704 (27) ER 30 CONESTOGA — ROVERS He ASSOCIATES The site will be constructed in five phases. The first Phase includes currently lined areas. The second Phase will include construction of the liners to connect cells and utilize the saddle areas between the currently constructed cells. The third Phase will utilize 6A and continue through 6C. The fourth Phase will utilize 6D. These four phases will be built to an average height of 180 feet above the base grades. The fifth Phase will include waste added on top of the first four phases to a peak elevation of 1060 feet. The phasing Drawings are presented included as CI -8 and CI -9. There is a site office trailer currently located along the access road on the route to the working face near Cell 5. This will ultimately be moved to a different location at a future date. 4.2.1 CELL 1 DEVELOPMENT Cell 1 was constructed in 1992 and stopped receiving waste in 1999. The final cover was constructed in 2001. The original design of Cell 1, utilizing a cap with a 7 percent slope had an anticipated closure date of 1995. In order to enhance the capacity of this cell, Cell 1 slopes were redesigned with a maximum slope of 25 percent during the 1997 permitting process. The final cover design was modified in 2001. A final cover design modification request letter dated May 11, 2001 was submitted to the MPCA. Approval was granted with a MPCA letter dated June 29, 2001. Construction was completed and the Construction Documentation Report dated September 2001, was submitted to the MPCA. Concurrent with the construction of Cell 1 was the development of a berm and a landscaped visual barrier along Highway 55. The berm, by its construction, provides a visual screen. The berm was planted with grass and landscaped with trees. Also included in the initial phase of construction was the construction of the office building, container management building, access roads, leachate storage tanks, retention basin #1, the utilities and the rail siding. 4.2.2 CELL 2 DEVELOPMENT Cell 2A opened for waste disposal in April 1999, stopped receiving waste in spring of 2003. Cell 2B was constructed in 2000 and began accepting waste in the summer of 2000, stopped receiving waste in early of 2004. Cell 2C was constructed in 2001 and began to accept waste in fall 2001, stopped receiving waste in early 2006. Cell 2D was constructed 075704 (27) ER 31 CONESTOGA - ROVERS & ASSOCIATES in spring of 2004, stopped receiving waste spring of 2006. The liner systems for the subcells are tied together prior to landfilling in the adjacent subcell. The liner systems between Cells 2 and 3 are tied together beneath the access road. 4.2.3 CELL 3 DEVELOPMENT The first subcell, 3A, was constructed in the 2005 and started accepting waste in November 2005. Cell 3B was built in 2007, Cell 3C was built in 2009 and Cell 3D was built in 2011 (Drawing CI -01A). The 3M Cell, a subcell within Cell 3B, was constructed for the purpose of containing sediment waste from 3M cleanup sites. The 3M cell was constructed in 2009 and was capped in Fall of 2012. Subcell 3E utilizes the saddle area between, Cells 2 and 3. Remaining subcells in Cell 3 to be constructed are subcells 3F and 3G, both estimated to be constructed in 2018. Subcell 3F utilizes the saddle area between Cells 3 and 5 overlying the Cell 3 liner. The southeastern boundary for Subcell 3F is defined by an operational delineation between C &D wastes and industrial wastes. Subcell 3G utilizes the saddle areas between Cells 2 and 3 and Cells 1 and 3. Subcell 3H will be constructed on top of Subcells 3A -3G. The construction schedule is currently based on receipt of 700,000 cubic yards of industrial waste per year being placed into cells. The currently constructed lined areas are shown on Drawing CI -08 and its estimated that these areas will take approximately 5 years to fill. Cells 3F and 3G are estimated to be constructed after 2018. Subcell 3H will take approximately one year to fill once the intermediate grades defined as the basegrades for Subcell 3H are reached. The vertical expansion above the permitted grades is designated Cell 3H, and will consist of industrial waste and co- disposal of C &D wastes as discussed in the WAP in Tab 3 of this Permit Renewal Application. 4.2.4 CELL 4 DEVELOPMENT Construction of Cell 4A was completed in summer of 1999 and began accepting MSW combustor ash in the fall of 1999. Cell 4B began accepting waste in Fall of 2001, Cell 4C started accepting waste in 2004. The construction sequence for the subcells in Cell 4 will follow the methodology outlined for Cell 2, above, but will consist of a total of 5 subcells. Cell 4D utilizes the saddle area between Cells 1 and 4 and was constructed in 2009. The construction schedule for the saddle cell, Cell 4E, utilizing the saddle area 075704 (27) ER 32 CONESTOGA - ROVERS & ASSOCIATES between Cells 3 and 4 is currently based on the annual receipt of 60,000 cubic yards of ash per year. Drawing CI -08 shows the construction Cell 4E to be constructed after 2018. The total permitted ash waste capacity in Cell 4 is 2,648,950 cubic yards. The total capacity of Subcells 4A -41) is 1,138,568 cubic yards. The top of Cell 4E will be lined and an industrial waste cell will be constructed above the closed combustor ash cell. The total capacity of Cell 4E will be capped with 1,506,124 cubic yards. The combustor ash waste volume is not proposed to increase in this permit renewal application. 4.2.5 CELL 5 DEVELOPMENT Cell 5 is the C &D Waste Facility. The first subcell, 5A, was constructed in 2004. Cell 5 will consist of five subcells. Cells 5A, 513, and 5C are constructed on the base of the landfill. Cell 5D will utilize the area between Cells 2 and 5, Cells 3and 5, and Cells 5 and 6 with an operational boundary defined as the current middle of the road to allow C &D wastes and approved industrial wastes to be placed over the Cell 5 liner. Subcell 5E will be constructed on top of Subcells 5A -5D. The other portion of the saddle cell will contain industrial wastes as discussed in Section 4.2.3. The construction schedule is currently based on a receipt of 350,000 cubic yards of C &D waste per year. Subcell 51) is expected to be constructed in 2018. Subcell 5E is expected to be constructed in 2030. 4.2.6 CELL 6 DEVELOPMENT Cell 6 will accept Industrial waste and allow the co- disposal of C &D debris. This permit renewal application proposes the expansion of the permitted footprint of Cell 6 by moving the southern boundary of Cell 6 within 180 feet of the southern property boundary. The proposed larger development of Cell 6 will remove a portion of an existing wetland. A draft EAW has been prepared in regard to removing the portion of the wetland and SKB is working with the City of Rosemount to ensure environmental concerns are addressed. And as part of the process, a wetland delineation and wetland application to the City of Rosemount as the entity with jurisdiction over the wetland is also in process. Cell 6 will consist of four subcells with Subcells 6A, 613, 6C, and 6D making up the base of the landfill. Basegrades for Subcells 6A and 6D will be constructed over portions of Cell 2. Subcell 6E will be constructed on top of subcells 6A -6D. The construction schedule is currently based on receipt of 700,000 cubic yards of industrial waste per year being placed into Cell 3 and the 368,000 cubic yards of C &D wastes being placed in Cell 075704 (27) ER 33 CONESTOGA - ROVERS & ASSOCIATES 5. Drawing CI -09 shows that Subcell 6A will be constructed in 2022. Subcell 6E is expected to be constructed in 2028. 4.3 FILL PROGRESSION A Final Contour Plan has been prepared that indicates the proposed final elevations of the site (Drawing CI -06). The final contour plan will enable continued filling within the fill boundaries to elevations that provide approximately 25 percent side slopes to promote surface water run -off of incident precipitation and also reduce the potential for post - closure drainage problems due to erosion. The active cells will develop a 4:1 external slope with 3:1 (horizontal: vertical) operational slope covered with 12 inches of intermediate cover and may be vegetated. The base of this slope would include a toe berm to be completed as shown in Drawing CI -29. As waste is placed up the slope, away from the toe berm, it will be covered with intermediate cover and may be vegetated, which will allow rainfall falling on this slope to be handled as runoff. The continuous disposal of waste at the site will occur until the proposed final elevations are achieved in each Phase of the total landfill area. Final cover will be applied to portions of the landfill that have reached final grades. The Facility will assess the need for final cover on an ongoing basis. Vertical and horizontal control of landfill development is maintained by grade and line staking conducted by the use of on -site staff using GPS equipment, which is verified each year during the annual survey. 075704 (27) ER 34 CONESTOGA- ROVERS & ASSOCIATES 5.0 LANDFILL GAS MANAGEMENT 5.1 INDUSTRIAL AND ASH FACILITY Based on the waste types accepted at the Facility; industrial in Cells 1, 2, 3, and 6, and ash in Cell 4, SKB does not believe that significant quantities of methane will be produced after closure of the cells. To verify this, and to monitor the condition below the final cover, SKB has installed a Methane Monitoring Point (MP -1) at the crown of Cell 1 during the Cell closure activities during the summer of 2001. SKB submitted a letter to the MPCA dated July 23, 2001, requesting closure modifications for Cell 1, which included the request to install the monitoring point. Monitoring Point MP -1 is sampled and recorded for methane using a hand held gas meter four times a year during the Facilities regular sampling events. The gas meter will be calibrated for methane to report the Percent of the Lower Explosive Limit (LEL) and Percent Total Gas by volume. Historical methane monitoring on the perimeter of the Facility show that there is not methane outside of the disposal areas. Should elevated levels of methane be detected on a regular basis outside the disposal area footprint in soils, SKB will evaluate the situation at that time and act accordingly as deemed necessary by the MPCA. 5.2 C &D WASTE FACILITY Since the waste accepted in the C &D Waste Facility is mostly inorganic and coupled with it being dry in nature, it is anticipated to produce very little methane gas. Once the landfill is capped, due to its design and the nature of the waste stream, it is anticipated that generation of methane will reduce to close to null production. SKB uses a hand held gas meter to monitor for the presence of methane at the monitoring points around the Facility. This will be done quarterly until the landfill is completely closed, at which time it will be performed on an annual basis. 5.3 MONITORING POINTS Monitoring points MP -1 through MP -5, MP -7 through MP -10, and MP -13 are installed around the Facility perimeter. The monitoring point locations are shown on Drawings Cl- 01A and CI -01B. The points are monitored on a quarterly basis. 075704 (27) ER 35 CONESTOGA - ROVERS & ASSOCIATES In the unlikely event that methane is detected in the perimeter monitoring points at or above the LEL, SKB would contact the MPCA and Dakota County to determine the appropriate course of action. If changes are needed, they may include increased monitoring frequency or additional monitoring locations. 5.4 HYDROGEN SULFIDE MONITORING SKB will monitor for the presence of hydrogen sulfide at the Facility using a hand held gas meter. Hydrogen sulfide gas will be monitored around the perimeter of the Facility footprint on a quarterly basis. Additionally, if hydrogen sulfide odors are noticed, the ambient air in and around the landfill cell will be monitored and the levels of hydrogen sulfide will be recorded. SKB will also measure hydrogen sulfide gases in all confined spaces prior to entry as per OSHA regulations. 075704 (27) ER 36 CONESTOGA - ROVERS & ASSOCIATES 6.0 RECYCLING CENTER & TRANSFER FACILITY 6.1 INTRODUCTION This section of the application provides design information for the construction and operation of a Recycling Facility and Transfer Facility for C &D materials, Industrial Waste, MSW Ash, Shredder Fluff, MSW, and source separated recyclables (collectively referred to as "wastes ") at SKB Rosemount. Operational details for these activities are included in Tab 4 of this Permit Renewal Application. This portion of the Facility was approved in the October 2001- Updated April 2003 Major Modification. Also submitted was the MPCA Facility Permit Reissuance Application in November 2007. For the Transfer Facility the following sections of this report address the requirements of Minnesota Rules parts: • 7001.3300 General Information Requirements for Final Application • 7001.3400 Final Application Information Requirements for Transfer Facilities • 7035.2865 Solid Waste Transfer Facilities In addition to the recycling and transfer building, SKB currently operates two recycling areas. The two operating recycling areas are contained entirely within the constructed footprint of the landfill. The first area is the metal recycling area, which takes place within Cell 4. At this area, SKB processes for recycling post -burn metal from the HERC incinerator. The other operating recycling area is within the footprint of Cell 5. At this second area, SKB processes and recovers or makes ready for recycling several materials that may be recovered from the C &D waste stream. These recycling areas, or additional recycling areas, may move to other areas within the permitted disposal areas. In the 2012 Annual Report, SKB accepted the following waste types: Concrete, Metal - Steel, Shingles, Wood, and Other (Pavers). Of these types, Concrete was utilized of on -site, while the rest of the recycled materials were destined to other locations. 6.2 DESIGN INFORMATION 6.2.1 ROAD DESIGN INFORMATION FOR RECYCLING FACILITY/TRANSFER FACILITY The facility, including on -site access roads and parking areas, will be surfaced with an all- weather class V, asphalt, or concrete surface and watered as needed to minimize dust 075704 (27) ER 37 CONESTOGA- ROVERS & ASSOCIATES concerns and ensure access. The paved surfaces and surface markings will be constructed/ applied to conform to applicable standards of the Minnesota Department of Transportation. 6.2.2 BUILDING DESIGN FOR RECYCLING FACILITY[rRANSFER FACILITY In general, the facility will consist of a 200' x 100' = 20,000 square ft. steel building (Butler or equivalent) constructed consistent with City Code. However, this building may change in size or operational requirements at the time of construction or in the future. Prior to constructing the building, SKB will share the final building design with the MPCA for approval. The building will be accessible through several overhead doors located on the sides of the building. The overhead doors will be either manually or electrically operated depending upon the anticipated frequency of use of each door. The facility will be heated only in select areas, such as the office and possibly some radiant heat for heat over processing lines. It is anticipated that the heating system will be a natural gas operated radiant heat, wood heat, oil heat, or natural gas fired unit heaters. The purpose will be to minimally heat the building so that the inside temperature does not go below approximately 20 degrees F. Ventilation in the facility will be achieved through a combination of natural and mechanical means. The facility will typically operate with overhead doors opened, unless prohibited by high winds or other inclement weather. Additional mechanical ventilation will be offered by a series of fans, vents, and filters placed at upper and lower levels. Lighting within the working area of the facility will be provided by high bay lighting fixtures and possibly clear panels within the roofing system. Since the facility will be operated primarily during daylight hours, the exterior lighting will be for security purposes. Such lighting will be located over key entrances and exits, and the parking area. 075704 (27) ER 38 CONESTOGA- ROVERS & ASSOCIATES 6.2.3 FLOOR DESIGN FOR RECYCLING FACILITY/TRANSFER FACILITY The floor of the building will be designed with a high strength concrete mix with thickness appropriate for the intended use. The floor may be hardened or sealed with concrete admixtures or chemical hardener such as Day -Chem Sure Hard. Day -Chem Sure Hard is a colorless, odorless solution of specialized reactive chemicals that penetrate concrete and masonry surfaces to seal, densify and harden. The hardener will make the floor easier to clean by washing or sweeping. Day -Chem Sure Hard is a water - based product and as a result, it is VOC compliant and environmentally safe to use. It advantages are as follows: • Seals, hardens, and dustproof • Resists black rubber fire marks on floors • Will not scratch or peel • Environmentally safe • Water - based, V.O.C. compliant • No odor, no fumes 6.2.4 SCALE AND SCALE OFFICE DESIGN FOR RECYCLING FACILITY/TRANSFER FACILITY The facility will initially utilize one of the four onsite scales. Additional scales may be installed based on the operations of the facility requirements. If additional scales are constructed, an enclosed scale office may be constructed between the scales. This scale office will be heated and ventilated. 6.2.5 FACILITY CONSTRUCTION DOCUMENTATION FOR RECYCLING FACILITY/TRANSFER FACILITY Prior to beginning construction of the transfer station/ recycling center, SKB will prepare and provide Construction documentation and Quality Assurance/ Quality Control (QA /QC) measures to the MPCA /Dakota County /City of Rosemount. These plans will provide specific detail for the following items: • Concrete slab floor • Footings (geotechnical data) 075704 (27) ER 39 CONESTOGA- ROVERS & ASSOCIATES • Architectural plans • Plan modifications • Structural details • Environmental containment devices The construction specifications will provide the required QA /QC for the above items. 075704 (27) ER 40 CONESTOGA - ROVERS & ASSOCIATES 7.0 COMPOST AREA 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. 7.1 SITE PREPARATION Because the compost area will be constructed on top of a temporarily closed portion of the landfill, 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 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 multiple liner designs that are used at the landfill. At a minimum, each of the liner designs has a synthetic geomembrane; which exceeds the 1x10 -7 cm /sec liner requirements of Minn. R. 7035.2836. As part of the construction of the composting, curing, and storage area, SKB will cover the landfill a portion of a 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 provided in the attached 2011 Major Modification Permit Application found on the CD -ROM. The composting area would be placed on top of a temporarily closed landfill cell. Initially, the composting area would likely be constructed in a temporarily closed cell 3C in the detail provided in the attached 2011 Major Modification Permit Application found on the CD -ROM. 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 be likely allow composting to happen in one location for a period of time. The attached drawing in the 2011 Major Modification Permit Application identifies a potential location for phase 2, which is over cells 3A /3B. The composting area would be of 075704 (27) ER 41 CONESTOGA - ROVERS & ASSOCIATES sufficient size to accommodate the volume of composting material accepted at the Facility. The Facility will ultimately have 166 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. Drawing CI -29 shows a detail of the all weather pad. In addition, SKB would construct a small ditch near the edges of the composting area where run -off to collect 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 would be moved to other locations. However, at all times, the location would be on top of a temporarily closed 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. 7.2 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. 7.2.1 TRAFFIC ROUTES All arriving traffic will enter the Facility's Gate 1. 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 would be rerouted and would 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. 7.2.2 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 075704 (27) ER 42 CONESTOGA - ROVERS & ASSOCIATES 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 142nd Street. A few vehicles may leave the Facility via this second gate. 7.3 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 from 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. 7.4 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 composting area will be of sufficient size to allow for the processing of up to 50,000 tons of compostable material per year. 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 2011 Major Modification Permit Application. 075704 (27) ER 43 CONESTOGA- ROVERS & ASSOCIATES The composting area 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. 7.5 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. 7.6 MATERIALS MANAGEMENT All putrescible materials will be processed on the day they are received. This will entail mixing the material with the proper ratio of carbon sources and bulking agents. The processed material will then be added to the compost pile. Once the compost has met the appropriate temperature and time ratio for PFRP, procedure to further reduce pathogens, as outlined in Minn. R. 7035.2836, the material may be moved to a curing pile where the material will continue it is mature compost. Maturity, along with other parameters, will be measured using the methods outlined in Minn. R. 7035.2836. 7.7 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, 075704 (27) ER 44 CON ESTOGA-ROVERS & ASSOCIATES actively aerating the compost pile, and introducing a sufficient amount of bulking agent in the construction of the compost pile. 7.7.1 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. 7.7.2 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. 7.7.3 COMPOST PILE CONSTRUCTION SKB will add sufficient bulking agent to the mix when constructing the compost pile. Bulking agents create sufficient void spaces into 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. 075704 (27) ER 45 CONESTOGA - ROVERS & ASSOCIATES TABLE 1.1 ADJACENT PROPERTY OWNERS SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA V— +,. n7,,,,or Prnnorhi T.nration Owner Address* Page 1 of 1 Flint Hills Resources, Pine Bend LLC West - Northwest of Facility Location 4111 East 37th Street North Wichita, KS 67220 Bonnie Mae Troska East- Northeast of Facility Location 9830 Abigail Court Inver Grove Heights, MN 55077 Masahiro & Brenda Sugii East of Facility Location 13701 Courthouse Boulevard Rosemount, MN 55068 Burger Family Limited Partnership East of Facility Location 3209 Galleria Unit 1008 Edina, MN 55435 Great River Energy South of Facility Location PO Box 800 South of 140th Street Elk River, MN 55330 Rahn Family Limited Partnership Southwest of Facility Location 3855145th Street East South of 140th Street Rosemount, MN 55068 Metropolitan Waste Control Comm' West of Facility Location 2305 th Street East St. Paul, MN 55101 Chicago & NW Trans Co West of Facility Location 165 Canal Street North Chicago, IL 60606 Union Pacific Railroad North of Facility Location 1400 Douglas Street North of HWY 55 Stop 1640 Omaha, NE 68175 Spectro Alloys Corporation North of Facility Location 13220 Doyle Path North of HWY 55 Box 10 Rosemount, MN 55068 Endres Rosemount Holdings, LLC North of Facility Location 5050 Lincoln Drive North of HWY 55 Suite 420 Edina, MN 55436 Endres Properties, LLC North of Facility Location 13420 Courthouse Boulevard North of HWY 55 Rosemount, MN 55068 Note: * - Owner address is not physical address of property CRA 075704 (27) ER TABLE 1.2 Page 1 of 1 FACILITY WASTE CAPACITY SUMMARY SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA General Cell Design Remaining Cell Capacity (Cubic Inplace Capacity Capacity (Cubic Activities Area (acres) Yards) (Cubic Yards) Yards) 1 (total) Industrial 5.3 341,454 341,454 - Closed 1 341,454 341,454 - Closed 2 (total) Industrial 17.1 1,458,507 1,458,507 - Closed 2A 361,387 361,387 - Closed 2B 297,082 297,082 - Closed 2C 624,407 624,407 - Closed 2D 228,458 228,458 - Closed 3 (total) Industrial 39.4 10,592,188 3,127,687 7,464,501 Open 3A 2,155,585 1,355,091 800,494 Open 3B 1,771,552 860,850 910,702 Open 3M (subcell of 313) 158,300 158,300 - Closed 3C 1,154,757 545,426 609,331 Open 3D 1,306,952 366,320 940,632 Open 3E (saddle) 870,815 - 870,815 Future 3F (New Final elev.) 1,575,469 - 1,575,469 Future 3G (New Final elev.) 1,224,424 - 1,224,424 Future 3H (New Final elev.) 532,634 - 532,634 Future 4 (total) Ash 12.4 2,648,950 838,516 1,810,434 Open 4A Open 4B 4C 1,138,568 838,516 300,052 Open Open 4D Open 4E (saddle) 1,510,382 - 1,510,382 Future 5 (total) C &D (2) 41.2 7,490,591 2,543,775 4,946,816 Open 5A 1,436,956 1,046,046 390,910 Open 5B 1,827,789 685,394 1,142,395 Open 5C 2,551,737 812,335 1,739,402 Open 5D (saddle) 1,501,619 - 1,501,619 Future 5E (New Final Elev.) 172,490 172,490 Future 6 (total) Industrial 51.8 12,659,927 - 12,659,927 Future 6A 5,257,970 - 5,257,970 Future 6B 2,021,179 - 2,021,179 Future 6C 859,318 - 859,318 Future 6D 4,077,496 - 4,077,496 Future 6E (saddle) 443,964 - 443,964 Future Waste Capacity Summary Total Industrial 113.6 25,052,076 4,927,648 20,124,428 Total Ash 12.4 2,648,950 838,516 1,810,434 (') 3M waste capacity is included in stated 3B capacities (2) Proposed reduction from 2008 capacity of 8,752,613 CY for DD001 to stated capacity CRA 075704 (27) ER TABLE 2.1 LOCATIONAL CRITERIA SUMMARY SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Minnesota Rule Part 7035.1600 e fill trench areas of Industrial solid waste land disposal facilities are >hibited within the following areas: The fill area is further than 1,000 feet from the normal high water irk of a lake, pond, or flowage, 300 feet from a stream; • regional floodplain • wetland E. within 1,000 feet of the nearest edge of the right -of -way of any state, federal, or interstate highway or of the boundary of a public park or of an occupied dwelling. Permission may be granted under this item, without these distance requirements, at the discretion of the commissioner, taking into consideration such factors as noise, dust, litter, and other aesthetic and environmental considerations; SKB Rosemount Industrial At the nearest point, the Facility is approximately 3,000 feet from the Mississippi River 100 -year flood plain. Page 1 of 2 The fill area will not be located in wetlands; There are unnamed wetlands onsite that will require mitigation prior to construction of portions of Cell 6. Facility is located within 1,000 feet of a state of interstate highway; lway 55. However, the MPCA commissioner has given permission to be do 1,000 feet of State Highway 55 as outlined in Minn R. 7035.1600. umentation of this permission can be seen in section 1.3.2 of the 2012 nit, PER008. F. locations considered hazardous because of the proximity of airports; IThe Facility is located approximately 4 miles from the closest public airport and which is not considered hazardous because of the proximity of airports G. an area which is unsuitable because of topography, geology, hydrology, or soils. Part 7035.2555 Subpart 1. owner or operator may not locate a new solid waste management lity in a floodplain. Facility is located in an area that has been determined to be igraphically, geologically, hydrologically and soil sufficient fill area of the Facility is not located within an area of potential floodu Facility is located approximately 3,000 feet from the Mississippi River Subp. 2. Other location standards. An owner or operator may not establish or construct a solid waste i manage facility in the following areas: A. within a shoreland or wild and scenic river land use district The Facility is not located within a shoreland or wild and scenic river land use governed by chapters 6105 and 6120; district B. within a wetland; or The Facility is not located on wetlands designated by the U.S. Department of Interior National Wetland Inventory (1988) or the Minnesota Inventory of Protected Waters. The fill area will not be located in wetlands; There are unnamed wetlands onsite that will require mitigation prior to construction of portions of Cell 6. C. within a location where emissions of air pollutants would violate The Facility does not emit air pollutants that would violate the ambient air the ambient air quality standards in chapters 7005, 7007, 7009, 7011, quality standards in chapters 7005, 7007, 7009, 7011, 7017, 7019, and 7028 or 7017, 7019, and 7028 and parts 7023.0100 to 7023.0120. parts 7023.0100 to 7023.0120 CRA 075704 (27) ER TABLE 2.1 LOCATIONAL CRITERIA SUMMARY SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Minnesota Rule SKB Rosemount Industrial Facility Part 7035.2815 2. disposal facilities must be located in accordance with items A to C and part7035 2555: A. A facility must be located only in an area where: 1. the topography, geology, and ground water conditions allow the facility to be designed, operated, constructed, and maintained in a (manner that minimizes environmental impacts; ground water flow paths and variations in soil or bedrock conditions known in sufficient detail to enable reliable tracking of pollutant )vement in the event of a release from the facility; Page 2 of 2 Facility is located in an area that has been determined to be )graphically, geologically, hydrologically and soil sufficient (see section of the Engineering Report) 3. it is feasible to construct a monitoring system with sufficient monitoring points to assure that pollutants can be detected and tracked The Facility maintains a monitoring system with various monitoring points in the event of a release from the facility; and that assure early detection and tracking of pollutants 4. in the event of a release from a facility, pollutants can be contained and corrective actions taken to prevent adverse impacts on water The Facility maintains a Contingency Action Plan which addresses actions to supplies and to return the facility to compliance with ground water and be taken in the event of a pollutant release to the environment. surface water quality standards. B. Unless the owner or operator provides an engineered secondary k " containment system, a facility cannot be located in an area where the hydrologic or topographic conditions would allow rapid or ; unpredictable pollutant migration, impair the long -term integrity of the facility, or preclude reliable monitoring. The additional engineering must be approved by the commissioner and must consist of at least: 1. a second liner with a collection system between the two liners; 2. an in- place, operational ground water containment and treatment or disposal system that can be activated immediately if ground water pollution is detected; or All land disposal cells at the Facility maintain secondary containment by use of multiple liners for each cell with leak detection. 3. another method of secondary containment backing up the liner providing additional protection equivalent to subitenr (1) or (2) and backing up the cover system. C. A land disposal facility must not be located on a site where: te_• 1, there are karst features, such as sinkholes, solution channels, disappearing streams, and caves, which may cause failures of the The site is not located in an area which contains karst features (see section 2.2 leachate management system or prevent effective monitoring or of the Engineering Report) containment of a release of leachate; 2. there are other unstable soil or bedrock conditions that may cause The sitr is not located in an area which contains unstable soils or bedrock (see failures of the leachate management system; or section 2.2 of the Engineering report) 3. an airport runway used or scheduled for use by turbojet aircraft is located within 10,000 feet of the waste boundary, or an airport runway used or scheduled for use by piston type aircraft only is located within 5,000 feet of the waste boundary, unless approval is obtained from the The Facility is not located within 10,000 feet of an airport Federal Aviation Administration. CRA 075704 (27) ER TABLE 2.2 ENVIRONMENTAL MONITORING PLAN SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Monitoring Point ID Sampling Frequency gygradient Outwash Unit Spring Summer Fall Other U -3S Abandoned U -4S X X X U -5S X X X Proposed C&D Well U gradient Prairie du Chien U-4D X X X U -5D X X X Downgradient Outzoash Unit D -1S X X X D -2S X X X D -3S X X X D -4S X X X D -5S2 X X X D -7 (dry) X X X D -8 X X X D -9 X X X DowngradientPrairie du Chien CW4 -1(dry) X X X DAD X D -2D X D -3D X D-4D X D -5D X Water Levels Only CW1 -1 Abandoned CW1 -2 Abandoned CW2 -1 Abandoned CW2 -2 Abandoned D -1VD 4 times /year D -2VD 4 times /year D -6 4 times /year U -1 4 times /year U -21) 4 times /year U -2S 4 times /year U -31) Abandoned U -61) 4 times /year U -7D 4 times /year U -7S 4 times /year U -8 4 times /year CRA 075704 (27) ER Page 1 of 2 TABLE 2.2 ENVIRONMENTAL MONITORING PLAN SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Industrial Leachate Sumps (2) C1W 4 times /year C1WS 4 times /yearn C1E 4 times /year C1ES 4 times /yearn C2A 4 times /year C2AS 4 times /yearn C2A2 4 times /year C2B 4 times /year C2BS 4 times /year2 C2C 4 times /year C2CS 4 times /yearZ C3A 4 times /year C3AS 4 times /yearZ C3B 4 times /year C3BS 4 times /yearZ C & D Leachate Sumps C5 4 times /year Ash Leachate Sumps (2) C4W 4 times /year C4WS 4 times /yearZ C4E 4 times /year C4ES 4 times /year2 C4B 4 times /year C4BS 4 times /yearZ Mixed Leachate Tank 1 4 times /yearZ Tank 2 4 times /yearZ Tank 3 4 times /yearZ Tank Sump 4 times /year2 Methane Monitoring Points MP -1 through MP -13 4 times /year Note: 1- Samples from individual sumps will be combined into one composite sample per cE 2 - Secondary sumps, tanks, and tank sumps will be sampled only if water present CRA 075704 (27) ER Page 2 of 2 TABLE 2.3 Page 1 of 3 ENVIRONMENTAL MONITORING PLAN GROUNDWATER ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Comound CAS/EMMI# Spring Summer Fall RL (ug/L) Field Parameters pH C -0 -06 X X X Specific Conductance C -0 -11 X X X Eh (Oxidation Potential) 4 X X X Temperature T -1 -21 X X X Turbidity, Field G -0 -19 X X X Static Water Level (Elevation MSL) PCA -00 -1 X X X General Chemistry Parameters 75343 X X X Alkalinity, Total as CaCO3 T -0 -05 X X X Ammonia Nitrogen 766 -44 -17 X X X Calcium 744 -07 -02 X X X Chloride 168 -87 -006 X X X Iron 743 -98 -96 X X X Magnesium 743 -99 -54 X X X Nitrate + Nitrite C -0 -05 X X X 2500 Potassium 744 -00 -97 X X X Sodium 744 -02 -35 X X X Sulfate 148 -08 -798 X X X Suspended Solids, Total C -0 -09 X X X Dissolved Oxygen, Field T -1 -05 X X X Dissolved Oxygen, Total C -0 -10 X X X VOC's and Metals 17.5 1,2- Dichloropropane 788 -75 X 1,1,1,2 - Tetrachloroethane 630 -20 -6 X X X 17.5 1,1,1 - Trichloroethane 715.56 X X X 50 1,1,2,2 - Tetrachloroethane 79345 X X X 0.5 1,1,2 - Trichloroethane 790 -05 X X X 0.75 1,1,2 - Trichlorotrifluoroethane 761 -31 X X X 1,1- Dichloroethane 75343 X X X 17.5 1,1- Dichloroethylene;(Vinylidene chloride) 753 -54 X X X 1.5 1,1- Dichloropropene 563 -58 -6 X X X 1,2- (Trans -) Dichloroethylene 156 -60 -5 X X X 25 1,2,3 - Trichlorbenzene 876 -16 X X X 1,2,3- Trichloropropane 961 -84 X X X 10 1,2,4 - Trichlorobenzene 120 -82 -1 X X X 17.5 1,2,4 - Trimethylbenzene 956 -36 X X X 1,2- Dibromoethane; (Ethylene dibromide):EDB 106 -93 -4 X X X 0.001 1,2- Dichlorobenzene (orth-) 955 -01 X X X 150 1,2- Dichlorethane 107 -06-2 X X X 1 (cis) -1,2- Dichloroethylene 156 -59 -2 X X X 17.5 1,2- Dichloropropane 788 -75 X X X 1.25 1,2- Dimethylbenzene 954 -76 X X X 1,3,5- Trimethylbenzene 108 -67 -8 X X X 1,3- Dichlorobenzene(meta -) 541 -73 -1 X X X 150 1,3- Dichloropropane 142 -28 -9 X X X 1,4- Dichlorobenzene(para -) 10646 -7 X X X 2.5 2,2- Dichloropropane 594 -20 -7 X X X CRA 073704 (27) ER TABLE 2.3 Page 2 of 3 ENVIRONMENTAL MONITORING PLAN GROUNDWATER ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Comound CAS/EMMI# Spring Summer Fall RL (ug&) 2,4- Dimethyphenol 105 -67 -9 X X X 25 2- Chlorotuelene (ortho -) 954 -98 X X X 3- Methylphenol (m- cresol) 108 -39 -4 X X X 7.5 4- Chlorotuelene (para -) 106 -43 -4 X X X Acetone 676-41 X X X 175 Allyl Chloride; (3 chloropropene) 107 -05 -1 X X X 7.5 Aluminum 742 -99 -05 X X X Appearance 1 X X X Arsenic 744 -03 -82 X X X 2.5 Barium 744 -03 -93 X X X 500 Benzene 714 -32 X X X 1.25 Boron 744 -04 -28 X X X 150 Bromobenzene 108 -86-1 X X X Bromchlormethane (Chlorobromomethane) 749 -75 X X X Bromodichloromethane (Dichlorobromomethan, 752 -74 X X X 1.5 Bromoform 752 -52 X X X 10 Bromomethane (Methyl bromide) 748 -39 X X X 2.5 Cadmium 744 -04 -39 X X X 1 Carbon tetrachloride 562 -35 X X X 0.75 Cation -Anion Balance F84 -1- X X X Chlorobenzene; (monochlorobenzene) 108 -90 -7 X X X 25 Chlorodibromomethane; (Dibromochloromethaj 124 -48 -1 X X X 2.5 Chloroethane 750 -03 X X X Chloroform 676 -63 X X X 15 Chloromethane; (Methyl Chloride) 748 -73 X X X chromium 744 -04 -73 X X X 25 cis -1,3- Dichloropropene 100 -61 -015 X X X Copper 744 -05 -08 X X X Cumene; (Isopropylbenzene) 988 -28 X X X 75 Dibromochloropropane; (DBCP) 961 -28 X X X 0.05 Dibromomethane; (Methylene bromide) 749 -53 X X X Dichlorodifluoromethane 757 -18 X X X 250 Dichlorofluoromethane 754 -34 Dichloromethane; (Methylene chloride) 750 -92 X X X 1.25 Ethyl benzene 100 -41 -4 X X X 175 Ethyl ether 602 -97 X X X 250 Hexachlorobutadiene 876-83 X X X 0.25 Lead 743 -99 -21 X X X Manganese 743 -99 -65 25 Mercury 743 -99 -76 X X X 0.5 Methyl ethyl ketone (MEK) 789 -33 X X X 1000 Methyl isobutyl ketonr; (4- Methyl- 2pentanone) 108 -10 -1 X X X 75 Methyl tertiary-Butyl Ether (MTBE) 163 -40 -44 X X X Napthalene 912 -03 X X X 75 n -Butyl Benzene 104 -51 -8 X X X Nickel 744 -00 -20 X X X 25 CRA 075704 (27) ER TABLE 2.3 Page 3 of 3 ENVIRONMENTAL MONITORING PLAN GROUNDWATER ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Comound CAS/EMMI# Spring Summer Fall RL (ug/L) n-Propyl benzene 103 -65 -1 X X X Phenol 108 -95 -2 X X X 1000 p- Isopropyltoluene 998 -76 X X X sec -Butyl Benzene 135 -98 -8 X X X Selenium 778 -24 -92 X X X 7.5 Silver 744 -02 -24 X X X 7.5 Styrene 100 -42 -5 X X X 25 tert -Butyl Benzene 980 -66 X X X Tetrachloroethylene; (Perchloroethylene) 127 -18 -4 X X X 1.25 Tetrahydrofuran 109 -99 -9 X X X 25 Tin 744 -03 -15 X X X 1000 Toluene 108 -88 -3 X X X 250 trans -1,3- Dichloropropene 100 -61 -026 X X X 0.5 Trichloroethylene; (TCE) 790 -16 X X X 1.25 Trichlorotrifluoromethane 756-94 X X X 500 Vinyl Chloride; (Chloroethene) 750 -14 X X X 0.05 Xylene; (M &P) 179 -60 -123 X X X 2500 Xylenes (mixture of o,m,p) 133 -02 -07 X X X 2500 Zinc 744 -06-66 X X X 500 CRA 075704 (27) ER TABLE 2.4 ENVIRONMENTAL MONITORING PLAN LEACHATE ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Confound CAS/EMMI# Quarterly 1,1,1 - Trichloroethane 715.56 X 1,1,2,2- Tetrachloroethane 793-45 X 1,1,2 - Trichloroethane 790 -05 X 1,1- Dichloroethane 753 -43 X 1,1- Dichloroethylene;(Vinylidene chloride) 753 -54 X 1,2- (Trans -) Dichloroethylene 156 -60 -5 X 1,2,4 - Trichlorobenzene 120 -82 -1 X 1,2,4- Trimethylbenzene 956-36 X 1,2- Dichlorobenzene (orth -) 955 -01 X 1,2- Dichlorethane 107 -06 -2 X 1,2- Dichloropropane 788 -75 X 1,2- Dimethylbenzene 954 -76 X 1,2- Diphenylhydrazine 122 -66 -7 X 1,3- Dichlorobenzene(meta -) 541 -73 -1 X 1,3- Dichloropropene 542 -75 -6 X 1,4- Dichlorobenzene(para -) 106-46 -7 X 2,4,6 - Trichlorophenol 880 -62 X 2,4- Dichlorphenol 120 -83 -2 X 2,4- Dimethyphenol 105 -67 -9 X 2,4- Dinitrophenol 512 -85 X 2,4- Dinitrotoluene 121 -14 -2 X 2,6- Dinitrotoluene 606 -20 -2 X 2- Chlorethvinyl Ether 110 -75 -8 X 2- Chlornapthalene 915 -87 X 2- Chlorophenol 955 -78 X 2- Methylphenol (o-cresol) 954 -87 X 3- Methylphenol (m- cresol) 108 -39-4 X 4,6- Dinitro-o-cresol; (4,6- Dinitro -2- methylphenol) 534 -52 -1 X 4- Bromophenyl phenyl ether 101 -55 -3 X 4- Chlorophenyl phenyl ether 700 -57 -23 X 4- Methylphenol (p- cresol) 106 -44 -5 X Acenaphthene 833 -29 X Acenpthylene 208 -96 -8 X Acetone 676 -41 X Acetonitrile 750 -58 X Acetophenone 988 -62 X Acrolein 107 -02 -8 X Acrylonitrile 107 -13 -1 X Aldrin 309 -00 -2 X Alkalinity, Total as CaCO3 T -0 -05 X Aluminum 742 -99 -05 X Ammonia Nitrogen 766 -44 -17 X Anthracene 120 -12 -7 X Antimony 744 -03 -60 X Appearance 1 X CRA 075704 (27) ER Page 1 of 4 TABLE 2.4 ENVIRONMENTAL MONITORING PLAN LEACHATE ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Comound CAS/EMMI# Quarterly Arsenic 744 -03 -82 X Barium 744 -03 -93 X Benzene 714 -32 X Benzidene 928 -75 X Benzo[a]anthracene 565 -53 X Benzo[a]pyrene 503 -28 X Benzo[b]fluoranthene 205 -99 -2 X Benzo[ghi]perylene 191 -24 -2 X Benzo[k]fluoranthene 207 -08 -9 X Beryllium 744 -04 -17 X Biochemical Oxygen Demand (BOD) C -0 -02 X Bis (2- chloroethoxy) methane 111 -91 -1 X Bis (2- chlorethyl) ether; (BCEE) 11144 -4 X Bis (2- chloroisopropyl) ether; (BCIE) 108 -60 -1 X Boron 744 -04 -28 X Bromodichloromethane (Dichlorobromomethane) 752 -74 X Bromoform 752 -52 X Bromomethane (Methyl bromide) 748 -39 X Butyl benzyl phthalate 856-87 X Cadmium 744 -04 -39 X Calcium 744 -07 -02 X Carbon disulfide 751 -50 X Carbon tetrachloride 562 -35 X Chemical Oxygen Demand (COD) C -0 -04 X Chlordane 577 -49 X Chloride 168 -87 -006 X Chlorobenzene ;(monochlorobenzene) 108 -90 -7 X Chlorodibromomethane; (Dibromochloromethane) 124 -48 -1 X Chloroethane 750 -03 X Chloroform 676 -63 X Chloromethane; (Methyl Chloride) 748 -73 X Chromium 744 -04 -73 X Chrysene 218 -01 -9 X cis -1,3- Dichloropropene 100 -61 -015 X Copper 744 -05 -08 X Cyclohexane 110 -82 -7 X Di(2- ethylhexyl)phthalate; (DEHP) 117 -81 -7 X Dibenz[ah]anthracene 537 -03 X Dibutyl phtalate; (Di -n -butyl phtalate) 847 -42 X Dichloromethane; (Methylene chloride) 750 -92 X Dieldrin 605 -62 X Diethyl phtalate 846-62 X Dimethyl phtalate 131 -11 -3 X Di -n -octyl phtalate 117 -84 -0 X Dissolved Solids C -0 -10 X CRA 075704 (27) ER Page 2 of 4 TABLE 2.4 ENVIRONMENTAL MONITORING PLAN LEACHATE ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Couiound CAS/EMMI# Quarterly Endosulfan I; (alpha - Endosulfan) 959 -98 -8 X Endosulfan II; (beta - Endosulfan) 332 - 13-659 X Endosulfan sulfate 103 -10 -78 X Endrin 722 -08 X Endrin aldehyde 742 -19 -34 X Ethyl benzene 100 -41 -4 X Ethyl ether 602 -97 X Fluoranthene 206 -44 -0 X Fluorene; (9H- Fluorene) 867 -37 X Heptachlor 764 -48 X Heptachlor epoxide 102 -45 -73 X Hexachlorobenzene 118 -74 -1 X Hexachlorobutadiene 876-83 X Hexachlorocyclohexane; (alpha -); (alpha BHC) 319 -84 -6 X Hexachlorocyclohexane; (beta -); (beta BHC) 319 -85 -7 X Hexachlorocyclohexane; (delta -); (delta BHC) 319 -86-8 X Hexachlorocyclohexane; (gamma -); (Lindane) 588 -99 X Hexachlorocyclopentadine 774 -74 X Indeno(1,2,3- cd)pyrene 193 -39 -5 X Iron 743 -98-96 X Isobutyl alcohol; (2- methyl -l- propanol) 788 -31 X Isophorone 785 -91 X Lead 743 -99 -21 X Magnesium 743 -99 -54 X Manganese 743 -99 -65 X Mercury 743 -99 -76 X Methyl ethyl ketone (MEK) 789 -33 X Methyl isobutyl ketonr; (4- Methyl- 2pentanone) 108 -10 -1 X Methyl tertiary-Butyl Ether (MTBE) 16340 -44 X Napthalene 912 -03 X Nickel 744 -00 -20 X Nitrate + Nitrite C -0 -05 X Nirobenzene 959 -53 X N- Nitrosodiethylamine 551 -85 X N- Nitrosodiphenylamine 627 -59 X N- Nitrosodimethylamine 863 -06 X N- Nitrosodipropylamine 621 -64 -7 X o-Nitrophenol; (2- Nitrophenol) 887 -55 X p,p'- Dichlorophenyl dichloroethane; (4,4 -DDD) 725 -48 X p, p'- Dichlorophenyldichloroethylene; (4,4 -DDE) 728 -59 X p, p '- Dichlorophenyltrichloroethane; (4,4 -DDT) 502 -93 X PCB -1016 (Aroclor 1016) 126 -74 -112 X PCB -1221 (Aroclor 1221) 111 -04 -282 X PCB -1232 (Aroclor 1232) 111 -41 -165 X PCB -1242 (Aroclor 1242) 534 -69 -219 X PCB -1248 (Aroclor 1248) 126-72 -296 X PCB -1254 (Aroclor 1254) 110 -97 -691 X CRA 07570.1(27) ER Page 3 of 4 TABLE 2.4 ENVIRONMENTAL MONITORING PLAN LEACHATE ANALYTE LIST SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY ROSEMOUNT, MINNESOTA Comound CAS/EMMI# Quarterly PCB -1260 (Aroclor 1260) 110 -96 -825 X p- Chloro -m- cresol; (4- Chloro -3- methylphenol) 595 -07 X Pentachlorophenol; (PCP) 878 -65 X pH C -0 -06 X Phenanthrene 850 -18 X Phenol 108 -95 -2 X p- Nitrolphenol; (4- Nitrophenol) 100 -02 -7 X Potassium 744 -00 -97 X Pyrene 129 -00 -0 X Pyridine 110 -86 -1 X Selenium 778 -24 -92 X Silver 744 -02 -24 X Sodium 744 -02 -35 X Specific Conductance C -0 -11 X Styrene 100 -42 -5 X Sulfate 148 -08 -798 X Suspended Solids, Total C -0 -09 X Temperature T -1 -21 X Tetrachloroethylene ;(Perchloroethylene) 127 -18 -4 X Tetrahydrofuran 109 -99 -9 X Thallium 744 -02 -80 X Tin 744 -03 -15 X Toluene 108 -88 -3 X Toxaphene 800 -13 -52 X trans -1,3- Dichloropropene 100 -61 -026 X Trichloroethylene; (TCE) 790-16 X Vinyl Chloride; (Chloroethene) 750 -14 X Xylene; (M &P) 179 -60 -123 X Xylenes (mixture of o,m,p) 133 -02 -07 X Zinc 744 -06-66 X Extended Leachate Analysis for MSW Combustor Ash 2,3,7,8 - Tetrachlorodibenzo -p- dioxin; (TCDD) 174- -60 -16 X Heptachlorodibenzodioxin 378 -71 -004 X Heptachlorodibenzofuran 389 -98 -753 X Pentachlordibenzodioxin 360 -88 -229 X Pentachlordibenzofuran 304 -02 -154 X Tetrachlorodibenzodioxin 419 -03 -575 X Tetrachlorodibenzofuran 557 -22 -275 X CRA 075764 (27) ER Page 4 of 4 N O 1—I z w z a0. 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NO. 075704 (27) WAP Prepared by: Conestoga- Rovers & Associates 1801 Old Highway 8 Suite 114 St. Paul, Minnesota 55112 Office: (651) 639 -0913 Fax: (651) 639 -0923 web: htto: \ \www.CRAworld.com Worldwide Engineering, Environmental, Construction, and IT Services DISTRIBUTION No. of Copies Sent To 3 Mr. Daniel Aamodt Minnesota Pollution Control Agency Industrial Land Permits 520 Lafayette Road North St. Paul, Minnesota 55155 3 Mr. Geoff Strack, P.E. SKB Environmental, Inc. 251 Starkey Street St. Paul, Minnesota 55107 1 Mr. Jeff Harthun Environmental Director Dakota County Environmental Management Western Service Center 14955 Galaxy Avenue Apple Valley, Minnesota 55124 1 Mr. Dwight Johnson City Administrator City of Rosemount 2875 West 145th Street Rosemount, Minnesota 55068 1 Ms. Margaret Zuckweiler, PE Conestoga- Rovers & Associates 1801 Old Highway 8, Suite 114 St. Paul, Minnesota 55112 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES PERMIT APPLICATION CONTENTS TAB 1 FACILITY PERMIT APPLICATION FACILITY PERMIT CHECKLISTS TAB 2 ENGINEERING REPORT TAB 3 WASTE ACCEPTANCE PLAN TAB 4 OPERATIONS PLAN TAB 5 CLOSURE, POST - CLOSURE AND CONTINGENCY ACTION PLAN TAB 6 DRAWINGS FOR PERMIT APPLICATION RENEWAL (11x17) DRAWINGS LIST (22X36 PLAN SET UNDER SEPARATE COVER) CI -01A MARCH 2013 CI -01B MARCH 2013 CI -02 MARCH 2013 CI -03 MARCH 2013 CI -04 CI -05 CI -06 CI -07 CI -08 CI -09 CI -10 MARCH 2013 MARCH 2013 MARCH 2013 MARCH 2013 MARCH 2013 MARCH 2013 EXISTING CONDITIONS AND ENVIRONMENTAL MONITORING LOCATIONS EXISTING CONDITIONS AND ENVIRONMENTAL MONITORING LOCATIONS GROUNDWATER CONTOUR MAP OCTOBER 23, 2012 BASE GRADES CELLS 1 -6 BASE GRADES CELL 6 LEACHATE COLLECTION SYSTEM TOP OF FINAL COVER STORMWATER MANAGEMENT PLAN PHASING PLAN (2013 -2018) PHASING PLAN (2018 -2026) ENGINEERING CROSS SECTIONS (1 OF 3) 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES DRAWINGS LIST (22X36 PLAN SET UNDER SEPARATE COVER) CI -11 MARCH 2013 ENGINEERING CROSS SECTION (2 OF 3) CI -12 MARCH 2013 ENGINEERING CROSS SECTION (3 OF 3) CI -13 MARCH 2013 INTERIOR BERM AND SADDLE AREA DETAILS (1 OF 2) CI -14 MARCH 2013 INTERIOR BERM AND SADDLE AREA DETAILS (2 OF 2) CI -15 MARCH 2013 CI -16 MARCH 2013 CI -17 MARCH 2013 CI -18 MARCH 2013 CI -19 MARCH 2013 Cl 20 MARCH 2013 CI -21 MARCH 2013 CI -22 MARCH 2013 CI -23 MARCH 2013 CI -24 MARCH 2013 CI -25 CI -26 CI -27 CI -28 CI -29 MARCH 2013 MARCH 2013 MARCH 2013 MARCH 2013 MARCH 2013 SADDLE AREA AND LEACHATE COLLECTION TRENCH DETAILS LEACHATE HEADER PLAN AND PROFILE CELL 6 LEACHATE HEADER PLAN AND PROFILE CELLS 1,2, 4 AND 6 LEACHATE HEADER PLAN AND PROFILE CELLS 2 AND 6 LINER AND LEACHATE COLLECTION DETAILS (1 OF 3) LINER AND LEACHATE COLLECTION DETAILS (2 OF 3) LINER AND LEACHATE COLLECTION DETAILS (3 OF 3) DETAILS LEACHATE SUMPS RECYCLING /TRANSFER FACILITY PLAN STORMWATER BASIN PLAN, BASINS 4 AND 5 STORMWATER BASIN PLAN, BASINS 6A, 6B, AND 6C STORMWATER DETAILS (1 OF 2) STORMWATER DETAILS (2 OF 2) PERIMETER BERM AND FINAL COVER DETAILS PHASE DELINEATION BERM AND DITCH DETAILS 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS Pale 1.0 INTRODUCTION ..................................................................................... ..............................1 2.0 GENERAL NOTIFICATIONS AND PROCEDURES ........................... ..............................3 2.1 POTENTIAL CUSTOMER NOTIFICATION .................... ..............................3 2.2 HAULER NOTIFICATION .................................................. ..............................3 3.0 INDUSTRIAL WASTE EVALUATION ................................................. ..............................4 3.1 INTRODUCTION .................................................................. ..............................4 3.2 PERSONNEL INVOLVED IN WASTE APPROVAL ....... ..............................4 3.3 DISCUSSION OF THE DECISION PROCESS ................... ..............................6 3.3.1 INFORMATION GATHERING .......................................... ..............................7 3.3.2 PRE - APPROVAL REVIEW .................................................. ..............................8 3.3.3 EVALUATION OF NEED FOR ADDITIONAL TESTING AND ANALYSIS ...................... ..............................9 3.3.4 FREQUENCY OF RECHARACTERIZATION OF INDUSTRIAL WASTE .................................................... ..............................9 3.3.5 RECHARACTERIZATION OF MUNICIPAL SOLID WASTE COMBUSTOR ASH .................................. .............................11 3.3.6 ANALYSES PERFORMED AND RATIONALE .............. .............................11 3.3.6.1 RATIONALE FOR ANALYZING AN INDUSTRIAL WASTE STREAM FOR A GIVEN PARAMETER DURING PRE - APPROVAL ...................... .............................11 3.3.6.2 RATIONALE FOR ANALYZING MSW INCINERATOR ASH FOR A GIVEN PARAMETER DURING PRE - APPROVAL ...................... .............................14 3.3.7 ANALYTICAL PROCEDURES .......................................... .............................15 3.3.8 WASTE ACCEPTANCE CRITERIA .................................. .............................15 3.3.8.1 TCLP ....................................................................................... .............................15 3.3.8.2 CORROSIVITY ...................................................................... .............................16 3.3.8.3 FLASHPOINT ....................................................................... .............................16 3.3.8.4 REACTIVITY ......................................................................... .............................16 3.3.8.5 FREE LIQUIDS ...................................................................... .............................16 3.3.8.6 LISTED WASTES .................................................................. .............................16 3.3.8.7 RADIOACTIVITY ................................................................ .............................17 3.3.8.8 PCBS ....................................................................................... .............................17 3.3.9 ASH ACCEPTANCE CRITERIA ........................................ .............................17 3.3.10 TOLERANCE LIMITS FOR WASTE ACCEPTANCE ..... .............................18 3.4 WASTE REJECTION AND APPROVAL .......................... .............................18 3.4.1 REJECTION ........................................................................... .............................18 3.4.2 APPROVAL ........................................................................... .............................18 4.0 MANAGEMENT DECISIONS FOR WASTE ....................................... .............................19 4.1 ACCEPTANCE/ REJECTION CRITERIA ......................... .............................19 4.2 PROCEDURES FOR MANAGING WASTE ..................... .............................23 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS Page 4.2.1 GENERAL PROCEDURES .................................................. .............................23 4.2.2 SPECIAL CONDITION GUIDELINES .............................. .............................24 4.2.3 WASTE USED AS COVER .................................................. .............................24 5.0 INSPECTION PROCEDURES ................................................................ .............................25 ACCEPTANCE INSPECTION AND ANALYSES ........... .............................28 5.1 PROCEDURES FOR ARRIVAL OF APPROVED LOADS ...........................25 .............................28 5.1.1 UNSCHEDULED ARRIVALS OF APPROVED WASTES ...........................25 .............................29 5.1.2 UNSCHEDULED ARRIVALS OF WASTES .............................30 5.2.3.4 NOT PREVIOUSLY APPROVED FOR ACCEPTANCE . .............................25 .............................30 5.2 RECEIVING PROCEDURES ............................................... .............................25 ...... .............................31 5.2.1 SHIPPING PAPER OR EQUIVALENT REVIEW ............ .............................25 .............................32 5.2.2 WASTE FINGERPRINT SAMPLING ................................ .............................26 .............................32 5.2.2.1 SAMPLING DEVICES ......................................................... .............................26 5.2.2.2 CLEANING OF SAMPLING APPARATUS ..................... .............................26 .............................32 5.2.2.3 SAMPLING METHODS ...................................................... .............................26 .............................33 5.2.2.4 SAMPLING OF FROZEN SHIPMENTS ........................... .............................27 .............................33 5.2.2.5 SCOPE OF SAMPLING ....................................................... .............................27 .............................34 5.2.2.6 DISPOSITION OF SAMPLES ............................................. .............................28 5.2.3 INCOMING WASTE 6.0 MANAGEMENT OF SPECIFIC WASTES ............................................ .............................36 6.1 EMPTY PESTICIDE AND EMPTY RCRA CONTAINERS ..........................36 6.2 ASBESTOS ............................................................................. .............................37 6.3 WASTES CONTAINING PCBS AT LESS THAN 50 PPM ..........................38 6.4 NON - HAZARDOUS WASTE SPILLS ............................... .............................38 6.5 RENDERING AND SLAUGHTERHOUSE WASTE ....... .............................38 6.6 MATERIALS THAT COULD SPONTANEOUSLY COMBUST OR THAT COULD IGNITE OTHER WASTES BECAUSE OF HIGH TEMPERATURE ............................. .............................39 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES ACCEPTANCE INSPECTION AND ANALYSES ........... .............................28 5.2.3.1 BULK SLUDGES AND BULK SOLIDS ............................. .............................28 5.2.3.2 CONTAINERS ...................................................................... .............................29 5.2.3.3 LABORATORY ANALYTICAL CAPABILITY ................ .............................30 5.2.3.4 GENERAL INCOMING LOAD ANALYSES ................... .............................30 5.2.3.5 SUPPLEMENTAL INCOMING LOAD ANALYSES ...... .............................31 5.2.3.6 RATIONALE FOR ANALYSES .......................................... .............................32 5.2.3.7 ANALYTICAL PROCEDURES .......................................... .............................32 5.3.3.8 LABORATORY CALIBRATION PROCEDURES AND FREQUENCIES .............................. .............................32 5.2.3.9 LABORATORY METHODOLOGY ................................... .............................33 5.2.4 WORKING AREA INSPECTION ....................................... .............................33 5.3 DECISION PROCESS ........................................................... .............................34 6.0 MANAGEMENT OF SPECIFIC WASTES ............................................ .............................36 6.1 EMPTY PESTICIDE AND EMPTY RCRA CONTAINERS ..........................36 6.2 ASBESTOS ............................................................................. .............................37 6.3 WASTES CONTAINING PCBS AT LESS THAN 50 PPM ..........................38 6.4 NON - HAZARDOUS WASTE SPILLS ............................... .............................38 6.5 RENDERING AND SLAUGHTERHOUSE WASTE ....... .............................38 6.6 MATERIALS THAT COULD SPONTANEOUSLY COMBUST OR THAT COULD IGNITE OTHER WASTES BECAUSE OF HIGH TEMPERATURE ............................. .............................39 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS FASe 6.7 FOUNDRY WASTE .............................................................. .............................39 6.8 ASH FROM INCINERATORS, RESOURCE RECOVERY FACILITIES AND POWER PLANTS .......... .............................39 6.9 PAINT RESIDUE, PAINT FILTERS, AND PAINT DUST ...........................40 6.10 SLUDGES, INCLUDING INK SLUDGE, LIME SLUDGE, WOOD SLUDGE, PAPER SLUDGE, AIR POLLUTION CONTROL SLUDGE, OR INDUSTRIAL WASTE WATER TREATMENT SLUDGE ....................................... .............................40 6.11 FIBERGLASS, URETHANE, 9.1 ACCEPTABLE WASTES AND MATERIALS .................. .............................48 POLYURETHANE AND EPDXY RESIN WASTE ........... .............................41 6.12 SPENT ACTIVATED CARBON FILTERS ........................ .............................41 6.13 RECYCLING RESIDUAL .................................................... .............................41 6.14 BLASTING MEDIA .............................................................. .............................42 6.15 MUNICIPAL SOLID WASTE COMBUSTOR ASH ......... .............................42 6.16 MERCURY CONTAMINATED WASTE .......................... .............................42 6.17 SHREDDER RESIDUE ......................................................... .............................43 6.17.1 SAMPLING AND ANALYSIS ............................................ .............................43 6.17.2 ACCEPTANCE ..................................................................... .............................44 6.18 WASTE FROM SEWAGE TREATMENT PLANTS ......... .............................44 6.19 FIRE TRAINING ASH DISPOSAL .................................... .............................44 6.20 CO- DISPOSAL OF INDUSTRIAL WASTE MSW INCINERATOR ASH ................................. .............................45 6.21 DISPOSAL OF SEDIMENT FROM MUNICIPAL STORMWATER PONDS ............................ .............................45 7.0 UNACCEPTABLE WASTES AT THE INDUSTRIAL WASTE AREA ..........................46 8.0 C &D DEBRIS AREA WASTE ACCEPTANCE PLAN ........................ .............................47 8.1 ACCEPTABLE WASTES ..................................................... .............................47 8.2 PROHIBITED WASTES ....................................................... .............................47 9.0 RECYCLING AND TRANSFER AREAS WASTE ACCEPTANCE PLAN ...................48 9.1 ACCEPTABLE WASTES AND MATERIALS .................. .............................48 9.2 PROHIBITED WASTES ....................................................... .............................49 9.3 WASTE HANDLING, SHIPMENT, AND DISPOSAL .... .............................49 9.3.1 WASTE HANDLING ........................................................... .............................49 9.3.2 OTHER RECYCLABLES ...................................................... .............................49 9.3.3 TIRES ...................................................................................... .............................50 9.4 CONTINGENCY PLAN ...................................................... .............................50 9.4.1 UNAUTHORIZED DEPOSITS OF ACCEPTABLE MATERIALS ..............50 075704 (27) WAa CONESTOGA- ROVERS & ASSOCIATES TABLE OF CONTENTS Page 9.4.2 DELIVERY OF HAZARDOUS OR OTHERWISE PROHIBITED WASTES ....................... .............................50 10.0 SOLID WASTE COMPOST AREA ........................................................ .............................52 10.1 PROCEDURE FOR NOTIFYING CUSTOMERS .............. .............................52 10.2 PROCEDURE FOR EVALUATING WASTE .................... .............................52 10.3 PROCEDURE FOR INSPECTING INDUSTRIAL SOLID WASTE ............53 10.4 ACCEPTABLE WASTE TYPES .......................................... .............................53 10.4.1 EMPTY PESTICIDE CONTAINERS .................................. .............................55 10.4.2 ASBESTOS ............................................................................. .............................55 10.4.3 WASTE CONTAINING PCBS ............................................ .............................55 10.4.4 SPILLED NONHAZARDOUS WASTE ............................. .............................55 10.4.5 RENDERING AND SLAUGHTERHOUSE WASTE ....... .............................55 10.4.6 WASTES THAT SPONTANEOUSLY COMBUST ........... .............................55 10.4.7 FOUNDRY WASTE .............................................................. .............................55 10.4.8 ASH FROM INCINERATORS ............................................ .............................56 10.4.9 SLUDGES ............................................................................... .............................56 10.4.10 FIBERGLASS, URETHANE, POLYURATHANE, AND EPDXY RESIN WASTE ......... .............................56 10.4.11 SPENT ACTIVATED CARBON FILTERS ........................ .............................56 10.4.12 OTHER WASTES .................................................................. .............................56 10.5 PLAN MODIFICATION ...................................................... .............................56 11.0 AMENDMENT OF PLAN ...................................................................... .............................58 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES LIST OF APPENDICES APPENDIX A TABLES TABLE 1 DESIRED INFORMATION REGARDING WASTES AND THE SOURCE OF GENERATION TABLE 2 FREQUENCY OF RE- CHARACTERIZATION GUIDELINES FOR INDUSTRIAL WASTE TABLE 3 GUIDANCE ON POTENTIAL USE OF TOXICITY CHARACTERISTIC TABLE 4 TYPICAL ACCEPTABLE TOLERANCE RANGES FOR INCOMING LOAD ANALYSES TABLE 5 TYPICAL ACCEPTABLE TOLERANCE RANGES FOR INCOMING LOAD ANALYSES OF MSW INCINERATOR ASH TABLE 6 SOME OF THE POTENTIALLY ACCEPTABLE WASTES AT SKB APPENDIX B FIGURES FIGURE 1 INITIAL DECISION FLOWCHART FIGURE 2 WASTE PROFILE SHEET FIGURE 3 WASTE ACCEPTANCE DECISION CHART CHART 1 INORGANIC PORTION OF WASTE CHART 2 ORGANIC PORTION OF WASTE APPENDIX C SAMPLE WASTE ACCEPTANCE LETTER APPENDIX D PCB PIPE WASTES APPENDIX E EMPTY CONTAINER POLICY APPENDIX F EVALUATING PAINT - RELATED WASTES APPENDIX G C &D FACILITY DISPOSAL LIMITS (UPDATED MARCH 26, 2013) 075704 (27) WAP CONESTOGA- ROVERS & ASSOCIATES 1.0 INTRODUCTION This Waste Acceptance Plan (WAP) exceeds the requirements of Minn. R. 7035.2525, subp. 5 for Industrial Solid Waste Management Plans. This plan describes how waste will be evaluated prior to shipment and upon arrival at the SKB Rosemount Industrial Waste Facility (Facility or SKB Rosemount). This WAP is a document that, as needed, will be revised for a variety of reasons such as revised test procedures or new waste types. This WAP should therefore be considered as a working document that will be updated from time to time. The following waste activity areas are covered with this WAP: • Industrial Waste Disposal Area (I1,001) • Municipal Solid Waste Combustor Ash Disposal Area (MA001) • Construction and Demolition (C &D) Disposal Area (DD001) • Solid Waste Recycling and Solid Waste Transfer Areas (RE001 and TR001) • Solid Waste Composting Area (MC001) The Industrial Waste Disposal Area denoted by IL002 in MPCA permit action PER008 (also referred to as the 3M Cell) was closed in the Fall of 2012. Because the area is closed and will no longer accept waste, this plan does not discuss acceptance criteria for this area. The WAP describes the methodology by which SKB Environmental, Inc. (SKB) evaluates each waste stream and determines its acceptance for management at the Facility. The general waste stream types managed at the Facility include but are not limited to: Industrial Solid Waste and Municipal Solid Waste (MSW) Combustor Ash, C &D, Source Separated Compostable Materials, and Mixed Municipal Solid Waste. The detailed sections below describe all the material types that will be accepted for management at the Facility and which of the permitted areas these materials may be accepted for management. The evaluation process of a material stream for acceptance and management at the Facility begins with an evaluation of the potential customer's process and the waste's characteristics to determine if the waste can be accepted at the Facility. These evaluations are made by representatives of SKB and must be approved by the Facility Manager (In this plan, Facility Manger means the Facility Manager or his /her designee. This designee works under the direct supervision of the Facility Manager) prior to waste acceptance. The Facility Manger will review information provided by the customer on 075704 (27) WAP 1 CONESTOGA - ROVERS & ASSOCIATES the Waste Profile Sheet (WPS), information obtained by SKB representatives, and information regarding whether the waste has been previously approved for disposal at other permitted landfills. The Facility Manager will require new testing when there is uncertainty as to whether the waste is hazardous and the potential customer cannot provide documentation to demonstrate that it is non - hazardous. At the time a WPS is completed, the customer must also provide a non - hazardous waste certification. Waste analyses may be performed on representative waste samples as part of the information gathering process. The decision to approve or reject a waste stream will be based on the results of these evaluations during pre - approval. Pre - approval procedures are detailed in Section 3. Management decisions are discussed in Section 4. Upon arrival of the waste shipment at the Facility, further waste evaluation is done to confirm that the incoming waste conforms to the pre - approval information and consistent with the accompanying shipping paper. The form of waste analysis done as a part of the confirmation evaluation is called "incoming load evaluation." The incoming load evaluation is discussed in Section 5. Management methods for several specific waste categories are outlined in Section 6. Section 7 contains a list of wastes that may not be accepted at the Facility. Section 8 provides the Waste Acceptance Plan for the C &D Debris Area and Section 9 provides the Waste Acceptance Plan for the Recycling & Transfer Areas. Section 10 provides the Waste Acceptance Plan for the Solid Waste Composting Area. Section 11 covers amendments of the plan. Appendix A includes the tables referenced in the text and Appendix B includes the figures referenced in the text. 075704 (27) WAP 2 CONESTOGA- ROVERS & ASSOCIATES 2.0 GENERAL NOTIFICATIONS AND PROCEDURES Potential customers will be made aware of the pre - approval process. SKB Rosemount will follow up inquiries made by potential customers who express interest. SKB Rosemount will notify potential haulers of the pre - approval process based either on knowledge that they currently transport non - hazardous industrial waste and/or the hauler's inquiries about transporting waste to the Facility. Appendix C contains sample notification letters. 2.1 POTENTIAL CUSTOMER NOTIFICATION Potential customers will be informed of the pre- approval procedures of SKB Rosemount and the information they will be required to provide. This information will include data about the waste and its generation process and the operations of the plant as a whole. Potential customers will be required to fill out a WPS for each industrial waste stream to be sent to the Facility. They will also be asked to provide results from previous testing conducted on the waste. If the Facility Manager, or their designee, decides additional testing is needed, the potential customer may be requested to (1) conduct testing on a representative sample of the waste, (2) provide a representative sample to the Facility, or (3) allow facility staff or representatives to take a representative sample. The customer must also certify the waste to be non - hazardous. 2.2 HAULER NOTIFICATION Haulers will also be notified of the pre - approval process that will be required at SKB Rosemount. They will be specifically informed of the hauler's responsibility to provide documentation for each waste they deliver to the Facility. 075704 (27) WAP 3 CONESTOGA- ROVERS & ASSOCIATES 3.0 INDUSTRIAL WASTE EVALUATION This section of the WAP outlines the procedures and criteria for accepting wastes into IL001 and MA001 areas of the Facility. Acceptance into DD001 is outlined in section 8 of this plan. Acceptance into RE001 and TRO01 is outlined in section 9 of the plan. Acceptance into MC001 is outlined in section 10 of this plan. 3.1 INTRODUCTION SKB Rosemount is permitted for the management of non - hazardous wastes as established by the permit. As such, there are permit restrictions on the materials that may be accepted for handling at the Facility. In order to ensure compliance with permit restrictions, each waste stream proposed for acceptance at the Facility must be evaluated prior to its being received for handling. In conjunction, wastes will also be evaluated upon actual arrival at the Facility to check that they are indeed the wastes that were pre - approved. The waste evaluation program at SKB Rosemount consists of several interconnected procedures that are described below. The purpose of these procedures is to provide a high level of confidence that only non - hazardous wastes are received and managed. Among the procedures involved are: proper personnel and personnel training, established decision procedures, 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 the region surrounding the Facility, as it provides for the environmentally safe management of non - hazardous industrial wastes. In order to safeguard this asset, facility management must use caution and care in accepting wastes, so as not to jeopardize the environmental security offered. 3.2 PERSONNEL INVOLVED IN WASTE APPROVAL 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 075704 (27) WAP 4 CONESTOGA- ROVERS & ASSOCIATES 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. A sample letter is provided in Appendix C. 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 (See Table 5) 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. All final waste approval decisions are to be made by the Facility Manager or a person specifically designated for this purpose. The Facility Manager must be a Type II or Type III Certified Operator under Minnesota Pollution Control Agency (MPCA) Rules. Consequently, the Facility Manager will have extensive knowledge of the waste industry and the Facility, including potential waste acceptance problems. The Facility Manager is responsible for the day -to -day operation of the site. As discussed earlier in this plan, the Facility Manager may designate an individual or individuals to assist in waste approval decisions; in all cases the designees will work under the direct supervision of the Facility Manager. Consequently, the certification requirements themselves will ensure that the decision - makers have adequate knowledge and experience to make informed, competent decisions. Therefore, hereafter, whenever the text refers to the Facility Manager, the same responsibility is applicable to any designee. The person(s) actually receiving the loads will receive both classroom and on -the -job training, specifically geared to waste receipt procedures. If the evaluation of the incoming load finds a waste deviates from what was expected beyond the tolerance limits discussed in this plan, the Facility Manager will decide what actions are to be taken. The Facility Manager will reject a load that from his /her experience or training is believed to be hazardous waste as defined by Minnesota and Federal rules and regulations. If the Facility Manager believes the load is non - hazardous, he /she may elect to allow the load to temporarily stay at the Facility receiving area pending clarification of why the shipment deviated from expectation. The Facility Manager will only authorize placement in the cell after he /she is satisfied the waste has been 075704 (27) WAP 5 CONESTOGA- ROVERS & ASSOCIATES adequately characterized and - -based on the test results, MSDS and Generator Knowledge of the process - -is non - hazardous. 3.3 DISCUSSION OF THE DECISION PROCESS In any complex decision - making process, it is useful to have a series of specific decision - points listed, so that a clear path can be followed in making the decision. Unfortunately, it is impossible to systematically list every conceivable question that might arise in a waste management decision, as the number of situations and permutations of those situations is essentially infinite. To complicate the procedure, not all questions can be answered "yes' or "no;' often there are many degrees of concern to be considered. The decision maker will also consider the extent of documentation, the Facility's experience with the waste, whether the waste had been previously approved to go to a permitted landfill, and similar factors. Analytical testing of a waste stream cannot always determine if it is legally a hazardous waste. A waste which is listed under 40 CFR 261 and its MPCA equivalent is considered hazardous waste regardless of specific constituent concentrations, unless it has been formally delisted by the regulatory agencies. For many waste streams, it is not always possible, necessary, or practical to obtain a sample that can be said to be representative of the entire stream. In these situations, knowledge of the process producing the waste must therefore be used either in conjunction with or in place of actual waste testing. There are three distinct, but not always clearly defined, situations relating to waste acceptance. In simplified terms, they are: i) Is the waste hazardous (listed or characteristic)? If so, the waste would be rejected. ii) Are there variables such that the waste might be hazardous under certain conditions? If so, additional evaluation of the waste is necessary before acceptance. iii) Is the waste non - hazardous and conditions are such that it is unlikely that it will ever be hazardous? If so, the waste may be accepted without reservation and only minimal evaluation is needed. Situations (i), (ii), and (iii) rely on the quality and quantity of information available on the waste as well as the knowledge and experience of the Facility personnel. Situation (i) is the most straightforward in that the waste is immediately identified as hazardous and is rejected. Situation (ii) is one in which there is uncertainty about whether the 075704 (27) WAP 6 CONESTOGA - ROVERS & ASSOCIATES waste is non - hazardous and consequently requires a more rigorous review relative to relating hazardous waste criteria. This review may include laboratory testing, discussions with County and /or MPCA staff. Situation (iii) is one where all available information makes it clear that the waste is non - hazardous. The waste approval process consists of first gathering the necessary relevant information, then evaluating that information and determining if the level of knowledge is sufficient to make an informed decision. If there is insufficient information, additional research or testing will be done, as needed. Figure 1 (Appendix B) shows one process used to determine whether sufficient data exists. 3.3.1 INFORMATION GATHERING The process begins first with a review of information about not only the waste but also the source of waste as needed to determine the proper management of the waste. As shown in Table 1 (Appendix A), the information gathering would typically include information on raw material, plant processes, and how the waste is internally managed at the plant. The questions in Table 1 are provided for illustration and are not intended to apply to every waste stream, nor are all possible questions listed. Table 1 shows the types of information needed to make an informed, correct decision. Table 1 consists of two columns. The first column lists a question concerning either the waste itself, the potential customer, or the plant or process that produces the waste, while the second column describes the significance of that question. This information will be gathered by the Sales and Customer Service staff or may be specially requested by SKB Rosemount management. In addition, information will be available from the WPS (Figure 2 in Appendix B) filed by the potential customer and the Non - Hazardous Waste Certification. The types of information listed above are useful in evaluating whether the waste contains or is likely to contain constituents or properties that could make it unacceptable at SKB Rosemount. Among the constituents or properties of concern are: metals, volatile organics, pesticides and/or herbicides, halogenated organics, ignitability, corrosivity, and reactivity. A certification by the laboratory personnel that standard MDH, USEPA, ASTM, or NELAC Institute methods have been utilized in the waste analysis may be required, by the Facility during the waste evaluation process. The potential for these items to be present can be evaluated by knowledge of the waste stream, the process by which it was generated (including the feedstocks), while others 075704 (27) WAP 7 CONESTOGA- ROVERS & ASSOCIATES require actual testing. For example, the Facility Manager could decide that a potential customer should conduct an analysis on a waste for metals and volatile compounds but has sufficient information in the process to know that analysis need not be performed for pesticides and semi - volatiles. Knowledge of the constituents of the waste, whether confirmed by process information or testing, helps the initial pre - approval review by identifying areas on which to place a higher emphasis. The knowledge that metals are present would create expectation that the customer has performed a leach test or could otherwise provide an adequate explanation why a leach test was not needed. The information gathering process therefore helps provide background on which to base the pre- approval review. In addition to actual chemical constituents, there are a number of indicator parameters that are useful in determining the proper management of a waste stream. These may be used to supplement the hazardous waste testing determined to be necessary by the Facility Manager. A non - inclusive list of these indicator parameters is: physical appearance, pH, reactivity, bulk density, and organic vapor generation in headspaces. The initial information gathering process would involve completion of the WPS. Accompanying a WPS would be testing data on the waste and the customer certification that the waste is non - hazardous. Once the above information is available, a decision may be made concerning waste approval and whether or not additional testing or analyses are needed to confirm the customer's certification that the waste is non- hazardous. 3.3.2 PRE - APPROVAL REVIEW The Facility Manager's initial pre- approval review will take into consideration the overall acceptance criteria illustrated in Figure 3 (Appendix B). The initial review will lead to one of three actions by the Facility Manager: (a) If the Facility Manager believes that the waste is unacceptable at SKB Rosemount, he will notify the potential customer. (b) If the Facility Manager decides that the waste is probably non - hazardous waste and is potentially acceptable at SKB Rosemount, the Facility Manager will then decide if additional testing or evaluation is needed, either on a one -time or periodic basis, to provide further assurances of the non - hazardous nature of the material. 075704 (27) WAP 8 CONESTOGA - ROVERS & ASSOCIATES (c) If the Facility Manager determines that the waste is definitely non - hazardous, then no further testing is needed and he will notify the potential customer so that arrangements can be made for shipment. Information gathered from the customer that was used by the Facility Manager in making the decision to accept the waste will be kept in the Facility operating records. 3.3.3 EVALUATION OF NEED FOR ADDITIONAL TESTING AND ANALYSIS The need to conduct additional tests during pre - approval will be based on the Facility Manager's review of the waste. That review is illustrated in Figure 3 (Appendix B). In conducting the review, the Facility Manager will evaluate whether information gathered is sufficient to demonstrate the waste is non - hazardous. If it is insufficient, the Facility Manager will request testing be conducted to address specific deficiencies. Until the deficiencies have been satisfied by additional testing or information that demonstrates that additional testing is not needed, the Facility Manager will withhold approval. Even if the pre - approval process has been completed and the Facility Manager has approved the waste, there may be a need for periodic testing of the waste stream on a continuing basis, so that variations in the waste may be properly addressed. This will be done by either obtaining samples from the site of generation or from an incoming load at SKB Rosemount. Samples taken during incoming load procedures can be analyzed and the resulting information used to update the customer's file for that waste stream. Some wastes may be approved subject to special handling conditions. In most cases this would mean that the customer would be asked to take extra steps prior to shipping the waste, such as placing it in specialized containers or mixing it with another waste or material. Other special handling may occur at the site such as immediately covering the waste with another material in the cell. All special handling conditions will be noted in the approval letter that is sent to the customer. 3.3.4 FREQUENCY OF RECHARACTERIZATION OF INDUSTRIAL WASTE During the pre- approval process, an initial determination will be made as to when recharacterization of the waste should be done. Subsequently, after each recharacterization, the need for future recharacterization will be considered. In addition, recharacterization will be considered appropriate when: 075704 (27) WAP 9 CONESTOGA - ROVERS & ASSOCIATES • State or federal rules change, indicating a need for retesting; • A customer informs SKB Rosemount that there has been a change in the waste or the process that produces the waste; • When incoming load tests fall outside of acceptable range and the customer fails to explain the reason for the difference; and /or • There is a significant change in physical appearance and the customer fails to explain the reason for the difference. Characterization of the waste will involve reconsideration of the information that had been gathered during the original pre - approval evaluation and SKB Rosemount's experience with the waste. If nothing has changed at the customer's plant and SKB Rosemount's incoming load evaluations confirm this, then the waste would continue to be received with retests conducted at the originally scheduled intervals. The requirements for testing that will be imposed by the Facility will reflect its knowledge about the waste's characteristic variability. A history of testing that conclusively demonstrates the waste to be non - hazardous, and no process changes, would justify infrequent testing. Situations where recharacterization would occur frequently are also anticipated. In the most extreme situation, every load would be tested. There are many factors that affect how often waste will be tested and the scope of testing. Shown in Table 2 (Appendix A) is a guideline of frequency of recharacterization that would be anticipated for new waste without a history. The frequency of recharacterization and testing would be a function of variability in the test results from the average test result and the proximity of the maximum value to the hazardous waste threshold. In general, the greater the variability there is in test results on a particular waste, the more often reevaluation would be considered. The frequency of testing would also increase when the test results approach hazardous waste thresholds. A waste that is near the hazardous waste threshold and has great variability in test results will be subject to the most frequent testing. A waste that is well below the hazardous waste threshold and has great variability in test results would be retested more than waste with test results that have slight variability and are consistently well below the hazardous waste threshold. Waste for 075704 (27) WAP 10 CONESTOGA - ROVERS & ASSOCIATES which only one test result is available will be assumed to have great variability, for the purpose of Table 2 (Appendix A). 3.3.5 RECHARACTERIZATION OF MUNICIPAL SOLID WASTE COMBUSTOR ASH Municipal SW combustor ash is continuously recharacterized as the owner of the incinerator must sample and analyze their ash in accordance with Minn. R. 7035.2910. SKB requires that the owner of the incinerator delivering ash to the Facility to furnish this data. In addition to the continuous re- characterization, recharacterization will also be considered appropriate when: • State or federal requirements change. • SKB Rosemount becomes aware that there has been a change in the MSW incinerator ash generating process. • Incoming load tests fall outside the acceptable fingerprint range or there is a significant change in the physical appearance of the MSW incinerator ash, and the customer fails to explain the reason for the difference. 3.3.6 ANALYSES PERFORMED AND RATIONALE During both the pre - approval and the waste acceptance process, analyses of the wastes may be performed to determine or verify the waste's composition and characteristics. Not all analyses will be performed on all wastes and some waste streams may receive very limited testing under certain conditions. For example, if the waste process is such that it is likely that the waste properties will vary only slightly, or would not exhibit a hazardous waste characteristic, then little testing would be needed. 3.3.6.1 RATIONALE FOR ANALYZING AN INDUSTRIAL WASTE STREAM FOR A GIVEN PARAMETER DURING PRE - APPROVAL The rationale for analyzing an industrial waste stream for a given parameter during pre - approval is provided below: • Physical Properties including odor s used to determine the visual characteristics of the waste. It is also used to detect multiple phases (e.g., liquids and solids). A 075704 (27) WAP 11 CONESTOGA - ROVERS & ASSOCIATES change in physical appearance could be indicative of a change in waste character. This facilitates comparison of the waste with prior waste descriptions. • pH is used to indicate potential corrosiveness and incompatibility with other wastes. A knowledge of pH is necessary in order to arrive at informed decisions regarding acceptability. The pH of solids will be determined using a protocol similar to Method 9045 from the EPA report titled "Test Methods for Evaluating Solid Waste Physical/ Chemical Methods" (SW -846). pH will be utilized as a comparison parameter during incoming load analyses. • Density can be used as an aid to determine if the process generating the waste has changed. Density will also be used as a comparison parameter during incoming load analysis. • Organic Vapor in headspace is used as an indicator of the level of volatile organic compounds in a waste load. Detection of organic vapors above 200 ppm will result in further evaluation of acceptability, such as ignitability, volatile organic analysis, or Toxicity Characteristic Leaching Procedure (TCLP) organic testing. • Radioactivity Screen is used to identify any radioactive industrial waste streams and to prevent their approval at SKB Rosemount. (NOTE: The above parameters are intended to serve as the primary incoming load evaluation tools. They will be performed as part of the pre - approval process to establish a reference point for waste arrivals. The parameters listed below may be performed during pre - approval procedures, but will not be routinely performed on incoming loads.) • Flashpoint/Ignitability is used when wastes are detected to have organic vapors in the headspace. It identifies wastes for approval, is a personnel safety precaution, and determines if special handling procedures are needed. Although the ignitability tests developed by the USEPA are applicable only to liquids, SKB Rosemount will test solids for ignitability using ASTM method D4982 -89. The test checks the ignitability of the headspace at room temperature. Although the Facility would not be prohibited from accepting solids solely because they flash at temperatures below 140 °, in most cases SKB Rosemount will reject such solids for safety reasons. • Reactivity, specifically: - Reactive Cyanides Screen is used to determine whether gaseous cyanides may be produced from the waste stream. The intermingling of acids and cyanides must be prevented. It is a cyanide bearing waste which, when exposed to pH concentrations between 2 and 12.5, can generate toxic gases, vapors, or fumes in quantity sufficient to present a danger to human health or the environment. - Reactive Sulfides Screen is used to detect incompatibility and to determine whether gaseous sulfides may be produced from the waste stream. The 075704 (27) WAP 12 CONESTOGA - ROVERS & ASSOCIATES intermingling of acids and sulfides must be prevented It is a sulfide bearing waste which, when exposed to pH concentrations between 2 and 12.5, can generate toxic gases, vapors, or fumes in quantity sufficient to present a danger to human health or the environment. - Water Reactivity Screen is used to determine whether the waste has a potential to vigorously react with water to form significant gases or solids or whether it generates significant heat. Knowledge of whether a waste is water reactive is necessary for safe management of the waste. Wastes that react violently generate toxic gases, or form potentially explosive mixtures when exposed to water are defined as hazardous and must be rejected. • Total Organic Halides is used to evaluate the presence of chlorinated solvents at levels that may be harmful to the liner (i.e. greater than 1000 ppm). Wastes that contain organic halides at such levels may be hazardous waste due to chlorinated organic content and would require further analysis, such as volatile and semi - volatile organic analysis and the TCLP for organics. • Total Metals may be used as an indicator of the amount of leachable metals. • TCLP (Metals and/or Organics) evaluates if the waste is a hazardous waste. The decision on when to use the TCLP and what portions of the test to run will be made based on knowledge of the waste and its generating process, and on the results of other testing. For example, if it is known only that the waste contains metals, the TCLP metals analysis would be appropriate. However, if results from a total metals test were available and showed that the amount of metals in the waste were insufficient to cause the waste to exhibit toxicity characteristic, the TCLP analysis for metals would not be carried out. - Table 4 (Appendix A) is included as guidance on the use of the TCLP for various waste types. The fact that a waste type is included on the table does not indicate that the waste type will be accepted at SKB Rosemount. Also, tests other than the TCLP will be appropriate for many of the waste types listed. • PCBs, present in concentrations above 50 ppm require that the waste be managed in compliance with 40 CFR 761 and MPCA hazardous waste regulations. These wastes will be rejected. • Solvent Screen will be used to indicate the presence of volatile organics. It will be used when information about the waste or the generation process indicates that solvents may be present or when other tests, such as organic vapor in headspace, indicate that solvents are present. • Pesticide Screen will be used when a customer produces these materials or uses them in manufacturing but the waste has not been identified as containing pesticide. 075704 (27) WAP 13 CONESTOGA - ROVERS & ASSOCIATES It will also be used to determine concentrations in wastes that have been identified as containing pesticides. • Presence of Free Liquids is used to determine whether a waste may be placed in a containment cell without further treatment such as solidification. The free liquids test need only be applied to waste that meet all other acceptability criteria since treatment of a hazardous waste will be prohibited at SKB Rosemount. • Total Organic Carbon (TOC) will be performed when information on whether to perform other analyses is desired. For example, a high TOC may indicate the need to perform the TCLP for organics. • Total Petroleum Hydrocarbon (TPH, GRO, or DRO) will be performed on petroleum contaminated soils and various other oily waste materials. Per MPCA precedence, unlimited concentrations of TPH will be accepted for disposal as long as the material passes the paint filter, is not ignitable, and is not hazardous waste. 3.3.6.2 RATIONALE FOR ANALYZING MSW INCINERATOR ASH FOR A GIVEN PARAMETER DURING PRE - APPROVAL The rationale for analyzing MSW incinerator ash for a given parameter during pre - approval is provided below: • Physical Appearance is used to determine the visual characteristics of the ash. It is also used to detect multiple phases (e.g. liquids and solids). A change in physical appearance could be indicative of a change in waste. • pH is used to indicate potential corrosiveness and leaching ability. A knowledge of pH is necessary in order to arrive at informed decisions regarding acceptability. The pH of solids will be determined using a protocol similar to Method 9045 from SW- 846. pH will be utilized as a comparison parameter during incoming load analyses. • Density can be used as an aid to determine if the process generating the ash has changed. Density will also be used as a comparison parameter during incoming load analysis. • Calcium Carbonate is used to identify any changes in the incineration process that could result in an increased potential to leach metals from the ash. • Radioactivity Screen is used to identify any radioactive waste streams and to prevent their approval at SKB Rosemount. (NOTE: The above parameters are intended to serve as the primary incoming load evaluation tools. They will be performed as part of the pre - approval process to establish a reference point for waste arrivals. The parameters listed below may be 075704 (27) WAP 14 CONESTOGA- ROVERS & ASSOCIATES performed during pre - approval procedures, but will not be routinely performed on incoming loads.) • MLCL (Metals and Minn. R. 7035.2910 Testing) is used to determine if the ash is suitable for disposal in MSW combustor ash cell per the requirements of Minn. R. 7035.2885. 3.3.7 ANALYTICAL PROCEDURES The typical analytical methods used in the approval and acceptance procedures include standard test methods from EPA (i.e. SW -846 methods) and American Standard Testing Methods (ASTM). These unique methods have proven to be useful for waste characterization. As new analytical procedures are developed, these procedures may be adopted and the WAP updated accordingly. A decision by the Facility Manager to modify a method for a particular waste stream or to select an alternative standard method will be documented in the operating record. In some situations, analyses by SKB Rosemount laboratory may not be necessary or appropriate, such as when the laboratory analyses are performed by another suitable laboratory or the analyses are provided by the customer. 3.3.8 WASTE ACCEPTANCE CRITERIA As SKB Rosemount will be permitted to accept only non - hazardous industrial waste, any material meeting either the listing criteria or the characteristics for a hazardous waste would be unacceptable at the Facility. In addition, there are certain types of wastes that are unacceptable due to other properties. Not all of these criteria can be simply expressed or easily measured; however, the hazardous waste criteria and several others are relatively straightforward. The acceptance limits for these criteria are listed below: 3.3.8.1 TCLP Any TCLP parameter must be below the levels listed in 40 CFR Part 261.32. Depending upon the waste's proximity to the TCLP limits, special testing or handling procedures specific to each waste may be imposed. This method is also used to test municipal combustor ash for metals to determine if amounts are greater than the maximum leachable contaminant levels listed in 7035.2885 Subpart 5. 075704 (27) WAP 15 CONESTOGA - ROVERS & ASSOCIATES 3.3.8.2 CORROSIVITY A material is only able to express a pH in a liquid form. As such to measure pH water must be added to the waste to form a slurry. The pH of the waste and water slurry must be between 2 and 13. Material slurries with a pH between 2 and 3, or 12 to 13, may be subject to special handling procedures specific to each waste. The Facility will not manage any liquid corrosive waste. 3.3.8.3 FLASHPOINT Any waste with a flashpoint between 140° and 200° can be accepted but may require special handling procedures specific to each waste. A flashpoint of over 200° is acceptable. In most cases, wastes with a flashpoint less than 140° are not accepted. SKB Rosemount will test solids for ignitability using ASTM method D4982 -89. 3.3.8.4 REACTIVITY Any waste which is so reactive as to be considered a hazardous waste, is unacceptable. Refer to 40 CFR 261.23 for guidance for the standard when a waste is hazardous due to reactivity. 3.3.8.5 FREE LIQUIDS No waste containing free liquids will be disposed of in the containment cells. Such liquids must be solidified prior to being disposed at the Facility. SKB Rosemount will test solids for liquid using EPA method 9095. 3.3.8.6 LISTED WASTES No waste listed as hazardous under 40 CFR 261 will be accepted at SKB Rosemount unless it has first been delisted by either EPA or the MPCA. 075704 (27) WAP 16 CONESTOGA - ROVERS & ASSOCIATES 3.3.8.7 RADIOACTIVITY No waste exhibiting radioactivity in excess of 0.2 mrem /hr or above 1000 counts/ minute will be accepted for handling without approval from the county and the MPCA. No Nuclear Regulatory Commission (NRC) regulated wastes will be accepted regardless of actual activity levels. 3.3.8.8 PCBs Per MPCA rules, no waste containing PCBs above 50 ppm will be accepted except for wastes discussed in the letter issued by the MPCA dated July 14, 2004. Waste pipe sections, when free of liquids do not meet the state hazardous waste definition for PCBs. This is consistent with the MPCA's determination that cmpt /transformer carcasses that once held PCB contaminated (50 to 499 ppm) oils are non - hazardous. A copy of this letter is included in Appendix D. 3.3.9 ASH ACCEPTANCE CRITERIA To ensure that ash received at SKB Rosemount is equivalent to the ash approved and characterized as non - hazardous during the pre - acceptance process, a minimum of one load per day or ten percent of ash loads per generator, whichever is greater, will be tested for all fingerprint parameters. Every load will be inspected for physical appearance and radioactivity. The following fingerprint parameters will be used for MSW incinerator ash: • Physical appearance • pH • Calcium Carbonate Content • Radioactivity • Bulk Density All fingerprint analysis, except for calcium carbonate analysis, will be performed using EPA or ASTM methods. Calcium carbonate analysis will be performed using a scientifically acceptable procedure approved by the Dakota County Environmental Management Department. 075704 (27) WAP 17 CONESTOGA- ROVERS & ASSOCIATES 3.3.10 TOLERANCE LIMITS FOR WASTE ACCEPTANCE It is inevitable that there will be some variation in the properties and characteristics of the wastes received at SKB Rosemount. While some variation is to be expected and is acceptable, large variations indicate that the waste may be significantly different than that approved during pre - approval. For the purposes of this WAP, the typical acceptable tolerance ranges for the incoming load analyses are shown in Table 5 and Table 6 (Appendix A). These are intended as guidance only; actual ranges will be established for each waste stream during the pre - approval procedure. 3.4 WASTE RETECTION AND APPROVAL 3.4.1 RETECTION Customers whose waste is rejected during the pre - approval procedure will be notified that their waste is unacceptable at the Facility and given an explanation why it is not acceptable. 3.4.2 APPROVAL Customers whose waste is found to be acceptable at SKB Rosemount will be notified in writing. The approval letter will typically contain information regarding the type of waste, the volume expected per load, the anticipated frequency of shipment, the pretreatment needed (if any), the packaging required, delivery scheduling, frequency of testing required, the incoming load analyses that the waste will receive, and the allowable range of results for these tests. The letter will inform the customer that wastes containing free liquids will not be allowed to be placed in cells at SKB Rosemount. The approval letter will also contain other information as appropriate to the waste stream such as applicable state policies or regulations. A sample approval letter is shown in Appendix C. 075704 (27) WAP 18 CONESTOGA - ROVERS & ASSOCIATES 4.0 MANAGEMENT DECISIONS FOR WASTE 4.1 ACCEPTANCE/RETECTION CRITERIA As discussed in Section 3, there are three general circumstances that will be encountered in reviewing a waste: (1) the information almost immediately indicates that the waste is not acceptable because it is listed or has characteristics that cause it to be hazardous, (2) the waste is probably acceptable but needs to be reviewed relative to SKB Rosemount acceptance/ rejection criteria, and (3) the waste is obviously an acceptable, non- hazardous, innocuous material. This section addresses the acceptance/ rejection criteria which would be applicable in all three cases. Figure 3 (Appendix B) illustrates the basic decision points that are made during the acceptance/ rejection review. The decision tree is a guideline that will vary depending upon the circumstances. If the reviewer believes one or two of the decision points are most critical, these would likely be evaluated first. For example, if the reviewer knows that organic vapors are present, he/she will likely place priority on flashpoint testing and cover other items if the waste was determined to have a non - hazardous flashpoint. In contrast, sand only from sandblasting of unpainted aluminum is a waste that is obviously non- hazardous. Between these two contrasting examples are many wastes that require more complete evaluations through the decision tree. In making the decision about acceptance or rejection of the waste, the Facility Manager has many resources to draw upon besides the information from the customer. In addition, there should be a regulatory history to the waste, possibly previous approval for disposal in sanitary landfills in Dakota County or other Minnesota counties in the past. Decision Criteria #1. Is the waste listed as hazardous by the USEPA? Based on the customers description of the waste and SKB Rosemount's experience in the hazardous waste field, the review will decide whether the waste is any of those listed USEPA hazardous wastes or by the MPCA such as waste oil. If the waste is listed, it cannot be accepted by the Facility unless the customer has formally delisted the waste by following USEPA and /or MPCA procedures. In addition, SKB Rosemount will only accept wastes which are acceptable under its permit. Table 7 (Appendix A) contains a list of some of the wastes that SKB Rosemount anticipates could be acceptable. 075704 (27) WAP 19 CONESTOGA- ROVERS & ASSOCIATES Decision Criteria #2. Does the waste contain free liquids? Wastes that contain free liquids will not be placed in a cell at the Facility. The free liquids test described in MPCA rules may be used when applicable to test for the presence of free liquids. The reviewer, upon determining there are free liquids by the test method, will place a special condition on acceptance that the waste must be solidified either before shipment to the Facility or solidified at the Facility. SKB Rosemount will test solids for liquid using EPA method 9095.. Decision Criteria #3. Is the waste reactive? A determination of whether a waste is reactive with water and /or would release free cyanides or sulfides that would make it a hazardous waste, will be based on the information gathered about the composition of the waste, raw materials, the source of the waste, and past SKB experience. In the absence of standard test methods, SKB Rosemount reserves the right to subject the waste to experimental non - standard procedures to aid in these decisions. It is a cyanide or sulfide bearing waste which, when exposed to pH concentrations between 2 and 12.5, can generate toxic gases, vapors, or fumes in quantity sufficient to present a danger to human health or the environment. Decision Criteria #4. Is the waste corrosive? The USEPA and MPCA have specific definitions of corrosivity thresholds that would cause a waste to be designated as hazardous. SKB Rosemount review will consider the composition of the waste (when available); past test results provided by the customer; and previous experience with other wastes from similar processes. SKB Rosemount will require new testing when uncertainty exists as to whether the waste is corrosive. If the waste is near the threshold limits of USEPA and MPCA, SKB Rosemount may require more frequent testing as described in Section 3.3.5. 075704 (27) WAP 20 CONESTOGA - ROVERS & ASSOCIATES Decision Criteria #5. Does the waste contain radioactivity? During pre - approval review, an evaluation will be made as to whether the waste has the potential to contain radiation. NRC regulated waste will not be accepted regardless of actual activity levels. If there is uncertainty as to whether non -NRC regulated waste exhibit activity, a screening test will be performed. The Facility will only manage Naturally Occurring Radioactive Materials (NORM) that are below the levels outlined in Section 3.3.8.7 of this plan Decision Criteria #6. Does the waste contain unacceptable organic substances? Essentially three circumstances can exist: 1. The available information on the waste demonstrates conclusively that no organic substance of concern is present in the waste. 2. The customer's information indicates specific organic substances of concern are present. 3. The customer's information is not sufficient to limit concerns to specific substances. In circumstance #1, the waste would pass this criterion. Circumstances #2 and #3 would necessitate additional review. The additional review could include items 6A through 6D below as applicable. Decision #6A. Is there conclusive evidence that no volatile organic substances are present? If volatile organics are not present, the reviewer will then go on to Decision 6C. If volatile organic vapors are potentially present, the reviewer will examine data from organic vapor detection reading and /or other comparable data. If organic vapor detection readings exceed 200 ppm or if other comparable information suggests flammability may be a problem, flashpoint data will be reviewed in Decision 6B. Decision #6B. What is the flashpoint of the waste? In most cases, waste with a flashpoint below 140oF will not be accepted at the Facility. Waste with a flashpoint over 140oF will be considered acceptable at the Facility subject to being acceptable by all other decision criteria. SKB Rosemount may place special 075704 (27) WAP 21 CONESTOGA - ROVERS & ASSOCIATES conditions on wastes with flashpoints between 140OF and 200oF as described in Section 4.2.2 and/or impose additional testing. The reviewer would proceed to Decision 6C. Decision #6C. Is there conclusive evidence that the waste does not contain TCLP organic substances? If organic compounds evaluated under the TCLP are not present, the testing will then focus on inorganic substances under Decision 7. Further consideration of organic constituents not included in the TCLP occurs in Decision #8. If the organic substances are present, the reviewer will examine TCLP data and proceed with review Decision 6D. This examination may exclude those organic substances that are known not to exist in the waste, such as pesticides. Decision #6D. Is there any organic substance in the waste that causes it to exceed TCLP hazardous waste thresholds established by USEPA and the MPCA? Any waste which exceeds the hazardous waste threshold will not be accepted at the Facility. Special conditions (see Section 4.2.2) and /or more frequent testing may be established by SKB Rosemount to provide additional assurance from hazardous waste accidentally being brought to the Facility. Decision Criteria #7. Does the waste contain unacceptable inorganic substances? Essentially three circumstances can exist: 1. The available information demonstrates conclusively that no inorganic substance of concern is present in the waste. 2. The customer's information indicates specific inorganic substances of concern are present. 3. The customer's information is not sufficient to limit concerns to specific substances. In circumstance #1, the waste would pass this criterion. Circumstances #2 and #3 would necessitate additional review. The additional review would include items 7A and/or 7B if applicable. 075704 (27) WAP 22 CONESTOGA- ROVERS & ASSOCIATES Decision #7A. Is there conclusive evidence that metals evaluated under the TCLP are not present? If inorganic compounds evaluated under the TCLP are not present, the review will then proceed to Decision #8. If the inorganic substances are present, the reviewer will examine the TCLP data and proceed to Decision #7B. This examination may exclude those inorganic substances that are known not to exist in the waste. Decision #7B. Is there any metallic substance in the waste that causes it to exceed TCLP hazardous waste thresholds established by USEPA and the MPCA? Any waste which exceeds the hazardous waste threshold will not be accepted at the SKB Rosemount. Special conditions (see Section 4.2.2.) and /or more frequent testing will be established by SKB Rosemount to provide additional assurance that hazardous waste will not accidentally be brought to the Facility. Decision Criteria #8. Is there any other reason why this waste should not be accepted? As discussed earlier in the text, it is impossible to describe every circumstance that could arise that would cause a waste to be rejected. The described waste evaluation process discussed in items 1 through 7B is a generalization of more detailed evaluation requirements that appear in state and federal hazardous waste regulations for differentiating hazardous from non - hazardous waste. In addition to considering whether or not the waste is hazardous, the Facility Manager will have to make a professional judgment as to whether the waste should or should not be accepted for other reasons. For example, non - hazardous wastes that contain significant leachable organic constituents will not be accepted because such materials could affect the Facility's compliance with its sewer discharge permit. SKB Rosemount reserves the right to reject any waste. 4.2 PROCEDURES FOR MANAGING WASTE 4.2.1 GENERAL PROCEDURES The management of waste at the cell is described in the Operations Plan Tab 3 of the Permit Renewal Application. Special conditions for management of waste will be established on a case -by -case basis. General guidelines for special conditions are provided in Section 4.2.2. 075704 (27) WAP 23 CONESTOGA - ROVERS & ASSOCIATES 4.2.2 SPECIAL CONDITION GUIDELINES These guidelines are provided for the purpose of describing special conditions that a SKB Rosemount reviewer may place on waste coming into the Facility. Free Liquids - SKB Rosemount will place a special condition that waste containing free liquids be solidified prior to disposal in the cell. Hot Loads - Customers that generate wastes that have the potential to have residual heat, such as slags from foundries, will be notified of the requirement that loads be cooled prior to delivery. Suspected hot loads will be set aside, and monitored until deemed cool. After it is confirmed that the load is cool, it will be thinly spread and incorporated over the entire working face. Combustible Properties - Wastes that have a flashpoint between 140oF and 200oF will be reviewed to determine if special provisions to isolate waste from hot engine components of operating equipment, etc. may be needed. Dusts - Wastes that have a high potential for wind dispersal will be subjected to special conditions. As appropriate, this could include wetting before shipment, special packaging, or other action to reduce the potential for wind dispersal. 4.2.3 WASTE USED AS COVER During the pre - approval review, the Facility Manager will evaluate whether an accepted waste has the potential to be dispersed by the wind. If the waste has characteristics which are resistant to wind dispersal, the Facility may submit a request to Dakota County to be allowed to use the waste as cover material, Dakota County approvals will be copied or made available to the MPCA and Minnesota Department of Revenue. 075704 (27) WAP 24 CONESTOGA- ROVERS & ASSOCIATES 5.0 INSPECTION PROCEDURES Incoming load procedures consist of a review of shipping papers or suitable equivalent documentation and comparison of waste acceptance analyses with the WPS information. Incoming waste load procedures are used to scrutinize a waste shipment, upon arrival at the Facility, to ensure that the waste is as described in the pre - approval information as contained in the WPS and the accompanying shipping papers. The on -site waste acceptance process is intended to confirm that the waste has essentially the same characteristics as the waste described during the pre - approval process. The incoming waste load procedures include the following: 5.1 PROCEDURES FOR ARRIVAL OF APPROVED LOADS 5.1.1 UNSCHEDULED ARRIVALS OF APPROVED WASTES Periodically, a shipment of wastes approved through the pre - approval process to the Facility may arrive without first being scheduled. When an unscheduled shipment arrives, the Facility Manager will determine if the shipment will be handled at that time or be rescheduled for delivery. Regardless, the incoming waste acceptance procedures will be followed. 5.1.2 UNSCHEDULED ARRIVALS OF WASTES NOT PREVIOUSLY APPROVED FOR ACCEPTANCE A non - approved waste, in this discussion, refers to waste that a particular customer has not completed the pre- approval procedure review on before it arrives at the Facility. The waste may or may not be acceptable at the Facility. 5.2 RECEIVING PROCEDURES 5.2.1 SHIPPING PAPER OR EQUIVALENT REVIEW Many incoming waste shipments will be accompanied by shipping papers or a suitable equivalent. Some industrial waste shipments may not be accompanied by shipping papers. Several examples of wastes that do not require shipping papers are contained in Section 5.01 of the Dakota County Solid Waste Ordinance. The information on the shipping papers or suitable equivalent is reviewed for completeness. Information about the customer, the waste and the piece count or volume will be checked. The check will 075704 (27) WAP 25 CONESTOGA - ROVERS & ASSOCIATES be to determine if there are discrepancies in either the amount or type of waste described on the shipping papers. Significant discrepancies may be corrected through contact with the customer, transporter, or the SKB Rosemount sales representative. Significant discrepancies are those that would raise questions about the composition and types of waste in the shipment. An insignificant discrepancy would, for example, be minor weight differences between those measured by the customer and weight measured by the SKB Rosemount scale. The shipping paper review will most often occur at the scale area, in the truck parking area, or at the railcar. The load will remain in the truck parking area or on the railcar until any discrepancies are resolved. If a significant discrepancy cannot be resolved, the entire bulk load will be rejected. When the discrepancies involve a shipment of containers, the containers that have the waste with the discrepancies will be rejected. 5.2.2 WASTE FINGERPRINT SAMPLING 5.2.2.1 SAMPLING DEVICES For non - flowable wastes, tubing or a trier may be used to obtain a representative sample. Light, dry powders and granules are sampled with a tube or a "thief" to obtain a vertical core. Heavier solids are sampled with a trier, shovel, or by coring with heavy tubing. For flowable materials (i.e., dusts, powders, or sludges), the sampling device of choice is either a coliwasa or tubing so that a full vertical section may be drawn or by a weighted bottle or bomb sampler in order to allow for sampling at various depths in the container. Samples may also be obtained from valves or sampling ports. 5.2.2.2 CLEANING OF SAMPLING APPARATUS Sampling tools are inspected to make sure that they are clean before the sample is taken. Cleaning of sampling equipment is performed as follows: • Solids are removed to the maximum extent possible with a brush or cloth. 5.2.2.3 SAMPLING METHODS The customer and /or a SKB Rosemount representative may perform sampling of a waste for pre - approval. Specific sampling procedures are dependent on both the nature 075704 (27) WAP 26 CONESTOGA- ROVERS & ASSOCIATES of the waste and its location. Presented below are the typical sampling methodologies to be utilized by SKB Rosemount both on and off site. Sampling of incoming loads is generally performed at SKB Rosemount, but for the special cases noted in this WAP, sampling may occur elsewhere. Representative samples will generally be taken using methods delineated in "Test Methods for the Evaluation of Solid Waste, Physical/ Chemical Methods," SW 846, EPA; "Handbook for Sampling and Sample Preservation of Water and Wastewater" (EPA- 600/4 -82 -029); "Samples and Sampling Procedures for Hazardous Waste Streams" (EPA- 600/2 -80 -018); or 40 CFR Part 261, Appendix I. The Facility Manager must approve any modification to a sampling method prior to implementation. 5.2.2.4 SAMPLING OF FROZEN SHIPMENTS Loads of waste may be received which, although they are not liquids, contain appreciable quantities of water and which have been frozen in transit. Sampling can occur at any temperature provided a representative sample can be obtained, although some test methods have designated temperatures; in such cases, the analysis will be performed at the designated temperature. If conditions warrant (i.e., anticipated freezing conditions); a sample of waste scheduled for delivery may be taken at the point of generation. Such samples may be taken by either the customer's representative or an SKB Rosemount representative and will be accompanied by documentation specifying the sample's origin and the sampler's name. If this procedure is utilized, the load will be visually inspected for physical appearance. 5.2.2.5 SCOPE OF SAMPLING Samples will typically be taken from 10% of the shipments of a particular waste each day. In bulk shipments of multiple waste streams, samples of two waste streams will be taken. In containerized shipments, at least one sample will be taken of each type of waste in a shipment per day. No less than one sample will typically be taken from ten containers of the same waste type in a shipment. All of the containers in each waste stream will be opened for inspection, except those that contain (a) asbestos, (b) glass powder, (c) other waste that poses an immediate risk to human health as identified and agreed to between SKB and Dakota County. In addition the number of samples taken, the number of containers and type of container, and that each container was opened will be recorded on the lab load sheet. 075704 (27) WAP 27 CONESTOGA - ROVERS & ASSOCIATES There are anticipated to be circumstances in which waste sampling on site may not be necessary. Waste sampling may not be necessary when the customer has done supplemental waste analysis prior to shipment of a waste to the Facility. Waste sampling may also be unnecessary in some circumstances where the waste is clearly non - hazardous and testing will not provide any further assurances. Examples of such wastes are asbestos wallboard, laboratory clothing and similar waste for which the customer has provided certification that the waste is non - hazardous. For combustor ash shipments to be disposed within the ash cells, analysis required by Minn. R. 7035.2910 will be provided by the customer and will be evaluated by SKB Rosemount personnel to ensure waste characteristics have not significantly changed. However, based on the liner components to be used in the construction of the ash cells, only ash reflecting hazardous characteristics will not be allowed for disposal in the ash cells. 5.2.2.6 DISPOSITION OF SAMPLES Samples from waste streams are managed in the same manner as other waste. Customer - supplied samples of waste, which are unacceptable for management at the Facility, are returned to the customer (or their representative) or shipped to an alternate disposal site as per the customer's instructions, and in compliance with all federal and state regulations. 5.2.3 INCOMING WASTE ACCEPTANCE INSPECTION AND ANALYSES 5.2.3.1 BULK SLUDGES AND BULK SOLIDS All bulk sludges and bulk solid waste deliveries will be inspected upon arrival at the Facility prior to acceptance. At this time, the physical appearance of the load (color, texture, physical state, etc.) will be compared against that described on the WPS and the waste will be sampled and analyzed for pH and organic vapor in headspace, and radioactivity. The pH will be run using either EPA Method 9040, 9041, or 9045, as appropriate and organic vapor will be run using either an organic vapor monitor (OVM) or a photoionization detector (PID). In addition, radiation will be measured at the scale. If a number of loads are required to transport a large amount of the same waste from a single source (i.e., a contaminated soil), all loads will be inspected for physical 075704 (27) WAP 28 CONESTOGA - ROVERS & ASSOCIATES appearance before incorporation into the working face, radioactivity, and at least 10 percent of such loads will be sampled and analyzed for pH and OVM or PID metered. In addition, suspect loads will be analyzed with an OVM or PID. Bulk sludges and solids are not off - loaded until the waste has been accepted for management at SKB Rosemount. Supplemental analyses may be ordered prior to final on -site acceptance, if deemed necessary by the Facility manager, to help clarify discrepancies. To ensure that ash received at SKB Rosemount is equivalent to the ash approved and characterized as non - hazardous during the pre - acceptance process, a minimum of one load per day or 10 percent of ash loads per generator, whichever is greater, will be tested for all fingerprint parameters. Every load will be inspected for physical appearance and radioactivity. The inspector compares the shipping paper to information contained in the customer file. The file is reviewed for such items as: • Certification as non - hazardous, • Customer waste profile, • Approved management method(s), • Required analyses, • Pre- approval analyses and • Inspection results from previous incoming loads. After inspection, if the waste meets the criteria of the incoming load procedures, the waste will be taken to the proper cell for disposal. 5.2.3.2 CONTAINERS Each shipment of containers is checked against the shipping documentation to verify piece count and contents. Containers are delivered to the dock where they will be inspected and sampled or off - loaded prior to inspection and sampling. All of the containers in each waste stream will be opened for inspection, except those that contain (a) asbestos, (b) glass powder, (c) other waste that poses an immediate risk to human health as identified and agreed to between SKB and Dakota County In addition the number of samples taken, the number of containers and type of container, and that each container was opened will be recorded on the lab load sheet. At least 10 percent of the containers in each waste stream will be sampled and combined for pH and organic 075704 (27) WAP 29 CONESTOGA — ROVERS He ASSOCIATES vapor in headspace and the presence of liquids. If it is determined during incoming load procedures that the waste in the container is not the same as described on the shipping paper, a discrepancy will be reported. An attempt will be made to resolve discrepancies through contact with the customer, transporter or the company sales representative. The shipping paper review will most often occur at the scale area, in the truck parking area or at the railcar. The load will remain in the truck parking area or on the railcar until any discrepancies are resolved. If a discrepancy cannot be resolved, the load will be rejected. For containers with free liquids, five different approaches are available, depending upon the circumstances: • Agents may be added to the container to solidify the liquids providing that there is sufficient capacity in the container. • The liquids may be decanted to another container where they may be absorbed or solidified, as above, or sent off site for alternate treatment and disposal. • The liquids may be decanted into a container where they will be mixed with other liquids and absorbed or solidified for subsequent disposal into a cell. • The contents of the entire drum may be emptied into a container for absorption or solidification as above. • Waste may be rejected and returned to the customer. 5.2.3.3 LABORATORY ANALYTICAL CAPABILITY Laboratory equipment at the Facility is capable of performing the most used incoming load analyses. Commercial laboratories will provide analytical service to supplement the Facility's laboratory capabilities. Most pre - approval analyses will be performed at either the Facility or at commercial laboratories. 5.2.3.4 GENERAL INCOMING LOAD ANALYSES The incoming load analyses (referred to as waste acceptance analyses) are performed to check that the waste shipped to the Facility is the waste that was anticipated. The following analyses would typically be performed on incoming loads where appropriate: • Free liquid screen 075704 (27) WAP 30 CONESTOGA- ROVERS & ASSOCIATES • Physical appearance • pH screen • Specific gravity or bulk density • Organic vapors in headspace • Radioactivity screen • Sulfide reactivity screen • Cyanide reactivity screen Performing these analyses on some wastes may not provide an additional assurance of their acceptability at the Facility. Wastes such as asbestos wallboard and similar materials would have no reason to be tested for pH, specific gravity or organic vapor. In such cases, the waste will typically not be sampled or tested. In all cases, however, the customer will be required to certify that the waste is non - hazardous. 5.2.3.5 SUPPLEMENTAL INCOMING LOAD ANALYSES Supplemental incoming load analyses may be performed if the SKB Rosemount Facility Manager has reason to believe that further waste characterization is necessary at any time. These analyses are typically performed using the procedures set forth in standard methods such as those of the USEPA or ASTM or may utilize unique procedures and protocols formulated for the management of hazardous waste which have proven to be useful for waste characterization. The Facility may also utilize other procedures developed at other waste management facilities. Examples of supplemental analyses which may be run on a waste are: • TOC (Total Organic Carbon) • TOX (Total Organic Halides) • Solvent screen • Total metals • Pesticide screen • PCBs • TCLP (Toxicity Characteristic Leaching Procedure) • Quantitative reactivity testing 075704 (27) WAP 31 CONESTOGA- ROVERS & ASSOCIATES 5.2.3.6 RATIONALE FOR ANALYSES The rationale for the use of any of the general and supplemental analyses listed above was discussed in the waste evaluation Section 3.3.6. 5.2.3.7 ANALYTICAL PROCEDURES SKB Rosemount will not have a full- service analytical laboratory on site. Consequently, some of the analytical testing performed in connection with SKB Rosemount will be done by contract laboratories. Any such laboratories used must demonstrate to the Facility Manager that they have adequate equipment and procedures in place to properly analyze for the parameters in question and have a formal QA /QC Plan in place. A certification by the laboratory personnel that standard MDH, USEPA, ASTM, or NELAC Institute methods have been utilized in the waste analysis may be required by the Facility during the waste evaluation process. The analytical methods used in connection with SKB Rosemount will be those generally accepted in the waste management industry and come from various sources. The most recognized tests are those contained in "Standard Methods for the Evaluation of Water and Wastewater (APHA)," and "Test Methods for the Evaluation of Solid Waste" (USEPA, SW -846). All such analyses conducted by or for the Facility in the evaluation of waste streams will be documented and traceable to established procedures. In the operation of its waste management areas, SKB Environmental has also developed a number of unique test protocols to evaluate wastes in special circumstances. If it is decided to use any of these procedures for waste evaluation in connection with SKB Rosemount, the test protocol will be kept on file at the Facility and made available to inspectors from the MPCA and Dakota County. As new analytical procedures are required, these procedures will be adopted and this WAP updated accordingly. 5.3.3.8 LABORATORY CALIBRATION PROCEDURES AND FREQUENCIES Any instrumentation used to generate data must be calibrated to assure that accuracy is within acceptable limits. The frequency of calibration is determined by several factors including instrument stability, accuracy of data required, and methodology employed. Calibration schedules are determined around a nominal period and 075704 (27) WAP 32 CONESTOGA - ROVERS & ASSOCIATES increased/ decreased to fit the requirements of a given test. The calibration schedule is generally biased to the increased side. The test equipment located at SKB Rosemount will be calibrated in accordance with the manufacturers recommendations; all expiration dates for expendable supplies will likewise be honored. Laboratories, which perform analyses for SKB Rosemount on a contract basis, will be expected to maintain a QA /QC program at all times. SKB Rosemount may periodically inspect or audit the QA /QC data generated by these laboratories. The QA /QC will be maintained in the decision - making at SKB Rosemount by limiting the authority to make disposal decisions on waste. The Facility Manager, or his specifically authorized designee, must approve all waste streams during the pre - approval process and upon arrival at the Facility. 5.2.3.9 LABORATORY METHODOLOGY Standardized test methods for selected waste characterization parameters are used. These methods are obtained from the following sources: • "Test Methods for Evaluating Solid Waste," SW -846, EPA, Office of Water and Waste Management, Washington, D.C. 20406, 3rd Edition, 1986. • "Annual Book of ASTM Standards," Parts 15, 19, 31; American Society for Testing Materials, 1916 Race Street, Philadelphia, Pennsylvania 19103. • "Standard Methods for the Examination of Water and Waste Water," 17th edition, American Public Health Association, 1989. • "Methods for Chemical Analysis of Water and Wastes," EPA - 600/4 -79 -020, EPA, Environmental Monitoring and Support Laboratory, Cincinnati, Ohio 45268, March 1979. • "Title 40 of the Code of Federal Regulations," Parts 260 -270. 5.2.4 WORKING AREA INSPECTION Personnel assigned to the cell operation will be instructed by SKB Rosemount to notify the Facility Manager if an unloaded shipment of waste appears to contain something other than the waste approved for acceptance. For example, personnel would notify the 075704 (27) WAP 33 CONESTOGA — ROVERS Sc ASSOCIATES Facility Manager, if containers or unusual wastes not consistent with the waste accepted by the Facility were intermixed with the load. The Facility Manager will be responsible to determine whether an inappropriate waste has been unloaded. If the Facility Manager believes there is an inconsistency in the waste unloaded, it will be his /her responsibility to direct appropriate actions depending on the circumstances. Unacceptable wastes that are discovered in the cell will be reloaded and shipped back to the customer. 5.3 DECISION PROCESS The waste acceptance process involves the following: • Inspection • Sampling and analytical results, as required • Information on WPS • Shipping paper or suitable equivalent • Facility Manager's judgment The Facility Manager may decide that supplemental analyses are needed for a particular waste load based on the results of waste acceptance inspection and knowledge of customer and /or waste generating process. Supplemental analyses or additional customer supplied information will be required if the results obtained during the incoming load inspection indicate unexpected characteristics with respect to pre - approval analytical results or if there are indications that the waste composition has changed. The type of supplemental analysis or additional information required from the customer will be dependent upon waste type. The Facility Manager will decide whether the waste will remain at SKB Rosemount's holding area or be returned to the customer. The result of waste acceptance analysis on incoming waste shipments will be entered in the computer program and compared to the corresponding pre - approval analysis. If the waste acceptance analyses are within the tolerance limits established during pre - approval, the waste is considered to be in conformance. Conformance and non - conformance will be documented in the Facility computer program. The Facility Manager may direct the on -site laboratory to redo the incoming load analysis to rule out laboratory error. Attempts to resolve non - conformance will be explained in the Facility operating record. 075704 (27) WAP 34 CONESTOGA - ROVERS & ASSOCIATES Wastes found to be in non - conformance will be rejected. The waste is returned to the customer or sent to an alternate facility of the customer's choosing. After the waste has been returned to the customer, it may go through the pre - approval process, if the customer chooses. In these situations, the customer will be required to provide the usual scope of information. This includes a certification from the customer that the waste is non - hazardous, completion of a WPS, and supporting test results where required. SKB Rosemount will also conduct incoming load analysis when the waste is reshipped back to the Facility. 075704 (27) WAP 35 CONESTOGA- ROVERS & ASSOCIATES 6.0 MANAGEMENT OF SPECIFIC WASTES 6.1 EMPTY PESTICIDE AND EMPTY RCRA CONTAINERS Empty RCRA containers sent to SKB Rosemount for disposal must meet all of the requirements of Minnesota Rules, Part 7045.0127 and meet all applicable criteria listed on the empty container policy (Appendix E). Empty containers shipped to SKB Rosemount for disposal must have had contents removed using commonly employed practices such as pouring, pumping, etc., and also one of the following three conditions must be met (unless the container held non- hazardous material that SKB Rosemount is permitted to accept): • No more than 2.5 centimeters of residue remains on the bottom of the container • No more than 3.0 percent by weight of residue remains inside a container or inner liner having a total capacity of 110 gallons or less • No more than 0.3 percent by weight of the total capacity of the container remains in a container having a capacity of greater than 110 gallons Empty containers that were used to hold an acutely hazardous waste (listed in Minnesota Hazardous Waste Rules 7045.0135 subpart 2, 3 or 4, item E) or empty pesticide containers that are regulated by the Minnesota Department of Agriculture must meet one of the three following conditions: • The container or inner liner has been triple- rinsed using a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate. To triple rinse is to flush the container three times. Each time using a volume of the normal diluents equal to approximately ten percent of the container's capacity. Any rinsate generated from the flushing of these containers must be used as product. If the rinsate is to be discarded, i.e., becomes a waste; it must be managed according to the Minnesota Hazardous Waste Rules. • The container or inner liner has been cleaned by another equally effective and approved method. • The inner liner that was in contact with the acutely hazardous material has been removed from the container. 075704 (27) WAP 36 CONESTOGA - ROVERS & ASSOCIATES Compressed gas containers will be accepted only if the empty container pressure is equal to atmospheric pressure. Containers will be crushed by landfill equipment in the containment cell. Compressed gas containers will be crushed as much as possible using landfill equipment. 6.2 ASBESTOS Customers and haulers of asbestos waste will be notified of the disposal requirements they must follow. These requirements include: • Standards in 40 CFR, Part 61 and Asbestos NESHAPS Revision Final Rule of November 20,1990 • Wetting of asbestos waste • Packaging in leak tight containers • Warning labels • Marked transport vehicles • Waste shipment record (manifest or bill of lading) • Taking measures to ensure that any chemicals (solvents) used in removal of asbestos are not included in load Rejected Asbestos waste will be returned to the generator and the MPCA will be notified. SKB Rosemount will accept non - regulated, Category II, asbestos material (packings, gaskets, floor coverings, roofing products, etc.) in bulk loads. Non - regulated asbestos will not be made regulated. SKB Rosemount will accept regulated asbestos, Category I, asbestos material if it is wetted and packed in plastic bags at least 6 -mils thick. The bags must be sealed shut and marked with warnings. Loads must be covered. Asbestos materials will be covered with at least 6 inches of soil or appropriate waste material at the end of the day in a way that creates no visible emissions. Bulk loads of asbestos will be kept separate from bagged loads of regulated asbestos material. Other precautions will be taken to reduce the potential of puncturing of packaged asbestos material by other wastes. Compaction equipment will not be used in areas containing 075704 (27) WAP 37 CONESTOGA- ROVERS & ASSOCIATES packaged asbestos material until at least 2 feet of material are covering the asbestos material. SKB Rosemount will maintain, until closure, shipping records, records of location, depth, area and quantity in cubic meters (cubic yards) of asbestos - containing material within the disposal site on a map of the disposal area. Any excavation in asbestos containing areas will be done in compliance with NESHAP. Any repackaging or handling of asbestos containing materials will be done by trained personnel. 6.3 WASTES CONTAINING PCBS AT LESS THAN 50 PPM Customers and haulers will be informed of the MPCA's policy regarding non - hazardous PCB disposal in the waste approval letter. Wastes that contain PCBs must be properly sampled and then tested using appropriate methods, such as EPA method 8080. 6.4 NON - HAZARDOUS WASTE SPILLS Contaminated soil proposed to be handled at the Facility is evaluated for metals, or organic compounds depending on the material spilled. Appropriate leach testing will also be utilized. Customers will be notified in the waste approval letter that proper County and MPCA spill reporting procedures must be followed. Contaminated soil that is approved for disposal at SKB Rosemount may be used as cover material at the discretion of the Facility Manager and with the approval of Dakota County. 6.5 RENDERING AND SLAUGHTERHOUSE WASTE Rendering and Slaughterhouse waste may be accepted with Facility Manager review and approval. These waste steams will be evaluated for odor potential and methane production potential. 075704 (27) WAP 38 CONESTOGA- ROVERS & ASSOCIATES These waste streams will be covered either with waste or cover materials by the end of each day. 6.6 MATERIALS THAT COULD SPONTANEOUSLY COMBUST OR THAT COULD IGNITE OTHER WASTES BECAUSE OF HIGH TEMPERATURE Materials that would spontaneously combust will not be accepted. Some materials. like bio- diesel bleaching earth, have some risk of spontaneous combustion and will be managed at the Facility Managers discretion. Potential high temperature materials will be accepted. The generator will be instructed in the approval letter to allow the waste to cool prior to shipment. Care will be taken during inspection to ensure that the wastes are cool prior to placement in the cell. 6.7 FOUNDRY WASTE All foundry wastes will be evaluated for metal content. This evaluation will be based upon knowledge of the waste and may include use of the TCLP. Any foundry wastes, such as bag house dust, that are subject to wind dispersal, will typically be dampened by the customer prior to shipping. All foundry waste loads shipped to SKB Rosemount must be covered during transit. Wastes subject to wind dispersal will be further dampened during disposal in the cell. Other foundry wastes will be considered for use as cover material. 6.8 ASH FROM INCINERATORS, RESOURCE RECOVERY FACILITIES AND POWER PLANTS SKB Rosemount will accept ash and slag from the burning of coal as a fuel source. All ash or slag is tested for metals using the TCLP unless the customer can demonstrate this is unnecessary through metals analysis or by some other method. During placement, operators will check for hot loads and wet as needed. Slags and bottom ashes may be considered for use as cover material if they do not contain fractions 075704 (27) WAP 39 CONESTOGA- ROVERS & ASSOCIATES that are susceptible to wind dispersal. Wastes that are subject to wind dispersal will be covered with an appropriate material. 6.9 PAINT RESIDUE PAINT FILTERS, AND PAINT DUST Paint related waste is common to a large number of industries and is often hazardous. SKB Rosemount will not accept any hazardous wastes, including hazardous paint wastes. Potential SKB Rosemount customers with paint wastes will be notified of SKB Rosemount's waste approval policy regarding paint wastes and supplied with an MPCA fact sheet on Evaluating Paint- Related Waste (Appendix F). Paint waste may contain both metals and organic compounds. During the pre - approval process, paint waste will be evaluated for metals and volatile organics using either pre- existing or newly developed data. Organic vapors in headspace will also be evaluated in paint waste. Depending on the nature of the waste, ignitability may be evaluated as well. The requirement for evaluation may be changed if the customer can demonstrate that this is unnecessary by certification of the manufacturer, for example. As with all wastes, paint wastes will not be disposed of in a liquid state. All containers of paint waste will be inspected for liquids. If liquids are present, the liquids will be solidified or the container will be rejected. Only wastes that have been approved for disposal (non- hazardous wastes) will be solidified. Paint waste, such as paint dust, that is subject to wind dispersal will be moistened and covered during transport and at the working face of the containment cell. 6.10 SLUDGES, INCLUDING INK SLUDGE, LIME SLUDGE, WOOD SLUDGE, PAPER SLUDGE, AIR POLLUTION CONTROL SLUDGE, OR INDUSTRIAL WASTE WATER TREATMENT SLUDGE Sludges have the potential to contain free liquids. Care will be taken to ensure that sludges are properly solidified prior to being placed in the cell to prevent the release of liquids. Ink sludge will be evaluated for selected metals and, if appropriate, volatiles and semi - volatiles using either pre - existing or newly developed testing information or product data. 075704 (27) WAP 40 CONESTOGA - ROVERS & ASSOCIATES Lime sludge will be evaluated for metals and for pH. During placement sludges will be checked for free liquids. Some sludges may be appropriate for use as cover materials. 6.11 FIBERGLASS, URETHANE, POLYURETHANE AND EPDXY RESIN WASTE These wastes can be found in a liquid, semi -solid or solid form. Waste will be inspected on arrival at the Facility and rejected if it does not pass the paint filter test. Waste received in containers will be individually inspected. 6.12 SPENT ACTIVATED CARBON FILTERS Activated carbon filters are used to remove organics and metals from liquids. Evaluation of this waste will be dependent on what it was used for. For example, filters that were used to remove metals will be evaluated for metals. Care will be taken to ensure that carbon filters arriving at the Facility do not contain free liquids. During placement, operators will check to determine whether dust control measures such as covering or dampening are necessary. 6.13 RECYCLING RESIDUAL Recycling residuals such as aluminum slag will be evaluated for metals or organic substances based on information available about the recycled materials. When there is a history of wide variations in the content of recycling residuals from given sources, SKB Rosemount will establish a sampling and testing plan following ASTM and /or EPA sampling procedures. 075704 (27) WAP 41 CONESTOGA - ROVERS & ASSOCIATES 6.14 BLASTING MEDIA Since blasting media waste is so highly variable and the variability is the result of the surface being blasted, waste from each job should be tested for TCLP metals. Generators of blasting waste are required to attach analytical results from each job with each manifest or verification that only clean surfaces were blasted and the waste does not contain paint chips. 6.15 MUNICIPAL SOLID WASTE COMBUSTOR ASH SKB Rosemount will accept ash from the incineration of municipal solid waste. All ash will be tested in accordance with Minn. R. 7035.2910. The ash landfill cell will meet the requirements of Minnesota Regulation 7035.2885 Subparts 10 and 11 for covers and liners. Therefore, the amount of metals in the ash is not restricted to below levels stated in Subpart 5 of 7035.2885. 6.16 MERCURY CONTAMINATED WASTE SKB Rosemount will accept solid waste that contains low levels of mercury. The wastes that may be accepted are mercury contaminated soils and construction/ demolition debris. The following criteria will be used to determine if the waste is acceptable: 1. Any mercury contaminated soils and construction/ demolition debris with total levels 0- 4 ppm mercury will be managed with no special handling requirements, for disposal at the Facility. 2. Any mercury soils and construction/ demolition debris with total levels 4 -10 ppm will be managed by immediately covering with six (6) inches of soil, upon acceptance at the Facility. 3. Any mercury contaminated soils and construction/ demolition debris with total levels greater than ( >) 10 ppm may be acceptable with PRE - APPROVAL FROM THE MPCA, on a case -by -case basis, depending on volume and concentration. The policy above does not apply to wastes other than mercury contaminated soils and construction/ demolition debris. The policy does not apply to industrial wastes. Examples of such industrial wastes which do not qualify for approval include but are 075704 (27) WAP 42 CONESTOGA- ROVERS & ASSOCIATES not limited to: ash, materials which have Standing Beneficial Use Determinations and materials that have received a Case Specific Beneficial Use Determination. Waste from a manufacturing process will be managed and evaluated using only the TCLP standard for Mercury SKB will not manage any mercury containing waste that results from a spill or the improper management of elemental mercury or materials contaminated with free mercury. 6.17 SHREDDER RESIDUE Shredder Residue will be accepted in accordance with the July 24, 2006 MPCA Program Management Decision Memo. Initially waste may be accepted based on the most recent historic data with an average concentration for each of the subject contaminants (Lead, Mercury, Cadmium, Chromium, and PCB's) less than 100% of the maximum allowable concentration listed in Minn. R. 7045.0131, Subp. 8 and Minn. R. 7045.0135, Subp. 5. 6.17.1 SAMPLING AND ANALYSIS A. Sampling Procedure. The generator must sample shredder residue waste in accordance with the sampling requirements of the Code of Federal Regulations, Title 40, Part 761, Subpart R, located at 40 CFR 761.340 through 40 CFR 761.350. B. The generator must analyze the collected waste samples: 1. for PCBs using the test methods described in 40 CFR 761.353 through 40 CFR 761.359; and 2. for the following Toxicity Characteristic contaminants using the test methods described in 40 CFR 261.24, as amended, or equivalent methods approved by the Commissioner of the MPCA, under the procedures in Minn. R. 7045.0075, Subp. 1: a. Cadmium b. Chromium c. Lead d. Mercury C. Sampling Frequency. All generators of shredder residue waste must sample the waste at an interval of 90 days (plus or minus 7 days), excepting that: 075704 (27) WAP 43 CONESTOGA — ROVERS He ASSOCIATES 1. Generators subject to increased sampling frequency must sample at the specified interval; and 2. Generators who are seeking first time disposal of shredder residue may sample at a minimum interval of at least 7 days. Waste will be accepted when five samples have been collected and an initial rolling average has been determined. 6.17.2 ACCEPTANCE A. Shredder residue waste with a rolling average for each of the subject contaminants less than 80% of the maximum allowable concentration (MAC) listed in Minn. R. 7045.0131, Subp. 8 and Minn. R. 7045.0135 Subp. 5 may be accepted. B. If any individual sample for any of the subject contaminants exceeds 100% of the MAC another round of sampling must be conducted within seven days. C. Shredder residue waste with a rolling average for any of the subject contaminants that exceeds 80% of the MAC is not acceptable. The waste must be sampled every 30 days and the rolling average must be below 80% of the MAC for 3 sample periods for the waste to be acceptable again. 6.18 WASTE FROM SEWAGE TREATMENT PLANTS Sewer Incinerator ash, grit, and screenings as defined by Minnesota Statutes 115A.03subd.29 will be accepted. The sewer incinerator ash should be tested for TCLP metals. Raw Sewage sludge and Septage as defined by Minnesota Statutes 115A.03, subd. 29 are prohibited from disposal and will not be accepted at the Facility. Class B sewage sludge that has been treated to meet the definition of Class B sewage sludge according to MN Rule 7041.1300 subp3 will also be managed. 6.19 FIRE TRAINING ASH DISPOSAL Fire training ash disposal will be accepted with no testing as demolition debris if the Facility is provided a copy of the notification required under MN Statute 116.07 Subd.12. 075704 (27) WAP 44 CONESTOGA - ROVERS & ASSOCIATES 6.20 CO- DISPOSAL OF INDUSTRIAL WASTE MSW INCINERATOR ASH The Facility will co- dispose of some Industrial Waste with MSW Incinerator Ash in the MSW Incinerator Ash Cell (Cell 4). Prior to co- disposal the waste will be evaluated according to MN Rule 7035.2910. Waste Streams seeking co- disposal approval must be evaluated for the compounds listed in Minnesota Rule 7035.2910 Subp.4 A. Total Composition (1) Table 1, (2) Table 2, and pH. The test results from the co- disposal waste will be evaluated to ensure that the leachate from cell 4 does not become acidic. The MPCA and Dakota County will be notified of the results of the analytical, and that the Facility approval of waste for co- disposal. Once a co- disposal approval has been granted, TCLP testing will be performed as necessary. 6.21 DISPOSAL OF SEDIMENT FROM MUNICIPAL STORMWATER PONDS The Facility will manage sediment from municipal stormwater ponds. These wastes are typically characterized according to the June 2012 MPCA guidance titled "Managing Stormwater Sediment Best Management Practice Guidance for Municipalities ". The guidance calls for testing of PAH's, Arsenic, and Copper. Sediment that is characterized using this guidance will be sufficient to determine if the waste can be disposed at the facility. 075704 (27) WAP 45 CONESTOGA - ROVERS & ASSOCIATES 7.0 UNACCEPTABLE WASTES AT THE INDUSTRIAL WASTE AREA SKB Rosemount was developed for the purpose of managing non - hazardous industrial waste, recycling residuals and municipal solid waste combustor ash. There are certain wastes that will not be disposed of: • Mixed municipal solid waste as defined by Minnesota Statutes, Section 115A.03, Subdivision 21, except for trace amounts of municipal waste inadvertently mixed with loads of industrial waste. • Hazardous waste which includes: (a) any hazardous waste as defined in Minnesota statute Section 116.06, Subdivision 13, and any substance identified as a hazardous waste pursuant to rules adopted by the agency under Section 116.07 and (b) any hazardous waste as defined in the Resource Conservation and Recovery Act, under 42 U.S.C. Section 6903, which is listed or has the characteristics identified under 42 U.S.C. Section 6921, not including any hazardous waste the regulation of which has been suspended by act of Congress. • Infectious waste as defined in MPCA Rules Chapter 7035.0300, Subpart 48. • Lead -acid storage batteries. • Radioactive waste as defined by Minnesota Statutes, Section 116C.71, Subdiv. 6. • Waste regulated as containing PCBs under the Toxic Substance Control Act in 40 CFR, Part 761.60. - Waste containing free liquids as defined in MPCA regulations Chapter 7035.0300, Subpart 39, unless waste is solidified either at the customers facility, by SKB Rosemount, or a third party acceptable to the customer and SKB Rosemount. • Packs of small containers of liquid surrounded by absorbents (Lab Packs). 075704 (27) WAP 46 CONESTOGA - ROVERS & ASSOCIATES 8.0 C &D DEBRIS AREA WASTE ACCEPTANCE PLAN 8.1 ACCEPTABLE WASTES The C &D Debris Area will only accept the following waste. Construction Debris - is defined as building materials, packaging, and rubble resulting from construction, remodeling and repair of buildings, roads and other man -made structures including, but not limited to, earth, blacktop, concrete, brick, lumber, sheetrock, plaster, glass, insulation, and packaging. Demolition Debris - is defined as waste resulting from the demolition of buildings, roads, and other man -made structures, including concrete, brick, bituminous concrete, wood, treated wood, masonry, glass, trees, rock, non - regulated asbestos, and plastic building parts. Industrial Waste - Industrial waste such as contaminated soil and regulated asbestos will be accepted at the C &D Debris Area. Any industrial waste that is accepted at the C &D Facility will be subject to the limits set forth in Appendix G "C &D Facility Disposal Limits ". These values are the same values referenced in County Board Action 9.1 approved by the Dakota County Board of Commissioners March 26, 2013. Both the Industrial and C &D Areas intend to provide an environmentally sound method for the disposal of treated wood. These materials need to be disposed of in a lined facility with leachate collection. The historical data shows minimal effect to the leachate caused by treated wood. 8.2 PROHIBITED WASTES Following MPCA guidelines for prohibited material in demolition landfills, wastes unacceptable for filling include, but are not limited to, mixed municipal wastes (MSW),dead animals, food and beverage containers, yard wastes, liquids, septic tank pumpings, , vehicles, tires, machinery, appliances, fertilizers, and hazardous wastes. On -site personnel will be responsible for visually inspecting all loads to ensure that prohibited materials are not unloaded on -site. In the event that prohibited materials are unloaded on -site, they will be removed from the waste and loaded into appropriate containers and disposed of in an appropriate facility. 075704 (27) WAP 47 CONESTOGA - ROVERS & ASSOCIATES 9.0 RECYCLING AND TRANSFER AREAS WASTE ACCEPTANCE PLAN 9.1 ACCEPTABLE WASTES AND MATERIALS SKB Rosemount will accept C &D debris, Industrial Waste (excluding asbestos), Municipal SW Combustor Ash, MSW, Shredder Fluff, and selected recyclables at the Recycling and Transfer Area. Construction Debris - is defined as building materials, packaging, and rubble resulting from construction, remodeling and repair of buildings, roads and other man-made structures including, but not limited to, earth, blacktop, concrete, brick, lumber, sheetrock, plaster, glass, insulation, and packaging. Demolition Debris - is defined as solid waste resulting from the demolition of buildings, roads, and other man -made structures including concrete, brick, bituminous concrete, wood, treated wood, masonry, glass, trees, rock, non - regulated asbestos, and plastic building parts. Industrial Solid Waste is defined as all solid waste generated from an industrial or manufacturing process and solid waste generated from nonmanufacturing activities such as service and commercial establishments. Industrial solid waste does not include office materials, restaurant and food preparation, discarded machinery, demolition debris, municipal solid waste combustor ash, or household refuse. Municipal SW Combustor Ash is defined as the incombustible material that remains after a fuel or solid waste is combusted. MSW is defined as garbage, refuse, and other solid waste from residential, commercial, industrial, and community activities that the generator of the waste aggregates for collection. 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 other materials collected, processed, and disposed of as separate waste streams, but does include source - separated compostable materials. Shredder Fluff is defined as non - metallic waste material remaining after removal of metal scrap from mechanically shredded automobiles, household and commercial appliances, or other household and commercial items. 075704 (27) WAP 48 CONESTOGA - ROVERS & ASSOCIATES As noted above, the Recycling Areas will also accept tires and recyclables such as paper, glass, aluminum, tin, mattresses, white goods, cardboard, and wood waste and other recyclables as markets allow. Any residual generated from the recycling facility will be managed appropriately in accordance with this plan and Facility permit. 9.2 PROHIBITED WASTES The Recycling Areas will not accept the following materials: dead animals, liquids, septic tank pumpings, sludges, machinery, fertilizers, Asbestos or hazardous wastes. As noted above, tires, and appliances, typically banned from land disposal facilities, will be accepted at the Recycling Areas for recovery purposes. On -site personnel will be responsible for visually inspecting all loads to insure that prohibited materials are not accepted at the Facility. The Contingency Plan, included in Section 9.4, addresses actions in the event that prohibited materials are inadvertently received. 9.3 WASTE HANDLING, SHIPMENT, AND DISPOSAL 9.3.1 WASTE HANDLING Recyclable and non - recyclable components of the deliveries will be separated by SKB Rosemount staff on the tipping floor. Separated components will be kept in a temporary storage area before delivery to markets or to the disposal facility. The appropriate containers or vehicles will typically be shipped as they are filled in order to minimize on -site storage. Space is available in the building for future processing areas. Processing equipment will be added as markets for other recyclables develop. 9.3.2 OTHER RECYCLABLES Recyclable materials, either those materials delivered source separated or the recyclables manually separated on the tipping floor, will be placed in a temporary storage area 075704 (27) WAP 49 CONESTOGA- ROVERS & ASSOCIATES before delivery to a processor or market. Containers or the appropriate transfer vehicles will typically be filled consecutively to minimize on -site product storage. 9.3.3 TIRES Tires will be accepted and stored in an appropriate area at the Facility. As per regulations, no more than 500 tires will be stored at the Facility at any one time. It is anticipated that as a full load is ready, the tires will be hauled away by a licensed tire hauler to an approved tire recycler. 9.4 CONTINGENCY PLAN 9.4.1 UNAUTHORIZED DEPOSITS OF ACCEPTABLE MATERIALS On a daily basis, a designated site employee will check the boundaries of the property for deposits of materials that, although acceptable, have been delivered to the wrong spot or at a time other than normal working hours. Any materials found will be collected by the site employee, using equipment as needed, and delivered to the Recycling Area for separation and shipment to an appropriate facility. 9.4.2 DELIVERY OF HAZARDOUS OR OTHERWISE PROHIBITED WASTES SKB employees will act according to the following policies and procedures in the event that prohibited wastes are delivered to the Recycling Area. Any prohibited material, despite the quantity, remains the property and responsibility of the hauler attempting delivery and the original property owner. Prohibited waste will be rejected and turned away. Prohibited wastes will be rejected and removed from the Recycling Area via the delivery vehicle if it is identified after the vehicle has entered the Recycling Area but before the vehicle leaves the site. If the material can be readily identified and is not hazardous to the health of personnel or the environment of the Recycling Area the driver of the 075704 (27) WAP 50 CONESTOGA - ROVERS & ASSOCIATES delivery vehicle will be required to remove the prohibited material and any adjacent material that may have become intermixed with the prohibited material. If SKB Facility personnel determine the prohibited material to be hazardous to the health or the environment of the site, or if the hazards associated with the material cannot be identified, County and State authorities will immediately be notified and an appropriate handling plan negotiated among those agencies, the hauler, the actual material owner, and SKB. If prohibited material is identified after the vehicle has left the Recycling Area and the material can be readily identified as not hazardous to the health of personnel or the environment of the site, SKB personnel will remove the prohibited material and any adjacent material that may have become intermixed with the prohibited material from the Recycling Area. Any materials removed in such a manner will be disposed of in an appropriate facility. 075704 (27) WAP 51 CONESTOGA - ROVERS & ASSOCIATES 10.0 SOLID WASTE 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. 10.1 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. 10.2 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 075704 (27) WAP 52 CONESTOGA- ROVERS & ASSOCIATES 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. 10.3 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. 10.4 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 that has been treated to meet Class B pathogen reduction standards in Minn. R. Ch. 7041; • Petroleum contaminated soil; • Unused scraps of gypsum drywall; and • Industrial Waste and Sludges - this means vegetative waste generated from an industrial or manufacturing process that prepares food for human 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 >_ 075704 (27) WAP 53 CONESTOGA - ROVERS & ASSOCIATES 50 %. Industrial sludges will meet the concentration values found in Minn. R. 7035.2836, subp. 6, Item A(1). In addition, below is a list of SIC codes of example industries SKB would likely pursue. 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 Coverted Paper & Paperboard Products Additionally, below is a list of SIC codes for waste streams that SKB will not be pursuing. 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 075704 (27) WAP 54 CONESTOGA - ROVERS & ASSOCIATES 10.4.1 EMPTY PESTICIDE CONTAINERS SKB will not accept empty pesticide containers at the composting area. 10.4.2 ASBESTOS SKB will not accept wastes containing asbestos at the composting area. 10.4.3 WASTE CONTAINING PCBs SKB will not accept wastes containing PCBs at the composting area. 10.4.4 SPILLED NONHAZARDOUS WASTE Only spilled nonhazardous wastes that are organic in nature and will compost will be accepted by SKB at the composting area. 10.4.5 RENDERING AND SLAUGHTERHOUSE WASTE SKB will accept rendering and slaughterhouse waste that can be composted at the composting area. 10.4.6 WASTES THAT SPONTANEOUSLY COMBUST SKB will not accept wastes that can spontaneously combust at the composting area. 10.4.7 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 075704 (27) WAP 55 CONESTOGA — ROVERS He ASSOCIATES products. However, SKB will obtain all necessary approvals from the MPCA prior to conducting this activity. 10.4.8 ASH FROM INCINERATORS SKB will not accept ashes from incinerators at the composting area. 10.4.9 SLUDGES SKB will accept select sludges at the compost area. The sludges must be nonhazardous per the requirements of Minn. R. Ch. 7045. 10.4.10 FIBERGLASS, URETHANE, POLYURATHANE, AND EPDXY RESIN WASTE SKB will not accept fiberglass, urethane, polyurethane, or epoxy resin waste at the composing area. 10.4.11 SPENT ACTIVATED CARBON FILTERS SKB will not accept spent activated carbon filters at the compost area. 10.4.12 OTHER WASTES SKB may accept bleaching earth from the production of bio- diesel and vegetable oil at the composting area. 10.5 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. 075704 (27) WAP 56 CONESTOGA - ROVERS & ASSOCIATES 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. 075704 (27) WAP 57 CONESTOGA - ROVERS & ASSOCIATES 11.0 AMENDMENT OF PLAN This plan will be amended as needed to document changes in procedures with respect to testing, inspecting or managing non - hazardous industrial solid waste. Examples of such changes include addition, revision, and/or removal of test methods, addition of new waste streams, and /or changes to incoming load inspection procedures. Amended plans will be submitted to the MPCA, the Dakota County Environmental Management Department, and the city of Rosemount. 075704 (27) WAP 58 CONESTOGA - ROVERS & ASSOCIATES APPENDIX A TABLES 075704 (27) WAP Page 1 of 3 TABLE 1 DESIRED INFORMATION REGARDING WASTES AND THE SOURCE OF GENERATION Question Significance General -About the Plant or Process What products or materials are manufactured at The presence of other products indicates that there this plant? may be additional waste streams that could be mixed with this one Does the manufacture of such products typically Even though this waste is represented as non - involve hazardous materials or hazardous waste hazardous, if there are chemicals used in its constituents; for what; and in what relative production that would be "hazardous waste quantity? constituents ", there may occasionally be residuals. How many separately identifiable waste streams If other wastes are produced, they could be come from this plant? casually mixed with this one, leading to erroneous results Is the plant a SARA Title II facility? SARA Title III implies that there are relatively large amounts of materials that might be hazardous waste constituents. These could end up in the plant wastes. Does the plant deal with any radioactive materials? The MICF is not intended for source regulated radioactive materials, nor for any source materials which mi ht be mixed with the waste. Does the plant handle or use PCB materials in any The MICF is not permitted to accept wastes way? containing PCBs above TSCA regulated levels (40 CFR Part 761 Is this a new plant, or a long - established one? How Newer plants (or those recently remodeled) tend to old? Recently remodeled? use equipment and processes which were designed with environmental concerns in mind. Waste streams from these plants are less likely to be mixed. Is the plant an independent operation or part of a Large corporations generally have environmental larger corporation? departments that work with thee plants to ensure compliance, leading to less variation in wastes. Similar plants may lack staff, resources, and /or environmental controls. Does SKB do business with plants or operations If so, experience gained from working with these owned by the same entity? other plan ts may be useful at the MICF. Does SKB do business with plants producing If so, experience gained from working with these similar products? similar plants may be useful at the MICF. Has there been a plant visit by SKB personnel in A relatively recent visit is useful in identifying the last two years? processes, and most importantly changes form earlier visits. Is there a history of business between SKB and this A prior business history with the plant may either plant, or the environmental personnel at this point? lend assurance that the waste is consistently If so, does that history indicate the potential for represented, or possibly misrepresented. Similarly, problems? if personnel at one plant are transferred to another, their level of expertise and training is known, and the ualit of the information they provide. 075704 (27) WAP -APPA Page 2 of 3 TABLE 1 DESIRED INFORMATION REGARDING WASTES AND THE SOURCE OF GENERATION About Materials Known To Be Produced At the Plant. Metal primer paints Heavy metals or solvents may be a concern. Paints, including lacquers, enamels, and urethanes. Many solvents may be used with these, primarily What types of paints or finishes are used? non - halogenated volatiles. Latex paints/ solvents, however, are more innocuous. Degreasers Degreasers may be either strong caustics or volatile organics, usually halogenated. Question Significance Strong Mineral Acids or Caustics (e.g. HCl or Upsets in plant processes may lead to pH extremes. NaOH) Also, acids may be used for surface preparation, leading to a concern for heavy metals. Leaching Compounds May be corrosive, contain heavy metals TCLF characteristic or listed pesticides Pesticide formulation may leave residuals in the waste Chlorides or sulfides Certain chemical processes use these chemicals; a misclassified waste which contained either of these compounds could be very dangerous. Plating chemicals Plating usually involves acids, caustics, and cyanides. About the Waste Production Process Itself., Does it come from a continuous or batch process? A continuous process is more likely to produce a consistent waste material than a batch process. Is the production process routinely changed? If a process is changed, waste constituents may vary. Was the waste stream characteristically hazardous If a production or feed - stream change was made or in the past? Is there the potential for the waste to will be made, the possibility of the waste reverting be characteristically hazardous in the future? to or becoming a hazardous waste must be considered. Historically, how close has the waste stream come If waste "quality" varies such that it may in being characteristically hazardous? 25 %? 50 %? occasionally become hazardous, closer surveillance 85 %? is needed. Is the production equipment or machinery for this Carry -over contamination from previous waste stream used for the production of materials production runs must be considered. which sometimes also produce hazardous wastes? Characteristic or listed? Cleaning procedures between runs? Are waste streams mixed? Which ones, and how? When waste streams are mixed, the variations in each must be considered. Does this plant produce hazardous waste streams? If mixing can occur, additional care must be In addition to the candidate industrial wastes exercised with each load received, to assure that it streams? Are they clearly separated? is not a hazardous waste. 075704 (27) WAP -APPA Page 3 of 3 TABLE 1 DESIRED INFORMATION REGARDING WASTES AND THE SOURCE OF GENERATION Waste Stream-Sp eci is Information Type of Information Other Information Sources Waste Profile Sheet? • MSDS Sheets Non - Hazardous Waste Certification Completed? • Previous Lab Results Previous and Current Test Data on Waste? • Site Visits/Reports Production Process, Rate, etc. known? 0 Outside Audits by Others (Must be publicly available Any history available on the waste stream, or similar? Site Files • Customer Service Files 075704 (27) WAP -APPA TABLE 2 FREQUENCY OF RE- CHARACTERIZATION GUIDELINE FOR INDUSTRIAL WASTE Variability 1 Test Result Slight ( t 20 %) >90% 75 % -90% 75 % -60% <60% Moderate (t 40 %) >75% 60 % -75% 70 % -55% <55% Great (> 40 %) >67% 55 % -67% 60 % -45% <45% Resulting Every load Quarterly Annually Every 4 years Frequency of Testing Note: 'Variability From Average Test Result of Waste 2Maximum test result listed as % of hazardous waste threshold 075704 (27) WAP -APPA Page 1 of 1 N O bA M W a H h 4 X X X X X X X X y 0� ti X X X X x X X W a W v u X X wo �� o� x �z �Q x X X X X X X X X X y W a y E"' U � o� 3 z� o u V) X X X X X o X x X X X x A� tl �u Q cn v !y A tr y v b N 7C � ,d O c v x b.0 +V+ N rpN N GJ U 'M N N N �N O y h co .C1 v V O y�,r � to N (C •� ++ m H N m a a d 3 N O n N n O N w O N v bA u. ". O� cWn C Ae a4 C M z C a p: O� P. U C z� A� 0-4 ► y o� X X X X X X X U G X X X X x y X X X X X X X X X X X X X 3 A X X X X X Im- X N W d O w � bA d .n CS v U c6 cC bA cz N bb q sN f. ti O bA b0 p L a c. a d a 3 N_ n N n O TABLE 4 TYPICAL ACCEPTABLE TOLERANCE RANGES FOR INCOMING LOAD ANALYSES Parameter Physical Appearance pH Screen 2,4 Bulk Density Reactive Cyanide Screen 3 Reactive Sulfides Screen Water Reactivity Screen Organic Vapor Screen (O.V.) Ignitability Test (if indicated by O.V. Screen) Radioactivity Screen Acceptable Variation (Typical) Similar waste character 1 t 2 pH units t 20% (solids) Positive screen may indicate the need for a quantitative analysis to determine whether the material can be accepted under MPCA permit Positive screen may indicate the need for a quantitative analysis to determine whether the material can be accepted under MPCA permit No tolerance 3 For an increase over 100 ppm from the original value obtained in prescreening, or any value over 200 ppm, run ignitability If flashpoint decreases from above 200 ° F to less than 200° F, reconsider handling requirements; if flashpoint decreases to less than 140° F, reject as hazardous waste If radiation count is over 0.2 mrem /hr. or 1000 counts /min., consult with regulatory agencies Page 1 of 1 Notes: 1 The inherent variability of the physical appearance of wastes does not allow quantifying the tolerance range. The inspection for physical appearance is performed during the incoming load procedures to indicate a significant change in the nature of the waste (e.g., a liquid rather than a solid), which may indicate a change in the composition or the process generating the waste. 2 pH is only run on liquids or free liquids associated with solids or sludges. 3 The result of the screen must be the negative during both the pre - approval and incoming load procedures. Does not necessarily determine corrosivity. 075704 (27) WAP -APPA TABLE 5 TYPICAL ACCEPTABLE TOLERANCE RANGES FOR INCOMING MSW INCINERATOR ASH LOAD ANALYSES Parameter Acceptable Variation (Typical) Physical Appearance Similar waste character pH ± 2 pH units Bulk Density ± 20% Calcium Carbonate t 20% Radioactivity Screen > 0.2 mrem /hr. consult with regulatory agencies 075704 (27) WAP -APPA Page 1 of 1 Page 1 of 2 TABLE 6 SOME OF THE POTENTIALLY ACCEPTABLE WASTES AT SKB ROSEMOUNT Waste Types Source Abrasive Saw Filter Dust Machine Shop Activated Carbon Filters Adhesives Broad Range of Industries Aluminum Slag Aluminum Recycling Aluminum Slag Waste Foundry Asbestos Buildings Auto Shredder Fluff Automobile Recycling Baghouse Dust Air Pollution Control Systems Bead Blaster Baghouse Dust Foundry Belt Grinder Baghouse Dust Machine Shop Blast Furnace Slag Foundry Contaminated Pallets Misc. Sources Contaminated Soil Misc. Sources Conveyor /Rattlebox Baghouse Dust Foundry Copper Blast Grit Foundry COZ Core Butts Foundry Discarded Crucibles Foundry Dried Paint (non- hazardous only) Diverse Sources Electric Furnace Slag Foundry Empty Containers Diverse Sources Edmpty Paint Cans -used & dry Auto Refinisher Epoxy Molding Materials Military/ Aerospace Epoxy Powder and Resin Diverse Sources Ferric Hydroxide Sludge Computer Components Fiberglass Trimmings Fiberglass Fabricating Filter Dust and Cake Filters Floor Sweepings Foundry Fluorosilicone Rubber Military/ Aerospace Furnace Linings Foundry Iron Furnace Material Waste Foundry Iron Slag Waste Foundry Iron Spent Ladle Waste Foundry Glass Grinding Sludge Eyeglass lens manufacturing Grinding Filter Sludge Machine Shop Grinding Waste Metal Grinding Grinding Wheels Foundry Hi -Temp Blanket Waste Foundry Honing Sludge Machine Shop Ink Waste Printing Iron Oxide Magnetic Tape Manufacturing Isocure Core Spills & Broken Cores Foundry Lathe Turning & Boring Baghouse Dust Machine Shop LYE Vat Sludge Railroad Machining Chips Metals Fabrication Magnetic Belt Sand and Iron Waste Foundry Magnetic Tapes Diverse Sources Metal Dust Metal Fabrication Metal Hydroxide Sludge Diverse Sources Metal Slags Metal Fabrication 075704 (27) WAP -APPA Page 2 of 2 TABLE 6 SOME OF THE POTENTIALLY ACCEPTABLE WASTES AT SKB ROSEMOUNT Waste Types Source Metal Sludges Metal Fabrication Nickel Plating Filter Wash Metal Fabrication Nickel Sludge Metal Plating Oil Contaminated Soils Petroleum Processor Oil Core Spills and Broken Cores Foundry Oily Tank Bottoms Petroleum Processor Overflow from Inside Shotblast & Spillage Foundry Packaging Foam Diverse Sources Paint Filter Ash Metal Fabrication Paint Filters Paint Shops Paint Waste Paint Shops Pepset Mold Making Spills & Sweepings Foundry Phosphate Sludge Metal Finishes Plastic Wastes Diverse Sources Plating Sludge Metal Plating Polishing Dust Sediment Diverse Sources Polyester Scrap Diverse Sources Polyurethane Foam Diverse Sources Product finishing Baghouse Dust Foundry Rubber Chips Foundry Sand (air set, green sand, core butts) Foundry Sand Blast Sand Foundry Sand Paper Scrap Sandpaper Manufacturing Sand Reclaimer Dust Dust Foundry Scrap Rubber Diverse Sources Settling Tank Waste Foundry Shakeout Conveyor Sand Waste Foundry Shaker Screen Overflow Green Sand Foundry Shell Core Spills and Broken Cores Foundry Shotblast Baghouse Dust Foundry Solidified Cutting Oil Diverse Sources Spent Catalyst Refinery Spent Furnace and Door Lining Waste Foundry Spent Furnace Refractory Foundry Spent Graphite Wash Waste Foundry Stabilized Lead Reverb. Furnace Slags Lead Recycling Tool Grinding Baghouse Dust Machine Shop Used Paint Steel Strainers Diverse Sources Varnish Solids Wood Finishing Waste Circuit Boards Electronics Waste Magnetic Tape Magnetic Tape Manufacturing 075704 (27) WAP -APPA APPENDIX B FIGURES 075704 (27) WAP INITIAL DECISION FLOW CHART Information Recived C R�A Review the Declared Waste Type, and Composition Yes Is the waste hazardous or otherwise unacceptable? No Compete Is it possible that the Customer waste may be hazardous Waste or potentially unacceptable? Yes Profile? No Is the waste acceptable, No and likely to remain so? Yes Notify Customer of waste acceptability, make necessary arrangements. 075704- 3063(027)GN -SP001 MAR 20, 2013 Reject - Notify Customer that waste is unacceptable. Yes Perform Specific Pre - Approval testing (See Figure 3.) Approve waste for shipment, establish routine incoming load inspection. Establish incoming load test parameters. 0. K. Pass - 0. K. figure 1 SKB Rosemount Industrial Waste Facility 2007A P.O. Number I Customer Code SKB Representative MI C_nnnra+nr Tn fnrmafinn Generator Name: Generator EPA ID Number SIC Code Generator Location: County: Generator Contact: Generator Mailing Address (if different:) Generator Email Address: Bill to Name & Address: Bill To #: Invoice Contact: Billing Contact: Phone: Fax: IAlae +n C_nncra+ inn Tnfnrmafinn Waste Name: Estimated rate of waste generation: ❑ Lbs. ❑ tons ❑ CY ❑ drums ❑ One time ❑ yearly Generator Facility Operations and /or Site History: Describe the generating process or source of contaminated soil/ debris and /or waste: III. Waste Composition and Constituents list all known Actual Range % PPM RI TAlae +o Prnnnrfine Physical state: Free Liquids: pH Range: Flash point: Color: Odor (describe): • Solid ❑ Liquid ❑ Yes ❑ No ❑ <2 ❑ 2 -4 ❑ <_ 140 °F • Sludge ❑ Gas ❑ 5 -8 ❑ 8 -12.4 ❑ >140 ° F to <200 ° F Content % ❑ >12.5 ❑ >200 °F V. Waste Classification Waste stream properties (answer ALL questions) ❑ Yes ❑ No Does this waste contain absorbents? ❑ Yes ❑ No Does this waste stream contain any D, F, K, U or P Is this waste lethal (by Minn. Rules 7045.0131 listed as hazardous waste, either in pure form, as Subp. 6)? a mixture, or treatment residue: Does this waste stream contain PCB material? ❑ Yes ❑ No Is this waste recyclable? ❑ Yes ❑ No If yes, concentration: m Does this waste stream contain fuming acids? ❑ Yes ❑ No Is this waste explosive? ❑ Yes ❑ No Does this waste contain asbestos: ❑ Yes ❑ No Is this waste infectious? ❑ Yes ❑ No Does this waste contain oxidizers? ❑ Yes ❑ No Is this putrescible waste? ❑ Yes ❑ No Does this waste contain radioactive material? ❑ Yes ❑ No Is this waste demolition debris? ❑ Yes ❑ No Is this waste sewer sludge? ❑ Yes ❑ No Please attach any available information or analytical test results that have previously been performed on this waste that substantiates these determinations. Include MSDS's and any information from other agencies i.e., Dakota County, MPCA VI. Shipping Information Proper DOT Shipping Name (per CFR 172.101) where applicable Reportable Quantity DOT Hazard Class UN /NA Number Packing Group Method of packaging: ❑ drums (size ) Method of shipment ❑ Bulk Solids ❑ boxes (size ) ❑ Roll -off ❑ End dump ❑ Rall ❑ Other (Specify) VII. Certification of Non Hazardous Waste & Approval Conditions I hereby certify and warrant, on behalf of the generator and myself that, to the best of my knowledge and belief, the information contained herein is accurate, and true and that the waste is nonhazardous as defined in Title 42, United States Code Section 6903, Minnesota Statute Section 116.06, Subdivision 13, and /or any rules adopted by the Minnesota Pollution Control Agency under Minnesota Statutes Section 116..07. I understand that any approval is no longer valid if there are any changes in the process generating the waste or there have been changes in the composition of the waste. Therefore, if the composition of the waste stream changes or potentially changes, I or someone representing the generator, will immediately notify SKB Environmental. I, on behalf of the generator, hereby agree to fully Indemnify SKB Environmental for any damages and /or costs incurred as a result of this certification being inaccurate or untrue. Signature: Printed Name: Title: Date: WASTE ACCEPTANCE DECISION CHART Is this listed Hazardous Waste? Yes Reject No Is the waste reactive (Water, Yes Reject CN, or S ?) No Is the waste Corrosive? Yes Reject No Does 5MPCA? meet tYes Reject chara define No Is the waste Consult with Radioactive, as Not j defined? Yes Agencies. Yes Acceptable Re ect No O.K. Inorganic Portion - Go to Chart 1 What is the Waste Composition? O.K. Are there Free Liquids must be Free solidified before disposal. Liquids? Yes Liquids No 075704- 3063(027)GN -SP002 MAR 20, 2013 Organic Portion - Go to Chart 2 No Reject figure 3 Waste Acceptable at e ® SKB 075704- 3063(027)GN -SP002 MAR 20, 2013 Organic Portion - Go to Chart 2 No Reject figure 3 INORGANIC PORTION OF WASTE CHART 1 Inorganic Portion Are there likely to _ Run TCLP for >100% Reject be TCLP metals at Yes metals as needed of TCLP levels of concern? <100% of TCLP No 501 075704- 3063(027)GN -SP003 MAR 20, 2013 figure 3A ORGANIC PORTION OF WASTE CHART 2 Inorganic Portion Is the waste putrescible or <with lt Not subject to rapid Yes CA Ac ceptable -� Reject bio- degradation? No I Does the waste exhibit Organic 1 Vapor Levels? No Yes Reject <140* What is the flashpoint of the waste? >140' but <200' Acceptable, but Special Handling. Are there likely to Run TCLP for be TCLP organics specific organic at levels of substances of >100% concern? concern. of TCLP <100% Reject of TCLP I Organic Portion of waste is O.K. CRA 075704- 3063(027)GN -SP004 MAR 20, 2013 Refer to Table 2 for Frequency of Re- Testing. * ** - Denotes that Special Handling may be required figure 3B APPENDIX C SAMPLE WASTE ACCEPTANCE LETTER 075704 (27) WAP SAMPLE WASTE ACCEPTANCE LETTER (PAGE 1 OF 2) Notification of Waste Acceptance CUSTOMER INFORMATION INVOICE INFORMATION EPA ID #: MNXXXXXXXXXXX Company Name Company Address City, State, Zip Contact: Name Phone: Profile Sheet #: 123456 Waste Stream #: MIXX -1234 Waste Name: Waste Name Bill #: 123456 Bill To Name Bill To Address City, State, Zip Contact: Name Phone: Thank you for selecting SKB ROSEMOUNT for your waste management requirements. Your waste stream has been reviewed and is acceptable for management at our facility based on the information provided in the profile sheet number listed above and the conditions below. Our facility ,has the necessary permits to allow the storage, treatment, or disposal of this waste. The above -pferenced acceptance number should be listed on all shipping documents and correspondence. -,ase retain these documents for your records and future reference. To schedule a shipment, or should you have any questions, please contact the facility at (651) 438 -1500. ACCEPTANCE INFORMATION The waste stream identified by the reference above is acceptable for disposal. The anticipated frequency of shipments is QUANTITY /FREQUENCY. This waste is acceptable for delivery beginning on XX/XX/XXXX thru XX/XX/XXXX at which time he material will need to be reanalyzed and recertified. PCB Statement: The Minnesota Pollution Control Agency encourages generators of non - hazardous PCB waste to voluntarily manage the waste as hazardous waste or to seek an alternative to land disposal, such as incineration. Spill Reporting Reminder: Proper County and MPCA spill reporting procedures must be followed. ?mpty Container Statement: Each shipment containing empty containers must be accompanied h a completed 'EMPTY CONTAIN ER.CERTIFICATION FORM'. �rce Liquid Statement: Free liquids will not be placed in cells at SKB Rosemount. Free liquids lust be solidified either prior to shipment to-SKB Rosemount, or at SKB Rosemount. SAMPLE WASTE ACCEPTANCE LETTER (PAGE 2 OF 2) Shipping Requirement: ANON- HAZARDOUS.Certificate is required to be on file, certifying the waste is non- hazardous as specified per 40 CFR 261.4. The shipment must be accompanied with an SKB Rosemount manifest. WASTE STREAM ANALYSIS INFORMATION Waste Name: XXXXXXX Physical State: (Solid) Process Producing Waste: XXXXX)UC PRE - APPROVAL SAMPLE RESULTS Color: XXX Physical State: XXX Dust Present: XXX Free Liquids: XXX Paint Filter Test: XXX Odor. XXX Flash Point Range: XXX Density: XXX Radioactive ?: XXX Water Reactivity XXX pH Range: XXX React to Acid: XXX React to Base: XXX % Moisture: XXX OVM Sniff: XXX Sulfide: XXX Oxidizers: XXX Cyanide: XXX Reacts with Air: XXX This analysis is solely for use by SKB Rosemount employees for the purpose of determining waste acceptability. No other claims are made or implied. COMMENTS AUTHORIZATION Approval: Date: APPENDIX D PCB PIPE WASTES 075704 (27) WAP 10:Lt7 VAA 612 ? -1 6357 TCEI, ENERGY ENS' SVCS - -- - -- - - -- - — -- -- -- 110 O 1 Minnesota Pollution Control Agency June 14, 2004 Post -It" brand fax transmittal memo 7671 Tb b olpages �� ~ Mr. Mark Gerlach �c �� From Environmental Services Dept. Xcel Energy Phone i� 'icollt >all (S8 ) Fax a q3 ? L( F 330 � Z� q Minneapolis, MN 55497 RE: Waste Detonation -gas pipe Dear Mr. Gerlach: The purpose "of this letter is to respond to Xcel Energy's (Con' an fo determination by the Minn"ota pollution P Y) rrna.i request for a was from the Ca Control Agency (YMCA). That request was in art t _MBU n to the M1'CA dated June 7, asbestos a and specifically described gas Pipeline,, ections that mdy or may not be contaminated with asbestos and/or PCBs. The description provides a t explanation of the applicability make a det wheh of federal PCB ntles (40 CFR Part 761) and requests that the gPCA etules i a to whether the wastes meet the definition of a Minnesota hazardous wa ;tc under Minnesota Rules Chapter 7045 Ile -\ _PCA agrees that the waste pipe sections� when free of liquids, do not meet the definitic •t of a state hazardous waste for PCBs. This is consistent with the NOCA'S determination transformer carcasses that once held PC8 contaminated (50 to 499 Oils are no that empt r PPM) oils are non- hazardo� :s. Based on this determination, Xcel Energy hazardous waste definition, provided ,31 oils consider hazardous waste from the - hazardous according tt state Federal PC$ rules (40 CM Part 761) also continue to apply. p Pe prior to dispose PCB disposal, please call Steve LaRoque at (218) 8467 -02 If you have any further question, about The disposal in a permitted landfill of this waste must meet all permit requir mcnts for any so id waste facility the Company chooses to utilize. Asbestos requirements Company's rc`a`ponsibility to ensure that the waste is ace ents must be met and it is tht Jackie Deneen at (651) 297 -5847 for further information on acceptable asbestos disposlal� permit Ple t ontact Sincerely, Paul Scheirer', Supervisor Regular Facilities Unit Detroit Lakes Office Regional Environmental Management Division PS jao Lake Avenue Ptaza, Suite 220, 714 Lake Av Sr. Paul • Duluth enoe; Detroit Lakes, Minnesota Moire (218) 847 -1 519; Fax (218) 846.0719 Brainerd Detroit 1 -Pikes • Marshall - R Eoual f ?nnt,rhiniry fiinntnv,.r Arine.r{ r`n .,,,., ochezter •Mankato wiilmac• W• TTX(6!,1)2$2�3; mot• t . _� ,_ -_. � , 4bb Site wwc •.pcd.st2te.mn.us APPENDIX E EMPTY CONTAINER POLICY 075704 (27) WAP EMPTY CONTAINERS Empty hazardous waste containers sent to SKB Rosemount for disposal must meet all of the requirements of Minnesota Rules, Part 7045.0127 and meet all applicable criteria listed below. The customer will be notified of this requirement in the approval letter. Empty containers shipped to SKB Rosemount for disposal must have had all contents removed using commonly employed practices such as pouring, pumping, etc, and also one of the following three conditions must be met (unless the container held non - hazardous material that SKB Lansing is permitted to accept): • No more than 2.5 centimeters of residue remains on the bottom of the container. • No more than 3.0 percent by weight of residue remains inside a container or inner liner having a total capacity of 110 gallons or less. • No more than 0.3 percent by weight of the total capacity of the container remains in a container having a capacity of greater than 110 gallons. Empty containers that were used to hold an acutely hazardous waste (listed in Minnesota Hazardous Waste Rules 7045.0135 subpart 2, 3 or 4, item E) or empty pesticide containers that are regulated by the Minnesota Department of Agriculture, must meet one of the three following conditions: • The container or inner liner has been triple- rinsed using a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate. To triple rinse is to flush the container three times. Each time using a volume of the normal diluents equal to approximately ten percent of the container's capacity. Any rinsate generated from the flushing of these containers must be used as product. If the rinsate is to be discarded, i.e., becomes a waste; it must be managed according to the Minnesota Hazardous Waste Rules. 11 • The container or inner liner has been cleaned by another equally effective and approved method. • The inner liner that was in contact with the acutely hazardous material has been removed from the container. Compressed gas containers will be accepted only if the empty container pressure is equal to atmospheric pressure. Containers will be crushed by landfill equipment in the containment cell. Compressed gas containers will be crushed as much as possible using landfill equipment. APPENDIX F EVALUATING PAINT - RELATED WASTES 075704 (27) WAP Minnesota Pollution Control Agency This fact sheet is intended for collision repair and other coating operations. In This Fact Sheet- Choosing Paint and Suppli es ........................1 Choosing Equipment .......2 Leftover Supplies .............2 Reducing Solvent Use.,....2 Classifying Wastes ............ I Hazardous Waste Requirements.......... 3 .Industrial Solid Waste Requirements ................ 3 Air Permits ......................3 More Information ..........:4 Managing Paint- Related Waste from Coating Operations Hazardous Waste Division Fact Sheet #4.39 August 1997 Choosing Paint and Supplies 3, The flashpointof the paint. A. flashpointbelow 140° F means There are three main environmental that the paint waste is hazardous concerns about industrial paints: because it is ignitable, I., The amount of toxic metals such as barium, cadmium and chromium In the paint.. Paint that has metal levels above those listed in Table 1 becomes hazardous waste when it is a waste. Related wastes, such as thinner wastes and used paint filter's, are often hazardous, as well. 2.. The amount of volatile organic compounds (VOCs) in the paint Paint that contains high VOC levels may affect air- permit requirements for a business. VOGs react with sunlight to form smog. High VOC paints and thinners may also contain toxic chemicals that pose health concerns for employees.. Table 1: Maximum Allowable Concentr ai lons (MAC) of ' Metal Contaminants Metal MAC (parts per million) Arsenic 5.0 Barium 100.0 Cadmium 1.0 Chromium 5.0 Lead 5.0 Mercury 0.2 Selenium 1.0 Silver 5.0 When choosing paints and primers, check the Material Safety Data Sheets. (MSDS) for those lowest in metals and VOCs that will do a good job in your type of operation. For waterborne coatings; flashpoint is usually not a concern and VOCs are otbm at such low concentrations that a permit may not be requited; toxic metals are a concern. Contact the eherakal company's technical - support division (their phone number is on thie MSDS) or the supplier if information about VOCs or toxic metals is, missing or unclear. Other things to consider are-. a the kind ofsurface preparation-that is necessary for the paint to sticlr*; • the compatibility of paints and primers ;. • how.many coats you need to get the finish you want; • drying time and temperature;. • the kind of materials needed for cleanup, and e clean-up time. * if you use solvents to prepare surfaces or clean -up equipment, look for the lowest VOC level and least toxic solvent that will do the job. Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155 -4194 (612) 296 =6300, TDD (612) 282 -5332, toll -free (800) 657 -3864 ,,,Upon request, this material can be made avallable in alternative formats for people with disabilities. Printed on recycled paper containing at least 20 percent fibers from paper recycled by consumers. Hazardous Waste Fact Sheet #4.39 August 1997 To prevent paint from becoming unusable (waste) when sitting on the shelf, use good housekeeping practices. Leftover Supplies Here are some examples: • Keep good records of what you have on hand. • Buy only what you need. Use it all. • Store it at the proper temperature. • Use the oldest material first — rotate inventory! • Consider investing in computerized mixing equipment that will allow you to match colors exactly and mix only what you need for a job. If your shop is small and paint -filter disposal is a problem, ask your supplier about styrene paint filters. Spent styrene filters dissolve if mixed with waste thinner so you end up with one container of waste. However, they may not hold as much paint as paper or fiber filters. Styrene filters must have a "fire resistant" rating. 'Remember: When paint and supplies become unusable, you pay twice — first for the product, then for the waste. Reducing or preventing waste will save you money! Choosing Equipment Use the most efficient painting practices and equipment you can. Make sure your time and supplies are used creating a finished product —not excess waste that must be cleaned up and disposed of Here are some ideas--- • Train employees an new equipment and refine skills regularly — talk to your vendor about their training programs. • Keep equipment in proper working order and review coating methods regularly. • Eliminate or reduce all sources of impurities. • Anvestigate using High - Volume Low - Pressure (HVLP) gravity-fed spray guns to reduce cleanup . and increase efficiency. • Consider avoiding the cost of extra equipment and worker exposure by sending paint stripping work to a specialized company. if you have leftover paint supplies, don't let them sit around until they are no longer usable! Instead — • Make arrangements with your vendors to return unopened supplies regularly, if possible. • Use similar and like - colored leftover paint as a primer and use it up! • Donate usable supplies to interested local technical colleges or high schools. • Explore materials exchange programs offered by organizations such as the Minnesota Technical Assistance Program (MnTAP) as an option. These may require significant quantities of common colors and materials. (MnTAP's phone number is on page 4.) Reducing Solvent Use Get the most out of your solvents! Using more than you need costs you money. Here are some ideas: If you clean spray - painting equipment manually, use two solvent baths to extend the solvent life. When the solvent in the first bath gets dirty, manage it as hazardous waste. Refill the first bath with the rinse solvent from the second bath, and refill the second bath with clean solvent If you clean spray - painting equipment mechanically, consider purchasing or leasing closed gun washing devices that use a minimal amount of solvent If you use large amounts of just one or two solvents, consider purchasing on -site distillation equipment to recover spent solvent. Note: Distillation recovers most of the solvent for reuse, but also produces a hazardous -waste sludge. The fire department, building inspector, and insurance carrier must approve the device. Classifying Wastes You must determine whether or not each waste is hazardous in order to determine how to classify it — either as hazardous or industrial solid waste. How a 2 Hazardous Waste Fact Sheet #4.39 August 1997 waste is classified dictates how it must be managed. ' Keep in mind: If, according to the MSDS the metal in the waste is above the maximum allowable concentration (MAC) listed in Table 1 or its flash point is below 140° F, it is hazardous and the hazardous waste requirements apply. If metal levels are below the MAC, the waste is an industrial solid waste and the industrial solid waste requirements apply. Ifyou cannot determine metal Ievels from the MSDS, contact the chemical company's technical- support division (the phone number is on the MSDS) or the supplier of this information. If you are still unable to determine the metal levels, you must have the waste tested by an environmental laboratory using the Toxicity Characteristic Leaching Procedure (TCLP). Related wastes, such as paint filters, that contain several kinds of paint will need to be tested to determine if they are hazardous. For a list of testing laboratories, request Hazardous Waste fact sheet #6.05, Hazardous Waste Consultants and Testing Laboratories. Hazardous Waste Requirements Hazardous waste must be stored on an impermeable surface and in a closed container marked with the words "Hazardous Waste," the date you begin filling the container, and- a clear description of the waste (example: Paint Thinner Waste). You must also inspect the container every week to make sure it is not-leaking and document the inspection. For complete storage requirements, see Hazardous Waste fact sheet # 1.04, Label and Store Hazardous Waste Correctly. If you generate 220 pounds (about 22 gallons of liquid) or less of hazardous waste per month, the Minnesota Pollution Control Agency (MPCA) considers you to be a very small quantity generator (VSQG). VSQGs may either transport hazardous waste themselves to a collection site licensed by the MPCA, or hire a licensed hazardous -waste transporter to take it to a licensed disposal facility. If transporting yourself, contact the collection program to arrange an appointment. The . program operator will help you package and transport your waste safely. Complete requirements for using a collection program are given on Hazardous Waste fact sheet # 2.5 1, VSQG Collection Program Requirements for Generators. If you intend to hire a transporter, refer to Hazardous Waste fact sheet # 1.06, Transport and Dispose of Hazardous Waste Correctly. Industrial Solid Waste Requirements If you have industrial solid wastes such as floor sweepings, tape, masks, strainers and filters, you need to arrange for transport of the wastes to a mixed - municipal or industrial landfill, or to a permitted municipal solid -waste incinerator. in order to be certain that the facilities will accept your industrial solid wastes, it is important to: contact the site operator where the hauler plans to bring the waste for information on what is and is not acceptable material at their site; store wastes separately in marked containers for the hauler; and keep records of TCLP tests and other determinations, where available. Air Permits If you use painting supplies containing VOCs, you may need a permit. Use your Material Safety Data Sheets (MSDS) to determine which painting supplies contain VOCs. If you need assistance, contact the company's technical support division (their phone number is on the MSDS) or the supplier. Calculate how many gallons of VOC- containing materials you used within the last 12 months. Less than 200 gallons of VOC- containing materials If you used less than 200 gallons of VOC- containing materials within the last 12 months, record the total monthly purchase (in gallons) of these items. Show that you use less than 200 gallondyear by keeping a running total for the last 12 months. If all other sources of air emissions are insignificant you do not need a permit. 3 4ROSEMOUNT PUBLIC WORKS MEMORANDUM DATE: August 21, 2013 TO: Eric Zweber, Senior Planner CC: Kim Lindquist, Community Development Director Andrew Brotzler, Director of Public Works /City Engineer Dan Schultz, Parks and Recreation Director Chris Watson, Public Works Coordinator Kathie Hanson, Planning & Personnel Secretary FROM: Phil Olson, Assistant City Engineer RE: SKB Landfill Expansion SUBMITTAL: Prepared by Conestoga — Rovers & Associates, the SKB Landfill Expansion dated March, 2013. Engineering review comments were generated from the following documents included in the submittal: • Stormwater Memo & Calculations (134 pages), received July 9, 2013 o Stormwater Memo & Calculations • Watershed Area Map • Offsite Drainage Areas Map • Summary of Site Soil Analysis • Modeling Results ■ 25 -Year Storm Summary Report ■ 100 -Years Storm Summary Report • Perimeter Ditch, Diversion Berms and Down Chute Calculations • Slope Stability Memo & Calculations • Grading Plan (Sheets CI -07, CI -24, CI -25, CI -26, CI -27, CI -28, CI -29) dated March 29, 2013 and received August 13, 2013 • IDF Curve Data (spreadsheet), Received August 8, 2013 • Channel X- Sections (spreadsheet), Received August 8, 2013 • Existing Drainage (model), Received August 8, 2013 • Proposed Drainage (model), Received August 8, 2013 GENERAL COMMENTS: 1. 140"' Street West is classified as an existing Collector roadway with a planned future functional classification as a Major Collector roadway, which requires a 100 -foot right -of- way corridor per the Transportation Plan Right -of -Way Guidelines. Landfill grading and ponding limits are required to accommodate the future 50- foot ' /z road right -of -way needs. 2. No ponding is allowed within the 50 -foot 1/z road right -of -way. A berm is required between ponding and the roadway ditch. The roadway ditch may be located at the 50 -foot right -of- way line. 3. An NPDES permit is the responsibility of the owner /contractor. Documentation of NPDES permit acquisition and a Storm Water Pollution Prevention Plan (SWPPP) defining the installation of silt fence and other erosion control Best Management Practices (BMP's) shall be forwarded to the City for review and approval prior to the start of grading activities. 4. All areas proposed to be naturally vegetated are required to be established by the property owner and maintained with a 5 year maintenance period. WETLAND COMMENTS: 5. The applicant is required to go through the permitting process and submit a sequencing and mitigation plan for wetland impacts. 6. Information is required to be provided that analyzes if there will be wetland impacts on the south side of 140th Street due to a change in subwatershed drainage. DESIGN MEMO COMMENTS: Additional clarification and revisions are needed for several of the items on page 4 of the CRA Design Memorandum. These items are listed below. • Design Outlet Elevations for Basins 1, 6A, & 6C (881.0, 873.0, & 870) are not consistent with elevations shown on Sheet CI -07 (876, 848, & 829) • It is not clear if a weir structure is proposed in Basin 6C. Table indicates Basin 6A indicates that the 100 -year maximum water surface is below the outlet control structure weir, but indicates a peak discharge of 5.3 cfs. These two items are inconsistent. STORMWATER MANAGEMENT COMMENTS: 8. Calculations for the NURP water quality volume are required to be submitted for the entire site, including the future recycling facility. 9. The stormwater model shows a 100 -year peak discharge of 5.3 cfs but it does not show the discharged volume. Both of these values are required to be equal to 0. 10. Infiltration is not allowed when establishing the 100 -year, 24 -hour storm event high water elevation. Infiltration rates of 3 inches /hour were used to define 100 -year, 24 -hour storm maximum water surface elevation. Additionally, stormwater pretreatment is required prior to discharge to an infiltration basin. See the Stormwater Management Plan for more details. 11. Outlet control structures are required to be installed in all basins to retain stormwater as designed in the model and maximize treatment potential of each basin. 12. High water elevations adjacent to 140`' Street are required to be a minimum of 2 feet below the roadway shoulder elevation at the low point in the road profile. 13. The stormwater model is required to be updated to define the normal water level /starting elevations at the designed outlet elevations and not at the pond bottom. 14. Additional infiltration testing data is required to verify that the rate control design is in conformance with City requirements. The infiltration testing should be completed during site grading and at the proposed grading plan elevations. If the tested site infiltration rates are not deemed adequate by the City, the property owner will be required to bring the site into conformance with City standards. 15. Ditches are required to be constructed with a minimum bottom width of 4 feet. Detail 35 and Detail 36 on Sheet CI -27 are required to be updated. 16. The proposed outlet from Basin 6A is a 12 -inch pipe which does not meet City standards. The minimum pipe diameter is 15- inches. GRADING PLAN COMMENTS: 17. An existing conditions plan including existing contours and drainage areas with contributing runoff is required to be provided for review. 18. The emergency overflow routes and elevations along with the NWI, and HWL should be shown on the final grades sheet. 19. Grading plans should include all roads and land adjacent to the property (200 feet minimum) to demonstrate that all ponding areas and outlet control structures are clear of the City's right -of -way and ditches. 20. The installation of erosion control BMPs were not indication on the plan. It is assumed that the installation of silt fence and other BMPs will be shown on the SWPPP. 21. The south and west ends of the cap as proposed on the grading plan appear to be well in excess of the City engineering guidance standard of 4:1 slopes for the ponds they drain into. 22. Down chute energy dissipation pads were not clearly defined. Provide a detail how energy dissipation pad will prevent erosion from water traveling in excess of 14 fps down the landfill cap. 23. The inverts of the 24 -inch culvert between Basin 3 and Basin 4 should be relabeled to reflect correct cardinal direction of inverts. (Sheet CI -07) 24. The overflow weir invert in the outlet control structure of Pond 6A is listed as 829.50. This elevation should be verified since it is inconsistent with the other areas of the plan. (Sheet CI -07) 25. The stormwater overflow structure Detail 30 on Sheet CI -07 shows a 12 -inch HDPE pipe bypassing below the overflow weir. Provide additional information on how the outlet control structure will function. (Sheet CI -26) Should you have any questions or comments regarding the items listed above, please contact me at 651 - 322 -2015.