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5.a. Request by SKB Enivornmental, Inc. to Renew an Interim Use Permit for Operation of the MN Industrial Containment Facility
EXECUTIVE SUMMARY Planning Commission Meeting Date: October 23, 2018 Tentative City Council Meeting Date: November 5, 2018 AGENDA ITEM: Case 18-30-IUP; Request by SKB Environmental, Inc. to Renew an Interim Use Permit for Operation of the Minnesota Industrial Containment Facility AGENDA SECTION: Public Hearing PREPARED BY: Kyle Klatt, Senior Planner AGENDA NO. 5.a. ATTACHMENTS: Location Map; Draft Interim Use Permit (Revised for 2018); Application Narrative; Aerial Photograph; Existing Conditions Map; Interim Use Permit Agreement (2013); Development Commitment; Dakota County Solid Waste License; MPCA Permit; Technical Memo – Conversion of C&D Waste to Industrial Waste Space; Conversion Area Drawings; Liner Details; WCA Extension Decision; March 2013 Renewal Drawings; City Engineer’s Memorandum APPROVED BY: KL RECOMMENDED ACTION: Motion to Recommend that the City Council Approve the Renewal of the Interim Use Permit for SKB Environmental, Inc. for an Additional Five Years, subject to the following Conditions: 1. Update storm water modeling to incorporate the requirements from the WSB the Technical Memorandum dated May 19, 2016 concerning the use of Atlas 14 precipitation data for storm water modeling. 2. Stormwater Basins 6A, 6B, 6C and associated grading shall be removed from within 50 feet of the 140th Street East centerline in conjunction with the updated storm water modeling. 3. 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. 4. Submit route maps of truck circulation within the facility and off-site, with the potential to require further information concerning traffic counts and updated route maps when deemed necessary in the future. 5. Implement sediment control best management practices to reduce sediment tracking and dust on and off-site. 6. Approval of the transfer facility and composting operation will be repealed from IUP if operations not commenced prior to termination of five-year renewal in 2023. 2 7. Compliance with all other requirements of the City Engineer’s review memorandum dated October 23, 2018. ISSUE The Planning Commission is being asked to consider a request from SKB Environmental, Inc. to renew its Interim Use Permit (IUP) for a non-hazardous industrial waste containment facility (landfill) at 13425 Courthouse Boulevard for an additional five years. The permit was last reviewed by Rosemount in 2013, at which time the City approved an expansion of the facility both in terms of land area and total disposal volume. The current renewal request does not include any modifications to the previously approved plans except for a minor reconfiguration of the distribution between construction and demolition waste and industrial waste between two of the existing cells. The applicant is not requesting an expansion of any of the existing operational parameters for the site at this time. Please note that prior City IUP reviews coincided with the timing of the facility’s required Minnesota Pollution Control Agency (MPCA) permit (every five years). With its last approval in 2013, the MPCA granted the SKB landfill a permit that is valid for 10 years. The 2013 MPCA permit therefore continues to serve as the primary regulatory instrument for the site, and all terms and conditions of this permit will apply separate from the City’s permitting authority. Staff is recommending that the City continue to review the permit every five years, which means that the next renewal in 2023 would happen concurrently with the MPCA permit renewal. There is substantially more information required for the MPCA permit; the City’s current review will focus primarily on any changes or issues that have occurred since the last review. Dakota County also permits the facility and their permit process is on a two-year cycle. 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 140th 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 for an 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 separate compostable material and process that material with yard waste into compost. 3 In early 2013, SKB requested and was approved to deposit low level industrial waste in their construction& demolition debris landfill cell. As part of SKB’s 2013 IUP renewal, the City approved an increase the disposal capacity by 8,475,814 cubic yards (32% increase) to a total capacity of 35,349,917 cubic yards. The expansion also increased 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 the applicant bought the site in 2000. In 2014, SKB requested and was approved to modify the previously approved IUP plans for a non-ferrous metal recycling facility to allow for a 4,200 square foot outdoor concrete waste depositing pad in addition to the 14,976 square foot recycling building. In 2018, the City approved a subdivision and Planned Unit Development final site development plan for 52 acres immediately east of the landfill site for three metals recycling buildings and a maintenance shop. Although this development is separate from and does not alter the approved landfill IUP in any manner, access to the metals recycling buildings and maintenance shop will occur from the landfill property. In addition, SKB proposed as part of the PUD development that trucks emptying loads at the landfill would obtain fill material from the property to the east prior to departing from the landfill. Surrounding Land Uses: North: General Industrial (Spectro Alloys and Endres) East: Future Metals Recycling and Maintenance Shop (grading and excavation of site to commence later this year) South: Agriculture West: Public/Institutional (Rosemount Wastewater Treatment Plant) and Agriculture Planned Land Uses: North: General Industrial East: General Undustrial South: Light Industrial West: Public/Institutional and General Industrial Existing Zoning District: WM: Waste Management Site Area: 236 Acres Approved Disposal Area: 151 Acres Proposed Disposal Area: 167.1 Acres Approved Disposal Capacity: 35,349,917 Cubic Yards Proposed Disposal Capacity: No Changes Approved Height: 1060 foot elevation (230 feet, measured from 140th Street East) Proposed Height: No Changes SUMMARY Landfill Configuration The SKB landfill facility 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 was expanded by 16 acres as part of the 2013 approval. SKB proposed a different liner construction for Cell 6 from the double-liner constructed in Cells 1,2, and 3 in 2013; this proposal was ultimately approved by the CPA and Dakota County after approval of the interim use permit renewal that year. The approved design will offer similar or more protection than the existing double-liner design. 4 Cell 3 contains a sub-cell (Cell 3M) that contains industrial waste containing PFCs from the 3M landfill clean up from Washington County. Each cell has its own liner and leachate collection system. 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 operations of Cell 4 are similar to Cells 1, 2, and 3 other than 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. In early 2013, SKB received approval from the City and Dakota County to deposit industrial waste in Cell 5 that is no more than 25% of the soil reference value (SRV). The SRV is the value by which the material is considered hazardous. 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 proposed one change to their vertical configuration in 2013 that was not approved until recently. Specifically, the area between Cell 3 and Cell 5 (referred to as a “saddle”) was approved in 2008 to accept C&D waste. As part of its 2013 permit, SKB proposed to draw an imaginary vertical line between Cells 3 and 5 and place industrial waste 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 was the 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. The City and Dakota County expressed concern about this design and some of the assumptions that went into the proposal; however, the MPCA reviewed the modification and determined that the proposed design changes will not create an increased risk to the environment and approved the minor modification to the permit in August of this year. The modification does not alter the overall permitted capacity of the landfill, and only revises the overall mixture of different waste types in the facility with more industrial waste and less construction and demolition waste. 2013 Permit Modifications The 2013 IUP permit renewal included several modifications to the permit that were ultimately approved by the City and incorporated into the IUP agreement with SKB Environmental. A brief summary of the previous permit changes are as follows: Horizontal Expansion and Wetland Filling. SKB Environmental received approval in 2013 to develop an additional 39 acres in the southwest corner of its landfill property to expand the area to store industrial waste (Cell 6). In order to accomplish this expansion, SKB will need to relocate existing power lines and a gas pipeline, and will need to fill the two remaining wetlands in this part of the site. There are also a number of trees that will be removed to accommodate the expansion; however, the removal of these trees was addressed in the applicant’s 2008 permit, which included a tree removal (and replacement) plan. Originally there were three wetlands within the Cell 6 expansion area, one of which has already been filled as part of the 2008 permit. The other two wetlands were discussed as part of the 2013 permit. 5 In 2013 SKB Environmental submitted an application under Wetland Conservation Act (WCA) rules to replace the wetlands, and the State technical evaluation panel (TEP) recommended approval of a wetland mitigation plan allowing for off-site replacement of the wetlands. At the time, City staff was more interested in providing a wetland replacement site near the landfill within the community. After performing the required search for a wetland replacement site within the City of Rosemount and failing to find a site that was suitable, SKB was permitted to purchase wetland credits from outside the City to meet its replacement requirements. It is staffs understanding that the payment has been made although the wetland has not been filled. The WCA approval has been renewed earlier this year, consistent with the 2013 approval. SKB has not yet commenced with the approved expansion of the landfill for Cell 6, and has done some limited gravel extraction in anticipation of using the area for industrial waste in the near future. Wetland Mitigation. In order to mitigate the loss of 9.49 acres of wetlands within the southwest expansion area, SKB proposed purchasing 18.98 acres of existing wetland credits from the State’s wetland credit bank. Both City staff and the TEP supported this plan, which was ultimately approved by the City Council as part of the previous IUP renewal. The original WCA permit approval for filling wetlands was valid for 5 years (until November of this year), however, the applicant has not yet commenced work to fill wetlands and has subsequently requested an extension from this deadline. The extension request was approved by the TEP, and the wetland permit is now valid through November 19, 2021. The applicant has secured their wetland banking credit withdrawal, and has stated that they intend to fill the wetlands in 2019. Vertical Expansion. The 2013 permit renewal authorized an increase in the overall size and capacity of the landfill, and specifically an expansion of the finished elevation to 1,060 feet (an increase of 50 feet from the 2008 permit). The approved landfill height will result in a berm 230 feet higher than 140th 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 overall plan creates a ridge 230 feet tall along 140th Street East that slopes over the entire landfill to the north. Grading/Future 140th Street. The previous IUP renewal permitted storm water ponding within a portion of the 140th Street right-of-way. This street is designated as a future collector road in the City’s transportation plan, which will require a 100 foot right-of-way to accommodate the needed street width. SKB Environmental has previously provided an easement to the City to expand its side of the 140th Street right-of-way from 33 feet to 50 feet (one half of the needed right-of-way). Under the current IUP agreement, SKB may use this additional easement area for storm water ponding provided they apply for a right-of-way permit from the City in advance of using the right-of-way in this manner. In order for the City to use the right-of-way to expand the road in the future, it must provide SKB with six months’ notice stating this intent. At this point, SKB must then either accommodate the required ponding on site or make a payment to the City for off-site ponding in a regional retention basin. To date, SKB Environmental has not started work in this area, and the pond has therefore not been needed to manage storm water runoff. Staff does not support the continuation of this provision in the IUP agreement, and is recommending changes as noted in the following section. 6 Environmental Assessment Worksheet (EAW). A voluntary EAW was completed by SKB in 2013, with the City acting as the responsible government unit for the review, in advance of the previous renewal/expansion request. The City received several comments during the review, most of which were ultimately addressed through the Dakota County and Minnesota Pollution Control Agency permit process. No major environmental issues were identified through the EAW and the City did not order an Environmental Impact Statement for further environmental review. The 2013 EAW is still valid since the current proposal includes no expansion or other changes from the information submitted at time. Other Permit Elements – Approved/Not Yet Implemented The 2013 IUP includes other uses that were approved at an earlier date but had not yet been implemented as part of the landfill operation and are still not in operation today. There activities include the following: Recycling/Transfer Facility. During the 2003 expansion, SKB had received approval within the IUP to construct a recycling/transfer facility on the site. A building housing the recycling facility has since been constructed, but the transfer operation still does not exist today. SKB has requested that the transfer facility approval remain in the 2013 IUP, and within the current 2018 renewal. With its review of the last IUP submittal, staff identified several additional conditions that were required of the transfer facility due to the nature of the waste products that could be processed by the facility. 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 included 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. The Council has historically indicated they did not support MSW being landfilled at the site. To address the any potential vermin attraction, staff placed two additional conditions within the IUP. First, any MSW brought to the facility must 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. The other major issue discussed with the 2013 permit focused on the materials that were to be used in the recycling and transfer structure. The approved permit requires 40% of the building to be constructed of masonry, which was the threshold used to review the permit for the recycling building constructed in 2014. Any future expansion of the recycling building to add space for a transfer facility will need to adhere to the existing permit condition. 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. This approval was also included in the 2013 IUP. To date, SKB has not begun composting but is requesting the ability to compost source separated compostable material within the 2018-2023 IUP. Due to some modifications proposed in the prior permit, the City added conditions concerning the used of petroleum contaminated soil (to not allow) and specifying that the sewage sludge used in the compost cannot exceed EPA levels for PFC’s. Staff is also recommended that a vermin control plan be required for the composting site the same as is recommended at the transfer facility. These conditions are carried forward in the 2018 permit update 7 and 2018 IUP agreement. SKB has not provided an update concerning the transfer facility and composting operations with the current renewal request. Staff has confirmed that they are still interested in incorporating the uses into the landfill at some point in the future, but have no immediate plans commence with these activities. 2018 Permit Renewal The application materials submitted by SKB Environmental for the 2018 IUP renewal includes a technical memorandum with detailed information concerning the current status of the facility, including the size, existing status, and remaining capacity for each of the cells within the landfill. The memorandum also includes an update concerning some of the previously permitted uses (recycling building) and the required monitoring that occurs on an ongoing basis. SKB has received its Dakota County facility license, now valid through December of 2019, and is operating under an approved MPCA permit that will expire in the year 2023. Staff did discuss the City’s pending IUP renewal with representatives of the Dakota County Solid Waste Division prior to the Planning Commission meeting, and their staff did not identify any areas of concern with the operations. The permits for all three permitting agencies (State PCA, County, and City) include provisions for dealing with any issues that may arise during the permit timeframe. In addition to the materials submitted for the IUP renewal by the applicant, staff has attached some of the plans incorporated into the 2013 permit for consideration by the Planning Commission. The applicant is not seeking any revisions to these previous plans, and all work performed in the last five years adheres to the final elevations documented on these plans. One minor modification that has been approved by the PCA and Dakota County, as noted earlier in this report, is the reconfiguration of the waste materials to be buried between cells three and five. Since this reconfiguration does not alter the approved final grades in any manner, it does not require any modification to the previous permit. The revised permit includes a reference to this change. Staff Review and Analysis Because the interim use renewal does not include any expansions or modifications to the existing SKB Environmental landfill permit, staff is focusing its review on some of the general operational and permitting issues associated with the landfill. In addition to these general issues, Staff is concerned about the continued inclusion of activities in the permit that have not yet commenced and that have no specific time frame for starting. These activities include the transfer facility permitted in 2003 and the composting approved in 2012. At the end of the current renewal period, these two activities will have been part of the IUP for 20 and 11 years respectfully, which is an extremely long time for an approval that has not been implemented. For example, other planning approvals, such as site plan approval or conditional use permits the approved use must be established within one year or the permit is null and void. From a City policy standpoint, there are numerous changes that have occurred over the last 11 or 20 years; the market for recycling and composting have changed substantially, City plans and ordinances have undergone major revisions, and the personnel involved in the original reviews are different. Staff is suggesting that if the applicant does want to conduct these activities on site, they should make use of the permit within the next 5 years or they can come before the Council in the future to again ask for the use and modify the permit. In order to give the applicant advance notice concerning the permitting for the transfer facility and composting operation, staff is not recommending any changes to the permit for 2018, but will no longer recommend the inclusion of these activities in the IUP if they are not in place by the next renewal in 2023. The IUP agreement includes a note concerning the potential removal of these items. 8 Other general comments from staff concerning specific aspects of the IUP or landfill facility include the following: • Storm Water Plans. The City Engineer has noted that the City’s storm water requirements have been updated since the IUP was last renewed in 2013. While recognizing that the applicant is not proposing any modifications to the site as part of its renewal, the City’s requirements concerning storm water modeling have changed and could impact pond design in the future. In order to address these changes, the City Engineer is asking that SKB update its storm water modeling to incorporate current requirements for such modeling. Storm Water Ponding and 140th Street. As noted earlier in this report, the interim use permit includes a provision that the applicant is allowed to retain storm water on a portion of the 140th Street right-of-way until such time that the City needs the right-of-way and easement area for expansion of this road. Staff is concerned that the current provision in the agreement regarding 140th Street will create significant issues when the City is ready to improve 140th Street in the future. It is an opportune time for SKB to review the long term stormwater plans since the City Engineer is recommending they update the plan using the new standards. At the same time, SKB should lay out a plan for meeting city standards that addresses stormwater standards wholly on site. This means that when the applicant submits an updated storm water plan to comply with current modeling requirements, they must also update the plans to depict the long-term solution for storm water ponding in the southwest part of the site without utilizing existing or future City right-of- way. If off-site/regional storm water retention is used, the applicant will not be required to pay the applicable fees until such time that the ponding is required. The applicant is several years away from needing additional area for storm water ponding in this part of the site. • Truck Traffic and Access. Staff has conducted recent traffic counts in the area and also made visual observations that indicate there are a larger number of trucks using the southern access to exit the site than in previous years. There is very little information concerning the circulation of trucks on the site in the application materials other than a general estimation of 1,000 trucks per day. Staff is requesting that the applicant submit route maps of truck circulation within the facility and off-site, with the potential to require further information concerning traffic counts and updated route maps when deemed necessary in the future. The current and proposed IUP agreement gives the City fairly broad discretion to “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 requirements apply” (Condition #29). The requested information is a first step prior to investigating any additional requirements concerning truck movements and routing in and out of the site. • Dust and Sediment Control. Over the past two years the City has received some complaints from nearby property owners concerning dust from the landfill site and the trucks entering and exiting the facility. Staff has also observed conditions when dirt has been tracked onto both 140th Street and State Highway 55 leading to the buildup of addition sediments on public roadways that can become airborne in normal conditions. The applicant does have a sweeper, water truck, and other equipment used to keep dust and airborne particles down; however, staff is recommending that the applicant work with the City to further implement sediment control best management 9 practices to reduce sediment tracking and dust on and off-site. The City Engineer also notes that the applicant must obtain approval from MnDOT prior to conducting street sweeping operations on TH55. RECOMMENDATION Staff recommends that the Planning Commission recommend renewal of the SKB Environmental Landfill Interim Use Permit for an additional five years with the conditions provided in the motion. Dakota County, MN Property Information Octo ber 8 , 2018 0 1,750 3,500875 ft 0 525 1,050262.5 m 1:19,200 Disclaimer: Map and parcel data are believed to be accurate, but accuracy is not guaranteed. This is not a legal document and should not be substituted for a title search,appraisal, survey, or for zoning verification. INTERIM USE PERMIT AGREEMENT REISSUANCE to SKB, INC. MINNESOTA INDUSTRIAL CONTAINMENT FACILITY THIS AGREEMENT, is made this ______ day of __________, 2013 2018 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. 383 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 2 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, metals recycling facility and on-site stormwater retention areas. The general site plan is illustrated on attached Exhibit C. 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 MICF. 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. 3 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 November 19, 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. 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 revegetated 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 of 2008 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 4 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. 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. 5 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. 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. B. Composting Operation. Composting shall be subject to the following: 1) Petroleum Contaminated Soil shall not be used in the composting operation. 2) Sewage Sludge used in the composting shall not exceed the Minnesota Pollution Control Agency and Environmental Protection Agency Region 5 Residential Soil Reference Values (SRVs) for perfluorocarbons (PFCs). 3) The composting operation will not be included in any subsequent IUP renewal if SKB fails to establish said operation by the expiration date of the current 2018is agreement. CD. 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. 15. Recycling/ Transfer Facility. SKB shall operate and maintain the Recycling/Transfer Facility in accordance with Section 14, Tab 4, 2013 MICF Permit 6 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. Prior to acceptance of any compostable materials A 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. The Plan may be amended from time to time subject to approval by the City Staff. C. The recycling and transfer facility shall be constructed of a minimum of 40% masonry for each side of the facility. C.D. The transfer facility will not be included in any subsequent IUP renewal if SKB fails to establish said facility and use by the expiration date of the current 2018 is agreement. 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 November 19, 2013. 17. Construction Plans. The construction plans shall be modified as directed in the Assistant City Engineer’s Memorandum Memoranda dated November 12, 2013 and October 23, 2018. SKB shall update its storm water management plan and storm water modeling to incorporate the requirements from the WSB the Technical Memorandum dated May 19, 2016 concerning the use of Atlas 14 precipitation data for storm water modeling 18. 140th Right of Way. In recognition of the 2013 expansion, SKB will dedicate to the City a 50’ easement from the existing centerline of 140th for public road and utility purposes. Stormwater Basins 6A, 6B, 6C and associated grading shall be removed from within 50 feet of the 140th Street East centerline in conjunction with the updated storm water modeling. All development stormwater will be brought into compliance with existing regulations and addressed on site or the applicant shall pay the fee at the time of construction of off site ponding. Until such time as the road is upgraded and expanded, SKB will be permitted to pond within the right of way as depicted on Plan Sheet CI-25 dated 10/16/2013. A right of way permit, which allows the approved stormwater encroachment until the easement is needed for road purposes with be authorized by the City. Upon determining the easement is needed for public infrastructure, the 7 City will give SKB six (6) months notice to vacate stormwater ponding activity within the road and utility easement. Upon notice, SKB will be required to provide stormwater ponding on-site or make payment in lieu of ponding for off-site ponding to meet the current stormwater ponding requirements for the SKB development. 19. 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". 20. 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. 21. 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. 22. 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 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 8 Administrator. 23. Monitoring/Reporting. SKB shall monitor MICF in accordance with MPCA Permit. Nothing shall be construed to prevent SKB from exceeding MPCA Permit requirements. 24. 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. 25. 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. 26. 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. 27. Development Commitment. The provisions of the Development Commitment, approved by the City Council on November 19, 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 15 years from the date of this Agreement, unless there are material differences in the operation at the landfill that negatively affects the municipal revenues as contemplated in this agreement. 28. 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. 9 Notwithstanding any provision of Section 2 of this Agreement, the City will not require any amendment of the Development Commitment for 15 years from the date of this Agreement, , unless there are material differences in the operation at the landfill that negatively affects the municipal revenues as contemplated in this agreement. 29. 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 requirements apply. A. SKB shall submit route maps of truck circulation within the facility and off-site, with the potential to require further information concerning traffic counts and updated route maps when deemed necessary by the City in the future. 30. 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. 31. Other Laws and regulations. SKB agrees to comply with all other laws, regulation, permits, or licenses that apply to MICF. 32. 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. 33. 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 10 agree in writing to extend the ten-day period. 34. 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; (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, 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 11 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, 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 12 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. 35. 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. 36. 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. 37. 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. 38. 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. 39. 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. 40. Recording. This Agreement shall run with the subject land and may be recorded in the Dakota County Recorder's Office. SKB ENVIRONMENTAL, INC. 13 By: ___________________________ Its: ___________________________ Andby: ___________________________ Its: ___________________________ STATE OF MINNESOTA ) ) ss. COUNTY OF _______ ) The foregoing instrument was acknowledged before me this ____ day of __________, 20132018, by _________________ and ______________, the _____________ and ___________________, respectively, of SKB Environmental, Inc., a Minnesota corporation, on behalf of the corporation. ______________________________ Notary Public CITY OF ROSEMOUNT By: __________________________ Its: Mayor And by: ______________________ Its: Clerk STATE OF MINNESOTA ) ) ss. COUNTY OF DAKOTA ) The foregoing instrument was acknowledged before me this ____ day of __________, 20132018, by William Droste and Erin FasbenderAmy Domeier, the Mayor and Clerk, respectively, of the City of Rosemount, a Minnesota municipal corporation, on behalf of the corporation. ______________________________ Notary Public Technical Memo Wenck | Colorado | Georgia | Minnesota | North Dakota | Wyoming Toll Free 800-472-2232 Web wenck.com To: City of Rosemount Date: May 14, 2018 Subject: Interim Use Permit Reapplication for the SKB Rosemount Industrial Waste Landfill SKB Environmental, Inc. (SKB) respectfully submits to the City of Rosemount (City) this Project Description as part of a renewal application for an Interim Use Permit (IUP) for the SKB Rosemount Industrial Waste Landfill. The landfill is located at 13425 Courthouse Boulevard within sections 19, 20, and 29, Township 115N, Range 18W, Dakota County, Minnesota. The total property for the landfill facility is approximately 237 acres (see Figures 1 and 2). The landfill is located within an area of the City that is classified as a “Waste Management Area” on the City’s 2017 zoning map. The City’s zoning code for the Waste Management District state that this district is intended to accommodate waste management, disposal, and recycling operations and that uses within this district shall be permitted by an Interim Use Permit. The landfill has been in operation since 1992 and was purchased in 2000 by SKB who has been operating the facility since that time. An initial IUP was issued by the City for the landfill when the facility opened in 1992, and SKB assumed the obligations of the IUP at the time it began operating the facility in 2000. The landfill has an existing IUP from the City of Rosemount that was renewed by the City on November 19th, 2013 (see Attachment 1). The landfill operates under Minnesota Pollution Control Agency (MPCA) solid waste permit number SW-383 (available upon request). The MPCA reissued SW-383 for the landfill in 2014 with a ten-year term until 2024. The landfill also operates under a solid waste facility license (see Attachment 2) and a Gem-Ash processing license (see Attachment 3), both issued by Dakota County and valid through 2019. This submittal serves as the reapplication for the existing IUP for the landfill to allow for the continued solid waste disposal and recycling operations of the Rosemount Industrial Waste Landfill. As directed by the City and through written and verbal correspondence, this memo provides summary updates of the ongoing activities at the Rosemount Industrial Landfill including facility operations, waste disposal areas, proposed permit modifications, wetland mitigation status, leachate collection, and landfill gas monitoring. SKB will continue to operate the Rosemount Industrial Waste Landfill under the terms of MPCA solid waste permit SW-383, the IUP permit from the City, and the additional requirements from the City and Dakota County. Landfill Operations Hours of operation of the facility are authorized as 6:00 AM through 8:00 PM, Monday through Saturday under terms of the existing IUP. The hours of operation for the facility can be amended by City Council to accommodate special projects at the landfill. SKB is not currently proposing changes to the hours of operations listed in the IUP. Facility Summary There are multiple disposal areas at the Rosemount Industrial Waste Landfill that receive separate waste streams. The disposal areas include demolition debris disposal, industrial waste disposal, and municipal solid waste combustor ash disposal. The landfill facility also City of Rosemount Interim Use Permit Reapplication for the SKB Rosemount Industrial Waste Landfill May 14, 2018 2 includes a solid waste recycling area. Additionally, the facility is permitted to include a solid waste transfer station and a solid waste composting facility, however neither item is currently operated at the landfill. If the transfer station were to be implemented and become operational at the landfill it would take place within the existing metal recycling building. The only facility currently permitted that is not constructed and that would need to be added to the landfill to become operational is the solid waste composting operation. The landfill does not include municipal solid waste (MSW) disposal areas. The solid waste disposal cells can be seen on Figure 3. Each solid waste disposal area has an allowable list of acceptable waste types that can be placed within the cells, specific to the demolition, industrial, and municipal solid waste combustor ash disposal. Acceptable wastes are defined and managed under the terms of the solid waste plans that are attached to the permit SW- 383. Unacceptable wastes are rejected by the facility and waste haulers are required to take them offsite to an acceptable disposal facility. Solid waste is transported to the facility via trucks which enter the facility at the main site access from Courthouse Boulevard (State Highway 55), where they access one of the scales at the facility before proceeding to the appropriate waste disposal area (see Figure 3). The landfill receives approximately 1,000 trucks per day delivering waste to the facility. SKB is not proposing changes to the site access points, or solid waste transport methods from the existing conditions under which the landfill has been operating. The IUP identifies terms and conditions for construction and operations Rosemount Industrial Waste Landfill. SKB will continue to operate the landfill following the requirements of the IUP including areas related to: Landfill Design and Specifications; Quality Control and Assurance; Construction Permits; Sanitary Sewer Connection; Construction Certification; Soil Protective Cover; Operation and Maintenance; and Waste Acceptance. Waste Disposal Areas There are seven disposal cells that comprise the Rosemount Industrial Waste Landfill. The surface area and the waste disposal volume capacity of the disposal cells are as follows: Cell 1 (Industrial Waste) covers 5.1 acres with a capacity of 341,454 yrds3 Cell 2 (Industrial Waste) covers 17.1 acres with a capacity of 1,458,507 yrds3 Cell 3 (Industrial Waste) covers 39.4 acres with a capacity of 10,592,188 yrds3 Cell 3M has a capacity of 158,300 yrds3 Cell 4 (Combustor Ash) covers 12.5 acres and 2,648,950 yrds3 Cell 5 (Demolition Waste) covers 41.2 acres with a capacity of 7,490,591 yrds3 Cell 6 (Industrial Waste) covers 51.8 acres with a capacity of 12,659,927 yrds3 Each disposal area is permitted for a total disposal capacity based on waste type. Cell 1 has been closed including the final cover and will not receive additional waste. Additionally, the Cell 3M disposal area is also closed. Based on the 2017 Annual Report for the landfill submitted to the MPCA the waste disposal areas are summarized in Table 1. The disposal volumes in Table 1 reflect the remaining waste disposal capacities based on the current version of SW-383 issued in 2014 for the landfill. Based on the recent annual fill volumes for each disposal area and the remaining permitted capacities for each area, SKB estimates that the remaining years of operations for the waste disposal areas are as follows: Demolition: 5.6 Years (averaging 650,000 yards per year) Industrial: 18.15 Years (averaging 539,000 yards per year) City of Rosemount Interim Use Permit Reapplication for the SKB Rosemount Industrial Waste Landfill May 14, 2018 3 MSW Combustor Ash: 32.75 Years (averaging 51,200 yards per year) Table 1: Remaining Permitted Capacity of Waste Disposal Areas for the Rosemount Industrial Waste Landfill reported in cubic yards Waste Disposal Area Permitted Capacity including Final Cover) Remaining Permitted Capacity including Final Cover)1 Demolition 9,060,322 3,622,281 Industrial 23,482,345 9,793,757 MSW Combustor Ash 2,648,950 1,678,110 1: Remaining permitted capacities will be updated to reflect additional industrial waste disposal volume and corresponding reduction in demolition waste disposal volume based on the requested solid waste permit described below. Annual surveys of the disposal capacity consumed and the disposal capacity remaining are conducted each year in approximately November as part of the annual reporting required under solid waste permit SW-383. These annual surveys are used to update the remaining operational life of the landfill disposal areas. Proposed Permit Modification In 2016, SKB submitted a modification application to the MPCA, Dakota County, and City of Rosemount to allow for redesign of a “wedge” of airspace between the industrial and demolition disposal to create a new industrial disposal cell. The modification requested the conversion of this wedge area from demolition disposal capacity over to industrial disposal capacity (see Attachment 3). This would increase the total disposal capacity of the industrial areas by 2,955,523 cubic yards, and a result in a corresponding reduction in the demolition disposal capacity. The MPCA is in the process of reviewing this application and approval of the waste conversion for this disposal area is pending final agency review. If the pending application is approved, SKB will adjust the remaining volumes and operational life of the two disposal areas accordingly to reflect the new approved permit conditions. Cell Construction and Wetland Impacts The July 2014 renewal of MPCA solid waste permit SW-383 included an approval for the construction of an expanded Cell 6. Environmental review evaluating the potential impacts of the landfill expansion and construction of Cell 6 was completed by the City who issued a negative declaration regarding the need for an Environmental Impact Statement (EIS) in November 2013. The landfill expansion and construction of Cell 6 authorized impacts, including filling, of up to 9.19 acres of wetlands on the facility property. A wetland permit and approved wetland replacement plan for the wetland impacts was issued to SKB in November 2013. The replacement plan includes the purchasing of 18.28 acres of wetland credits from approved mitigation banks. SKB has not yet completed the construction of the Cell 6 that would result in the impacts to the wetlands. The impacts to the wetlands were delayed from the originally proposed schedule however the wetland mitigation to offset the wetland impacts has already been completed. The wetland permit issued in November 2013 carried a five-year term and was set to expire in November 2018. It is currently estimated that the construction of the portions of Cell 6 that will result in wetland impacts will take place in 2019. SKB recently City of Rosemount Interim Use Permit Reapplication for the SKB Rosemount Industrial Waste Landfill May 14, 2018 4 submitted a request for an extension of the wetland permit. A three-year extension to the wetland permit, through November 2021, was granted to SKB in March 2018. The permit extension approval is provided as Attachment 5. The approved mitigation plan still includes the purchased of approved wetland bank credits to provide compensation for wetland impacts that would result from the construction of Cell 6. Recycling There a several recycling activities that are conducted at the Rosemount Industrial Waste Landfill. One recycling activity is the separation and recovery of ferrous and nonferrous metals from construction and demolition waste as well as from the municipal solid waste combustor ash. An additional recycling activity at the landfill includes the separation and recovery of clean wood and concrete from construction and demolition waste. The process of recovering these recyclable materials from the construction and demolition waste takes place within the disposal cell. SKB has also implemented a recycling operation that entails mining metals from the municipal solid waste combustor ash cells to recover these metals for recycling. All of the recycling of the metal materials recovered from the mining of the ash takes place within the metals recycling building. This operation began in 2015. The existing solid waste permit SW-383 includes approvals for the landfill to conduct composting activities as well as operate a solid waste transfer station. These two activities are not currently included in operations at the landfill, however if either of these operations are initiated at the landfill in the future they have the potential to increase the separation, recovery and recycling activities at the landfill. SKB intends to continue the current recycling activities at the landfill and explore opportunities for additional recycling efforts that are economically feasible. Leachate Management The Rosemount Industrial Waste Landfill includes a leachate collection and management system. Leachate is wastewater that is generated at a landfill that has percolated through the solid waste and now has extracted, dissolved, or suspended materials within it. Leachate at the landfill percolates down through the waste until it reaches the liner, where it is then directed to sumps. The sumps flow to the header pipes of the leachate collection system. The leachate flows through the pipes to a centralized leachate storage tank. The leachate collected at the tank is transported via a direct gravity line to the Metropolitan Council Environmental Services (MCES) Empire Wastewater Plant. Stormwater that comes in contact with the waste is treated as leachate, while stormwater that falls outside the active waste disposal areas is directed into the stormwater management system at the landfill. Leachate is collected separately from the demolition, industrial, and ash disposal areas, however all leachate is directed to the central storage tank and from there sent to the MCES Empire Plant. The landfill operators work to keep the active face of the disposal area as small as possible to minimize the amount of rainfall that comes into contact with the waste and becomes leachate. Monitoring and analytical testing of the leachate is conducted as required under the terms of the solid waste permit SW-383. Leachate monitoring was completed at two locations in 2017. The leachate results in 2017 were consistent with prior years of testing, where there were limited detection at low levels of metals analyzed as well as detected organic compounds including acetone and tetrahydrofuran. SKB will continue operation of the leachate collection and management system for the landfill as well continue the monitoring of leachate for the landfill as required under terms of the solid waste permit SW-383. City of Rosemount Interim Use Permit Reapplication for the SKB Rosemount Industrial Waste Landfill May 14, 2018 5 Groundwater Monitoring There is a groundwater monitoring network in place at the Rosemount Industrial Waste Landfill. The groundwater flow in the area of the landfill is to the northeast towards the Mississippi River. There are 28 monitoring wells and five piezometers where groundwater is monitored around the landfill including shallow aquifer and deep aquifer groundwater wells. There are also wells located both upgradient and downgradient of the waste disposal areas. The upgradient wells are used as a control to establish background groundwater conditions that are not potentially influenced by the landfill. The groundwater monitoring event in 2017 was conducted in October. A total of 90 different analytical parameters are tested from the groundwater samples including nutrients, metals, and organic compounds. In 2017, none of the detected parameters in the groundwater samples were above the MPCA defined intervention limits for groundwater concentrations. SKB will continue groundwater monitoring for the landfill as required under terms of the solid waste permit SW-383. Landfill Gas Monitoring As waste within a landfill decomposes it generates gas. The amount and types of gas generated at a landfill is dependent on the specific waste types. There is a landfill gas monitoring network at the landfill that consists of 16 monitoring points. Four of the points are located within the waste disposal cells and the remaining points are located along the perimeter of the landfill site. Landfill gas monitoring is conducted quarterly at the Rosemount Industrial Waste Landfill. The landfill gas monitoring mainly focuses on methane, which is a gas generated from the decomposition of landfill waste. Methane has been detected during the gas monitoring events at one of the waste cells, Cell 1 which is an industrial waste cell. There have been no detections of methane at the perimeter monitoring points outside of the waste cells. SKB will continue gas monitoring for the landfill as required under terms of the solid waste permit SW-383. Figures 1 Site Location Map 2 Aerial Photograph 3 Landfill Existing Conditions Site Location SKB ROSEMOUNT Site Location Map Figure 1 2,000 0 2,0001,000 Feet ± Path: L:\3053\0109\mxd\Site Location Map.mxdDate: 4/17/2018 Time: 1:30:43 PM User: shujc0243 APR 2018 HennepinCounty RamseyCounty DakotaCounty GoodhueCountyScottCounty LeachateStorageArea Ash Recycling Area Office & Primary Scale Site Access Alternate Scale Site Location SKB ROSEMOUNT Aerial Photograph Figure 2 1,000 0 1,000500 Feet ± Path: L:\3053 \0109\mxd \Aerial Photograph .mxdDate: 4/27/2018 Time: 12:53:43 PM User: KacHD0606 2017 Aerial Photograph (Source: MN GEO) APR 2018 Attachment 1 Rosemount Interim Use Permit and Development Agreement Attachment 2 Dakota County Solid Waste License Attachment 3 Gem Ash County License www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • Use your preferred relay service • Available in alternative formats w-sw3-33 • 12/8/15 Page 1 of 7 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 Submittal: You must submit one (1) paper copy and one (1) electric copy (i.e., disc or thumb drive) of your application. 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: mm/dd/yyyy) Variance request(s) included (check appropriately): Yes No If yes, please describe: 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/enzq8a9. 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 Industrial Solid Waste Landfill Application Checklist Transfer Station Solid Waste Transfer Station Application Checklist Solid Waste Compost Facility Solid Waste Compost Facility Application Checklist Source-Separated Organic Material (SSOM) Compost Facility SSOM Compost Facility Application Checklist Checklist for a Site Suitability Workplan for a Source-Separated Compost Facility Refuse-Derived Fuel Processing Facility Refuse-Derived Fuel Processing Facilities Application Checklist www.pca.state.mn.us • 651-296-6300 •800-657-3864 •Use your preferred relay service •Available in alternative formats w-sw3-33 • 12/8/15 Page 2 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 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 Acknowledgment/Permission (to be completed by County Solid Waste Administrator or County Zoning Administrator) Signature: Date: Print name: Dave Magnusson Phone: 952-891-7551 Title: Waste Regulations Supervisor Fax: 952-891-7588 Email: dave.magnuson@co.dakota.mn.us Organization: Dakota County - Environmental Resources 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: Date: Print name: Kim Lindquist Phone: 651-322-2020 Title: Community Development Director Fax: Email: kim.lindquist@ci.rosemount.mn.us Organization: Ctiy of Rosemount Address: 2875 West 145th Street, PO 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 and SSOM Compost Facilities The applicant for a transfer facility or SSOM compost facility must attach copies of all required municipal licenses/approvals, unless the applicant is a municipality. The MPCA will not process an application without these approvals. See Minn. R. 7001.3400, item C, or 7001.3375 item L 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 (include a copy of each approval) If no, please sign the following line confirming no municipal approvals are required: Signature: Date: Print name: Title: II.Facility Information A.General Information Facility name: SKB Rosemount Industrial Waste Facility Permit number 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 •Use your preferred relay service •Available in alternative formats w-sw3-33 • 12/8/15 Page 3 of 7 B.Legal description of property (acreage includes the entire area of the facility) 238 Acres SE ¼ ¼ ¼ ¼ Section 19.20.29 T 115 N R 18 W Township name: Rosemount MN Legislative District: 37A County: Dakota Latitude: 44 Deg 45 Min 05 Sec North Longitude: 93 Deg 00 Min 43 Sec West 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 Boulevard. 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 Insitutional and Agricultural. 4.Describe the key topographic features at and around the facility: Rolling topography; highs and lows where the lows hold water intermittently. 5.Environmental Assessment Worksheet (EAW) or Environmental Impact Statement (EIS) required? Yes No Explain: C.Identify the following features within a one mile radius of the site Feature Name of feature Distance Current and former water supply or monitoring wells see Permit Application, dated March 2013, prepared by CRA for feature information Airports Lakes or ponds Rivers, streams or springs Wetlands Floodplains Karst features (sinkholes, caves) Parks or wildlife refuges Present or proposed access and major haul roads, and their weight restrictions Easements or right-of-way Recreational areas Historical or archeological areas 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 •Use your preferred relay service •Available in alternative formats w-sw3-33 • 12/8/15 Page 4 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 Capacity (yd3) Disposal area Ultimate design capacity Proposed additional capacity Current in-place volume Remaining permitted capacity Certificate of Need MSW only) Mixed Municipal Solid Waste (MSW) NA NA NA NA NA Industrial Waste 23,639,293 2,955,523 12,801,717 10,837,576 NA Demolition Debris 9,060,322 -2,955,523 4,233,309 4,827,013 NA Municipal Solid Waste Combustor Ash 2,648,950 NA 821,750 1,827,200 NA Other: Total Processing activity areas Processing area Proposed capacity Permitted capacity Design capacity tons/year tons/day tons/year tons/day tons/year tons/day Solid Waste Composting 50,000 50,000 50,000 SSOM Composting Solid Waste Transfer Station 808,080 cy/yr 808,080 cy/yr 808,080 cy/yr Solid Waste Recycling See below Solid Waste Processing prior to mass burn) Solid Waste Storage Refuse-Derived-Fuel (RDF) Other: Recyclables, wood, concrete, asphalt, carboard, shredder fluff, source separated recyclables, shingles, and metals 346,320 cy/yr 346,320 cy/yr 346,320 cy/yr Total 1,154,500 cy/yr and 50,000 tons/yr 1,154,500 cy/yr and 50,000 tons/yr 1,154,500 cy/yr and 50,000 tons/yr 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) Management Method Municipal Solid Waste 808,080 cy/yr Transfer MSW Combustor Ash 113,800 cy/yr Disposal Demolition Debris 633,650 cy/yr Disposal Industrial Waste 753,200 cy/yr Disposal Asbestos no limit CY as delivered for disposal Disposal Appliances Electronics www.pca.state.mn.us • 651-296-6300 •800-657-3864 •Use your preferred relay service •Available in alternative formats w-sw3-33 • 12/8/15 Page 5 of 7 Yard Waste part of compost below Compost bulking agent SSOM Tires 500 Tires Recycle Household Hazardous Waste Recyclables (list) See below See below See below Other: Compost 50,000 tons/yr SSCM process onsite Other: Recyclables, wood, concrete, asphalt, carboard, shredder fluff, source separated recyclables, shingles, and metals 346,320 cy/yr onsite processing or offsitte transfer B.The facility will have capacity to receive vehicles per day and expects to receive an average of 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 End-Dump Trailer 30-50 CY MSW Combustor Ash, Industrial, C&D Debris Straight Dump 20-40 CY MSW Combustor Ash, Industrial, C&D Debris 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: 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: Date: Print name: Tom Shustarich LicenseNumber: Title: State licensed: Email: tshustarich@wenck.com Organization: Wenck Associates, Inc. Address: 1800 Pioneer Creek Center City: Maple Plain State: MN Zip: 55359 21210 12/21/2016 Project Engineer Phone: 763-479-4226 Fax: 763-479-4242 Phone: 763-479-4226 Fax: 763-479-4242 MN tshustarich@wenck.com I certifyunder penalty of law thatthis document and all attachments were prepared under my directionor supervision to assure thatqualifiedpersonnelproperlygatheredandevaluatedtheinformationsubmitted. Basedon my inquiry ofthe person or personsdirectlyresponsibleforgatheringtheinformation, the information submitted Is, to the best of my knowledge and belief, true, accurate, and complete. I further certifythat the construction and operation of the above described facilitywill ba in accordancewith the plans, specifications, reports and related communications acceptedby the Minnesota Pollution Control Agency (MPCA) and on filein Its office; and inaccordancewithconditionsimposedinthepermitissuedbytheMPCA. I certifythat the facilityis consistent with local solid waste management plans. I am aware en MPCA permit must be obtained beforeconstructionoroperationofthefacflltymaybeginandalllocalpermits, licenses or other governmen t approval must be obtainedbeforeanMPCApermitcanbeissued. I am awam that lhere are significant penalties for submittingfalseinformation, including the possibilityof finesand Imprisonment Landownar () / 0 _ /) _ Signature: -----------------Date: Print name: _Jofi n'-D_o"'"m"'k-'-'e __________ , _______ Phone: 651-224-6329 Titre: -=D-'--'iv""'is""'io:..cn'-'V'"""ice"'-=--'P'-'re=si'-=d-=-en"'t'--------------Fax: 651-223-5053 Email: iohndo@wasteconnection s.com Organization:_S __ KB ....... E""n-'-vi"--ro'"'"n"'mc.:;e'-'-n'""ta""'l'""l""nc.;;.;. ______________________________ _ Address: 251 Starkey Street City: St. Paul ___ .,__ __________ , ___ _ Phone: 651-224-6329 State: Mn _____ _ Zip: 55107 Fa _6.c..5:..c1c..:·22c.o3....c-5c..c0.;c.5.c..3 ___________ _ Owner (Applicant n /) Signature: ---A- ....... ---''-'--'-----------Date: Print name: John Phone: 651-224-6329 TiUe: _D_iv_ls _lo_n'-Vi_1c_e _P'-r'-e_sl=d-"-en"""t'-------------- Fax: 651-223-5053 Email: johndo@ w asteconnectlons.com Organization: SKB Environmental Inc. Address: 251 Starkey Street City: St. Paul --'-..__ ___ -,-:==---------- Q State: -"'M"-'N'--------Zip: 65107 Date: Print name: Dave Haeckel Certification No: ___________ _ Tille: _D_iv __ is __ lon L=a .... nd=fl=ll..c-M=a=n=a""g.c..e'-r ____________ Expiration Date: ___________ _ Email: /o=hnd""o.,.@""w""as""t.;.;;e-=-co.:c.:nn,;;ce cti;..;:·o"'n s . ..::.co.:c.:m"-'-----------Phone: 651-224-6329Organization: SKB Environmental, Inc. Address: 251 Starkey Street City: St. Paul Provide the same information for other certifiedoperators. VI.Solid Waste Annual Report Contact Print name: John Domke Titie: Division VicePresidentEmail: johndo@ w asteconnections.com Orga nization: SKB Environ mental Inc. www.pca.state.mn.us , 651-296-6300 , 800-657-3864 W·SW3·33 • 12/8/ 15 Fax: 651-223-5053 State: -=M"-'N'------ Phone: 661-224-6329Fax: 65·1-223-5053 Zip: 55107 Use your preferredrelay service • Available in alternativeformatsPage6of7 II II Address: 251 Starkey Street City: St. Paul, www.pca.state.mn.us w-sw3-33 , 12/8/15 651-296-6300 800-657-3864 State: MN Zip: 55107 --------- Use your preferred relay service • Available in alternative formats Page 7 of 7 Attachment 4 Volumes Memo Technical Memo Wenck Associates, Inc. | 7500 Olson Memorial Highway | Suite 300 | Golden Valley, MN 55427 Toll Free 800-472-2232 Main 763-252-6800 Email wenckmp@wenck.com Web wenck.com To: Geoff Strack, P.E. Regional Engineer Waste Connections From: Tom Shustarich, PE, Wenck Associates, Inc. Date: December 21, 2016 Subject: SKB Rosemount Industrial Waste Facility, SW-383 Liner Reconfiguration Wenck Project # B3053-0048 Introduction The currently permitted site plans for the SKB Rosemount Industrial Waste Facility, SW-383 require separate liner systems for the industrial Cells 3A, 3C, and 2D and the adjacent (C&D) Cells 5A, 5B, and 5C. The approved liner design for the “wedge” of space between the two waste disposal areas is the industrial waste liner. The liner would be placed with a high point acting as the divide between the industrial Cells and the C&D Cells. The current permit authorizes placement of industrial waste over this wedge liner up to the highpoint and is to have a 3:1 backslope. The rest of the “wedge” space is permitted to be filled with C&D debris. Liquids collected in these cell’s leachate collection systems direct leachate to the C&D waste cells or industrial waste cells leachate collection sumps depending on the which side of the high point the liquid is collected, with the majority directed to the industrial waste cells. SKB is seeking to convert the wedge area to industrial waste capacity. As outlined in the last permit application, at a future date SKB will comingle industrial waste and C&D waste in the industrial cells as is done at numerous landfills around the state. Per previous discussions with the MPCA and Dakota County, this can be accomplished if the overlying industrial waste is separated from the C&D waste by extending the industrial waste liner system over the underlying C&D wastes so that the leachate generated from industrial waste is directed to leachate collection sumps within the current industrial waste disposal areas. This technical memorandum and accompanying drawings discuss the reconfiguration of the permitted industrial liner at the SKB Rosemount Industrial Waste Facility to overlay the permitted Construction and Demolition (C&D) area Cells 5A-5C) that will result in a conversion of permitted C&D disposal capacity to industrial waste disposal capacity with no net change to the total permitted volume for the facility. Geoff Strack, P.E December 21, 2016 2 T:\3053 Waste Connections\0048 - Liner Config\Final Submittal\Volumes Memo_FINAL1.docx The following factors are discussed in this memorandum: The global slope stability and liner interface stability of this reconfiguration was analyzed and determined to be adequate. Discussion of fill placement to protect the extended industrial liner system from being adversely affected by filling operations. Qualitative discussion of leachate volumes to be directed towards existing sumps. Typical liner connection and transition section that will be required for the connection of the industrial liner section during side slope liner construction. Revised C& D Disposal Capacity and Industrial Waste Disposal Capacity Volume calculations corresponding to the re-configuration. Geotechnical Analysis Wenck used Slope/W to evaluate the global slope stability and interface stability of the liner system components. The Factor of Safety (FS) with respect to either a sliding or global failure was determined to be over 77. The FS is well above the minimum Design FS of 1.5. Due to the nature of the waste types and their associated settlement mechanisms, differential settlement is not expected to be a concern. Liner System and Connections The proposed liner system for the industrial waste overlying the existing C&D waste consists of a GCL encapsulated between two 60 mil HDPE geomembranes and overlain by a geonet geocomposite drainage layer and a protective soil layer. The liner system will extend from the edge of the existing industrial liner perimeter berm at a slope across the existing perimeter road to connect with a 60 mil HDPE liner that overlies the existing C&D waste. The lower 60 mil HDPE liners will be connected with an extrusion weld, creating a contiguous secondary geomembrane across the site. The GCL and primary 60 mil HDPE liner will then be installed, creating continuous coverage of the side slope area proposed for waste type conversion. A detail depicting this is shown on the attached drawings. The design principles for evaluating and utilizing an encapsulated GCL are summarized in a three part GCL Design Series published in the Geotechnical Fabrics Report (Erickson, Thiel, Richardson 2002) and included as Attachment A. The primary performance advantages of the encapsulated GCL design include improved leachate containment and improved bentonite durability during construction by decreasing the potential for pre-hydration of the encapsulated bentonite. Welding the geomembranes together at the top and bottom of the overlying slopes lessens the potential for hydration of the bentonite sandwiched between the geomembranes which then minimizes the potential for reduced bentonite shear strength which could adversely affect slope stability. Geoff Strack, P.E December 21, 2016 3 T:\3053 Waste Connections\0048 - Liner Config\Final Submittal\Volumes Memo_FINAL1.docx In addition to the stability and performance attributes, the estimated leakage rates for encapsulated designs are typically 100 to 100,000 times lower than the prescriptive Subtitle D geomembrane/compacted clay liners [Erickson and Thiel 2002)]. Fill Placement The slope liner system described above will be constructed in phases, beginning with the lower elevations connected to the base liner system and progressing vertically as industrial waste placement requires, and as C&D waste placement allows. The slope liner system, constructed over the existing C&D waste is designed to direct leachate from the overlying areas to the industrial base liner for removal and treatment. Volume Calculations Volume calculations performed to determine the volume conversion from C&D capacity to industrial capacity with the overlying liner construction results in a decrease to the C&D capacity of 2,955,523 CY based on in-place volumes reported in the 2015 Annual Report. Accordingly, the increase to the permitted Industrial waste capacity is 2,955,523 cubic yards for a total industrial waste permitted capacity of 26,594,816 cubic yards. The permitted C&D waste capacity proposed is 6,104,799 cubic yards. These volumes do not modify the total permitted airspace at the site and are reflected on the attached minor modification permit application. Summary The proposed conversion of C&D waste disposal capacity to industrial waste disposal capacity at SKB Rosemount Industrial Waste Facility meets the applicable requirements for a minor modification to their existing permit as indicated by the following: There is no expansion of overall footprint proposed. There is no increase in landfill height proposed. There is no total capacity increase proposed. All technical design issues have been addressed o Liner System modifications meet current permit conditions and requirements, and are appropriate for waste types. o Leachate Collection and Removal systems are adequate for the volume of leachate anticipated o There are no changes required to the final cover system, surface water management system or environmental monitoring systems as a result of this proposed liner reconfiguration. The proposed liner system is constructible using traditional construction practices for the liner system components proposed. Current operational practices will not compromise the integrity of the liner system. Drawings 830 830 830830 830830830830830840830 82 0 840 850840 850 860 850 860 860 850 840 85084085086087088089 0 90 0 910920850 860 860 8 8 089 0 900910 9 2 0 930 860 870 880 880890900910870 890 890 890890 8 90890 880 88 0 87 0880890900 9 0 0 900900890880 8 80890900910920930930 9 3 0910920920920910900890880890900910920930930920910900890 840 850 860 870 880 890 900910 92083084085086087088089090091092 0 920 850 860870880890890900920910900 890 920910900890 890 890 89 0880870 880880 900910 880 850 85 0 84090 0 9 10920 920 930 880890900910920 89089090090091091092092093093094094095095096096097098099010008909009109209309409509609709809901000101010201030 INDUSTRIAL CELL6A INDUSTRIALCELL6B INDUSTRIAL CELL6C INDUSTRIAL CELL6D 140TH ST E 60' WIDE R.O.W.) SCALES SCALES LEACHATE STORAGE TANKS CONTAINER MANAGEMENT BUILDING OFFICE U-8 U-7S U-5S U-4S U-2S U-1 D-9 D-8 D-7 D-6 D-5S2 D-4S D-3S D-2S D-1S U-5D U-6D U-7D U-2D U-4D D-4D D-2D D-2VD D-1D D-1VD CW4-1 D-3D D-5D ROUTE 55 72" BOX CULVERT N INV = 820.20 S INV = 820.00 NW INV = 863.30 SE INV = 861.10 36" CULVERT NW INV = 860.90 SE INV = 860.40 30" CULVERT NW INV = 863.30 SE INV = 862.20 36" CULVERT NW INV = 853.10 SE INV = 849.30 CULVERT ROADSIDE) CULVERT ACCESS DRIVE) CULVERT 10" CULVERT FINAL COVER EXISTING PERMITTED LINER OVERLAY PROPOSED INDUSTRIAL CELL 2D INDUSTRIAL CELL 2B INDUSTRIAL CELL 2C INDUSTRIAL CELL 2A INDUSTRIAL CELL 3D INDUSTRIAL CELL 1 INDUSTRIAL CELL 3C INDUSTRIAL CELL 3A INDUSTRIAL CELL 3B ASH CELL 4C ASH CELL 4B ASH CELL 4A 3M CELL PROJECTSHEET TITLEREVISIONSDATEDATE: SHEET NO.DWNAPP'DFILE NAME:CHK'DM:/ 3053/ 0048? DEMO OVERFILL. DGN MINOR PERMIT MODIFICATION SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY SW-383 DAKOTA COUNTY, MN PROPOSED GRADES DECEMBER, 2016 1 Responsive partner. Exceptional outcomes. MAPLE PLAIN, MN 553571800 PIONEER CREEK CENTERFAX: 763- 479- 4242PHONE: 763-479-42000 200 400 SCALE IN FEET N INDUSTRIAL WASTE EXISTING WASTE EXISTING WASTE EXISTING WASTE FUTURE CELL 4 CELL 4E CELL 3A CELL 5A CELL 3B CELL 3H 800 825 850 875 900 925 950 975 1000 1025 1050 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 800 825 850 875 900 925 950 975 1000 1025 1050 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 800 825 850 875 900 925 950 975 1000 1025 1050 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 800 825 850 875 900 925 950 975 1000 1025 1050 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 800 825 850 875 900 925 950 975 1000 1025 1050 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 800 825 850 875 900 925 950 975 1000 1025 800 825 850 875 900 925 950 975 1000 1025 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 PROJECTSHEET TITLEREVISIONSDATEDATE: SHEET NO. DWNAPP' DFILE NAME: CHK'DM:/3053/0048/TYPICAL SITE SECTION.DGN MINOR PERMIT MODIFICATION SKB ROSEMOUNT INDUSTRIAL WASTE FACILITY SW-383 DAKOTA COUNTY, MN TYPICAL SECTIONS DECEMBER, 2016 2 Responsive partner. Exceptional outcomes.MAPLE PLAIN, MN 553571800 PIONEER CREEK CENTERFAX: 763- 479-4242PHONE: 763-479- 42004 1 INDUSTRIAL WASTE CELLS 2,3, AND 6 WASTE CELL 5 C & D 4 1 3 1 1 3 CELLS 2,3, AND6CELL 5 24'-0"3'- 0"3'-0" 2'-0" 2'- 0" 22'-0"MIN 12" ROAD GRAVEL AS NEEDED TO MAINTAIN EXISTING TEMPORARY ROAD TO BE REMOVED DURING FUTURE SADDLE AREA CONSTRUCTION)CELLS 2, 3, AND 6 BOTTOM LINER PROFILE CELL 5 BOTTOM LINER PROFILE 2004 - 2012 HIGH GROUNDWATER TABLE LINER TIE-IN DETAIL NOT TO SCALE 1 # 2 Attachment A Attachment 5 WCA NOD Replacement Plan BWSR Forms 7-1-10 Page 1 of 3 Minnesota Wetland Conservation Act Notice of Decision Local Government Unit (LGU) City of Rosemount Address 2875 145th St W Rosemount, MN 55068 1. PROJECT INFORMATION Applicant Name Waste Connections/SKB Project Name SKB Site Date of Application March 15, 2018 Application Number 1916-780; 11258-000 Attach site locator map. Type of Decision: Wetland Boundary or Type No-Loss Exemption Sequencing Replacement Plan Banking Plan Technical Evaluation Panel Findings and Recommendation (if any): Approve Approve with conditions Deny Summary (or attach): 2. LOCAL GOVERNMENT UNIT DECISION Date of Decision: March 26, 2018 Approved Approved with conditions (include below) Denied LGU Findings and Conclusions (attach additional sheets as necessary): BWSR Forms 7-1-10 Page 2 of 3 For Replacement Plans using credits from the State Wetland Bank: Bank Account # Bank Service Area County Credits Approved for Withdrawal (sq. ft. or nearest 01 acre) 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! SKB received WCA approval for a replacement plan on November 19, 2013 for proposed expansion at their facility which would impact 9.49 acres of wetland. On January 9, 2014, they provided the wetland banking credit withdrawal forms, meeting one of the conditions of their approval. The other approval was that the WCA permit was valid for five years. On March 15, 2018, SKB submitted a request to extend the WCA permit (see attached). The work that would impact the wetland has not yet been completed. The current timing would be to fill the wetland in 2019. Based on this request, a three-year extension is provided. This permit will expire on November 19, 2021. BWSR Forms 7-1-10 Page 3 of 3 LGU Authorized Signature: Signing and mailing of this completed form to the appropriate recipients in accordance with 8420.0255, 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 Andrea Moffatt, WSB & Associates Title Principal Signature Date March 26, 2018 Phone Number and E-mail 763-287-7196 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: Check one: Appeal of an LGU staff decision. Send petition and $500 fee (if applicable) to: Appeal of LGU governing body decision. Send petition and $500 filing fee to: Executive Director Minnesota Board of Water and Soil Resources 520 Lafayette Road North St. Paul, MN 55155 4. LIST OF ADDRESSEES SWCD TEP member: David Holmen, david.holmen@co.dakota.mn.us BWSR TEP member: Ben Carlson, ben.carlson@state.mn.us LGU TEP member (if different than LGU Contact): Kim Lindquist kim.lindquist@ci.rosemount.mn.us; Mitch Hatcher mhatcher@wsbeng.com; Kyle Klatt Kyle.Klatt@ci.rosemount.mn.us DNR TEP member: Becky Horton, becky.horton@state.mn.us, Jennie Skancke Jennie.Skancke@state.mn.us DNR Regional Office (if different than DNR TEP member) WD or WMO (if applicable): Mark Zabel, Vermillion JPO mark.zabel@co.dakota.mn.us Applicant (notice only) and Landowner (if different): Mike Graham mgraham@wenck.com; Geoff Strack GeoffS@WasteConnections.com Members of the public who requested notice (notice only): Corps of Engineers Project Manager (notice only) Ryan Malterud, Ryan.m.malterud@usace.army.mil BWSR Forms 7-1-10 Page 4 of 3 BWSR Wetland Bank Coordinator (wetland bank plan applications 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/DNR_TEP_contacts.pdf Department of Natural Resources Regional Offices: NW Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 2115 Birchmont Beach Rd. NE Bemidji, MN 56601 NE Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 1201 E. Hwy. 2 Grand Rapids, MN 55744 Central Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 1200 Warner Road St. Paul, MN 55106 Southern Region: Reg. Env. Assess. Ecol. Div. Ecol. Resources 261 Hwy. 15 South New Ulm, MN 56073 For a map of DNR Administrative Regions, see: http://files.dnr.state.mn.us/aboutdnr/dnr_regions.pdf For a list of Corps of Project Managers: www.mvp.usace.army.mil/regulatory/default.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: Map March 15, 2018 request for extension letter Technical Memo Wenck | Colorado | Georgia | Minnesota | North Dakota | Wyoming Toll Free 800-472-2232 Web wenck.com To: Ms. Andy Moffatt, WCA Coordinator - City of Rosemount From: Mike Graham, Wenck Associates, Inc. Copy: Geoff Strack, SKB Environmental, Inc. Date: March 15, 2018 Subject: WCA Replacement Plan Approval – Extension of Expiration Date Ms. Moffatt, As you are aware, the City of Rosemount, under its authority as the Local Government Unit administering the Wetland Conservation Act within the City, issued a Notice of Decision approving the Replacement Plan for the SKB Rosemount Industrial Waste Facility on November 19, 2013 (Application Number 1916-780) for expansion of its existing landfill facility. It is our understanding that this approval will expire on November 19, 2018. SKB requests an extension of that expiration date to provide adequate time to complete the expansion. Since the time of the 2013 application, SKB has focused on utilizing areas of the site that are part of the expansion plan but that are the less efficient, more complicated and costly areas to develop. The decision to prioritize these areas in the construction sequence means that the expansion areas planned in the wetland have not yet been completed . This change to the filling sequence means that the wetland impacts will occur at a later date than expected when the permit was issued in 2013. The current plan is to begin utility work within the wetland in 2019. The completion of the wetland impacts could occur as early as the end of 2020. One part of the change to the construction sequence is subject to MPCA approval and a request for such a change is currently pending at the MPCA. Long-term, it is still the intention of SKB to complete the expansion as proposed in 2013 but the wetland fill is now projected to be completed by the end of 2020 at the earliest. SKB requests an extension of the expiration date of its permit to November 19, 2021 (3- year extension). This should provide adequate time for the landfill expansion and approved wetland impacts to be completed. It is important to note that wetland mitigation bank credits were purchased in 2013 for this project, providing wetland functions and values for impacts which have not yet taken place. If additional information is required to support this request, please let me know at your convenience. Engineers - Scientists Business Professionals www.wenck.com Copyright:© 2013 National Geographic Society, i-cubed SKB ENVIRONMENTAL Site Location Map Figure11800PioneerCreekCenter Maple Plain, MN 55359-0429 1-800-472-2232 2,000 0 2,0001,000 Feet ± Inver Grove Heights 7.5 Minute Quadrangle (USGS: 1993) St. Paul Pakr 7.5 Minute Quadrangle (USGS: 1993) Coates 7.5 Minute Quadrangle (USGS: 1993) Vermillion 7.5 Minute Quadrangle (USGS: 1993) Wenck Path: L:\3053\03\mxd\Site Location Map_Aug 2013.mxd Dakota County Goodhue County Hennepin County Washington County Scott County Ramsey County Rice CountyDate: 8/30/2013 Time: 3:26:50 PM User: MadJC0259 AUG 2013 Legend Project Site MEMORANDUM DATE: October 23, 2018 TO: Kyle Klatt, Senior Planner CC: Kim Lindquist, Community Development Director Brian Erickson, Director of Public Works/City Engineer Stacy Bodsberg, Planning Department Secretary FROM: Stephanie Smith, Assistant City Engineer RE: SKB Rosemount Industrial Waste Landfill– IUP Renewal Engineering Review SUBMITTAL: Prepared by Wenck Associates, Inc. the SKB Interim Use Permit (IUP) Renewal Application was dated May 14, 2018. Engineering review comments were generated from the technical memo submitted with the application. GENERAL COMMENTS: This is an application for renewal of an IUP first issued for the Rosemount Industrial Waste Landfill in 1992. The most recent renewal was November 19th, 2013. The requested IUP renewal does not propose a change to the current operations of the site that have been previously approved. 1. Any damaged or faded signage for truck routing shall be maintained or replaced by the applicant. 2. The applicant shall submit route maps of truck circulation in- and off-site. City staff reserves the right to require traffic counts and updated route maps as they deem necessary. 3. The applicant shall maintain and renew as necessary all permitting through Dakota County and the Minnesota Pollution Control Agency. STORMWATER, EROSION AND SEDIMENT CONTROL Stormwater design was not submitted with the renewal application package, therefore, was not reviewed as part of this memorandum. As the applicant is not proposing significant changes to the site design from what was approved in the 2013 IUP renewal, City staff has not requested a re-design of the stormwater management with this application. The applicant should note that if they revise the site design in the future, they will be required to meet the stormwater design guidelines in place at that time. 1. The applicant shall update their stormwater modeling to incorporate the requirements from the WSB Technical Memorandum dated May 19, 2016 concerning use of Atlas 14 precipitation data for stormwater design. The modeling shall determine the High-Water Level (HWL) for the site’s drainage ponds per the Engineering Guidelines. City staff may have additional requirements for the applicant if the HWL is determined to be problematic with drainage off-site. 2. The applicant shall work with City staff to implement sediment control Best Management Practices (BMPs) to reduce sediment tracking and dust off-site. Staff may require SKB implement drive pavement, truck washes, street sweeping and/or other BMPs. 3. The applicant shall obtain MnDOT approval prior to street sweeping operations on TH 55. Should you have any questions or comments regarding the items listed above, please contact me at 651-322-2015.