notice of availability of an environmental assessment worksheet (eaw) · 2016-06-27 · •...

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Notice of Availability of an Environmental Assessment

Worksheet (EAW) Pine Bend Landfill Airspace Expansion Project

Doc Type: Public Notice

Public Comment Information EAW Public comment period begins: June 27, 2016

EAW Public comment period ends: July 27, 2016

Notice published in the EQB Monitor: June 27, 2016

Facility Specific Information Facility name and location: Facility contact: Pine Bend Landfill Inver Grove Heights Dakota County

Jeff Marone 4325 E. 66th Street Inver Grove Heights, MN 55076 Phone: 651-286-4572 [email protected]

MPCA Contact Information

MPCA EAW contact person: MPCA Permit contact person: Charles Peterson Planner Principal 520 Lafayette Road North St. Paul, MN 55155-4194 Phone: 651-757-2856 Fax: 651-297-2343 [email protected]

Abdi Hassan Permit Engineer 520 Lafayette Road North St. Paul, MN 55155-4194 Phone: 651-757-2449 Fax: 651-297-8683 [email protected]

General InformationThe Minnesota Pollution Control Agency (MPCA) is distributing this Environmental Assessment Worksheet (EAW) for a 30-day review and comment period pursuant to the Environmental Quality Board (EQB) rules. The MPCA uses the EAW and any comments received to evaluate the potential for significant environmental effects from the project and decide on the need for an Environmental Impact Statement (EIS).

An electronic version of the EAW is available on the MPCA Environmental Review webpage at http://www.pca.state.mn.us/oxpg691. If you would like a copy of the EAW or NPDES/SDS Permit or have any questions on the EAW or NPDES/SDS Permit, contact the appropriate person(s) listed above.

Description of Proposed Project BFI Waste Systems of North America, LLC (“Proposer”) owns and operates the Pine Bend Landfill (“Facility”), a mixed municipal solid waste landfill located in Inver Grove Heights, Minnesota, in Dakota County. The Proposer proposes to increase permitted capacity with a vertical expansion over the existing Facility footprint (an airspace capacity expansion) by constructing 3:1 cover slopes around the entire existing landfill footprint (“Project”). The Project will increase the permitted capacity from 29,800,000 cubic yards (“cy”) airspace to 33,937,400 cy airspace; an increase of approximately 4,137,400 cubic yards cy airspace which is greater than 10% but less than 25% expansion.

Written comments on the EAW must be received by the MPCA EAW contact person within the comment period listed above.

For information on how to comment on the (NPDES/SDS Permit, contact the MPCA Permit contact person listed above.

p-ear2-99a

http://www.pca.state.mn.us/mailto:[email protected]:[email protected]://www.pca.state.mn.us/oxpg691

www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • Available in alternative formats Page 2 of 2

NOTE: All comment letters are public documents and will be part of the official public record for this project.

Need for an EIS The MPCA Commissioner will make a final decision on the need for an EIS after the end of the comment period.

http://www.pca.state.mn.us/

Pine Bend Landfill Airspace Expansion Project Environmental Assessment Inver Grove Heights, Minnesota 1 Worksheet

ENVIRONMENTAL ASSESSMENT WORKSHEET This Environmental Assessment Worksheet (EAW) form and EAW Guidelines are available at the Environmental Quality Board’s website at: http://www.eqb.state.mn.us/EnvRevGuidanceDocuments.htm. The EAW form provides information about a project that may have the potential for significant environmental effects. The EAW Guidelines provide additional detail and resources for completing the EAW form. Cumulative potential effects can either be addressed under each applicable EAW Item, or can be addresses collectively under EAW Item 19. Note to reviewers: Comments must be submitted to the RGU during the 30-day comment period following notice of the EAW in the EQB Monitor. Comments should address the accuracy and completeness of information, potential impacts that warrant further investigation and the need for an EIS. 1. Project title: Pine Bend Landfill Airspace Expansion Project 2. Proposer: BFI Waste Systems of 3. RGU: Minnesota Pollution Control North America, LLC Agency

Contact person: Jeff Marone Contact person: Charles Peterson Title: General Manager Title: Planner Principal Address: 4325 E.66th Street Address: 520 Lafayette Road North City, State, ZIP: Inver Grove Heights, MN 55076 City, State, ZIP: St. Paul, MN 55155 Phone: 651-286-4572 Phone: 651-757-2856 Fax: 651-286-4549 Fax: 651-297-2343 Email: [email protected] Email: [email protected]

4. Reason for EAW Preparation: (check one)

Required: Discretionary: ® EIS Scoping ® Citizen petition ˛ Mandatory EAW ® RGU discretion ® Proposer initiated If EAW or EIS is mandatory give EQB rule category subpart number(s) and name(s): Minnesota Environmental Review Rules, Section 4410, 4300, Subp. 17.F., Solid Waste, “For expansion by at least ten percent but less than 25 percent of previous capacity of a mixed municipal solid waste disposal facility for 100,000 cubic yards or more of waste fill per year, the PCA is the RGU.”

5. Project Location: County: Dakota City/Township: Inver Grove Heights PLS Location (¼, ¼, Section, Township, Range): Sections: 33: NE1/4, NW1/4SE1/4, NE1/4SW1/4,

E1/2NW1/4, Township: 27N, Range: 22W Watershed (81 major watershed scale): Mississippi River – Lake Pepin Watershed GPS Coordinates: Lat: 44o46’59”N, Lon: 93o3’15”W Tax Parcel Number: 20-57575-01-010

http://www.eqb.state.mn.us/EnvRevGuidanceDocuments.htm


List of Figures Figure 1: Site Location Map Figure 2: Existing Conditions Figure 3: Cell Phasing for Proposed Expansion Figure 4: Met Council 2010 Land Use Figure 5: Inver Grove Heights Zoning Map Figure 6: Tax Parcel Map Figure 7: Soils Map Figure 8: Prime Farmland Figure 9: Public Waters Inventory Figure 10: NWI Map Figure 11: Nearby Residences Figure 12: Map of nearby wells.

List of Tables Table 1: Historical Leachate Collection Data Table 2: Project Magnitude Table 3: Disposal Area Summary Table 4: Pine Bend Landfill Major Feature Construction Summary Table 5: Cover Types Table 6: Permits Required Table 7: Wells within one (1) mile.

List of Attachments Attachment 1: Solid Waste Permit Application Plan Sheets Attachment 2: NHIS Query Attachment 3: SHPO Query

6. Project Description: a. Provide the brief project summary to be published in the EQB Monitor, (approximately 50

words). BFI Waste Systems of North America, LLC (“Proposer”) owns and operates the Pine Bend Landfill (“Facility”), a mixed municipal solid waste (“MSW”) landfill located in Inver Grove Heights, Minnesota, in Dakota County. The Proposer proposes to increase permitted capacity with a vertical expansion over the existing Facility footprint (an airspace capacity expansion) by constructing 3:1 cover slopes around the entire existing landfill footprint (“Project”). The Project will increase the permitted capacity from 29,800,000 cubic yards (“cy”) airspace to 33,937,400 cy airspace; an increase of approximately 4,137,400 cubic yards cy airspace which is greater than 10% but less than 25% expansion.

b. Give a complete description of the proposed project and related new construction, including infrastructure needs. If the project is an expansion include a description of the existing facility. Emphasize: 1) construction, operation methods and features that will cause physical manipulation of the environment or will produce wastes, 2) modifications to existing equipment or industrial processes, 3) significant demolition, removal or remodeling of existing structures, and 4) timing and duration of construction activities.


EXISTING FACILITY The Facility, a MSW landfill, located in Inver Grove Heights, Minnesota, consists of 255 acres located in Township 27 North, Range 22 West, Section 33, city of Inver Grove Heights, Dakota County. The Facility is generally comprised of two (2) areas. The first area is a closed unlined MSW disposal area in the northern-most part of the Facility, designated as Phases 1 and 2. This area has an existing airspace volume of approximately 15,500,000 cy. The second area is the open, lined, MSW disposal area with an existing airspace volume of 14,300,000 cy and includes Phases 3, 4, and 5. Phase 5 is the current active disposal area at the Facility. A site location map including a United States Geological Survey topographic map and a site detail map with an aerial photograph are Figures 1 and 2. The Facility has operated since 1971, under the Minnesota Pollution Control Agency (“MPCA”) Solid Waste Permit #SW-45. MPCA Permit #SW-45 was most recently issued by the MPCA on July 30, 2015. The Facility lies approximately 200 feet above the present level of the Mississippi River. Consequently, it is not in the 100-year flood plain, despite its proximity to the river. Relatively low natural relief ranging from approximately 864 feet in the west side of the Facility to approximately 905 feet in the east side of the Facility, mean sea level (“MSL”), characterizes the majority of the site. The Mississippi River lies approximately one (1) mile to the east of the Facility at its nearest point. Figure 2 shows the existing conditions at the site. PROPOSED PROJECT The Proposer has prepared a request for a major modification to their Solid Waste Permit (SW-45) of the existing Facility that includes a proposed airspace capacity expansion over the existing Facility footprint. The Project would develop and permit 3:1 cover slopes around the entire existing Facility footprint, including the north and east sides which were closed with a 5:1 slope. The Facility is currently permitted with 3:1 cover slopes on the south and west sides. The Proposer notes that the Project does not include an increase in the footprint or increase to the currently permitted peak elevation of the existing Facility. Based on current waste volume, the proposed expansion would add approximately eight years of additional disposal capacity to the existing landfill. Liner System The liner system for MSW disposal areas must have a minimum leachate collection efficiency of 95% according to MPCA solid waste rules (Minn. R. 7035.2815 subp. 7J – Mixed Municipal Solid Waste Disposal Facilities). In addition, the liner system in combination with the final cover must have a minimum collection efficiency of 98.5% (Minn. R. 7035.2815, subp. 7A).

The approved liner system designs for the existing and remaining Facility development vary for the different areas of the site depending upon the existing liner system in-place below the vertical expansion. The most recently constructed liner designs of the existing landfill are as follows:

1. Construction of the western fill area in Phase 4 development included a composite liner consisting of one 60-mil (0.060 inch) high density polyethylene (“HDPE”) liner, overlying a two (2)-foot compacted clay liner. The clay liner has a maximum permeability of 1x10-7 centimeters per second, and was compacted to a minimum of 95% Standard Proctor Dry Density, with a moisture content 0 to 5% wet of optimum moisture content.


2. The central fill area or the valley between Phases 1, 2, and 3 and Phase 4 development is generally on virgin ground and a composite liner is currently permitted for this area. The composite liner is the same design as western fill area and currently utilized in Phase 4, and Phases 5A through 5 E, and permitted for 5F.

3. The southeast fill area is the portion of Phase 3 landfill development which has received final cover with a 40-mil flexible membrane liner. The permitted liner design for overfill in this area is one 60- mil HDPE liner, overlying a geosynthetic clay liner (“GCL”).

The majority of the Project area will be over Phases 1 and 2 which are over an unlined area. Sheet 2 of Attachment 1 shows the unlined areas comprising Phases 1 and 2. Overfill currently in place in this area and for the Project has a permitted liner design of one 60- mil HDPE liner overlying a GCL. Overfill refers to the areas of the landfill where construction, filling and closing of new waste cells is on top of existing in- place waste. The current Phase 5 areas include overfill on the prior Phase 3 and 4 areas (Sheet 2 of Attachment A). For construction of new overfill areas as part of Phase 6, the Facility would utilize the existing two (2)-foot clay cap as part of the base liner system for this area in place of the GCL if the existing two (2)-foot clay cap meets base liner quality clay standards. A detailed geotechnical investigation completed by the Proposer to demonstrate that the liner system would not be affected by settlement of the underlying waste due to the combined effects of biodegradation and physical creep. The post settlement slopes of the slopes analyzed would be greater than or equal to 3% slope (a three feet vertical change over a horizontal distance of 100 feet), at the end of the site life and subsequent post closure care period (a total of 45 years), consistent with the Hydrologic Evaluation of Landfill Performance Model’s prediction of leachate head buildup. MPCA Solid Waste Rules require the base of the liner be graded to a minimum 2% and a maximum 10%slope (Minn. R. 7035.2815, subp.7G). Drainage Layer System MPCA Solid Waste Rules require that 12 inches of granular drainage layer material overlie the HDPE liner (Minn. R. 7035.2815, subp. 7E). On all sideslopes steeper than 10% (ten (10) feet vertical change over a horizontal distance of 100 feet), a textured HDPE membrane will improve stability of the geomembrane/clay interface, geomembrane/drainage layer interface and the geomembrane/GCL interface. The granular drainage layer will collect leachate and provide drainage along the liner to the leachate collection trench. MPCA Solid Waste Rules require that the drainage layer have a permeability 1X10-3 centimeters per second or greater throughout (Minn. R. 7035.2815, subp.7F). Collection Pipes Construction of the leachate collection trench begins with the placement of a geotextile fabric in the pipe trenches above the HDPE liner. A three (3) inch layer of coarse aggregate covers the geotextile fabric. The pipe (a six (6) inch diameter, perforated, Standard Dimension Ratio (SDR) 11, HDPE pipe) is set and aligned on top of the layer of course aggregate. After installing the pipe additional coarse aggregate will cover the pipe. A 12-inch thick layer of graded filter aggregate will cover the coarse aggregate to provide a filter from the overlying granular drainage layer. This filter would help stop migration of particles that might clog the collection pipe. The granular drainage layer material lies over the trench.


Since the Project's leachate collection piping are over existing waste, there does exist a potential for settlement caused by loading of waste. Calculations performed for the anticipated settlement of the Project piping assure that at least 1% slope (post-settlement) would remain in the pipes. The Solid Waste Permit Application details the design of the leachate piping system, including all locations of collection pipes in the leachate piping plan. Access to the leachate collection pipes for maintenance is by cleanout risers which extend up the sideslopes (see Attachment 1 – Solid Waste Permit Application Plan Sheets – Sheet No.5, Leachate Piping Plan). Leachate Collection Sump, Head Build-Up, and Removal Design of the leachate collection system is for the Project to collect and convey leachate from the Project area to one of six (6) leachate collection sumps (see Attachment 1 – Site Plan Drawings – Sheet 5). For the Project area, leachate sumps are at the intersection of the proposed perimeter berm and the existing final cover. Design of the sumps is to be two (2) feet deep and contain approximately 4,000 gallons of leachate. During regular operations, submersible sump pumps will maintain the leachate head 12 inches or less. The submersible pumps are capable of pumping approximately 80 to 120 gallons per minute. They will pump leachate collected in the sumps to the existing forcemain that encircles the perimeter of the Facility. The leachate will transfer from the sumps to one of the two (2) existing leachate tanks. Secondary Collection System Two (2) side-slope leachate risers will be in the leachate storage sump for Phase 5F (not yet constructed) running for five (5) feet along the base of the sump and up the side-slope to a riser vault. This will provide a redundant leachate extraction system in case the first riser fails. Leachate Storage Currently, service of the site is by two (2) above ground leachate storage tanks as follows:

∑ One 101,000-gallon tank in southern portion of site near office building; ∑ One 80,000-gallon tank in southern portion of site near office building.

Historical annual leachate collection volumes from 2008 through 2014 varied from 5,000,000 to 9,600,000 gallons. Table 1: Historical Leachate Collection Data

Year Leachate Collection Volumes (Gallons) 2014 8,372,828 2013 7,820,987 2012 6,642,340 2011 9,670,009 2010 7,610,212 2009 5,148,812 2008 7,540,650

Based on this information, the Proposer assumes that leachate generation will continue at approximately eight (8) to nine (9) million gallons per year. As the Proposer plans final closure on portions of the Facility and opens new areas, the active disposal area should remain approximately the same. The potential variability in leachate generate is a function of seasonal


precipitation and the amount of open active disposal surface area, rather than total Facility area. The Proposer will continue to collect leachate daily and transport to the Metropolitan Council Environmental Services wastewater treatment plant in St. Paul for treatment. There are no pretreatment provisions for the landfill leachate. Lysimeter The Project will include an enhanced liner system in the sump areas. Following each phase of liner system construction the Proposer will use liner leak location testing using electric leak location testing instead of lysimeters. The Facility has seen little or no liquid and no detection of leachate in the current lysimeters. The Proposer will commit to providing enhanced design and construction activities for this overfill development; above and beyond past performance for their liner system that shows no indication of loss of integrity. Final Cover Design The design of the final cover contains or diverts precipitation from filled areas of the site. One design features of the proposed expansion is to continue the 3:1 benched final cover slope around the entire perimeter of the existing Facility. This design provides for increased capacity without increasing site footprint or permitted peak elevation of the Facility. The permitted peak elevation for Phase 5 is 1,018.8 feet MSL (Mean Sea Level). The Project is north and east of Phase 5 and will be finished at the same elevation of 1,018 feet MSL (See Attachment 1 – Sheet 6). This design has demonstrated stability and efficiency of surface water management. Benches are flat tiers that circle the landfill and direct stormwater to the down slopes; they are 12 feet wide with a berm at the edge. The benches incorporate access roads and surface water management. Construction of the benched sideslope final cover system will be on all areas covered at a 3:1 slope (see Attachment 1 – Site Plan Drawings). The design of the Facility uses the MPCA guidance document for 3:1 final cover systems. The final cover barrier layer would consist of a 40-mil low-density polyethylene liner, or equivalent. For increased stability, all final cover slopes would utilize a textured liner material. A synthetic geonet drainage layer with geotextile bonded on both sides would overlie the liner. The cover material would consist of 24 inches of cover soil and/or topsoil. The upper six (6) inches would be topsoil capable of sustaining vegetation. The final cover topsoil layer would be mulched and seeded with shallow-rooted, drought-tolerant grasses. Slopes on the final cover of the facility will be up to a 33% (33 feet in vertical change over a distance of 100 horizontal feet) grade. The final cover then peaks at a 3% grade to a maximum elevation of 1,018 feet. Dual Extraction System The existing Facility utilizes a dual extraction system that is able to collect landfill gas as well as landfill leachate from a single well. The system has been vital in reducing the amount of leachate generated within the closed portion of the landfill while also maximizing the amount of landfill gas recovered and delivered to the gas plant. There are currently 26 dual extraction wells operated at the landfill configured into four (4) sections or nodes with a separate control panel containing electrical breakers for each well within the node. The Proposer reduced the number of dual extraction wells to allow for the construction of Phase 5 landfill cells. As waste placement within Phase 5 continues, the Proposer will bring wells back online into the dual


extraction system to continue maximize the capture of leachate and landfill gas. As construction and waste placement proceeds within the Project, the Proposer will add additional dual extraction wells into the new cells and bring them online to collect leachate and landfill gas. SURFACE WATER MANAGEMENT The design of the surface water system is to manage a 100-year, 24-hour Type II storm event of 7.42 inches. This design exceeds the General Industrial National Pollutant Discharge Elimination System (“NPDES”) Stormwater rule requirements for a 25-year, 24-hour, Type II storm event. The system consists of benches, catch basins, drainage piping, downslope structures, junction vaults, and sedimentation ponds. Final Cover Access The proposed benches included along the slopes of the final cover provide for more designed access roadway surface than typically provided on landfill covers. The large amount of final cover roadway access results in better access to the final cover, surface water control features, and many of the landfill gas wellheads for operation, maintenance, and inspection. Placement of landfill gas wellheads is for easy access from the benches (access roads). The Proposer will either maintain main access roads from the south that provide access to the top of the landfill or construct new roads as needed to ensure appropriate access to the final cover. Peak Run-off Design of the final cover system used hydro CAD 10.00 to model the maximum discharge to each of the stormwater management ponds. The estimate of peak runoff used a runoff curve number (“CN”) of 76. The CN of 76 is a composite number based on hydrologic soils group B soils. Calculation of the composite number was by assigning 30% to the newly graded condition (CN 91) and 70% to a fair, 50 to 70% grass cover condition (CN 69). These percentages represent the proposed construction phasing because the entire final cover area will not be in the newly graded condition at the same time. Bench and Drainage Swale Design Bench design includes a 3:1 slope, 12 foot wide, and sloped into the final cover. The design of the drainage benches is to handle the flow for each sub-area and spaced 40 feet vertically around the perimeter of the Facility. The peak flow depth will not exceed the depth of the bench. Benches will have erosion control matting installed to protect against erosion until establishment of permanent vegetation. For the Phase 5 overfill construction and development, the MPCA approved the removal of the swales at the Facility and additional erosion control matting at the change in grade from the top 3% to the sideslope at 3: 1. The Proposer requests to continue this practice for the Project. Downslope Structures Each bench will discharge into one (1) of six (6) cable concrete lined downslope structures located around the perimeter of the site. Two (2) of these structures currently exist as part of the permitted design. The Proposer plans to install four (4) additional structures located on the northwest, northeast, east, and southeast sides of the proposed final cover area. Junction Vaults The downslope piping systems in the southwest and northeast corners discharge to concrete junction vaults. In the junction vaults, flow combines to a single pipe which outlets to the


existing railroad crossing culverts, which flows to existing stormwater ponds on adjacent property owned by the Proposer. Sedimentation Ponds Surface water from the Project will discharge to existing sedimentation ponds. Discharge to the existing east pond (6P) will be through an existing low area into a set of culverts beneath the railroad tracks. Currently one 36-inch culvert exists beneath the tracks. To accommodate additional stormwater flows the Project will include two additional 36-inch culverts. Due to the adjacent railroad tracks the Proposer will use horizontal drilling methods to install the new culverts. Design of the ponds is to serve as infiltration ponds. The sandy soils at the Facility are conducive to infiltration. LANDFILL GAS MANAGEMENT Background The U. S. Environmental Protection Agency (“EPA”) and the MPCA require control of landfill gas (“LFG”) generated at MSW landfills. This control requirement achieves two (2) objectives. First, the methane component of LFG combusts in the concentration range of 5 to 15% by volume in air. Five (5) percent is considered the lower explosive limit (“LEL”) and 15% the upper explosive limit. Consequently, migration and concentration of methane into enclosed spaces could result in an explosive atmosphere. Minn. R. 7035.2815 subp. II requires that the concentration of any explosive gas not exceed the LEL at the property boundary or 25% of the LEL in or around facility structures. The Facility has an MPCA approved gas collection and monitoring system to address concerns with migration of combustible gas. The second objective for controlling LFG is maintenance of air quality standards. In March of 1996, the EPA promulgated air emissions regulations for large new and existing MSW landfills. These are the New Source Performance Standards and Emission Guidelines (“NSPS”). Under these regulations, affected facilities that emit more than 50 megagrams per year of non-methane organic compounds (“NMOC”) must install controls. The installed controls must be capable of reducing the NMOC in the collected LFG by at least 98% by weight. The Proposer has installed landfill gas control equipment. The Facility employs a comprehensive monitoring program for early detection of LFG in on-site structures and at adjacent properties. The Proposer monitors occupied buildings and structures located at the Facility using electronic monitoring devices. These devices allow for detection of concentrations of LFG well below the explosive range. Permanent LFG monitoring probes around the perimeter of the Facility monitor migration from the Facility. Currently, the Proposer is working with the MPCA and the city of Inver Grove Heights to address gas migration concerns. The Proposer completed a geoprobe investigation at the site in July 2015 and will submit the findings along with proposed gas migration mitigation measures to the MPCA during the first quarter of 2016. Future Gas System Installation Augmentation of the Facility’s gas extraction system in the Project area will include a horizontal gas collector system as well as six (6) new pumping stations. With a retrofit the pumping stations may serve as dual extraction wells and provide for landfill gas collection. Lateral sub-header piping will connect to the existing


header piping system to provide vacuum to the new horizontal gas collection system. Installation of the horizontal collector piping will be as described in the Solid Waste Permit Application. PROPOSED GAS SYSTEM DESIGN Existing Extraction Wells Gas wells already exist in Facility areas where the Project will occur. Extension of the existing gas wells will happen as filling progresses during Project development. Horizontal Collectors Horizontal collectors are proposed in Project areas where overfill waste thickness would be too shallow for practical installation of vertical extraction wells. The horizontal collectors would consist of six (6)-inch HDPE piping. Each horizontal gas collector will connect to the gas lateral subheader piping via a wellhead. The Proposer will install valves to regulate vacuum and gas flow. Gas System Piping Gas extraction from the existing wells through existing or temporary laterals, subheaders, and header piping will continue until final grades Project completion. At that time, the Proposer will install new laterals from the existing wells to new subheaders. These will drain to either the existing header or the new header to along the southern boundary. This will complete a loop around the entire site. Gas Generation Estimate The previous estimated peak generation rate for the Facility was approximately 3,500 cubic feet per meter. This estimate is from 2011 when the Gas Collection and Control System (“GCCS”) Plan was updated. During the plan update the Proposer completed a LandGEM (Landfill Gas Emissions Model) model on the waste mass to predict the future gas generation at the Facility. Additional information on the landfill gas generation is in the GCCS Plan and LandGEM model are within the Solid Waste Permit Application. LANDFILL CONSTRUCTION Technical Specifications and the Construction Quality Assurance Manual described in the Solid Waste Permit Application will guide cell and final cover construction. ENVIRONMENTAL MONITORING SYSTEM Routine groundwater and surface water monitoring will happen during the post-closure period in accordance with the Facility permit or an approved Closure Order issued by the MPCA. The current Site Specific Sampling Protocol includes the lists of analytical parameters and current sampling locations used to develop the proposed environmental monitoring system for the post-closure monitoring of groundwater, surface water, and leachate. The Phase IV Water Quality Monitoring Workplan on file for this site will guide groundwater and surface water monitoring. Procedures detailed in the Leachate Management Plan will guide leachate monitoring.

Closure Upon reaching final grade, closure of each phase will occur according to the closure requirement in the permit. The surface will conform to the design plans for final grade and benching. The Proposer will place appropriate buffer layers to bring the surface to final grade during site operations. A summary of closure procedures is as follows:


a. Install minimum 40-mil synthetic flexible membrane liner. b. Install geonet drainage layer according to the design plans. c. Grading and placement of 18 inches of soil fill. d. Placement of six (6) inches of vegetation supporting topsoil. e. Seed and mulch the final covered area.

c. Project magnitude:

Table 2: Project Magnitude

Total Project Acreage 255 ac site. (The project does not increase the footprint)

Linear Project length NA Number and type of residential units NA Commercial building area (in square feet) NA Industrial building area (in square feet) The Facility office and storage buildings occupy

approximately 10,000 sq. feet. The scale occupies approximately 770 sq. feet.

Institutional building area (in square feet) NA Structure height(s) 1,019 MSL- top of permitted final closed Facility

cells

d. Explain the project purpose; if the project will be carried out by a governmental unit, explain the need for the project and identify its beneficiaries. The Project will allow for the expansion of airspace capacity over the existing Facility footprint. The Project will increase capacity from 29,800,000 cy by 4,137,400 cy, for an ultimate design capacity of 33,937,400 cy, and extend the life of the Facility by approximately eight (8) years. Table 3: Disposal Area Summary

Disposal Area

Ultimate Design Capacity (cy)

Proposed Additional Capacity (cy)

Current Permitted Capacity (cy)

Current In-Place Volume (cy)

Remaining Permitted Capacity (cy)

Mixed Municipal Solid Waste (MSW)

33,937,400 4,137,400 29,800,000 27,156,684 2,643,316

e. Are future stages of this development including development on any other property planned

or likely to happen? Yes x No If yes, briefly describe future stages, relationship to present project, timeline and plans for environmental review.

f. Is this project a subsequent stage of an earlier project? X Yes No If yes, briefly describe the past development, timeline and any past environmental review.

The Proposer currently owns and operates the Facility. The Facility has operated since 1971, under MPCA Solid Waste Permit SW-45. As specified in MPCA Permit SW-45, the Facility is a mixed MSW land disposal facility with the disposal of MSW limited to the existing and pre-


existing footprint and a total permitted capacity of 29,800,000 cy. The footprint of the landfill is approximately 198 acres within the approximately 255-acre Facility property. Phoenix, Inc. leased the Facility until 1976 when they purchased the Facility. Browning Ferris Industries purchased the stock of Phoenix, Inc. on August 1, 1980. Browning Ferris Industries then established Pine Bend Landfill, Inc. as a wholly owned subsidiary. The Facility ownership ultimately changed to its current status, BFI Waste Systems of North America, LLC. a subsidiary of Republic Services, Inc. Phoenix Inc. completed an Environmental Impact Statement (“EIS”) for the site in 1980. With regards to capacity, on September 25, 1973, the MPCA approved an amended operating plan for the west portion of the site and a new operating plan for the east portion of the site. This amended plan allowed for a total airspace capacity of 16.43 million cy. The April 1980 EIS proposed a volume expansion of 4,500,000 cy, which resulted in 20.93 million cy of total airspace capacity. On July 27, 1983, the MPCA authorized a further increase of 66,000 cy to the airspace capacity. Based on an April 1993 report prepared by Woodward-Clyde Consultants entitled “Evaluation of Airspace Capacity,” the Facility currently has an approved total airspace of 24.00 million cy. On March 4, 2003, the MPCA granted the Facility a Certificate of Need ("CON") capacity as part of the Phase 5 vertical expansion of the facility. The CON capacity granted was six (6) million cubic yards and brought the total facility disposal capacity to 29,800,000 cubic yards. On October 2, 1984, the MPCA made an amendment to the permit to reflect the change in ownership to the Proposer and to amend sections on landfill gas monitoring and reporting requirements. On December 14, 1993, the MPCA modified Permit SW-45 to include the requirements of Federal Rule 40 CFR Part 258 (subtitle D), which became effective at the Facility on October 9, 1993. The Permittee has constructed, and the MPCA has approved, the following major features:

Table 4: Pine Bend Landfill Major Feature Construction Summary

Feature Year Constructed Methane Gas Extraction System 1995, 1996

Liner Base Phase 1 1987 Phase2 1988 Phase 3 1992

Phase 3B 1995 Phase 4 Cell A 1999 Phase 4 Cell B 2001 Phase 5 Cell A 2005 Phase 5 Cell B 2006 Phase 5 Cell C 2009 Phase 5 Cell D 2010 Phase 5 Cell E 2013 Phase 5 Cell F Future Construction

Final Cover of Unlined Fill Area Phase 1 1993

Phases 2 and 3 1995, 1996 Phase 3 (SE corner)

Phase 4 (lower portion of Phase 4) 2001 2011

Liner Sidewall Extension 1995, 1996


∑ April 23, 1985 – The Proposer and the MPCA entered into a Response Order by Consent (“Order”) under Section 17 and 18 of the Minnesota Environmental Response and Liability Act of 1983. Minn. Stat. ch. 115B. The Order required the Proposer to perform a Remedial Investigation and Feasibility Study to investigate the source or sources of groundwater contamination at and near the Facility; to assess actual and potential impacts of the releases or threatened releases of hazardous substances, pollutants and contaminants from the Facility on public health, welfare and the environment; and to identify, assess, design, develop and implement response action alternatives.

∑ October 23, 1990 – The Proposer and the MPCA entered into an Amended Response Order by Consent (“Amended Order”). The scope of the Amended Order required the Proposer to redesign and complete the remedial investigation agreed to in the 1985 Order, conduct a feasibility study; develop a plan to provide an alternative drinking water source for certain residential wells adversely affected by the release(s) from the Facility and the neighboring Crosby American Demolition Landfill; and to develop a response action plan and implement the approved response actions.

∑ September 23, 1991 – The MPCA approved the Updated Remedial Investigation Report for the Facility. In regard to the alternative drinking water source, the Proposer developed a plan and the MPCA issued a Record of Decision in September 1991 which required the residences with affected wells to connect to the city’s water supply system. The city of Inver Grove Heights completed the connections supplying municipal water to the residences in December 1994.

∑ November 21, 1994 – The MPCA approved No Action Alternatives under the Superfund process for the source control and the remediation of groundwater contamination as recommended in the Updated Detailed Remedial Analysis Report. The Minnesota solid waste management rules require more stringent levels for cleanup and remediation than the Superfund Program, therefore, the source control and the remediation of groundwater contamination was previously and currently managed in accordance with this Permit.

∑ March 4, 2003 – The MPCA granted the Proposer a CON capacity as part of the Phase 5 vertical expansion of the Facility. The CON capacity granted was six (6) million cy and brought the total Facility disposal capacity to 29,800,000 cy.

∑ July 2008 and November 2013 – The Proposer submitted Applications for Permit Renewal with a new SW-45 Permit being reissued.

7. Cover types: Estimate the acreage of the site with each of the following cover types before and

after development:

Figure 4 shows cover types identified using Geographic Information Systems (GIS) data, aerial photograph interpretation, and the existing and Project site plans. Landfilling of MSW occurs as an overfill vertical expansion within the existing footprint of the current operation on top of existing Facility cells. The permit requires seeding for erosion at certain intervals as active areas are filled. The new landfill cells will sit on top of existing closed cells and would not create a change in cover types. At closure, disturbed areas will be re-vegetated as grassland. The MPCA does not expect any significant impacts to existing land cover types from the Project.


Table 5: Cover Types

Before After Before After Barren 0 0 Alfalfa/Grass/Pasture 0 0 Crops 0 0 Forest 0 0 Developed 255 255 Developed/Open Space 0 0 Shrubland 0 0 Wetlands 0 0 Open Water 0 0 TOTAL 255 255

Source: METC 2010 8. Permits and approvals required: List all known local, state and federal permits, approvals,

certifications and financial assistance for the project. Include modifications of any existing permits, governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees, Tax Increment Financing and infrastructure. All of these final decisions are prohibited until all appropriate environmental review has been completed. See Minnesota Rules, Chapter 4410.3100.

Table 6: Permits Required

Unit of Government Type of Application Status MPCA

Solid Waste Permit-45 Expires July 30, 2025 Air Permit Application submitted National Pollutant Discharge Elimination System/State Disposal System (NPDES/SDS) General Construction Permit

To be obtained during construction projects

NPDES General Stormwater Permit For Industrial Activity Permit MNR053B5P

Expires April 5, 2020

Minnesota Office of Environmental Assistance

Landfill Expansion Certificate of Need (CON)

Application to be submitted

Metropolitan Council Industrial Discharge Permit #2001 Expires September 30, 2016 Dakota County Solid Waste Facility License To be amended City of Inver Grove Heights

Conditional Use Permit To be amended

Cumulative potential effects may be considered and addressed in response to individual EAW Item Nos. 9-18, or the RGU can address all cumulative potential effects in response to EAW Item No. 19. If addressing cumulative effect under individual items, make sure to include information requested in EAW Item No. 19 9. Land use:

a. Describe: i. Existing land use of the site as well as areas adjacent to and near the site, including

parks, trails, prime or unique farmlands.


Land uses in the vicinity of the site are industrial and agricultural uses. North of the Facility is the closed Crosby American Properties Demolition Landfill. To the east of the Facility is a vacant property and commercial businesses. Locations further east include an Xcel Energy generating facility, food processing plant, chemical plants, a former CENEX warehouse, and a trucking terminal. East of this is a State of Minnesota Scientific and Natural Area that adjoins the Mississippi River. The SKB Rich Valley Demolition Landfill lies south of the Facility. West of the Facility lies residential property, farmland, and vacant properties. Figure 5 shows the 2014 City of Inver Grove Heights zoning map. Figure 6 shows a tax parcel map with the existing property lines. The MPCA does not expect any adverse impacts to surrounding land use from the Project. The Project will not create new development in the area. Prime Farmland Resources The Proposer identified prime farmland soils using data from the United States Department of Agriculture. The Code of Federal Regulation 7 CFR 657 defines the farmland classifications. Prime farmland is land that has the best combination of physical and chemical characteristics for producing food and crops, and is also available to grow these uses. Farmland of statewide importance is land, in addition to prime and unique farmlands, that is of statewide importance for the production of food and crops based on criteria determined by state agencies. Figure 8 shows approximately 76 acres of the 255 acre site classified as Prime Farmland or as Farmland of Statewide Importance. The majority of this acreage is currently in use for the existing Facility. Permitted for waste disposal activities since 1971 the Facility’s future land use does not include agricultural uses. The Project does not include the use of federal funding. The Project over the existing waste footprint will not result in impacts to Prime Farmland.

ii. Plans. Describe planned land use as identified in comprehensive plan (if available) and any other applicable plan for land use, water, or resources management by a local, regional, state, or federal agency. The Project is within the city limits of Inver Grove Heights in Dakota County. The city of Inver Grove Heights has planning and zoning jurisdiction over the Project. Land Use Plan The city of Inver Grove Heights adopted its current Land Use Comprehensive Plan (“Comp Plan”) in 2010. The Comp Plan outlines goals and policies for the following: land use, environmental protection, housing, transportation, parks and recreation, sanitary sewer, water supply, critical areas, and surface water management. The Comp Plan provides land use classifications showing the Project site classification as an Industrial Area near the southern boundary of the city limits.

iii. Zoning, including special districts or overlays such as shoreland, floodplain, wild and scenic rivers, critical area, agricultural preserves, etc. Zoning for the Project site is Industrial. Figure 5 shows the current Inver Grove Heights city zoning map.


b. Discuss the project’s compatibility with nearby land uses, zoning, and plans listed in Item 9a above, concentrating on implications for environmental effects. The Inver Grove Heights zoning ordinance allows for the airspace expansion of current landfills (10-13E-6) as a conditional use. Therefore, the Project is allowable on the site with a Conditional Use Permit ("CUP"). The Facility currently operates under an existing CUP and a Non-Conforming Use Certificate from the city of Inver Grove Heights. The Facility also operates under a Solid Waste Facility License from Dakota County. The Proposer will need to amend their existing CUP and Dakota County Solid Waste License for the Project. The Project would not change the nature of the Facility. The Project will not expand the footprint of the Facility and it would continue to operate as a municipal waste landfill. Existing conditions associated with traffic, noise, dust, odor, and other issues related to Facility operations would continue, but would not change from current operations.

c. Identify measures incorporated into the proposed project to mitigate any potential incompatibility as discussed in Item 9b above. The Project is compatible with the nearby land uses, zoning and plans, and consistent with the Future Land Use Map.

10. Geology, soils and topography/land forms: a. Geology - Describe the geology underlying the project area and identify and map any

susceptible geologic features such as sinkholes, shallow limestone formations, unconfined/shallow aquifers, or karst conditions. Discuss any limitations of these features for the project and any effects the project could have on these features. Identify any project designs or mitigation measures to address effects to geologic features. Regional Geology The bedrock in the vicinity of the Facility is overlain by a thick sequence of glacial deposits. Near the ground surface, the deposits consist of sand and gravel outwash associated with the Late Wisconsinan Rosemount Outwash Plain. This sand and gravel outwash was a result of melt-water drainage from the Superior Lobe glacier. North of the Facility, the sand and outwash deposits are overlain by till deposits consisting of sandy loam. West of the Facility, the sand and outwash deposits are overlain by deposits associated with the Rich Valley melt-water channel that drained the Des Moines Lobe glacier. Hobbs and others (1990) identify the different outwash deposits as being underlain by Superior Lobe tills and undifferentiated valley fill sediments consisting chiefly of fine sand. Four distinct bedrock formations that subcrop in the area of the Facility are, from youngest to oldest, the Prairie du Chien Dolomite, the Jordan Sandstone, the St. Lawrence Formation, and the Franconia Formation. Below the Franconia Formation are Paleozoic sedimentary formations that include the Ironton and Galesville Sandstones, the Eau Claire Formation, and the Mt. Simon Sandstone. In the vicinity of the Facility, depth to bedrock varies from approximately 150 feet to more than 500 feet below grade (Bloomgren and others 1990). Consequently, the subcropping bedrock changes from the Prairie du Chien Dolomite just southwest of the Facility, to the Franconia Formation in a bedrock valley north and east of the Facility. The axis of this bedrock valley


trends west/northwest to east/southeast and may have been incised by the ancestral Mississippi River before the Late Wisconsinan glaciation. Regional information indicates that beneath the outwash and till of the Superior Lobe, the bedrock valley is filled (at depth) with fine sands and gravel. Characterization of the Facility site is as alluvial soils overlain by Superior Lobe glacial tills. Alluvial soils extend to the groundwater table and likely reach the bedrock subcrop at depths of from 250 - 450 feet. Before Facility development, the unconsolidated soils above the bedrock at the site consisted of till and outwash areas. These soils reflect the effects of glaciations of the area particularly in the latest Wisconsin glacial period. At least one ice lobe during the Wisconsin period, the Superior Lobe, covered this particular area. This lobe moved into the area from the north-northeast. The mechanics of deposition of the unconsolidated soils are as follows. The buried bedrock valley running beneath the site was operational as a main channel of the Mississippi- Minnesota River drainage system during pre-Wisconsin times. Because it drained a large area and likely carried a significant amount of sediment, the stream valley aggraded and filled with the presently in place alluvial soils. As the terminal moraine overrode the in place alluvial valley fill soils of the area, there apparently was considerable reworking of that material resulting in the very sandy nature of the tills presently on the site. Additional alluvial outwash soils were likely added to the plain during waste of the subsequent ice advance in the area, the Des Moines Lobe. Site Geology Site geology and hydrogeology has received extensive evaluation since the Facility began operations in 1971. The Facility owner installed a groundwater monitoring network in 1972 and collected more than 35 years of groundwater monitoring data. The 2014 Annual Water Quality and Natural Attenuation Monitoring Report prepared by Groundwater and Environmental Services, Inc. represent the most recent compilation of site hydrogeologic information available. Refer to the 2014 Annual Report for a more detailed discussion. Following is a brief overview of the site hydrogeology. The uppermost aquifer underneath the site consists of the glacial deposits hydraulically connected to the Prairie du Chien Group and the Jordan bedrock formations. In the bedrock valley, also hydraulically connected to the glacial deposits is the Franconia Formation. Prairie du Chien and Jordan together comprise the major aquifer in the Twin Cities Metropolitan Area. The Franconia Formation can provide small amounts of water, but usually considered, along with the St. Lawrence Formation, a confining unit (Schoenberg, 1990). The Ironton and Galesville Sandstones serve as a regional aquifer above the Eau Claire formation, which acts as a major aquitard. The Mt. Simon Sandstone is considered the deepest aquifer in the area. An extensive monitoring well network functions for water-level measurements and water quality sampling at the Facility. The water table in glacial deposits lies between 725 to 800 feet National Geodetic Vertical Datum. Groundwater flows to the northeast with the northeast flow becoming more easterly as it approaches the bedrock valley along the northern boundary of the Facility. The average horizontal hydraulic gradient in the uppermost aquifer was calculated to be 0.010 feet per feet. Historically, the gradient has been steeper along the eastern boundary of the Facility. Adjacent to and east of the Facility, the hydraulic gradient becomes more gradual until


about U.S. Highway 52/Minnesota Highway 55 where the hydraulic gradient increases once again due to the proximity of the Mississippi River Valley.

b. Soils and topography - Describe the soils on the site, giving NRCS (SCS) classifications and

descriptions, including limitations of soils. Describe topography, any special site conditions relating to erosion potential, soil stability or other soils limitations, such as steep slopes, highly permeable soils. Provide estimated volume and acreage of soil excavation and/or grading. Discuss impacts from project activities (distinguish between construction and operational activities) related to soils and topography. Identify measures during and after project construction to address soil limitations including stabilization, soil corrections or other measures. Erosion/sedimentation control related to stormwater runoff should be addressed in response to Item 11.b.ii. NOTE: For silica sand projects, the EAW must include a hydrogeologic investigation assessing the potential groundwater and surface water effects and geologic conditions that could create an increased risk of potentially significant effects on groundwater and surface water. Descriptions of water resources and potential effects from the project in EAW Item 11 must be consistent with the geology, soils and topography/land forms and potential effects described in EAW Item 10.

The Project is not a silica sand project. Soils at the Facility, consist mostly of Udorthents, moderately shallow; Kingsley sandy loam (8-15% slopes); Kingsley sandy loam (3-8% slopes); Hawick coarse sandy loam (6-12% slopes); Hawick loamy sand (18-25% slopes);Kingsley-Mahtomedi complex (5-15% slopes); Kingsley-Mahtomedi complex (15-25% slopes); Jewett silt loam (1-6% slopes); Otterholt silt loam (1-6 % slopes); Antigo silt loam (1-8% slopes); Wadena loam (2-6% slopes); Dickinson sandy loam (2-6% slopes); Estherville sandy loam (2-6% slopes); and Kennebec variant silt loam. Figure 7 shows the soil map for the Project site. Soil Components Construction and operation of the Project requires several soil components, including: Controlled Fill; Clay; Drainage Material, Corse Aggregate, Cover Soils and Top Soils. These soils may not be available at the Project site and would need to be trucked in for construction. The Project requires the following soils and aggregates for construction and development: Controlled Fill Construction of the necessary subgrade and berms utilizes controlled fill. Off-site sources will provide the majority of the controlled fill. Useable soils classified under the Unified Soils Classification System are clayey sand (“SC”); silty sand (“SM”); poorly graded sand (“SP”); well-graded sand, fine to coarse sand (“SW”); silt (“ML”); and clay of low plasticity, lean clay (“CL”). Clay Barrier Layer The clay barrier layer will consist of soils classified as SC, CL or CH. Off-site sources will provide the clay barrier layer material.


Drainage Layer The Project will use granular material for the drainage layer in the leachate collection system.

Coarse and Intermediate Filter Aggregate Placement in the leachate collection trenches requires coarse aggregate. Course aggregate provides a highly permeable drainage media, and a bedding material for the leachate collection pipes, as well as bedding for the gas extraction well casings. Cover Soils Cover soils are necessary between the drainage layer and topsoil in the final cover. These soils need to provide a rooting zone for the final cover vegetation. The Proposer will use yard waste compost or a mix of yard waste and organic waste compost as intermediate cover at the site. Topsoil The top layer (six (6) inches) of the final cover requires topsoil as well as for the top layer on berms, embankments, and drainage ditches, etc. This soil will meet Minnesota Department of Transportation (“MnDOT”) 3877.2A or an approved equal. Class 5 Aggregate Class 5 aggregate is required as a surface stabilizer for the site access roads.

11. Water resources: a. Describe surface water and groundwater features on or near the site in a.i. and a.ii. below.

i. Surface water - lakes, streams, wetlands, intermittent channels, and county/judicial ditches. Include any special designations such as public waters, trout stream/lake, wildlife lakes, migratory waterfowl feeding/resting lake, and outstanding resource value water. Include water quality impairments or special designations listed on the current MPCA 303d Impaired Waters List that are within 1 mile of the project. Include MDNR Public Waters Inventory number(s), if any.

No Minnesota Department of Natural Resources (“MDNR”) listed public waters (Figure 9) exist on the Project site. Review of the National Wetlands Inventory (“NWI”) and Revised NWI identified six (6) wetlands within the Project area. The NWI indicates that four (4) wetlands exist on the Facility parcel, all four (4) located on the eastern side of the site. The Project will not impact the far northeastern wetland. Two (2) of the identified wetlands are in the proposed Phase 6, Cell B location and the third is in the proposed Phase 6, Cell A location. Located on closed portions of the Facility all these identified basins are created basins. Created as a result of disturbance (i.e. creation of the closed Facility), these basins, likely are not true wetlands, and therefore not jurisdictional wetlands covered under State or Federal wetland rules and regulations. Additionally, the Revised NWI dataset does not identify these four (4) basins as wetlands, which further confirms that these are either created areas or not wetland basins at all. The Revised NWI identifies two (2) existing sedimentation ponds as wetlands in the northwestern corner of the site and in the far northeastern corner of the site. Figure 10 shows the NWI wetlands at the Project site.


The Project is a vertical expansion of the Facility completely over the existing Facility waste footprint. Construction or operation of the Project will not disturb or impact any wetlands.

ii. Groundwater – aquifers, springs, seeps. Include: 1) depth to groundwater; 2) if project is within a MDH wellhead protection area; 3) identification of any onsite and/or nearby wells, including unique numbers and well logs if available. If there are no wells known on site or nearby, explain the methodology used to determine this. The Project will not appropriate or consume groundwater and therefore not contribute to groundwater supply issues in the area. The Facility has an existing groundwater monitoring network in place and would continue to monitor groundwater quality. This system would ensure early detection of groundwater quality impacts. If the Proposer observes groundwater quality impacts during monitoring, they would work with the MPCA to develop appropriate actions to address and improve groundwater quality under the terms of their solid waste permit. The Proposer would secure all necessary permits required prior to implementing actions targeted at improving groundwater quality.

1) Depth to groundwater: 90 to 210 feet below ground surface (elevations of 790 to 720 feet MSL).

2) The Project is not within a Minnesota Department of Health wellhead protection area.

3) County Well Index records for wells within one (1) mile of the Pine Bend Landfill. See Figure 12 for map of wells.

Table 7: Wells within one (1) mile.

UNIQUE NUMBER TOWNSHIP RANGE SECTION

USE CODE

DEPTH COMPLETE

WELL CASE

DEPTH 104127 27 22 32 DO 290 267 471702 27 22 33 AB 470 440 451947 27 22 28 DO 252 247 441890 27 22 28 DO 408 402 149796 27 22 27 TW 200 175 190492 27 22 28 DO 426 418 129284 27 22 32 DO 300 267 249051 27 22 34 DO 350 340 426997 27 22 28 DO 245 240 426938 27 22 28 DO 274 270

W0000906 27 22 32 DO 248 0 594998 115 19 13 OT 168 88 509068 115 19 13 RW 184 164 198344 27 22 28 DO 319 314 174673 27 22 32 AB 380 326 612663 115 19 13 MW 161 141 208391 115 19 13 IN 1022 623 240190 27 22 33 OT 188 184 240192 27 22 33 MW 326 316 194293 27 22 28 DO 223 218

W0000031 27 22 32 DO 320 0 408264 27 22 32 DO 248 245


W0000355 27 22 32 DO 265 0 410938 27 22 28 DO 351 346 208393 115 19 13 IN 433 173 190493 27 22 28 DO 428 408 429889 27 22 28 DO 320 315 435174 27 22 28 DO 320 315 451595 27 22 27 DO 358 353 186325 27 22 28 DO 425 420 612014 115 19 13 OT 105 65 159487 27 22 27 DO 285 279 426249 27 22 34 MW 225 0 198326 27 22 34 AB 420 402 402554 27 22 27 DO 260 255 412379 27 22 28 DO 283 279 124321 115 19 14 DO 94 89 426264 27 22 33 MW 223 218 429890 27 22 28 DO 300 295 509070 115 19 13 PS 185 165 136513 27 22 34 DO 290 285 437944 27 22 28 DO 335 330 194296 27 22 28 DO 275 270 208395 115 19 14 DO 192 186 216474 115 19 14 DO 225 200 145931 27 22 27 DO 257 252 568553 27 22 33 RM 218 218 496285 27 22 27 AB 840 615 426266 27 22 28 MW 115 105 240191 27 22 33 MW 440 390 568552 27 22 33 RM 237 237 509066 115 19 13 RW 183 163 426265 27 22 28 MW 198 0 509063 115 19 13 RW 178 158 425209 27 22 28 DO 300 295 612003 115 19 13 OT 182 152 410930 27 22 28 DO 420 392 198280 27 22 28 DO 374 369 240193 27 22 33 OT 140 135 666490 115 19 13 MW 164 139 208389 27 22 34 AB 821 747 208394 115 19 13 AB 1019 822 554202 115 19 13 RM 180 150 426260 27 22 34 AB 273 0 426263 27 22 34 AB 221 0 426267 27 22 34 AB 409 0 207297 27 22 34 AB 1000 425 509065 115 19 13 RW 180 160 425245 27 22 28 DO 362 357 149793 27 22 27 TW 200 177 149795 27 22 33 TW 152 126 426270 27 22 33 MW 395 0 427041 27 22 28 DO 225 220


207293 27 22 33 TW 227 223 501451 27 22 28 DO 405 405 437895 27 22 27 DO 297 292 608018 27 22 32 PP 185 181 190479 27 22 28 DO 411 361 429885 27 22 27 DO 380 375 425296 27 22 28 DO 340 335 412499 27 22 28 DO 360 355 441888 27 22 33 AB 650 560 612015 115 19 13 RM 173 143 427051 27 22 28 DO 225 220 208392 115 19 13 IN 436 165 185296 115 19 14 DO 171 150 426272 27 22 34 MW 237 227 408247 27 22 28 DO 273 269 434096 27 22 27 287 282 412479 27 22 28 DO 250 245 265255 27 22 33 PN 0 0 420005 27 22 28 DO 307 302 612004 115 19 13 RM 85 45 151553 27 22 34 PP 989 650 170767 27 22 27 DO 318 313 171820 27 22 28 DO 350 345 207295 27 22 33 TW 227 210 435171 27 22 28 DO 321 316 441949 27 22 28 AB 300 296 617783 115 19 13 0 0 591294 27 22 33 MW 185 175 122276 27 22 28 DO 465 397 100014 27 22 33 CO 466 372 441914 27 22 27 DO 347 342 127289 27 22 34 PP 680 635 142060 27 22 28 DO 290 285 159538 27 22 28 DO 352 347 418604 27 22 28 DO 328 323 150192 27 22 28 DO 403 398 437946 27 22 28 DO 300 295 198319 27 22 28 DO 340 335 404812 27 22 28 DO 356 351 435231 27 22 28 DO 348 343 190488 27 22 33 DO 236 196 186039 27 22 28 DO 203 198 509071 115 19 13 RW 184 164 194255 27 22 32 DO 243 238 207292 27 22 34 PN 508 412 207294 27 22 33 TW 377 374 451529 27 22 28 DO 279 274 208386 27 22 28 DO 289 0 207296 27 22 33 DO 100 0 129266 27 22 34 AB 506 400 612010 115 19 13 RM 180 140


213584 115 19 13 PP 1038 935 100961 27 22 28 DO 302 0 435249 27 22 28 DO 297 292 208390 115 19 13 IN 444 283 643923 115 19 13 MW 205 145 418836 27 22 29 PN 178 163 149794 27 22 28 TW 185 153 568551 27 22 33 RM 220 220 612729 115 19 13 MW 114 84 402559 27 22 28 DO 180 175 434095 27 22 27 DO 308 303 441916 27 22 28 DO 300 295 612008 115 19 13 RM 85 45 272766 27 22 32 0 0 780331 27 22 32 IN 645 465

USE Codes CO =Commercial DO = Domestic IN = Industrial MW = Monitor Well OT = Other PN = Public Supply/Non-community-transient PP = Public Supply/Non-community-non-transient PS = Public Supply/Non-community RW = Relief Well TW = Test Well

b. Describe effects from project activities on water resources and measures to minimize or

mitigate the effects in Item b.i. through Item b.iv. below.

i. Wastewater - For each of the following, describe the sources, quantities and composition of all sanitary, municipal/domestic and industrial wastewater produced or treated at the site.

1) If the wastewater discharge is to a publicly owned treatment facility, identify any

pretreatment measures and the ability of the facility to handle the added water and waste loadings, including any effects on, or required expansion of, municipal wastewater infrastructure.

Sanitary System The domestic sanitary system at the Facility consists of one (1) 1,000-gallon underground septic tank and a drain field. A sewage collection company pumps this tank out once every two (2) years. Landfill Leachate The Facility is a source of leachate, which varies in quantity based on precipitation and the existence of active waste cells. Leachate is wastewater generated from the landfill. Leachate is caused principally by precipitation or snowmelt percolating through the disposed waste, or inherent moisture within the waste, which drains to the bottom of


the landfill where it is collected. Leachate is primarily water with concentrations of metals, volatile organic compounds and other organic and inorganic constituents. The MPCA does not consider landfill leachate a hazardous substance. Leachate is water, which has percolated through the refuse, carrying with it some of the dissolved and suspended components of the refuse. Its composition varies with the amount of water in the landfill, the composition and age of the buried refuse, and the thickness and degree of compaction within the waste cells. Design of the leachate collection system is for the Project to collect and convey leachate from the Project area to one of six (6) leachate collection sumps (see Attachment 1 – Site Plan Drawings – Sheet 5). A submersible pump capable of pumping approximately 80 to 120 gallons per minute will pump leachate collected in the sumps to the existing forcemain that encircles the perimeter of the Facility. Buried at a five (5) foot depth to prevent freezing, the forcemain is a double-wall, solid HDPE pipe. The forcemain transfers leachate to the two (2) leachate tanks. There is a leak detection system installed beneath the low point of each sump (north, south) for pollution prevention. The leak detection system includes a small leak detection sump beneath the clay barrier of the leachate collection sump. The Proposer will continue to collect leachate daily and transport to the Metropolitan Council Environmental Services wastewater treatment plant in St. Paul for treatment. There are no pretreatment provisions for the landfill leachate.

2) If the wastewater discharge is to a subsurface sewage treatment systems, describe the

system used, the design flow, and suitability of site conditions for such a system.

Sanitary System The domestic sanitary system consists of one (1) 1000-gallon tank and a drain field. A sewage collection company pumps this tank out once every two (2) years transports the sewage to the St. Paul Pigs Eye Wastewater Treatment Facility for treatment.

3) If the wastewater discharge is to surface water, identify the wastewater treatment

methods and identify discharge points and proposed effluent limitations to mitigate impacts. Discuss any effects to surface or groundwater from wastewater discharges.

NA

ii. Stormwater - Describe the quantity and quality of stormwater runoff at the site prior to

and post construction. Include the routes and receiving water bodies for runoff from the site (major downstream water bodies as well as the immediate receiving waters). Discuss any environmental effects from stormwater discharges. Describe stormwater pollution prevention plans including temporary and permanent runoff controls and potential BMP site locations to manage or treat stormwater runoff. Identify specific erosion control,


sedimentation control or stabilization measures to address soil limitations during and after project construction.

On-Site Surface Water Management The design of the surface water system is to manage a 100-year, 24-hour Type II storm event of 7.42 inches. The system consists of benches, catch basins, drainage piping, downslope structures, junction vaults, and sedimentation ponds. Routes and Receiving Water Bodies There are no immediate receiving waters at or near the Facility. The design of the Facility is to direct surface water discharges to existing sedimentation ponds. The Mississippi River lies approximately one (1) mile from the Facility. No perennial streams exist in the immediate vicinity of the Facility. Nearby surface water bodies are wetland areas and small ponds occupying undrained kettlehole depressions. Perched in glacial drift these wetlands and kettlehole depressions are unconnected to the water table. Scattered areas of cattails and wetland vegetation are associated with the small ponds throughout the region. No known sinkholes or geologic features suggesting the presence of sinkholes exist within one (1) mile of the Facility.

iii. Water appropriation - Describe if the project proposes to appropriate surface or

groundwater (including dewatering). Describe the source, quantity, duration, use and purpose of the water use and if a DNR water appropriation permit is required. Describe any well abandonment. If connecting to an existing municipal water supply, identify the wells to be used as a water source and any effects on, or required expansion of, municipal water infrastructure. Discuss environmental effects from water appropriation, including an assessment of the water resources available for appropriation. Identify any measures to avoid, minimize, or mitigate environmental effects from the water appropriation.

No water appropriations occur with this Project.

iv. Surface Waters a) Wetlands - Describe any anticipated physical effects or alterations to wetland features

such as draining, filling, permanent inundation, dredging and vegetative removal. Discuss direct and indirect environmental effects from physical modification of wetlands, including the anticipated effects that any proposed wetland alterations may have to the host watershed. Identify measures to avoid (e.g., available alternatives that were considered), minimize, or mitigate environmental effects to wetlands. Discuss whether any required compensatory wetland mitigation for unavoidable wetland impacts will occur in the same minor or major watershed, and identify those probable locations.

See Part 11.a.i. for detailed discussion on wetlands on the Facility parcel.

b) Other surface waters- Describe any anticipated physical effects or alterations to surface water features (lakes, streams, ponds, intermittent channels, county/judicial ditches) such as draining, filling, permanent inundation, dredging, diking, stream


diversion, impoundment, aquatic plant removal and riparian alteration. Discuss direct and indirect environmental effects from physical modification of water features. Identify measures to avoid, minimize, or mitigate environmental effects to surface water features, including in-water Best Management Practices that are proposed to avoid or minimize turbidity/sedimentation while physically altering the water features. Discuss how the project will change the number or type of watercraft on any water body, including current and projected watercraft usage.

The Mississippi River lies approximately one (1) mile to the east of the Facility. The Project, an airspace expansion with no change to the existing footprint, will not result in impacts or alterations to the Mississippi River or other surface waters.

12. Contamination/Hazardous Materials/Wastes:

a. Pre-project site conditions - Describe existing contamination or potential environmental hazards on or in close proximity to the project site such as soil or ground water contamination, abandoned dumps, closed landfills, existing or abandoned storage tanks, and hazardous liquid or gas pipelines. Discuss any potential environmental effects from pre-project site conditions that would be caused or exacerbated by project construction and operation. Identify measures to avoid, minimize or mitigate adverse effects from existing contamination or potential environmental hazards. Include development of a Contingency Plan or Response Action Plan. Through the use of the ‘What’s in My Neighborhood’ website, hosted by the MPCA (http://pca-gis02.pca.state.mn.us/wimn2/index.html) the Facility is:

1) An active Hazardous Waste, Small to Minimal QG – MND000245795. 2) An inactive Comprehensive Environmental Response, Compensation and Liability

Information System site (CERCLIS Site – MND000245795) under investigation and cleanup.

3) An inactive Superfund Project (SR111) Federal and State Superfund Project 4) An active Landfill – Open – SW-45 5) An inactive Industrial Stormwater Permit (MNR0534JT) 6) An active Industrial Stormwater Permit (MNR053B5P) 7) A prior Construction Stormwater Permit (C00029744) Phase 5 Cell D Landfill Cell

Construction CSW. 8) A prior Construction Stormwater Permit (C00035686) Phase 5 Cell E Landfill Cell

Construction CSW.

b. Project related generation/storage of solid wastes - Describe solid wastes generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from solid waste handling, storage and disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of solid waste including source reduction and recycling.

Solid Waste The Facility is a permitted disposal site for MSW. The Facility’s office activities generate a minimal amount of MSW, consisting of office-related waste disposed of at the Facility. Office recyclables go to the adjacent Material Recovery Facility for processing.

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c. Project related use/storage of hazardous materials - Describe chemicals/hazardous materials used/stored during construction and/or operation of the project including method of storage. Indicate the number, location and size of any above or below ground tanks to store petroleum or other materials. Discuss potential environmental effects from accidental spill or release of hazardous materials. Identify measures to avoid, minimize or mitigate adverse effects from the use/storage of chemicals/hazardous materials including source reduction and recycling. Include development of a spill prevention plan. The site utilizes the following hazardous materials: petroleum products and used oil. The Facility’s Spill Prevention and Controls and Countermeasures Plan contains the procedures and Best Management Practices (“BMPs”) used to prevent these materials from impacting the environment.

d. Project related generation/storage of hazardous wastes - Describe hazardous wastes generated/stored during construction and/or operation of the project. Indicate method of disposal. Discuss potential environmental effects from hazardous waste handling, storage, and disposal. Identify measures to avoid, minimize or mitigate adverse effects from the generation/storage of hazardous waste including source reduction and recycling. Hazardous waste generated at the site will not increase as a result of the Project. Hazardous Waste The site generates a minimal amount of waste oil (approximately 1,200-1,300 gallons per year) and has a very small-quantity generator VSQG license. A 560-gallon underground storage tank stores waste oil on site. Safety Kleen pumps out this tank approximately every three (3) months and disposes of as fuel blending.

13. Fish, wildlife, plant communities, and sensitive ecological resources (rare features): a. Describe fish and wildlife resources as well as habitats and vegetation on or in near the site.

There are no natural fish or wildlife resources and habitats located at the Facility. In operation since 1971, no fish or wildlife resources or habitats have existed at the Facility since that time. The Facility has a fence around the perimeter to prevent large animals from accessing the area. Small animals may access and use the Facility area. The Proposer does not anticipate any impacts because land use would stay consistent with current uses. Eventually, the site will be open space, which will encourage wildlife habitat.

b. Describe rare features such as state-listed (endangered, threatened or special concern) species, native plant communities, Minnesota County Biological Survey Sites of Biodiversity Significance, and other sensitive ecological resources on or within close proximity to the site. Provide the license agreement number (LA-____) and/or correspondence number (ERDB 20160168) from which the data were obtained and attach the Natural Heritage letter from the DNR. Indicate if any additional habitat or species survey work has been conducted within the site and describe the results. The Proposer contacted the MDNR to determine if rare or endangered plant or animal species or sensitive resources or habitats are present within a one (1) mile of the Project site (see


Attachment 2). The letter from the MDNR summarizing the Natural Heritage Information System (“NHIS”) query results provided the following analysis stating that the query:

“did identify rare features within an approximate one-mile radius of the proposed project, but these records did not include any federally listed species and were either historical or not of concern given the project details that were provided with the data request form. As such, I do not believe the proposed project will adversely affect any known occurrences of rare features”.

The MDNR did not provide a list of the specific occurrences of the rare features identified in the query results. The letter did note that the Northern Long Eared Bat (Myotis septentrionalis) is listed as threatened by the U.S. Fish and Wildlife Service in 2015. The Northern Long Eared Bat occurs throughout Minnesota and the species roosts underneath bark and within crevices of both live and dead trees. The Project, a vertical expansion of the Facility over the existing Facility footprint, would not result in the disturbance or loss of forested habitats utilized by the northern long eared bat.

c. Discuss how the identified fish, wildlife, plant communities, rare features and ecosystems may be affected by the project. Include a discussion on introduction and spread of invasive species from the project construction and operation. Separately discuss effects to known threatened and endangered species. In operation since 1971, there are no natural fish or wildlife resources and habitats located at the Facility. The Facility will use BMPs to avoid the introduction or spread of invasive species.

d. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to fish, wildlife, plant communities, and sensitive ecological resources. The Proposer does not expect impacts to fish, wildlife, plant communities, or sensitive ecological resources, therefore no mitigation measures are necessary.

14. Historic properties: Describe any historic structures, archeological sites, and/or traditional cultural properties on or in close proximity to the site. Include: 1) historic designations, 2) known artifact areas, and 3) architectural features. Attach letter received from the State Historic Preservation Office (“SHPO”). Discuss any anticipated effects to historic properties during project construction and operation. Identify measures that will be taken to avoid, minimize, or mitigate adverse effects to historic properties. The Proposer consulted with the Minnesota Historical Society (“MHS”) during the preparation of the EAW. The MHS reported a low probability of historical and archeological resources existing at the site. See Attachment 3 for a copy of the SHPO response email correspondence dated September 22, 2015. SHPO concluded that no properties eligible for or listed on the National Register of Historic Places exist within the area of potential effect for the Project. However, the search did indicate that one historical roadway, the Mendota-Wabasha Military Road, did exist within the same section as the Project. The query also indicates that the historic roadway is now Rich Valley Boulevard,


northwest of the Facility. The previous EAW for the Facility in 2002 also noted this roadway. At that time, the EAW noted that if Rich Valley Boulevard is the historic roadway it has been altered and paved and that the activities at the Facility would not alter or impact the current state of the roadway.

15. Visual:

Describe any scenic views or vistas on or near the project site. Describe any project related visual effects such as vapor plumes or glare from intense lights. Discuss the potential visual effects from the project. Identify any measures to avoid, minimize, or mitigate visual effects. The Facility has operated at this site since 1971. Such activities and the subsequent visual impacts related to the expansion’s construction and operation will not differ from existing conditions. The current Facility permit allows for a final peak construction height of approximately 1,019 feet MSL. The Project designed such that the final peak height of the Project will match the currently permitted final height. Industrial properties surround the Facility with limited visibility from residential or scenic areas. No additional visual impacts from the proposed vertical expansion of the Facility will occur.

16. Air:

a. Stationary source emissions - Describe the type, sources, quantities and compositions of any emissions from stationary sources such as boilers or exhaust stacks. Include any hazardous air pollutants, criteria pollutants, and any greenhouse gases. Discuss effects to air quality including any sensitive receptors, human health or applicable regulatory criteria. Include a discussion of any methods used assess the project’s effect on air quality and the results of that assessment. The Facility has potential air emission sources from typical landfill operations, including fugitive dust, fugitive landfill gas emissions, and controlled landfill gas emissions. Traffic and the compacting and earth moving activities at the Facility cause fugitive dust emissions. Control of fugitive dust at the Facility will continue during operation and after construction; the approach road and main on-site road are paved, an on-site water tank truck applies water to unpaved aggregate branch roads, and, if necessary, the Proposer will spread sand on the unpaved roads. Operations at the Facility will continue at the current rate, therefore the Proposer anticipates no increase in fugitive dust from traffic operations. Carbon dioxide (“CO2”) is a product of refuse decomposition under aerobic conditions. Buried refuse quickly reaches anaerobic conditions and the production of CO2 ceases. The waste accepted daily at the Facility will not change with the Project, therefore CO2 emitted on a daily or annual basis will not change and will not pose a safety or health hazard. The anaerobic decomposition of refuse produces methane, a component of LFG. An active LFG collection system at the Facility prevents methane concentrations from reaching combustible conditions. The Facility has a comprehensive monitoring system for early detection of LFG. The waste accepted daily at the Facility will not change with the Project; therefore LFG produced on a daily or annual basis will not change and will not pose a safety or health hazard.


The Proposer routes the collected LFG to the Fortistar gas-to-energy facility located in the northwest corner of the Facility (Figure 2). Fortistar’s permitted components consist of two stationary gas turbines, and an enclosed ground flare.

b. Identify pollution control equipment and other measures that will be taken to avoid, minimize, or mitigate adverse effects from stationary source emissions. The Facility has installed and operates a GCCS for the active fill areas and areas filled to final grade. The existing GCCS consists of vertical extraction wells in the final grade and active fill areas which convey the LFG from the refuse to the gas-to-energy facility.

c. Vehicle emissions - Describe the effect of the project’s traffic generation on air emissions. Discuss the project’s vehicle-related emissions effect on air quality. Identify measures (e.g. traffic operational improvements, diesel idling minimization plan) that will be taken to minimize or mitigate vehicle-related emissions. Operations at the Facility will continue at current levels with the Project. The Facility will continue to accept approximately 370,000 tons per year of MSW, approximately 100 vehicles per day. The Proposer does not expect the Project to generate additional traffic and as a result significant changes in vehicle-related air emissions are not expected. Vehicles will idle on site when delivering loads of waste. This could cause temporary impacts from vehicle-related air emissions in localized areas on site, but levels of air emissions are not anticipated to significantly increase over existing operations. Existing operations at the Facility include the use of dozers, loaders, and similar equipment for waste placement and compaction. The Proposer expects these operations to remain similar to the current operation, and therefore, expects no significant changes in vehicle-related air emissions. During constructi