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Landmark Environmental LLC <br />May 6, 2010 <br />Ms. Rebecca Haug <br />Environmental Administrator <br />City of Elk River <br />13065 Orono Parkway <br />Elk River, MN 55330 <br />RE: Elk River Landfill -Request for CUP and License Amendment, February 2010 <br />Dear Ms. Haug: <br />Landmark Enviromnental has completed a review of the Elk River Landfill (ERL) -Request for CUP <br />and Solid Waste Facility License Amendment project, as directed. The following comments were <br />generated related to ordinance requirements and potential environmental concerns associated with the <br />proposed landfill expansion. <br />The application expands the authorized extent of the curretrt landfill and proposes the placement of <br />waste to the south property boundary. This design for the expansion (Cell 18} does not meet the <br />establishment of a suitable buffer zone on the site, as required by City ordinance. The engineering plans <br />for the request show that landfill facility features, including the perimeter access road, soil berms and <br />screening, are located offsite on the property located to the south. <br />The engineering design for landfill expansion will require approval from the State of Minnesota for <br />deviation fiom their waste fill setback rule of 200 feet fiom the property boundary (MN Rules Part <br />7035.2815, Sub. 5. C.}. <br />Page 1-1 Back rg ound <br />The application indicates that the site is 476.8 acres. The site, as indicated in the current CUP/License, <br />is a subarea of the area indicated in the application. <br />Page 2-4 Groundwater <br />The expansion will require the abandonment of inonitori~g wells/piezometers 209OWA, 213OWA and <br />P213B as part of the development for Cell 18 and this should be complete according to Minnesota <br />Deparhnent of Health Water WeII Rules. Similarly, landfill gas monitoring probes GP23 and GP24 will <br />require abandonment and replacement and the Landfill Gas Monitoring Plan will need to be revised <br />accordingly. Given the construction of liner system up to the south property boundary, it is apparent <br />that wells and gas probes will be replaced offsite, on adjacent property south of the ERL. A revision to <br />the current Please N Water Quality Monitoring Work Plan will be required to address the replacement <br />of monitoring welUpiezometers 209OWA, 213OWA and P213B. <br />ERL has installed numerous monitoring welUpiezometers outside of the current buffer area in order to <br />investigate the nature and extent of contaminant migration associated with the historic unlined waste <br />deposit. For the Tiled expansion of ERL, monitoring welUpiezometers and gas probes would typically <br />be located witlnul the 200-foot buffer area surrounding the waste deposit. <br />Page 2-7 Proposed Landfill Design <br />From air overall engineering standpoint, the des}gn of the Cell 18 expansion area is feasible/acceptable. <br />The south interior sideslope (a strong area of concern) is proposed as a 3:1 grade, which is standard <br />2042 W. 98'" Street Bloomington, Minnesota 55431 Phone: (952) 887-9601 Fax: (952) 887-9605 viww.landmarkenv.com <br />