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City of <br /> <br />River <br /> <br />she bur ZONiNG [ <br /> <br />ADMINISTRATION <br /> <br />February 5, 1997 <br /> <br />Mr. Bill Armstrong <br />Senior Engineer <br />Minnesota Pollution Control Agency <br />Groundwater and Solid Waste Division <br />520 Lafayette Road <br />St. Paul, MN 55155-4194 <br /> <br />RE: Elk River Landfill - Draft MPCA Permit <br /> <br />Dear Bill: <br /> <br />Sherburne County and the City of Elk River have completed a review of the Draft MPCA solid <br />waste facility permit for the Elk River Landfill, Inc. (ERLI) and offer the following comments. <br /> <br /> Proposed Final Elevations - General <br />The Long Term Development Plan proposal to increase the height of the final elevation by more <br />than 70 feet has not been evaluated by the City and County. The specific concerns relate to the: <br />1) impact on neighboring land use and values; 2).potential for extreme differential settlement; <br />3) aesthetic impact on a large radius around the site; and 4) nuisance effect relating to dust, <br />blowing litter and noise. Plans which are currently approved restrict the development to the <br />existing 40 acres and authorize waste placement to approximately elevation 1,100 NGVD. <br /> <br /> Corrective Action - General <br />MPCA has embraced the concept of allowing ERLI three years to demonstrate that the LFG <br />extraction system is having an effect on the VOC ground water quality. <br /> <br />The MPCA proposed performance standard which is "no clear and significant decreasing trend" <br />for VOCs is inadequate for enforcement purposes. Ideally, the permit should identify a number <br />of VOC parameters which would be specifically evaluated. The data set would be evaluated <br />using specific statistical methods identified in the permit. A 95 percent confidence interval <br />would be used to evaluate the groundwater data to determine whether a statistically significant <br />decrease in VOC concentration has occurred. <br /> <br /> 13880 Highway 10 <br /> P.O. Box 320 <br /> Elk River, MN 55330 <br />1-800~438-0578 ~ 241-2900 <br />13065 Orono Parkway · P.O. Box 490 · Elk River, MN 55330 · (612) 441-7420 · Fax: (612) 441-7425 <br /> <br /> <br />