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Page 5 <br />February 5, 1997 <br /> <br />unreasonable as determined by the MPCA. Dust pollutives shall be utilized to the extent <br />necessary on cover material such as stockpiles to reduce wind erosion as well as on other <br />exposed surfaces as appropriate. Cover compaction and revegetation activities shall be <br />undertaken promptly on the completion of various fill areas and vegetative cover capable of <br />quick growth shall be utilized. Planting of bushes and trees shall be installed if needed to buffer <br />the Site and minimize wind erosion. <br /> <br />An all-weather haul road shall be provided to the unloading area and watered on a regular basis. <br />The Landfill shall pave the access roads from T.H. 169 to the scale and from T.H. 169 to the <br />shop building by June 30, 1997 to reduce dust generation. <br /> <br />All equipment and vehicles utilized at the Landfill Site shall be periodically inspected and <br />maintained to minimize noise. Vegetative barriers along the boundaries of the Landfill Site shall <br />be utilized to minimize off-site noise impacts. Applicable state standards for noise pollution <br />shall not be exceeded by the Landfill operation, equipment, vehicles or machinery. <br /> <br />The Permittee shall take reasonable actions to control odors from the Site. <br /> <br />Part Ill.7. - Heavy Metal Contaminant Monitorina and Assessment (new item). Heavy metal <br />contaminants for surface water and groundwater must be addressed in addition to VOC <br />contaminants. Based on the need for additional monitoring to confirm exceedances and identify <br />trends, the Landfill shall conduct monitoring and prepare an evaluation report which shall be <br />submitted with the Phase IV Water Quality Monitoring Report. <br /> <br />Part III. C. - Corrective Action. If heavy metal concentrations in groundwater and surface water <br />exceed regulatory standards, the Permittee will be required to conduct a Feasibility Study and <br />submit it to MPCA within six months of completing the Phase IV Water Quality Monitoring <br />Report. <br /> <br />Part IV.C.2. - Leak Detection Lvsimeters <br />Leachate monitoring of the lysimeters should identify an acceptable leakage rate in consideration <br />of the liner design and an allowable efficiency of 95 %. Leakage rates above this level should <br />trigger sampling and subsequent remedial action. The requirement for 100% efficiency of the <br />liner system is not consistent with other MPCA requirements. <br /> <br />Part VI.A. - Closure <br />The draft permit should include the requirement of a post-closure road for maintenance of the <br />final cover. The road should extent to the highest elevation of the fill area. <br /> <br />Overall, MPCA has developed a draft permit which incorporates many of the concerns that the <br />City of Elk River has previously expressed. The inclusion of the above language in the draft <br />permit will cover a broader perspective of the Landfill design and operation and may reduce the <br />City's need for regulatory oversight in the future. <br /> <br /> <br />