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5.2.-5.4. PCSR 09-13-2011
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5.2.-5.4. PCSR 09-13-2011
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Rebecca Haug <br />City of Elk River <br />August 18, 2011 <br />Page 2 <br />Response: The ERL has modified the final cover drainage design to incorporate the drainage terrace at <br />the break in grade on the top of the west slope. The proposed downslope structure, erosion control <br />matting, and intermediate drainage control pipes have also been modified to incorporate the revisions. A <br />copy of the final cover drainage design is attached as Attachment 2. <br />3. Temporary final cover is proposed as an element of the September 2008 "Leachate <br />Recirculation Permit Application "proposal. The plans need to be revised to identify the criteria <br />for when an area would receive temporary final cover indicating the maximum length of time. of <br />inactive fill operations. Similarly, the maximum area allowed for inactive fill areas prior to <br />placing temporary final cover needs to be on the plans. <br />Response: Temporary cover systems have been tried over time to address many different elements of <br />landfill operations. Currently, the systems that have been tried have not proven to be sustainable. As <br />new ideas are introduced some are tried in pilot type programs to verify their sustainability. The ERL <br />commits to continue to respond to new technology in regard to temporary cover system as they realize <br />how important this is not only to their operation, but to the surrounding residents of Elk River, as well. <br />There will be continued attempts to identify other sustainable system in the future. As systems are <br />evaluated the performance of them will be summarized in the annual reports that are prepared and <br />submitted to the City. <br />4. Gas Probe Monitoring and Anal <br />Significant positive pressure readings for gas probes have been indicated over the past several <br />years. This condition may indicate landfill gas migration beyond the waste boundaries. In order to <br />fully evaluate this situation, the landfill must collect and report gas concentration and pressure for <br />each probe for each monitoring event. The landfill must also collect temperature and barometric <br />pressure for the site at the time of the monitoring event and the preceding three days before the <br />monitoring event. All gas probe monitoring data must be fully evaluated in the annual operating <br />report. <br />Response: Although the US EPA and MPCA do not require pressure readings on gas probes and gas <br />probes are subject to atmospheric conditions, thereby limiting the viability of pressure data, the ERL <br />will collect the pressure readings at the probes using appropriate sampling techniques if methane is <br />present in the probes. Thus information will be collected, if applicable, for one license period. Results <br />will be reported and evaluated in the applicable annual report. The requested temperature and <br />barometric pressure data will be provided from the on-site weather station for several hours prior to the <br />monitoring event on the day of the event and results will be provided in the Annual Report. <br />5. Ambient Air Monitoring <br />The current air monitoring for landfill gas emissions field survey is only conducted for the topslope <br />area accounts for roughly 20 percent of the fill area. There is a higher likelihood that emissions will <br />occur on the sideslope based on the horizontal stratification of the waste and preferred movement of <br />landfill gas. ERL must modify the area of traverse to include all sideslope and topslope areas for <br />ambient air monitoring events. The safety concern for vehicles on landfill sideslopes can be <br />mitigated by traverse on foot with the survey instrument. <br />T:\07420 406Uune11 CByApp\Comment response\Response_0818111LRH_080411 MtgResponse_081811.docx <br />
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