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City of <br /> Elk <br /> River <br /> 13065 Orono Parkway <br /> Elk River,MN 55330 <br /> March 14, 2013 <br /> Paula Connell <br /> MPCA <br /> 520 Lafayette Rd <br /> St. Paul MN 55155-4194 <br /> RE: City of Elk River Comments - Elk River Landfill Solid Waste Management Facility Permit, SW-74 <br /> February, 2013 Draft Permit <br /> Dear Mrs. Connell: <br /> The City of Elk River (City) has received a copy of the undated draft Solid Waste Management Facility Permit, SW- <br /> 74 for Waste Management, Inc. (WMI), Elk River Landfill (ERL). The draft was included in email correspondence <br /> to the City on February 26, 2013. <br /> Item 1.1.28 Facility Description <br /> The historic references for areas and volumes should be relocated to the Facility History (1.1.19) section. This <br /> section should clearly state that the permitted design capacity is 19,487,900 cubic yards of MSW. The discussion of <br /> Certificate of Need should be relocated to Section 1.1.31. <br /> Item 1.2.9 March 2012 Permit Modification <br /> The MSW Industrial Solid Waste Management Plan (ISWMP) (April 2008) is outdated and needs to be revised to <br /> reflect the industrial waste streams which are being accepted at the Site. The City requests that MPCA include a <br /> condition which requires the preparation, submittal and approval of a new ISWMP within six months of the new <br /> permit date. <br /> Item 1.2.25 13) Compliance Boundary <br /> The April 2009 compliance boundary is referenced. The ERL has identified alternative compliance boundaries in <br /> subsequent submittals to the City and the MPCA. Most recently, the 2012 Annual Water Quality Report contains <br /> Figure 2 which indicates the compliance boundary in a location approximately 300 feet west of the location shown <br /> in the approved compliance boundary. <br /> One of the concerns with the proposed compliance boundary is that ERL is incorporating the City trail property <br /> inside the compliance boundary. The MPCA rule requirements are outlined in Minn. R. 7035.2815, subp. 4 and a <br /> synopsis provided by MPCA guidance (in part),is as follows: <br /> The compliance boundary must be on the facility property, must completely surround the landfill, and <br /> cannot be more than 200 feet from the 10-year fill footprint. To facilitate monitoring and any potential <br /> Phone: 763.635.1000 <br /> Fax: 763.635.1090 P 0 W E R E 0 O Y <br /> www.ci.elk-river.mn.us INAT" URE1 <br />