8.3. SR 05-16-2013 - Laserfiche WebLink

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future corrective actions unless otherwise approved by the commissioner, the permittee must maintain a minimum 200-foot setback from the fill and the property boundary. The ERL has indicated that it has an agreement with the City, dated December 28, 1992 which addresses this concern and enables the compliance boundary in the proposed location. The City entered into the agreement with ERL to allow access onto the City property for the purposes of installing monitoring wells and water quality monitoring but the agreement does not provide for expanding the compliance boundary to include city property. Item 1.6.1 Contingency Action If the MPCA wishes to approve the proposed compliance boundary incorporating the City property, the City requests that the permit include a specific provision which indicates that all land use rights of the City be preserved and that potential contingency actions,which effect the City property,are subject to City approval. Section 3.5.7 Leachate Recirculation Contingencies Leachate recirculation will greatly increase the amount of landfill gas that will be generated from the landfill. The primary concerns of the City relate to landfill gas collection and the prevention of fugitive gas emissions and odors. The permit should be modified to require ERL to also provide notification of odor complaints to the City. This will enable the City staff to be apprised of odor issues when they occur. Item 4.5 Closure Criteria The MPCA-approved March 2012 Closure Plan identifies that: "Per the Conditional Use Permit with the City of Elk River, no MSW waste will be disposed in the MSW area after December 31, 2030," (page 2-2). ERL's unconditional closure date for the MSW fill area should be included in the MPCA permit. Limits Tables The City could not find a requirement in the permit that related the "Limits Table" to the groundwater monitoring wells. The MPCA should include a permit condition which indicates that ERL needs to comply with the intervention limits (identified in the Limits Table) for groundwater monitoring wells. The intervention limits have been established by MPCA utilizing groundwater compliance boundary standards for some wells and surface water compliance boundary standards for other wells. The surface water interventions presume that groundwater in the western portion of the Site discharges to the wetland of Rice Lake and Tibbits Brook. The surface water compliance boundary extends more than 2,500 feet from monitoring wells P301 C to P311 C. Previous investigations for the area down gradient of the waste deposit show that the groundwater flow in the deeper outwash deposits is confined. The major conclusion from current hydrogeologic reports is that the groundwater is discharging to Rice Lake wetland and Tibbits Brook. A change in the lithology in the area of concern has been theorized by ERL. The City previously asserted that future investigation needed to provide supporting geologic evidence which demonstrates that the till unit is absent to the west of the landfill thereby enabling a pathway for groundwater flow to the surface water.