Landfill Q-and-A

The following questions were submitted by a local Cloquet resident in regards to the proposed landfill modifications at the Ulland property near Hilltop soccer fields. The responses which follow the questions were given by Dem-Con officials.

What are the long term environmental impacts?

Installing a liner on the site will minimize any potential long term environmental impacts of the existing landfill. The proposed landfill will be lined with a leachate collection and treatment system. This system is the state-of-the-art, best available technology with no known leaking lined landfills (per MPCA and SWANA). The most important environmental protection in the longterm will be the capping system of the landfill which will prevent leachate from being generated. This capping system is easily inspected and maintained to help prevent environmental contamination in perpetuity.

How will this affect our property values?

The landfill was permitted in 1971 as a sanitary landfill. The existing homes are currently near an unlined landfill and active gravel pit. Having a state-of-the-art environmentally protective facility that is protective of the surrounding properties is an improvement to the property. This is not a new use of the land, and thus should not affect property values.

Smell?

The waste types accepted at this facility will not produce odor in a properly run landfill. Odor is typically associated with Municipal Solid Waste and other putrescible wastes which this facility will not accept.

Visibility?

The site is surrounded by dense vegetation which will provide year-round visual screening of the site.

The landfill will only be visible from two locations, the overpass on Interstate 35W and the soccer fields. The current landfill is visible from these locations as well and we are not aware of any complaints regarding the visual aesthetics of the existing landfill which is the same height as the proposed landfill. Additionally, in recognition of the public concerns regarding the views from the soccer fields, we are proposing to install a berm and coniferous trees along the east end of the soccer fields to provide additional year-round screening from this location.

Traffic Changes?

All landfill traffic will access the site off of County Road 45. The volumes of traffic will be consistent, and likely less than, historical averages as there are no new uses being proposed for the site and Ulland has scaled back the gravel operations from a "merchant" gravel pit to a private gravel pit.

Community Image impacts - potential economic development impact, from I-35, soccer fields - Aesthetics?

There has been an existing unlined landfill and gravel pit on this site since 1971. Any potential economic development would need to incorporate the existing landfill and gravel pit. The area is zoned heavy industrial and will continue mining operations into the foreseeable future.

From a community image standpoint, it will be an improvement to have a state-of-the-art lined landfill that is protective of the environment and the surrounding properties as opposed to an unlined landfill.

From an economic standpoint , the facility will support the future of local businesses by providing them with a cost-effective disposal option.

Is this location wrong from a city planning standpoint? (Potential development at I-35 & Hwy 33 junction, may need interstate access or exit in the future from 14th street?)

Any future city planning would need to incorporate the existing landfill and the gravel pit grades which are substantially lower than 14th Street. From a future planning perspective, the development of property next to an unlined landfill would be less desirable than next to a lined landfill with the proper environmental controls. These modern-day lined landfills can be completed to incorporate various end uses such public open space, bike trails, sledding hills, etc. which would allow for a better end use of the property.

The plastic liner will fail at some point in the future - it will break down and leak. Then what?

The proposed liner is the state-of-the-art Best Available Technology (BAT) for disposal of industrial wastes. Our design exceeds current MPCA requirements. If the liner fails in the future, it would be several hundred years from now, long after the landfill has been closed, when the most important environmental protection will be the cap on the landfill which will stop leachate from being generated in the first place. This cap can easily be maintained, inspected for damage, and repaired if necessary.

Additionally, as time elapses, the waste in the landfill will degrade and stabilize, minimizing any potential effects if a release were to occur.

All landfills will eventually fail and leak leachate into ground and surface water. Plastics are not inert. State-of-the-art plastic (HDPE) landfill liners (1/10 inch or 100 mils thick) and plastic pipes allow chemicals and gases to pass through their membranes, become brittle, swell, and breakdown.

Based on the waste types being accepted at this facility, the HDPE plastic liner offers the greatest resistance to chemicals and is the most protective of the environment. HDPE plastic liners are the industry standard used throughout the United States and are the recommended Best Available Technology.

How does erosion affect the landfill? Will it ever settle and or collapse?

Erosion is inspected and repaired on a regular basis per our MPCA permit and the approved Operations and Maintenance Plan. Settlement of the landfill will occur over time as the waste degrades and compresses under its own weight. This settlement is normal and is accounted for in the liner and cap designs. If excessive settlement occurs, it will be repaired in accordance with our MPCA permit.

Will it still be a functioning gravel pit? If yes, how will the logistics work?

The 59 acres of property being purchased from Ulland for the landfill operations will not be used as a gravel pit. However, the adjacent gravel pit properties will continue gravel mining operations. The adjacent gravel mining operations will not effect or interfere with the operation of the landfill.

Any chance of expansion? Can/will the landfill/leachate move closer to 14th Street?

It is not in our current business plan to expand the landfill and this proposal does NOT include any provisions for expansion. If an expansion is requested in the future, the MPCA, County and City would need to approve the request.

What will it look like on a daily basis? How high? Dozers? Dust? Truck noise? Exhaust?

A well run landfill is not a public nuisance. On a daily basis you will have trucks delivering waste to the site and heavy equipment operations such as those that currently occur on-site (dozers, compactors, loaders, etc.). The maximum height of the landfill will be 1228 feet which matches the height of the existing landfill. Truck traffic, and the associated noise and exhaust, will be consistent with historical volumes at the site.

What will the process on procedure be for corrections? Are there monetary penalties assigned or compensation amounts defined?

The facility is required to perform routine inspections for compliance with the MPCA and CUP requirements as outlined in the Operations and Maintenance Plan (Section 2.2, page 2-1). For example, the facility will perform and keep records of monthly inspections for uncontrolled vegetative growth, erosion, vandalism, settlement, drainage structures, liner systems and final cover systems, as well as general facility inspections which occur on a daily basis. These items will be corrected to maintain compliance with our MPCA permit as well as the City CUP. If the CUP conditions are not adhered to, the City may cite the landfill with a misdemeanor and impose fines and/or penalties as detailed in Section 17.4.05 of the City Zoning Ordinance. If the MPCA conditions are not complied with the MPCA may revoke the landfill permit and close the facility. Additionally, the MPCA has financial assurance, which is funded by the landfill, to be used to close the landfill and/or respond to any noncompliance issues, if needed.

How do we ensure that the water outside of the landfill will continue to be safe? Will Dem-Con's usage of the area affect the property around it?

The proposed landfill liner is designed to separate the waste from the groundwater, collect and treat the water that contacts the waste, and prevent any contaminants from contacting the groundwater.

Without this liner, such as the condition that exists at the site today, the water will contact the waste, pick up contaminants and continue on into the groundwater. The landfill was also designed to be 5-15 feet above the seasonal high groundwater mark so it does not interact, divert, or otherwise alter the flow of the groundwater. The groundwater will continue to pass freely beneath the site toward the river as it has historically done. Additionally, to verify that the groundwater has not become contaminated, a series of monitoring wells will be at the facility to sample the groundwater 3 times per year. These samples are reported to the MPCA and reviewed by a hydrogeologist to assure that they comply with the state standards.

WHO MONITORS THIS? How often? Define this in C.U.P.

The site is permitted by the City of Cloquet, Carlton County, and the Minnesota Pollution Control Agency. All of these permitting entities can perform monitoring and enforcement activities. The MPCA and the City will perform random site inspections in addition to investigating any potential complaints.

The CUP will define response times to remedy any non-compliance issues. Additionally, the facility is required to submit an annual report summarizing the facility operations, groundwater monitoring, and waste accepted each year and any non-compliance issues to the MPCA and the City.

Hydro geological concerns - MPCA data on existing wells? Are the existing wells in the correct location to get accurate water data?

The wells were placed in the proposed locations based on the MPCA recommendations. The MPCA feels that this is the best placement of the wells for protection of human health and the environment.

We are proposing to enhance the existing environmental monitoring of the site by adding 2 additional monitoring wells. The site will have a total of 7 monitoring wells, which is a significant number of wells for a facility this size relative to other landfills in the state, which will provide accurate water quality data. Both the upstream (upgradient) and downstream (down-gradient) conditions are monitored at the site.

Define dust and air control monitoring in C.U.P.

Dust will be addressed in the CUP to state that it does not become a Public Nuisance as described in Chapter 7 of the City Code. However, based on over 40 years of operational experience, dust will not be problematic at the site due to operational controls implemented such as watering the roads as necessary to control fugitive dust.

Any chance of spontaneous combustion?

Spontaneous combustible wastes are not allowed to be accepted at the facility.

Are there any chemicals used in the processing/recycling? At all?

No, the recycling and processing operations consist mainly of sorting, consolidating, and grinding of materials for delivery to recycling markets.

How hazardous is the water that is transported to WLSSD? What if there is a spill?

The leachate from the facility is NOT hazardous. It is standard practice to discharge landfill leachate at a wastewater treatment plant. These plants are capable of treating the leachate to meet their discharge requirements. WLSSD currently treats the leachate from the Waste Management landfill in Canyon, Minnesota. The leachate is very dilute and has very low levels of contaminants compared to other industrial discharges.

Fire hazards? There isn't city water at this location - will this increase our fire protection costs (Knife Falls township)?

Minor fires will be controlled by the use of fire extinguishers on the equipment and/or an onsite water truck. In the rare event of a larger fire in the landfill the fire department will be contacted for assistance. If a larger fire were to occur, it would likely be in the waste area of the landfill where water from the leachate sump can be used to fight the fire. Fires are not common in this type of waste.

Lead? Pesticides? Bacteria?

If there are any levels of lead, pesticides, or bacteria in the landfill they will either be encapsulated within the waste by the liner and cap of the landfill or will be in the leachate generated from the landfill. The leachate is sent to the WLSSD waste water treatment plant for treatment and disposal.

The WLSSD plant has the capacity to remove any of these potential contaminants to meet their discharge standards.

Any methane (or other) gas emissions?

Due to the waste type being accepted and the operating procedures of the landfill, methane and other gasses will not be generated in any appreciable amounts and will thus not be problematic.

Is $1 million financial assurance enough?

Yes. This financial assurance is approved by the MPCA and is consistent with other solid waste facilities in the State. A detailed financial assurance plan for closure, post-closure, and contingency actions was submitted to the MPCA for review and approval. Additionally, the financial assurance is reviewed and adjusted on an annual basis as needed to assure that it remains adequate into the future.

Will the C.U.P. have the ability to be updated and changed in the future?

The CUP is issued with the land and states the conditions of the operation that the business owner must adhere to. The business owner then develops a business plan around these conditions and depends on them to be consistent throughout the operations of the facility. The City has the ability to enforce and modify the zoning code and ordinances if deemed necessary.

How will this affect the safety (and aesthetics) of the St. Louis River Trail?

The landfill is not visible from the St. Louis River Trail and thus should not affect the aesthetics of the trail.

Although the traffic from the landfill will not increase the historical volumes of traffic at the site, trail crossing improvements through the use of the appropriate signage on the trail and access road are being proposed as part of this application. We have agreed to work with Carlton County and pay the expenses of the trail improvements so there is no cost to the City.

How to handle the current usage as a recreation area - safety/fencing?

Any recreational use of the private property is considered trespassing and is punishable under current laws. The landfill property will have a locking gate at the entrance to prohibit unauthorized dumping and will post no trespassing signs around the perimeter of the property. Additionally, landfill personnel will be present on the site 5-6 days a week which will help deter unauthorized access to the property. It has been our experience that a majority of the trespassing occurs when the owner or occupant of the property is not on site.

Rats or rodents? Impact on wildlife?

Due to the nature of the waste being accepted at the facility (non-petrucible, no municipal solid waste) rats, rodents, and birds will not be attracted to the facility and will not be problematic. Given the current and historical operations of the property and surrounding areas, there will not be any additional impacts to wildlife from the proposed operations.

Are landfills typically allowed within city limits? Are there other MN communities that we can model from, and ask questions? Will the traffic damage the city infrastructure?

Yes, landfills have long been a part of our community waste management practices and are almost always located within city limits to be placed near population centers to service their disposal needs.

There are numerous landfills throughout the state that the City staff has been in contact with throughout this process.

The traffic from this landfill will not be an increase over historical traffic volumes at the site and will not damage the city infrastructure any more than normal wear and tear from existing traffic on city roads.

What do the city and county get out of this? Why is this particular location being considered? Are there any other locations that would be more suitable?

The City, County, and local community benefit in several ways from this proposal including increased environmental protection and enforcement mechanisms. The most significant benefit is that we are proposing to install a liner with leachate collection at the site and relocate all of the existing waste onto the liner. The relocation of this waste will reduce any potential long term environmental impacts on the groundwater of the community. Without this proposal, the community would be left with an unlined landfill at the site forever. Another benefit to the community is that the City will now have actionable and enforceable conditions in the CUP to better regulate the facility operations.

Additionally, without this proposal, the MCPA will not have financial assurance mechanisms in place to address any potential future environmental liabilities.

The location for this site is being considered for several reasons, one of which is that an existing landfill has been in operation on the site since 1971. Given that the landfill is unlined, our company saw an opportunity for a win-win proposal for the community in that the existing waste could be relocated onto a liner, thus reducing any long term environmental liabilities of the community. Additionally, we saw an opportunity to support the local industrial customers by providing an affordable long term disposal option.

Why is Ulland still able to function and run their business if they are not following their MPCA permit guidelines? Why don't they need to clean up their current mess?

This is a question that is best addressed by the MPCA and Ulland Brothers.

Would a moratorium be beneficial to allow time to consider all aspects?

The current CUP with the City as well as the Heavy Industrial zoning for the property allows the continued use of the property as a landfill. However, City did consider a moratorium on this project but has agreed that the City has the mechanisms in place to process the application through the existing City code and ordinances. In an effort to give the City more time to discuss the issue, the applicant agreed to delay the submittal of the application and work with the City and the community to educate and inform them of the proposed project.