p-ear2-45a

p-ear2-45a TDD (for hearing and speech impaired only) 651-282-5332

Printed on recycled paper containing 30 fibers from paper recycled by consumers

ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to reviewers The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects This EAW was prepared by the Minnesota Pollution Control Agency (MPCA) acting as the Responsible Governmental Unit (RGU) to determine whether an Environmental Impact Statement (EIS) should be prepared The project proposer supplied reasonably accessible data for but did not complete the final worksheet Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) EQB Monitor Comments on the EAW should address the accuracy and completeness of information potential impacts that are reasonably expected to occur that warrant further investigation and the need for an EIS A copy of the EAW may be obtained from the MPCA by calling 651-757-2101 An electronic version of the completed EAW is available at the MPCA website at httpwwwpcastatemnusnewseawindexhtmlopen-eaw 1 Project Title Becker Ash Landfill Expansion 2 Proposer Great River Energy 3 RGU Minnesota Pollution Control Agency Contact Person Matt Herman Contact Person William Lynott

and Title Environmental Compliance Coordinator

and Title

Planner Principal

Address 12300 Elm Creek Boulevard Address 520 Lafayette Road North Maple Grove Minnesota 55369 St Paul Minnesota 55155-4194 Phone 763-445-5204 Phone 651-757-2587 Fax 763-445-5235 Fax 651-297-2343 E-mail mherman2GREnergycom E-mail williamlynottstatemnus 4 Reason for EAW Preparation

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

+ If EAW or EIS is mandatory give EQB rule

category subpart number and name

Minn R 44104300 subp 17G (MSW Ash Landfill) 5 Project Location County Sherburne City Becker SW 14 SW 14 Section 7 Township 33N Range 28W

GPS Coordinates N 453613 W 938785

Tax Parcel Number 60-007-3200

p-ear2-45a TDD (for hearing and speech impaired only) 651-282-5332

Printed on recycled paper containing 30 fibers from paper recycled by consumers

ENVIRONMENTAL ASSESSMENT WORKSHEET

Note to reviewers The Environmental Assessment Worksheet (EAW) provides information about a project that may have the potential for significant environmental effects This EAW was prepared by the Minnesota Pollution Control Agency (MPCA) acting as the Responsible Governmental Unit (RGU) to determine whether an Environmental Impact Statement (EIS) should be prepared The project proposer supplied reasonably accessible data for but did not complete the final worksheet Comments on the EAW must be submitted to the MPCA during the 30-day comment period which begins with notice of the availability of the EAW in the Minnesota Environmental Quality Board (EQB) EQB Monitor Comments on the EAW should address the accuracy and completeness of information potential impacts that are reasonably expected to occur that warrant further investigation and the need for an EIS A copy of the EAW may be obtained from the MPCA by calling 651-757-2101 An electronic version of the completed EAW is available at the MPCA website at httpwwwpcastatemnusnewseawindexhtmlopen-eaw 1 Project Title Becker Ash Landfill Expansion 2 Proposer Great River Energy 3 RGU Minnesota Pollution Control Agency Contact Person Matt Herman Contact Person William Lynott

and Title Environmental Compliance Coordinator

and Title

Planner Principal

Address 12300 Elm Creek Boulevard Address 520 Lafayette Road North Maple Grove Minnesota 55369 St Paul Minnesota 55155-4194 Phone 763-445-5204 Phone 651-757-2587 Fax 763-445-5235 Fax 651-297-2343 E-mail mherman2GREnergycom E-mail williamlynottstatemnus 4 Reason for EAW Preparation

EIS Scoping

Mandatory EAW

X

Citizen Petition

RGU Discretion

Proposer Volunteered

+ If EAW or EIS is mandatory give EQB rule

category subpart number and name

Minn R 44104300 subp 17G (MSW Ash Landfill) 5 Project Location County Sherburne City Becker SW 14 SW 14 Section 7 Township 33N Range 28W

GPS Coordinates N 453613 W 938785

Tax Parcel Number 60-007-3200

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 2 Worksheet

The following are attached to the EAW middot Figure 1 StateCounty Location Map middot Figure 2 Sherburne County Map middot Figure 3 US Geological Survey 30 x 60 Quadrangle Map middot Figure 4 Site Map middot Figure 5 Liner Detail middot Figure 6 Alternate Liner Design middot Figure 7 Leachate Sump Plan View middot Figure 8 Leachate Sump Section middot Figure 9 Final Cover middot Figure 10 Proposed Base Grades middot Figure 11 Proposed Final Grades middot Figure 12 Site Cross Section A ndash Arsquo middot Figure 13 Site Cross Section B ndash Brsquo middot Figure 14 Stormwater Control System Details middot Figure 15 Zoning Map middot Figure 16 Comprehensive Plan Land Use Map

middot Appendix A Minnesota Department of Natural Resources (DNR) ndash Natural Heritage Review middot Appendix B US Department of Agriculture (USDA) Soil Survey middot Appendix C State Historic Preservation Office (SHPO) Review middot Appendix D Table 1 Leachate Quality Summary 6 Description

a Provide a project summary of 50 words or less to be published in the EQB Monitor Great River Energy (GRE) proposes to expand the existing Becker Ash Landfill to provide needed disposal capacity for refuse-derived fuel ash generated at GRErsquos Elk River Energy Recovery Station power plant The existing landfill is expected to reach its permitted capacity in early 2015 thereby creating a need for additional capacity to continue operation of the power plant The expansion would increase the landfillrsquos storage capacity from 1717300 to 6313300 cubic yards providing approximately 51 years of additional site life at fill rates associated with peak production at the power plant

b Give a complete description of the proposed project and related new construction Attach

additional sheets as necessary Emphasize construction operation methods and features that will cause physical manipulation of the environment or will produce wastes Include modifications to existing equipment or industrial processes and significant demolition removal or remodeling of existing structures Indicate the timing and duration of construction activities Background The Becker Ash Landfill (BAL or Facility) is owned and operated by GRE BAL receives and disposes of refuse-derived fuel (RDF) ash produced at GRErsquos Elk River Energy Recovery Station power plant in Elk River Minnesota BAL is permitted by the MPCA as a Municipal Solid Waste Combustor Ash Landfill is licensed by Sherburne County as an Energy Recovery Ash Landfill and operates under the terms of a Conditional Use Permit from the city of Becker BAL is located in the city of Becker on Sherburne Avenue south of US Highway 10 (see Figures 1 2 and 3) The currently-permitted BAL occupies 196 acres within a 413-acre permitted area on an 858-acre parcel owned by GRE

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 3 Worksheet

BAL is part of an integrated solid waste management system owned and operated by GRE consisting of the processing of mixed municipal solid waste (MSW) into RDF at the Elk River Resource Recovery Facility in Elk River Minnesota combustion of the RDF for electrical generation at the Elk River Energy Recovery Station in Elk River Minnesota and disposal of the ash produced by the combustion process at BAL Current Status As of October 28 2011 there were 214596 cubic yards of volume available for ash disposal within the currently permitted landfill GRE expects ash production rates of approximately 61000 cubic yards per year through the year 2015 Based upon that rate BAL has approximately 35 years of remaining disposal capacity as of October 28 2011 and will be full in April 2015 In order to maintain uninterrupted disposal capacity construction of the proposed expansion must occur during the summer of 2014 Ash production is currently limited by the rate of feedstock delivery to the Elk River Resource Recovery Facility The processing and energy conversion facilities have the capacity to produce approximately 90000 cubic yards of ash per year so an increase in feedstock could shorten the remaining life of BAL by one year to April 2014 in this case construction of the proposed expansion must occur in the summer of 2013 The processing of MSW into RDF at the Elk River Resource Recovery Facility and subsequent combustion of the RDF to generate energy at the Elk River Energy Recovery Station combine to significantly reduce the volume of material that is landfilled resulting in a successful landfill abatement strategy GRE plans to continue long-term operation of those facilities To ensure efficient operation long-term landfill capacity for ash disposal is necessary Development of the proposed expansion is needed to meet long-term operational and landfill abatement goals BAL currently accepts ash only from the GRE Elk River Energy Recovery Station The capacity provided by the proposed expansion will allow GRE to consider accepting ash from other MSW energy recovery facilities These facilities have not been identified and the current permit application does not seek approval for such activities If this is proposed in the future BAL may need to seek the requisite approvals from permitting authorities Additional environmental review may also be required pursuant to rules in effect at that time Proposed Project The proposed project includes expansion of the landfill in two areas as shown on Figure 4 The expansion areas include a contiguous horizontal expansion of 14 acres within the current 413-acre site (Northeast Expansion) and a contiguous horizontal expansion of 279 acres to the south onto a 430-acre site owned by GRE (South Expansion) The proposed project thus consists of a 293-acre expansion of the existing 196-acre landfill resulting in an ultimate landfill footprint of 489 acres The Northeast Expansion would provide approximately 196000 cubic yards of disposal volume Since the footprint is located within the existing site characterization area and within the existing groundwater monitoring network additional hydrogeologic investigation is not required The South Expansion would provide approximately 44 million cubic yards of disposal volume The footprint would be established to maintain a minimum 200-foot buffer from property lines Associated landfill features such as stormwater ponds access roads leachate conveyance and storage facilities and monitoring points would be located within the 200-foot buffer area outside the landfill footprint Phase I and Phase II hydrogeologic investigations have been completed for the South Expansion area

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 4 Worksheet

In total the proposed project would increase the permitted capacity of BAL from 1717300 cubic yards to 6131300 cubic yards for an increase of 4596000 cubic yards At the expected average fill rate of 61000 cubic yards annually the site life would be increased by approximately 75 years The maximum annual ash production volume (assuming peak production at the power plant) is 90000 cubic yards which results in an increase of 51 years)

Design Features The proposed expansion will include liner leachate collection and final cover design features that are currently in place at the existing Facility as described below Liner The liner system for the proposed expansion will be constructed with a Type P liner system as defined by Minn R 70352885 subp 11P Figure 5 shows components of the liner and leachate collection system The liner consists of the following materials (listed from bottom to top)

middot Three-foot thick compacted clay liner middot 40-mil High Density Polyethylene (HDPE) geomembrane middot Synthetic drainage net middot 60-mil HDPE geomembrane middot 12-inch thick sand drainage layer

The sand drainage layer and 60-mil geomembrane function as the primary liner and leachate collection system The synthetic drainage net 40-mil geomembrane and clay liner function as a secondary containment system An alternate design for the secondary liner on slope areas of the expansion as shown on Figure 6 may be proposed as part of the permitting process The alternate design substitutes a geosynthetic clay liner (GCL) for the compacted clay liner The project proposer intends to demonstrate as part of the MPCA permitting process that the proposed alternate liner for slope areas is equivalent to the standard liner and will meet the required performance standards If equivalency is not demonstrated to the satisfaction of the MPCA the standard liner will be constructed throughout the expansion area Leachate Collection and Removal System The leachate collection system for the proposed expansion meets the requirements of Minn R 70352885 subp 13 Figure 5 shows a cut-away perspective view of a typical leachate collection trench The leachate collection system for the primary liner consists of a six-inch diameter perforated polyethylene pipe and two-stage aggregate filter installed in trenches and a collection sump with extraction pump The secondary leachate collection system consists of three layers of synthetic drainage net installed between the primary and secondary liners in the trenches and a separate collection sump and extraction pump A leak detection lysimeter will be placed beneath both the primary and secondary sumps Figures 7 and 8 show cross sections of the primary and secondary sump designs Separate leachate collection systems and sumps will be constructed for the Northeast and South Expansion areas

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 5 Worksheet

Leachate will be pumped from the primary and secondary sumps through a double-wall forcemain to double-wall storage tanks for temporary storage Liquid level in the sump is monitored and controlled using automated level-control equipment Leachate will be pumped from the storage tanks into tank trucks and hauled for off-site treatment as described in Item 18 below Final Cover The final cover system for the proposed expansion is the same final cover design that is currently permitted for BAL The final cover is a performance-equivalent alternate design to that specified in Minn R 70352885 subp 10C3 for which a variance was granted by the MPCA in 1995 The final cover design prescribed by the aforementioned rule consists of the following components (listed from bottom to top)

middot Minimum 2-foot thick clay barrier layer middot Minimum 30 mil synthetic membrane middot Minimum 6-inch thick drainage layer middot Minimum 42-inch thick top layer of which the top 6 inches is topsoil

Figure 9 shows a cut-away perspective view of the final cover system which has been shown to sufficiently restrict infiltration into the landfill The currently-permitted final cover system will be extended over the expansion areas and consists of the following components (listed from bottom to top)

middot Zero to 6-inch-thick buffer layer middot GCL barrier layer middot 40-mil LLDPE geomembrane middot 12-inch-thick sand drainage layer middot 12-inch-thick rooting soil layer middot 6-inch-thick top soil layer middot Vegetation

Liner Grades The proposed grades for the top of the primary liner are shown in Figure 10 The elevations are based upon providing a minimum 5-foot separation distance from the expansion liner low-point to the historic high water table elevation and providing slopes to promote leachate drainage across the liner The Northeast Expansion will consist of a single cell with two percent slopes on the floor of the liner and a leachate collection pipe and sump The South Expansion will be constructed as six cells Each cell will have slopes floor slopes of two to three percent with a central leachate collection pipe All leachate collection pipes in the South Expansion drain to a common leachate header pipe that in turn drains to a collection sump that serves all six cells Final Cover Grades The proposed final cover grades are shown on Figure 11 The side slopes will be constructed at a slope of 3 horizontal to 1 vertical (3H1V) with benches spaced not more than 40 feet vertically as currently approved The maximum elevation is 1099 feet above mean sea level The minimum final cover slope is three percent Figures 12 and 13 contain site cross sections showing the liner and final cover grades along with the existing topography and water table elevation

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 6 Worksheet

Construction The BAL expansion will be constructed sequentially The liner and leachate collection system along with the perimeter berm roadways and drainage features will be constructed first before the currently operating cells reach final grades This stage of construction includes topsoil stripping soil excavation placement and compaction of excavated soil for berm construction placement and compaction of the clay liner installation of geomembranes and synthetic drainage nets screening and placement of excavated sand for drainage layer placement of topsoil on perimeter berms and turf establishment As current and future areas reach final grades final cover and surface water controls will be constructed Construction includes installation of GCL and geomembrane layers screening and placement of sand for drainage layers placement of soil for rooting soil layer installation of catch basins manholes and stormwater pipes placement of topsoil on final cover areas and turf establishment Initial construction is expected to begin as early as the summer of 2013 The schedule for construction is dependent on the rate of ash disposal and will be spread over the lifetime of the facility with the final closure to occur after all disposal activities have been completed Operations Hours of operation are generally from 300 am to 400 pm seven days per week Ash deliveries typically arrive between 300 am and 200 pm The landfill operators generally spread and compact ash and engage in other related activities such as spreading cover soil between 600 am and 400 pm Operating hours sometimes vary to coordinate with plant outages or other power-plant-related operations which affect the ash production rate Ash is hauled to the site in dump trucks and placed directly in the active disposal area Approximately 13-truck trips are made per day Ash is spread in approximate eight-inch lifts and compacted Previously placed ash is covered within 48 hours with either a lift of fresh ash or soil Areas that are inactive for 30 days or more are covered with intermediate cover soil Leachate is pumped using automated pumping systems from collection sumps through a double-walled forcemain and into two 12000-gallon double-walled storage tanks for temporary storage The tanks have provided adequate storage for typical leachate volumes generated during normal facility operations During future phases of landfill development the amount of open fill area within the landfill at any given time is not expected to increase significantly from current conditions therefore the volume provided by the existing tanks should be sufficient to accommodate leachate generated within the new cells Leachate from the storage tanks is pumped into 6000-gallon-capacity tank trucks for transport and off-site treatment Tank truck loading occurs inside an existing on-site building Since the leachate generation rate varies with the amount of precipitation occurring at the site the leachate hauling frequency also varies Since operation began at BAL the average number of loads of leachate hauled per year has been approximately 400 Two to four loads are hauled per day during the peak rainfall season in the summer and one to two loads are hauled per week during the winter The Becker Wastewater Treatment Facility (WWTF) serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the Metropolitan Council Environmental Services (MCES) Third and Commercial discharge site in St Paul for use in the event that Becker would be unable to accept leachate

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

1_State L

ocation M

apd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

2_Sherburne C

ounty M

apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

960

960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

4_

Existing C

onditio

nsd

gn

pdfpltcfg

1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

OCCURRED IN THIS AREA SINCE THE TOPOGRAPHY WAS GENERATED NOVEMBER 2005 TOPOGRAPHY ONLY ROW CROP PRODUCTION HAS4 CONTOURS WITHIN THE SOUTH HALF OF THE PROPERTY REPRESENT

2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Becker Minnesota

LANDFILL EXPANSION

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LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

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wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 3 Worksheet

BAL is part of an integrated solid waste management system owned and operated by GRE consisting of the processing of mixed municipal solid waste (MSW) into RDF at the Elk River Resource Recovery Facility in Elk River Minnesota combustion of the RDF for electrical generation at the Elk River Energy Recovery Station in Elk River Minnesota and disposal of the ash produced by the combustion process at BAL Current Status As of October 28 2011 there were 214596 cubic yards of volume available for ash disposal within the currently permitted landfill GRE expects ash production rates of approximately 61000 cubic yards per year through the year 2015 Based upon that rate BAL has approximately 35 years of remaining disposal capacity as of October 28 2011 and will be full in April 2015 In order to maintain uninterrupted disposal capacity construction of the proposed expansion must occur during the summer of 2014 Ash production is currently limited by the rate of feedstock delivery to the Elk River Resource Recovery Facility The processing and energy conversion facilities have the capacity to produce approximately 90000 cubic yards of ash per year so an increase in feedstock could shorten the remaining life of BAL by one year to April 2014 in this case construction of the proposed expansion must occur in the summer of 2013 The processing of MSW into RDF at the Elk River Resource Recovery Facility and subsequent combustion of the RDF to generate energy at the Elk River Energy Recovery Station combine to significantly reduce the volume of material that is landfilled resulting in a successful landfill abatement strategy GRE plans to continue long-term operation of those facilities To ensure efficient operation long-term landfill capacity for ash disposal is necessary Development of the proposed expansion is needed to meet long-term operational and landfill abatement goals BAL currently accepts ash only from the GRE Elk River Energy Recovery Station The capacity provided by the proposed expansion will allow GRE to consider accepting ash from other MSW energy recovery facilities These facilities have not been identified and the current permit application does not seek approval for such activities If this is proposed in the future BAL may need to seek the requisite approvals from permitting authorities Additional environmental review may also be required pursuant to rules in effect at that time Proposed Project The proposed project includes expansion of the landfill in two areas as shown on Figure 4 The expansion areas include a contiguous horizontal expansion of 14 acres within the current 413-acre site (Northeast Expansion) and a contiguous horizontal expansion of 279 acres to the south onto a 430-acre site owned by GRE (South Expansion) The proposed project thus consists of a 293-acre expansion of the existing 196-acre landfill resulting in an ultimate landfill footprint of 489 acres The Northeast Expansion would provide approximately 196000 cubic yards of disposal volume Since the footprint is located within the existing site characterization area and within the existing groundwater monitoring network additional hydrogeologic investigation is not required The South Expansion would provide approximately 44 million cubic yards of disposal volume The footprint would be established to maintain a minimum 200-foot buffer from property lines Associated landfill features such as stormwater ponds access roads leachate conveyance and storage facilities and monitoring points would be located within the 200-foot buffer area outside the landfill footprint Phase I and Phase II hydrogeologic investigations have been completed for the South Expansion area

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 4 Worksheet

In total the proposed project would increase the permitted capacity of BAL from 1717300 cubic yards to 6131300 cubic yards for an increase of 4596000 cubic yards At the expected average fill rate of 61000 cubic yards annually the site life would be increased by approximately 75 years The maximum annual ash production volume (assuming peak production at the power plant) is 90000 cubic yards which results in an increase of 51 years)

Design Features The proposed expansion will include liner leachate collection and final cover design features that are currently in place at the existing Facility as described below Liner The liner system for the proposed expansion will be constructed with a Type P liner system as defined by Minn R 70352885 subp 11P Figure 5 shows components of the liner and leachate collection system The liner consists of the following materials (listed from bottom to top)

middot Three-foot thick compacted clay liner middot 40-mil High Density Polyethylene (HDPE) geomembrane middot Synthetic drainage net middot 60-mil HDPE geomembrane middot 12-inch thick sand drainage layer

The sand drainage layer and 60-mil geomembrane function as the primary liner and leachate collection system The synthetic drainage net 40-mil geomembrane and clay liner function as a secondary containment system An alternate design for the secondary liner on slope areas of the expansion as shown on Figure 6 may be proposed as part of the permitting process The alternate design substitutes a geosynthetic clay liner (GCL) for the compacted clay liner The project proposer intends to demonstrate as part of the MPCA permitting process that the proposed alternate liner for slope areas is equivalent to the standard liner and will meet the required performance standards If equivalency is not demonstrated to the satisfaction of the MPCA the standard liner will be constructed throughout the expansion area Leachate Collection and Removal System The leachate collection system for the proposed expansion meets the requirements of Minn R 70352885 subp 13 Figure 5 shows a cut-away perspective view of a typical leachate collection trench The leachate collection system for the primary liner consists of a six-inch diameter perforated polyethylene pipe and two-stage aggregate filter installed in trenches and a collection sump with extraction pump The secondary leachate collection system consists of three layers of synthetic drainage net installed between the primary and secondary liners in the trenches and a separate collection sump and extraction pump A leak detection lysimeter will be placed beneath both the primary and secondary sumps Figures 7 and 8 show cross sections of the primary and secondary sump designs Separate leachate collection systems and sumps will be constructed for the Northeast and South Expansion areas

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 5 Worksheet

Leachate will be pumped from the primary and secondary sumps through a double-wall forcemain to double-wall storage tanks for temporary storage Liquid level in the sump is monitored and controlled using automated level-control equipment Leachate will be pumped from the storage tanks into tank trucks and hauled for off-site treatment as described in Item 18 below Final Cover The final cover system for the proposed expansion is the same final cover design that is currently permitted for BAL The final cover is a performance-equivalent alternate design to that specified in Minn R 70352885 subp 10C3 for which a variance was granted by the MPCA in 1995 The final cover design prescribed by the aforementioned rule consists of the following components (listed from bottom to top)

middot Minimum 2-foot thick clay barrier layer middot Minimum 30 mil synthetic membrane middot Minimum 6-inch thick drainage layer middot Minimum 42-inch thick top layer of which the top 6 inches is topsoil

Figure 9 shows a cut-away perspective view of the final cover system which has been shown to sufficiently restrict infiltration into the landfill The currently-permitted final cover system will be extended over the expansion areas and consists of the following components (listed from bottom to top)

middot Zero to 6-inch-thick buffer layer middot GCL barrier layer middot 40-mil LLDPE geomembrane middot 12-inch-thick sand drainage layer middot 12-inch-thick rooting soil layer middot 6-inch-thick top soil layer middot Vegetation

Liner Grades The proposed grades for the top of the primary liner are shown in Figure 10 The elevations are based upon providing a minimum 5-foot separation distance from the expansion liner low-point to the historic high water table elevation and providing slopes to promote leachate drainage across the liner The Northeast Expansion will consist of a single cell with two percent slopes on the floor of the liner and a leachate collection pipe and sump The South Expansion will be constructed as six cells Each cell will have slopes floor slopes of two to three percent with a central leachate collection pipe All leachate collection pipes in the South Expansion drain to a common leachate header pipe that in turn drains to a collection sump that serves all six cells Final Cover Grades The proposed final cover grades are shown on Figure 11 The side slopes will be constructed at a slope of 3 horizontal to 1 vertical (3H1V) with benches spaced not more than 40 feet vertically as currently approved The maximum elevation is 1099 feet above mean sea level The minimum final cover slope is three percent Figures 12 and 13 contain site cross sections showing the liner and final cover grades along with the existing topography and water table elevation

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 6 Worksheet

Construction The BAL expansion will be constructed sequentially The liner and leachate collection system along with the perimeter berm roadways and drainage features will be constructed first before the currently operating cells reach final grades This stage of construction includes topsoil stripping soil excavation placement and compaction of excavated soil for berm construction placement and compaction of the clay liner installation of geomembranes and synthetic drainage nets screening and placement of excavated sand for drainage layer placement of topsoil on perimeter berms and turf establishment As current and future areas reach final grades final cover and surface water controls will be constructed Construction includes installation of GCL and geomembrane layers screening and placement of sand for drainage layers placement of soil for rooting soil layer installation of catch basins manholes and stormwater pipes placement of topsoil on final cover areas and turf establishment Initial construction is expected to begin as early as the summer of 2013 The schedule for construction is dependent on the rate of ash disposal and will be spread over the lifetime of the facility with the final closure to occur after all disposal activities have been completed Operations Hours of operation are generally from 300 am to 400 pm seven days per week Ash deliveries typically arrive between 300 am and 200 pm The landfill operators generally spread and compact ash and engage in other related activities such as spreading cover soil between 600 am and 400 pm Operating hours sometimes vary to coordinate with plant outages or other power-plant-related operations which affect the ash production rate Ash is hauled to the site in dump trucks and placed directly in the active disposal area Approximately 13-truck trips are made per day Ash is spread in approximate eight-inch lifts and compacted Previously placed ash is covered within 48 hours with either a lift of fresh ash or soil Areas that are inactive for 30 days or more are covered with intermediate cover soil Leachate is pumped using automated pumping systems from collection sumps through a double-walled forcemain and into two 12000-gallon double-walled storage tanks for temporary storage The tanks have provided adequate storage for typical leachate volumes generated during normal facility operations During future phases of landfill development the amount of open fill area within the landfill at any given time is not expected to increase significantly from current conditions therefore the volume provided by the existing tanks should be sufficient to accommodate leachate generated within the new cells Leachate from the storage tanks is pumped into 6000-gallon-capacity tank trucks for transport and off-site treatment Tank truck loading occurs inside an existing on-site building Since the leachate generation rate varies with the amount of precipitation occurring at the site the leachate hauling frequency also varies Since operation began at BAL the average number of loads of leachate hauled per year has been approximately 400 Two to four loads are hauled per day during the peak rainfall season in the summer and one to two loads are hauled per week during the winter The Becker Wastewater Treatment Facility (WWTF) serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the Metropolitan Council Environmental Services (MCES) Third and Commercial discharge site in St Paul for use in the event that Becker would be unable to accept leachate

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

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3272012

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3272012

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wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 4 Worksheet

In total the proposed project would increase the permitted capacity of BAL from 1717300 cubic yards to 6131300 cubic yards for an increase of 4596000 cubic yards At the expected average fill rate of 61000 cubic yards annually the site life would be increased by approximately 75 years The maximum annual ash production volume (assuming peak production at the power plant) is 90000 cubic yards which results in an increase of 51 years)

Design Features The proposed expansion will include liner leachate collection and final cover design features that are currently in place at the existing Facility as described below Liner The liner system for the proposed expansion will be constructed with a Type P liner system as defined by Minn R 70352885 subp 11P Figure 5 shows components of the liner and leachate collection system The liner consists of the following materials (listed from bottom to top)

middot Three-foot thick compacted clay liner middot 40-mil High Density Polyethylene (HDPE) geomembrane middot Synthetic drainage net middot 60-mil HDPE geomembrane middot 12-inch thick sand drainage layer

The sand drainage layer and 60-mil geomembrane function as the primary liner and leachate collection system The synthetic drainage net 40-mil geomembrane and clay liner function as a secondary containment system An alternate design for the secondary liner on slope areas of the expansion as shown on Figure 6 may be proposed as part of the permitting process The alternate design substitutes a geosynthetic clay liner (GCL) for the compacted clay liner The project proposer intends to demonstrate as part of the MPCA permitting process that the proposed alternate liner for slope areas is equivalent to the standard liner and will meet the required performance standards If equivalency is not demonstrated to the satisfaction of the MPCA the standard liner will be constructed throughout the expansion area Leachate Collection and Removal System The leachate collection system for the proposed expansion meets the requirements of Minn R 70352885 subp 13 Figure 5 shows a cut-away perspective view of a typical leachate collection trench The leachate collection system for the primary liner consists of a six-inch diameter perforated polyethylene pipe and two-stage aggregate filter installed in trenches and a collection sump with extraction pump The secondary leachate collection system consists of three layers of synthetic drainage net installed between the primary and secondary liners in the trenches and a separate collection sump and extraction pump A leak detection lysimeter will be placed beneath both the primary and secondary sumps Figures 7 and 8 show cross sections of the primary and secondary sump designs Separate leachate collection systems and sumps will be constructed for the Northeast and South Expansion areas

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 5 Worksheet

Leachate will be pumped from the primary and secondary sumps through a double-wall forcemain to double-wall storage tanks for temporary storage Liquid level in the sump is monitored and controlled using automated level-control equipment Leachate will be pumped from the storage tanks into tank trucks and hauled for off-site treatment as described in Item 18 below Final Cover The final cover system for the proposed expansion is the same final cover design that is currently permitted for BAL The final cover is a performance-equivalent alternate design to that specified in Minn R 70352885 subp 10C3 for which a variance was granted by the MPCA in 1995 The final cover design prescribed by the aforementioned rule consists of the following components (listed from bottom to top)

middot Minimum 2-foot thick clay barrier layer middot Minimum 30 mil synthetic membrane middot Minimum 6-inch thick drainage layer middot Minimum 42-inch thick top layer of which the top 6 inches is topsoil

Figure 9 shows a cut-away perspective view of the final cover system which has been shown to sufficiently restrict infiltration into the landfill The currently-permitted final cover system will be extended over the expansion areas and consists of the following components (listed from bottom to top)

middot Zero to 6-inch-thick buffer layer middot GCL barrier layer middot 40-mil LLDPE geomembrane middot 12-inch-thick sand drainage layer middot 12-inch-thick rooting soil layer middot 6-inch-thick top soil layer middot Vegetation

Liner Grades The proposed grades for the top of the primary liner are shown in Figure 10 The elevations are based upon providing a minimum 5-foot separation distance from the expansion liner low-point to the historic high water table elevation and providing slopes to promote leachate drainage across the liner The Northeast Expansion will consist of a single cell with two percent slopes on the floor of the liner and a leachate collection pipe and sump The South Expansion will be constructed as six cells Each cell will have slopes floor slopes of two to three percent with a central leachate collection pipe All leachate collection pipes in the South Expansion drain to a common leachate header pipe that in turn drains to a collection sump that serves all six cells Final Cover Grades The proposed final cover grades are shown on Figure 11 The side slopes will be constructed at a slope of 3 horizontal to 1 vertical (3H1V) with benches spaced not more than 40 feet vertically as currently approved The maximum elevation is 1099 feet above mean sea level The minimum final cover slope is three percent Figures 12 and 13 contain site cross sections showing the liner and final cover grades along with the existing topography and water table elevation

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 6 Worksheet

Construction The BAL expansion will be constructed sequentially The liner and leachate collection system along with the perimeter berm roadways and drainage features will be constructed first before the currently operating cells reach final grades This stage of construction includes topsoil stripping soil excavation placement and compaction of excavated soil for berm construction placement and compaction of the clay liner installation of geomembranes and synthetic drainage nets screening and placement of excavated sand for drainage layer placement of topsoil on perimeter berms and turf establishment As current and future areas reach final grades final cover and surface water controls will be constructed Construction includes installation of GCL and geomembrane layers screening and placement of sand for drainage layers placement of soil for rooting soil layer installation of catch basins manholes and stormwater pipes placement of topsoil on final cover areas and turf establishment Initial construction is expected to begin as early as the summer of 2013 The schedule for construction is dependent on the rate of ash disposal and will be spread over the lifetime of the facility with the final closure to occur after all disposal activities have been completed Operations Hours of operation are generally from 300 am to 400 pm seven days per week Ash deliveries typically arrive between 300 am and 200 pm The landfill operators generally spread and compact ash and engage in other related activities such as spreading cover soil between 600 am and 400 pm Operating hours sometimes vary to coordinate with plant outages or other power-plant-related operations which affect the ash production rate Ash is hauled to the site in dump trucks and placed directly in the active disposal area Approximately 13-truck trips are made per day Ash is spread in approximate eight-inch lifts and compacted Previously placed ash is covered within 48 hours with either a lift of fresh ash or soil Areas that are inactive for 30 days or more are covered with intermediate cover soil Leachate is pumped using automated pumping systems from collection sumps through a double-walled forcemain and into two 12000-gallon double-walled storage tanks for temporary storage The tanks have provided adequate storage for typical leachate volumes generated during normal facility operations During future phases of landfill development the amount of open fill area within the landfill at any given time is not expected to increase significantly from current conditions therefore the volume provided by the existing tanks should be sufficient to accommodate leachate generated within the new cells Leachate from the storage tanks is pumped into 6000-gallon-capacity tank trucks for transport and off-site treatment Tank truck loading occurs inside an existing on-site building Since the leachate generation rate varies with the amount of precipitation occurring at the site the leachate hauling frequency also varies Since operation began at BAL the average number of loads of leachate hauled per year has been approximately 400 Two to four loads are hauled per day during the peak rainfall season in the summer and one to two loads are hauled per week during the winter The Becker Wastewater Treatment Facility (WWTF) serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the Metropolitan Council Environmental Services (MCES) Third and Commercial discharge site in St Paul for use in the event that Becker would be unable to accept leachate

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

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LANDFILL EXPANSION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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Becker Minnesota

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

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EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 5 Worksheet

Leachate will be pumped from the primary and secondary sumps through a double-wall forcemain to double-wall storage tanks for temporary storage Liquid level in the sump is monitored and controlled using automated level-control equipment Leachate will be pumped from the storage tanks into tank trucks and hauled for off-site treatment as described in Item 18 below Final Cover The final cover system for the proposed expansion is the same final cover design that is currently permitted for BAL The final cover is a performance-equivalent alternate design to that specified in Minn R 70352885 subp 10C3 for which a variance was granted by the MPCA in 1995 The final cover design prescribed by the aforementioned rule consists of the following components (listed from bottom to top)

middot Minimum 2-foot thick clay barrier layer middot Minimum 30 mil synthetic membrane middot Minimum 6-inch thick drainage layer middot Minimum 42-inch thick top layer of which the top 6 inches is topsoil

Figure 9 shows a cut-away perspective view of the final cover system which has been shown to sufficiently restrict infiltration into the landfill The currently-permitted final cover system will be extended over the expansion areas and consists of the following components (listed from bottom to top)

middot Zero to 6-inch-thick buffer layer middot GCL barrier layer middot 40-mil LLDPE geomembrane middot 12-inch-thick sand drainage layer middot 12-inch-thick rooting soil layer middot 6-inch-thick top soil layer middot Vegetation

Liner Grades The proposed grades for the top of the primary liner are shown in Figure 10 The elevations are based upon providing a minimum 5-foot separation distance from the expansion liner low-point to the historic high water table elevation and providing slopes to promote leachate drainage across the liner The Northeast Expansion will consist of a single cell with two percent slopes on the floor of the liner and a leachate collection pipe and sump The South Expansion will be constructed as six cells Each cell will have slopes floor slopes of two to three percent with a central leachate collection pipe All leachate collection pipes in the South Expansion drain to a common leachate header pipe that in turn drains to a collection sump that serves all six cells Final Cover Grades The proposed final cover grades are shown on Figure 11 The side slopes will be constructed at a slope of 3 horizontal to 1 vertical (3H1V) with benches spaced not more than 40 feet vertically as currently approved The maximum elevation is 1099 feet above mean sea level The minimum final cover slope is three percent Figures 12 and 13 contain site cross sections showing the liner and final cover grades along with the existing topography and water table elevation

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 6 Worksheet

Construction The BAL expansion will be constructed sequentially The liner and leachate collection system along with the perimeter berm roadways and drainage features will be constructed first before the currently operating cells reach final grades This stage of construction includes topsoil stripping soil excavation placement and compaction of excavated soil for berm construction placement and compaction of the clay liner installation of geomembranes and synthetic drainage nets screening and placement of excavated sand for drainage layer placement of topsoil on perimeter berms and turf establishment As current and future areas reach final grades final cover and surface water controls will be constructed Construction includes installation of GCL and geomembrane layers screening and placement of sand for drainage layers placement of soil for rooting soil layer installation of catch basins manholes and stormwater pipes placement of topsoil on final cover areas and turf establishment Initial construction is expected to begin as early as the summer of 2013 The schedule for construction is dependent on the rate of ash disposal and will be spread over the lifetime of the facility with the final closure to occur after all disposal activities have been completed Operations Hours of operation are generally from 300 am to 400 pm seven days per week Ash deliveries typically arrive between 300 am and 200 pm The landfill operators generally spread and compact ash and engage in other related activities such as spreading cover soil between 600 am and 400 pm Operating hours sometimes vary to coordinate with plant outages or other power-plant-related operations which affect the ash production rate Ash is hauled to the site in dump trucks and placed directly in the active disposal area Approximately 13-truck trips are made per day Ash is spread in approximate eight-inch lifts and compacted Previously placed ash is covered within 48 hours with either a lift of fresh ash or soil Areas that are inactive for 30 days or more are covered with intermediate cover soil Leachate is pumped using automated pumping systems from collection sumps through a double-walled forcemain and into two 12000-gallon double-walled storage tanks for temporary storage The tanks have provided adequate storage for typical leachate volumes generated during normal facility operations During future phases of landfill development the amount of open fill area within the landfill at any given time is not expected to increase significantly from current conditions therefore the volume provided by the existing tanks should be sufficient to accommodate leachate generated within the new cells Leachate from the storage tanks is pumped into 6000-gallon-capacity tank trucks for transport and off-site treatment Tank truck loading occurs inside an existing on-site building Since the leachate generation rate varies with the amount of precipitation occurring at the site the leachate hauling frequency also varies Since operation began at BAL the average number of loads of leachate hauled per year has been approximately 400 Two to four loads are hauled per day during the peak rainfall season in the summer and one to two loads are hauled per week during the winter The Becker Wastewater Treatment Facility (WWTF) serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the Metropolitan Council Environmental Services (MCES) Third and Commercial discharge site in St Paul for use in the event that Becker would be unable to accept leachate

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

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COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

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PROJECT LOCATION

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MW-4

MW-1 MW-2B

MW-2A

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P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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SITE MAP

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LANDFILL EXPANSION

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 9

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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6

9561

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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FIGURE 11

LEGEND

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EXISTING

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BOUNDARY

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CONTOURS

PROPOSED

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RUNOFF FLOW

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PONDS

STORMWATER

NORTHEAST EXPANSION

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EXISTING STORMWATER

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333

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FINAL COVER

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LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

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FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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VERTICAL SCALE EXAGGERATED 5 TIMES

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CURRENTLY APPROVED

FINAL GRADE

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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LEGEND

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CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

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GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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RE1005 B

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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16 _

Co

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nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 6 Worksheet

Construction The BAL expansion will be constructed sequentially The liner and leachate collection system along with the perimeter berm roadways and drainage features will be constructed first before the currently operating cells reach final grades This stage of construction includes topsoil stripping soil excavation placement and compaction of excavated soil for berm construction placement and compaction of the clay liner installation of geomembranes and synthetic drainage nets screening and placement of excavated sand for drainage layer placement of topsoil on perimeter berms and turf establishment As current and future areas reach final grades final cover and surface water controls will be constructed Construction includes installation of GCL and geomembrane layers screening and placement of sand for drainage layers placement of soil for rooting soil layer installation of catch basins manholes and stormwater pipes placement of topsoil on final cover areas and turf establishment Initial construction is expected to begin as early as the summer of 2013 The schedule for construction is dependent on the rate of ash disposal and will be spread over the lifetime of the facility with the final closure to occur after all disposal activities have been completed Operations Hours of operation are generally from 300 am to 400 pm seven days per week Ash deliveries typically arrive between 300 am and 200 pm The landfill operators generally spread and compact ash and engage in other related activities such as spreading cover soil between 600 am and 400 pm Operating hours sometimes vary to coordinate with plant outages or other power-plant-related operations which affect the ash production rate Ash is hauled to the site in dump trucks and placed directly in the active disposal area Approximately 13-truck trips are made per day Ash is spread in approximate eight-inch lifts and compacted Previously placed ash is covered within 48 hours with either a lift of fresh ash or soil Areas that are inactive for 30 days or more are covered with intermediate cover soil Leachate is pumped using automated pumping systems from collection sumps through a double-walled forcemain and into two 12000-gallon double-walled storage tanks for temporary storage The tanks have provided adequate storage for typical leachate volumes generated during normal facility operations During future phases of landfill development the amount of open fill area within the landfill at any given time is not expected to increase significantly from current conditions therefore the volume provided by the existing tanks should be sufficient to accommodate leachate generated within the new cells Leachate from the storage tanks is pumped into 6000-gallon-capacity tank trucks for transport and off-site treatment Tank truck loading occurs inside an existing on-site building Since the leachate generation rate varies with the amount of precipitation occurring at the site the leachate hauling frequency also varies Since operation began at BAL the average number of loads of leachate hauled per year has been approximately 400 Two to four loads are hauled per day during the peak rainfall season in the summer and one to two loads are hauled per week during the winter The Becker Wastewater Treatment Facility (WWTF) serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the Metropolitan Council Environmental Services (MCES) Third and Commercial discharge site in St Paul for use in the event that Becker would be unable to accept leachate

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

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COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

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LANDFILL EXPANSION

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FIGURE 3EAW - BECKER ASH

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PROJECT LOCATION

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ASH LANDFILL SITE

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P-114

P-115P-113

P-116

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MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

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FIGURE 4

SITE MAP

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FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

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3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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CELL 1

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CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

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95

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6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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1010

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5

95

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6

9561

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

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PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

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PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

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333

333

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500 1000 1500 2000 2661222500900

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EXISTING GROUND SURFACE

FINAL COVER

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BASE GRADES

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WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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EXISTING GROUND SURFACE

FINAL COVER

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BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

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15_

Zonin

gd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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16 _

Co

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nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 7 Worksheet

GRE and the city of Becker are currently working on an agreement that will allow GRE to accept as much as 600 tons of WWTF biosolids from the Becker WWTF The BAL Solid Waste Permit was amended to allow the disposal of this material in May of 2012 GRE is currently working on the local government approvals necessary to accept this material Disposal of this material will be conducted in accordance the procedures discussed in the most current Industrial Solid Waste Management Plan Environmental Monitoring There are two forms of environmental monitoring proposed for the expansion The first is leak detection monitoring which takes place at the sumps The secondary liner functions as a leak detection device and backup for the primary liner Leachate that accumulates on the secondary liner will be detected in and pumped from the secondary sump In addition leak detection lysimeters will be constructed below both the primary and secondary sumps in both expansion areas The lysimeters will be monitored for liquid accumulation which provides a means to monitor if the secondary liner is leaking A typical lysimeter is shown on Figure 8 The second form of environmental monitoring is the network of groundwater monitoring wells surrounding the existing landfill and proposed expansion area The monitoring wells are used to assess whether the Facility is impacting the groundwater quality beneath the site The monitoring network surrounding the currently permitted landfill consists of 11 wells that are sampled twice annually A hydrogeologic investigation for the southern expansion area has been conducted during which a total of 29 soil borings and 5 water level piezometers were installed (see Figure 4) Information from the hydrogeologic investigation will be used to develop a network of wells that will be used to monitor the new cells associated with the Southern Expansion Three additional wells have been proposed for installation in this area The existing monitoring points (groundwater monitoring wells and sump lysimeters) will continue to be used for the Northeast Expansion This area is located on the upgradient side (with respect to groundwater flow direction) of the BAL and it is anticipated that the existing groundwater monitoring systems will provide the required coverage

Summary The proposed expansion would provide additional ash disposal capacity required to facilitate the continued operation of the Elk River Resource Recovery Facility and the Elk River Energy Recovery Station which are important components of an integrated solid waste management system operated by GRE The proposed expansion would occur both within and outside the existing BAL permit boundary and would utilize many existing engineered containment and monitoring features of the BAL The proposed expansion would use the same ash and leachate containment design features (double liner and composite cover sump lysimeters double-wall forcemains and storage tanks) as have been used for the past 20 years at the BAL The effectiveness of these features in preventing environmental impacts has been demonstrated throughout the BAL operating history Monitoring systems and monitoring data as contained in the BAL annual reports to the MPCA indicate that operation of the BAL has not resulted in any adverse environmental impacts

c Explain the project purpose if the project will be carried out by a governmental unit explain the need for the project and identify its beneficiaries The purpose of the proposed expansion is to provide additional disposal capacity for RDF ash The BAL is one component of an integrated solid waste management system that includes processing MSW into fuel for use in electrical generation at the Elk River Energy Recovery Station power plant The ash

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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RE1005 B

AL P

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1_State L

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apd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

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MANAGEMENT

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20

1020

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1030

1030

OA

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9566

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95

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6

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Water

9514

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CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

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FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

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WELL NEST

MONITORING

CONTOURS

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LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

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LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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955

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970

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970

970

970

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970 970975

975

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975

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75

975

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975

975

980

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980

980

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980

980980

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985

985

985

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985

985

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990

990

990

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995

995

1000

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1015

1015

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1025

1025

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1025

1025

1025

1025

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1030

1030

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1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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GRADES

PROPOSED BASE

FIGURE 10

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PROPERTY

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WATER TABLE

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13

13

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945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

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926

925

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935

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1010

1020

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1025

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1035

OA

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9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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980

990

1000

1010

1020

1030

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1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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REG

RE1005 B

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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AW D

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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win

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15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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RE1005 B

AL P

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nDra

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 8 Worksheet

remaining from RDF combustion at the power plant is disposed at the BAL The integrated solid waste management system accomplishes the following environmental goals abatement of unprocessed MSW landfilling conservation of existing landfill airspace and reduction in use of fossil fuels for electrical generation GRE intends to continue RDF combustion at the power plant for the foreseeable future therefore creating continued need for disposal capacity Current ash production projections show that additional disposal capacity will be needed in early 2015 to continue normal operations at the BAL

d Are future stages of this development including development on any other property planned or likely to happen Yes No

e Is this project a subsequent stage of an earlier project Yes No

If yes briefly describe the past development timeline and any past environmental review BAL was originally permitted by Northern States Power Company (NSP) and constructed in 1991 The 1991 permit authorized construction of Cells 1 through 3 with an airspace capacity including waste and cover materials of 720000 cubic yards An EAW was completed as part of the original permitting process The 1991 EAW process concluded with a negative declaration for an EIS (ie the project did not present the potential for significant environmental impacts that would require further study in an EIS) In 1997 the permit was re-issued to NSP and NRG as co-permittees and authorized construction of Cells 4 through 6 with a total facility airspace of 1387318 cubic yards on a footprint of 172 acres A second EAW was completed in December 1999 as part of the permitting process for horizontal and vertical expansion of Cells 4 through 6 again resulting in a negative declaration for an EIS The permit was re-issued in 2000 with a capacity of 1725900 cubic yards on a footprint of 196 acres In 2005 the ownership of BAL transferred from NRG to Resource Recovery Technologies LLC In 2006 a minor modification was made to the permit to change the liner design in Cell 6 to ldquoType Nrdquo (Minn R 70352885 subp 11N) In 2008 another minor modification was made to the permit to change the final cover slopes which resulted in the total capacity decreasing to 1717300 cubic yards In 2010 the permit was transferred to GRE The permit was reissued in 2011 for a five-year period The proposed expansion is a subsequent development of the existing Cells 1-6 of the BAL as shown on Figure 4 Development of the Facility has progressed by construction of new cells as previously constructed cells were filled and were capped Cells 1 through 4 have been filled to their permitted capacity Cells 1-3 and approximately one-third of Cell 4 have received final cover Cells 5 and 6 are being actively filled As described above past environmental review includes two EAWs one of which was completed in 1991 during permitting of the original BAL and another completed in 1999 during expansion permitting for Cell 5 and Cell 6 Both of the previous EAWs are on file with the MPCA and both resulted in negative declarations on the need for an EIS

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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PROJECT LOCATION

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ASH LANDFILL SITE

EXISTING BECKERDISTANCE

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1030

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OA

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95

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8

Water

9514

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CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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REG

RE1005 B

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3

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SLOPE TOP OF CLAY

GEOSYNTHETIC CLAY LINER (GCL)

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EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

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RE1005 B

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

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970 970975

975

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975

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980

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1025

1025

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1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 10

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13

13

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945

945

940

950

960

970

980

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945

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965

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927

926

925

924

936

935

934 93

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932

931

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75

975

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5

95

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6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

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980

990

1000

1010

1020

1030

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1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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REG

RE1005 B

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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REG

RE1005 B

AL P

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nDra

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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16 _

Co

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 9 Worksheet

7 Project Magnitude Data Total Project Area (acres) Expansion Area 486 Acres or Length (miles) NA

Number of Residential Units

Unattached

0

Attached

0

Maximum Units

Per Building

NA

CommercialIndustrialInstitutional Building Area (gross floor space) total square feet

NA

Indicate area of specific uses (in square feet)

Office 0 Manufacturing 0 Retail 0 Other Industrial 293 193 Warehouse 0 Institutional 0 Light Industrial 0 Agricultural 0 Other Commercial (specify) 0 Building height NA If over 2 stories compare to heights of nearby buildings NA

The project area includes the 430 acres of land owned by GRE directly south of the existing landfill parcel plus 42 acres adjacent to the south edge of Cell 6 that are within the currently permitted area plus the 14-acre footprint of the Northeast expansion

The total landfill footprint included in the proposed expansion is 293 acres 237 of which are on the 430 acres not previously permitted 42 acres of which are within the currently permitted area south of Cell 6 and 14 acres for the Northeast expansion

The remaining 193 acres on the 430-acre area that is not currently permitted includes the setback area which is a minimum of 200 feet from the property line This area will include the berms stormwater management structures leachate management facilities access roads and monitoring devices

8 Permits and approvals required List all known local state and federal permits approvals and financial

assistance for the project Include modifications of any existing permits governmental review of plans and all direct and indirect forms of public financial assistance including bond guarantees Tax Increment Financing and infrastructure All of these final decisions are prohibited until all appropriate environmental review has been completed See Minn R 44103100

Table 8-1 Permits and Regulatory Approvals for the Proposed Project

Unit of Government Type of Application Status MPCA Solid Waste Permit Modification Application submitted National Pollutant Discharge Elimination

SystemState Disposal System (NPDESSDS) General Construction Permit

To be obtained

NPDESSDS General Industrial Stormwater Permit Modification

To be obtained

Sherburne County Solid Waste License Modification To be obtained City of Becker Zoning changed (for the430 acres not currently

permitted for landfill use) To be obtained

Conditional Use Permit Modification To be obtained

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

1_State L

ocation M

apd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

2_Sherburne C

ounty M

apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

960

960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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3272012

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CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

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9566

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95

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9561

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 11

LEGEND

N

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CONTOURS

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PROPERTY

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CONTOURS

PROPOSED

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RUNOFF FLOW

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

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FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 10 Worksheet

9 Land use Describe current and recent past land use and development on the site and on adjacent

lands Discuss project compatibility with adjacent and nearby land uses Indicate whether any potential conflicts involve environmental matters Identify any potential environmental hazards due to past site uses such as soil contamination or abandoned storage tanks or proximity to nearby hazardous liquid or gas pipelines The proposed expansion is located on the existing 858-acre parcel in the southern part of the city of Becker Minnesota The current 413-acre permitted area is located within the Industrial Power Generation Zoning District The proposed project would expand the landfill footprint by 14 acres within this area consistent with the current land use The southern 430 acres of the parcel is in the Agricultural Zoning District The proposed project would change the use on the southern 430 acres from agricultural to ash disposal and therefore requires a change in zoning to Industrial Power Generation Nearby land uses are shown on Figure 3 Industrial uses include an aggregate mine located to the west across the Mississippi River the Vonco II Landfill (an industrial waste disposal facility) located to the southeast and the ash management facilities for the Sherco Power Plant located to the north and northwest These Sherco facilities include several lined ponds used for the stabilization and disposal of wet ash from the power plant The land directly west of the BAL is open space and part of the Mississippi River Scenic and Recreational District Directly south and east the land is in agricultural use All of the land surrounding the BAL is owned by Xcel Energy and used as a buffer for the Sherco Power Plant A set of large electrical transmission lines are located adjacent to the southwest corner of the proposed project The land to the east of Sherburne Avenue is agricultural except for the Vonco II Landfill There is one residence within a one-mile radius to the east and several to the southwest across the Mississippi River There are numerous water wells in the vicinity of the landfill however there are no downgradient water supply wells between the site and the Mississippi River The following discussion on vicinity wells is taken from the Phase II Hydrogeologic Investigation Report and Phase III Water Monitoring System Work Plan prepared by Carlson McCain Inc in April 2012

ldquoThere are at least 69 water wells within one mile of the Site The wells nearest the Site on the east side of the Mississippi River primarily consist of monitoring wells surrounding the nearby landfills and surface impoundments and irrigation wells providing water for the numerous agricultural operations in the area On the west side of the Mississippi River the vast majority of the wells are domestic water supply wells The nearest domestic well is located approximately frac12 mile east (upgradient) of the Site and the nearest public supply well to the Site is approximately 12 miles northwest of the Site There are no water supply wells between the Site and the Mississippi River which is the discharge location for the water table aquifer Further information regarding vicinity water wells including well location maps and well logs can be found in the Preliminary Evaluation Reportrdquo

There are no known environmental hazards associated with the proposed project site The proposed project is compatible with the surrounding land uses which include other land disposal facilities Semi-annual groundwater sampling and reporting is currently conducted at the existing landfill site Sampling shows that with the exception of nitrates no parameters exceeded their permit-assigned Intervention Limit which is typically one-quarter of the applicable drinking water limits Nitrate concentrations range from 7 to 14 milligrams per liter (mgL) The high nitrate levels are attributed to fertilizer use on surrounding agricultural land

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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REG

RE1005 B

AL P

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AW D

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1_State L

ocation M

apd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

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REG

RE1005 B

AL P

ermit e

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nDra

win

gsE

AW D

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2_Sherburne C

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apd

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

960

960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

PProje

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SLOPE TOP OF CLAY

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3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

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RE1005 B

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9_

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

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960

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960

960

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965

965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

980

980

980

980980

980

985

985

985

985

985

985

990

990

990

990

990

995

995

1000

1000

1005

1005

1005

1010

1010

1010

1015

1015

1015

1015

1015

1015

1015

1015

1020

1020

1020

1020 10

20

1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

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gsE

AW D

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gsFIg10_

Base G

radesd

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N

LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

__

Arsquo

Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

927

3 2

05

SUMP

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

970

970

970

970

970

970 9709

75

975

975

975

975 9

75

975

980

980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFIg11_Fin

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Gradesd

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Brsquo

B

13

13

A

12

Arsquo

12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

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nDra

win

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 11 Worksheet

10 Cover types Estimate the acreage of the site with each of the following cover types before and after development

Table 10-1 Cover Types

Cover Type Before (acres)

After (acres) Cover Type Before

(acres) After

(acres) Types 1-8 wetlands

0 0 Lawnlandscaping (re-vegetated final coverslopes)

0 372

Woodedforest 0 0 Impervious surfaces 0 0 BrushGrassland 56 114 Other (describe)

0 0

Cropland 430 0

TOTAL 486 486 At closure the ash disposal areas will be re-vegetated grassland

11 Fish Wildlife and Ecologically Sensitive Resources a Identify fish and wildlife resources and habitats on or near the site and describe how they would

be affected by the project Describe any measures to be taken to minimize or avoid impacts

The proposed project is located adjacent to the Mississippi River Scenic and Recreational District but will not impair the movement of any wildlife in the area The land surrounding the site is general flat to very gently rolling and locally slopes gradually to the south and west toward the Mississippi River located approximately 2000 feet west of the site The expansion area is in agricultural use and is therefore not considered prime habitat for mammals or bird species Wildlife currently living near the project site is accustomed to the daily operations of the landfill The nearest natural lake or pond to the site is a small unnamed pond approximately 032 acres in size and located 077 miles west of the proposed expansion area west of the Mississippi River Based on a review of the US Fish and Wildlife Service National Wetlands Inventory database there are no wetlands mapped within the proposed expansion area A wetland delineation on the proposed project area was conducted in September 2011 concluding no wetlands on the site The mapped wetland nearest the site occurs within the parcel adjacent to the east of the site and is located approximately 1300 feet east of Cell 5 The wetland is mapped as ldquoFreshwater Emergentrdquo and is 019 acres in size Another freshwater emergent wetland encompassing 12 acres is located approximately 4500 feet south of the southeast corner of the expansion area The proposed project incorporates infiltration ponds designed to contain stormwater runoff from the landfill eliminating off-site discharges of sediment therefore protecting the nearby water resources The proposed groundwater monitoring network surrounding the perimeter of the landfill is designed to detect a release from the Facility This groundwater monitoring network is expected to detect any potential contamination from the Facility that may affect the Mississippi River and other water resources in the area of the site

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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3272012

Becker Minnesota

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

Becker Minnesota

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EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 12

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

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LANDFILL

BECKER ASH

EXISTING

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 12 Worksheet

b Are any state (endangered or threatened) species rare plant communities or other sensitive

ecological resources on or near the site Yes No

If yes describe the resource and how it would be affected by the project Describe any measures that will be taken to minimize or avoid adverse impacts Provide the

license agreement number andor Division of Ecological Resources contact number (ERDB 20120041-0002) from which the data were obtained and attach the response letter from the DNR Division of Ecological Resources Indicate if any additional survey work has been conducted within the site and describe the results The DNR Natural Heritage and Nongame Research Program was contacted to query the Minnesota Natural Heritage database to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed expansion Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project Correspondence from the DNR Natural Heritage and Nongame Research Program is included in Appendix A The DNR response letter indicates that the DNR Heritage staff does not believe the proposed project will negatively affect any known rare features if effective erosion and sediment control practices are implemented As stated in Section 11a above the proposed design incorporates infiltration ponds that will contain runoff from the landfill minimizing off-site discharges of sediment and will therefore protect rare resources that could be affected by runoff Additional detail on proposed stormwater controls is provided in Items 16 and 17 of this EAW

12 Physical Impacts on Water Resources Will the project involve the physical or hydrologic alteration

(dredging filling stream diversion outfall structure diking and impoundment) of any surface waters such as a lake pond wetland stream or drainage ditch Yes No

13 Water Use Will the project involve installation or abandonment of any water wells connection to or

changes in any public water supply or appropriation of any ground or surface water (including dewatering) Yes No

14 Water-related land use management districts Does any part of the project involve a shoreland zoning district a delineated 100-year flood plain or a state or federally designated wild or scenic river land use district Yes No The site on which the existing Facility and the proposed expansion are located borders the Mississippi River Scenic and Recreational District to the west See Figure 16

15 Water Surface Use Will the project change the number or type of watercraft on any water body Yes No

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

PProje

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REG

RE1005 B

AL P

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nDra

win

gsE

AW D

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win

gsFig

1_State L

ocation M

apd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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2_Sherburne C

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apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

960

960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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REG

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AL P

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nDra

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5_

Lin

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

PProje

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3

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SLOPE TOP OF CLAY

GEOSYNTHETIC CLAY LINER (GCL)

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DOUBLE GEOMEMBRANE LINER

3rsquo

DRAINAGE LAYER

3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

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REG

RE1005 B

AL P

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9_

Cover D

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

980

980

980

980980

980

985

985

985

985

985

985

990

990

990

990

990

995

995

1000

1000

1005

1005

1005

1010

1010

1010

1015

1015

1015

1015

1015

1015

1015

1015

1020

1020

1020

1020 10

20

1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFIg10_

Base G

radesd

gn

pdfpltcfg

N

LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

__

Arsquo

Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

927

3 2

05

SUMP

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

970

970

970

970

970

970 9709

75

975

975

975

975 9

75

975

980

980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg11_Fin

al

Gradesd

gn

pdfpltcfg

Brsquo

B

13

13

A

12

Arsquo

12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFIg12_Section Ad

gn

pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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win

gsFig

15_

Zonin

gd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

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win

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 13 Worksheet

16 Erosion and Sedimentation Give the acreage to be graded or excavated and the cubic yards of soil to

be moved 396 acres 538000 cubic yards Describe any steep slopes or highly erodible soils and identify them on the site map Describe any erosion and sedimentation control measures to be used

during and after project construction This includes the acreage for the proposed additional disposal area plus the additional area needed for berms and infiltration ponds The excavated soil will be used on-site to build berms stockpiled for use as cover soils and screened for drainage aggregate Currently stockpiled soil will also be used for these purposes In addition approximately 161000 cubic yards of clay will be imported to the site for construction of the secondary liner system The existing terrain is flat and the soils are not highly susceptible to erosion BAL will control erosion and sedimentation using a combination of temporary and permanent measures known as best management practices (BMPs) Any construction activity disturbing more than one acre of soil including all phases of liner and final cover construction requires an NPDESSDS Construction Stormwater Permit Included with the permit is a Stormwater Pollution Prevention Plan (SWPPP) specific to the proposed construction activity that describes the BMPs to be implemented Typical BMPs used during construction include hay bales silt fence berms and ditches with check dams as necessary Disturbed areas will be seeded and mulched as soon as possible Surface runoff from all constructed features in the expansion area will be routed to the on-site infiltration ponds shown on Figure 11 Therefore there will be no discharge of stormwater containing sediments from the site during construction Housekeeping measures such as the sweeping of tracked sediment on nearby roadways will also be conducted BAL operates under the Minnesota Industrial Stormwater Multi-Sector General Permit number MN R050000 which also includes a SWPPP describing all the activities at the site and the BMPs used to minimize or eliminate the effect of any exposed materials that can generate contaminated runoff The SWPPP will be modified to reflect the expansion after the MPCA permit is issued BMPs include housekeeping measures (picking up trash) and structural measures (using covered dumpsters to store trash requiring trucks hauling ash to be covered with tarps cleaning roadways to prevent tracking of mud or spilled ash having contingencies in place to manage spills of fuels and lubricants) Both the construction permits and the general industrial permit include schedules for inspections and maintenancerepair of the BMPs to ensure they are functioning properly BAL employees undergo annual training to review the requirements in the SWPPP and the implementation inspection and maintenance of BMPs

17 Water Quality ndash Surface-water Runoff a Compare the quantity and quality of site runoff before and after the project Describe permanent

controls to manage or treat runoff Describe any storm-water pollution prevention plans As long as BMPs are used to control runoff from the site there will be an unnoticeable difference in the quantity and quality of site runoff before and after the project Due to the flat terrain and permeable soils the undeveloped areas of the site currently produce very little runoff After development runoff from the proposed expansion will be routed to on-site infiltration ponds minimizing the volume of runoff that leaves the site The approximate locations of the ponds are

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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3272012

Becker Minnesota

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MW-4

MW-1 MW-2B

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P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 4

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FIGURE 5

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LANDFILL EXPANSION

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 9

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3272012

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 12

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12300 Elm Creek Boulevard

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

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PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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LANDFILL EXPANSION

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FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 14 Worksheet

shown in Figure 11 however the precise location and size may be adjusted during the permitting phase of the proposal to comply with technical requirements As described in Item 16 above the Facility is required to prepare a SWPPP which will be updated to reflect the expansion area The design of the landfill incorporates permanent stormwater management features as required in the MPCA Solid Waste Rules Benches will be constructed on the 3H1V slopes at intervals of no more than 40 feet vertically to minimize erosion Runoff will be collected at the benches and will drain to catch basins and then be conveyed via pipes to ground-level infiltration basins Energy dissipation manholes will be installed at the bottom of each pipe system to reduce the stormwater discharge velocity for erosion control at the outlets The infiltration ponds will be designed to fully contain runoff for the 100-year 24-hour rainfall event with no surface discharge Figure 14 shows the proposed design of the benches and piping system

b Identify routes and receiving water bodies for runoff from the site include major downstream water bodies as well as the immediate receiving waters Estimate impact runoff on the quality of receiving waters All surface water runoff will be routed to on-site infiltration ponds Stormwater routed to the ponds discharges through infiltration and evaporation The ponds would not discharge to a receiving water

18 Water Quality ndash Wastewater a Describe sources composition and quantities of all sanitary municipal and industrial wastewater

produced or treated at the site Wastewater generated at the BAL consists of water that comes into contact with the RDF ash and is referred to as leachate Leachate is collected by the leachate collection system pumped through double-wall forcemains temporarily stored in double-wall tanks and hauled by tank truck for off-site treatment at licensed wastewater treatment plants or recycled at the GRE Elk River Energy Recovery Station in the ash quenching system The proposed expansion will utilize new and existing leachate collection transmission and storage systems Leachate quantities and chemical composition have been monitored since the BAL began receiving ash in 1991 The average volume produced is 190105 gallons per month or 2281000 gallons per year Appendix D shows the analytical results of quarterly samples of leachate for the last three years along with the historic median minimum and maximum concentrations It is anticipated that neither the chemical composition nor volume of will vary significantly from historical composition and volume Sanitary wastewater generated at the BAL operations office is treated on site via an individual sewer treatment system (ISTS) that was installed in 1991 in accordance with applicable rules No increase in the volume of sanitary wastewater is expected due to the proposed project

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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2_Sherburne C

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

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960

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960

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970

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970

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980

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990

990

1000

1000

1010

1010

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1020

1020

1020

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20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

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Water

9514

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CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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RE1005 B

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

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FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

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WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

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955

955

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955

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965

965

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965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

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75

975

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975

975

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980

980

980

980

980

980

980

980980

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985

985

985

985

985

985

990

990

990

990

990

995

995

1000

1000

1005

1005

1005

1010

1010

1010

1015

1015

1015

1015

1015

1015

1015

1015

1020

1020

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1020 10

20

1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

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Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

927

3 2

05

SUMP

950 950955

955

955

955

955

955

955

955

955

955

955

955

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960

960

960

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960

960

960

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965

965

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970

970

970

970

970

970 9709

75

975

975

975

975 9

75

975

980

980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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AW D

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Brsquo

B

13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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REG

RE1005 B

AL P

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nDra

win

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

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AW D

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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REG

RE1005 B

AL P

ermit e

xpansio

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win

gsE

AW D

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win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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REG

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16 _

Co

mp Pla

nd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 15 Worksheet

b Describe waste treatment methods or pollution prevention efforts and give estimates of

composition after treatment Identify receiving waters including major downstream water bodies (identifying any impaired waters) and estimate the discharge impact on the quality of receiving waters If the project involves on-site sewage systems discuss the suitability of site conditions for such systems No leachate is discharged on site or treated for on-site discharge On-site treatment of leachate is limited to the addition of hydrogen peroxide for odor control for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide is added to the leachate at a rate of one gallon of hydrogen peroxide per 2000 gallons of leachate This pre-treatment is performed within the tank truck by the landfill operators at the time of loading Pollution prevention efforts include all of the BAL containment and monitoring systems including

middot Double liners to prevent release of leachate from the Facility middot Double-contained forcemains and storage tanks to prevent leakage during pumping and

storage middot Tank truck loading performed inside the existing garage building to avoid weather-related

issues middot Sump lysimeters to monitor liner performance middot Groundwater monitoring for early detection of release of leachate to groundwater middot Temporary clay capping to minimize leachate generation during operations middot Composite final cover system to minimize leachate production after closure

The ISTS for the sanitary wastewater from the Facilityrsquos office was installed (in 1991) in accordance with rules and regulations and in soils that were deemed suitable for the on-site system

c If wastes will be discharged into a publicly owned treatment facility identify the facility describe any pretreatment provisions and discuss the facilityrsquos ability to handle the volume and composition of wastes identifying any improvements necessary The Becker WWTF serves as the primary off-site treatment plant for BAL leachate GRE also has discharge permits with the St Cloud WWTF and the MCES Third and Commercial discharge site in St Paul for use in the event that the Becker WWTF would be unable to accept leachate The Becker WWTF discharges to the Elk River The Elk River is listed on the 303(d) list as impaired for polychlorinated biphenyl (PCB) and mercury GRE and the city of Becker have a formal agreement in place regarding leachate acceptance GRE is limited to 60000 gallons per day of discharge The Facility is required to monitor the quantity and quality of leachate that it sends to the municipal WWTF Sampling parameters include those listed in the table in Appendix D and periodic sampling for volatile organic compounds semi-volatile organic compounds PCBs and pesticides Pretreatment of the leachate is not required for any of the municipal treatment facilities The Becker WWTF has demonstrated to have sufficient capacity to handle the volume and composition of BAL leachate over the operating history of the BAL No improvements are necessary for these treatment facilities to accommodate the discharge of leachate from the proposed project Since

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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AW D

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win

gsFig

1_State L

ocation M

apd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFig

2_Sherburne C

ounty M

apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

960

960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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win

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4_

Existing C

onditio

nsd

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

OCCURRED IN THIS AREA SINCE THE TOPOGRAPHY WAS GENERATED NOVEMBER 2005 TOPOGRAPHY ONLY ROW CROP PRODUCTION HAS4 CONTOURS WITHIN THE SOUTH HALF OF THE PROPERTY REPRESENT

2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFig

5_

Lin

er_

LC

S D

etaild

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

gsE

AW D

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win

gsFig

6_

GC

L Lin

er Alternated

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

3

1

SLOPE TOP OF CLAY

GEOSYNTHETIC CLAY LINER (GCL)

WITH DRAINAGE NET

DOUBLE GEOMEMBRANE LINER

3rsquo

DRAINAGE LAYER

3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

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CELL 1

CELL 2

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CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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0 100 200

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FIGURE 10

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PROPERTY

BOUNDARY

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CONTOURS

PROPOSED

CONTOURS

WATER TABLE

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13

12

945

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950

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NORTHEAST EXPANSION SOUTH EXPANSION

945

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928

927

926

925

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935

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931

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9604

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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EXISTING GROUND SURFACE

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B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 16 Worksheet

the project is not expected to cause a significant change in the volume or composition of leachate generated from the expansion no impacts are anticipated to the treatment facilities or on the waters that receive the WWTF discharge

19 Geologic hazards and soil conditions a Approximate depth (in feet) to Groundwater 30 minimum 35 average Bedrock 70 minimum 90 average

Describe any of the following geologic site hazards to groundwater and also identify them on the site map sinkholes shallow limestone formations or karst conditions Describe measures to avoid or minimize environmental problems due to any of these hazards There are no geologic hazards present at the site

b Describe the soils on the site giving Natural Resources Conservation Service classifications if

known Discuss soil texture and potential for ground-water contamination from wastes or chemicals spread or spilled onto the soils Discuss any mitigation measures to prevent such contamination Soil descriptions for the proposed project site are provided in Appendix B The US Department of Agriculture Soil Conservation Service web soil survey indicates that the predominant soil located on the site is the Hubbard-Mosford Complex The Hubbard and Mosford soils are very deep excessively drained loamy sands and sandy loams The other soil type present is the Hubbard Loamy Sand which is also a deep excessively drained soil All of the soils at the site have a very low capacity for retaining water The organic matter content is low and natural fertility is low This soil can be cultivated but yields are usually low without irrigation and fertilization Hydrogeologic field investigations encountered four major geologic formations beneath the proposed expansion area 1 Undifferentiated outwash and terrace deposits are present over the entire site and consist of

sandy topsoil and underlying silty sand and gravel The unit as a whole ranges from 3 to 20 feet thick The topsoil is contained in the upper 1 to 25 feet of the outwash Below the topsoil the outwash sand consists of very loose to medium-dense sand with silt and silty sands with a little gravel

2 Glacial till is present immediately beneath the outwash under the entirety of the proposed

expansion area The till consists primarily of medium-dense to very-dense silty sand with gravel Occasional pockets of fine to coarse grained sand and lean clay occur within the till but are not laterally continuous within the unit The till ranges in thickness from 3 to 29 feet

3 A lower outwash layer is present over the entire site and occurs immediately beneath the glacial

till This unit includes a layer of fine alluvium at the top immediately beneath the till and a relatively thicker layer of coarse alluvium at depth The fine alluvium layer ranges from 03 to 15 feet thick and consists of mostly of fine grained silty sand and silt with isolated areas of lean clay The coarse alluvium consists of fine to coarse grained sand and sand with silt with lenses of fine gravel and extends from the bottom of the fine alluvium down to the bedrock surface

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

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1000

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1020

1020

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1020

1020

1030

1030

OA

9604

6

9566

5

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80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

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RE1005 B

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

OCCURRED IN THIS AREA SINCE THE TOPOGRAPHY WAS GENERATED NOVEMBER 2005 TOPOGRAPHY ONLY ROW CROP PRODUCTION HAS4 CONTOURS WITHIN THE SOUTH HALF OF THE PROPERTY REPRESENT

2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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REG

RE1005 B

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nDra

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Lin

er_

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3

1

SLOPE TOP OF CLAY

GEOSYNTHETIC CLAY LINER (GCL)

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3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

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RE1005 B

AL P

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nDra

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9_

Cover D

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

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955

955

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975

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75

975

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990

990

990

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1000

1000

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1010

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1015

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1015

1015

1015

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1015

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1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

__

Arsquo

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CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

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05

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950 950955

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970

970 9709

75

975

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985

985

990

990

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1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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RE1005 B

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15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 17 Worksheet

4 Granite bedrock was encountered at depths ranging from 730 to 125 feet

Due to the coarse-grained nature of the outwash deposits infiltration rates are high in the vicinity of the site As a result spills and leaks can move rapidly downward through the unsaturated zone to the water table The Mississippi River functions as a regional groundwater discharge for the surficial aquifer and controls the groundwater flow direction In the vicinity of the site to the north and east of the river groundwater flow is generally to the southwest toward the river To the south and west of the river channel groundwater flow is to the northeast toward the river There are no potential receptors (water wells) between the Facility and the Mississippi River However engineering controls are in place to mitigate potential groundwater contamination from spills or leaks resulting from the Facility These controls include

middot The existing landfill cells are lined with a double composite liner system and leachate is

collected and disposed of at a permitted water treatment facility middot Tanks containing petroleum and other hazardous materials utilize secondary containment

measures as described in Item 20 middot Groundwater monitoring wells have been installed around the site to provide early

detection of a release to groundwater In addition the Solid Waste Permit requires the BAL to develop a Contingency Action Plan which describes mitigative actions that would be taken in the event of a release to the groundwater

20 Solid Wastes Hazardous Wastes Storage Tanks a Describe types amounts and compositions of solid or hazardous wastes including solid animal

manure sludge and ash produced during construction and operation Identify method and location of disposal For projects generating municipal solid waste indicate if there is a source separation plan describe how the project will be modified for recycling If hazardous waste is generated indicate if there is a hazardous waste minimization plan and routine hazardous waste reduction assessments No solid or hazardous wastes are produced at the Facility The Facility accepts municipal solid waste combustor ash under Minn R 70352885 GRE conducts regular sampling of incoming ash according to Minn R 70352910 and submits annual reports of the results to the MPCA The testing focuses on the metals content of the ash Of the list of metals tested arsenic and mercury are considered to be of the most concern The 2011 annual ash testing report shows that the concentrations of those two metals are not changing in a statistically significant way over time The primary potential impact of ash disposal is a release of leachate to groundwater The leachate collected at the Facility is also routinely sampled and analyzed A detailed discussion of the results is included in the 2011 annual report submitted to the MPCA The concentrations of arsenic and mercury in the leachate are below the laboratory detection limits for most sampling events and in all cases are below the maximum leachable contaminant levels (MLCLs) which are concentrations set by the MPCA to trigger the inclusion of the more conservative ldquoType Prdquo liner design GRE is proposing the Type P design for the expansion as a contingency against future exceedances of the MLCLs No changes to the composition of the ash are expected beyond the normal variability observed in the past data so the arsenic and mercury concentrations should not change significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

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LANDFILL EXPANSION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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3272012

Becker Minnesota

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

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3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 9

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3272012

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 12

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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LANDFILL EXPANSION

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FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 18 Worksheet

b Identify any toxic or hazardous materials to be used or present at the site and identify measures to

be used to prevent them from contaminating groundwater If the use of toxic or hazardous materials will lead to a regulated waste discharge or emission discuss any alternatives considered to minimize or eliminate the waste discharge or emission No toxic or hazardous materials other than fuels and lubricants for operating equipment are present at the site These fuels and lubricants are properly contained

c Indicate the number location size and use of any above or below ground tanks to store

petroleum products or other materials except water Describe any emergency response containment plans Two underground 12000-gallon double-wall fiberglass tanks are used for temporary storage of leachate These tanks are located at the northeast corner of the existing Facility near the officegarage as shown on Figure 4 These tanks would remain in operation to service the proposed expansion A double-contained 990-gallon above ground tank is used to store diesel fuel for off-road equipment at the Facility The tank is installed within a concrete containment barrier Any spills from the tank would be captured in the containment barrier and would be properly managed The proposed expansion would have no effect on the existing storage tank

21 Traffic Parking spaces added 0 Existing spaces (if project involves expansion) 0 Estimated total average daily traffic generated See below

Estimated maximum peak hour traffic generated and time of occurrence See below

Indicate source of trip generation rates used in the estimates

The estimated total average daily traffic generated based on past experience will be 13 to 17 trucks (this includes both ash and leachate haul trucks) and four personal vehicle trips per day Traffic generated by the BAL consists primarily of covered 18-cubic yard capacity dump trucks used for ash hauling and 6000-gallon semi-trailer trucks used for leachate hauling Currently approximately 13 truckloads of ash per day are hauled to the BAL Zero to six truckloads of leachate are hauled per day from the BAL Ash haul-truck traffic travels along Minnesota Highway 10 between Elk River and Becker and on 137th Street between Minnesota Highway 10 and the BAL Ash deliveries typically arrive between 300 am to 200 pm Leachate haul-truck traffic travels from the BAL on 140th Avenue north to Liberty Lane then east to Minnesota Highway 10 then west to Sherburne Avenue then north to Central Avenue then east to the plant entrance With the proposed expansion the BAL would initially continue to operate with the same volume of truck traffic potentially adding two or three additional ash truckloads per day over the next five years Leachate haul truck traffic is not expected to increase significantly

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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RE1005 B

AL P

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1_State L

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

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VONCO II LANDFILL

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990

990

1000

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20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

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FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

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SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3

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SLOPE TOP OF CLAY

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EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

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RE1005 B

AL P

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nDra

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9_

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

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960

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960

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965

965

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965

965

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965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

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985

985

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995

1000

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1015

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1025

1025

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1025

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1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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GRADES

PROPOSED BASE

FIGURE 10

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LINE

PROPERTY

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CONTOURS

PROPOSED

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WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

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927

926

925

924

936

935

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3

932

931

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929

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926

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985

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1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

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Brsquo

B

13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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REG

RE1005 B

AL P

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nDra

win

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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AW D

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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win

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15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

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RE1005 B

AL P

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nDra

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win

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 19 Worksheet

22 Vehicle-related Air Emissions Estimate the effect of the projectrsquos traffic generation on air quality

including carbon monoxide levels Discuss the effect of traffic improvements or other mitigation measures on air quality impacts Currently approximately 13 to 17 truck trips are made tofrom the site each day If future ash generation rates increase as projected up to three additional truck trips per day would be made Current operations at the Facility include the use of dozers loaders and similar equipment for ash placement and compaction No changes to current operations will occur due to the proposed expansion No significant changes in vehicle-related air emissions are expected from the project

23 Stationary Source Air Emissions Describe the type sources quantities and compositions of any

emissions from stationary sources of air emissions such as boilers exhaust stacks or fugitive dust sources Include any hazardous air pollutants (consult EAW Guidelines for a listing) any greenhouse gases (such as carbon dioxide methane and nitrous oxides) and ozone-depleting chemicals (chlorofluorocarbons hydrofluorocarbons perfluorocarbons or sulfur hexafluoride) Also describe any proposed pollution prevention techniques and proposed air pollution control devices Describe the impacts on air quality There are no stationary source emissions associated with the project The proposed expansion will not produce additional significant fugitive dust emissions The only potential fugitive dust emissions are related to routine BAL operations and the proposed expansion would not significantly change existing operations Potential fugitive dust emissions are a function of material characteristics (soil and ash) and operational activities (vehicle types travel distances size of the active working face) Potential fugitive dust emission sources include vehicle traffic placing and spreading ash and wind erosion The ash has initial moisture content of approximately 27 percent when delivered to the site which effectively suppresses fugitive dust emissions from the ash Previously placed ash is covered with fresh ash at least every 48 hours Significant drying of the ash generally does not occur prior to placement of a fresh lift During especially hot dry and windy periods water is applied to ash and exposed soil surfaces as needed to suppress dust emissions The previous 20 years of operations have demonstrated that fugitive dust emissions do not present a significant potential for environmental impact The BAL is formally self-inspected weekly and regularly inspected by state county and city officials The proposed expansion will not change either the material characteristics or operational activities therefore no changes to current levels of fugitive dust emissions are expected

24 Odors noise and dust Will the project generate odors noise or dust during construction or during

operation Yes No

If yes describe sources characteristics duration quantities or intensity and any proposed measures to mitigate adverse impacts Also identify locations of nearby sensitive receptors and estimate impacts on them Discuss potential impacts on human health or quality of life (Note fugitive dust generated by operations may be discussed at item 23 instead of here)

Odor The leachate produces a hydrogen sulfide odor particularly when agitated or heated However the odor is not normally released to the atmosphere because the leachate is contained in a closed system

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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ctsG

REG

RE1005 B

AL P

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nDra

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gsE

AW D

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1_State L

ocation M

apd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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AL P

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nDra

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2_Sherburne C

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

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VONCO II LANDFILL

I-94

PLANT

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SCATTERED

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MANAGEMENT

SHERCO ASH

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960

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960

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960

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970

970

970

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970

970

980

980

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980

980

980

980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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1 EXISTING SITE MONITORING WELLSPIEZOMETERS ARE LABELED P-1xx

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

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FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3

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SLOPE TOP OF CLAY

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EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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AW D

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9_

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

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955

955

955

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955

955

955

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955

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960

960

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960

960

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965

965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

980

980

980

980980

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985

985

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985

985

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990

990

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995

995

1000

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1005

1005

1010

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1015

1015

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1015

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20

1020

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1025

1025

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1025

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1025

1025

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1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

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Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

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929

928

927

926

925

927

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05

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955

955

955

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965

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965

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970

970

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970 9709

75

975

975

975

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75

975

980

980

980

980

980

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985

985

990

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1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

gsE

AW D

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Gradesd

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Brsquo

B

13

13

A

12

Arsquo

12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

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nDra

win

gsE

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pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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win

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15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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AW D

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win

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 20 Worksheet

(forcemain piping and storage tanks) The odor is noticeable in the leachate load-out garage during loading operations when hydrogen peroxide pre-treatment is not used Such odors are rapidly dispersed and are not noticeable outside the building For purposes of odor control pretreatment of leachate with hydrogen peroxide is performed for leachate that is recycled as quench water at the GRE Elk River Energy Recovery Station Hydrogen peroxide treatment has proven effective at controlling the hydrogen sulfide odor at the power plant Noise Noise generation during construction and operation will not change from the current levels The proposed project will result in phased construction activities occurring every one to two years for berm liner and final cover construction (see Item 6 above) Dust Construction activity occurs in the summer months and lasts for two to three months during which time large earth moving equipment would generate dust (from soil excavation and filling) and noise Dust is controlled during construction by the use of water See Item 23 above for additional detail regarding fugitive dust emissions

25 Nearby resources Are any of the following resources on or in proximity to the site a Archaeological historical or architectural resources Yes No b Prime or unique farmlands or land within an agricultural preserve Yes No c Designated parks recreation areas or trails Yes No d Scenic views and vistas Yes No e Other unique resources Yes No If yes describe the resource and identify any project-related impacts on the resources Describe any

measures to minimize or avoid adverse impacts a A record search was conducted by the SHPO to determine if any historically significant sites are in

their database on or adjacent to the proposed project site No sites were found within the database A copy of the SHPO e-mail is included in Appendix C

e The site is located adjacent to but does not encroach upon the boundary of the Mississippi River

Scenic and Recreational District This segment of the Mississippi River also has a special designation as an Outstanding Resource Value Water The design for the proposed expansion includes mitigative measures to protect the river such as the stormwater controls described in Items 16 and 17 and the groundwater monitoring network and contingency action plan described in Items 18 and 19 of this EAW

26 Visual impacts Will the project create adverse visual impacts during construction or operation Such as

glare from intense lights lights visible in wilderness areas and large visible plumes from cooling towers or exhaust stacks Yes No Intense lighting is not used at the Facility and no plumes are generated by Facility operations Construction of the landfill will result in the creation of a hill that will be visible from 140th Avenue SE however the ash surface facing the road will be covered to the extent practicable with intermediate or final cover and vegetated in order to address both visual aesthetics and surface water management

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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RE1005 B

AL P

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AW D

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1_State L

ocation M

apd

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

ermit e

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nDra

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AW D

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2_Sherburne C

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apd

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

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SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

960

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960

960

960

960

960

960

960

960

960

960

960

960

970

970

970

970

970

970

970

970

980

980

980

980

980

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980

980

980

990

990

990

990

1000

1000

1010

1010

1010

1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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S D

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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AW D

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9_

Cover D

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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955

955

955

955

955

955

955

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955

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965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

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985

985

985

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985

985

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990

990

990

990

995

995

1000

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1005

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1015

1015

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20

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1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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nDra

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gsE

AW D

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N

LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

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Arsquo

Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

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970 9709

75

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75

975

980

980

980

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985

985

990

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1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

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Gradesd

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Brsquo

B

13

13

A

12

Arsquo

12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

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nDra

win

gsE

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pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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RE1005 B

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win

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15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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AW D

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 21 Worksheet

Based on the current design the projected maximum elevation of the BAL upon closure is expected to be 1099 feet above mean sea level or approximately 140 feet above the existing terrain in the expansion area

27 Compatibility with plans and land use regulations Is the project subject to an adopted local comprehensive plan land use plan or regulation or other applicable land use water or resource management plan of a local regional state or federal agency Yes No

If yes describe the plan discuss its compatibility with the project and explain how any conflicts will be resolved If no explain

The site of the proposed expansion is located within the city of Becker in Sherburne County Minnesota The city has planning and zoning jurisdiction over the project site The 413-acre area containing the current landfill (and the additional 15 acres that is not permitted) was re-zoned from Agriculture (AG) to Industrial-Power Generation (I-PG) by the city to accommodate the BAL prior to initial construction in 1991 A city of Becker zoning map is included as Figure 15 GRE will need to apply for a change in zoning from AG to I-PG for the remaining 430 acres of the parcel to encompass the proposed Southern Expansion Both the existing landfill and proposed expansion are in areas designated as ldquoIndustrial Reserverdquo in the City of Becker Comprehensive Plan adopted in 2004 (see Figure 16) so the proposed zoning change complies with the comprehensive plan Operation of the BAL is subject to a Conditional Use Permit issued by the city of Becker Current operation is in compliance with the permit Modification of the Conditional Use Permit will be required for the proposed expansion to incorporate the additional area

28 Impact on infrastructure and public services Will new or expanded utilities roads other infrastructure or public services be required to serve the project Yes No

29 Cumulative potential effects Minn R 44101700 subp 7 item B requires that the RGU consider the

ldquocumulative potential effects of related or anticipated future projectsrdquo when determining the need for an environmental impact statement Identify any past present or reasonably foreseeable future projects that may interact with the project described in this EAW in such a way as to cause cumulative potential effects (Such future projects would be those that are actually planned or for which a basis of expectation has been laid) Describe the nature of the cumulative potential effects and summarize any other available information relevant to determining whether there is potential for significant environmental effects due to these cumulative effects (or discuss each cumulative effect under appropriate item(s) elsewhere on this form) Cumulative impacts include those caused by the addition of the project to past present and foreseeable future activities The city of Becker Community Development Department and the Sherburne County Planning and Zoning Department were contacted to determine if there were any approved or known planned projects that might have cumulative effects with the proposed project The only future activity known at this time is that of the cityrsquos industrial park located approximately one mile north of the proposed project on the east side of Sherburne Avenue The city owns a 30-acre parcel on the north and a 40-acre parcel abutting that to the south Both of the properties are served with sanitary sewer water and storm sewer but none of the parcels have been developed or sold for development at this time

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

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EAW - BECKER ASH

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3272012

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3272012

Becker Minnesota

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

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wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 22 Worksheet

There are several other waste management facilities located within a one-mile radius of the proposed BAL expansion (see Figure 3) Other facilities include several coal ash management ponds located on the Xcel Energy Sherco Generating Plant site to the north and northwest of the BAL and the Vonco II Landfill located southeast of the BAL Potential cumulative effects resulting from the proximity of these facilities are discussed below Traffic Waste hauling trucks for both BAL and Vonco II travel on Sherburne Avenue Sherburne Avenue is designed to accommodate this traffic The proposed project will not result in an increase in truck traffic however the existing 13 to 17 truck trips per day associated with the current operation of the BAL will continue for a longer period of time if the proposed project is implemented There is no truck traffic on public roads associated with operation of the Sherco ash management facilities Erosion and Sediment Transport The proposed expansion of the BAL includes provisions for stormwater management BMPs during construction and engineered stormwater control structures including on-site infiltration ponds for operations The infiltration ponds are designed to fully contain the runoff volume from the 100-year 24-hour rainfall event and do not discharge stormwater or sediment from the site There is no overland stormwater discharge from the BAL site and thus no cumulative effect related to potential erosion and sediment transport impacts Groundwater Waste management facilities present a potential for groundwater impacts if leaks from the facilities were to occur This potential is mitigated for each individual facility by permit requirements imposed and enforced by public regulatory authorities Such permit requirements include engineered containment systems to prevent leaks (liner systems leak detection systems leachate collection systems final cover systems) that are facility-specific based upon the type of waste being managed groundwater monitoring systems for early detection should a leak occur contingency action plans for implementation of remedial actions should such a response be required and financial assurance requirements to ensure funds are immediately available for responding to a release The potential cumulative effect of several waste management facilities being located within a one-mile radius of the proposed BAL expansion include increased areal extent of potential impacts comingling of groundwater impacts from different facilities and comingling of impacts to the Mississippi River where groundwater discharges This segment of the Mississippi River (Clearwater River to the Elk River) is listed by the MPCA as impaired for fecal coliform fish bioassessments and mercury The proposed BAL expansion would increase the footprint of the Facility and thus increase the areal extent of liner from which leaks could occur However the likelihood of a leak from the lined area is remote given the controls imposed by public regulatory authorities as described above In addition the sequential development of new landfill cells coupled with closure of previously-developed cells results in a minimal increase in active liner area from which a leak could occur When final cover is placed over filled areas of the landfill the source of leachate is cut off (rainwater is diverted away from rather than absorbed by the landfill) and the potential for a leak from the lined area beneath the final cover is significantly reduced

For this site comingling of potential impacts in groundwater as a result of multiple facilities leaking into the same groundwater flow path associated with potential for increased contaminant concentration that might be present from a single facility is offset by the relative positions of the facilities with respect

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

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3272012

Becker Minnesota

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

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FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

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3272012

Becker Minnesota

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Ash Landfill Expansion Environmental Assessment Becker Minnesota 23 Worksheet

to groundwater flow direction Groundwater flow direction is toward the Mississippi River from each of the facilities Each facility has a separate groundwater flow path and thus comingling of impacts in groundwater is unlikely to occur There is a slight overlap in flow paths between the existing BAL footprint and Sherco Pond No 3 however there is a frac14-mile separation of flow paths between the BAL expansion footprint and the Sherco facilities The Xcel Energy Sherco Generating Plant and the Vonco II facilities are required to conduct routine groundwater monitoring under their respective permits Groundwater monitoring data at Vonco II indicates no exceedances of state or federal drinking water standards Groundwater monitoring data at the Xcel Energy Sherco Generating Plant shows exceedances for boron and sulfate which are indicator parameters used to document the extent of coalash influence The scrubber solids ponds coal yard and power house areas have been attributed as sources for the observed boron and sulfate concentrations Comingling of potential impacts in the Mississippi River as a result of the proposed BAL expansion will not be significantly changed from current conditions in terms of potential mass loading of contaminants to the river Due to sequential development of new landfill cells and closure of previously-developed cells as described above the active liner area from which impacts could occur will shift in position but will not be significantly larger in size BAL has indicated some interest in accepting wastes at some point in the future from other sources than currently listed in the permit application This is not currently accounted for in the current permit application If this is proposed at some time in the future and leachate generation or other impacts might increase as a result BAL must contact MPCA for a possible permit amendment and additional environmental review pursuant to applicable rules Potential cumulative impacts resulting from the proposed BAL expansion are thus limited to continuation of the existing cumulative effect of multiple facilities for a longer period of time rather than increasing the magnitude of effects The current potential cumulative effect would begin to diminish within five years if the BAL expansion does not occur and the existing BAL is closed beginning in 2015 The current potential cumulative effect would continue for the life of the proposed BAL expansion if the project proceeds Wastewater Treatment Plant discharge Similarly since the volume of daily waste disposal is not expected to change effects on the Becker WWTF discharge should also not change unless leachate generation increases in the future due to acceptance of waste from additional sources This again would require revisiting the permit and the possibility of additional environmental review See also Item 18c Therefore as the project is now proposed significant cumulative effects on WWTF receiving waters are not expected

30 Other Potential Environmental Impacts If the project may cause any adverse environmental impacts

not addressed by items 1 to 28 identify and discuss them here along with any proposed mitigation None

31 Summary of issues List any impacts and issues identified above that may require further investigation before the project is begun Discuss any alternatives or mitigative measures that have been or may be considered for these impacts and issues including those that have been or may be ordered as permit conditions None

MAP

STATE LOCATION

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

SYSTEM DESIGN

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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12300 Elm Creek Boulevard

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LOCATION

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wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

MAP

STATE LOCATION

FIGURE 1

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

N

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

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1_State L

ocation M

apd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

SHERBURNE COUNTY

CITY OF BECKER

SITE LOCATION

N

MAP

COUNTY LOCATION

FIGURE 2

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ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

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2_Sherburne C

ounty M

apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

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1030

1030

OA

9604

6

9566

5

95

80

6

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8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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AW D

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4_

Existing C

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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AW D

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gsFig

5_

Lin

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

PProje

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RE1005 B

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nDra

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

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RE1005 B

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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CELL 1

CELL 2

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OA

9604

6

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5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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12

13

13

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945

945

940

950

960

970

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NORTHEAST EXPANSION SOUTH EXPANSION

945

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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ctsG

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FIGURE 11

LEGEND

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

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FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

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PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

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LANDFILL EXPANSION

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FIGURE 15

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15_

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

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16 _

Co

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nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

N

MAP

COUNTY LOCATION

FIGURE 2

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

gsE

AW D

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2_Sherburne C

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apd

gn

SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

SHERBURNE COUNTY

T33N R28W

SW14 SW14 SEC 7

PROJECT LOCATION

N

00 750 1500 3000

LANDFILL EXPANSION

Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

$FILE$

$D

AT

E$

SURVEYING ENGINEERING ENVIRONMENTAL

PROJECT LOCATION

SOUTH EXPANSION

ASH LANDFILL SITE

EXISTING BECKERDISTANCE

ONE-MILE

VONCO II LANDFILL

I-94

PLANT

POWER

SHERCO

RESIDENCE

RESIDENCES

SCATTERED

MINE

PONDS

MANAGEMENT

SHERCO ASH

950 950

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1010

1010

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1020

1020

1020

1020 10

20

1020

1020

1030

1030

OA

9604

6

9566

5

95

80

6

9561

8

Water

9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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nDra

win

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Existing C

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

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GRE WATER

POND

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OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

RE1005 B

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3272012

SYSTEM DESIGN

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FIGURE 6

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3272012

Becker Minnesota

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FIGURE 9

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3272012

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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95

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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FIGURE 11

LEGEND

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

N

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Becker MinnesotaUSGS QUAD MAP

FIGURE 3EAW - BECKER ASH

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PROJECT LOCATION

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SHERCO ASH

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960

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1000

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1020

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20

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OA

9604

6

9566

5

95

80

6

9561

8

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9514

W

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

BOUNDARY

EXPANSION

WELL

GRE WATER

POND

STORMWATER

SITE ENTRANCENORTHEAST EXPANSION AREA

OUT BUILDING

LEACHATE LOAD-SOUTH EXPANSION AREA

CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

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RE1005 B

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3272012

SYSTEM DESIGN

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FIGURE 6

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3272012

Becker Minnesota

LANDFILL EXPANSION

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FIGURE 9

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3272012

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 11

LEGEND

N

100 200

CONTOURS

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PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

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NORTHEAST EXPANSION

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SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

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PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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16 _

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nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

950 950

960

960

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1010

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1030

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6

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5

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80

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W

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CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

P-108P-111

P-109P-107USGS WELL 582051

P-114

P-115P-113

P-116

MW-3

MW-4

MW-1 MW-2B

MW-2A

P-112B

P-112A

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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nDra

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2 NEW SITE MONITORING WELLSPIEZOMETERS ARE LABELED MW-xx

OCTOBER 2011 TOPOGRAPHY3 CONTOURS WITHIN THE NORTH HALF OF THE PROPERTY REPRESENT

FIGURE 4

SITE MAP

LEGEND

N

0 100 200

WELL

MONITORING

WELL NEST

MONITORING

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

CELL

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CHARACTERIZATION

SOUTH LIMIT OF CURRENT SITE

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

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3272012

SYSTEM DESIGN

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3272012

Becker Minnesota

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3272012

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

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PROPOSED

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500 1000 1500 2000 2661222500900

0

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1000

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BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

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FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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REG

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Becker Minnesota

LANDFILL EXPANSION

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FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

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N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

DESIGN

LINER SYSTEM

FIGURE 5

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

PProje

ctsG

REG

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

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nDra

win

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6_

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er Alternated

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

3

1

SLOPE TOP OF CLAY

GEOSYNTHETIC CLAY LINER (GCL)

WITH DRAINAGE NET

DOUBLE GEOMEMBRANE LINER

3rsquo

DRAINAGE LAYER

3-FOOT THICK CLAY LINER

EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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win

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9_

Cover D

etaild

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

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1025

1025

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1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

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ctsG

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FIGURE 10

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12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

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3 2

05

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1010

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1025

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1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

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nDra

win

gsE

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gn

pdfpltcfg

9000 500 1000 141592

1000

1100

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FINAL COVER

FINAL COVER LINER

BASE GRADES

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WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

nDra

win

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Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

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win

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15_

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

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win

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AW D

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win

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16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

SYSTEM DESIGN

ALTERNATE LINER

FIGURE 6

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

pdfpltcfg

3

1

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WITH DRAINAGE NET

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EXTEND GCL 2rsquo DOWN CLAY LINER

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

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RE1005 B

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

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985

985

985

990

990

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1000

1000

1005

1005

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1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

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945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

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930

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1010

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OA

9604

6

9566

5

95

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6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

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1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

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nDra

win

gsE

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1100

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WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

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FIGURE 15

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

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3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

DESIGN

FINAL COVER

FIGURE 9

PProje

ctsG

REG

RE1005 B

AL P

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xpansio

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Cover D

etaild

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SURVEYING ENGINEERING ENVIRONMENTAL

3272012

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

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960

960

960

960

960

960

960

960

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965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

980

980

980

980980

980

985

985

985

985

985

985

990

990

990

990

990

995

995

1000

1000

1005

1005

1005

1010

1010

1010

1015

1015

1015

1015

1015

1015

1015

1015

1020

1020

1020

1020 10

20

1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

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xpansio

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win

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N

LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

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Arsquo

Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

927

3 2

05

SUMP

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

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965

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970

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75

975

975

975

975 9

75

975

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980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

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win

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win

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Brsquo

B

13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

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AW D

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9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

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REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

965

965

965

970

970

970

970

970

970

970

970

970 970975

975

975

975

975

975 9

75

975

975

975

975

980

980

980

980

980

980

980

980

980980

980

985

985

985

985

985

985

990

990

990

990

990

995

995

1000

1000

1005

1005

1005

1010

1010

1010

1015

1015

1015

1015

1015

1015

1015

1015

1020

1020

1020

1020 10

20

1020

1020 1025

1025

1025

1025

1025

1025

1025

1025

1025

1025

1030

1030

1030

1035

1035

CELL 1

CELL 2

CELL 3

CELL 4 CELL 5 CELL 6

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

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Base G

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gn

pdfpltcfg

N

LEGEND

0 100 200

GRADES

PROPOSED BASE

FIGURE 10

B

A

__

Arsquo

Brsquo

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

CONTOURS

PROPOSED

CONTOURS

WATER TABLE

12

13

13

12

945

945

940

950

960

970

980

NORTHEAST EXPANSION SOUTH EXPANSION

945

955

965

928

927

926

925

924

936

935

934 93

3

932

931

930

929

928

927

926

925

927

3 2

05

SUMP

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

970

970

970

970

970

970 9709

75

975

975

975

975 9

75

975

980

980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

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win

gsE

AW D

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win

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al

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Brsquo

B

13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg12_Section Ad

gn

pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

950 950955

955

955

955

955

955

955

955

955

955

955

955

955

960

960

960

960

960

960

960

960

960

960

960

960

965

965

965

965

965

970

970

970

970

970

970 9709

75

975

975

975

975 9

75

975

980

980

980

980

980

980

985

985

990

990

995

1000

1010

1020

1020

1025

1030

1030

1035

OA

9604

6

9566

5

95

80

6

9561

8

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg11_Fin

al

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gn

pdfpltcfg

Brsquo

B

13

13

A

12

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12

980

990

1000

1010

1020

1030

1040

1050

1060

1070

1080

1090

1099

GRADES

PROPOSED FINAL

FIGURE 11

LEGEND

N

100 200

CONTOURS

EXISTING

LINE

PROPERTY

BOUNDARY

EXPANSION

0

CONTOURS

PROPOSED

DIRECTION

RUNOFF FLOW

DROP PIPES

PONDS

STORMWATER

NORTHEAST EXPANSION

POND

EXISTING STORMWATER

3

3

333

333

SOUTH EXPANSION

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg12_Section Ad

gn

pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

500 1000 1500 2000 2661222500900

0

1100

1000

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

A - Arsquo

CROSS SECTION

FIGURE 12

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

HORIZONTAL

VERTICAL SCALE EXAGGERATED 5 TIMES

FINAL GRADE

CURRENTLY APPROVED

FINAL GRADE

PROPOSED

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg12_Section Ad

gn

pdfpltcfg

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

9000 500 1000 141592

1000

1100

EXISTING GROUND SURFACE

FINAL COVER

FINAL COVER LINER

BASE GRADES

BASE GRADES LINER

WATER TABLE

LEGEND

B - Brsquo

CROSS SECTION

FIGURE 13VERTICAL SCALE EXAGGERATED 5 TIMES

HORIZONTAL

GRADE

PROPOSED FINAL

GRADE

PROPOSED BASE

Notes

3272012

SURVEYING ENGINEERING ENVIRONMENTAL Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

Maple Grove MN 55369

12300 Elm Creek Boulevard

GREAT RIVER ENERGY

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFIg13_Section Bd

gn

pdfpltcfg

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

ZONING MAP

FIGURE 15

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

15_

Zonin

gd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

N

Becker Minnesota

LANDFILL EXPANSION

EAW - BECKER ASH

LAND USE MAP

COMPREHENSIVE PLAN

FIGURE 16

PProje

ctsG

REG

RE1005 B

AL P

ermit e

xpansio

nDra

win

gsE

AW D

ra

win

gsFig

16 _

Co

mp Pla

nd

gn

3272012

SURVEYING ENGINEERING ENVIRONMENTAL

LOCATION

PROJECT

LANDFILL

BECKER ASH

EXISTING

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

wwwmndnrgov

AN EQUAL OPPORTUNITY EMPLOYER

March 13 2012 Correspondence ERDB 20120288 Mr John Cannon Carlson McCain Inc PLLC PO Box 429 Maple Plain MN 55359 RE Natural Heritage Review of the proposed Becker Ash Landfill Expansion T33N R28W Section 7 Sherburne County Dear Mr Cannon

As requested the Minnesota Natural Heritage Information System has been queried to determine if any rare species or other significant natural features are known to occur within an approximate one-mile radius of the proposed project Based on this query rare mussels have been documented in the Mississippi River in the vicinity of the project However provided effective erosion and sediment control practices are implemented I do not believe the project will negatively affect any known occurrences of rare features

The Natural Heritage Information System a collection of databases that contains information about Minnesotarsquos rare natural features is maintained by the Division of Ecological and Water Resources Department of Natural Resources The NHIS is continually updated as new information becomes available and is the most complete source of data on Minnesotas rare or otherwise significant species native plant communities and other natural features However the NHIS is not an exhaustive inventory and thus does not represent all of the occurrences of rare features within the state Therefore ecologically significant features for which we have no records may exist within the project area

For environmental review purposes the results of this Natural Heritage Review are valid for one year the results are only valid for the project location (noted above) and project description provided on the NHIS Data Request Form Please contact me if project details change or if an updated review is needed

Please note that locations of the gray wolf (Canis lupus) state-listed as special concern and the Canada lynx (Lynx canadensis) federally-listed as threatened are not currently tracked in the NHIS As such the Natural Heritage Review does not address these species

Furthermore the Natural Heritage Review does not constitute review or approval by the Department of Natural Resources as a whole Instead it identifies issues regarding known occurrences of rare features and potential effects to these rare features Additional rare features for which we have no data may be present in the project area or there may be other natural resource concerns associated with the proposed project For these concerns please contact your DNR Regional Environmental Assessment Ecologist (contact information available at httpwwwdnrstatemnusecoereviewerp_regioncontactshtml) Please be aware that additional site assessments or review may be required

Thank you for consulting us on this matter and for your interest in preserving Minnesotas rare natural resources An invoice will be mailed to you under separate cover Sincerely

Lisa Joyal

Natural Heritage Review Coordinator

Minnesota Department of Natural Resources Division of Ecological and Water Resources Box 25

500 Lafayette Road

St Paul Minnesota 55155-4025

Phone (651) 259-5109 E-mail lisajoyalstatemnus

Appendix A

1231

7B7B

1260B

430880

430880

430960

430960

431040

431040

431120

431120

431200

431200

431280

431280

431360

431360

431440

431440

431520

431520

5023

040

5023

040

5023

120

5023

120

5023

200

5023

200

5023

280

5023

280

5023

360

5023

360

5023

440

5023

440

0 300 600 900150Feet

0 90 180 27045Meters

plusmn

45deg 21 42

93deg

52 2

5

45deg 21 26

93deg

52 2

5

45deg 21 25

45deg 21 4193

deg 52

59

93

deg 52

59

Map Scale 13560 if printed on A size (85 x 11) sheet

Soil MapmdashSherburne County Minnesota(GRE Becker Ash Landfill Expansion)

Natural ResourcesNatural ResourcesNatural ResourcesNatural ResourcesConservation ServiceConservation ServiceConservation ServiceConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 1 of 3

Appendix B

MAP LEGEND MAP INFORMATION

Area of Interest (AOI)Area of Interest (AOI)

SoilsSoil Map Units

Special Point FeaturesBlowout

Borrow Pit

Clay Spot

Closed Depression

Gravel Pit

Gravelly Spot

Landfill

Lava Flow

Marsh or swamp

Mine or Quarry

Miscellaneous Water

Perennial Water

Rock Outcrop

Saline Spot

Sandy Spot

Severely Eroded Spot

Sinkhole

Slide or Slip

Sodic Spot

Spoil Area

Stony Spot

Very Stony Spot

Wet Spot

Other

Special Line FeaturesGully

Short Steep Slope

Other

Political FeaturesCities

Water FeaturesStreams and Canals

TransportationRails

Interstate Highways

US Routes

Major Roads

Local Roads

Map Scale 13560 if printed on A size (85 times 11) sheet

The soil surveys that comprise your AOI were mapped at 115840

Warning Soil Map may not be valid at this scale

Enlargement of maps beyond the scale of mapping can causemisunderstanding of the detail of mapping and accuracy of soil lineplacement The maps do not show the small areas of contrastingsoils that could have been shown at a more detailed scale

Please rely on the bar scale on each map sheet for accurate mapmeasurements

Source of Map Natural Resources Conservation ServiceWeb Soil Survey URL httpwebsoilsurveynrcsusdagovCoordinate System UTM Zone 15N NAD83

This product is generated from the USDA-NRCS certified data as ofthe version date(s) listed below

Soil Survey Area Sherburne County MinnesotaSurvey Area Data Version 8 Dec 15 2009

Date(s) aerial images were photographed 6292004

The orthophoto or other base map on which the soil lines werecompiled and digitized probably differs from the backgroundimagery displayed on these maps As a result some minor shiftingof map unit boundaries may be evident

Soil MapndashSherburne County Minnesota(GRE Becker Ash Landfill Expansion)

Natural ResourcesConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 2 of 3

Map Unit Legend

Sherburne County Minnesota (MN141)

Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI

7B Hubbard loamy sand 2 to 6 percent slopes 24 55

1231 Hubbard-Mosford complex 0 to 3 percentslopes

406 942

1260B Stonelake-Nebish complex 2 to 6 percentslopes

01 03

Totals for Area of Interest 431 1000

Soil MapndashSherburne County Minnesota GRE Becker Ash Landfill Expansion

Natural ResourcesConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 3 of 3

From Thomas CinadrTo John CannonSubject Re Information request for EAWDate Thursday February 23 2012 14317 PMAttachments Archaeologyrtf

THIS EMAIL IS NOT A PROJECT CLEARANCE

This message simply reports the results of the culturalresources database search you requested Thedatabase search produced results for only previouslyknown archaeological sites and historic propertiesPlease read the note below carefully No historic structures were identified in a search of the Minnesota Archaeological Inventory and HistoricStructures Inventory for the search area requested A report containing the archaeological sitesidentified is attached The result of this database search provides a listing of recorded archaeological sites and historicarchitectural properties that are included in the current SHPO databases Because the majority ofarchaeological sites in the state and many historic architectural properties have not been recordedimportant sites or structures may exist within the search area and may be affected by developmentprojects within that area Additional research including field survey may be necessary to adequatelyassess the arearsquos potential to contain historic properties If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites orhistoric architectural properties you may need to hire a qualified archaeologist andor historian If youneed assistance with a project review please contact Kelly Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found athttpwwwmnhsorgshposurveyinventorieshtm SHPO research hours are 800 AM ndash 400 PM Tuesday-FridayThe Office is closed on Mondays

Tom CinadrSurvey and Information Management Coordinator651-259-3453

Appendix C

MAP LEGEND MAP INFORMATION

Area of Interest (AOI)Area of Interest (AOI)

SoilsSoil Map Units

Special Point FeaturesBlowout

Borrow Pit

Clay Spot

Closed Depression

Gravel Pit

Gravelly Spot

Landfill

Lava Flow

Marsh or swamp

Mine or Quarry

Miscellaneous Water

Perennial Water

Rock Outcrop

Saline Spot

Sandy Spot

Severely Eroded Spot

Sinkhole

Slide or Slip

Sodic Spot

Spoil Area

Stony Spot

Very Stony Spot

Wet Spot

Other

Special Line FeaturesGully

Short Steep Slope

Other

Political FeaturesCities

Water FeaturesStreams and Canals

TransportationRails

Interstate Highways

US Routes

Major Roads

Local Roads

Map Scale 13560 if printed on A size (85 times 11) sheet

The soil surveys that comprise your AOI were mapped at 115840

Warning Soil Map may not be valid at this scale

Enlargement of maps beyond the scale of mapping can causemisunderstanding of the detail of mapping and accuracy of soil lineplacement The maps do not show the small areas of contrastingsoils that could have been shown at a more detailed scale

Please rely on the bar scale on each map sheet for accurate mapmeasurements

Source of Map Natural Resources Conservation ServiceWeb Soil Survey URL httpwebsoilsurveynrcsusdagovCoordinate System UTM Zone 15N NAD83

This product is generated from the USDA-NRCS certified data as ofthe version date(s) listed below

Soil Survey Area Sherburne County MinnesotaSurvey Area Data Version 8 Dec 15 2009

Date(s) aerial images were photographed 6292004

The orthophoto or other base map on which the soil lines werecompiled and digitized probably differs from the backgroundimagery displayed on these maps As a result some minor shiftingof map unit boundaries may be evident

Soil MapndashSherburne County Minnesota(GRE Becker Ash Landfill Expansion)

Natural ResourcesConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 2 of 3

Map Unit Legend

Sherburne County Minnesota (MN141)

Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI

7B Hubbard loamy sand 2 to 6 percent slopes 24 55

1231 Hubbard-Mosford complex 0 to 3 percentslopes

406 942

1260B Stonelake-Nebish complex 2 to 6 percentslopes

01 03

Totals for Area of Interest 431 1000

Soil MapndashSherburne County Minnesota GRE Becker Ash Landfill Expansion

Natural ResourcesConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 3 of 3

From Thomas CinadrTo John CannonSubject Re Information request for EAWDate Thursday February 23 2012 14317 PMAttachments Archaeologyrtf

THIS EMAIL IS NOT A PROJECT CLEARANCE

This message simply reports the results of the culturalresources database search you requested Thedatabase search produced results for only previouslyknown archaeological sites and historic propertiesPlease read the note below carefully No historic structures were identified in a search of the Minnesota Archaeological Inventory and HistoricStructures Inventory for the search area requested A report containing the archaeological sitesidentified is attached The result of this database search provides a listing of recorded archaeological sites and historicarchitectural properties that are included in the current SHPO databases Because the majority ofarchaeological sites in the state and many historic architectural properties have not been recordedimportant sites or structures may exist within the search area and may be affected by developmentprojects within that area Additional research including field survey may be necessary to adequatelyassess the arearsquos potential to contain historic properties If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites orhistoric architectural properties you may need to hire a qualified archaeologist andor historian If youneed assistance with a project review please contact Kelly Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found athttpwwwmnhsorgshposurveyinventorieshtm SHPO research hours are 800 AM ndash 400 PM Tuesday-FridayThe Office is closed on Mondays

Tom CinadrSurvey and Information Management Coordinator651-259-3453

Appendix C

Map Unit Legend

Sherburne County Minnesota (MN141)

Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI

7B Hubbard loamy sand 2 to 6 percent slopes 24 55

1231 Hubbard-Mosford complex 0 to 3 percentslopes

406 942

1260B Stonelake-Nebish complex 2 to 6 percentslopes

01 03

Totals for Area of Interest 431 1000

Soil MapndashSherburne County Minnesota GRE Becker Ash Landfill Expansion

Natural ResourcesConservation Service

Web Soil SurveyNational Cooperative Soil Survey

2222012Page 3 of 3

From Thomas CinadrTo John CannonSubject Re Information request for EAWDate Thursday February 23 2012 14317 PMAttachments Archaeologyrtf

THIS EMAIL IS NOT A PROJECT CLEARANCE

This message simply reports the results of the culturalresources database search you requested Thedatabase search produced results for only previouslyknown archaeological sites and historic propertiesPlease read the note below carefully No historic structures were identified in a search of the Minnesota Archaeological Inventory and HistoricStructures Inventory for the search area requested A report containing the archaeological sitesidentified is attached The result of this database search provides a listing of recorded archaeological sites and historicarchitectural properties that are included in the current SHPO databases Because the majority ofarchaeological sites in the state and many historic architectural properties have not been recordedimportant sites or structures may exist within the search area and may be affected by developmentprojects within that area Additional research including field survey may be necessary to adequatelyassess the arearsquos potential to contain historic properties If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites orhistoric architectural properties you may need to hire a qualified archaeologist andor historian If youneed assistance with a project review please contact Kelly Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found athttpwwwmnhsorgshposurveyinventorieshtm SHPO research hours are 800 AM ndash 400 PM Tuesday-FridayThe Office is closed on Mondays

Tom CinadrSurvey and Information Management Coordinator651-259-3453

Appendix C

From Thomas CinadrTo John CannonSubject Re Information request for EAWDate Thursday February 23 2012 14317 PMAttachments Archaeologyrtf

THIS EMAIL IS NOT A PROJECT CLEARANCE

This message simply reports the results of the culturalresources database search you requested Thedatabase search produced results for only previouslyknown archaeological sites and historic propertiesPlease read the note below carefully No historic structures were identified in a search of the Minnesota Archaeological Inventory and HistoricStructures Inventory for the search area requested A report containing the archaeological sitesidentified is attached The result of this database search provides a listing of recorded archaeological sites and historicarchitectural properties that are included in the current SHPO databases Because the majority ofarchaeological sites in the state and many historic architectural properties have not been recordedimportant sites or structures may exist within the search area and may be affected by developmentprojects within that area Additional research including field survey may be necessary to adequatelyassess the arearsquos potential to contain historic properties If you require a comprehensive assessment of a projectrsquos potential to impact archaeological sites orhistoric architectural properties you may need to hire a qualified archaeologist andor historian If youneed assistance with a project review please contact Kelly Gragg-Johnson in Review and Compliance 651-259-3455 or by email at kellygraggjohnsonmnhsorg The Minnesota SHPO Survey Manuals and Database Metadata and Contractor Lists can be found athttpwwwmnhsorgshposurveyinventorieshtm SHPO research hours are 800 AM ndash 400 PM Tuesday-FridayThe Office is closed on Mondays

Tom CinadrSurvey and Information Management Coordinator651-259-3453

Appendix C

On Tue Feb 21 2012 at 425 PM John Cannon ltjcannoncarlsonmccaincomgtwrote

Mr Cinadr

Our firm is preparing an EAW for a proposed project for Great River Energy Theproject involves the expansion of GRErsquos Becker Ash Landfill The proposed projectis located on a 40 acre parcel in the City of Becker Sherburne County Minnesota The location is in the SW14 of the SW14 of Section 7 T33N R28W Theattached map shows the project location and surrounding area

We are requesting a file search to meet EAW requirements Please contact me ifyou have any questions

John Cannon PE

Senior Engineer

Carlson McCain Inc

PO Box 429 530 Highway 12 | Maple Plain MN 55359

Tel 952-346-3872 | Cell 763-458-8323 | Fax 952-346-3901

wwwcarlsonmccaincom

This message is intended for the individual or entity named above If you are not the intended

recipient please do not read copy use or disclose this communication to others Thank you

Table 1 Leachate Quality Summary

GRE Becker Ash Landfill Expansion EAW

2009 Loading Station Sample Results 2010 Loading Station Sample Results 2011 Loading Station Sample Results Samples Values Greater Than Detection Median Maximum Minimum

1272009 4212009 7212009 1072009 1182010 4142010 7132010 10132010 1172011 4142011 762011 10202011 (1992-present)Alkalinity mgL CaCO3 145 163 127 125 100 182 328 892Aluminum mgL 279 0775 248 64 88 008 44 BLRLAmmonia mgL 23 30 258 76 100 23 45 050Arsenic mgL BLRL BLRL 0005 BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 001 075 107 42 BLRL 018 BLRLBarium mgL 171 112 18 616 161 276 178 84 183 12 144 146 3000 171 100 1400 153 331

Beryllium mgL 43 12 BLRL 001 BLRLBOD mgL O2 BLRL BLRL 140 56 98 57 630 BLRLBoron mgL 132 036 BLRL 0298 lt075 BLRL 9 125 90 019 218 BLRL

Cadmium mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 006 110 57 000 005 BLRLCalcium mgL 9330 8480 669 141 100 10958 23400 67Chloride mgL 37800 34300 41100 16700 38600 47400 31500 20700 38300 33700 33400 41100 169 100 33051 69739 5500

Chromium mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 15 72 75 001 008 BLRLCOD L O2 3450 1560 1490 658 1860 1710 1680 3670 1350 1310 998 1760 189 100 1630 21760 80 0

UnitsParameter MLCLs

COD mgL O2 3450 1560 1490 658 1860 1710 1680 3670 1350 1310 998 1760 189 100 1630 21760 800Copper mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 15 123 67 001 016 BLRLCyanide mgL BLRL BLRL BLRL BLRL 001 0032 BLRL 0036 00223 BLRL BLRL 69 49 BLRL 015 BLRL

Iron mgL 215 108 216 167 130 99 5 557 BLRLLead mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 03 125 53 00004 018 BLRL

Magnesium mgL 188 154 38 126 100 16 310 38Manganese mgL 878 106 103 321 64 166 462 73 677 459 37 859 9 187 100 18 250 0005

Mercury mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 003 158 39 BLRL 001 BLRLNickel mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 21 97 84 002 017 BLRL

Nitrate + Nitrite mgL BLRL BLRL BLRL 69 65 013 16 BLRLpH Lab Std Units 690 710 680 720 670 670 730 690 700 700 700 660 200 100 7 86 63

Potassium mgL 5790 6230 4810 78 100 38975 7930 583Selenium mgL BLRL BLRL 002 BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 03 103 53 001 043 BLRL

Silver mgL 005 BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 03 102 89 005 026 BLRLSodium mgL BLRL BLRL 10800 5310 12800 14000 BLRL 5910 BLRL 9370 9740 10400 165 100 7710 16800 11280

TDS mgL 65600 53700 65000 26300 66000 82500 52500 34700 63100 54900 55400 69400 166 100 63050 122000 302TSS mgL 34 5 67 1 48 2 24 9 174 197 62 8 36 5 76 4 23 164 68 9 201 99 41 00 200 BLRLTSS mgL 345 671 482 249 174 197 628 365 764 23 164 689 201 99 4100 200 BLRL

Specific Conductance umhoscm 86600 72200 89100 40800 95700 106000 70900 51600 86900 76400 683 80800 172 100 73689 115600 683Sulfate mgL 779 152 563 905 356 472 692 553 39 754 969 589 168 96 9101 1025 BLRL

Zinc mgL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL BLRL 21 83 64 001 054 BLRLMolybdenum mgL 011 01 BLRL BLRL 0051 BLRL 0191 0147 BLRL 00996 0096 BLRL 21 100 010 8677 BLRLPhosphorus mgL BLRL BLRL BLRL BLRL BLRL BLRL 0072 0058 BLRL BLRL 005 0054 9 100 007 016 01

BLRL Below Laboratory Reporting Limit

PProjectsGREGRE1005 BAL Permit expansionEAWLeachate Data and Chartsxlsx 2011 BAL 3rd Quarter Report

612012

Appendix D

• EAW Cover Letter13
• EAW13
• EAW Figures-Appendicespdf
• • EAW Figures amp Appendices
  • • Figure 1 - 13State Location Map
    • Figure 2 -13Sherburne County Map
    • Figure 3 - 13USGS Quad Map
    • Figure 4 - 13Existing Conditions
    • Figure 5 - Liner 13LCS Detail
    • Figure 6 - GCL Liner Alternate
    • Figure 7 - 13Sump Section 1
    • Figure 8 - 13Sump Sections 2
    • Figure 9 - 13Cover Detail
    • Figure 10 - Base Grades13
    • Figure 11 - Final Grades13
    • Figure 12 - Section A13
    • Figiure 13 - Section B13
    • Figure 14 - Stormwater Control System13
    • Figure 15 - Zoning Map13
    • Figure 16 - Comp Plan Land Use Map13
    • Appendix A - DNR Review13
    • Appendix B - USDA Soil Survey13
    • Appendix C - State Historic Preservation Office Review13
    • Appendix D - Leachate Quality Summary13