HomeMy WebLinkAbout2009-03-09 OPH Ltr to MPCAl
a
City of Oak Park Hei*ghts
14.168 Oak Park Blvd. N •Box 2007.Oak Park Heights, MN 550 82 •Phone (651) 439 4439 • Fax (651) 439 -0574
March 9, 2009
Mr. Robert Criswell
MPCA- Metro District
520 Lafayette Road, N.
St. Paul, MN 55122 -4194
RE: Xcel Energy Letter Dated 2127109. AS ling Ash Permit SW -54; Request for re-
Issuance
Dear Mr. Criswell:
I am in receipt of my copy of the above dated letter from Xcel Energy seeking renewal
of their Ash Permit. The following comments should be considered as part of any renewal
of such permit.
1111111111111 111111111 11111li
Section 2.0
Section 2.0 references the use of "Best Management Practices" (BMP) for dust
suppression on the access roads "into and around" the Disposal Facility. There
should be an explicit insertion that clearly defines what BMP in fact are.
Section 2.0 also discusses the installation of a wheel wash at the exit of the
gravel road. Any permit renewal should state that this shall be installed by a
date certain and must be operable at all times fly ash is being hauled.
Moreover, the subsequent water draining from the vehicles must be
adequately dealt with, meaning it may not wash into the street and down
storm sewers. This will be a violation of MSCWMO rules. A wash/storm retention
basin should be installed and made part of this permit renewal
Section 2.0 mentions the use of a watering truck for dust control. While this
may be an acceptable method to control dust in some locations inside the
facility itself, it is not an acceptable use for public streets (such as Beach Road
which is a Washington County roadway) as this only carries debris into the
storm sewer and subsequently into the St. Croix River. Moreover, as this dries
on the public streets, additional dust is created. Instead, the permit should be
explicitly revised stating that all streets shall be swept daily by means of a
"street sweeper" that applies water, agitates and then picks up such debris.
Simply applying water does not work on the public streets.
Section 3.0
Section 3.0 discusses dust control techniques for "active area" surfaces; to
date, dust control at the site has been poorly maintained and the City
receives several complaints per year. The MPCA should implement specific
and rigid standards that explicitly deal with this dust issue beyond the
generalities discuss in this section. Moreover, to the city's knowledge, the
MPCA has done very little to nothing in terms of enforcement or site review to
spot verify dust control operations and must be addressed. If the MPCA has
significant concerns about eliminating fly -ash from escaping to the
atmosphere at the plant itself; it should express equal concerns and similarly
address these for the fly -ash dust leaving this landfill site.
Section 5.0
Section 5.0 discusses techniques for off -site Roads. To date, the City has
received numerous phone calls from area residents regarding the dust, noise,
lack of courtesy of the drivers., excessive speeds, uncovered loads, etc.,
stemming from the operations at this site. The MPCA must implement spot
checks of this site to ensure that all aspects of any permit is implemented and
followed through in detail.
This section also mentions street washing and street sweeping. Carefully note,
street sweeping as suggested in the letter would be satisfactory, but must be
implemented EVERY DAY that xcel Energy does decide to haul fly -ash to and
from this site. The use of the words "as- needed" is unacceptable to the City of
Oak Park Heights and is vague phrasing. The MPCA must explicitly clarify
when these streets are to be swept, by whore and to what degree.
This section also mentions street washing, as discussed above any water
applied to public streets will wind -up in the St. Croix River (which may be a
separate pollution problem of fly -ash getting into the St. Croix River) and does
little to actually control on- street dust as it just collets in larger piles down-
grade. The use of a streets- sweeper that wets and then picks -up materials is
psibly an acceptable alternative.
Tease et m now if you have any questions.
i erel —
Eric . J nson,
Ci A finis #rator
Weekly Notes
Manuel Castillo, xcel Energy
Gary Kriesel, Washington county Commissioner
Jeff Travis, Washington County
Amy Carolan, MSCWMO
Senator Kathy Saltzman
Representative Julie Bunn
Xcel Energy SM
414 Nicollet illlall
Minneapolis, Minnesota 55401 -1993
February 27, 2009
Robert Criswell
Metro District
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55122 -4194
Re: A.S. King Ash Permit SW-54; Request for Re- issuance
Dear Mr. Criswell:
xcel Energy requesting uesting that the re- issuance of the King Landfill SW-54 continue under the
q
Application for Permit Re- issuance fled September 24, 2007. Included is a copy of the original re-
issuance application cover letter. The submittals for expansion of the King Landfill are formally
withdrawn.
As rt of this request xcel Energy is including an updated dust suppression plan that corresponds to
p q
the existing application for re- issuance.
Sincerely,
Manuel Castillo
Sr, Environmental Analyst
612-330-6506
Attachments:
c: Roger Clarke
Chuck Donkers
Scott Thomas
Tom Smith
Jeff Travis
Cary Bruns
Eric Johnson
ES Record Center
MP 3
MP 3
MP
King Plant
Washington County
Washington County
City of oak Park Heights
Dust Suppression Plan
A.S. Ding Ash Disposal Facility
Oak Park Heights, Minnesota
MPCA Permit # SW-54
Devised 2009
UK
The following document serves to provide a protocol for dust suppression at the
A.S. King Ash Disposal Facility. The plan addresses techniques for dust
suppression on road surfaces, in the active area and on closed areas. The dusting
conditions at any particular time may require a subset of the techniques
identified in this document and the attachments.
�piiq V1111111117 1:
Four techniques will be used for dust suppressio(fordusit access roads into and
around the A.S. Ding Ash Disposal Facility. Thefined as follows:
Road Maintenance /Grading: Roads will be d in a manner to
conform to Best Management Practices (BMP's suppression. Such
practices will include periodic removal of gravel that has been clogged with
fines and replacement with fresh gravel. Minimize road development and
remove roads that are no longer required and re- vegetate. Locate roads
minimize exposure to prevailing winds and use temporary or permanent
windbreaks or berms when applicable.
A wheel wash, will be located on the gravel exit road.' All trucks shall pass
over this wheel wash prior to exiting the site. The wheel wash will be re-
constructed as needed.
Daily Maintenance: Application of water will be the primary source of dust
control for daily maintenance. A self-contained water truck will be on -site at all
times. when conditions are right for dusting on the roads, additional personnel
will be brought to the site to ensure watering is being done - throughout the daily
operation of the landfill.
Chemical Mainte nceo The application of chemical dust suppressants may be
applied as needed, either by surface application or incorporation into the upper
2 - 3 inches of the surface gravel. The products can vary from salts to
biodegradable products that meet specific safety requirements. The attached
Bust Suppression Plan
A.S. King Ash Disposal Facility
Oak Park Heights, Minnesota
MPCA Permit # SW-54
Page 2
document, "Techniques for Dust Prevention and Suppression ", (Publication
Number 96 -433), Washington State Department of Ecology, provides a
reasonable selection process for use of these products.
Operational Restrictions: The operational restrictions that can be enforced
include reducing the speed limit of the vehicles traveling on the unpaved portion
of the facility roads, minimizing traffic on roads that are not required for active
operations and limiting traffic of tracked vehicles on the unpaved roads. These
restrictions will be used on an as- needed basis.
3.0 Techniques for Active Area Surfaces
The techniques for the active area include daily maintenance using a watering
true., chemical daily covers and operational restrictions. In addition, the
following additional techniques can be applied to minimize dusting on the active
area.
Operation Planning: Through good operations planning, dusting from the
active area can be kept to a minimum. Such items as using a small operations
area, staging fill to provide protection from the prevailing wind and placing
intermediate cover as quickly as practicable all serve to reduce dusting. In
addition, proper conditioning of ash and compaction of ash to achieve high
density is an excellent means to reduce dusting to acceptable levels. Also
important is to eliminate traffic of nonessential vehicles across the active area
either during or after daily operations.
4.0 Techniques for Closed Areas and Construction Activities
Final closure serves to stabilize areas of the disposal facility on a permanent
basis. The details of the final closure are fully discussed in the current permit
application document. However, proper maintenance and access restrictions
serve to prevent areas that are closed from becoming a dusting issue.
Established vegetation should be mowed and watered as require to maintain a
healthy vegetative cover at all times. Rutting and areas of surface erosion
should be repaired and a new vegetative cover should be established as quickly
as possible. +
Traffic should be prevented from accessing the final cover. Appropriate
postings and physical barriers should be placed to identify that the area is off
limits to vehicle traffic.
Dust Suppression Plan
A.S. King Ash Disposal Facility
Oak Park Heights, Minnesota
MPCA Permit # SW -54
Page 3
Where stockpiles arg required for construction, the piles should be shaped and
surface compacted. If the material is fine grained silt size material, tarps or
other chemical covers should be used to stabilize the stockpile. The techniques
for road surfaces should be applied to any area where construction has exposed
underlying soils. In addition, proper construction staging to minimize dusting
should be explicitly called out in the bid documents.
5 .0 Techniques for Off -site Roads
In addition to the wheel wash identified in Section 2. several techniques will be
implemented to control tracking of coal ash onto public roads and thus prone to
dusting.
Truck equipment: All trucks used for hauling will be fitted with oversized mud
flaps to prevent ash from getting on the trucks under carriage during the
dumping process. All trucks will be tarped (covered), 'n both directions, while
traveling between the ADF and the Plant.
'00 Street sweeping: The public roads between the ADF and the Plant will be swept
as needed. A commercial street sweeper, utilizing a wet spray ,will collect any
r aw irom the road and properly dispose of the sweepings. Street sweeping
will be limited to the months April thru November when minimum air
temperatures are above freezing.
Street washing:
A water truck will wet the street periodically from the Plant to the ADF on the
r
days ash is being hauled. Wetting the road surface will be lim to the months
April thru November when minimum air temperatures are above freezing.
Truck audits:
A security system has been installed, and is being tested, for auditing truck
compliance with tarping requirements. Random checks will be made each
month to ensure all trucks are tarped.
19 xcelEnergy SM
414 Nicoliet Mali
Minneapolis, Minnesota 55401 -1993
September 25, 2007
Mike Lynn
Metro District
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55155 -4194
Re: Application for Re- issuance Request: A.S. King Landfill SW-54;
Dear Mr. Lynn:
Xcel Energy y pp hereby applies for re-issuance of permit SW-54 for the operations of the A.S Ong
Landfill. On August 22 2007 Xcel Energy applied for a minor modification. to Permit SW -54d The
requested modification dealt with a change in the side slope of the landfill from the currently
permitted 4H: IV to 3H: IV, and lowering the top elevation to produce a net zero change in permitted
airspace_
WCA staff has conditionally approved the minor modification, and the application reflects the
p changes. Enclosed for your revi are four copies of the application with a full size set of
drawings.
Additional materials included are the Delegation of Authority for Roger Clarke, and copies of the
n
otification letters sent to the local officials. The signed return receipt forms will be sent separately
upon their arrival.
Sincerely,
0"
Manuel Castillo
Sr. Environmental Analyst
612- 330 -6506
Enclosure 8
cc: Scott Th om.e s
Roger Clarke
Chuck Donkers
John McCain
Darrell Knutson
ES Record Center
NT 8
MP 8
MP 8
McCain and Associates
King Plant
w/o enclosure
w/o enclosure
w/o enclosure
w/ o enclosure
e a �
�o ,ct`
r� CL
y�
qb
w
tz
m
as
}
C co Ov
C ❑
❑ V
� U
h m
0
N
Lij
cc
r.
ift
6
� g
tn
0
CD U)
U) a)
CU
�U)
cu W r (3)
CL
L
0 LrL �
a
cd
r 0 o
. C L
...�. Co
C)
C
• .>
w
. 40.-;
co (1) z U
E
CD
° Co (D
■0 ..3 cn
D-
x w E
0 w
CO 0
*� W
co
p N ���� - _ >
U) a.w� 0 W
P\
.� 0
Co
oU Co a
a.
0
w ,�,..� E
a) 0 (D
CL c�
,CD
C Co 0
0 Co
C � 0
co
4 """ 0 W
o a Co oo
CD 0 C: Cl)
:
0 �
a ) o ^rt 0
CD 4-A -W L.
'0 co
WARM
�: CD
CD ..0 Co
r °� M- M
aw-so 0 E
tl q
.a)
. v
r
r.
c
CD
o.
CU Co
-4-j
0 C: C:
co E
0 "
cts ,� .....
Co E
r M // O arf4
C $
co �0' .arcs
ova) C)
ri � t`
aw V
t!] `C� C6 >1
E < 0
0
� Co (,
tL 0 Cl) 0
co
co
cn -a r.L C:
..... o 0% 3:
cu C/) m � 0
C: W
M Wh 0 0 C0 o 0) 4-1 20) (D C Q.0.
4-
X 0 V
Cl) .4..j (1) _U) m
i� D U � C
L . Y
ID W
tai �°°�°� -.��' ;� .0 CD �]
0� ��:�. x z z
S - 5 V�
. .O"a , C.) o
C 6 -