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Home My WebLink About2008-10-23 Applicant Ltr. to OPHc End: 3 Sincerely, October 23, 2008 Dear Mr. Johnson: Eric A. Johnson City Administrator 14168 Oak Park Blvd N. P.O. Box 2007 Oak Park Heights, MN 55082 Re: Conditional Use Permit (CUP) Amendment: Enclosed are 3 copies of a request to amend the existing CUP. The application has taken into account the public's comments, and the City of Oak Park Heights concerns. In addition to the amended CUP, Xcel Energy will file an application to modify the existing Minnesota Pollution Control Agency PermitSW-54. you have any questions regarding the file please contact Chuck Donkers at (612) 330- 6082. c: Robert Criswell Jeff Travis Tom Smith John McCain Roger Clarke Chuck Donkers Scott Thomas ES Record Center Manuel Castillo Sr. Environmental Analyst 612-330-6506 MPCA Washington County King Plant McCain & Associates MP8 w/o enclosures MP8 w/o enclosures MP8 wlo enclosures 414 Nicollet Mali Minneapolis, Minnesota 55401-1993 2008 Permit Modification A.S. King Ash Disposal Facility Revised CUP Application 10/23/08 X Environmental Services 414 Nicollet Mall, RSQ8 Minneapolis, MN 55401 -1993 r t 200 Vert ical o King Ash Disposal Facility ctober 22, 20 ntrii ictiir The King Generating Plant was renovated under the Metro Emissions Reduction Program (MERP); this renovation resulted in the need for additional landfill capacity. XceI Energy had plans to construct a new facility and close the existing site in 2010/2011, however a moratorium was placed on permitting new landfills in 2008. The proposed expansion of the A.S. King Ash Disposal Facility (Moelter Landfill) will provide additional time for Xcel Energy to evaluate options and develop utilization markets while the MPCA conducts rule-making to address the landfill moratorium. In June 2008, Xcel Energy applied for an amended CUP to allow for the expansion of the AS King Ash Disposal Facility. Since that time, Xcel Energy has: 1) had more time to evaluate alternatives to disposing of ash at the Moelter Landfill; 2) hosted a public meeting to listen to citizens concerns; and 3) has had several discussions with City staff regarding landfill expansion issues. Xcel Energy has addressed many of the issues identified since its initial application and has significantly revised its proposal for the Moelter Landfill expansion. The public meeting identified dust issues associated with both the haul road and the landfill surface as a primary citizen concern. Xcel Energy has responded to this issue by taking the following actions, which will be incorporated into the facility's 2009 Operations and Maintenance Plan: 1) Increasing water applications to control dusting. 2) Modifying equipment to prevent ash from getting on the trucks' under carriage, thus reducing tracking on to the road. 3) Installing a security camera system to audit ash transport compliance. 4) Establishing a landfill hotline to record complaints. 5) Scheduling regular street sweeping between the plant and the landfill. The City identified concerns about excessive loading upon the sewer line, landscaping and park impacts. Xcel Energy has addressed these issues in this revised CUP application by incorporating previously-approved design criteria, established in City and State permits, which used in combination increase site capacity. Project Description The proposed expansion, shown on Sheet 4 of the plan set included as Attachment 1, will yield an additional 58,351 CY of ash capacity, and 62,638 CY of total capacity including final cover soils and drainage improvements. At present, all bottom ash (slag) is utilized and all fly ash (SDA ash) is landfill. However, XceI Energy has identified a utilization opportunity SDA ash. Assuming 50% SDA ash utilization, the proposed expansion will increase the landfill's life by approximately one year. The proposed expansion will occur only in areas that are already lined; no new construction is required for this expansion. The vertical expansion will have a peak elevation of 847.5 feet MSL. This is the peak elevation originally established in the 1995 Solid Waste permit and 1996 CUP, and was voluntarily kmered by )(eel Energy in a 2007 permit modification. This proposed expansion simply restores the peak elevation that has been previously approved by the City and the MPCA. cel Energy is cognizant of the neighborhood's desire to have a definitive end date for landfill operations. To address this issue, Xcel Energy will commit to an operational end date of 2011 with final closure activities completed no later than 2012, regardless of remaining capacity at that time. iSL: al impacts A visual impact analysis for the proposed expansion is provided as Attachment 2. Figures 1 and 2 of Attachment 2 are plan views of the landfill and surrounding area and show the active, uncapped area and proposed expansion area, respectively. Figures 1 and 2 also show the locations and fields of view for the photographic renderings that are included as Figures 3A & B through 5A & B. Photographs were taken from three vantage points, one on Hwy 36 with a view to the southeast (Figures 3A & B); one from Beach Road with a view to the south (Figures 4A & 4B); and one from Cover Manor with a view to the northeast (Figures 5A & B). The views show existing site conditions on May 15, 2008, along with superimposed renderings of the proposed expansion on the same photographs. The existing berm, visible from the Hwy 36 and Beach Road perspectives, provides a convenient reference point. The top of the berm has an elevation of 843 MSL, and the peak elevation for the vertical expansion is 847.6 feet MSL. Due to the relatively low profile of the proposed expansion, the enhanced landscaping that was previously proposed for screening is unnecessary for that purpose and might limit park amenity opportunities unless those amenities are designed in conjunction with landscaping design. Additional landscaping beyond establishment of turf was therefore not included in these renderings. Landscaping, Trails and Parks Xcel Energy proposes public access to the facility for both active and passive recreation as the ultimate end-use for the landfill. The expansion will not impact existing trails or the planned end use. However, it would be prudent to defer development of park amenities until the disposal facility is closed in 2012. Current use of the hiking/biking trails and green space can continue during final development of the landfill expansion. At this time, it is proposed that final landfill grades will be vegetated with a grass mixture; no enhanced landscaping is proposed. There are two reasons for this proposal: 1) final park designs are not available, and landscaping should be coordinated with the park design; 2) the final contours are relatively flat, with less intrusive topographic lines, therefore the previously-proposed landscaping for screening purposes is unnecessary. Xcel Energy is committed to funding additional enhancements, however it wishes to have the city take the lead in planning and developing the park project. Xcel Energy will work ‘Atith the City to gain MPCA approval for site modifications ass ciated with park development Terms and conditions fir this work can be specified in the CUR Utilities Earlier proposals had identified a final grade of 877.5 feet MSL, which triggered a concern regarding sewer pipe integrity. The current proposal calls for a final grade of 847.4 feet MSL. This elevation was previously analyzed and accepted without conditions in the CUP. Although it is not in the city's five-year plan, re-routing the sewer pipe has been contemplated. A possible route would cross along the facilities northern edge. If such a route is selected, Xcei Energy will work with city officials to establish an easement. Description of Visual Impact Analysis Figure 1 Figure 2 Figure 3A Figure 3B Figure 4A Figure 4B Figure 5A Figure 5B Visual Impact Analysis 2( 08 Vertical Expansion October 22, 2008 A.S. King Ash Disposal Facility MPCA Permit No SW-54 A.S. King Generating Plant Oak Park Heights, Minnesota Table of Contents Photo Rendering Location Map (current conditions) Photo Rendering Location Map (proposed expansion) Current Conditions, Camera Location I Proposed Expansion, Camera Location 1 Current Conditions, Camera Location 2 Proposed Expansion, Camera Location 2 Current Conditions, Camera Location 3 Proposed Expansion, Camera Location 3 Visual Impact Analysis Z008 Vertical Expansion A.S. King Ash Disposal Facility This report presents an analysis of visual impacts from the proposed vertical expansion of the A.S. King Ash Disposal Facility. The analysis consists of presentation of rendered photographs taken from three vantage points around the facility. For each vantage point, two depictions are presented: 1) Photograph showing existing conditions (how the site appears as of the date of the photograph) 2) Rendered photograph showing the proposed expansion (how the facility would appear with the vertical expansion, peak elevation 847„5) Photographs of the site were taken on May 7, 2008 for Camera Location 1 (north frontage road on Hwy 36 in front of the County Government Building), and on May 15 for Camera Location 2 (top of entrance ramp to westbound Hwy 36 at Beach Road) and Camera Location 3 (east facility property line, in front of Cover Manor). The coordinate locations and elevations for each camera location and target direction were surveyed so that an accurate perspective could be produced. In order to accurately portray the future conditions, a three - dimensional CAD model was developed for the proposed expansion. The CAD model was then "viewed" from the surveyed camera and target locations in a perspective mode that accurately displays a camera perspective view. A "wirefranle" model of the future conditions was extracted from the CAD model for each perspective and converted to a graphic file format for rendering. The wireframe models of future conditions were superimposed on the photographs, and rendered with a turf grass texture using Photoshop CS2 software to produce the final rendered images. Figures 1 and 2 show in plan view the Moelter Landfill site and surrounding area, including the currently - permitted, active (uncapped) ash fill area (Figure 1) and the proposed expansion fill area (Figure 2). Figures 1 and 2 also show the camera locations and fields of view for the base and rendered photographs. Figures 3A and 3B show existing conditions and proposed expansion, respectively, from Camera Location 1. 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