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February 10, 2012Marcus Zbinden, Environmental Specialist III
Kellie Kish, Environmental Specialist I
Carver County’s Comments to MPCA Source Separated Organic
Compost Facility Rules
Carver County Organics Demonstration SiteArboretum Site I Mayer Site
Arboretum Site II
Site Location
Arboretum I Mayer Arboretum II
Capacity 40,000 yds at any one time
100,000 yds annually
13,000 yds annually
Material Type
Co-collected residential with large volumes of commercial accepted in year 3
Co-collected Residential and Commercial
Primarily co-collected residential with limited commercial
Management Method
Static Piles Static Piles Aerated Static Piles
Average Pile Height
20 feet 20 feet 12 feet
Distance to Neighbors
250 feet 400 feet 1,800 feet
Demonstration Site Comparison
Arboretum II (SET)
Site:• Size- 2.5 acres• Site pad – All weather surface
of 3 inches of 1½ minus limestone and 3 inches class V
• Lester Kilkenny clay loam soil Profile:
0 – 7 inches: Clay loam 7 – 38 inches: Clay loam 38 – 80 inches: Loam
• Depth to seasonally saturated soil is 12 inches
• Depth to water table is >80 inches (National Cooperative Soil Survey)
Installing Water Collection Tubes
Lysimeter Placement at Arboretum II
Site:
• Only 16% of lysimeters under piles had some liquid present but none had sufficient volume to be analyzed.
Oct. 11th - 13th: 0.74” rainfall event
Contact Water Analytical Results
(Metals)Paramete
r
Carver Co. Average
(ppm)
Landfill* (mid-range)
(ppm)
Landfill* (high-range)
(ppm)
Drinking Water Limit
(ppm)
Arsenic 3.91 500 1,700 10***
Barium 565.12 1,500 5,000 2,000
Cadmium .0025 8 70 4
Copper 11.35 30 140 1,300
Lead ND 300 1,400 15**
Mercury ND .7 2 2
Nickel 23.12 1,000 2,000 100
Selenium 3.18 500 1,300 30
Silver ND**** 40 50 30
Zinc 126.3 400 18,000 2,000* Landfill mid-range and high-range data was taken from Land Treatment of Landfill Leachate. MPCA, April 2011.** No HRL has been set for these elements as they are not found in source waters.*** The HRL for Arsenic was changed from 50 ug/L to 10 ug/L in 2006.**** Silver was sampled at ARB I and Mayer sites only.
Agronomic ConstituentsParamete
rCC Avg.
(ppm)
Landfill* (mid)(ppm)
Landfill* (high)(ppm)
Drinking Water Limit(ppm)
Nitrates 2,999 n/a n/a 10,000
Phosphorous
425.33 1,000 3,000 No HRL Set
Potassium 137,072.22**
140,000 320,000 No HRL Set
TKN 5,103.57*** n/a n/a No HRL Set
TOC 79,735 n/a n/a No HRL Set* Landfill mid-range and high-range data was taken from Land Treatment of Landfill Leachate. MPCA, April 2011.** Potassium sampled at ARB I only.*** TKN – 2 samples from ARB II were not analyzed correctly for Nitrates by PACE – both returned ND results.
Chromium & Copper
Chromium Copper0
50
100
150
200
250
300
350
CC Average
Landfill* (mid)
Landfill* (high)
Drinking Water Limit
Parameter ARB II (ppm)
Landfill* (mid)(ppm)
Landfill* (high)(ppm)
TDS 668.5 6,000,000 20,000,000
TSS ND 1,300,000 5,000,000
TDS & TSS
* Landfill mid-range and high-range data was taken from Land Treatment of Landfill Leachate. MPCA, April 2011.
(ppm
)
Residential Organics Collection
Residential Source Separated – Co-
Collected
September 26, 2011 load from Edina -Vierkant Waste Sort
Organics 2,318 lbs. 6 yards 21% (by weight) Yard Waste 8,800 lbs. 12 yards 78% (by weight) Contamination 43 lbs. .17 yards <1% (by weight)
Commercial Organics
Carver County Comments on Rules
Subp 3. B. Operator may establish a source-separated organics waste composting facility within 5 feet of water table.
Recommendation: If aquifer is that of MN Rule 4725.0100, Supb. 21, Carver County accepts rule change.
MN Rule 4725.0100, Subp. 21: “Aquifer” means a stratum of saturated, permeable bedrock or unconsolidated material having a recognizable water table or potentiometric surface which is capable of producing water to supply a well.
Carver County Comments on
RulesSupb. 8. F. The active composting, curing and storage areas for immature compost must be located on an impervious surface…
1.Contact water test results from organics demonstration sites demonstrate that there is no contact water leaving the site that exceed testing standards for drinking water.
2. Contact water levels in lysimeter installed at the demonstration site supports industry findings that compost piles absorb most moisture from rain events and allow little to enter surface water containment area or infiltrate into sub-soils.
Recommendation:• Tipping Pad - 6 inches of Class V as a minimum• Active composting, processing and curing areas – all
weather working surface which is defined as any surface that allows the ability of equipment and hauling trucks to access site for 365 days of operations.
Site Size (acres)
Class V Needed (tons)
Total Cost (Estimate:
$19.50/ton)
ARB II 2 4,840 $94,380
ARB I 4 9,680 $118,760
Mayer 7 16,940 $330,330
Tipping Pad .5 1210 $23,595
Estimated Pad Costs
1 acre = 43,560 ft2 2’ Class V to cover 1 acre = 2,420 tons
7035.2555 Subp. 3. Minimum of 500 feet horizontal separation distance from the facility to the nearest residence, place of business or public contact area.
• There is no distance requirement for either solid waste compost facility or yard waste compost facilities; there should not be a mandated distance for SSO facilities.
• Facilities vary in size, capacity, feedstock, topography and zoning.
Recommendation:• Allow local units of government to establish
distance requirements on a case by case basis. • Provide distance requirement in guidance
document.
Carver County Comments on
Rules
Compost Data Team ReportOctober 30, 2009
Background:• Data Team comprised of 4 metro county staff and 2
MPCA staff led by Allen Dotson and Geoffrey Strack.• Team was formed to complete revision of MPCA’s
Demonstration Agreement and review other state regulation on composting.
Conclusions:• Data from demonstration projects may help
answer questions regarding contamination in contact water.
• May be reasonable to provide flexibility on composting pad requirements, varying for example with site-specific soils types, feedstock types, location and scale of operation.
Recommended Tiers:I. Backyard Composter No MPCA permit or training required
II. Yard Waste Permit by Rule
III. Small Site Recommend increase to 100yds3 annually or equivalent weight
IV. Residential Source Separated V. Commercial Source Separated 0ther material as approved by MPCA
VII. MSW
• Regulation and permitting requirements become more stringent as the types or tonnages of organics material increases.o Residential co-collected sites should have reduced horizontal distance
requirement and potentially a less restrictive pad requirement. o Residential co-collected sites should also have less strict operating
procedures such as mixing material by the end of the day versus immediate cover and/or processing for commercial facilities.
Potential CompromisesAllow less stringent pad requirement and separation distance if the following conditions are met:
1. Site operator must take soil sample under processing and curing area prior to site development and periodically thereafter to ensure no contamination of ground water is occurring.
2. Facility operator could also elect to install lysimeters and take periodic samples.
3. If finished compost or contact water tests show issues, require additional testing or mediation.