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HomeMy WebLinkAboutCouncil Information Memorandum 03-02-1989CITY COUNCIL INFORMATIONAL MEMORANDUM March 2, 1989 RECYCLING CASH DRAWING March 2: No Winner Next Week: $300 Cash Award UPCOMING MEETINGS AND EVENTS..... 1. COUNCIL STUDY MEETING -- Monday, March 6, 5:30 p.m. Council study meeting in City Council conference room. 2. COUNCIL MEETING -- Monday, March 6, 7:30 p.m. Regular City Council meeting in City Council Chambers. 3. TWIN WEST "STATE OF THE CITY" ANNUAL COFFEE BREAK MEETING -- Wednesday, March 8, 8:00 a.m. Coffee and rolls will be provided. A copy of the announcement is attached. (M-3) 4. PLANNING COMMISSION -- Wednesday, March 8. The Planning Commission Forum will begin at 7:15 p.m., with the regular Planning Commission meeting following at 7:30 p.m. in the City Council chambers. Agenda attached. (M-4) 5. PARK & RECREATION ADVISORY COMMISSION -- Thursday, March 9, 7:30 p.m. The Park and Recreation Advisory Commission will meet in the City Council chambers. Agenda attached. (M-5) 6. MEETING CALENDARS -- Meeting calendars for March and April are attached. The March calendar has been revised to show the cancellation of the March 14 Board of Zoning meeting. (M-6) 3400 PLYMOUTH BOULEVARD, PLYMOUTH, MINNESOTA 55447, TELEPHONE (612) 559-2800 CITY COUNCIL INFORMATIONAL MEMORNDUM March 2, 1989 Page 2 FOR YOUR INFORMATION.... 1. REVISED OPTICAL SCAN AGREEMENT - The City Council approved an Optical Scan Voting Machine Agreement in 1988 which sets forth the understandings between the City and school districts if they desire to use the City's Optical Scan voting equipment for school district elections. No school districts have signed the agreement to date; however, Wayzata School District No. 281 has indicated a possible interest in using the equipment in 1990. The City Attorney has reviewed the Agreement to ensure that it conforms with recent State law changes. The attached agreement conforms to the new laws and will take the place of the agreement previously approved by the City Council. (I-1) 2. TRANSFER STATION FINAL SEIS -- Attached is the Final Supplemental EIS for the Hennepin County Resource Recovery Transfer Stations. The Metro Council has placed the adequacy determination on its agenda for March 23 at 4:00 p.m. (I-2) 3. RESIDENT FEEDBACK FORMS -- Staff responses to resident feedback forms from the February 13 Town Meeting are attached. (I-3) 4. LEGAL DEADLINE FOR POST NEWSPAPER -- Post Publications has announced a change in its publication date and legal deadline. The paper is now published on a Wednesday date instead of Thursday. Legal notices for publication are to be submitted to the paper by noon Friday rather than 2:00 p.m. on Friday. A letter on the changes is attached. (I-4) 5. HWY 12/I-394 UPDATE -- Charleen Zimmer of Strgar-Roscoe-Fausch, Inc., has provided the attached fact sheets and construction timetables on the Highway 12/I-394 project. (I-5) 6. COMMUNITY IMPROVEMENT REMINDER CARD -- Attached is a memorandum from Fred Moore responding to a sight distance complaint at the stop sign on 38th Avenue and Plymouth Boulevard. (I-6) 7. BZ CORRESPONDENCE -- I have received the following correspondence on City departments or employees: a. Department Commendation Award to Jane Laurence Cooper for her work on the Deer Task Force studies. (I -7a) b. Note of appreciation from Paul and Vivian Mohr for assistance provided by Plymouth police. (I -7b) c. Note of appreciation from Patrick and Mark Albrecht to Plymouth police for tour of department offices. (I -7c) CITY COUNCIL INFORNATIONAL NEMORNDUM March 2, 1989 Page 3 8. INDEPENDENT SCHOOL DISTRICT 281 - ROBBINSDALE - SUPERINTENDENT'S COMMUNITY ADVISORY MEETING - Councilmember Zitur attended a recent meeting of District 281 in which state funding and district finances were discussed. Attached are the materials which Bob was provided. The data had been prepared by the School District in order to acquaint the public with the condition of their general fund and the need for additional state funding to support their general fund. (I-8) 9. DEATH OF FORMER CITY COUNCILMEMBER ED HINTZ - Former City Councilmember Ed Hintz passed away Thursday in Lancaster, South Carolina. Ed was a member of the Plymouth Council between 1970 and 1971. Ed is survived by his wife Connie and son Matt. The funeral will be held Saturday in Lancaster and I have sent a memorial on behalf of the City. 10. CORRESPONDENCE: a. Letter from Mayor Schneider responding to Mrs. Robert Thoren, 4385 Trenton Lane, concerning transit service improvements near the Sagamore and Hummingbird Cove condominiums. (I -10a) b. Letter to Ronald Goltz, 17615 - 8th Avenue North, from Chuck Dillerud, regarding the landscaping plans of the Wayzata Evangelical Free Church. (I -10b) c. Letter to Mrs. Mary Doherty, 17830 - 8th Avenue North, from City Manager, in response to Councilmember Vasiliou's inquiry on requirements and procedures for dredging the pond adjacent to her property. (I -10c) d. Letter from Mayor Schneider, responding to Loretta Chown, on the City's parking 2 a.m. to 5 a.m. parking ban ordinance. (I -10d) e. Letter to Chuck Speier, 11100 - 39th Avenue North, from Mayor Schneider, regarding the Zachary Lane improvement project. (I -10e) Twin West Chamber of Commerce State of the City Community Coffee Breaks During March, TwinWest brings its Coffee Breaks to city hall for a "State of the City" presentation by city staff and,elected officials in each community. It is your opportunity to learn- about local 'hap-" penings including new and proposed developments, public improve- ment projects, proposed ordinances and other matters that affect businesses in your community. The Coffee Breaks are held from 8:00 - 9:00 am. and coffee and rolls are provided The State of the City Coffees are always TwinWesfs most highly attended and informative coffee breaks of the year. Please join us! Wednesday, March 1 St. Louis Park City Hall 5005 Minnetonka Boulevard Tuesday, March 7 Crystal City Hall 4141 Douglas Drive Wednesday, March 8 Plymouth City Hall 3400 Plymouth Boulevard Wednesday, March 15 Minnetonka City Hall 14600 Minnetonka Boulevard Oir 0,1 Monday, March 20 New Hope City Hall ZFw HOQ`` 4401 Xylon Avenue North Thursday, March 23 Hopkins City Hall 1010 South 1st Street CITY Of HOPKINS Tuesday, March 28 Golden Valley Brookview Community Center Clty of Golden Valley 8200 Wayzata Boulevard Coffee Breaks are free and no reservation is required. Ask a business associate to join you! PLANNING COMMISSION MEETING AGENDA WEDNESDAY, MARCH 8, 1989 CITY COUNCIL CHAMBERS A —'A WHERE: Plymouth City Center 3400 Plymouth Boulevard Plymouth, MN 55447 CONSENT AGENDA All items listed with an asterisk (*) are considered to be routine by the Planning Commission and will be enacted by one motion. There will be no separate discussion of these items unless a Commissioner, citizen or petitioner so requests, in which event the item will be removed from the consent agenda and considered in normal sequence on the agenda. PUBLIC FORUM 7:15 P.M. 1. CALL TO ORDER 7:30 P.M. 2. ROLL CALL 3.* CONSENT AGENDA 4.* APPROVAL OF MINUTES February 22, 1989 5. PUBLIC HEARINGS A. Request of Sandra Bebault for a Conditional Use Permit to operate a beauty salon located in her home at 10921 36th Avenue North (89003) 6. OTHER BUSINESS A. Comprehensive Plan Update 7. ADJOURNMENT 10:00 P.M. (pc/cd/3-8:jaw) Regular Meeting of the Park and Recreation Advisory Commission March 9, 1989, 7:30 p.m. AGENDA I. Call to Order 2. Approval of Minutes 3. Visitor Presentations a. Athletic Associations b. Staff c. Others 4. Report on Past Council Action a. Final Payment Parkers Lake Pavilion b. Selected Community Center Architect (BWBR) c. Accepted PRAC Annual Report d. Approved 1989 Park Rental Policies and Fee Schedule 5. Unfinished Business a. Comprehensive Plan - Continue Discussion b. Plat North of Mooney Lake c. West Medicine Lake Drive Trail d. Plymouth Creek Parking Lot Expansion e. f. 6. New Business a. New Plats b. C. d. 7. Commission Presentation B. Staff Communication 9. Adjournment Next Regular PRAC Meeting April 13, 1989 M -S 00 0) r� z U Q QI = N QI i^O N co H m Y M 6 7 r r N n m F W LL O O N 0 N M—� O N •�" N m ^ r N N LL 00 1 o, ~ Go �1 W iii N m to J Q N 0. cr tf Q j C4 b F z M O N O f z N m (a N LO H 00 0) r� z U Q QI = N QI i^O N co H m Y M 6 7 r r N n m F W LL O O N 0 N M—� m 00 1 N Q M Q cr b D cQn LO N 0 c N ]C LL G a � Q Q N Lc LL N Ch M C, F z cn w� w� D Ma wa = M O N a� M ruiOdO E Q) Ln UOO M 3 4- M Z CD 0 CU 4-j CO ro LO couj +-* coO- = 4 CD J r' r Q Q W H W d Z V� cn Z� C b ten. i OQ O O U O Z N U O M �� h-1 T ••�(D� OowX N r�LU F -c00 o � z NW a f }Q a Q Z N N (0 N Ul) r- O M N �y N LL x ' N cc 01 D pcoj O P'f O it N M Q LO N W LO N V N CO o N T C i N N P, CO to N N } cr LL r00 t� r- N N } L, 0 Q Z o ` C3 cn F- W E � f � F- W U O g m O NCC _ N oaU T-. O aLL! OZ Z M o C3 M ►-r n WCNZ 1� Z S OE TT �QC3 LO r- W 2, r- C%4" F- aX: C.D z 007 C/)� w U_oa. F- o �o r M 00 U) [1. r- m N _J �C7 U LD O 0Z-4 X: Q O LAJ U O �-� F -g rz W� O a Z M W N LLJ _ M N O Q 1 E Q --� W O 00C3 LL M Z=O N C3 C3 W F- O O ¢ r� qqt = N Of t0 M O M�� �- r� �� N � f�f DD ^f W CO Ln N Cf _ ; N N r, Q W N a- Q H W ^ N Ncl Z Or C � N N N LO y N N N O M AGREEMENT THIS AGREEMENT is made this day of , 1988, by and between the CITY OF PLYMOUTH, a Minnesota municipal corporation ("City") and INDEPENDENT SCHOOL DISTRICT NO. , an independent school district organized under the laws of the State of Minnesota ("School District"). WHEREAS, the City has purchased 16 optical scan electronic voting machines ("Voting Machines"), to be used at the 16 pre- cinct voting locations for city, state, and national elections; and WHEREAS, the School District desires to make use of the Voting Machines for school district elections and bond referenda. NOW, THEREFORE, in consideration of the mutual covenants set forth herein, the parties agree as follows: 1. School District Use. Upon request by the School District, the City will make available the Voting Machines to the School District under the conditions described below, except that the Voting Machines will not be made available to the School District until the City has used the Voting Machines for two elections as provided for in the maintenance and technical agreement that was included in the initial cost of the Voting Machines. 2. Election Judges. The School District will provide, pay and supervise all election judges required for School District elections and bond referenda. 3. Instruction. The School district will allow only properly instructed individuals, as determined by the City, to serve as election judges or any other official in charge of the Voting Machines. The School District will pay all costs of instructing such individuals. The School District will also instruct voters in the use of the Voting Machines. 4. Testing. The School District will test the Voting Machines as required by Minnesota Statutes Section 206.83 and will bear the costs of such tests and any necessary corrections or adjustments that the tests disclose. 5. Delivery to Polling Place. The School District will arrange for and pay all costs of transporting the Voting Machines from their locations to the polling places and returning the Voting Machines from the polling places to their original loca- tions. The School District will assume responsibility for and pay all costs associated with having the Voting Machines put in order, set, adjusted, and made ready for voting prior to School District elections, as required by Minnesota Statutes Section 206.90. 6. Loss or Damage; Insurance. The School District assumes all liability for loss of or damage to the Voting Machines while the machines are in the possession of the School District, its agents or employees. The School District will obtain insurance in an amount satisfactory to the City to provide first dollar coverage for any loss of or damage to the Voting Machines while in the possession of the School District, its agents or employ- ees. Such insurance will list the City as an additional named insured. The School District must provide proof to the City that 2 such insurance is currently in force before the City will make the Voting Machines available to the School District. 7. Indemnity. The School District will indemnify the City against any claim or cause of action for personal injury or property damage arising out of the transportation, installation, or use of the Voting Machines by the School District, its agents or employees. 8. Term. This Agreement shall terminate in five years from the above date, unless extended by mutual written agreement of the parties. 9. Amendment. This Agreement may be amended only by written agreement of both parties. IN WITNESS WHEREOF, the undersigned hereby execute this Agreement on behalf of the respective parties. CITY OF PLYMOUTH By Its Mayor By Its City Manager 0066AGO1.I48 01 INDEPENDENT SCHOOL DISTRICT NO. By Its By Its �1 oZ- METROPOLITAN COUNCIL Mears Park centre, 230 East Fifth Street, St Paul, MN. 55101 612 291-6359 r� 1'Y: February 23, 1989 Cp MkR _ li j 9a9 Gregg Downing, Environmental Review Coordinator Environmental Quality Board' �£- 300 Centennial Office Bldg. 658 Cedar Street St. Paul, MN 55155 Dear Mr. Downing: Enclosed is a copy of the Hennepin County Resource Recovery Transfer Stations Final Supplemental EIS. The Metropolitan Council approved its release today. Please publish the following notice in the March 6, 1989 issue of the EQB Monitor. The Metropolitan Council has released the Hennepin County Resource Recovery Transfer Stations Final Supplemental EIS. Copies of the document are available at the Metropolitan Council Data Center on the third floor of its office in Mears Park Centre, 230 East Fifth St., St. Paul, MN 55101 (telephone 612-291-6400). The adequacy determination is on the agenda for the Council's 4:00 p.m. meeting on March 23, 1989 at the above address. Arrangements for public comment should be made with the Council's project manager for this EIS, Wayne Nelson (telephone 612-291-6406). Cordially, Wayne Nelson Solid Waste Division Enclosure cc: EQB Distribution List Interested Parties List WN5007 HENNEPIN COUNTY RESOURCE RECOVERY TRANSFER STATIONS FINAL SUPPLEMENTAL EIS Prepared by Metropolitan Council of the Twin Cities Area Mears Park Centre, 230 East Fifth Street St. Paul, Minnesota 55101 Publication No. 521-89-032 February 1989 TABLE OF CONTENTS Page Introduction 1 Section One 1 Minneapolis public meeting, comments and responses 1 New Hope public meeting, comments and responses 8 Responses to written comments 13 Section Two - Additions To The Draft SEIS Text 21 Section Three - Written Comments 22 HENNEPIN COUNTY RESOURCE RECOVERY TRANSFER STATIONS - FINAL SEIS Environmental Quality Board Rules allow the response to written comments on a draft supplemental environmental impact statement (SEIS) to be distributed as the final SEIS if only minor changes are made in the draft document. This document responds to both the verbal and written comments presented during the comment period and identifies minor changes in the draft document. Thus the final SEIS, the draft SEIS and the original EIS together constitute the complete environmental review of the proposed changes in the Hennepin County transfer station network. The Metropolitan Council conducted two meetings to receive comments on the draft SEIS. About 80 people attended in addition to county and Metropolitan Council officials. The sign -in sheets, presentation scripts and tape recordings have been retained along with this document as the public meeting record. This document is organized in three sections. The first contains the public meeting comments and responses plus responses to the written comments. The comments and responses are numbered to coincide for reference purposes. The middle section contains changes and additions to the text of the draft SEIS. The final section contains the written comments received by the Council. SECTION ONE PUBLIC MEETING COMMENTS AND RESPONSES Hennepin Draft SEIS Meeting Minneapolis - Stewart Park Multipurpose Meeting Room January 3, 1989 Council member Josephine Nunn called the meeting to order at 7:05 pm. Approximately 30 people were in the audience and those who signed in are indicated on the attached list. The other Metropolitan Council members present were: Joan Campbell, John Evans and Carol Flynn. Ms. Nunn followed the attached convenor script. Wayne Nelson of the Council's Solid Waste Division presented an overview of the draft study using slides of figures from the document. The original EIS evaluating the mass -burn facility and a network of four transfer stations was completed in 1986. It included nine alternative transfer station sites. Three new transfer station sites have been selected by the county and these are the subject of the SEIS along with two additional alternative locations. Mr. Nelson described the transfer station design and operational expectations. He then explained how the study addressed governmental approvals, geology and soils, surface water, land use and zoning, transportation, noise, solid waste system impacts, utilities, local community -impacts, wasteshed analysis, aesthetics and historical/cultural resources, and flora and fauna. Patricia Christensen offered testimony first. (1) She felt the meeting should have been conducted 3-5 years earlier before decisions had been made. (2) She challenged the reliability of the burner. (3) She asked where the garbage will go if the burner doesn't work and how rats and flies will be prevented. (14) She would like more detailed information about recycling operations anticipated at the facility including the operation of a conveyor and management of hazardous waste like copier toner mixed with trash. (5) How will plastics be sorted out. (6) She believes as much as 90 percent of waste could be recycled and reduce the need the county system. Christensen response 1 - Meetings on the original EIS were conducted during 1986 for this purpose. 2 - The reliablity of the incinerator is not an issue in the SEIS scoping document and is not relevant to the environmental suitability of the transfer stations. 3 - If the incinerator is out of service, the transfer stations will redirect deliveries to other waste processing facilities or landfills without disrupting. trash collection services. Rats and flies will be prevented by promptly moving mixed waste through the station into transport trucks, removal of waste on a daily basis and the application of chemicals by a licensed pest control service if problems are detected. 4 - Recyclable separation operations will be developed on an experimental basis by the county. Separation operations where the organic residues are promptly disposed have no history of environmental problems with off-site risk potential. Copier toner is not a typical household hazardous waste, but it would likely be placed in a labeled container and either recycled or disposed as hazardous waste if delivered to the station. Household hazardous waste will be stored in a separate room designed with concrete sills and special heating and air conditioning controls to contain any spills and prevent air dispersal in the event of an accident. Recycling staging and storage operations are defined adequately for purposes of environmental review. These operations are traditional types of industrial activity that will be adjusted based on the types and volumes of materials actually delivered to the facility. The operations do not pose environmental risks identified in the scoping decision and are not listed as a review category in Environmental Quality Board rules. 5 - Plastics are not currently expected to be sorted from mixed waste., but hand picking is a future possibility. 6 - More recycling would require shifting the mix of waste and recycled materials management within the transfer stations without affecting the overall need for transfer stations. Ray Peterson reported the Phillips Neighborhood Improvement Association has no specific position yet on the study although it requested the environmental review. (1) Particular concerns include the rerouting of 22nd Ave. S. How does the connection with 29th St. affect the signal at 21st Ave. and Lake St? (2) Will increased truck traffic at Cedar Ave. and 28th St. affect the nursing home there or other nearby residents? Another site was rejected because of potential impact on a nursing home. (3) The High -Lake Center was not specifically analyzed in the land use analysis and none of its tenants are mentioned by name. (4) Does the proposed site compare favorably with the alternative Crosstown site indicated on page 28? (5) The details about recycling are not clear enough. (6) If volume goes beyond 700 TPD, will there be additional review? Peterson response 1 - 22nd Ave. will be eliminated within the transfer station site, but a local street around the site will be constructed to connect with 21st Ave. Use of 21st Ave. by loaded compactor trucks would violate a city ordinance requiring the use of truck routes when feasible for truck delivery operations. The only truck route facility access available is off 28th St. Minneapolis Weights and Measures staff and law enforcement officials have the authority to issue -2- T ;::L, citations for violation of this ordinance. The arriving and departing peak hour traffic associated with the facility totals only 33 vehicles from 7:00 to 8:00 am. and 36 vehicles from 4:30 to 5:30 pm. If half of these vehicles used the Lake and 21st Ave. intersection, the numbers involved are less than 20 arrivals and departures each hour. Assuming measures to discourage compactor trucks are effective, the trips would consist of residents and employees and the impact at the Lake St. and 21st Ave. signal would be negligible. Site access through this intersection will not be more convenient than for the existing transfer station and the situation will not change appreciably because combined traffic flow from the existing station and the six businesses and 27 residences displaced by the new station likely exceeded 20 arrivals and departures each hour. The county could install a sign at the facility entrance denying access to trucks observed entering from 21st Ave. and a portable barrier or curbing could be installed just inside the facility entrance (off 29th St.) to make it difficult for trucks to enter or exit the facility via the 21st Ave. route. Selective truck route enforcement by local police or the county sheriff could also be instituted. 2 - Impacts on residents and nursing home occupants near Cedar Ave and 28th St. are not likely to be perceptible. Facility traffic at 28th St. and Cedar will involve a maximum of 11 vehicles in the am. or pm. peak traffic hours out of a total volume of more than 2,000 vehicles using the intersection each hour in 1989. The peak hour of truck traffic from the facility will occur between 11:00 am. and noon and involve a maximum of 81 trips. The study projects that 35 percent of the facility traffic other than transfer trailers will use the Cedar and 28th Ave. intersection. Thus a maximum of 26 trucks are likely to use the intersection during the busiest hour of facility operations. The highest volumes of trucks associated with the facility are insignificant in comparison with the current volumes experienced during rush hours. The high truck traffic from the facility will occur about midday when the roads are least used. 3 - The "existing land uses" description on p. 64 should indicate that the High - Lake Center is immediately to the south of the site. The High -Lake Center is multi -tenant shopping center that includes a grocery store. 4 - The site compares favorably with the Crosstown site in terms of size, convenience of access (improvements to I -35E could eliminate convenient freeway access), zoning, noise (immediately adjacent to residential) and development issues (cement plant demolition and possible relocation). It compares about evenly on the other criteria. 5 - See Christensen response # 4. 6 - Additional environmental review could be required if the transfer station plan is changed substantially and the changes pose a risk of significant adverse environmental impacts. Throughput volume increases are subject to control through the MPCA permit and county licensing and intake over 700 tons in a single day would not represent so substantial a change as to require additional environmental review. Al Eggen represented the Seward South Project Review Committee. (1) It is concerned the station would be detrimental to the industrial park proposed for development north of the Minnehaha Mall. (2) A Cub food store planned at 26th Ave. & 28th St. would attract 2,000 cars per day which might exceed roadway capacities if the transfer station is approved. (3) If transport trucks for the incinerator take Hiawatha and proceed through downtown on 7th St., will the litter problems be acceptable? Eggen response 1 - The Minnehaha Mall is east of Hiawatha Ave. and the railroad property that -3- .--� 7 vZ� currently presents a barrier to facility associated truck traffic that would use Hiawatha Ave. Facility truck traffic would have essentially no impact on this neighborhood as long as 28th St. continues to terminate at Hiawatha Ave. When 28th St. is extended to the east, the residents and local haulers with destinations in this direction would be likely to use this route. The wasteshed map projection suggests by its general vertical alignment that the north/south arterials will continue to serve as the preferred access routes to the facility. 2 - A Cub Food store would attract much more traffic than a transfer station. 3 - Transport trucks will be routed through the interstate highway system to the incinerator. Leslie Davis represented "the Earth Protector Organization and all people of Minneapolis with any brains." (1) Recycling only 20 percent of the waste is inadequate. (2) Is it even needed along with the Reuter facility? (3) A complete plan for the recycling operations should be included. (4) There's not enough garbage in South Mpls. to justify a transfer station when the burner is three miles away downtown. (5) If 350 TPD of garbage is currently being transferred on a half -acre site, why is a 10 -acre site needed for 400 to 700 TPD in a new facility? (6) What is the total traffic volume likely at the facility including resident deliveries? Davis response 1 - Environmental review is not the forum for establishing waste management system priorities. This review evaluates the risks associated specifically with the transfer station proposals. 2 - The wasteshed analysis includes the Reuter facility and the downtown incinerator. 3 - See Christensen response #4. 4 - The Minneapolis transfer station proximity to the downtown incinerator is desirable because of the large volume of trash generated in this heavily urbanized area and the intervening downtown traffic situation. 5 - The transfer station will dramatically decrease the number of vehicles delivering to the incinerator and assure that the highway network will be used to the maximum feasible extent. A 10 -acre site offers significantly better buffering and traffic management capabilities. 6 - The maximum daily traffic volume is estimated on page 82 at 790 incoming and outgoing trips including trucks as well as employees and citizens. City Council member Tony Scallon (1) reported that garbage trucks are currently diverting off the area of 18th Ave. and Cedar Ave. into residential neighborhoods. Mitigation is a serious need for this situation. The city may not be able to handle this problem even though the use of residential streets for truck transport is not legal. (2) A clearer recycling plan would be helpful. Scallon response 1 - Apparently some haulers currently use 18th Ave. S. a block west of Cedar Ave. to avoid turning from Lake St. at that signalized intersection. The same problem could occur on Longfellow Ave. a block east of Cedar to avoid the signal for southbound traffic approaching 28th St. These residential streets could be posted with signs indicating "trucks prohibited except to access residences". A warning system could be implemented based on residents reporting the license registrations of haul vehicles observed on the residential streets.- County staff could follow-up with license inspections or encouragement to file misdemeanor complaints against driver violators observed -4- more than once. A barrier could be erected at the intersection of the facility access road and 28th St. to discourage eastbound traffic from entering and westbound traffic from exiting. With a city's concurrence, the county has been receptive to designating access routes. These routes can be enforced through citations by the police or authorized county staff. The problem could be reduced by making 28th St. a one-way westbound throughfare, but this would increase pressure to seek site access from 21st Ave: and Lake St. or require circuitous routes to Hiawatha Ave. Departing traffic could still use residential streets off of 28th Ave. 2 - See Christensen response #4. Ralph Rye (1) suggested Soo Railroad land would make a better site than Hungry Hollow. (2) Food stores are within 100 feet of this site and the Hopkins site was rejected because of proximity to food warehouses, is this fair? (3) Are the buffer zones adequate? (4) All the transfer stations should have the same operating hours and limitations so that problems aren't shifted to stations with the most.lenient requirements. (5) Can the light rail transit station coexist with the transfer station? (6) What traffic is anticipated from 21st Ave? Rye response 1 - Alternative sites were evaluated adequately during the original environmental review. The transfer station requirements for about 10 acres with good road system access in an industrial zoning can be met in a number of locations. 2 - The environmental review of the Hopkins site provided no indication that the transfer station would pose any environmental risk to food warehouses located nearby. 3 - The minimum set -back of 80 feet from city streets allows space for fencing, access roads and tree plantings. 4 - Operating hours and limitations are controlled by licenses and conditional use permits and may be adjusted to deal with problems. Flexibility is desirable to address special situations. The operating hours and limitations anticipated vary only marginally for the three facilities and shifts in waste flows or constituents between facilities are not predicted as a result. Annual license reviews should provide an opportunity to adjust facility schedules and operating requirements if necessary to avoid such problems. 5 - Light rail transit is projected on two alignments in the vicinity. One is on the east side of Hiawatha Ave. and may tunnel under the intersection of Hiawatha and Lake. The other will leave the railroad right of way on the north side of 29th St., and either cross to the south of 29th St. near the transfer station site and turn south along the west side of Hiawatha or skirt the transfer station on the north side of 28th St. before turning south along the west side of Hiawatha Ave. A passenger station is likely to be designed to service the Hiawatha and Lake area. Transfer station development during 1989 is likely to preceed light rail development by two or more years. Construction planning for the two facilities is, however, being coordinated by Hennepin County. County staff responsible for light rail and transfer station planning (Ken Stevens and Brent Lindgren, respectively) were cooperating to assure that neither project would disrupt the other. The site layout on page 20 of the Draft SEIS shows an unlabeled light rail right of way on the west side of Hiawatha Ave. on the alignment that is expected to be used if part of the transfer station site is needed for this purpose. A light rail system will not reduce the current capacity of throughfares in the vicinity, but implementation should reduce traffic volumes generally and thereby marginally improve vehicle access to the transfer station. -5- 6 - Only facility residential and employee traffic is anticipated from 21st Ave. S. Susan Bell (1) reported neighborhood concern about truck traffic on 18th Ave. and some residents even shot tires last summer. A child was killed by a garbage truck a couple of years ago. The increase in truck traffic relative to current truck traffic levels should be studied. (2) The residential investment on 18th Ave. is not reflected in the study. Bell response 1 - See Scallon response #1. Increases in the proportion of truck only traffic cannot be predicted because the MnDOT base data does not specify trucks. The calculations of level of service impacts on intersections and volume to capacity ratios of affected roadways were, however, adjusted to reflect truck trips as being the equivalent of three vehicle trips. 2 - Property value impacts from the facility are not anticipated so the amount of investment in any particular neighborhood should not be affected. Norb Kayipes expressed nervousness about odor because of the noticeable odor near the transfer station in St. Cloud where he worked. It was pointed out that the St. Cloud facility included a compost operation that is the primary cause of odors there. (1) Who made the determination of negligible property value impacts? (2) Will there be tree plantings to hide the facility? (3) Will there be a connecting street around the facility? (4) Will the site attract rodents and will residents be provided assistance with rodent control? (5) How will odor be controlled? Kay ipes response 1 - The Barton-Aschman Assoc. Inc. consultant firm found no reason to anticipate adverse property value impacts based upon an interview with the Minneapolis City Assessor and an analysis of current land uses in the immediate vicinity including the existing transfer station. 2 - Landscaping including trees and shrubs are proposed. 3 - Access around the facility site is shown on the east side (page 20), but could be established on the west side. 4 - Rodents are not likely to be attracted to the site. If rodents become a problem, prescribed mitigation measures should provide sufficient control without off-site impacts. 5 - Odor is not likely to be a problem outside the building because of operational procedures requiring prompt movement of mixed waste through the transfer process. This will minimize ane rabic decomposition of waste which is the cause of most odor problems at waste management facilities. Chemical treatments have been identified as mitigation measures to counteract the unlikely occurrence of unusual odors. Tom Steeb (1) feels that 14 employees is too low an employment rate for a Minneapolis industrial area.- (2) Could local residents be hired? Steeb response 1 - Any employment rate calculation for the facility should account for the two to ten haulers and recyclers that are likely to be visiting the facility at any time. 2 - Residency requirements for employment are not appropriate for this environmental review. The employment standards of the operating entity must assure that staff with an appropriate range of knowledge, skills and abilities -6- are retained in a context of equal employment opportunity. John Tafte (1) is concerned that displaced low-income people have assistance in moving. (2) What is the advantage in transfering the waste to larger trucks for a relatively short trip downtown? Tafte response 1 - County relocation benefits have been and are available for low-income people displaced by the project. 2 - Transfering waste to large trucks reduces by three-fourths the number of vehicle deliveries from the south Minneapolis wasteshed to the downtown incinerator or any other facility. The transfer station will allow deliveries to more distant facilities, when the incinerator is shut down, without disrupting the trash collection business. The meeting concluded at 9:10 pm. -7- T - Hennepin Draft SETS Meeting New Hope - Cooper High School January 5, 1989 Council member John Evans called the meeting to order at 7:05 pm. Approximately 50 people were in the audience and those who signed in are indicated on the attached list. The other Metropolitan Council members present were: Dirk deVries, Carol Flynn, Mike McLaughlin, Josephine Nunn, Dottie Rietow, Gertrude Ulrich and Marcy Waritz. Mr. Evans followed the attached convenor script. Wayne Nelson of the Council's Solid Waste Division presented an overview of the draft study using slides of figures from the document. The original EIS evaluating the mass -burn facility and a network of four transfer stations was completed in 1986. It included nine alternative transfer station sites. Three new transfer station sites have been selected by the county and these are the subject of the SEIS along with two additional alternative locations. Mr. Nelson described the transfer station design and operational expectations. He then explained how the study addressed governmental approvals, geology and soils, surface water, land use and zoning, transportation, noise, solid waste system impacts, utilities, local community impacts, wasteshed analysis, aesthetics and historical/cultural resources, and flora and fauna. Plymouth mayor Virgil Schneider and the city council continue to have grave concerns about the Plymouth site. (1) Experimentation with recycling and household hazardous waste management is not appropriate. (2) The proposed site is within the city's water well field. (3) Illegal citizen disposal at the gate and along the road is likely. (4) A new facility should meet or exceed high design and operational standards. (5) The city has an inequitable burden of county facilities including the 70 -acre adult correctional facility, two regional parks (440 acres) and 65 acres of trail. (6) Alternative sites not just within Plymouth should be studied. (7) The study superficially addresses Plymouth's concerns. Schneider response 1 - Experimentation with recycling and household hazardous waste management is necessary and is most appropriate in facilities designed to protect the environment. 2 - Essentially any Twin Cities location is over acquifers that serve as municipal well fields. Risks of groundwater contamination will be controlled. Liquids other than household hazardous wastes are prohibited. The bottom of the mixed waste pit Will be sealed and have no drain. Liquids that are admitted to the facility will be controlled four ways: 1) the absorbtion effect of mixed waste that is moved through the facility and loaded into transfer vehicles on a daily basis, 2) containerized storage of liquid household hazardous waste in secure storage areas designed with concrete sills and special heating and air conditioning controls to contain any spills and prevent air dispersal in the event of an accident, 3) operational procedures and training requiring prompt cleanup and notification to regulatory entities in potential high risk situations, and 4) runoff controls to collect and treat the small amounts of material lost from vehicles on the exterior paved areas of the site. No groundwater impacts can be projected and the location a mile from a city well does not pose an environmental risk. Occasional inspections by city staff could assure that the above techniques for managing liquids are implemented satisfactorily. Z Z a ---i 3 - Dumping by the gate is not a common problem at transfer stations or landfills. Anoka Sanitary Landfill Manager Terry Miller reports that illegal dumping near the entrance has occurred only twice in eight years and both violators were traced from the contents and agreed to pay the costs of cleanup. The landfill operation includes a recycling dropoff center. The South Minneapolis transfer station has no history of this problem. 4 - The facility exceeds design standards for appearance, buffer and runoff controls. The operational standards indicated as a result of conditional use permit negotiations with Brooklyn Park are exemplary. 5 - Hosting a 70 -acre correctional facility, two regional parks and trail systems does not constitute an inequitable community burden. The potential reduction in property tax receipts is not significant relative to total city tax revenues. Private ownership of the transfer station or some other means of adjustment for reduced city tax receipts could be proposed. 6 - Nine alternative site locations outside Plymouth have already been studied as part of the original EIS. 7 - The study provides the information necessary as a basis for governmental approvals. David Lilja, who owns land the county intends to acquire for the Brooklyn Park site, objected to the taking of his land. His business employes 150 people and anticipated expansion on the parcel selected for the transfer station. (1) No one from the county or Brooklyn Park has contacted him about the impact on his business. (2) There is vacant land across the street and diagonally across Jefferson Hwy. and 77th Ave. Lilja response 1 - The site acquisition procedures are not subject to environmental review because the impacts are individual and not societal in nature. The implications that this business may relocate are thoroughly described in the study. 2 - An appropriate study of alternative site locations has been conducted. The findings for the county proposed site would apply in nearly every respect to the site identified by Mr. Lilja and this site could probably be selected by the county without an additional supplemental environmental review. LeRoy Reinke is concerned because his house will be within 32 feet of Co. Rd. 6 after it is widened. (1) He objects to noise, litter, safety, fumes, dumping by the gate, spill contamination, monitoring, rodents and property value impacts. The nearby properties should be purchased if the county can spend all million on the project. Reinke response 1 - The study addresses noise, litter, safety, fumes, spills, monitoring, rodents and property value impacts. See Schneider response #3 regarding illegal dumping. 2 - Set back from Co. Rd. 6 will not be affected by the transfer station. Transfer station traffic will play a very small factor in any traffic related problems that develop in the future on this expanding throughfare. Bella Braverman ( 1 ) complained that the study stressed the industrial zoning while the site is on the edge of this zone near her residential neighborhood. (2) The truck volume will tie up traffic especially during rush hours. (3) The workhouse site alternative is in the heart of a residential area. Braverman response 1 - Residential development begins about a quarter mile west of the Plymouth site, but this development is buffered from the industrial area by Interstate 494. Residential development about a mile to the east is separated by Hwy. 55. Residences about three-fourths mile southeast are separated by a railroad track. 2 - The traffic analysis indicates that truck volume will not tie up traffic. This will be particularly true during rush hours when haulers tend to schedule pickups in order to avoid traffic delays on throughfares. 3 - The workhouse site alternative is about a quarter mile from residential development. Stacy Maniak asked questions about the Brooklyn Park site that were answered as follows. The site location was changed at the request of the Brooklyn Park city council. The household hazardous waste management operation will be segregated with sills, floor coverings and storage containers provided to manage these items safely. Rats have not been attracted to other well managed transfer facilities like the one in South Minneapolis and rodent control services could be used if necessary. Brian Mark represented the Plymouth Business Action Association. (1) He feels the traffic information is inaccurate because the situation has changed considerably. (2) The noise measurements were taken out on Co. Rd. 6 and 494. The study should evaluate levels at the facility entrances or where trucks idle. (3) Can the trucks be handled without backing up outside the facility entrance during peak delivery times. (4) The political decision to eliminate the Hopkins site does not seem fair. (5) Property values in this exclusive industrial area are likely to decline. Mark response 1 - The traffic information is based upon MnDOT growth projections. Recent increases in employment at CVN Companies and other firms do not invalidate these projections because growth always occurs in spurts. The assumed growth rate for background traffic levels in Plymouth are twice the growth rate for the entire Metropolitan Area. 2 - The noise measurement takes existing ambient noise levels where they are loudest (the Co. Rd. 6 intersection with Xenium Ave.) and adds the projected noise from a comparison facility (a waste transfer station in Baltimore Md.) and the projected noise from the increase in truck traffic associated with the facility. This approach represents a worst case including truck access to the facility and on the access roadway. 3 - The peak daily traffic at the facility is projected to occur between 11:00 am. and Noon with 107 arrivals and departures. Approximately 40 truck arrivals are included in this estimate. There is more than 2,000 ft. of on-site road on which vehicles could wait to enter the facility. At 40 feet per vehicle, 50 waiting vehicles could be accomodated. No waiting is anticipated, however, because the facility is designed to handle a minimum of 46 compactor trucks per hour (7 trucks at a time at 4-7 minutes to unload and allowing a margin of unpredictable delay) and a substantial number of commercial recycling vehicles. The scale operation can accomodate 120 trucks per hour. Thus even at peak inflow, only a few vehicles are likely to have to wait outside the facility building to unload. 4 - The basis for elimination of the Hopkins site from consideration is not subject to environmental review, but the analysis of this site remains part of the environmental review record. 5 - The study found no objective basis for anticipating a decline in property values. The proposed project involves a high quality industrial building with 1W �__-;_I_ more landscape buffering than any building within view of the site. Lawrence McGowan (1) suggested the Plymouth transfer station should be sited on top of a landfill. McGowan response 1 - Differential settling of landfills generally makes them unsuitable for the construction of buildings for a period of 20 years or more. Paul O'Gorman represented the Plymouth Business Action Association and CVN Companies which employes 4,000 employees on a 24 hour basis and is located across Co. Rd. 6 from the Plymouth transfer station site. (1) Traffic is his primary concern. The study does not include 1,500 new CVN employees added during the past year. (2) The amount of household hazardous waste that could be stored on the site was not mentioned, will more trucks be required to haul this away? (3) The study considered traffic from the corners of Xennium and Co. 61 with Co. 6. This traffic may not change much and will primarily be affected by the installation of the interchange. The traffic pressure is going to be where the trucks turn off on Annapolis Dr. and on Watertower Circle, the accesses to and from the site. (4) Both traffic and noise should be tested for these locations and compared with after the fact projections. (5) Runoff to the ponding area will drain either to the 494 ditch or the storm sewer and then into the pond or swamp area between CVN and 494. This area is connected to the wetlands across 494 and a system draining to Medicine Lake. The study doesn't address this impact. (6) Facilities like this shouldn't be put in established locations, an extra mile or two further wouldn't hurt much. O'Gorman response 1 - See Mark response #1. 2 - The volume of household hazardous waste likely to be delivered to all three transfer stations per week is predicted on page 138. Storage will depend upon the stability of materials, the time it takes to fill storage containers and arrangements for delivery to disposal facilities. Federal hazardous waste management restrictions govern the duration and volumes of storage allowed. 3 - Trucks will turn off Co. Rd. 6 on Annapolis La. to access the facility. They will not proceed as far north as Watertower Circle. Facility related traffic on Annapolis La. will not be affected by intersections and is too low, combinedwith normal local traffic, to project level of service delays from optimum conditions. 4 - Projecting noise on Annapolis Dr. would reduce the worst case projection used in the study. The difference between normal traffic noise on Annapolis La. and the higher level on Co. Rd. 6 at Xenium Ave would be missed. 5 - Runoff drainage to wetlands after grit has settled and floating litter and petroleum based materials have been skimmed off is an accepted means of stormwater treatment. 6 - A more remote site location would raise hauler costs and lose the advantages of freeway access that minimize truck impacts near less buffered roadways. Lyle Clemmens (1) asked if recycling is successful will the waste volumes diminish enough so transfer stations aren't needed to the extent planned. Clemmens response 1 - The result will be a shift toward more emphasis on recycling materials management within the facility and less mixed waste management. Population and employment growth projections portend an increase in the total stream of waste -11- Z - and recyclable collections. Recycling is not expected to reduce the need for transfer stations. Tom Dierks (1) asked if anyone is promoting the transfer stations in a positive light because he has only heard criticisms. Dierks response 1 - environmental review provides objective information to evaluate concerns. Rick Peterson (1) indicated that he had invested his life savings in a $200,000 home about a half mile from the Plymouth site and wouldn't have invested if he had known the station was going to be built. Peterson response 1 - Personal opinion about adverse property value impacts is not shared by the city assessors. Leslie Davis (1) complained that the Metropolitan Council has the wrong plan in the first place because it relies on dumping and burning. He feels the suburban communities have the most important ingredient to fight the plan - money. They just have to make sure they get the right folks to fight for them. Davis response 1 - These comments do not relate to the environmental review. The meeting concluded at 9:15 pm. -12- RESPONSES TO WRITTEN COMMENTS (The letters are reprinted as Section Three) Ralph Rye response (Preferred Soo Railroad site) - See Rye verbal comment response #1. (Food store proximity) - See Rye verbal comment response #2. (Buffer zone) - See Rye verbal comment response #3. (Traffic) - See Rye verbal comment response #4. (Facility visibility) - The building height will be approximately 58 feet - about five stories high. (Truck wash) The truck wash concept was deleted because vehicle owners have their own facilities for this purpose. (LRT) See Rye verbal comment response #5. (Truck storage) No trucks are expected to be serviced or stored on site. (28th Ave.) See Scallon verbal comment response #1. (Lake St.) See Peterson verbal comment response #1. Mary Rye response (Traffic routes for transfer vehicles) These vehicles must use truck routes and compliance can be enforced through the contract with the county. Access routes for the Bloomington facility were negotiated through the conditional use permit process. (Trucks waiting on public property) Ample space for any trucks waiting to unload are provided on-site with more than 1200 feet of access road for at least 30 compactor trucks. For additional analysis of truck queing see Mark verbal comment response #3. (Operation before or after hours) No strategy of fines has been deemed necessary by Minneapolis officials to assure that official hours of operation are respected. (Access to Hiawatha Ave. from 29th St.) No such access is planned. (Waiting in the event of facility delay) Truck delay of more than a half hour will not be acceptable and haulers will be redirected to other locations. (Recycling and household hazardous waste disposal services) The three stations studied will each offer these services daily. 'Fees were not addressed during the study. Illegal dumping is not likely to be a frequent problem and prompt clean up by facility staff is likely to be negotiated through the conditional use permit process. See Schneider verbal comment response #3. (Vehicle inspections) Hennepin County licenses trash haulers and this management responsibility will not change although the transfer stations may provide a convenient opportunity for oversight. (Additional traffic for citizen drop-offs) This resident and employee traffic are estimated at 284 incoming and outgoing trips on page 82. (One-way 28th St.) See Scallon verbal comment response #1. (Backup power supply for transfer stations) The transfer stations are designed to use public utilities. A portable generator is necessary to supply needed emergency electrical power. See "Contingency Planning" on page 14 of the draft SEIS for additional information. (Noise level above MPCA standards) The noise level in a residential back yard at 28th St. and Longfellow was measured at 65.8 dBA for 10 percent of a daytime period. This exceeds the standard by .8 decibels for a residential area. The standards for 10 percent of the time and 50 percent of the time are projected to be exceeded by five and two dBA, respectively. The transfer station and related traffic will account for only 1.0 to 1.2 dBA of the predicted levels. Noise increases of 0-3 dBA have been determined to be imperceptible in many independent tests. Noise associated with the transfer station could not be distinguished from background noise in the back yard location indicated above. -13- (Hazardous waste storage schedule) See O'Gorman verbal comment response #2. (Fire and security precautions) Liquid household hazardous waste will be stored in containers in secure storage areas designed with concrete sills and special heating and air conditioning controls to contain any spills and prevent air dispersal in the event of an accident. Operational procedures and training will require prompt cleanup and notification to regulatory entities in potential high risk situations. Specific fire management strategies are identified in paragraph three of page 14 of the draft SEIS. Plymouth Mayor Virgil Schneider response (A true "no -build alternative" would not involve sites in Plymouth) The "no build alternative" evaluated in the original EIS assumed no transfer stations would be built. Alternative sites outside Plymouth were adequately addressed in the original EIS. Nine alternative sites were studied. (I.A. - Significant issues remain) All the issues raised are addressed to a reasonable extent. (I.B. - The study contains inaccuracies or incomplete information) Any inaccuracies noted have been corrected. The information provided is sufficient for the risk levels posed by a project of this nature. (I.C. - Reasons for choosing a Plymouth site over county land in Hopkins are not valid) An EIS provides background information to support decisionmaking but does not dictate the basis that must be used to make approvals. (I.D. - Implication that tax exempt status for a transfer station implies a minimal impact) The SEIS indicates only that the difference between a taxable and tax exempt status for the station would have only a minimal impact on Plymouth's total property tax receipts. (I.E. - Dropoff operations should have been analyzed in more detail) See Christensen verbal comments response #4. All transfer station materials management operations including drop-off programs will be conducted within the station buildings. (II.A. - Unacceptable materials management) Unacceptable materials are defined in Hennepin County Ordinance # 12 dealing with solid waste designation. No measures can assure that no arbitrary or improper dropoffs will occur outside the facility premises, but this has not proven to be a significant problem in similar circumstances - See Schneider verbal comments response #3 (II.B. - Actual experience with improper hazardous waste) Only citizen dropoff of household hazard waste is anticipated. The SEIS documents the actual experience with citizen dropoffs and predicts somewhat higher volumes will be collected through a continually available program. The information on page 10 refers to hazardous waste that will not be accepted at the facility from commercial haulers or recyclers. These volumes can only be estimated because the volumes refused at operating facilities are believed to represent only a small portion of the actual volume of these materials that are generated. (II.C. - Small quantities of hazardous waste discovered in the mixed waste stream) State and federal regulations apply once these materials are aggregated. Facility efforts to identify and separate such materials are exemplary because they could legally be left comingled with the waste stream and have undesirable affects on pollutants associated with incineration facilities and landfills. (II.D. - Finalization of plans for hazardous waste management) Hazardous waste management is and will continue to be an evolving activity. Final design will be dependent upon approvals including conditional use permits. Operational procedures and facility adjustments and improvements will be necessary on an ongoing basis. (II.E. - Waste diversion plans) While the SEIS describes the backup capacity available in the proposed transfer station and processing facility network, the -14- long-term unavailability of any major system component would have to be addressed in conjunction with replacement plans for the component. (II.F. - More information desired in support of governmental approvals) The purpose of environmental review is to present the information deemed essential to evaluate the potential risks identified through the scoping process. Unnecessary detail would be counterproductive to an analysis of reasonably likely implications. (III.A.,B. - Well field proximity analysis was cursory) More detailed analysis of the geohydrology affecting the city well field is not relevant because no significant groundwater impacts are likely from this facility. City and MPCA facility inspections can verify whether facility operations are conducted to standards that prevent liquids from penetrating floor surfaces or storm water runoff from escaping treatment. See Schneider verbal comment response #2 for additional information. (III.C. - Observations of groundwater potential impacts do not specifically address depository functions including household hazardous waste) The groundwater analysis and mitigation measures on pp. 55-57 and 165-170 respectively of the draft SEIS address the collection and management of any materials dropped or spilled on the site or in the facility. (III.D. - Alternative Plymouth site analyses do not address proximity to the city well fields) See response to III.A.,B. above. The alternative sites would be no more or less likely to affect groundwater than the proposed site. (III.E. - Storm water runoff analysis does not address implications on city well fields) The analysis indicates that wetlands will not be adversely affected. The wetlands would have to be adversely affected for storm water runoff to affect the groundwater. See O'Gorman verbal comment response #5. (III.F. - Plymouth zoning standards for the industrial park containing the proposed site discourage public retail/service activities and may prevent citizen dropoff and recycling functions) The volume of projected citizen dropoffs does not require a large parking lot or a commercial style operation. The city position is noted by the inclusion of this letter in the final SEIS. (III.G. - Use of hazardous waste collection estimates questioned) Estimates based on actual county experience with special collection projects is the most reliable way to predict the types and quantities of materials likely to be delivered to the site. An independent waste generation study provides additional support for the estimates. (III.H. - Household hazardous waste definition is contradictory regarding used motor oil) Although motor oil does not appear on the MPCA list of inventory categories of household hazardous wastes accepted through its programs, it is listed in the tables summarizing MPCA collections and the projection for the transfer stations. There is no implication that this material is not a problem. (III.I. - Implications for the Plymouth station if household hazardous waste collections are terminated at another county facility) This possibility is not addressed in the SEIS scoping decision. Speculation about termination of such operations at one facility and not the others does not seem very credible. Presumably, the county would react by replacing any terminated capacity if a significant volume of collections is jeopardized. (III.J. - The "no build" option should have addressed specifically the Plymouth station instead of the network of transfer stations) From an environmental review perspective the larger network perspective is appropriate because a specific transfer station is not a mandatory EIS category under EQB rules. The wasteshed analysis was used to indicate likely backup destinations in the event of the shutdown of any of the transfer stations (draft SEIS Table 1.6-1). (III.K. - Property value implications to the community should,not be based upon assessed value and potential ancillary development) Assessed values are the basis for predicting the impact on tax receipts if the facility is given a tax -15- exempt status. The current assessed value is specifically referenced in the text to indicate that this represents current value only. Potential ancillary commercial beneficial impacts are enumerated without implying that they would offset adverse impacts. See Schneider verbal comment response #5. (III.L. - Outside storage and litter controls) Outside storage will not occur according to the facility plan. The frequency of outdoor litter pickup is likely to be negotiated with each city based on minimum standards in a conditional use permit. Experience with the existing South Minneapolis transfer station indicates that litter can be successfully controlled. (III.M. - Control of illegal dumping outside the facility) See Schneider verbal comment response #3. (III.N. - Will someone be on-site 24 hours every day) The site will be protected by a chain link fence and exterior gate that would be locked when the facility is closed and no one is on the premises. (III.0. - Does not deal head-on with rejecting extremely hazardous materials) Mitigation measures encourage the county not to blindly turn away unusual or particularly troublesome materials. Liability for accepting such materials may, however, have to be negotiated in some instances. Any materials rejected at the facility as too dangerous would only be allowed to be taken away under safe circumstances - illegal dumping outside the gate is not a realistic outcome. (III.P. - Concern that design and outreach mitigation recommendations will be ineffective because they reflect assumptions instead of actual experience) The county and the MPCA have repeatedly and successfully conducted household hazardous waste collection programs. The proposed measures are a responsible professional judgement of additional measures that can assure the safe operation of continuing programs. Every new program requires initiative. (IV. - Burden of public facilities) This is an issue that was not included in the scope for the study largely because there are no standards for community share of public facility burdens. Facilities vary dramatically in impact and the significance of these impacts other than property tax consequences is largely subjective. See Schneider verbal comment response #5. (V. - Plymouth is asked approve the facility on good faith) The SEIS does not request city approval. It portrays what is known and can be predicted in advance that may affect potential environmental impacts. (VI. - Dropoff and recycling functions were hastily added and require more study) These management issues do not pose risks that justify additional environmental review. See Christensen verbal comment response #4. Cimmarron East Homeowners Association Inc. response (Traffic impacts are underrepresented) Co. Rd. 6 traffic was estimated using MnDOT data from actual traffic count records and a projection after an interchange connecting to I494 is added. Future growth added to both figures. (Household hazardous waste management not sufficiently addressed) See Christensen verbal comment response #4 and O'Gorman verbal comment response #2. (Noise increases from the new Co. Rd. 6 intersection with I494 in combination with the transfer station would be objectionable) Noise associated with the transfer station was modeled•on traffic levels with the Co. 6/1494 interchange and did not exceed state standards. (Property values will be affected) See Mark verbal comment response #5. Phillips Neighborhood Improvement Association response 1.1 - Continued operation of the existing transfer station) The existing South Minneapolis transfer station will not be used to transfer solid waste in the forseeable future. Minneapolis will use the facility for other purposes and that were not addressed in the SEIS. -16- (1.5.1 - Consistent operating hours) See Rye verbal comment response #4. (1.5.2 - Management plan for dropoff components) See Christensen verbal comment response #4. (1.5.3 - Odor control for trucks outside the building) The facility is not responsible for controlling odors from hauler's trucks. The trucks have no history of odor nuisance complaints. (1.6 - Contingency planning not adequate for capacities estimated in 2020) Certainly additional planning will be necessary during the life of the facility. (2.2 - Alternatives to South Mpls. not adequately explored) Alternatives were adequately studied in the original EIS. The county decision to reject the Hopkins site is not subject to the environmental review process. The original EIS documented that transfer station operation on the Hopkins site would have no impact on vector levels at food warehouses within a half mile. No off-site vector problems are anticipated. (2.2.1 - Disagreement with rationale for selecting the South Mpls. transfer site) The site selection criteria provided by the county are listed. The environmental review has to address the sites the proposer seeks to have approved. (4.1.3.1 - Measures to be taken if contaminated soils are found) This issue was not addressed in scoping and should be addressed as in any other construction project. (4.2.3.3 - Are there contaminants that will remain after passing through the grit oil and flammable liquids separator) The MWCC will require an industrial sewer connection application that will be completed in conjunction with the local plumbing permits. Monitoring and sampling of the processed waste water may be required and an industrial discharge permit may be issued at a fee between $30 and $180 for three years. (4.2.3.1 - Water quality impacts if there is no stormwater retention pond) A retention pond may be negotiated with Minneapolis. If one is established, the connection with the storm sewer system that would be required is indicated on page 147. The analysis shows that storm water runoff will not increase in conjunction with the transfer station development and the effect on runoff quality if a retention pond is not included will not be appreciably different than under current conditions.(4.3.2.1 - Evaluation of compatibility with existing land uses) See Peterson verbal comment response #3 regarding reference to the Hi -Lake Center. The new transfer station building will be set back and buffered from the Hi -Lake Center and the cemetery. The buffering will include fencing, landscaping, vegetation, and site roads. (4.3.2.2 - The B3S-2 zoning to the south of the site allows residential use and should be mentioned in the narrative) This zoning is clearly indicated on the site zoning map (Figure 4.3-3). The zone encompases the Hi -Lake Center and its exclusion from the narrative is not likely to confuse anyone. (4.3.2.3 - Compatibility with future land uses should address light rail and plans for redevelopment east of Hiawatha Ave.) See Rye verbal comments response #5 and Eggen verbal comments response #1. (4.4.1 - Would MnDOT estimates of traffic on redesigned Hiawatha be preferable to estimates based upon current traffic) Redoing this portion of the analysis from the original EIS was not warranted. Hiawatha improvements are not likely to increase the impact of facility traffic. (4.4.3.3 - Accuracy of projection that 65 percent of facility traffic will use Hiawatha Ave.) This projection derives from a computer model of optimal travel times using truck routes between waste generation points and disposal locations. -17- —T:-,Z� (4.4.3.4 - 1989 traffic projections are not far enough into the future) This section estimates 1989 traffic and indicates the impact of adding facility traffic. This projection best reflects likely impacts from implementing the project. Impacts while Hiawatha Ave. is being reconstructed are beyond the scope of this SEIS. (4.4.3.4 - Truck access from residential streets and impacts on residential use near Cedar Ave. and 28th St.) See Peterson verbal comments responses #1 and #2. The study of level of service implications at Cedar Ave. and 28th St. addresses turns from all directions. (4.5.2 - Would seasonal differences in noise levels be significant) Noise will carry somewhat further during winter but people tend to stay inclosed more and be less affected. (4.5.3 - The location of receptor #2 misses impacts on the shopping center) The location of noise receptor #2 allows a worst case analysis of traffic noise from Hiawatha Ave. in combination with the projected facility operational noise. This combined level is less than MPCA standards for commercial uses like the shopping center. (4.5.7.1 - Are more stringent Minneapolis noise limits applicable) The facility is not likely to operate on Sundays or holidays that apply to haulers. Operations will slow substantially after 6:00 pm and MSW will not be accepted after 7:00 pm. so the MPCA standards are likely to be more stringent than the Minneapolis limits and apply as indicated in the SEIS. (4.5.7.1 - Increases in noise levels above standards should be addressed in some way other than mitigation measures) The study purpose is to describe the impacts and potential mitigation in an understandable context. (4.6.1 - Dramatic increases in county recycling goals should be evaluated for impact on transfer stations) The 20 percent recycling goal is significant because it represents additional recycling above 1985 levels. See Christensen verbal comment response #6 regarding the implications of more recycling. Implications of the incinerator are outside the scope of this SEIS. (4.6.3.1 - Household waste generation based on Marin County figures is inaccurate) The Marin County figures were used to estimate an overall generation rate because they are the best documented figures available from actual waste samples. Estimates of volumes likely in Hennepin County also reflect the MPCA experience with demonstration programs. (4.6.3.2 - Participation in household hazardous waste dropoff ought to exceed a 5 percent rate, would this affect the facilities) Higher volumes than projected would increase the frequency that collected volumes would have to be disposed. Substantial increases in volume would have to occur before more storage space would be prepared for this purpose. Removal of these materials will benefit incineration and landfill operations, but this impact is outside the scope of this study. Hazardous materials remaining in the waste stream will be comingled or absorbed as they have in the past. Most hazardous materials not disposed separately from MSW are likely to escape detection at the transfer stations. (4.6.4.2 - If throughput will be near capacity in 2020, why weren't these volumes evaluated) The capacity referred to here is the 700 tons per day projected maximum throughput, not the 1,800 maximum design capability. The year 2000 was chosen because waste generation rates have been estimated to this date. Longer projections are not as reliable. Table 1.6-1 indicates the likely backup facilities if capacity at the Bloomington station is not available. Capacity for dropoff functions is ample for expansion with about half of each facility reserved for these purposes. The evolutionary nature of these programs makes predictions of future throughput speculative. (4.6.5.1 - Can the transfer stations handle all the yard waste after the ban on disposal with MSW is implemented in 1990) The stations will only provide an area for citizen dropoff. Most yard waste disposal is expected to occur through other city and county programs. Modification of dropoff operations in the future cannot be reliably predicted. (4.6.5.2 - System modifications could have environmental impacts that have not been evaluated) A responsible effort was undertaken to predict the likely significant impacts. (4.7.3 - Indication that a storm water retention pond will be required is contradictory) The section indicates the nature of the connection that would be required between a retention pond and the storm sewer system. (4.8.1.2 - Property value impacts may be realized) They may occur but adverse impacts are not anticipated by city assessors. (4.8.3.1 - Displaced employees and residents face problems associated with poverty) The study does not contest this, it indicates the number of homes and jobs affected. (4.8.3.2 - The Minnesota Realtors Association should be contacted about valuation impacts) Assessor information is superior because these professional judgements reflect sales price ratios to assessed values instead of listing expectations. The 58 -foot facility height will not dominate the community. (4.8.4.3 - A tax generating use would be better for the site) The SEIS portrays the current tax receipt situation. A tax-exempt facility will not provide this level of tax receipts. (4.9 - Wasteshed mapping is disputed) The mapping was derived from a computer model of optimal travel times using truck routes between waste generation points and disposal locations. The map indicates that downtown and Northeast Mpls. generators are likely to be the primary direct contributors to the downtown facility. The mapping is not intended to establish wasteshed boundaries. It portrays the likely wastesheds if the proposed network is implemented. (4.10.1.1 - Litter and odor controls with frequently opening doors, elimination of truck wash, fee arrangements and queing delays) Doors will have to be frequently opened and closed but disposal within the facility will minimize odor and litter problems. Truck conditions will controlled through county licensing procedures as they have been in the past. Fee arrangements are not within the scope of the SEIS. Ample space for any trucks waiting to unload are provided on-site with more than 1200 feet of access read for at least 30 compactor trucks. For additional analysis of truck queing see Mark verbal comment response #3. (4.10.3.1 - Only on-site historical/cultural resources studied) The perspective of this portion of the study is to determine whether existing resources will be obliterated. The nearby cemetery will not be affected in a way that is appreciably different than it is by the existing transfer station operation and recent site uses. (4.10.3.2 - How can a 58 -foot structure be buffered?) Trees near the fence will provide some buffer. (5.2.2 - Mitigation measures for transportation are desired) See Scallon verbal comment response V. (5.3.1 - Mitigation for household hazardous waste remaining in MSW should be specified) This is a waste management problem beyond the scope of this SEIS. (The demonstration on-site recycling program should be evaluated more thoroughly) See the Christensen verbal comment response #4. Sterling Electric Co. response (Additional trash hauler traffic would disrupt business and decrease safety) The analysis shows the impacts on the Plymouth site area traffic associated with the facility will not be consequential. (A transfer station will detract from the appealing community) See the Mark -19- verbal comment response U5. (Illegal dumping fear) See Schneider verbal comment response #3. (Household hazardous waste volumes and turnover) See the Schneider verbal comment response #2 and Christensen verbal comment response Oto. _Minnesota Dept. of Natural Resources response (More information on soils and wetlands on the Carlson Parkway alternative site would be needed if it is chosen for development) The information would be provided during the permit process. Dept. Of The Army response (No additional information is requested) No response is required. Earth Protector response (Challenges the need for transfer stations and the adequacy of an SEIS for transfer stations that support incineration facilities) These concerns are not within the scope of study specified for the SEIS. City of Minneapolis response (Design and operational mitigating measures for storage of unprocessed recyclables and household hazardous waste) Measures for hazardous waste management are specified in section 5.3 of the draft SEIS. Additional measures for the control of liquids are specified in Section Two of this document. Specific design of the recycling materials storage area is outside the scope of study for this SEIS. See the Christensen verbal comment response Ito. (Mitigation measures to discourage truck use of residential streets) Mitigation measures for this purpose have been added in Section Two of this document. (Changes in the Hiawatha Ave. intersection with 28th St. may pose implications for facility design) The possible extension of 28th St. as a "through" street proceeding east from Hiawatha Ave. does not pose significant implications on or from facility generated traffic. Deliveries by transfer vehicles would continue to use the indicated routes to the interstate highway system. Local residents and haulers serving the area east of Hiawatha Ave. would not be affected by turns to and from Hiawatha. Some traffic volume from Lake St. would probably divert to 28th St. and facility related traffic would constitute an even smaller proportion of 28th St. volume. (Effects of more packer trucks using the incinerator facility than originally intended) This issue is not within the scope of study specified for the SEIS. Wasteshed or other limitations of truck volume at the downtown facility could be negotiated with Hennepin County. The transfer station is certain to reduce the number of vehicles directly accessing the incinerator facility. (Additional measures for hazardous incident prevention and response) See the first response to this letter. (Analysis documenting the ability to address truck queing on site) The peak daily traffic at the facility is projected to occur between 11:00 am. and Noon with 107 arrivals and departures. Approximately 40 truck arrivals are included in this estimate. There is more than 1,200 ft. of on-site road on which vehicles could wait to enter the facility. At 40 feet per vehicle, 30 waiting vehicles could be accomodated. No waiting is anticipated, however, because the facility is designed to handle a minimum of 46 compactor trucks per hour (7 trucks at a time at 4-7 minutes to unload and allowing a margin of unpredictable delay) and a substantial number of commercial recycling vehicles. The scale operation can accomodate 120 trucks per hour. Thus even at peak inflow, only a few vehicles are likely to have to wait outside the facility building to unload. -20- --7- --L--) SECTION TWO - ADDITIONS TO THE DRAFT SEIS TEXT MITIGATION SECTION ADDITIONS The county could install a sign at the facility entrance denying access to trucks observed entering from 21st Ave. and a portable barrier or curbing could be installed just inside the facility entrance to make it difficult for trucks to enter or exit the facility via the 21st Ave. route. Selective truck route enforcement by local police or the county sheriff could also be instituted. Residential streets like 18th Ave. S. and Longfellow Ave. S. near 28th St. could be posted with signs indicating "trucks prohibited except to access residences". A warning system could be implemented based on residents reporting the license registrations of haul vehicles observed on the residential streets. County staff could follow up with license inspections or encouragement to file misdemeanor complaints against driver violators observed more than once. A barrier could be erected at the intersection of the facility access road and 28th St. to discourage eastbound traffic from entering and westbound traffic from exiting. With city concurrence, the county has been receptive to designating access routes. These routes can be enforced through citations by the police or authorized county staff. Occasional inspections by city staff could assure that the following techniques for managing liquids are implemented satisfactorily. Liquids other than household hazardous wastes are prohibited. The bottom of the mixed waste pit will be sealed and have no drain. Liquids that are admitted to the facility will be controlled four ways: 1) the absorbtion effect of mixed waste that is moved through the facility and loaded into transfer vehicles on a daily basis, 2) containerized storage of liquid household hazardous waste in secure storage areas designed with concrete sills and special heating and air conditioning controls to contain any spills and prevent air dispersal in the event of an accident, 3) operational procedures and training requiring prompt cleanup and notification to regulatory entities in potential high risk situations, and 4) runoff controls to collect and treat the small amounts of material lost from vehicles on the exterior paved areas of the site. GOVERNMENTAL APPROVALS SECTION ADDITIONS Add to Table 3.2-1. The MWCC will require an industrial sewer connection application that will be completed in conjunction with the local plumbing permits. Monitoring and sampling of the processed waste water may be required and an industrial discharge permit may be issued at a fee between $30 and $180 for three years. Add to Table 3.2-1. A hazardous materials storage and processing permit may be required from the city of Minneapolis. LOCAL COMMUNITY IMPACTS ADDITIONS The transfer station network including the Bloomington station is projected to cost $12.4 million annually. This expense includes $5.2 million for debt service, $4.2 million for transfer vehicle hauling, and $3.1 million for operation. -21- SECTION THREE - WRITTEN COMMENTS -22- Jan 3. 1989 SITE Why was this site picked when Soo Railroad land was available and no business or homes would need to be relocated at that site? Of all possible sites in the city of Minneapolis which was closest to residental zoning? OTHER SITES How could the Hopkins site be rejected on basis of closeness to food warehouses when this site is much closer to a grocery store? BUFFER ZONE How much land is required for a buffer zone bewteen industral use and residental use? TRAFFIC How can other transfer sites limit hours of operation and storage of refuse overnight? Should not all transfer stations have the same operational limits? SITE LOOKS When did plans for an emposing 6 story tall building replace the current height of transfer station? SITE CLEANILNESS When did truck wash and insecption stations get dropped from site plans^ LRT STATION Can a LRT station coexist with a garbage transfer station^ TRUCKS AND STORAGE Where will trucks be serviced and stored overnight? 2.8TH AVENUE Can -8th revete to a one way all the way across the ` railtrack? And will development of Cub foods and access road to that new shopping area impact on truck: traffic LAF::E STREET Will there be only administration traffic off Lake Street? Ralph Rye �0 7 Jan 3. 1989 ✓ What traffic routes will the transfer vechicles from the South Minneapolis transfer station be restricted to?' What traffic routes will transfer vechicles from Bloomington V transfer station be restrict& to? What traffic routes will transfer vechicles returning from the Garbage Burner be restricted to? Will compactor vehicles be allowed to wait on public property? If the transfer station operates after or before hours, is there a fine? Will there be entrance and/or exit access for compactor vechicles and transfer vechicles to Hiawatha North and/or South via 29th Street? If ther is a slowdown or temporary shutdown, how long will compactor vehicles be allowed to wait to unload? How many compactor vehicles can wait to unload on Transfer site property? Are all Hennepin County sites going to be drop off sites for recyclable materials, yard waste, and household hazardous wastes'7 hat days and hours will this drop off service be in operation? Is this a free service or will ther be a fee charged? Who will clean up "dumping" bby impatient or late or wrong day individuals and how soon will it be cleanedup? How often eill vechicles be inspected for adequate braises, lead emissions, etc? What is the projected additional traffic for drop off area for recyclable, yard waste, and hazardous wastes? Can 28th Street become one way East between Cedar and Hiawatha? What is the planned backip power supply for transfer stations z and garbage burner? To what level is the MFCA noise standards exceeded at the interections of Cedar and 28th Street in the Suplemental EIS'? What is an imperceptible increase? And who is it imperceptible to? How long will hazardous wastes be stored at all of the transfer stations? What fire and securrity precautions are planned'? CIJ�`j � 7 C -%, Q_ INFORMATION SUBMITTED IN SUPPORT OF REMARKS BY CITY OF PLYMOUTH MAYOR VIRGIL SCHNEIDER FOR THE JANUARY 5, 1989 PUBLIC MEETING REGARDING SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT FOR HENNEPIN COUNTY RESOURCE RECOVERY TRANSFER STATION PROJECT I. The City of Plymouth continues to have grave concerns regarding the proposed location of a resource recovery transfer station in the City. The City has expressed concerns previously to the Hennepin County Board on June 11, 1987 and before a Metropolitan Council Panel on February 29, 1988, at the Environmental Impact Statement Scoping Hearing. Copies of the City remarks and background information were submitted at those times. The true "no -build alternative" that should have been explicitly addressed in this document is that other alternative sites in Hennepin County, not just within Plymouth, might be available and that placing such a facility in a developing/developed urban area might very well be inappropriate, hazardous, and environmentally unsound. A. The City has reviewed the December, 1988, draft Supplemental Environmental Impact Statement (SEIS) and finds that significant issues remain which either have not been fully addressed or which are not addressed at all, apparently due, to the lack of information regarding the construction and operation of such facilities. B. It contains inaccurate or incomplete information which can significantly alter one's perception of the proposed facility and, in this case, tends to minimize features which in fact can be reasonably expected to present ongoing environmental problems and to foster continued anxiety by the residents of the area and of the entire community. C. The contention that alternate sites and the "no build option" have been adequately addressed is not valid. The stated reasons for considering the site which the County has already purchased as an "alternative" to the previously selected site on land the County already owned in Hopkins have stronger contradictions than the reasons the Hopkins site was rejected. The proximity to a food distribution facility in Hopkins pales against the proximity to the major Plymouth municipal water well field and food distribution facility in Plymouth. D. The suggestion in the SEIS that the proposed transfer station would have minimal impact due to its tax exempt status is incredible, given the existing facilities this City has, versus other communities in the County with similar transportation system access who have no facilities whatsoever. E. The proposal to add additional functions to the originally proposed transfer station may have a rational philosophical basis but has not had the attention or analysis it deserves because of potential problems. Dropoff areas for citizens as well as for waste haulers and municipal recyclers for delivery of recyclable materials and yard waste, and a dropoff area for County residents for delivery of , household hazardous waste present awhole spectrum of management and environmental problems that, at best, receive cursory treatment in the SEIS, apparently due to the lack of knowledge of how these functions will work. 2 `=- The external impacts of this facility upon the community are significantly heightened due to these additional proposed functions, whereas, the transfer stations alone were to have been self-contained and enclosed except for the entry and exit of commercial vehicles. II. The SEIS raises a variety of questions which should be publicly and thoroughly addressed before AU environmental approvals and permits are granted. Where there is a lack of knowledge and/or information then those operations should be explicitly excluded from the proposal until such time they can be addressed in an acceptable manner. It is not acceptable to expect the City of Plymouth to be a testing laboratory for the functions other than the transfer operations based upon current data. (Note: The page numbers refer to the December, 1988 draft SEIS.) A. Page 4. What does the statement, "obviously unacceptable material will be rejected" mean, exactly? Does it suggest that it will be rejected from the immediate premises but perhaps left elsewhere in the vicinity because the person bringing it did not realize it would be rejected? What exactly are the controls for the unwanted/illegal items? What are the measures that will assure no arbitrary/improper dropoffs will be made "at the gate"? B. Page 10. What actual experience has there been relative to the expected percentage of improper hazardous waste? Much emphasis seems to be placed upon the estimates of five to ten percent expectation based on a previous Environmental Impact Statement for other facilities. This would not be a problem if the site were only identified as a transfer station not available to the general public or recyclers. 3 T � C. Page 11. The SEIS states the County "will attempt to separate and remove loads of waste that can be visually identified as containing unacceptable or hazardous waste, but will not separate small quantities of household hazardous waste or less obvious commercial or industrial waste." Is this to be exclusively defined by the County, and, more probably by personnel on the site? Are guidelines established by the Pollution Control Agency or by Federal authorities? The resolution of this problem is not treated directly by the SEIS. D. Page 13. The County at this time has not specified details regarding the design and layout of the Household Hazardous Waste Facility. The County at this time has not developed guidelines for determining acceptability of the various types of household hazardous waste that may be encountered. Exactly when will those be accomplished? Does it not make sense that those should be available for review now and not, perhaps, at some indefinite time after the facility is under construction or even under operation? E. Page 14. The County has no formal waste diversion plan and there is thus only speculation as to what might happen as a contingency if other facilities in the County broke down or were unable to legally handle materials. Is this not an environmental concern and problem? The SEIS treads lightly on this. F. Page 32. The purposes of an Environmental Impact Statement in support of government approvals are outlined. If the SEIS is to be truly meaningful should it not be more detailed and demanding of the proponent? How can the SEIS effectively serve as a guide to sound decisionmaking at any level of government, if key elements about 4 matters such as hazardous waste handling are circumspect, at best? The demands that government at all levels place upon the private sector for performance and compliance should be fully expected and required of public agencies. The SEIS repeatedly suggests that what can't be answered now will "probably" be addressed later. This is not acceptable. A similar proposal from the private sector would be tabled to allow additional data and analysis to be submitted. That should be the case here. III. There are numerous specific questions about accuracy of the data and of the analysis of technical data and these require careful scrutiny. Cursory analyses and environmental assurances are found in response to these facts: the site is within the City's water well field; there is a high likelihood of anonymous, illegal citizen drops "at the gate" and "along the road" off of the site; and the City's restrictions on all land uses in the Planned Industrial district which are designed to minimize public activities of retail service nature, e.g., the dropoff recycling functions that were added to the transfer station use. A. Page 38 and Page v. One of the main environmental issues, ground water contamination, has only been addressed in a cursory manner. The City has previously demonstrated that the proposed transfer site is within the City's municipal well,field. The statement is made that the study has concluded that releases of contaminants could pose the same risk to the area ground water supplies regardless of the location of the transfer stations. The SEIS cites the EAW: "that, 'This option (relocation of the facility to another area) would not reduce the potential impact to 5 the regional ground water in that the entire Minneapolis -St. Paul area has similar hydrogeologic characteristics. The same potential water resource threats would exist at any site selected in this area' (Metropolitan Council -1987)." The soil borings presented in figure 4.1 - 9 and 10 indicate that the Plymouth site is underlaid by a "clay sand and silty clay." General conclusions cannot and should not be made for the entire Minneapolis - St. Paul area and applied to the proposed Plymouth site. The Plymouth site is directly within the City's municipal well field, and therefore, requires more detailed, specific analysis for minimum measures on ground water impact. B. Page 51. The SEIS indicates that the proposed site possibly features a creek bed or drainage way based upon the borings that were taken. The City has been aware of and has expressed concern about the potential problems that could result with the City's municipal water well field in the area; this heightens that concern. C. Page 55 - 57. The ground water levels are such that well points will probably be required at least to lower the water table during construction. The observations about ground water apparently deal with the transfer station and do not deal with the depository functions that have been added that include household hazardous waste (legal and illegal). D. Page 58. The discussion of the so-called alternative site does not address the location of the City's municipal water well fields which are clearly identified in the City's Comprehensive Plan and which have been identified in all previous submittals regarding the Environment Impact Statement for this project. _T Q�l E. Pages 61 and 62. The discussion of storm water drainage from the site does not address the municipal water well fields and possible impacts. F. Page 69 (and Pages v and iii, 19, and 26). Plymouth has high development standards for all industrial buildings and it is expected of all development that standards regarding external impacts such as litter, odor, noise, outside storage, and traffic are met or exceeded. This includes a County transfer station. The City planning has produced a planned industrial district which intentionally discourages public retail/service activities. Citizen dropoff and recycling functions are of a public retail/service character. It is not appropriate to assume that all aspects of the transfer stations including these functions, would be consistent with City plans and ordinances. The inquiries made to the City that resulted in the responses in the SEIS were about a totally self- contained transfer station. G. Page 135. Hennepin County has not developed estimates of participation rates, or estimates of waste volumes or characteristics to be expected for the transfer station, household hazardous waste dropoff sites. The suggestion that "rough estimates" should be used based upon the "one -day special collection projects" is highly indicative of the shallow analysis of this SEIS as to what could be one of the most significant problems of the operation. The study is actually guessing and estimating based on meager experience while at the same time suggesting that the use of the facility should be promoted to citizens throughout the County to use it. Interestingly, the SEIS notes the Bloomington facility will not have these functions. 7 H. Page 136 and 137. The information about expected quantity of household hazardous waste and the definition of those wastes is contradictory relative to used motor oils. These substances which are identified as ones likely to represent the highest volume of any single item are typically inclusive of gasoline. The implication (by omission) that they are not a problem, is further evidence of the shallow analysis. One only needs to compare the Minnesota Pollution Control Agency data on Page 136 to the tables on Pages 137 and 138. I. Page 138. Little substantive information is provided relative to the possibility of other facilities breaking down or otherwise failing to handle the household hazardous wastes. Even if one accepts the artificially low projected figures (in barrels), the physical quantity is significant, especially when it is not clear where the materials will be stored and how they will be disposed of on a regular and dependable basis. J. Pages 143, 144. It is difficult to conclude that the discussion of the "potential effects of system modifications" and presumably the "no build option" is realistic and meaningful. Exactly what does this discussion mean with respect to the environmental impact of this program and of this facility? Neither the original EIS nor this supplement deals specifically with the impact of not building this transfer station. Is that not a requirement? The reference here is to the entire transfer station system. One can easily conclude from the analysis that there are so many problems the system should probably not be built until more answers and policies can be resolved. U K. Page 149. There are sevcral inaccuracies and problems with data here. Our remarks earlier stated the amount of already acquired County land in the City of Plymouth. It is not an accurate conclusion, at least for the City of Plymouth, that "no serious or long term adverse impacts on property tax revenues are anticipated for any of the proposed site taxing authorities." Further, the discussion about the potential cost of acquisition, is misleading. The facts are that Hennepin County purchased this prime industrial land for $1,900,000 about one year ago for the express purpose of developing a transfer station. This followed the political decision by the County Board to forego the already selected and owned Hopkins site. The purchase preceded the preparation of this report. The analysis in the SEIS that the potential cost of acquisition should be based on the "assessed market value of the parcels involved" is nonsensical. Have you actually experienced or are you aware of a purchase of prime industrial land for the assessed market value? Incidentally, the County purchased this property at a substantial premium over what the seller bought it for about one year earlier. The suggestion that there is no financial impact upon the citizens of Plymouth and the County is inaccurate. The suggestion that this EIS is technically accurate because the land has already been acquired, for the most part, and therefore can ignore the actual cost to the County (and to the City and to the school district) is improper and suspect. The City is not impressed with the suggestion on Page 149 that the transfer station may bring a higher level of commercial activity and i therefore a "beneficial impact to ancillary businesses". Is the SEIS seriously suggesting that the additional business realized by "gas stations and fast food restaurants" would counterbalance the potential adverse social, economic, and environmental impacts of this operation? L. Page 156. City policy governs more than only landscape transition and litter control. Structures as well as sites must be compatible with the surroundings. Outside storage and activity, especially those related to the "new" functions involving citizen dropoff are not analyzed in detail. The litter control comments do not indicated how often the site, versus the pit inside of the building, would be policed for litter. M. The control of site access by means of a fence does not address the issue of potential dropoff by citizens and others "outside the gate." How exactly will that be controlled? N. Pages 168 to 169. Will at least one person be on the premises at all time, every day? What exactly will be done to control "anonymous" dumping of high risk materials? Exactly how will citizen access be restricted especially when the facility is "closed"? 0. Page 169. The SEIS talks about good intentions but does not deal head-on with the handling of materials that are rejected or refused or accepted if there is "no convenient alternative." The comment that one should avoid having a citizen return later with illegal material packaged "in an opaque plastic trash bag" does D91 deal with the probabl situation of finding the illegal material in the ditch just down the street or freeway from the facility. 10 P. Pages 170, 171. The statements on facility design and "outreach" are part of the picture but do not effectively grasp the potential severe consequences of mishandling or inappropriate management techniques. They suggest instead that quesses will guide and that, based on limited experience and knowledge, these prototype activities should be undertaken. IV. The City of Plymouth is concerned about equity and the burden it is asked to bear in addition to existing County sponsored and/or owned facilities. The identification of two other potential sites in Plymouth as alternatives begs the question we have raised before: What is the appropriate equitable burden any given city must bear for county sponsored and/or owned facilities? The City's position statement originally adopted in September, 1987, and submitted with earlier testimony, states that the City has been and shall remain a responsible member of the Hennepin County community. This SEIS fails to even mention that the City currently features the following County -owned and related facilities: Adult Correctional Facility (70 acres); Clifton E. French Regional Park (280 acres); Pike Lake/Eagle Lake Regional Park (160 acres); and regional trail corridor (65 acres). The burden of these facilities is part of the City of Plymouth environment. Adding to this burden i� an impact upon the environment. V. The City finds the SEIS Statement to be lacking in substance on critical issues. The document has many references to the things the County has ygii to do, and the things the County lacks in the way of programs, policies, and experience. Yet the City of Plymouth is being asked to trust the County to build and operate a multipurpose facility on the faith that it "should" have minimal impact upon the community and "should" be compatible with established uses in this area. The City cannot share that conclusion, based upon the review of the Supplemental Environmental Impact Statement. VI. Plymouth residents are responsible and concerned county citizens. We are willing to work with the County and with the Metropolitan Council to ensure that the concerns expressed herein will be dealt with in a sensitive and responsible manner. The City has specific zoning requirements for waste facilities and we understand the statutory limitations on local zoning prerogatives, relative to facilities such as transfer stations. The issue here is whether the required Environmental Impact Statement has been prepared in a thorough manner to serve as the meaningful tool that the law requires. We have not reached that conclusion and we suggest that neither can you. Further research and work is needed by both the County and Metropolitan Council before any approvals should be granted for the facility as proposed. The addition of the dropoff functions and recycling functions distort the earlier perceptions of the need for and operation of a transfer station. The haste with which those additional features were added and analyzed is apparent. This should be rectified before any permits are issued and development is undertaken. 1/5/89 12 Cimarron East Homeowners Association, Inc. 14898 19th Ave. No. Plymouth, MN 55441 January 12, 1989 Wayne Nelson Project Manager, SEIS Mears Park Centre 230 East 5th Street St. Paul, MN 55101 Dear Mr. Nelson: I am President of the Cimarron East Homeowners Association. One of our Board Members (E.W. Olson) and a few of our homeowners attended your January 5th meeting at Cooper High School. Our Board represents 184 homeowners located between Fernbrook and Niagra Lanes, one block north of County Road 6. After reviewing the written information brought to us by Mr. Olson and hearing his verbal report, the Board of Directors have unanimously gone on record as strongly opposing the construction of a Waste Transfer Station either at the primary site on the northeast corner of 494 and County Road 6 or the secondary site at the Hennepin County Work House Industrial Site. Referral to the map of Plymouth will show you that we are a large residential community practically next door to your primary site and only a few blocks from the Work House Site. Please find below just a few of our objections. (1) We do not feel that your report has adequately addressed the traffic problem. The new clover leaf, already under construction at 494 and County Road 6 will bring additional traffic to the area off of 494 that does not exist at the present time. This increase in traffic will exist regardless of the proposed sights, and would increase significantly with the opening of the Transfer Station at either of the proposed locations. January 12, 1989 Wavne Nelson Project Manager, SEIS Page (2) We do not feel the hazardous waste issue has been adequately addressed. In addition to the problem of possible ground water contamination and/or run-off, there will be additional traffic of homeowners and plant personnel bringing waste materials to the facility. (3) The increased noise level would be a direct result of the opening of the new intersection and would increase significantly with the opening of the Transfer Station. Such an increase in the noise level, existing six days a week to accommodate the Transfer Station would be objectionable. (4) Contrary to your belief, there is no question in our minds that when you review the aforementioned objections in addition to others already on record from testimony at the meeting on January 5, 1989; our property values would indeed be reduced. We all purchased our homes prior to any interest being indicated in establishing a Waste Transfer Station in our backyard. We wish to make our objections a matter of record and would welcome any opportunity to discuss them with you in persc: Sincerely, ,�� 1y�..7 ��s-cel_-•-L Lr'� Thomas Lanenberg Q President Cimarron East Homeowners Association, Inc. cc: City of Plymouth - City Council , Board of Directors, Cimarron East Homeowners Association, Inc. _1_" t, Phillips NEIGHBORHOOD IMPROVEMENT ASSOCIATION c/o Fairview Deaconess Hospital; 1400 E. 24th street, '.Fls.,.'.i, S CC4 January 1 i , 1989 Wayne Nelson Metropolitan Council Mears Park Centre, 230 E. Fifth Street St. Paul, MN 55 10 1 Dear Mr. Nelson. At its January 9,1989 Boara Meeting, the Phillips Neighbornood Improvement Association adopted a resolution to submit the following questions and comments on the Draft Supplemental Environmental Impact Statement (SEIS) for the proposed Hennepin County Resource Recovery Stations. General questions and comments concern the transfer station system and Its role as part of the county's effort to reduce reliance on landfills. Specific questions and comments address the South Minneapolis site. We nave organized our questions ana comments in the same format as that used in the SEIS. We are sending copies to our local elected officials. Please duplicate and distribute copies to appropriate Committee and Metro Council Members. At the time of our board meeting, we were not able to get copies of Mary Rye's questions as presented at the January 3, 1989 Public Meeting. Please consider her comments as added to this 1 ist of our neighborhood organization. 1 1 Wi 11 the current City Operated transfer station located across the street from the proposed county facility be closed down or will it continue to operate in some related function. If it continues to operate, how will it fit within the County' s waste management plan. Was continued operation of the current facility taken into account in the 5E15. i S 1 Al l transfer stations should have the same operating hours 1.5.2 No management plan is presented for the recycling, yard waste and household hazardous waste components of the facility. l 5.3 How will odors be controlled from hauler trucks while outside the building) 1.5 Contingency plans will not be effective as the transfer stations reach capacities estimated for the year 2020. 2.2 No reasonable attempts were made to identify alternative sites to the Minneapolis South site. The SEIS does not adequately list the reasons for terminating further consideration of the Hopkins site. However, It has been stated at other meetings that the Hopkins site was rejected because of proximity to food industries. The proposed South Minneapolis site is across the street ( less than 100 feet) from a grocery store. How doe's this Compare with the proximity to the food industries in Hopkins. PJ*,4c 2 2 1 it the oreierrea site size is 15 acres, wny is the 5outn riinnaaoolis site a%ouate at 4 3 ;yc,r Es If it was preferable that the site be on county owned property or property inat was uo for sale, why was the South Minneapolis site chosen when the land was not county owned or for sale? The South Minneaplis site has a high potential for traffic congestion The changes to Hiawatha Avenue are not even Under construction yet. Bridging under the railroad tracks and site access off of 28th Street are tied to construction of Hiawatha which is still seYeral years into the future. Why was the South Minneapolis site determined preferable if access to all -season roadways and minimal traffic congestion were high priority criteria? If preference was shown for sites which evidenced minimal visual impact, which were 1 ,000 feet from the nearest residence and showed low potential for adverse impacts on local access routes, why was the South Minneapolis site dertermined preferable? The South Minneapolis site is smaller than desireable. It not only requires the purchase and relocation of 27 homes and four businesses, but is still within 1 ,000 feet of remaining residences and a nursing home. It also has the potential to adversely affect an adjacent cemetery and shopping center. How is this different from the reasons used to reject the Crosstown site, the Eden Prarie site , or the County Home School site? The site evaluation summary in table 2.2- i for the Crosstown site is similar to the South Minneapolis site, yet the Crosstown site was rejected. The reasons for selecting the South Minneapolis site obviously are not to be found within the county's site selection criteria. Without further explanation the selection process rem?lns a mystery. 4.1.3.1 The SETS does not identify if any of the proposed site contains contaminated soils. Some of the site contains prior and existing industrial uses. Industrial land to the east has been found to contain contaminated soils. Soil analysis was not done for the proposed site, but was based on a site to the east. What mitigating measures should be taken if contaminated soi I is found? 4.1.3.3 Are there other contaminates from wastewater collected from the truck maneuvering floor area, the recycling area floor and the transfer trailer load -out area that will remain after passing through the grit, oil and flammable liquids separator that pose a hazard if discharged into the city's sanitary sewer system? How will the wastewater be tested or monitored for contaminates? How does the projected content of wastewater specificelly compare to MWCC standards? 4.2.3.1 Other sites will have a holding pond for storm water detention and treatment. This section along with section 4.1.3.3 imply that there will not be a holding pond for the South Mpis. site. However, section 4.7.3 on page 147 states that a storm water detention pond will be required. If there will be a pond, where is it on the site plan on page 20. Will there be any offensive odors and if so, how will they be mitigated? Detention ponds at other sites are also used for treatment through skimming and sedimentation of fine sands prior to discharge into storm sewers. If there is no pond at the South Mpis. site, how will this water be treated. Why is it necessary to treat the water at the other two sites but not at the Mpis. site. What will be the effect on water quality? 4.3 2.1 The evaluation of existing land use fails to mention the general commercial aree immediately to the south of the site. The proposed transfer station is across the st-eet from the Hi -Lake Shopping Center, less than 100 feet away. The shipping ano-eceiviny area for the grocery store is just across the street from the oroposed transfer facilit,' This section does not mention or evaluate land use compatibility of this area. While other businesses are mentioned by name that are further away from the site, not one of the businesses in the Hi -Lake Shopping center is named. While identifying the cemetery as an ad)oining social/cultural land use, this section fails to discuss the potential impact and land use compatibility of the transfer station on the cemetery except to make a blanket statement for the whole area saying that the transfer station is not an incompatible land use. This is not a true statement and requires further substantiation and documentation. 4.;,.2.2 This section fails to mention the B'3S-2 business/commercial/residential zoning to the south. This section does not mention that this zoning classification allows for a fairly high residential usage ( about the same as R-4 ) 4.3.2.3 This section mentions compatibility with either current or future land use plans. it fails to mention the proposed light rail station at Lake and Hiawatha (one block from the site) and its potential impact on future land use plans. It also does not mention the proposed development currently planned for the former railroad land immediately to the east of the site and the fact that the City Council appointed planning group for this area has publically gone on record as stating that the proposed transfer station is not compatible with their development plans. 4.4.1 The methodolgy used to evaluate the transportation impacts is faulty. Why is the projected traffic volume from the transfer station in the year 2000 compared to the overall traffic volumes in 1989. In the case of the South Mpls. site, Hiawatha Avenue is just beginning to be rebuilt It will not be completed in 1989. However, it is the only probable change that will occur prior to the year 2000. One would assume that MnDot completed some sort of traffic analysis prior to designing Hiawatha Avenue and it would make more sense to comoare estimated taffic volumes after the road is open. It makes no sense to use traffic volumes that we know will change in two or three years. 4.4.3.3 it is difficult to comment on trip distribution shown on figure 4.4-4 as the wastesneo map ( figure 4.9.1 ) does not show the location of the transfer station or the access roads. However, general comparison of the wasteshed map with figure 2 1- 3 makes it difficult to see why 65 percent of incoming and outgoing traffic will use Hiawatha Avenue. 4 4 3.4 This section makes it sound like 1985 is the present and 1989 is the future Exactly how far in the future should projections be made. It would seem that pro)ecting Traffic volumes at a point in time that is one or two years before the transfer st?tion is even open is not exactly the future. In rebuilding Hiawatha, major changes will be made in 28th Street. It will become a through street and access to and from Hiawatha will be improved. This will probably generate much more traffic on 28th Street. Direct access to the Minnehaha Mall, Rainbow foods, and Cub Market will be possible. These stores are mayor traffic generators. The area to the east will be intensely developed, generating even more traffic. Turns off of 25th street may become difficult seeing as there will be no turn lanes/turn signals let alone any traffic signals. fJCJC - This section fads to ioentify ImoactS wnile Hiawatha is unher construction The SEIS projects that traffic will use Cedar, 25th Street and Hiawa+.na In this respect, the sitE access for the proposed station is exactly the some as it is for the existing transfer station. However, experience shows that the trucks use other residential : treets, including i 8th Avenue, instead of using identified truck. routes This !s despite being Told not to use residential streets. Proposed volumes for the new station are much higher than now and this problem will intensify. The SETS does not identify this as a problem nor does it propose any workable mitigating measures. While the SEIS shows that vehicles will enter the transfer station from 28th Street, the site plan on page 20 shows that access to the station is easier by entering from Lake Street on 21 st Avenue. The use of this route is likely because the intersection at 21 st and Lake Street is signalized and left and right hand turns off of Lake Street onto 2 1 st AvenuP are easy. This will impact the shopping center and the cemetery. Trucks will also use 31 st Street and turn north on 21 st Avenue to access the transfer station. This would pose a problem to residences and to South High School which is only a couple of blocks from the proposed transfer station site. Operation of the exisiting transfer station has shown that trucks will use the easiest route no matter what they are told and nor matter which streets are designated as truck routes. As stated in section 4.8.1 of this document, haulers will also be attracted to take breaks at the fast food businesses and restaurants in the shopping center ( four, not including the grocery store or the two reastaurants across Lake Street.) Combining the likely use of 21 st Avenue as an access route with patronage of restaurants in the shopping center by haulers, a situation will result that will be almost equivalent to placing the transfer station in the middle of the parking lot of the shopping center. This is not acceptable. Yet the SEIS does not comment on these potential traffic problem. Instead the HIS acceots at face value an access plan that does not conform to the reality of the situation or other facts presenter+ within the report. No mitigating measures are proposed. The transportation analysis does not mention that Cedar Avenue and 28th Streets are primarily residential streets in the stretches that are shown as access routes on figure 4.4-4. What are the impacts of adding significant truck traffic on these streets? What mitigating measures are possible. The SEIS does not mention that there is a nursing home at one of the major access corners at 28th Street and Cedar Avenue. What will be the impact on the nursing home) Will it be more difficult or dangerous for elderly to cross this intersection The SEIS fails to mention that there is a major 220 unit family housing protect located on Cedar Avenue two blocks north of one of two major access,intersections to the site at 28th Street. The project was built on both sides of Cedar Avenue and children run across Cedar Avenue. Children can not be expected to act like adults and safety is a major concern of residents. What will be the affect of adding more truck traffic on Cedar Avenue and what mitigating measures are possible. The SEIS does not adequately address the fact that lefthand turns from southbound lanes on Cedar to eastbound lanes on 28tH are difficult and more likely to nave a L05 of 'E' or 'F'. Lefthand turns from westbound lanes on 28th Street to southbound lanes on Cedar are equally difficult. Righthand turns from westbound lanes on 28th Street are likely to substantially delay eastbound traffic on 28th Street trying to make lefthand turns into the northbound lane of Ce,,zr Avenue. zl- 03�e Tne transportation section snould be redone using better information and a more creave methodology. ,I S.2 This section Includes a discussion of characteristics of sound. It would seem that there might be a variation In sound behavior in different seasons, as the buffering capacity of the surroundings change. In winter, forage is substantialy reduced and ground freezes. This would seem to reduce absorption and increase reflectance, thereby increasing sound levels. Field measurements were taken in July. Would fielC measurements be different if taken in January? if so, what would they be? 4.5.3 The location of receptor a2 for the South Mpls. site shown on figure 4.5-2 is not adequate to measure the noise impact on the shopping center. A location closer to the intersection of 21 st Avenue and 29th Street is also needed. At this location, as well as for most of its length, the shopping center is less than 100 feet from the proposed transfer station, not 500 feet. At this location, the site plan ( figure 1.7-4) also shows the access doors for the large transfer trailors directly in line with 21st Avenue. Operational noise will be more perceptible, both for the shopping center and at the cemetery at this location. The proposed site plan also shows X11 on site truck traffic passing 21 st Avenue and 29th Street. This is a different situation from conditions at receptors a2 and R3 where on site truck traffic is not as intense. In addition, proiected traffic noise after the station is in operation does not include the traffic noise from trucks accessing the station using 21st Avenue. The probability of trucks using 21 st Avenue has been mentioned in the comments under the transportation section. Both the L( 10) and L( 50) MPCA noise standards for residential (cemetery) and commercial (shopping center) are likely to be exceeded at 21 st Avenue and 29th Street. 4.5.7.1 The transfer station will be in operation from 7 p.m. to 9 p.m. These operating hours would fall into both category I and I I of the Minneapolis noise limitations ( Table 4.5-4). As the transfer station is in continual operation, the duration of sound is in excess of 2 hours. Traffic noise from motor vehicles near the receptor points would also be from these vehicles operating on the transfer station site and not just on traffic ways of the city ( and therfore not exempt.) It would appear from the information presented in the HIS that the Minneapolis noise ordinance standards would be more stringent than MPCA standards. Therfore comparisons should also be made with the Minneapolis standards. Will the transfer station be operational on state and federal holidays and/or is a permit needed if it will operate on these holidays? 4.5.7.2 Comments have already been made on the inadequacy of the selection of noise receptor locations and also on the application of noise standards. Comments in this section bring up a question that also appiys to other sections. That is, when do impacts become significant? This section comments that noise levels at receptor s 1 already exceed noise standards. What justification is there for making the situation even worse. The projected noise levels after the station is in operation are two to three times as loud as MPCA standards stated in this report. ( "As stated, noise level measurements are logarithmic - an increase of 3 dB represents a doubling of the energy level of sound.) From table 4.5-3, the noise level after the station is in operation is 5d5 greater than the MPGA standard for L( 10) and 2 dB greater for L( 50). Receptor a 1 is also the location of a nursing home, not just a single family residence. Instead of suggesting mitigating measures, the SEIS simply rights off this problem as impercep2ble. This is not credible. The three cons ioer at ions iisted in the discussion er receptor a3 in the ser °tery fall to mention that the cemetery is open to the public and used more than just or.. 'lemorial Ga and for burials. Is the SETS attempting to define what constitutes a religloia °?wisp or. ooservation? Different MPGA standards should not be used for the cemetery as recommended in the SETS. 4.6.1 This section states that it seeks to identify the types of changes in the regional and state solid waste management systems which could affect facility operations. If this is the case, then this section should address the possible affects if the county or state changes current plans that call for only 20% of wastes to be handled by recycling. The 20% figure is low and it is reasonable to assume that future changes are likely. This section should identify ouamties of waste that need to he handled t7y the trynsfer stations in order to keep the burner operating at an economically feasible level. If changes are made in the county and state waste management plans, the impact of these changes would seem to be critical information that would affect facility operations. ( For example, what would happen if the proportion of combustible material in the overall MSW is significantly reduced. ) This section should address possible regulation of ash disposal as this may greatly affect the operation of the transfer station (e.g. capacity to handle source separation, storage, and disposal requirements) 4.6.3.1 it would seem that the level of household hazardous waste from the Marin County study does not account for the tendancy to store such materials and that the MPCA demonstration program generated significantly higher rates. In calculating the amount of household nazardous waste for Hennepin County, why were the Marin County figures used without making adjustments based on the MPCA demonstration program? After all, Marin County is in California and Hennepin County is in Minnesota. 4 6,3 2 It is apparent from this section that Hennepin County has not presented a plan for nand) ino of household hazardous waste. How can you evaluate a plan that does not exist) With the nsense of a pian, participation rates seem to be a matter of conjecture. it any case, a participation rate of 5% is dismal. This leaves one to assume that 95% of household hazardous waste will be handled as part of municpal solid waste. With su,.h dismal projections, it would seem that the county or state would make changes in how this waste is handled. What might these changes be and what would be the affect on facility operation? If a demonstration source separation program is to be put in operation at the South Mpis. site, what impact will it have on further separation of household hazardous wastes. If 5% participation in the drop of program generates "considerable" materiais, what additional storage capacity is needed for the South Minneapolis site for harzardous materials removed during source separation What will the impact of source separation be on the reduction of household hazardous waste that would otherwise be sent to the burner? How will these wastes be identified for separation? For example, pesticides and lawn care products? A typical label on these products state that "this product is toxic to fish, birds and other wild life. Birds feedino on treated areas may be killed. Keep out of lakes streams or ponos... Do not V4UC contaminate water by cleaning epuipment." These same product labels go on to recommend disposal methods, "discard by wrapping original container in several layers of newsoaDer and discard in trash." These are dangerous products and how can such waste, that is wrapped in newspaper, be identified for separation? What will be the affect on wastewater from contaminants contained in household hazardous waste that are not separated out, but that are released dur ing the compacting process? If only 5% will be handled through the drop off point, 95Z will go through the municipal solid waste portion of the facility. This is 69,300 gallons per week ( 17,325 gallons per station) using the estimates provided in the SETS document. 4.6.4.2 Tnis section states that operating levels of each transfer station will be near capacity by the year 2020. Capacity of the stations is between 1,500 to l ,800 tons per day. The evaluation of impacts in the SETS is based on a station operating at 400 to 700 tons per day. Why weren't higher operating levels chosen for use in evaluating impacts? Why weren't impacts evaluated at different operating levels over the projected operating life span of the transfer stations? Why was the year 2,000 chosen instead of 2005 or some other year? The projections made in this section invalidate much of the assessments made in other sections of the SE1S and would seem to indicate that impacts will be significantly greater beyond the year 2000. If capacity will be exceeded at the Bloomington station, what will be the impact on the South Minneapolis station? Will wastesheds be reassigned? This section only discusses the capacity level of the MSW transfer function and does not address the capacity levels of the drop off and recycling functions. 4.6.5.1 All yard wastes must be diverted from landfills and waste combustion facilities by the year 1990. Currently it is estimated that 8.7% of the waste stream is yard waste. By the year 2000, the County projects that 8% of the waste stream that is yard waste, almost all yard waste, will be diverted through separating of yard waste from the MSW. The yard waste drop off section of the facility and its operating role in the overall handling of yard waste is not cleasrly presented or evaluated in the SEIS. Will the transfer stations be the only drop off center's for yard waste in the system? Will large trucks transfer yard waste's from the stations to the composting facilities. Are the drop off sections adequately designed to handle 92% of ali yard waste? How will the County achieve a 92% level of participation in separation of yard wastes when participation levels in drop off of household hazardous waste are only estimated at 5%? If emphasis has been placed on management of household hazardous waste, why is a program envisioned that will only handle 5% of the problem? How will planning and management efforts, that are implemented to reduce the toxicity and volume of ash, affect facility operations of the transfer stations, especially since it is anticipated that new rules will be in effect within two years? Exactly what is Hennepin County doing to acheive recycling goals and how does the rw/cling drop off portion of the facility fit into these pians? Exactly how does the transfer station concept allow for modification of drop off and recycling activities in the future and what are the impacts of these modifications that have been planned into the design? GAGE o 4 6 5 LacKing a reel plan from the County on the recycling, household h&arwus waste and yard waste drop off components of the facility, it would seem that the affects of system modification could signifcantly change the oesign and operation of the drop off and recycling components of the facility. The impact of even the changes mentioned in this section of the SEIS has not been evaluated in terms of facility design, operations, and other impact areas (e.g. transporetion, noise, etc.) The time between the adoption of the original EIS and the new plan presented by the county for the concept and operation of the transfer stations was about two years. During this time, the changes resulted in the expansion of the South Mpls. facility from an original plan for 1.3 acres to a plan for 9.3 acres and minimum site area criteria were increased to 15 acres. based on the potential chances and unanswered ouestions that nave been identified in this EIS, the 9.3 acre facility planned for the South Mpls. site could reach rapacity and/or become outmoded in a similarly short timo period ( two to three years. ) 4.7.3 This section states that a storm water detention pond will be required. This pond is not on the site plan and contradicts information presented in other sections of this report. 4.8.1.2 The adequacy of the report from the Metropolitan Council on affects on property values is ouestionable. We have contacted the Minnesota Association of Realtors. They are aware of the Metropolitan Council study. The Minnesota Asociation of Realtors have no statement to support or to contradict the Metro Council study at this time. instead, they are currently Wing their own study on this issue. This study will not be completed by January 19th. Other states are being contacted to find out what has happened in comparable situations. While not able to comment on the specific affects on property values of the location of such facilities, they have done other studies in which negative perceptions have been shown to affect property values (e.g. group homes for ex -felons) and where other environmental issues have affected property values. The 16 parcels of land curently owned by Hennepin County were only recently purchased by the County for the sole purpose of building the transfer station. 4.8.3.1 While the existing 30 to 35 employees may not be location dependent, this is not true for the local community in which these jobs are located. According to census information, 50% of the households in the Phillips Neighborhood do not have access to a vehicle. These housenolds are dependent on jobs that are located in the community or that are easily ac:,essable by public transportation. The number of jobs that will be at the transfer station is very low compared to other development alternatives for this site Affordable housing is in low supply. Removing the existing housing is a major ,mpact on the supply of affordable housing. Relocation efforts to date are already partially responsib)e for two deaths from stress associated with moving and one dealth from fire in one of the remaining occuoieo nouses. How do you place a dollar value on these lives or evaluate this in an environmental impact statement's 4.8.3.2 The Minnesota Realtors Association should be contacted to access potential impacts on property and business values. The existing transfer station is substanial ly smaller than its proposed replacement and it is not of the same kind. The impact of a two story building is not the same as a building that will be as tall as a six, story building. A site that is only 1.3 acres is not the same as a site that is 9.3 acres. The oresense of the new station will De Z)-- aaGE 7 Pvioent form env Dlocks around the site, wnereas the currents tat ion is not visually oerceotaole for more than a block. 4 b.4.3 Minneapolis already has too much property that is not on the tax roles. Tne amount of lost tax money is important for the school district which already has financial problems. There are better uses for the site that would generate even more taxes 4.9 If--ignment of wastesheds, as stated in this section and in the executive summary, was done to minimize travel time and associated costs, then the area served by the main garbage burner (NERC) would include the proposed South Minneapolis site. Based on this, the South Mpis. site is not a logical location for a transfer station. To achieve use of the wastesheds identified in figure 4.9-1 will recluire that haulers use designated stations only. For portions of the wasteshed identified for the Minneapolis South station, the westeshed is not based on minimizing travel time and esswiated costs. The wasteshed map should show the location of the transfer stations and identidy the wasteShed boundaries. 4.10.1.1 With trucks arriving or leaving approximately every minute, how feasible will it be to maintain doors in a closed position to control litter and odor? This has not been possible at the existing transfer station. The truck washing facility has been eliminated from the plan. How will odors from hauler trucks at the site be controlled if they are not washed? The trucks will not be in the building ail the time and may have to wait in line to be weighed and to gain entrance to the building. Private vehicles are allowed to dump solid wastes for a tipping fee at the existing station. 'Hill this be allowed at the proposed station? If it is, what will be the impact on odor and litter control') What will be the impact on truck traffic delays and lines forming outside the building? 4.10.3.1 Other sections of the SEIS evaluate impacts on adjoining land. Why is the section on historical/cultural resources limited to only the proposed site. How does the proposed transfer station affect the historical/cultural resource of the cemetery? You could not get by with putting this transfer station next to Fort 5neliing National Cemetery. 4.10 3.2 How do you buffer a 58 foot tall structure with landscaping? 5-2 Based on comments made in the section on transportation, mitigating measures are necessary and should be identified. 5.3.1 Mitigating measures should be identified for handling household hazardous waste that remains in the MSW. There is to be a demonstration source separation program at the South Minneapolis Transfer station that will screen municipal solid waste more thoroughly than at the other stations. The operating plan and facility design do not clearly indicate how this is incorporated and it is not reviewed in the SETS What facility design cnanges are needed to screen and separate materials after they have been dumped from hauler trucks, as waste will not be dumped directly into the pits? How will separated materials be handled and stored % what are the estimated quantities of such materials') How will aodtional materials Nage 1 C be disposed of? How will remaining solid waste get to the compactor aree? How will the area be kept clean to control litter, odors and vectors? Will an overhead misting system still be used to control dust? What safety measures will be required for workers confined to an enclosed building in which no special ventilation and air cleaning equipment is planned? What are exposure risks to household hazardous wastes, explosives, etc. in a portion of the building that will not have the some design precautions as the drop off storage area for household hazardous wastes? PNIA would appreciate a response to these questions and comments on the SEIS for the proposed Hennepin County Resource Recovery Transfer Station Project and in particular the South Minneaplis site. SinternIy, Y/ 7-17 Ray Peterson PNIA President CC: State Representative Karen Clark State Senator Linda Berglin Minneapolis Council Member Tony Scallon Hennepin County Commissioner Jeff Spartz U.S House Representative Martin Sabo January 16, 1989 Metropolitan Council of the Twin Cities Area Mears Park Centre 120 East Fifth Street St. Paul, MN 55101 RE: Supplemental Environmental Impact Statement for Hennepin County Resource Recovery Transfer Station Project TO WHOM IT MAY CONCERN: We at Sterling Electric Company have serious concerns regarding the proposed location and handling of waste at the Plymouth Waste Transfer Site location. We believe the Metropolitan Council has not adequately assured us that this facility would be well managed and safely operated. The area of County Road 6 and 1-494 is rapidly changing. With the addition of the Carlson Complexes, and the growth of other major businesses in the Industrial Park, the addition of this Recovery Transfer Station is intolerable. Our traffic levels have doubled since we moved to Plymouth four years ago. The introduction of 400 or more garbage haulers would disrupt our business and make it less safe for our employees and customers. We, like others in the complex, chose the Plymouth area to conduct our business. Up to 10% of our total business is conducted over our counter. We are proud of our facility and our community. We invite our customers to visit us. A Waste Transfer Station located less than a block from our doors will make it difficult and less appealing for our customers to come here, especially during the outdoor functions we hold every summer. After attending the Public Meeting at Cooper High School on Thursday, January 5th, 1989, 1 have grave concerns regarding the handling of waste and the plan of management, which did not segm of real concern to the Council. Your responsibility is not only to find the most reasonable location, but also to assure residents of the community of a safe and sound operation. If find no assurance in such matters as a "run-off pond" and skimming devices for floatable wastes". I also find nothing safe in the fact that you will provide a drop-off location for household hazardous wastes. As it has been proven, many people dump hazardous waste with no regard to their environment or the residents living in the area. We at Sterling Electric do not care to pick up trash, hazardous or otherwise from our lawn, nor do we want oir dumpster filled with wastes refused at your facility. In the event dumping occurs at our location, our neighbor's property or the freeway system, who will take responsibility for clean-up and disposal costs? The Metropolitan Council is taking a band-aid approach to a long term problem. There are numerous other environmental problems the Council has failed to address. Specific details on the design should be made so that those affected will be adequately informed before we approve such a facility in our backyard. A hazardous waste drop-off site for residents of Hennepin County is needed, but without proper management 24 hours per day this project could not begin to work effectively. How will household hazardous wastes be separated, stored and transported out of this facility and what will the turn -over rate be? The Metropolitan Council has not seemed responsive to the issues facing their future neighbors. Why should we accept our backyards for a transfer facility when in return the most important issues of personal safety, local costs and a clean environment are overlooked. The Council must address these environmental issues head-on. We appeal to you. We work best when we as a community are united. You must do your part, too. We are responsible caring people. I write this because we take pride in being a part of the Plymouth Community. We need a safe and clean environment to live and work in. We have waste and we must deal with our growing waste problem. As always, some end up paying a higher price than others, but we in Plymouth are not reassured as to the feasibility, safety factors and the need of this transfer site. We stand behind the City of Plymouth, as presented by Mayor Virgil Schneider on January 6, 1989. We will not approve of this proposed "neighbor" until we are assured of a safe and workable facility. Respectfully, Sterling Electric Company 9 Karin J. Lindquist Operations Manager cc: Dale Lindquist, President of Sterling Electric Mr. Virgil Schneider, Mayor of Plymouth, MN