3.b Update of BHE Renewables Solar Site
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November 6, 2018
Mr. Jim Shaver, Administrator
Carnelian-Marine-St. Croix Watershed District
Post Office Box 188
21150 Ozark Avenue
Scandia, Minnesota 55073
jshaver@cmscwd.org
Delivered VIA Electronic Mail Transmission
Re: Notice of Deficiency of Storm Water Facilities at Argo Navis Community
Solar Garden
Mr. Shaver,
This letter follows BHE Renewables’ (BHER) initial response letter dated October 5,
2018, responding to the Notice of Deficiency (Notice) issued to the Argo Navis
Community Solar Garden (Argo Navis CSG). The Notice required a response with the
outline of near-term, short-term, and long-term plans for the storm water system at the
Argo Navis CSG. In an October 23, 2018 e-mail communication, you requested
additional details and completion dates for the activities outlined in BHER’s initial
response letter. The following chart contains estimated completion dates, assumptions
and supplemental information, as requested. The information provided is the most up-to-
date view of events; however, the dates could change based on conditions, such as
weather, permitting requirements or other factors outside our immediate control.
Short-Term Implementation Plan
Action Estimated Date
of Completion
Notes
Immediately following notification, crews were
employed to stabilize the location of the
overflow by placement of sandbags to prevent
any further overflow
Complete September 22, 2018
Best Management Practices (BMP) repair
activity: Inspection of current site runoff
Complete
BMP repair activity: Collection of as-built
topographic data to confirm the post-
construction onsite drainage patterns and
storm water storage capacity
December 14,
2018
All topographic information aside from basins
containing water has been collected. Final as-built
data will be collected following complete de-watering
of the site and scarification of basins
BMP repair activity: preliminary analysis to
determine the best course of action for
immediate improvement to existing storm water
basins
Complete Ongoing pumping for dewatering of the site as well as
additional temporary holding basin at northern
boundary of site with approval from and coordination
with Watershed District, MPCA, City of Scandia and
DNR
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Near-Term Plan and Timeline to Investigate Cause of Storm Water System Failure
Action Estimated Date of Completion Notes
Pumping of the onsite retention basins
to create immediate onsite storage
capacity
November 25, 2018 Initiated week of September 30, 2018,
including movement of onsite water
between existing retention basins to
reduce potential for additional discharge.
Grading permit (City of Scandia) will
allow for additional retention basin
Onsite investigation by contractor
representative
November 25, 2018 Initiated September 30, 2018. Anticipate
completion following complete
dewatering activities
De-silt and scarify the bottoms of the
existing onsite retention basins to
increase percolation rates
December 7, 2018 Anticipated following completion of
dewatering activities and topographic
measurements of emptied basins
Topo and hydrology analysis by third-
party engineering firm to confirm as-
built site conditions meet design
specifications
November 28, 2018 Analysis of central basin and site
topography anticipated by November 20,
2018 and dewatered basins by
November 28, 2018
Application for Minnesota Department
of Natural Resources (DNR)
Appropriations Permit for water
movement throughout the site
Complete Initial verbal approval obtained October
5, 2018. Final permit approval granted
October 31, 2018. Additional Land
Alteration and Grading permit required
from City of Scandia for additional
holding pond proposed on site
Spill Report with Minnesota State Duty
Officer
Completed Report number 178184
Participation in investigation and
potential remediation requirement
meetings with the District, DNR,
Scandia City Council and other
jurisdictional agencies
Ongoing BHE participating in all requested
meetings, site visits and requests for
information from DNR, Watershed
District, MPCA, City of Scandia, etc.
Retain third-party independent water
resources engineer/ hydrologist with
knowledge of local hydrology to provide
an independent opinion with any
necessary design changes
November 28, 2018 Third party engineer hired October 23,
2018. Preliminary analysis completed
November 2, 2018. Final analysis
awaiting full dewatering of basins on
Argo Navis site
Long-Term Plan Permanent Remediation and Monitoring of Storm Water System
Action Estimated Date of Completion Notes
Additional remedial efforts as needed
to meet design criteria
TBD Currently unknown if design changes will
be needed. Determination will follow final
analysis slated for December 14, 2018
Ongoing monitoring and inspections
until site has reached full stabilization
and revegetation
Summer 2019 Anticipate completion of remediating
storm water basins on December 7,
2018. Full stabilization not likely until
Summer 2019. Monitoring will be
ongoing per site SWPPP.
Continued cooperation with local and
state agencies in identification of
necessary remediation efforts and
ongoing storm water compliance until
full stabilization of the site is confirmed
TBD Awaiting findings from Technical
Evaluation Panel (TEP). According to
Watershed District, findings and
recommendations from all agencies will
be summarized in one document.
Ongoing participation in site inspections
and meetings at the request of the
Watershed District and/or any agencies
involved
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As we continue with remediation of the storm water retention ponds at the Argo Navis
Community Solar Garden, we will continue with our ongoing cooperation with the Watershed
District and all other agencies. BHE Renewables is committed to environmental excellence and
working with responsible agencies to ensure a similar storm water event does not occur.
Please direct any questions or comments to Wendy Greene, Environmental Compliance Director
at (805) 458-7924 or WLGreene@bherenewables.com and Neal Poteet, General Manager at
(805) 835-8856 or NPoteet@bherenewables.com.
Thank you,
Wendy Greene, Environmental Compliance Director
BHE Renewables, LLC
Cc: Carl Almer, Engineer for Carnelian-Marine-St.-Croix Watershed District
Brandon Dahl, Construction Stormwater Inspector, Minnesota DNR
Wade Johnson, President of Carnelian-Marine-St.-Croix Watershed District
Eric Lundberg, District Manager for Carnelian-Marine-St.-Croix Watershed District
Tom Polasik, District Manager for Carnelian-Marine-St.-Croix Watershed District
Paul Richert, District Manager for Carnelian-Marine-St.-Croix Watershed District
Joe Richter, Groundwater Hydrologist, Minnesota DNR
Daniel Scollan, Groundwater Protection Hydrologist, Minnesota DNR
Neil Soltis, City Administrator, City of Scandia, MN
Jenifer Sorenson, East Metro Area Hydrologist, Minnesota DNR
Sussannah Toerseth, Attorney for Carnelian-Marine-St.-Croix Watershed District
Kristin Tuenge, District Manager for Carnelian-Marine-St.-Croix Watershed District
Andy Weaver, District Manager for Carnelian-Marine-St.-Croix Watershed District
Cody Worton, Engineer, M+W Energy, Inc.
Dr. James Zavoral, Property Owner