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9.a Staff Report Tiller Mine 2020 AOP Memorandum To: Scandia City Council Reference: Tiller Corporation— 2020 Annual Operating Permit Application for Scandia Mine Copies To: Ken Cammilleri, City Administrator Christina Morrison, Tiller Corporation Kirsten Pauley, Sunde Engineering Project No.: 17722.000 From: Merritt Clapp-Smith, Planner Routing: Date: February 11, 2020 SUBJECT: Tiller Corporation, Inc. – 2019 Annual Operating Permit (AOP) Application for a Mining and Processing Operation MEETING DATE: February 18, 2020 LOCATION: 22303 Manning Trail. Lengthy legal description provided in application Attachment 1. APPLICANT: Tiller Corporation 7200 Hemlock Lane Maple Grove, Minnesota 55369 60-DAY PERIOD: March 30, 2020 ZONING: Aggregate Mining Overlay District ITEMS REVIEWED: Application, Plans and Related Submittals; subconsultant and agency comments, site visit findings BRIEF DESCRIPTION OF THE REQUEST: Tiller Corporation has applied for its 2020 Annual Operating Permit (AOP) for an existing sand and gravel mining operation located on Manning Avenue near 225th Street in Scandia. The site has been actively mined since 1966 and currently operates under Conditional Use Permits (CUPs) granted by the City on May 20, 2008. The Tiller mine site previously operated under a CUP issued by Washington County when the County exercised land use authority within New Scandia City Council Tiller Scandia Mine 2020 AOP Page 2 February 18, 2020 Scandia Township. Permitted activities included the mining and processing of aggregate, the production of hot-mix asphalt, and the recycling of concrete and asphalt products. The City’s Mining Ordinance specifies an AOP cycle that coincides with the active mining season. Applications are due by January 31 each year, to enable permits to be approved before the start of the mining season in that year. The applications for the Scandia Mine Site since 2010 have included both the Tiller site and the adjacent former Dresel Mine site to the south. Tiller purchased the Dresel site in 2009 and is operating both sites. The City issued a CUP for mining and processing at the Dresel site on May 20, 2008. As the Owner of both sites, Tiller needs to comply with the conditions of both the Tiller and Dresel CUPs. Issues and compliance with each are discussed in this report. EVALUATION OF THE AOP REQUEST The Applicant is requesting an Annual Operating Permit (AOP) for a mining and processing operation. The permit requirements are governed by the City’s Ordinance No. 103, Regulation of Mining and Related Activities, which is Chapter 4 of the Development Code. The Ordinance requires review of the following items for the AOP: 1. The operating conditions of the previous year and conditions required by the CUPs for the Tiller and Dresel sites. 2. Proposed operating conditions and any variation from the previous year. 3. Results of the annual inspection by the City. CONDITIONAL USE PERMIT REQUIREMENTS Tiller Mine Site The City of Scandia approved a Conditional Use Permit for sand and gravel mining and processing at the Scandia Mine site for Tiller Corporation on May 20, 2008. The conditions included the items noted on the table that follows. Tiller’s performance is indicated on the table and in the text sections that follow: There were no issues identified in 2019 for the Tiller Mine site. Scandia City Council Tiller Scandia Mine 2020 AOP Page 3 February 18, 2020 Condition Deadline Specified in CUP Status Notes 1. Comply with CUP Ongoing + In process--monitored by City staff and consultants 2. Comply with Rules and Regulations Ongoing + In process--monitored by City staff and consultants. 4. Permits from CMSCWD None specified * CMSCWD staff reviewed the AOP application and had no concerns. CMSCWD Permit 08-003 for the Tiller mine remains in effect. 5. Monitoring Wells July 20, 2008 + Three required monitoring wells were installed in 2008. One well was taken out of service and sealed in 2011 to accommodate reclamation activities (MW- 2). Monitoring results for the two active wells in 2019 were provided with the AOP application and reviewed by LRE Water, the City’s groundwater consultant. 6. Ground Water Monitoring July 20, 2008 + The Ground Water Monitoring Plan was approved in the fall of 2008 and revised in 2013. The plan is on-file at the City. 7. Excavation below water table May not begin before August 20, 2008 + Excavation into the water table began in 2009. The CUP permits mining into ground water to a depth of 50 feet. Excavation into the groundwater table has occurred as follows: 2013 – to a depth of 15 to 20 feet 2014 – no mining into groundwater table 2015 – no mining into groundwater table 2016 – to a depth of 15 to 20 feet 2017 – no mining into groundwater table 2018 – no mining into groundwater table 2019 – to a depth of 15 feet 2020 – excavation into the groundwater table may occur. Water level data is collected on an ongoing basis and submitted to the City. Water level data has been submitted for this application, and Dave Hume’s review and recommended conditions are discussed in the section on Groundwater Monitoring. 8. Production Well July 20, 2008 + Production well records are being kept by Scandia City Council Tiller Scandia Mine 2020 AOP Page 4 February 18, 2020 Condition Deadline Specified in CUP Status Notes Records Tiller Corp. and are available to the City. Water pumped at the site in 2019 was 15,882,400 gallons. The DNR Water Appropriation Permit for the site allows up to 20 million gallons to be used each year --18 million gallons per year for washing, and 2 million gallons per year for dust control. 9. Ground Water Analysis - DRO (Diesel Range Organics) and GRO None specified + Groundwater samples were analyzed for DRO. No gasoline is stored on site. If gasoline storage is added, GRO will be analyzed. Monitoring results were included with the application and reviewed by LRE Water. No DRO were detected in the samples in 2019. 10. Map of Index Well Sites July 20, 2008 + Map was provided to the City on August 28, 2008. 11. Asphalt Plant Setback from Lake Ongoing + Setback has been maintained as required by the CUP. 12. Lake Depth Ongoing + Application indicates that the depth of excavation will not exceed fifty (50) feet below the water table, per the CUP. Excavation depth to date was approximately has been less than 50 feet into the groundwater table through 2019. 13. Truck Signage and Roadway Cleaning July 20, 2008 + Washington County has posted Lofton and Manning Avenues per County requirements. Tiller has posted signs on 218th Street and at Lofton Avenue to restrict trucks from using 228th Street per City of Scandia requirements. The signs were in place at the City site visit in 2019. 14. Lofton/Highway 97 Intersection July 20, 2008 + Tiller restricts importing add-rock from Lofton Avenue during non-daylight hours per the CUP requirements. 16-19. Updated Reclamation Plan July 20, 2008 + Included in application materials; discussed below. 20. Letter of Credit/Security Due before AOP approval + The financial guarantees are current. 21. AOP Application Submittal January 31, annually + Application submitted on January 29, 2020 and determined to be complete. Scandia City Council Tiller Scandia Mine 2020 AOP Page 5 February 18, 2020 Dresel Mine Site The City of Scandia approved a Conditional Use Permit for sand and gravel mining and processing for Dresel Contracting, Inc. on May 20, 2008. Tiller Corporation now owns and operates this site, and therefore must also comply with the conditions of the Dresel CUP. There were no issues identified in 2019 on the Dresel Mine site. Condition Deadline Specified in CUP Status Notes 1. Comply with CUP Ongoing + In process--monitored by City staff and consultants. 3. Comply with rules and regulations Ongoing + In process--monitored by City staff and consultants. 4. Permits from CMSCWD None specified * The CMSCWD Board renewed Permit 08-003 for the Tiller permit in February 2019. 5. Installation of Monitoring Wells July 20, 2008 + Installed in May 2008. Groundwater Plan was updated to reflect changes to monitoring well MW-2 in 2013. The site complied with plan in 2019. 6. Revise Proposed Conditions Plan Pit Elevations July 20, 2008 + The City approved a maximum mining depth at 922 feet-amsl at the Dresel site, ensuring three feet of separation between the floor of the mine and the water table surface during high water table conditions, based on monitoring results. LRE Water, water quality consultant to the City of Scandia, reviewed the submitted data and made recommendations which are included for the 2020 AOP. 7. Ground Water Monitoring Plan July 20, 2008 + Approved in October 2008 and on file at the City. 8. Revise Site Plan to include Index Wells July 20, 2008 + Provided to City on August 28, 2008. 9. Identify Bench Mark Elevation July 20, 2008 + Established at top of Well Casing MW-1. 10. Ground Water Analysis - DRO and GRO None specified + Samples are analyzed for DRO when mining activity is occurring. No gasoline is stored on site. If gasoline storage is added, GRO will be analyzed. No DRO or other contaminants detected in 2019 monitoring at the Dresel site. 11. Signage on 218th and Roadway Cleaning Ongoing + Signage was installed and meets the CUP requirements; inspected by City staff during 2019 site visit. 12. Truck Cleaning Ongoing + Trucks must meet requirements for Scandia City Council Tiller Scandia Mine 2020 AOP Page 6 February 18, 2020 Condition Deadline Specified in CUP Status Notes cleaning per CUP. No issues identified in 2019. 13. Delineate Northern Wetland None specified + Wetland report and delineation completed. Buffer marked by September 15, 2008. Complaint received regarding encroachment into wetland in late 2014. Mitigation and replacement plan were completed and approved by TEP panel and wetland credits successfully withdrawn from the BWSR Wetland Bank in 2016. 14-17. Updated Reclamation Plan July 20, 2008 + Reclamation Plan revised as part of combined Reclamation Plan submitted for the Tiller site with the AOP application. 18. Letter of Credit/Security Before AOP approval + Financial guarantees are current. 21. AOP Application Submittal January 31, annually + Application submitted on January 29, 2020 and determined to be complete. OPERATING CONDITIONS - EVALUATION FOR THE AOP Site Operations - Background Information The Tiller mine site includes several parcels, as indicated on the Site Plan. Excavation activities in 2010-2011 removed material between the Tiller site and former Dresel Mine site, merging the two sites into one. Tiller mined both sites in 2019. The mining operation includes removal of overburden, excavation of sand and gravel, crushing, washing, screening, stockpiling of sand and gravel; recycling of concrete and asphalt products; the production of hot-mix asphalt; and reclamation activities. The overburden is removed from areas to be mined and stockpiled on the site for use in reclamation activities. The operator brings portable crushing, washing, and screening plants to the site periodically and these are used to process and stockpile materials. The operator produces and sells asphalt throughout the construction season and delivers add- rock materials to site as needed to produce required mixes and materials. Mining into the groundwater began at the site in 2009. This activity has been described in the previous mining plans for this site and was evaluated in the Environmental Assessment Worksheets completed for the Tiller site in 1987 and 1999. The CUP allows mining into the groundwater to a maximum depth of 50 feet. Mining into the groundwater table occurred in 2013 and 2016, to a depth of 15-20 feet, and did not occur in 2014, 2015, 2017 or 2018. Mining into the groundwater table occurred in 2019. The asphalt plant at the site is equipped with a bag-house air pollutant collection device, and operates under a Minnesota Pollution Control Agency (MPCA) Air Emissions Permit. Storage tanks as the site (for fuel and asphalt cement) are regulated by the MPCA. Scandia City Council Tiller Scandia Mine 2020 AOP Page 7 February 18, 2020 The main access routes to and from the site are Manning Avenue (County Road 15) and Lofton Avenue (County Road 1). Both Manning and Lofton are paved. The haul road from Manning Avenue is paved through the site to the hot-mix asphalt plant and loading area. Annual Activity 2019 Activity. The application generally includes the data required by the ordinance regarding annual activity on the site, as follows: ___2019 2018 ___ The amount of material removed from the site: 425,000 Tons 445,000 Tons Amount of add-rock brought onto the site: 60,500 Tons 110,520 Tons Recycled asphalt and concrete brought to the site: 50,000 Tons 50,000 CY Average number of trips to and from the site each day: 214 Trips/day 242 Trips/day 2020 Activity. The 2020 application anticipates that mining and processing will continue at the site in 2020. The level of activity will depend on market demand for the site products. The Site Plan identifies the Potential Mining Areas for 2020, which are within the approved mining limits. Reclamation: Ongoing reclamation activities are anticipated in the southern portion of the Site, immediately north and west of the common mining border and within the east half of the mining area, south of the common mining border during 2020. These areas are shown on Figure 2, Site Plan as 2020 Potential Reclamation Activity. Some of the areas shown as potential reclamation will also see active mining during 2020. Once mining is complete, reclamation may advance into these areas during 2020. Ground Water Monitoring Plan and Monitoring Issues The approved Groundwater Monitoring Plan for the site is on file at the City. The City’s groundwater consultant, LRE Water, reviews the ground water monitoring results each year for the AOP and provides comments to the City. Groundwater Quality Analysis Based on 2019 Monitoring Data LRE Water has reviewed the groundwater monitoring data provided by Sunde for Tiller’s 2020 AOP Application. We do not see any concerns with the 2020 application as it relates to groundwater quality and quantity. Tiller’s Scandia Site (Manning Ave.) - 2019 Groundwater Monitoring Data Review Comments • The 2019 groundwater monitoring was completed in accordance with the approved monitoring plan; • Diesel Range Organic (DRO) were not detected above the method detection limit in any of the groundwater samples collected from the wells in Sept 2019. These results and the other groundwater chemistry results indicate no groundwater quality concerns; Scandia City Council Tiller Scandia Mine 2020 AOP Page 8 February 18, 2020 • Groundwater flow direction across the site is generally to the north and consistent with previous submittals; and, • Groundwater levels across the site have continued to rise since about 2014, and level are 3 to 4 feet higher than they were in 2008. This increase is the result of local and regional water table fluctuations unrelated to mining operations. LRE Water Recommendation and Comments Figure 2 of Sunde’s AOP Application shows a second area where excavation has gone into the groundwater (see attached). If Tiller plans for this area to remain as a groundwater-fed lake at the completion of reclamation, the proposed area of the lake shown on Figure 3 should be revised to include this area that has been excavated. There are no concerns with this second area since it is located within the area that was proposed in the original mining plan as a future lake. Tiller should continue to observe groundwater levels during the year. If levels continue to rise, there is the potential for the water table surface to be above the depth of the excavation and outside of the limits of the proposed lake. If this occurs, maps submitted in 2020 for the 2021 AOP should identify the general areas where excavation depth is below the water table. Setbacks The AOP application indicates that the minimum setbacks are maintained as follows: • 50 feet from the adjoining property line • 200 feet from an existing occupied structure • 100 feet from residential property boundaries of 5 acres or less • 100 feet from any road right-of-way The setbacks meet the requirements of Ordinance No. 103. City inspection during 2019 indicated that the setbacks were maintained and meet City requirements. Fencing The application indicates that the majority of the site is fenced with 3-strand wire fencing, except where prohibited due to topography, heavy vegetation and wetlands. There are locking metal gates at both entrances. The fencing meets the intent of the City’s Ordinance. City staff reviewed the fencing during the site visit on November 5, 2019, and verified that it meets the requirements of the Ordinance and CUP. Hours of Operation The site is operated from 7 a.m. to 7 p.m. Monday through Friday, except holidays. The applicant is required to obtain the City’s permission for any extended hours in accordance with procedures set in Ordinance No. 103, Section 7.1(3): Scandia City Council Tiller Scandia Mine 2020 AOP Page 9 February 18, 2020 “(3) Hours of Operation. Those portions of the mining operation consisting of excavating, stockpiling, processing, or hauling shall be conducted only between the hours of 7:00 a.m. and 7:00 p.m., Monday through Friday, unless other hours or days of operation are specifically authorized by the City.” Tiller requested, and the City approved, extended hours one time in 2019, for operation of the asphalt plant on a Saturday to meet the needs of a Chisago Lakes community center project. In 2018, the city granted extended hours on 14 occasions. Requests for extended hours vary from year to year, depending on projects and weather. Screening and Berms The mine is screened from surrounding areas by berms, wooded areas, and agricultural fields. The operator planted a large numbers of trees over the years of mine operation to augment the screening. Processing and stockpiling operations are conducted in recessed portions of the site to minimize visibility. Dust Control Major haul roads are hard-surfaced or covered with asphalt millings as dust control measures. The application indicated that Tiller used a water truck to control dust on unpaved portions of the site, and calcium chloride was applied to minimize dust generated by trucking activity. The applicant indicated that these actions were implemented in 2019 and will be continued as needed in 2020. The CUP does not require additional dust control efforts. Noise The Applicant must comply with all Federal, State, and City noise standards. Depth of Excavation The CUP requires that the depth of excavation shall not exceed fifty feet below the water table (865 feet above mean sea level) on the Scandia Mine site and may not be lower than 922 feet above mean sea level (amsl) on the former Dresel Mine site. In 2019, excavation into the groundwater table occurred to a depth of 906 feet amsl on the Scandia Mine site, to obtain material needed to meet the gradation requirements of the final products. This excavation level is above the 865 feet amsl allowed on that site. Excavation into the groundwater table is likely to occur in 2020 based on availability of equipment. Water level data is collected on an on-going basis and submitted annually to the City (see Table 1). Site Clearance Site clearing did not occur in 2019 but may occur within the areas identified on the site plan for Potential Mining Activity in 2020. The areas are within the permitted mining limits. Appearance/Condition The City’s site inspection in 2019 confirmed that the site and facilities are maintained in a neat condition. Scandia City Council Tiller Scandia Mine 2020 AOP Page 10 February 18, 2020 Sanitary Facilities The application indicates that the site is served by individual sanitary facilities that meet the requirements of the City’s Ordinance and the Mine Safety and Health Administration. City staff inspection confirmed that the City’s requirements were met in 2019. Waste Disposal The application indicates that waste generated by the operation is disposed of in accordance with Federal, State and City requirements. The City’s site visit in 2019 confirmed that the Applicant is meeting the requirements of the CUP. Water Quality Monitoring Plan The CUP required that Tiller Corporation complete a plan for groundwater monitoring within 60 days of approval of the CUP (July 20, 2008). The approved ground water monitoring plan was completed and is on file at the City. Tiller submitted monitoring results for 2019 with its application for the 2020 AOP. LRE Water reviewed the ground water monitoring activities and found that no DRO (diesel range organics) were detected in the samples in 2019. Fuel and Chemical Storage The application describes fuel and chemical storage at the site. The applicant notes that these materials are stored in accord with Federal and State standards and County requirements. On- site fuel storage consists of a 200-gallon above-ground storage tank which is located within a steel secondary containment area and a 1,000-gallon above-ground double walled tank located next to the standby electrical generator. When processing and/or reclamation crews are present, an additional 1,000-gallon double walled tank is brought to the site and used to fuel the respective equipment. All asphalt cement storage tanks are above-ground. These tanks consist of two 40,000 gallon tanks and two 32,000 gallon tanks. There is also a 20,000 gallon above-ground used oil storage tank. The used oil is utilized as an alternative fuel supply for the asphalt plant. All tanks containing asphalt cement and used oil are located within a concrete secondary containment area. All tanks are registered with MPCA’s Storage Tank Program. MPCA Site ID 51999 is for the asphalt plant and MPCA Site ID 55016 is for the sand and gravel operation. City staff reviewed the facilities with Tiller staff at the 2019 site visit. Small amounts of chemicals utilized by the QM Lab are regulated by Washington County under United States Environmental Protection Agency (EPA) rules. EPA ID Number MND 981 953 417 has been issued for the site which is classified as a Very Small Quantity Generator. Contingency Response Plan The application indicates that the site operates under a Spill Prevention, Control and Countermeasure Plan (SPCC) Plan that was submitted and is on file at the City. The applicant notes that the mine operator will comply with other such reasonable requirements that the City may find necessary to adopt for the protection of health, safety and welfare and/or prevention of nuisance. Scandia City Council Tiller Scandia Mine 2020 AOP Page 11 February 18, 2020 Processing The CUP application describes the operation of permanent processing equipment on the site and indicates that the equipment is operated in accordance with Federal, State and City air quality, water quality and noise standards. The equipment is screened from view from other properties and adjacent roads. The CUP requires that the asphalt plant and related structures be set back at least 100 feet from the shore of the proposed lake on the site. The site visit in 2019 verified that the processing facilities meet the setback requirements of the CUP, and no violations of permits were reported in 2019. Recycling Recycling at the site is permitted by Ordinance 103. Asphalt production used approximately 50,000 tons of RAP in 2019. Processed RAP is used in asphalt production and recycled concrete is sold in various aggregate products. A Solid Waste Storage Facility license that authorizes the storage of unprocessed concrete, concrete products and brick and a Recycling Facility license that authorizes the storage and processing of recycled asphalt products are issued to Tiller by Washington County. General and Specific Conditions are established for each license and are reviewed on an annual basis and may include an annual inspection completed by the County. Trucking Operations The application indicates that the site has access to County Road 15 (Manning Trail N.), County Road 91 (Lofton Avenue N.) and 218th Street North. These are hard-surfaced roads. The operator reported that the average number of trucks travelling to and from the site per day in 2018 was approximately 214 trucks per day. The Planner’s proposed conditions for the trucking activities at Scandia Mine 2020 AOP are the same as those included in previous AOP’s and require that Tiller inform all contractors about the following requirements related to trucking operations, and monitor compliance with the requirements by all of its contractors: • Engine braking is prohibited in Scandia • Lofton Avenue is restricted to daytime use only • Loads are required to be covered Asphalt Plant The site operates a permanent hot-mix asphalt plant that was in operation at the time the City adopted its mining ordinance. The plant operates under an air quality permit issued by the MPCA and must meet federal, state and city air, water and noise standards. The City received no complaints regarding the operation of the asphalt plant in 2019. Reclamation Plan Section 8.4 of the City’s Mining ordinance requires the following for reclamation areas: • All banks must be graded or backfilled; • Graded or backfilled areas shall be surfaced with soil of a quality at least equal to the topsoil of areas immediately surrounding, to a depth at least four inches; Scandia City Council Tiller Scandia Mine 2020 AOP Page 12 February 18, 2020 • The topsoil shall be planted with trees, shrubs, legumes or grasses • Slopes shall not be steeper than 4:1 Section 8.2 of Ordinance 103 requires the “restoration shall proceed concurrently and proportional to actual mining operations and will be subject to review and approval at each annual inspection and at the end of the permit period.” This section is included in the ordinance to ensure that: • Large areas of the site are not left in an un-reclaimed state, encouraging erosion, dust and weed establishment • The mining operation is making an ongoing investment in reclamation, to avoid potential problems that may occur at the end of the mining operation if a large investment is needed in reclamation, and the applicant’s resources are limited at that point, or the applicant abandons the site. Area reclaimed and type of reclamation: Reclamation activities in 2019 included placement of overburden and suitable fill material in the west half of the mining area, south of the Scandia Mine/Dresel Mine common mining border. The completed and ongoing reclamation areas are indicated on Figure 2, Site Plan. Ongoing reclamation activities are anticipated in the southern portion of the Site, immediately north and west of the common mining border and within the east half of the mining area, south of the common mining border during 2020. These areas are shown on Figure 2, Site Plan as 2020 Potential Reclamation Activity. Some of the areas shown as potential reclamation will also see active mining during 2020. Once mining is complete, reclamation may advance into these areas during 2020. The reclamation completed meets the requirement of the CUP. Watershed District Comments The Carnelian-Marine-St. Croix Watershed District reviewed the 2020 AOP application and has no concerns. The CMSCWD permit runs until completion of mine activities, with some exceptions as identified in the permit. The permit requires the applicant to complete the following activities on an annual basis: 1. Provide a copy of the annual AOP performance submittals for the City of Scandia, to the watershed for review. 2. Coordinate a site inspection by the CMSCWD Administrator 3. Reimburse CMSCWD for all expenses associated with implementation of the permit. SITE INSPECTION City staff completed a site visit to the Tiller Corporation Scandia Mining Operation on November 5, 2019, including documenting conditions on the site. The site visit reviewed 2019 activities and site conditions based on the CUP and 2019 AOP and discussed expected activity in 2020. Scandia City Council Tiller Scandia Mine 2020 AOP Page 13 February 18, 2020 ACTION REQUESTED: The City Council can: 1. Approve the AOP; 2. Approve the AOP with conditions; 3. Deny the application if it is found that the request is not consistent with the Comprehensive Plan, CUP, AOP Criteria, and Mining Ordinance, and is not in the best interest of the community; 4. Table the request if the Council needs additional information to make its decision. PLANNING STAFF RECOMMENDATIONS: The Planner recommends approval of the Tiller Corporation 2020 AOP for sand and gravel mining and related processing at the Scandia Mine, 22303 Manning Avenue North, with the following conditions: 1. The applicant shall comply with the conditions of the Conditional Use Permit for sand and gravel mining and processing at the Scandia Mine site approved on May 20, 2008. 2. The applicant shall comply with site operation hours of 7 a.m. to 7 p.m. Monday through Friday, except holidays, unless the applicant requests and receives the City’s permission for extended hours in accordance with procedures set forth in Ordinance No. 103. 3. The applicant shall continue to observe groundwater levels during the year. If levels continue to rise, there is the potential for the water table surface to be above the depth of the excavation and outside of the limits of the proposed lake. If this occurs, maps submitted in 2020 for the 2021 AOP shall identify the general areas where excavation depth is below the water table. 4. The applicant shall provide the approximate depth of the excavation below the water table in future annual reports to confirm the excavation did not go below the 865.87 feet amsl threshold. 5. The applicant shall continue to provide the production well records for the site to the City so the pumping records can be compared to past and future groundwater level trends at the site. The applicant should measure the water level in the production well under non-pumping conditions during monitoring periods. 6. Requests for operating hours or haul routes outside those specified in the Conditional Use Permit shall be accompanied by a proposed truck haul route for approval by staff. 7. The applicant shall inform its contractors about the following requirements related to trucking operations, and monitor compliance with the requirements by all of its contractors: • Engine braking is prohibited in Scandia • Lofton Avenue is restricted to daytime use only • Haul loads are required to be covered Scandia City Council Tiller Scandia Mine 2020 AOP Page 14 February 18, 2020 8. The applicant shall regularly monitor the entrances and exits to the site, and work with their hauling contractors and truck drivers to maintain compliance with traffic laws. 9. The Reclamation activities shall meet the requirements of the Conditional Use Permit, including soil and planting requirements. 10. If the applicant has knowledge that a crash or traffic violation occurs involving a truck hauling for Tiller, Tiller shall contact the City to report the incident immediately. The applicant shall report actions it will take to respond to the incident. 11. The applicant shall pay all fees and escrows associated with this application. 12. This Annual Operating Permit shall expire on March 31, 2021. ACTION REQUESTED: Staff request that the Council review this report and approve the AOP at the meeting on February 18, 2020.