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Solid & Hazardous Waste Bureau 
(406) 444-2821 


DEC 2 9 13.7 

December 16, 1987 

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Re: Preliminary Environmental Review 

City-County Sanitation Service 
Class II Landfill 

Donna Tenneson, President, City-County Sanitation Service, 3630 York 
Road, Helena, MT 59601 

Doug Kuntzweiler, M.D., Health Officer, Jefferson County, Box 28 
Boulder, MT 59632 

Jefferson County Commissioners, P.0. Box H, Boulder, MT 59632 
Lewis Sc Clark County Commissioners, 316 North Park, Helena, MT 59623 
Robert Johnson, Health Officer, Lewis Sc Clark County Health Department 
316 North Park, Helena, MT 59623 

Kathy Macefield, Co-Chairman, City-County Solid Waste Study Committee, 
City of Helena, 316 North Park, Helena, MT 59623 
Bob Rasmussen, Co-Chairman, City-County Solid Waste Study Committee 
City of Helena, 316 North Park, Helena, MT 59623 
Document Section, State Library, Capitol Complex, Helena, MT 59620 
Environmental Quality Council, Capitol Complex, Helena, MT 59620 
Tom Ellerhof , Environmental Sciences Division, MDHES, Helena, MT 59620 
Montana Historical Society, 225 North Roberts, Helena, MT 59620 

M °° re ’ May ° r ’ City ° f EaSt Helena > P -°- Box E, East Helena, MT 

Ladies and Gentlemen: 

Pursuant to the Administrative Rules of Montana, 16.2.604, the following 
Prelimrnapr Environmental Review has been prepared by the Department of 
Health and Environmental Sciences concerning the proposed City-County 
Sanitation Service Class II Landfill. 

The purpose of the preliminary Environmental Review is to inform all 
interested governmental agencies, public groups, or individuals of the 
proposed action and to determine whether or not the action may have a 
significant effect on the environment. This Preliminary Environmental 
Review will be circulated for a period of fifteen (15) days at which time 
a decision will be made as to our future action. 



If you care to comment on this proposed action, please do so within the 
allotted time. Your comments can be sent to me in care of the Depart- 
ment of Health and Environmental Sciences, Solid & Hazardous Waste 
Bureau, Capitol Station, Helena, MT 59620. 

Sincerely , 

James E. Leiter, R.S. 

Solid & Hazardous Waste Bureau 

Enc losure 


Cogswell Building, Helena, Montana 59601 
(406) 444-2821 



Division/Bureau Environmental Sciences Division/Solid & Hazardous Waste Bureau 

Project or Application City-County Sanitation Service Class II Landfill 

Description of Project City-County Sanitation Service, 3630 York Road, Helena, Montana, 

has made application for a Class II Solid Waste Management System License for a proposed 

landfill located in the north \ Southeast \ Section 6, Township 9 North, Range 2 West, 

Jp f f er aon County. Montana. The facility will be generally located 1.4 miles south of the 

community of East Helena off Highway 518. Poten tial impacts are described on the report 
attached. A complete copy of the license ap plication is available for review in the 
offices of the bureau. Copies of the application may be obtained by requesting a copy in 
writing or by visiting the office . 

1 . Terrestrial & aquatic 
life and habitats 

2. Water quality, quantity 
and distribution 

3. Geology & soil quality, 
stability and moisture 

4. Vegetation cover, quant 
ity and quality 

5. Aesthetics 

6. Air quality 

7. Unique, endangered, 
fragile, or limited 
environmental resources 

8. Demands on environmen- 
tal resources of land, 
water, air & energy 

9. Historical and archaeo- 
logical sites 


u • „ . . Comments on 

Major Moderate Minor None Unknown Attached Pages 




















1. Social structures and 

2. Cultural uniqueness 
and diversity 

3. Local and state tax 
base & tax revenue 

4. Agricultural or in- 
dustrial production 

5. Human health 

6. Quantity and distri 
bution of community 
and personal income 

7. Access to and quality 
of recreational and 
wilderness activities 

8. Quantity and distri- 
bution of employment 

9. Distribution and 
density of population 
and housing 

10. Demands for govern- 
ment services 

11. Industrial & commer- 
cial activity 

12. Demands for energy 

13. Locally adopted en- 
vironmental plans & 

14. Transportation net- 
works & traffic flows 

Major Moderate Minor 





Comments on 

None Unknown Attached Pages 

















Other groups or agencies contacted or 

Which may have overlapping jurisdiction Jefferson County Health Officer and Sanitarian 

Individuals or groups contributing to this PER. 

Recommendation concerning preparation of EIS No eis Nece 


PER Prepared by: James E. L eiter, R.S. 

8s te : December 16, 1987 



City-County Sanitation Service 
Class II Sanitary Landfill 
Jefferson County, Montana 

Donna Tenneson, President, City-County Sanitation Service, 3630 York Road, 
Helena, Montana 59601, has filed application for a solid waste management 
system license for a sanitary landfill proposed for the north edge of 
Jefferson County, near the community of East Helena. The company is 
purchasing 140 acres of land located in the North \ of the Southeast £ of 
Section 6, Township 9 North, Range 2 West. Approximately 80 acres of land 
is intended for use as a solid waste disposal facility. The applicant has 
requested licensing for the entire usable portion of the parcel. The 
Department will negotiate actual licensed area with the applicant, depending 
upon the portion of the area addressed in the hydrogeological portion of the 
application. Currently, we expect to license a twenty to sixty acre parcel 
in the eastern portion of the property. 

The proposed landfill is intended for use by the owner/operator only for the 
wastes the firm collects in the process of operating a private waste 
collection service in Lewis and Clark and Jefferson Counties. The business 
services both commercial and residential customers. The landfill would be 
licensed as a Class II facility, able to handle Group II (household and 
commercial) and Group III (demolition waste, tires, rock, earth and other 
inert waste materials). The landfill is not proposed as a facility open for 
public use. 

Access to the facility would be from Highway 518, with private and on-site 
roadways to the active portion of the fill. 

The applicant has retained the services of several local consulting firms to 
assist with the hydrogeological evaluation of the site, the completion of 
the application itself and an operation and maintenance plan for the 
landfill . 

Waste brought to the facility would be buried at the site in accordance with 
current operating requirements for sanitary landfills found in Section 75- 
10-201 through 75-10-233, MCA, and Sections 16.14.501 through 16.14.608 
A.R.M. The facility will be inspected and regulated by this bureau and the 
Jefferson County Health Officer and Sanitarian. 

In review of the application, the Department finds the following potential 
impacts from the site: 


1. Terrestrial and Aquatic Life and Habitats - Operation of the landfill at 
the site will displace some small species of insect and mammal life. Since 
the surrounding area consists of very similar habitat types, these species 
will very likely relocate to adjacent areas without actually being reduced 
in total populations to any significant degree. 

2. Water Quality, Quantity and Distribution - The landfill appears to be 
located in an area which will provide good protection to groundwater 
aquifers beneath and adjacent to the site. The plan for the site includes a 
thorough hydrogeological investigation. All potential pathways for 
contamination are to be monitored with wells and ongoing ground and surface 
water monitoring. Given the current climactic setting and hydrogeological 
regime, the site is not expected to have any influence on groundwater 
quality, quantity or distribution. 

3. Geology and Soil Quality, Stability and Moisture - Landfilling 
commercial and residential wastes has a long term effect on soil quality, 
stability and moisture holding capability. Once in place, the waste will 
slowly settle, allowing some subsidence of the surface. Upon completion in 
any area, the site will be reclaimed with a final cover of earth. The 
applicant proposes to use a four foot earthen cover over the buried waste, 
an d to revegetate the surface so that it can be placed back into use as 
active agricultural ground. 

4. Vegetation cover, quantity and quality - As each area is landfilled, 
there will be some disturbance of vegetative cover in the areas being 
worked. Since the applicant intends to return the land to agricultural use 
a ^ter it is filled, the areas finished will be completed and revegetated in 
phases. This should reduce the amount of vegetative cover lost at any one 
time. If the landfill is returned to active agricultural use, the types of 
vegetation should be basically the same as before the site's use as a 
landfill . 

5. Aesthetics - No landfill is ever operated without some effect upon 
aesthetics. Properly operated, these effects can be minimal and the impact 
can be confined to the immediate landfill site. The particular site chosen 
is largely shielded from public view by the natural terrain of the area. In 
addition, the majority of the landfill operation will be below natural 
grade. this will further protect the visual aesthetics of the area. The 
majority of the potential problem will be in litter control, since the site 
sits on the upper reaches of a high drainage at the southeast edge of the 
Helena Valley. The operator has proposed several kinds of litter fencing 
and daily application of soil cover to control the litter. There are no 
residences or public roadways downwind of the site, so any impact if litter 
should escape would be minimal. 

6. Air Quality - Class II landfill facilities frequently obtain open 
burning permits to burn untreated wood waste at landfills. While this is 
not specifically addressed in the application, the landfill could obtain 
these permits at some time in the future. Since there are few residences 
even close to the fill, the impact from any such burn should be negligible. 
Other materials may not be burned at landfills. 

9. Historical and Archaeological Sites - The proposed landfill will be 
located approximately two thirds of a mile from the Kleffner Ranch, which 
has recently been considered by the State of Montana as a state historical 
site, but as yet, is undeveloped as such. The only impact from the landfill 
to the Kleffner site would be the shared access highway to the ranch and to 


the landfill. Some refuse vehicles would be evident. It is unlikely there 
would be other potential impact. 


4. Agricultural or Industrial Production - Landfilling will remove small 
portions of the site from agricultural usage for short periods of time. Due 
to the general shortage of solid waste management alternatives to landfills, 
however, the potential life of the landfill is very long. Overall, the 
impact on agricultural production should be minimal, especially if portions 
of the fill are returned to farm use upon completion of each phase of the 

10. Demands for Government Services - The new landfill will require some 
additional use of government services, particularly those of the bureau and 
the Jefferson County Sanitarian for inspection and regulation. Time spent 
would normally be minimal. 

12. Demands for Energy - Operation of the landfill will cause some increase 
in the general consumption of fossil fuels. Since the increase will be 
coupled with a small decrease at other area landfills, there will only be a 
very minor overall change. 

11. Industrial and Commercial Activity - Truck traffic to the site and some 
equipment operation to maintain the site will add some commercial activity 
in an area which is principally agricultural. Due to the proximity of the 
ASARCO Smelter, American Chemet, and some other adjacent commercial 
enterprises, however, the increase should be insignificant. 

13. Locally Adopted Environmental Plans and Goals - The City of Helena and 
Lewis and Clark County have a solid waste study committee which has been 
investigating solid waste plans for the area over a several year period. 
The current emphasis of this committee has been to work with a consultant to 
site a new, city-county landfill site. Since City-County Sanitation Service 
is the only private hauler in the area, removal of the waste being handled 
by the private waste firm could affect the plans of the committee slightly. 
The current two landfill sites could last slightly longer and some 
adjustments to proposed waste quantities for any new city-county landfill 
site might be in order. 

14. Transportation Networks and Traffic Flows - See it 11.