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Letter To:Mr.Stephen Rohlf,Building&Zoning Administrator,City of Elk River November 30,1993 <br /> Re: ERS Solid Waste Facility License and Conditional User Permit#87-10 Applications renewal <br /> The following additional information may also be of interest. <br /> 1111 a. Emissions Testing <br /> The most recent emissions test(stack test) was completed in November of <br /> 1992. Results of that testing were reported to the MPCA and to the City <br /> of Elk River. As has been the case with previous emissions testing, ERS <br /> was shown to be well below the established emission standards. Refer to <br /> attached March 9, 1993 letter. <br /> Mercury was the only one of the eight metals tested. There presently are <br /> no emission limitations for mercury or the other metals. However, one is <br /> being proposed for mercury. <br /> The measured emission rate for mercury was approximately 16 times less <br /> than the standard proposed in the current MPCA rule-making. At its <br /> March 15, 1993 meeting, the Elk River City Council waived the <br /> requirement to analyze for the seven other metals in November 1992 with <br /> the understanding that the complete series will be done in the next emission <br /> test in early 1994. <br /> The next emissions test is being planned for February of 1994. As with <br /> prior emission tests, UPA will notify the City of the results. With the <br /> • completion of this planned emission test, we will have completed emissions <br /> testing in all four seasons. <br /> b. Proposed New Municipal Waste Combustor Regulations <br /> The Minnesota Pollution Control Agency (MPCA) is in the process of <br /> promulgating new municipal waste combustor regulations. UPA <br /> anticipates that these regulations will be finalized in 1994 and will then be <br /> making application for re-issuance of the permit. There may be some plant <br /> modifications needed to meet anticipated stricter emission limitations such <br /> as a new sulfur dioxide (SO2)emission limitation. There is no SO2 <br /> emission limitation currently in place. However, ERS emits SO2 at a very <br /> low rate relative to the rates of other power plants. <br /> c. The following parameters are limited by the MPCA and are monitored to <br /> demonstrate compliance: particulate matter, PCDD/PCDF, hydrogen <br /> chloride gas (HC1), carbon monoxide (CO), and opacity. ERS continues to <br /> operate well within the established emission limits. However, ERS has <br /> experienced exceedances of HC1 and CO gases especially in the first several <br /> years since beginning commercial operation in August of 1989. Such <br /> occasional exceedances are due to equipment failures and excessive fuel <br /> variability. The numbers of exceedances have been reduced in the last <br /> • <br /> 2 of 3 <br />