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_ _ <br /> LIEXH <br /> B.A.LIESCH ASSOCIATES, INC. 13400 15TH AVE.N. MINNEAPOLIS, MN 55441 612/559-1423 FAX:612/559-2202 <br /> MEMORANDUM <br /> TO: STEVEN ROHLF - CITY OF ELK RIVER <br /> FROM: JOHN LICHTER - B.A. LIESCH ASSOCIATES, INC. <br /> DATE: DECEMBER 20, 1993 <br /> RE: RENEWAL OF UNITED POWER ASSOCIATION CONDITIONAL <br /> USE PERMIT <br /> Based on our recent telephone conversation, I have taken a look at several issues with <br /> regard the Conditional Use Permit renewal request forwarded by United Power <br /> • Association (UPA). The attached table indicates the impact of the new waste combustor <br /> rules on UPA. The regulated items are shown on the right hand column, the second <br /> column indicates the old standards for Class A incinerators which were taken from the <br /> State Register. The new standards shown are in the third column which also came from <br /> the Minnesota State Register. Federal guidelines for large municipal waste combustors <br /> are shown in the last column. These were taken from the Federal Register of February <br /> 11, 1991. Significant changes in emission standards include a drop in the carbon <br /> monoxide standards from 400 parts per million to 200 parts per million, opacity from <br /> 20% to 10%, the addition of a mercury standard of 30 micrograms per dry standard cubic <br /> meter or 85% removal and lowering of acid gas emissions on a parts per million basis. <br /> Comprehensive emissions testing has been accomplished by UPA on five separate <br /> occasions, in November 1989, March and May of 1990, August of 1991 , and in <br /> November of 1992. Another round of testing is scheduled for early 1994. At the <br /> completion of that test, all four seasons will have been tested by UPA. <br /> The second table enclosed illustrates RDF burned by UPA by month. The existing permit <br /> allows for 1 ,050 tons per day burned as a monthly average. In no case is this standard <br /> been exceeded. <br /> • Our analysis of all of the emissions data collected by date by UPA indicates compliance <br /> with all applicable standards at this time and likely compliance with all new standards <br /> proposed by the State and the Federal Government. <br />