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Mr. Steven Rohlf • November 22, 1995 - Page 2 Other Information a. Emission Testing The two air emission tests conducted since our last application were completed in February of 1995 and June of 1994. Both of these tests were reported as required to the City of Elk River and to the Minnesota Pollution Control Agency (MPCA). As has been that case with previous tests, these two test showed that the facility is in compliance with MPCA air emission limits. b. New Regulations In June of 1994, the MPCA promulgated new Standards of Performance for Municipal Waste Combustors. In addition, the U.S. Environmental Protection Agency (EPA) is currently promulgating emission guidelines for Existing Municipal Waste Combustors. (We understand that these guidelines will be published as final in the Federal Register in the very near future). These new guidelines are at 40CFR part 60, subpart Cb (the less stringent subpart Ca guidelines promulgated in February of 1991 are rescinded). The time frame for implementation of these new requirements is not clear at this time. We understand that the states will have some time to bring their own programs in line with these new Federal guidelines. UPA will be meeting next month with the MPCA to determine the implementation schedule for ERS. We anticipate that the deadline for meeting the new limits will be pushed beyond the June 1997 date previously established by the state regulations. We have known for some time that we may not meet the pending new limitations with the plant as it presently exists. We have been monitoring the changing requirements and we are planning for continued compliance. The primary feature of our compliance efforts will be modifications in the fuel feed system. This will allow tighter control of carbon monoxide (CO) so that we can meet the new 200 ppm CO limitation. After implementing this change, we will be in a better position to determine what other changes may be needed to meet the other tighter standards such as for sulfur dioxide (SO2) and nitrogen oxides (NOx). On the other hand, the actual emissions of heavy metals and dioxins/furans are very low. Emissions of these pollutants are well under the strictest standards, i.e. below the standards mandated by the above-mentioned, new guidelines from EPA. c. Exceedances of Air Emission Limitations We have experienced occasional exceedances of the CO and HCI limitations as shown in the table below. Exceedances have been less prevalent in recent years due to our operations efforts and increased experience. There have been no exceedances of the several other air emission limitations. Numbers of Exceedances Year CO HCI 1990 22 2 1991 14 9 1992 5 1 1993 1 0 • 1994 6 2 1995 to date 5 0