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<br />e <br /> <br />e <br /> <br />e <br /> <br /> <br />Ute 2 ~ 1~:;3 <br /> <br />- <br />- <br />- <br />- <br /> <br />LIi:SJ:H <br /> <br />B.A. LIESCH ASSOCIATES, INC. 13400 15TH AVE. N. MINNEAPOLIS, MN 55441 612/559-1423 FAX: 612/559-2202 <br /> <br />MEMORANDUM <br /> <br />TO: <br /> <br />STEVEN ROHLF - CITY OF ELK RIVER <br /> <br />FROM: <br /> <br />JOHN LICHTER - B.A. LIESCH ASSOCIATES, INC. <br /> <br />DATE: <br /> <br />DECEMBER 20,1993 <br /> <br />RE: <br /> <br />RENEWAL OF UNITED POWER ASSOCIATION CONDITIONAL <br />USE PERMIT <br /> <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 (UP A). 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 /> <br />Comprehensive emissions testing has been accomplished by UP A 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 /> <br />The second table enclosed illustrates RDF burned by UP A by month. The existing permit <br />allows for 1,050 tons per day burned as a montWy average. In no case is this standard <br />been exceeded. <br /> <br />Our analysis of all of the emissions data collected by date by UP A 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 />