6.3. ERMUSR 10-09-2007 - Laserfiche WebLink

Home Browse Search

Adams, Bryan From: Paul Taylor [ptaylor@barr.com] Sent: Tuesday, September 04, 2007 4:46 PM To: Walters, Debra; Adams, Bryan Cc: Stolz, Stephanie; Ken.Kruszynski@shawgrp.com Subject: Elk River Landfill: Implications for Routing LFG from High H2S Wells to Existing Flare Sensitivity: Confidential DebBryan: Following up on our phone call this morning, you had prompted me to check whether there is a SO2 limit on ERL's flare that would be in danger of being exceeded by the proposed routing of LFG from high H2S wells to the existing flare. I checked ERL's current permit and there is no such limit. However, there is a 0.5 Ib/MM Btu limit on each engine. This raises the question of whether this limit is being exceeded by the current operation. Based on the individual well flow rates that you provided during my 5/11/07site visit and the H2S measurements made in June (using Draeger tubes for 7 high H2S wells and canister results from one of these wells), I calculate that the SO2 emissions from the LFG collected from all wells and fed to the engines averages out to be 0.3 lb/MM Btu, below the 0.5 Ib/MM Btu limit. In other words, there appears to be sufficient low H2S LFG to offset the high H2S wells such that the SO2 limit on each engine will not be exceeded. It should also be noted that the permit does not require testing of SO2 emissions from the engines provided they only combust LFG. Using the same data, I estimate that the 7 high H2S wells would produce 74 tons SO2/yr assuming complete combustion of the H2S while the other wells would collectively produce an additional 6 tons/yr. It's not clear how the MPCA would view these high SO2 emissions but there's a good chance that they will be concerned about them (the permit does not require SO2 testing for the engines because it is assumed that SO2 emissions will be low from combusting LFG). Stephanie provided a spreadsheet this afternoon that included H2S and flow data from March 2007 and some H2S data for selected wells in May/June and August 2007. The latter included H2S data from 2 high H2S wells (EW-23 and EW-43) that were not known to me previously. Stephanie has promised to send more comprehensive H2S and flow data that will allow me to refine the calculations presented above. Ken: I believe it was your colleague (another Ken!) who called me last Friday to discuss the air permitting implications of routing the high H2S wells to the existing flare. Could you please forward this a-mail to him and ask that he send me his contact details for the future. Thanks. Paul Taylor Air Quality Engineer Barr Engineering Company 4700 West 77th Street Minneapolis, MN 55435-4803 Tel: 952-832-2671 (direct) Fax:952-832-2601 e-mail: ptaylor~a,barr.com This e-mail and files transmi[ted with it are the property of Barr Engineering Company, are confidential and are intended solely for the use of the individual or entity to whom this e-mail is addressed. /jyou are not one of the named recipients or believe tha[ you have received this message in error, please nat~ the sender and delete [his message from your computer. Any other use, retention, dissemination, forwarding, printing or copying of this e-mail is prohibited.