5.1. PCSR 10-13-2009 - Laserfiche WebLink

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Rebecca Haug City of Elk River October 6, ?009 Page 2 Emissions testing data was compared to historical levels and to existing permit requirements. Emission parameters analyzed included dioxins and furans, hydrochloric acid (HCL), particulate matter, nitrogen oxides (NOX), sulfur dioxide (SOZ), carbon monoxide (CO) and ten metals. Certain parameters such as CO and NOX were reduced and most showed no significant change from historical operations. Two parameters were higher than typical past operations. These were zinc and sulfur dioxide. Both zinc and sulfur are present in TDF in higher concentrations than RDF. Zinc emissions are currently not regulated by MPCA. Further MPCA current air emission risk assessment program does not establish a toxicity factor for zinc. The SOZ emissions, while higher than for historical 100% RDF firing, were below the permitted emission rate. SOZ is currently monitored by GRE using a continuous emissions monitor, which is calibrated every day. Using CEM data, the plant operators can adjust the TDF feed rate to control any SOz exceedance issues. In conclusion, some predicted emission increases and reductions from historical emissions levels were recorded during the TDF test burn. None of the increases reached permitted limits. State-of--the-art controls and emissions monitoring devices are available to the GRE operational staff. Based on the test burn ash and emissions analytical data, the proposed TDF feed rate, current air emission permit and emissions monitoring system in place at the Elk River Station, Liesch finds no technical reason to deny the CUP request to co-fire TDF with RDF. Should you have any questions, please contact me. Thank you. Sincerely, LIESCH ASSOCIATES, INC. ~~~~~ ~. ohn Lichter, P.E. Environmental Engineer w:\env\648]3\gre tdf review ltr 10 O1 09.doc www.liesch.com THE LIESCH COMPANIES ^ MINNEAPOLIS ^ CHICAGO ^ LOS ANGELES ^ MADISON ^ MILWAUKEE ^ PHOENIX