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Conditional Use Permit and Solid Waste Facility <br />Narrative <br />L.~e on-~ite_tan s. <br />The ERS facility has three bulk fuel oil tanks. Until recently, these tanks were empty and <br />unused since ~ 9~~ , As part of the construction of the peaking station, two of the tanks <br />were refurbished; one is used for fuel oil storage and the other is used for demineralized <br />water storage. The third tank remains sealed vtf and unused. The refurbished fuel oil <br />tank supplies backup fuel to ERS and the peaking station, The demineralized water is <br />used to control NOx emissions when the peaking station combustion turbine is firing fuel <br />oil, <br />3. Requested ~4rnendments <br />3.1. Alterr~ to Fuel escr~i ion Scope <br />GRE requests approval to cofire alternate fuels at Elk River station with RDF. The <br />alternate fuels will be limited to TDF, wood and waste wood, A single alternate fuel may <br />be cofired with the RDF or a combination of the alternate fuels maybe cofired with the <br />RDF. None ofthe proposed alternate fuels would be fired without concurrently firing <br />RDF, <br />The ERS will remain primarily a RDF~fired waste-to~energy facility. However, the <br />economics of the overall operations waste processing and waste combustion} are <br />negatively impacted by an overall Iow supply of municipal solid waste to feed the RDF <br />production plant or by short term interruptions in the municipal solid waste supply or <br />RDF supply. cofiring alternate fuels is being proposed as a potential opportunity to <br />maintain the overall economic viability of operating the waste to energy plant. Any <br />economic advantages of cofiring will be dependent an the actual cyst of any alternate <br />fuels and the impact of the alternate fuel on operating and maintenance costs, GRE has <br />begun to investigate fuel supply costs, but we cannot identity actual operating and <br />maintenance cost impacts without actually cofiring the materials over a period at time. <br />Our initial analyses suggest that the requested opportunity fuels after same promise for <br />cost savings, <br />The air emissions permit issued for the Elk River campus currently allows ERS to cofire <br />TDF at a rate at "less than or equal to ~ DD tonslday using ~a] 30-day rolling average" but <br />also "less than ar equal to 2DD tonslday using [a~ 24~hour block." It the City feels it is <br />necessary to also restrict the amount of TDF that is cofired, we request that these same <br />restrictions be used in the CUP, <br />The air emissions permit does not explicitly allow for ERS to burn any wood, However, <br />the air permit, in conjunction with Elk River Station's Industrial Solid Vllaste Management <br />Plan does allow ERS to burn "Excess wood chips from county projects," GRE will have <br />to obtain approval from the MPCA prior to cofiring any wood that is not currently <br />authorized by the permit and Industrial Solid waste Management Plan. <br />S.lLegallEnvironmer~tallERSlAirlCity of ER - Cand.UsePermit1~~09 Alt Fuels AmendmentlER CUP Amend Narrative <br />v~.dac <br />Page 3 of 4 <br />