INFORMATION #1 05-11-2009INFORMATION
of
ver
MEMORANDUM
TO: Mayor & City Council
FROM: Rebecca Haug, Environmental Administrator
DATE: May 11, 2009
SUBJECT: Request by Great River Energy to Test Burn Tire Derived Fuel
Great River Energy has approached the City to request authorization to test burn Tire-
Derived Fuel (I'DF) at their Waste to Energy Plant in Elk River as a supplement to Refuse
Derived Fuel (RDF). TDF is processed (shredded) tires.
The reason for this request is the uncertainty of continued RDF due to the contract
negotiations between the counties who are currently providing RDF to the facility. Because
of this uncertainty, GRE is exploring alternative fuel options to ensure sufficient fuel will be
provided to the Waste to Energy Plant.
The test burn is amulti-phased process which GRE has detailed out in the attached letter
dated Apri128, 2009. The important thing to note is that they anticipate starting as early as
May 25, 2009 and completing the testing by October 31, 2009. The actual test burns are
expected to occur on less than 14 days during this period. The TDF will be stored in the
existing RDF receiving building. During the second phase, stack testing will be completed
to ensure that TDF combustion can be accomplished within the confines of the air emission
permit.
Under GRE's Air Emission Permit through the Minnesota Pollution Control Agency
(MPCA) they are allowed to burn an average of 100 tons of TDF per day. The current CUP
for GRE does not allow burning of TDF so if the test burn is successful, GRE anticipates
amending their CUP to allow the use of TDF as a supplement to RDF. Based on the
information provided, City staff and the City's Environmental Consultant, John Lichter,
Leisch and Associates, are comfortable with allowing GRE to test burn TDF.
GREAT RIVER
ENERGY®
12300 Elm Creek Boulevard • Maple Grove, Minnesota 55369-4718 • 763-445-5000 Fax 763-445-5050 • www.GreatRiverEnergy.com
Apri128, 2009
Ms. Rebecca Haug ~ ~^
Environmental Administrator ~ ~~~'
~~
City of Elk River °~~'
13065 Orono Parkway i o6' ~~
Elk River, MN 55330 ~ `~
Subject: Elk River Station -Waste to Energy Plant
Request to Test Burn Tire Derived Fuel
Dear Ms. Haug:
Great River Energy's Waste-to-Energy Plant in Elk River is looking at fuels to
supplement the Refuse Derived Fuel (RDF) that has served as the primary fuel source for
the plant in the last 20 years. We are planning to test burn tire-derived fuel (TDF) and
understand that the City of Elk River is interested in more information before issuing us
written approval to conduct the test burn under our existing Conditional Use Permit. This
letter provides a summary of the test burn and'the information you have requested. Of
note, our air emissions permit issued by the Minnesota Pollution Control Agency
currently allows us to burn an average of 100 tons of TDF per day. If after reading this
letter you need any additional information, please contact us.
Background
RDF has been provided to the Waste-to-Energy Plant by Resource Recovery
Technologies (RRT), also located in Elk River, which processes municipal solid waste
into RDF. The municipal solid waste is currently supplied to RRT by amulti-county
consortium under along-term contract that is scheduled to expire in August 2009. At this
time, Great River Energy believes that the counties and RRT may not be able to execute a
new contract that will guarantee sufficient fuel for our Waste-to-Energy Plant to continue
operating it at its rated capacity. Accordingly, we are investigating alternative fuels that
could supplement the RDF.
At this time, Great River Energy is seeking City approval only to conduct a TDF test
burn. If the test burn is successful, we would seek the City's approval to supplement the
RDF with TDF on a long-term basis. It is our intent to continue to use RDF as the
primary fuel at the plant and to only use TDF to supplement the RDF.
A Touchstone Energy Cooperative j~~i ( ~ Contains 100% post consumer waste
~-
Ms. Rebecca Haug
April 30 2009
Page 2 of 3
Details on the test burn
Great River Energy is proposing to conduct amulti-phase test burn. The first phase will
consist of an engineering feasibility study that will assess fuel handling issues, identify
fuel quality characteristics from multiple vendors that allow for efficient fuel combustion,
evaluate ash handling issues, and provide sufficient operational experience with the fuel
to enable a consistent four- to eight-hour test burn. The second phase will consist of
four- to eight-hour burns during which air emissions stack testing will be conducted and
ash samples will be collected for analysis. The second phase testing will provide
operational and environmental data that will be used to ensure that TDF combustion can
be accomplished within the confines of the air emissions permit on a long-term basis and
that the impacts on the ash do not adversely impact ash disposal options.
We anticipate up to 14 discrete days of test firing over the two phases, but if we find
significant fuel differences among vendors or if fuel handling is an issue, we may require
more days. Testing could start as early as May 25, 2009, and we anticipate completing
the test phases by October 31, 2009.
We are currently looking at three different possible fuel vendors. We may add other
vendors as our work progresses.
Fuel will be delivered to the site by semi trucks as processed (shredded) tires; we do not
anticipate shredding tires at the Elk River site for the test burn. Each semi-trailer is
expected to hold 15 to 20 tons of TDF. The TDF will be stored in the existing RDF
receiving building. On a long-term average, each TDF truck would replace
approximately three RDF trucks because TDF has a heating value approximately three
times greater than RDF (15,000 Btu/lb vs. 5,500 Btu/lb).
For the test burn, we would simply add the TDF to the RDF walking floor with the front
end loader. 'This requires minimal engineering and requires no additional capital
expenses for the test burn.
Over the two phases of the test, we anticipate burning between 300 and 600 tons of TDF.
Most of the testing will be conducted with TDF comprising 20 percent or less of the total
fuel on a mass basis (8 tons TDF with 21 tons of RDF per hour). We may also do some
testing at up to 80 percent TDF on a heat input basis.
Testing will be primarily conducted between the hours of 7:00 am and 5:00 pm, but we
may conduct some longer term overnight test runs.
During both burning phases, we will monitor stack emissions with our existing
continuous emissions monitoring systems (GEMS). During Phase 2, we will hire a third
party firm to conduct stack emissions testing for our routine list of analytical parameters.
The following table lists these analytical parameters and the method of measurement.
Ms. Rebecca Haug
April 30 2009
Page 3 of 3
Anal tical Parameter Test Method Phase 1 Phase 2
Carbon Monoxide (CO) CEMS X X
Oxides of Nitro en (NOx) GEMS X X
Sulfur Dioxide (SOZ) CEMS X X
Oxygen (Oz) CEMS X X
Particulate Matter (Dry + Organic Wet) Stack Test X
Hydro en Chloride (HCl -Outlet only) Stack Test X
Arsenic (As) Stack Test X
Beryllium (Be) Stack Test X
Cadmium (Cd) • Stack Test X
Chromium (Cr) Stack Test X
Lead (Pb) Stack Test X
Mercury (Hg) Stack Test X
Nickel (Ni) Stack Test X
Selenium (Se) Stack Test X
Dioxins Stack-Test X
If you have any questions, please contact Mark Strohfus at 763-445-5210 or
MStrohfus(a,GREener~y com.
Thank you for your considerations.
Sincerely,
GREAT RIVER ENERGY
Wayne Hanson
Manager, Minnesota Generation
c: Tim Steinbeck
Mark Strohfus