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5. SPSR 09-09-2009,.r+ Wd ~0~6€~Z 600ZIZ/6'~'Mp'~~W ua!~e~©11d~J 62-60 fl~ld~l~lsa~id ase~l~NINN'dld1~S . ,::~ _ i ~. ~. ~; ~", - - ~._ ~ # ~ a ~, - - ~:. 'Yc ~ r 1 1 ~ 4 ~`~ ~ s q, ~'- w' t e, , ~ i - ~ ~~. ~ i jtr P :~j. ,~>~. ~ a t 1 r ~ _ ` ~ ~~ ',t ~_ ~ ~~~ ~~ ~ "'~ ~ '~ r 111VVVllI ^~.6 \ ~ a ~"~ ~\ ~ ~. ~, . a i~ ~ _ ~ ~ ~. ~~ ~ .,_ , , `~: ~ ' "~ . ~ : ~ ~~ .. ~. -~ z:~ t 11 gr _' ~ i ~~ ~.~ ~F a ~- P, _, _ ~ ,' ( ] .. _ C~ ~. ~ -~- ~_ ~ - ~,,~ ~~~ ~ _ ~~ + c.~~~~~ ~ .~~ ~- ~ •~ ~~ ~ ~ ~, - ' _r ~ ~ ~ _..._ i - ~=~ . - ~ .. a_ - x; ^: _ ~ Q, - ,~ ~_- _ .. s,. - c~ _ cn Conditional Use Permit and Solid Waste Facility Narrative Large on-site tanks: The ERS facility has three bulk fuel oil tanks. Until recently, these tanks were empty and unused since 1981. As part of the construction of the peaking station, two of the tanks were refurbished; one is used for fuel oil storage and the other is used for demineralized water storage. The third tank remains sealed off and unused. The refurbished fuel oil tank supplies backup fuel to ERS and the peaking station. The demineralized water is used to control NOx emissions when the peaking station combustion turbine is firing fuel oil. 3. Requested Amendments 3.1. Alternate Fuel Description and Scope GRE requests approval to cofire alternate fuels at Elk River station with RDF. The alternate fuels will be limited to TDF, wood and waste wood. A single alternate fuel may be cofired with the RDF or a combination of the alternate fuels may be cofired with the RDF. None of the proposed alternate fuels would be fired without concurrently firing RDF. The ERS will remain primarily aRDF-fired waste-to-energy facility. However, the economics of the overall operations (waste processing and waste combustion) are negatively impacted by an overall low supply of municipal solid waste to feed the RDF production plant or by short term interruptions in the municipal solid waste supply or RDF supply. cofiring alternate fuels is being proposed as a potential opportunity to maintain the overall economic viability of operating the waste to energy plant. Any economic advantages of cofiring will be dependent on the actual cost of any alternate fuels and the impact of the alternate fuel on operating and maintenance costs. GRE has begun to investigate fuel supply costs, but we cannot identify actual operating and maintenance cost impacts without actually cofiring the materials over a period of time. Our initial analyses suggest that the requested opportunity fuels offer some promise for cost savings. The air emissions permit issued for the Elk River campus currently allows ERS to cofire TDF at a rate of "less than or equal to 100 tons/day using [a] 30-day rolling average" but also "less than or equal to 200 tons/day using [a] 24-hour block." If the City feels it is necessary to also restrict the amount of TDF that is cofired, we request that these same restrictions be used in the CUP. The air emissions permit does not explicitly allow for ERS to burn any wood. However, the air permit, in conjunction with Elk River Station's Industrial Solid Waste Management Plan does allow ERS to burn "Excess wood chips from county projects." GRE will have to obtain approval from the MPCA prior to cofiring any wood that is not currently authorized by the permit and Industrial Solid Waste Management Plan. S:\Legal\Environmental\ERSWir\City of ER - Cond.UsePermit\2009 Alt Fuels Amendment\ER CUP Amend Narrative v2.doc Page 3 of 4 Conditional Use Permit and Solid Waste Facility Narrative The current cofiring proposal will result in little or no perceivable changes to the operation of the Elk River Station by the general public. cofiring of the requested alternate fuels will not require: • Physical modifications to existing building structures. Construction of any new structures. • Alteration or addition of roadways. • Increases in employee parking or staffing levels. • Changes in fuel delivery schedules. If a particular fuel source is identified that offers along-term supply at a price that is competitive with RDF, GRE would likely evaluate additional fuel storage and handling facilities. At that time, we would talk with the City to determine if the CUP would need to be amended. 3.2. Alternate Fuel Delivery and Storage Alternate fuels would be delivered directly to Elk River Station via the same route currently approved for the RDF trucks in the CUP. The requested alternate fuels would be delivered in covered trucks and unloaded in the existing RDF receiving barn. A similar number or fewer trucks would deliver fuel to Elk River Station. On a daily basis, Elk River Station historically operates very near its permitted capacity of 1,050 tons of RDF per day. TDF fuel has a higher heating value than RDF and would result in fewer trucks arriving at the site. Wood and wood wastes have heating values and densities similar to RDF and truck traffic volumes are not expected to increase significantly. S:1Legal\Environmental\ERS\Air\City of ER - Cond.UsePermit12009 Alt Fuels Amendment\ER CUP Amend Narrative v2.doc Page 4 of 4 GREAT RIVER ENERGY® 12300 Elm Creek Boulevard Maple Grove, Minnesota 55369-4718 763-445-5000 • Fax 763-445-5050 www.GreatRiverEnergy.com August 31, 2009 HAND DELIVERED Ms. Rebecca Haug Environmental Administrator City of Elk River 13065 Orono Parkway, PO Box 490 Elk River, MN 55330 Re: Conditional Use Permit and Solid Waste License Amendment Request for the Co-firing of Alternate Fuels Great River Energy -Elk River Station Dear Ms. Haug: Great River Energy (GRE) is seeking the City of Elk River's permanent approval to burn alternative fuels at Elk River Station to help ensure the future economic viability of the project. Specifically, we are requesting your approval to burn the following, along with the refuse-derived fuel (RDF) we currently burn: • Tire-derived fuel (TDF) • Wood • Wood waste As you are aware, GRE is evaluating purchasing Resource Recovery Technologies (RRT's) processing facility and landfill. We have a bridging agreement through December 31, 2009, with RRT to keep their processing plant and landfill operating so we can continue to operate Elk River Station and conduct the necessary due diligence prior to purchasing RRT's assets. During the bridging period, the processing plant and Elk River Station will be operating at less than capacity due to a short supply of municipal solid waste, which results in higher operating costs. The ability to burn the requested alternate fuels with RDF will help reduce the operating cost increases. We are requesting permanent approval for these alternate fuels to ensure that the future economic viability of the operations is not jeopardized by similar interruptions in the supply of municipal solid waste. Enclosed are: • A check in the amount of $1,520 to cover the initial fee and escrow. • A completed Land Use Application Form. • Parcel and Legal Descriptions. • A Conditional Use Permit Application Form. • A narrative describing the Elk River Station and the requested amendments. • A facility layout drawing. • Mailing labels for the owners of property located within 350 feet of the boundaries of GRE's Elk River campus. }r-d, - --a ~L:~ ~ ._...._ A Touchstone Energy Cooperative )~~~( !»~~ Contains 100% post consumer waste ~- Ms. Rebecca Haug August 31, 2009 Page 2 of 2 In addition to an amended Conditional Use Permit, we request that the City also issue an amended Solid Waste License. GRE is requesting the City's approval to cofire tire-derived fuel (TDF), wood and wood wastes along with RDF. Our current air emissions permit issued by the Minnesota Pollution Control Agency (MPCA) allows us to cofire a maximum of 200 tons of TDF in any day and 100 tons per day based on a 30-day rolling average. Prior to being able to cofire wood and wood wastes, the MPCA may have to issue GRE an amended air emissions permit. GRE has completed testing during which TDF was cofired with RDF. Analytical results are expected this week. Once we receive the data, we will review and summarize the data and submit it to the City. If you have any questions on the information contained in this letter, please contact me by telephone at (763) 445-5210 or by email at MStrohfus@GREnergy.com. Sincerely, GREAT RIVER ENERGY ``i ~" 1 ~~ Mark Strohfus Environmental Project Leader Enc. c: Timothy Steinbeck, GRE-ERS S:\LegallEnvironmental\ERSWir\Ciry of ER - Cond.UsePermit\2009 Alt Fuels Amendment\ER CUP Alt Fuel Amendment V2.doc Great River Energy Elk River Campus Site ._ ~ _ - ~~~ w ~i ° -. ~;t_ ~ i, ~. ~, - r ~ ~ u ~ ,. `, -~ .. ~ s ~- ~ ~, ~ ,,~ - _ - ~ E :, 1 ~ i1 w ~~ 3 ~ ~ L ~~ ~ - ~ Ali ~ ~ ' ~ 4 ~ ~! ~: -; ~ ,. ~, M ~ ~ ~~~ ,~ ~ Fem. -"° ~ ~ .~ ~~'.~* ~~ d i..- _ r .; . y ~ i s . ~ ~~ F.~ ~~ ~~ a ~. ;" ~ ~i ~:~ - _. _ g a...~ , x ~ ~~ ~ t z ~. f W ~~ _ # _~gw (y7~ ii ..- -. ~~ ,,,. 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