HomeMy WebLinkAbout2000-03-29 NSP Ltr to OPHKris Danielson, Community Development Director
City of Oak Park Heights
City of Oak Park Heights
14168 North 57 Street
P.O. Box 2007
Oak Park Heights, MN 55082-2007
Dear Kris,
Please find enclosed the documentation requested by the Planning Commission and City Council to
move forward with the necessary permitting needed to continue construction of the new cooling tower
cells at NSP, Allen S. King Plant. As discussed during the proceedings, this cooling capacity addition is
vital for NSP and the communities it serves to assure electrical capacity and reliability during high energy
periods of the summer. The project has been moving forward per the construction schedule using a
general permit for excavation and masonry work. We are approaching a phase that will require the
additional permitting for the actual structure construction.
The documentation represents the opinions of permitting requirements of the Minnesota Department of
Natural Resources, Department of the Army and the Minnesota Pollution Control Agency. Please review
these documents and advise as to any additional requirements the City of Oak Park Heights may have to
assist Northern States Power Company in moving forward with this project allowing the schedule to
provide completion and operation of the new cells by July 1, 2000.
Kris, if there is anything needed that I can expedite to assure success with this process, please contact
me immediately. My office phone number is 651-731-5751 and I can be paged at 612-510-2374.
Sincerely,
/Da G. Knutson, Site Project Manager
c. Mark Fritsch, Plant Manager
Office File
Northern States Power Company
Alien S. King Plant
1103 King Plant Road
Bayport, MN 55003-1000
March 29, 2000
FILE COPY
March 28, 2000
Daryl Knutson
1103 King Plant Road
Bayport, MN 55003
RE: Cooling Tower Construction Issues, City of Oak Park Heights, WashingtorrCounty
Dear Mr. Knutson:
' ` ; V L'7- J t
Minnesota Department of Natural Resources ; : }
DNR Waters - 1200 Warner Road, St. Paul, MN 551 0667 lift 2 9 2000
Telephone: (651) 772-7910 Fax: (651) 772 -7977
The DNR is in receipt of a Joint Notification Form (JNF) for the construction of new cooling tower
cells at the NSP Plant in Oak Park Heights. No DNR Protected Waters Permit is required for this
tower construction or the access road. A dewatering permit has already been obtained from us.
There are however, some local zoning issues that have not been covered. The City of Oak Park
Heights has a Lower St. Croix ordinance that requires a 35' height limit, a 140 foot structure setback
from the ordinary high water elevation (OHW) (675.0') and a 40' bluffline (12% slope) setback. To
my knowledge, the City did not consider their St. Croix ordinance when making decisions. It is likely
that hardship can be shown and the variances can be certified, but it is our opinion that NSP must go
through the appropriate local processes. For our part, the DNR will move uickl to complete
q y p
certification process once we receive the hearing decisions from the City.
Because the site is in the floodplain, a conditional use permit from the City may also be required. The
construction must be consistent with the City's Floodplain Ordinance, as well as the State Building
Code Floodproofing Standards.
Please contact me at (+651) 772-7910 if you have any questions.
Sincerely,
AV)
Molly C. Shodeen
Area Hydrologist
c: City of Oak Park Heights, Tom Melena
Jim Bodensteiner, 414 Nicolette Mall, Minneapolis, MN 55401
U.S. Army Corps of Engineers, Dan Seeman
Central Waters, Steve Johnson
Regional Hydrologist, Dale Homuth
DNS. Information: 651 -296 -6157 • 1- 888 -646 -6367 • TTY: 651- 296 -5484 • 1 -800 -657 -3929
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03/24/00 FRI 11:55 FAX
R TO
ATTENTION OF
Construction-Operations
Regulatory (00-03289-DAS)
March 16, 2000
Mr. Jim Bodensteiner
Northern. States Power Company
4J_4 Nicollet Mali
Minneapolis, Minnesota 55401-1927
Dear Mr. Bodensteiner:
DEPARTMENT of: THE ARMY
$T. PAUL DISTRICT, CORM Or ENGINEERs
ARMY CORPS OF ENGINEERS CENTRE
190 FIF114 STREET EAST
ST. PAUL, MN 551)1-1538
We have reviewed information about your project to install
additional coal tower clis . the'PalenS, King .Generftt•ng
Plant. The project site is in Sec. 2, T. 251q., R. 20W.,
Washington County, Minnesota.
The work proposed at the location stated is nct within the
regulatory jurisdiction of the Corps of Engineers. No work will
be done in a navigable water of the United States, and no dredged
or fill material will be discharged in any water of the United
States, including wetlands. Therefore, a Department of the Army
permit is not required to do this work.
This letter is valid only for the project referenced above_
If any change in design, location, or purpose is contemplated,
contact this office to avoid doing work that may be in violation
of Federal law. PLEASE NOTE THAT THIS CONFIRMATION LETTER DOES
NOT ELIMINATE THE NE2D FOR STATE, LOCAL, OR OTHER AUTHORIZATIONS,
SUCH AS THOSE OV THE DEPARTMENT OF NATURAL RESOURCES OR COUNTY.
If you have any questions, contact David A. Studenski in our
St. Paul office at (651) 290-5370. In any correspondence or
inquiries, please refer to the Regulatory number shown above.
Sincerely,
A Char M. Hauer
Chief, Regulatory Branch
flk
Prinieci on al , Aserled Paper
4 1,
FILE COPY
03/24/00 FRI 11:55 FAX
February 25 , 2000
Mr, Jim Bodensteiner,
Senior Environmental Scientist
Northern States Power Company
ERAD
414 Nicollet Mall
Minneapolis, Minnesota 55401
Dear Mt Bodensteiner:
Minnesota Pollution Control Agency
RE: Northern States Power Company Alien S. King Generating Plant
NPDES Permit No. MN0000825
Northern States Power (NSP) staff notified Minnesota Pollution Control Agency (MPCA) staff
that National Pollutant Discharge Elimination System (NPDES) daily MaXiMUM temperature
limitations were violated in July 1999 under the circumstances described below.
Effluent Charactexistic Dischar Lirnitatioii
Temperature Daily Maximum (12 minute average) 86 Degrees Fahrenheit
July 25, 1999, Temperature 87 Degrees Fahrenheit
July 29, 1999, Temperature = 83 Degrees Fahrenheit
July 30, 1999, Temperature = 89 Degrees Fahrenheit
FILE. COPY
From July 25 througli July 30, 1999, a number of weather anomalies occurred that resulted in
NSP Allen S. King facility (King) exceeding its NPDES temperature limitation_ Beginning
Sunday, July 25, Minnesota experienced a combination of extremely high ambient temperatures,
river temperatures and record wet bail temperature (or dew point). The clew point at the Twin
Cities airport broke a record at 81 degrees Fahrenheit Hot, humid weather inhibits cooling
tower efficiency. Commensurate with the record high temperatures, was record high energy
dema.nd.
During the heat wave, NSP was looking at all of their options to reduce demand and buy
additional energy at any cost. NSP implemented "Saver Switch" for the first time ever on a
weekend and asked its customers to reduce optional use of electricity. Because such a peak
demand put NSP at a risk of violating its permitted temperature effluent limitations NSP
considered implementing "rolling blackouts". NSP had already de-rated King to moderate
discharge temperatures. According to NSP, de-rating a plant during very high energy demand
comes at a great expense to an electric utility since energy was not available to be bought at any
price in the region.
520 Lafayette Rd. N.,; St. Paul, MN 55155-4104: (661) 296-6300 (Voice); (651) 292-5332 (TTY)
St. Paul - Brainerd - Detroit Lakes • Duluth • Mankato - Marshall - Rochester • Willmar, www.pca.state_mn.us
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t 003
03/24/00 FRI 11:56 FAX 004
Mr. Jim Bodensteiner,
Page 2
After King's first permit temperature exceedance on Sunday, July 25, NSP ERAD
as prepared
to cut power further on the subsequent Thursday when they were in jeopardy of another NPOES
permit exceedance, However, the King facility received a mandate from NSP System � Operations
that a Heat Storixl Emergency was declared., This declaration meant that all available e n e,
grating
units were to be put back on -line in the interest of public safety. The Heat Storm Emergency
was
declared in part to save the overall regional system from a power blackout that can occur from
extra strain on on -line systems due to other systems being taken. off-line. Therefore the decision
to further de -rate King was ao longer , NSP ERA:D's control and they violated the ta temperature
limitation o n 29 � P
`Thursday, July 29 and Friday, July 3 0, 1 999. Since public safety is the first
priority of a utility, it was not possible to cut power due to health risks, especially for elderly
people and other people at medical risk.
.According to the Discharge Monitoring Report (DMR) submitted for Kial for July 1999 `the
g a
hot, humid. weather affected discharge temperature :3 directly by i -nh biting cooling capacity aid
elevating intake temperatures, and indirectly through record electricity demand. in the region with
high air conditioning use". The result was that during the heat wave that occur ed from Jul 25
throe - y
through July 30, 1 999, King had three daily temperature maximum violations with the greatest
being 89 degrees Fahrenheit (the limitation is 86 degrees). The King plant personnel surveyed
the ever for fish r i
ver fosh toortab,ties and observed none. Therefore, t is not believed that these
temperature exceedances resulted in environmental harm in terms of fish habitat.
In 1998 the NSP King plant reported.'two daily ma thaurn temperature violations for which they
were cited in. the June 11, 1999, Compliance Monitoring Survey report by MPCA, staff. As a
result, NSP was required to submit a plan to prevent recurrence of such violations. NSP
submitted its response on July 19, 1999, that outlined operational changes it would make to
prevent recurrence. After the violations occurred in 1999, albeit due in large part to anomalous
weather conditions as described above, NSP recognized that it needed to go further to ensure
compliance with its NPDES permit
In consideration of both years' violations, NSP staff presented a proposal to MPCA staff on
January 31. 2000, to install a new bank of cooling towers at King in the suminer of 2000, to
prevent any future temperature violations. NSP provided MPCA std a detailed description of
the cooling tower option with fiberglass comporxenxs it plans to construct. This type of addition
to its cooling capacity does not require a modjication oft the existing NPDES permit since it will
only change the description in the permit which can be addressed during the impending permit
refssuanc e.
MPCA staff considers exceedances of effluent limitations serious permit violations and
normally, subject to enforcement action. However, MPCA staff acknowledges that NSP took
extreme measures to avoid an exceedance of the temperature limitation during the July heat
wave. Furthermore, if NSP had taken a dditional measures it would. have created a human health
risk.
03/24/00 FRI 11:56 FAX
Mr. Jim B o den.stein er,
Page 3
As a result of this second series of temperature violations, NSP has evaluated other steps that
could be taken and proposed additional measures to prevent a recurrence of temperature
exceedances. To ascertain what enforcement action, if any, should be taken please submit a
timeline for implementation. of these proposed additional measures. ACA staff will evaluate
the timeline and monitor future discharge activities to determine whether and what level of
enforcement action is appropriate.
Sincerely,
Maw Hayes
Compliance Coordinator
Major Facilities Section
Metro DisLdct
MH:blt
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