HomeMy WebLinkAboutTetra Tech Permitability of Small Cogens
Tetra Tech, Inc.
4900 Pearl E. Circle, Suite 300W, Boulder, CO 80301
Tel 303.447.1823 Fax 303.447.1836 www.tetratech.com
June 2, 2008
Randy Hobbs
President
Alpine Energy, LLC
P.O. Box 436
Palmer, AK 99645
Subject: Permitability of Cogeneration Projects
Dear Mr. Hobbs:
This letter summarizes Tetra Tech’s assessment of the environmental permitability of the multiple
cogeneration projects being proposed by Alpine Energy in Alaska. Tetra Tech understands that
Alpine Energy plans to construct and operate several facilities that will each generate 5 MW of
electric power and provide thermal energy from the waste heat generated by the natural gas-fired
engines. The following discusses the types of permits required, emissions and permit
applicability, and estimated permitting schedule.
As a new source of air pollutant emissions, each cogeneration facility will require approval by the
Alaska Department of Environmental Conservation (ADEC), Division of Air Quality. The facility
will need to obtain a Title I Air Quality Control Minor Permit. Depending on the level of
formaldehyde emissions, a Title I construction permit for a major source of hazardous air
pollutants (HAPs) may also be required. Since the carbon monoxide (CO) emissions will be
greater than 100 tons per year, a Title V Operating Permit will also be required. These permits
will allow the internal combustion engines at each facility (two natural gas-fired, 3,922-hp
engines) to be constructed and operate. The Title I permit will need to be obtained before
construction is allowed to begin. An application for a Title V permit will need to be submitted
within 1 year after startup of the facility.
A primary task in the minor permit application process will be dispersion modeling of nitrogen
oxides (NOx) emissions to demonstrate that the proposed project will comply with the Prevention
of Significant Deterioration (PSD) increment and National Ambient Air Quality Standard (NAAQS)
for nitrogen dioxide (NO2). Emissions of all other air pollutants are projected to be less than their
respective modeling thresholds.
No significant technical or administrative difficulties are foreseen in obtaining any of the required
air quality permits. Tetra Tech anticipates that the permitting process will take 4 to 6 months after
the Title I permit application is submitted. This assumes no significant delays by ADEC during
application processing (which includes up to 60 days for completeness review, preparation of the
draft permit and technical analysis, a 30-day public comment period, and Coastal Zone
Management review).
Tetra Tech would be happy to assist Alpine Energy with the permitting process. Attachment 1
provides a Statement of Qualifications demonstrating Tetra Tech’s vast experience with similar
projects.
Mr. Randy Hobbs
June 2, 2008
Page 2 of 2
Tetra Tech looks forward to the opportunity to assist you with the permitting of these cogeneration
projects. If you have any questions, please feel free to contact me at (303) 447-1823
(tom.gibbons@tetratech.com).
Sincerely,
Thomas H. Gibbons
Program Manager
Attachment
ATTACHMENT 1
Tetra Tech Statement of Qualifications