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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