The New Mexico Environment Department (NMED) - Air Quality Bureau will be conducting an emission inventory (EI) for all minor sources located in the state of New Mexico for reporting year 2020. For those unfamiliar with EIs, an emission inventory is defined as “an accounting, by source, of the amount of air pollutants discharged to the atmosphere.” There is currently no minimum reporting threshold by pollutant. Emissions of the following pollutants are required to be reported:
- Criterial Pollutants: Carbon Monoxide (CO), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Particulate Matter less than 10 microns in diameter (PM10), Particulate Matter less than 2.5 microns in diameter (PM2.5), and Lead
- Greenhouse Gas Pollutants: Methane, Carbon Dioxide (CO2), and Nitrous Oxide (N2O)
- Volatile Organic Compounds (VOC)
- Hazardous Air Pollutants (HAPs)
Minor sources pulled into this action include all sources permitted under the following mechanisms: Notice of Intents (NOI), General Construction Permits (GCP), New Source Reviews (NSR), and Streamline Permits. Emissions from portable equipment will also need to be reported for this EI. Title V, No Permit Required (NPR) facilities, and sources exempt from permitting are not included in this inventory. According to the NMED, there are approximately 5,000 minor sources in the state that will be subject.
The deadline to start gathering information for the 2020 minor source EI is fast approaching. This inventory will involve quantifying all actual emissions from each minor source in reporting year 2020. Therefore, sources will need to start maintaining records of the data needed to calculate actual emissions from each permitted unit starting January 1st, 2020. It is vital that recordkeeping systems are in place by the start of 2020, to ensure the necessary data is collected.
In general, the information that will need to be gathered for each permitted source is as follows:
- Actual hours of operation for each piece of equipment
- Sources with portable equipment should maintain records of operation for those units by county
- The type and quantity of fuel combusted
- Facility-wide production
- Materials processed
For a more detailed description of the data required to be collected, sources should refer to their most recently issued permit and its corresponding application. These documents should contain information on all emission units at a source and what data is needed to calculate the emissions from each unit.
The data described above will be used to quantify the actual emissions from each minor source throughout 2020, then those emissions will be reported to the NMED during the period of January 1st through April 1st, 2021. Reporting will be completed using the NMED's web-based Air Emission Inventory Reporting (AEIR) tool. Information in the submittals for each unit will include the hours of operation, fuel consumed, and fuel heating value, as well as the quantity of each pollutant released and method used to calculate the emissions. Some acceptable methods of calculation include using emission factors from AP-42, manufacturer's data, or stack testing. Emission monitoring (such as CEMS data) and gas analyses may also be applied. If used, stack test data should be from within the past five years and gas analyses from within the last year. Please note that these are not definitive time restrictions; the NMED is still discussing these requirements and have not yet released guidance.
In addition to the information above, emission calculations will be required to be submitted, unless the newly revised NMED-developed Air Emission Calculation Tool (AECT) is used. Once complete, it will be the preferred method of calculation for the minor source EI. Furthermore, the NMED believes that they will be able to incorporate it into the AEIR tool, so it will calculate and auto-populate the submittal within the same system. In addition, the NMED is adding GHG calculations to the AECT based on 40 CFR Part 98. The AECT is scheduled to be completed before the minor source EI must be submitted (Jan. 2021).
Submittals will be entered into AEIR individually by facility or in mass by uploading an XML file with all facilities that will auto populate the system. The NMED is still troubleshooting the mass submittal system, but they will release the necessary format for the XML file to do this once they've finished testing. The submittals will still need to be individually certified for each source. If there are multiple permits for the same source, an EI submittal will need to be entered for each permit and will be split up based on the equipment that is permitted under each authorization. There will be no fees associated with the minor source EI, and annual fees will not be affected.
The NMED is holding several additional outreach events to prepare affected parties for the EI. NMED staff plan to discuss the pollutants that will need to be reported, as well as what facility and equipment information will need to be tracked and reported. These events are scheduled for the following dates and locations:
Las Cruces - September 25, 2019
1:30 - 3:30 PM
Thomas Branigan Memorial Library, Roadrunner Room
200 E Picacho Ave.
Las Cruces, NM 88001
Carlsbad - September 26, 2019
Carlsbad Museum & Art Center
418 W Fox St.
Carlsbad, NM 88220
Albuquerque - September 30, 2019
1:30 - 3:30 PM
6135 Edith Blvd. NE
Albuquerque, NM 87107
For any questions regarding the current status of the NM Minor Source Emission Inventory or general questions regarding new NMED initiatives, please contact our Trinity Albuquerque office at (505) 266-6611