Air Quality Permitting and Reporting

Introduction

Each University campus holds an Air Emission Permit issued by the Minnesota Pollution Control Agency (MPCA). The permit contains air pollution limits for significant emission sources. It defines allowable hourly and annual throughputs for fuel consumption requires monitoring, recordkeeping and reporting. Adding a new source to an existing permit may require a new source review and usually requires a permit amendment.

Processes and equipment that emit air pollution must be designed and installed to meet ambient air quality standards (MN Rules 7009). In general, exhaust stacks must be at least ten feet above the highest roof line to disperse the exhaust and avoid building downwash. Alternative location and height of an exhaust stack requires modeling to demonstrate compliance.

This procedure outlines the steps required by the installation or modification of an air emission-producing source. The time and effort required to amend a permit depends on the type of the current permit and the capacity of the new emission producing equipment.  Federal permits are very restrictive and detailed while Minnesota registration permits are more flexible.

Permit Amendment Thresholds

The type of permit amendment required for adding or modifying emission sources depends on the source's potential emissions. Potential emissions are determined by assuming continuous operation of the source.

All emission sources that are part of related projects must be aggregated and totaled. Whenever possible, DEHS must justify separating projects that arise within 18 months of each other to avoid aggregation.

Existing University Permits

Four campuses hold an existing air emission permit.

• Twin Cities – Title V Federal Operating Permit (Major Source)
• Duluth – State Operating Permit
• Crookston – State Operating Permit
• Morris – State "Option D" Registration Permit

Three Steps to a Permit Amendment

1. Identify processes and equipment that are emission sources
   • Identify sources during the planning or schematic design phase of a project.
   • The project manager should review the project for the following types of emission sources:
     1. Internal combustion engines, including fire pumps, and emergency generators
     2. Boilers, furnaces, incinerators, or kilns
     3. Petroleum and solvent storage tanks
     4. Material handling equipment, including conveyors, grinders, and screens used to process or transport grain, ore, or coal
     5. Surface coating operations such as paint booths and plating.
     6. Ethylene oxide sterilizers
     7. Woodworking operations
     8. Paint booth or chemical spray booth

     Laboratory-scale equipment usually exempt, however records of fume hoods in operation are maintained.

2. Document descriptive information for the emission source

   Information required includes:

   • Make and model number of the equipment
   • Throughput and output capacity
   • Building intake and exhaust locations
   • Equipment and stack locations
   • Construction schedule
3. Notifiy DEHS when a source is removed or installed and operated

   Permit amendments require timely submittal to the MPCA.  Failure to do so may result in project delay.

   The University’s permit may require notice to the MPCA for installation, initial operation, and decommissioning of a permitted emission source.

   Project managers should consult with DEHS staff about milestone dates.

Permitting Schedule

Emission source information should be provided to DEHS at least six months prior to the expected start of construction for all types of modifications except major modifications. Major permit modifications may require at least twelve months lead time. MPCA staff review and approval can take many months. The process can sometimes be expedited by paying additional fees.

After the permit application has been submitted to the MPCA, the following schedule reflects the time required for issuance:

• Insignificant Modification: No amendment is required and installation and operation may begin once an internal record of the proposed modification has been made and approved by DEHS.
• Minor Modification: Installation and operation can occur seven days after the application has been submitted to the MPCA. However, the University is at risk of violating its permit if the MPCA later determines that the project does not qualify as a minor modification.
• Moderate Modification: Construction can begin once the University receives a letter of approval from the MPCA. Operation cannot begin until the actual permit amendment is issued. EPA has 45 days to review the amendment once it is finalized by the MPCA but before operations can begin.
• Major Modification: A major modification is defined as a change that both exceeds the moderate permit amendment threshold and is a major modification under the federal New Source Review construction permit program.

Roles and Responsibilities

Facilities Management:

• Approves design of equipment and systems
• Assures that safety codes and standards are met
• Operates sources and provides data required for reporting
• Maintains equipment and systems
• Assists with development of code and permit conditions

Capital Project Management:

• Provides equipment data to FM and DEHS
• Notifies DEHS of start of construction, initial start-up of the equipment, and discontinuance of commercial operation

DEHS:

• Submits permit applications and amendments to MPCA
• Submits notification documents to MPCA
• Represents the University as the primary environmental contact with MPCA and regulatory agencies

Building Code Division

• Reviews project plans to ensure that applicable codes are met
• Inspects and approves installation
• Issues certificate of occupancy