Air Quality Permitting
Each University campus holds an Air Emission Permit issued by the Minnesota Pollution Control Agency ("MPCA"). The purpose of the permit is to identify all federal and state air quality rules that apply to the affected campus. The permit also contains air pollution limits for each significant emission source, defines allowable hourly and annual throughputs (e.g., fuel consumption in boilers), and consolidates monitoring, recordkeeping and reporting requirements. Adding a new source to an existing permit usually requires a permit amendment.
This procedure outlines steps required to install or modify air emission-producing equipment. The time and level of effort required to obtain a permit amendment depends on the type of permit held by the particular campus and the capacity of the identified emission source to emit air pollution.
Existing University Permits
Each of the four major campuses holds an existing air emission permit, as follows:
- Twin Cities – Title V Federal Operating Permit (Major Source)
- Duluth – State Operating Permit
- Crookston – State Operating Permit
- Morris – State "Option D" Registration Permit
The type of permit held affects the procedure for amending the permit. Federal permits are the most restrictive and detailed. State registration permits are the most flexible for purposes of making changes at the existing facility. Links to individual permits are found at the end of this procedure.
Three Steps to a Permit Amendment
- Identifying Processes and Equipment that may Require a Permit Amendment
- Filling Out and Submitting Internal Forms for each Emission Source
- Providing Notifications of Removal, Installation and Operation to DEHS
Each of these steps is discussed in the remainder of this document. For shutdowns & breakdowns and ongoing compliance and submittals, see other individual instructions.
- Identifying Processes and Equipment that may Require a Permit Amendment
Processes and equipment that may emit air pollution should be identified during the planning or schematic design phase of a project. The project manager should review the project for the following types of emission sources:
- Internal Combustion Engines, including fire pumps and emergency generators.
- Boilers, Furnaces, Incinerators or Kilns (excluding water heaters)
- Petroleum and Solvent Storage Tanks
- Material Handling Equipment, including conveyors, grinders, screens and other items used to process or transport grain, ore, coal or other similar materials.
- Surface Coating Operations, including paint booths and plating.
- Ethylene Oxide Sterilizers
- Woodworking Operations
Laboratory-scale equipment usually does not require an air permit amendment. However, the Twin Cities campus must maintain records of the number of fume hoods in operation to demonstrate compliance with the permitted Hazardous Air Pollutant emission limit.
Processes and equipment that emit air pollution must be designed and installed to meet ambient air quality standards (MN Rules 7009). A key component in meeting these standards is stack height. In general, exhaust stacks must be approximately ten feet above the highest roof line to disperse the exhaust and avoid building downwash, which can cause ambient air quality problems. Alternate location of exhaust stacks requires submission of modeling to DEHS to document compliance with these standards. DEHS will review modeling and determine whether it meets the standards or whether further modeling is required.
- Filling Out Internal Forms
Using the Air Emission Checklist on the Capital Planning Project Management website , fill out applicable forms for emission sources that will be installed or removed as part of the project. Submit completed forms to DEHS. Information required to fill out the forms will include: make and model number of the equipment to be installed; throughput and output capacity of the equipment; building, equipment and stack locations; and expected construction schedule. Call Twin Cities DEHS (612) 626-6002 with any questions or comments regarding form applicability or other details.
- Providing Notifications of Removal, Installation and Operation
Ensure timely submittal to the MPCA. Depending on the type and capacity of equipment installed under a permit amendment, the MPCA may require notifications of the installation, removal and/or initial operation of the newly permitted units. Project managers must provide expected and actual milestone dates to DEHS for review. Failure to do so may result in project delay.
Annual emission thresholds for each type of permit are shown in Appendix A.
Permit Amendment Thresholds
The type of permit amendment required for adding or modifying emission sources depends on the source's potential emissions, both in terms of pounds per hour (lb/hr) and tons per year (tpy). All emission sources that are part of a related project must be totaled. MPCA amendment thresholds are shown in Appendix A.
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. This will allow time for DEHS to make a final determination regarding permit amendment type, prepare the MPCA application and obtain permit issuance. Due to the backlog at the MPCA, it is suggested that major modifications be submitted with at least twelve months lead time.
The following schedule reflects the time required for issuance after the permit application has been submitted to the MPCA:
- Insignificant Modification: No amendment is required. 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 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. As the MPCA has no set time schedule for issuing letters of approval, it may be necessary to expedite this process by authorizing the initial and/or final reviews to be done by MPCA staff on overtime or through an outside consultant. There will be an added cost for expediting permit review. DEHS will advise on whether expediting is advisable.
- 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. See Appendix A for applicable thresholds.
Roles and Responsibilities
Capital Planning Project Management:
- Prepares internal forms and submits them to DEHS
- Notifies DEHS of start of construction, initial start-up of the equipment, dismantlement, commercial operation
- Pays any fines and penalties for non-compliance
- Prepares permit applications and amendments and submits these to MPCA
- Prepares notification documents and submits these to MPCA
- Represents the University as the primary environmental contact with MPCA and regulatory agencies