Air Quality Permit Reporting

Introduction

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.

Many of the monitoring, reporting and recordkeeping requirements are specific to each permit. This procedure addresses only those items that are typically required, regardless of permit. Please refer to each facility’s specific permit to determine if special recurring or one-time notifications or submittals are required. For example, grain handling activities may require special monitoring steps to ensure that particulate control devices are working properly. In any case, compliance with all permit requirements are the responsibility of the operator, and submittals and notifications are ultimately the responsibility of each campus’s Department of Environmental Health & Safety (DEHS) officer. Each campus must send a copy of any MPCA submittal (with supporting documentation) to the Twin Cities DEHS.

If you have any questions regarding the standard requirements or special submittals, please contact Twin Cities DEHS at 612-626-6002.

Standard Reporting & Recordkeeping Requirements

Permitted facilities are required to maintain operating records that are used for compliance determination and which serve as a basis for periodic reporting to the Minnesota Pollution Control Agency. This procedure is divided into the following sections:

1. General Recordkeeping Requirements
2. Shutdowns & Breakdowns
3. Annual Emission Inventory
4. Annual Emission Fees
5. Semi-Annual Deviation Reports / Annual Compliance Certification
6. Annual Fuel Certification

For air permitting requirements, see Administrative Procedure: Air Quality Permitting.

General Recordkeeping Requirements

Unless otherwise specified within each facility’s operating permit, fuel consumption and other material throughputs should be logged each time permitted equipment is used. For emergency generators, run times should be automatically metered. For boilers, fuel flow should be automatically metered. Other processes and pollution control equipment included as permitted emission sources should either be automatically metered or hand-logged, depending on specific permit conditions.

All campuses must retain copies of fuel deliveries, including sulfur content (oil and coal only), ash content (coal only), higher heating value (Btu/unit for each fuel), and quantity delivered (all fuels). Campuses that combust biofuels must, at a minimum, maintain all of the information listed above for each delivery, unless otherwise indicated in the specific operating permit.

All monthly operating data listed above must be submitted to the appropriate DEHS official on each campus by the 10th day of the following month. For example, January operating data must be submitted by February 10. If meters or other monitoring devices malfunction or, for any other reason, recordkeeping deviates from permit requirements, the date and time of the failure (and failure resolution) must be noted and reported to DEHS as part of the monthly report.

Shutdowns & Breakdowns

Shutdowns and breakdowns that may affect human health or the environment are not deviations. Instead, they should be reported immediately to the campus DEHS officer and within 24 hours to the MPCA. A link to an online notification form and instructions is included at the end of this procedure. Please submit a copy of any MPCA form submittal to campus DEHS as well.

Annual Emission Inventory

Each of the four major campuses holds an air emission permit and is required to submit an annual emission inventory:

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

Fuel or process throughputs (operating hours for emergency generators) must be annually submitted to the MPCA for the previous operating year, which is defined as December through November. An emission inventory for the previous year will be sent by the MPCA to each individual campus at least three months prior to the deadline of April 1.

The Twin Cities campus must also submit a Hazardous Air Pollutant Emission Inventory. Please contact the Twin Cities DEHS office for assistance with this submittal.

The Twin Cities DEHS office will assist with the compilation and submittal of the emission inventory. However, it is the responsibility of each campus to comply with the rules.

Annual Emission Inventory Fees

Once each year, the MPCA will send an invoice to each campus requiring payment for the past year’s actual emissions. The invoice is based on a $/ton rate for selected criteria pollutants (some are not included). The invoice must be paid within 60 days of receipt.

Semi-Annual Deviation Reports / Annual Compliance Certification

Semi-annual deviation reports must be submitted by July 30 and January 31 for the first and last six months, respectively, for each calendar year. The reports must highlight any deviations from permitted operating conditions. Typical permit limits include fuel throughputs, sulfur/ash content, and pollution control equipment operating parameters.

Campus EHS officers must send report copies to Twin Cities DEHS.

Annual Fuel Certification

All fuel delivery invoices must be copied and submitted to the MPCA, along with a signed certification page, by April 1 for the previous operating year. A copy, written or electronic, of each annual fuel certification report must be submitted to Twin Cities DEHS.

Roles and Responsibilities

Twin Cities Campus: Facilities Management is responsible for collecting information listed under “General Recordkeeping Requirements”. Information is to be provided, in a mutually agreed-upon format, to Twin Cities DEHS by the 10th of each month. DEHS staff is responsible for maintaining the monthly database and for providing final reports to the MPCA.

Other Campuses: The EHS officer at each campus is responsible for maintaining an on-site monthly equipment usage database, demonstrating compliance with any annual emission limits that require monthly calculations, preparing MPCA reports and submittals, and reporting any shutdowns or breakdowns to the MPCA. The Twin Cities DEHS staff will assist with any questions or calculations.

Supporting Documentation

Existing University Air Quality Permits:

• Crookston: http://www.pca.state.mn.us/air/permits/issued/11900016-001-aqpermit.pdf
• Duluth: http://www.pca.state.mn.us/air/permits/issued/13700039-001-aqpermit.pdf
• Twin Cities: http://www.pca.state.mn.us/air/permits/issued/05301050-001-aqpermit.pdf

MPCA Fact Sheets:

• Facts About Emission Inventory and Fee Rules: http://www.pca.state.mn.us/publications/aq4-05.pdf
• Facts About Deviations: http://www.pca.state.mn.us/air/pubs/2-06.pdf
• Facts About Shutdowns & Breakdowns: http://www.pca.state.mn.us/air/pubs/2-09.pdf

MPCA Forms & Instructions:

• Air Emission Inventory Forms & Instructions: http://www.pca.state.mn.us/air/emforms.html
• Shutdowns & Breakdowns – Online Form: http://www.pca.state.mn.us/air/emissionsnotice.html
• Annual Compliance Certification: http://www.pca.state.mn.us/publications/forms/aq-f6-cr04.pdf
• Semi-Annual Deviation Forms: http://www.pca.state.mn.us/publications/forms/drf-2.pdf