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. 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

1. Identifying Processes and Equipment that may Require a Permit Amendment
2. Filling Out and Submitting Internal Forms for each Emission Source
3. 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.

Stack Height

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 Forms on the Capital Planning Project Management website http://www.cppm.umn.edu/standards.html Appendix HH, 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

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 and submittal to the MPCA.

Permit Thresholds

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.

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. 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

DEHS: 

• 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

Forms and Instructions

• Appendix A  Air Permitting Emission Thresholds

Other Procedures

• Air Quality Permit Reporting

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:

• Obtaining Air Permit Amendments: http://www.pca.state.mn.us/publications/aq2-03.pdf
• Processes & Equipment that may need an Air Permit: http://www.pca.state.mn.us/publications/aq2-01.pdf
• Determining Applicability of New Source Review: http://www.pca.state.mn.us/publications/aq4-25.pdf

 

Appendix A: Air Permitting Emission Thresholds

Operating Permit and Permit Amendment Thresholds

Table 1. Air Emission Operating Permit Thresholds (tons/year)

Pollutant	Option D Registration Permit (< value)	State Permit (< value)	Federal Permit (> value)
Carbon Monoxide (CO)	50	100	100
Nitrogen Oxides (NOx)	50	100	100
Sulfur Dioxide (SO2)	50	100	100
Particulate Matter (PM)	50	100	100
Particulate Matter < 10 microns (PM10)	50	100	100
Volatile Organic Compounds (VOC)	50	100	100
Lead	0.5	10	10
Combined Hazardous Air Pollutants (HAP)	12.5	25	25
Single HAP	5	10	10

Registration permit thresholds are based on actual emissions while other permits are based on “allowable” emissions, which are either potential emissions (8,760 hr/yr) or are calculated considering voluntary operating limits.

Table 2.  Air Emission Permit Amendment Thresholds

	Insignificant	Minor	Moderate/Major
Pollutant	lb/hr	lb/hr	lb/hr
Nitrogen Oxides (NOx)	< 2.28	2.28 – 9.13	9.13
Sulfur Dioxide (SO2)	< 2.28	2.28 – 9.13	9.13
Volatile Compounds (VOC)	< 2.28	2.28 – 9.13	9.13
Particulate Matter <10 microns (PM10)	< 0.855	0.855 – 3.42	3.42
Carbon Monoxide (CO)	< 2.28	5.70 – 22.80	22.80
Lead	< 2.28	0.025 – 0.11	0.11

Table 3 presents examples of the types of individual processes or equipment that may qualify for each amendment type:

Table 3.  Air Emission Permit Amendment Thresholds –
     Equated to Table 1 by Equipment Type and Rated Throughput

	Insignificant	Minor	Moderate/Major
Process/Equipment Type	Throughput	Throughput	Throughput
New Emergency Generators	< 200 kw	<= 750 kw	> 750 kw
New Peak-Shaving Generators	n/a	n/a	ALL
Boilers – Natural Gas	< 10 MMBtu/hr	n/a	> 10 MMBtu/hr
Boilers – Distillate Oil	< 4.4 MMBtu/hr	4.4 – 10	> 10 MMBtu/hr

The preceding tables are provided only for guidance. Please contact DEHS and provide relevant data for final determination.

Construction Permit Thresholds (New Source Review)

The federal New Source Review (NSR) Program ensures that major projects (such as a new steam plant) undergo thorough review before permission to construct is granted. The NSR program affects only those projects that occur at a facility that is already a NSR major source (see column 1 of Table 4), or that, by adding new emission sources, will have potential emissions that exceed column 2 of Table 4. The Twin Cities campus is a NSR source. The other campuses are state-permitted facilities and are likely not going to become subject to the NSR program.

If a project will have a potential emission increase greater than those listed below (for any pollutant), a detailed review must be conducted to ensure that local ambient air quality will not be adversely impacted and that “best available control technology” is installed on new equipment. New Source Review can increase the permitting timeline by one year.

NSR can be avoided by accepting voluntary operating limits (hours or throughput) that would reduce increased annual emissions to less than the thresholds listed below.

Table 4. Air Emission NSR Construction Permit Thresholds (tons/year)

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