The New Mexico Environment Department (NMED) is conducting its triennial Minor Source Emissions Inventory for Air Quality sources. This inventory applies to all Minor sources with air quality construction permits (20.2.72 NMAC), including General Construction Permits (GCP). It will also apply to sources with Notices of Intent (NOI) (20.2.73.200 NMAC) for reporting year 2023 (per 20.2.73.300 NMAC). Minor source emission inventory recordkeeping will be required from January 1, 2023 – December 31, 2023, for all minor sources.
There is currently no minimum reporting threshold by pollutant. Emissions of the following pollutants will be required to be reported to the NMED by April 1, 2024:
- Criteria 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 (Pb).
- Greenhouse Gas Pollutants: Methane, Carbon Dioxide (CO2), and Nitrous Oxide (N2O), etc.
- Regulated Pollutants: Volatile Organic Compounds (VOC), Hazardous Air Pollutants (HAPs), and Toxic Air Pollutants (TAPs).
Minor sources pulled into this action include all sources permitted under the following mechanisms:
- Notice of Intent ;
- General Construction Permit ;
- New Source Review (NSR); and
- Streamline Permits.
Emissions from portable equipment will also need to be reported for this minor source emission inventory. Title V and No Permit Required (NPR) facilities are not included in the minor source emission inventory; however, Title V sources submit annual major source emission inventory by April 1, each year. In addition, sources exempt from permitting are exempt from the minor source emission inventory. According to the NMED, there are approximately 5,000 minor sources in the state that will be subject.
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;
- The type and quantity of fuel combusted;
- Facility-wide production; and
- Materials processed.
Reporting will be completed using the NMED’s web-based Air Emission Inventory Reporting (AEIR) tool. Information in the submittals for each unit may 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. Submittals will be input into AEIR individually by facility or en masse by uploading an XML file with all facilities that will auto-populate the system. The submittals will still need to be individually certified for each source. If there are multiple permits for the same source, an emission inventory 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 emission inventory. Annual fees will not be affected.
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 the past five (5) years and gas analyses from the last year. Please note that these are not definitive time restrictions but rather guidelines based on data that the NMED has used in past emission inventories.
If you would like to discuss the New Mexico minor source emission inventory and how they may impact your facility, please contact Trinity’s Albuquerque office or call 505.266.6611.
