GHG common questions
Q. I have an Option C registration permit and have some GHG-emitting units, but they all qualify as insignificant under Minn. R. 7007.1300, subp 2 and 3. Can I keep my current permit?
A. Yes, you continue to qualify under the revised Minn. R. 7007.1125, subp. 1.
Q. I currently have a Part 70 permit and I’ve completed PTE calculations for GHG and I am under 100,000 tpy of CO2e. Do I need to submit my PTE calculations to the MPCA?
A. You were required to complete PTE calculations by July 1, 2011 (see Minn. R. 7007.0150, subp. 1(E)), but you do not have to submit these calculations to the MPCA. If you are under 100,000 tpy, just keep records of your calculations. If you are over 100,000 tpy, you needed to submit a notification by June 30, 2011. Send this notification to:
Air Quality Compliance Tracking Coordinator
Minnesota Pollution Control Agency
520 Lafayette Road North
St Paul, MN 55155
Q.I have an Option A Registration Permit. Do I need to do the PTE calculations required by Minn. R. 7007.0150, subp. 1(E)?
A. Under the permanent rule that went into effect on January 24, 2013, you need to assess whether or not you still qualify for an Option A permit by re-evaluating your insignificant activities and calculating your GHG potential emissions. If you can continue to qualify for your Option A permit, you do not need to take any further action. If you no longer qualify for your Option A permit, you needed to notify the MPCA of this by February 23, 2011.
If you now qualify for a different registration permit, you needed to submit the new registration application by February 23, 2011. If need to apply for some other type of permit, you must have applied by July 23, 2011.
See Greenhouse Gas Information Updates for Holders of Registration Permits for what is required for the various registration permit options.
Q. I have a Part 70 permit that includes limits to avoid being major under New Source Review. In addition, my permit includes some flexibility in that it lets me make changes to my facility as long as I remain a minor source as required by the permit (with some recordkeeping, notifications, and possibly minor/moderate amendments required, depending on the change). I’ve calculated by GHG PTE and I know that it is greater than 100,000 tpy CO2e. I know I eventually want to add limits to my permit to remain minor under NSR including GHGs, but I don’t see any deadline in the rule by when I need to do this. Can I continue to make modifications/changes under my permit after 7/1/11 and then just include GHG limits when my permit is up for renewal in 3 years?
A. While the rule does not require you to add limits for GHG to your permit (i.e., you can become a major NSR source), you may wish to get an amendment to incorporate new GHGs so that you can remain a minor NSR source. As of July 1, 2011, with each change that you propose to make, you will need to determine if you are an existing major source under NSR. It is possible that proposed changes will need to be analyzed based on your facility being major for NSR (e.g., using form CH-04a, not CH-04b) – meaning that changes that might have previously only required a minor amendment could now require a major amendment in order to take limits to avoid NSR. It is likely in your best interest to apply for a major amendment to incorporate limits on GHGs sooner rather than later.
In addition, for any changes you plan to make after 7/1/11, you need to complete the calculations/analyses required by Minn. R. 7007.0150, subp. 1(B) and (C). See Greenhouse Gas Information Updates for Holders of Individual (Part 70 or State) Permits for more information on what is required by the new rules for facilities who have an individual Part 70 permit.
Q. I have an Option C or an Option D permit. Do I need to calculate my PTE?
A. No. Follow the specific requirements for registration permits and for Option C or D facilities in Minn. R. 7007.1100, 7007.1125 and 7007.1130.
Q. I have an Option D permit. Do I need to submit my monthly GHG calculations to the MPCA?
A. No, you do not have to submit this information on a monthly basis. Starting in January 2, 2011, you were required to start calculating your GHG emissions. Keep records as you do for your other pollutants. Once you have more than 12 months of calculations, track your 12-month rolling sum to ensure your actual emissions are below the Option D thresholds.
However, you will need to submit your calculated actual emissions when you submit your annual emissions inventory which is due in April of each year. While many facilities will not have to report their GHG to the MPCA, those facilities with Capped Permits or Option D Registration permits will have to report these emissions as required by Minn. R. 7019.3020(D) and (E).
Q. Where can I find GHG emission factors?
A. Emission factors for GHGs are still being developed for many industries. Typical sources for emissions are US EPA’s AP-42. AP-42 has GHG factors for fuel use and for some industries, such as asphalt plants. Additionally, US EPA’s Reporting Rule has calculation information for sources included in the rule. However, not all types of equipment at a facility subject to reporting are covered. Other possible options include The Climate Registry, test results, or data from your industry, association or equipment manufacturer, or mass/chemical balance. You may also make a proposal to the MPCA to use other sources of data. The MPCA has a webpage with further guidance on calculating GHG emissions.
The U.S. Environmental Protection Agency also has a set of questions and answers about this subject on their Implementing GHG Permitting page.