Starting in 2020, the New Mexico Environment Department (NMED) is requiring an Emissions Inventory of criteria pollutants and greenhouse gas to be reported for both major and minor sources with air quality construction permits (20.2.72 NMAC), excluding facilities on Tribal Lands and in Bernalillo County. This includes General Construction Permits (GCP) and applies to sources with Notices of Intent (NOI) (20.2.73 NMAC).
All sources/facilities are required to submit to the Air Quality Bureau (AQB) before 11:59 p.m. on April 1,2021. The New Mexico Air Quality Bureau (NMAQB) is proposing to conduct a Minor Source EI every 3 years, which coincides with the Nation Emissions Inventory (NEI).
To prepare, facilities are expected to maintain facility production, materials processed, materials consumed, such as fuel, and hours of operation at a minimum. However, facilities can and should refer to their permit applications to determine what types of other records they might be required to keep.
In order to submit your inventories, a web-based application called the Air Emissions Inventory Reporting (AEIR) tool will be used. To cut time off of the possibly hundreds of submissions per operator, especially in the oil and gas sector, the NMED is accepting an XML schema to upload into the AEIR tool.
Calculations for all reported criteria pollutants, volatile organic compounds (VOC), Hazardous air pollutants (HAP), and GHGs must be submitted as an attachment, but the already existing Air Emissions Calculation Tool (AECT) can assist in the calculations and may be a part of the submission.
There are, however, minimum reporting thresholds:
For each piece of equipment, report emission amounts of 0.5 tons per year or more for the following pollutants: CO, H2S, NOx PM2.5, PM10, SO2 and VOCs.
If the entire facility emits a HAP at a rate of one ton per year or greater, then that HAP shall be reported at each emission unit that emits that HAP at a rate of 0.1 tons per year or greater. Individual HAPs from a particular emission unit should be aggregated to report totals HAPs, but also reported separately. VOCs are to be reported with HAPs included in their total.
The NMED is requiring data for CH4, CO2 and N2O to be reported. The minimum reporting threshold for GHGs is 25,000 metric tons CO2e per year. NMED is requesting only those facilities currently required to submit GHG emissions data to EPA under 40 CFR 98 to submit data to AQB but only submit emissions data from the New Mexico portions of the basins.
Amerigo is managing an effort to augment the emission calculation capabilities for a NM operator’s existing EMIS and fit the reporting needs for the XML schema. The project began in late 2019 as the operator is subject to reporting 300+ minor source EIs between their NOI and GCP authorizations. We want to leverage our experience to support other NM operators navigating the NMED Minor Source EI for the first time.