When should you submit an Emissions Inventory to the New Mexico Environmental Department?

October 1, 2020

Most owners and operators in New Mexico are aware of the state’s 2020 Minor Source Emission Inventory requirement; however, there have been some new developments regarding emission inventories during regular years that have come to light according to a September 18, Trinity Consultants report.

Emission inventory (EI) regulations are detailed in Part 73 in Chapter 2 of Title 20 of the New Mexico Administrative Code. Specifically, 20.2.73.300.B(1) NMAC states: “any source which emits, or has the potential to emit, 5 tons per year or more of lead or lead components, or 100 tons per year or more of PM10, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds shall submit an emissions report annually.” Historically, this has been interpreted to only include Title V sources in New Mexico (i.e. those with a potential to emit of criteria pollutants above 100 tpy excluding fugitives).

However, in recent discussions with the NMED, this definition has been expanded to include the following:

  • Sources which may be authorized under another permitting path (e.g. GCP-O&G) that have fugitive emissions which place the source over the 100 tpy threshold. As an example, a compressor station permitted for 90 tpy VOC with an additional 15 tpy of fugitive emissions would be required to submit an EI even though it is not a Title V source.
  • Sources which may have permitted emissions below 100 tpy, but have actual emissions above 100 tpy. As an example, a production facility authorized under a Notice of Intent (NOI) that has an event, such as a facility shut-in, that results in actual emissions above 100 tpy would be required to submit an EI.

What this means to you
There have been some new developments regarding emission inventories during regular years that have come to light in New Mexico regarding potential to emit, 5 tons per year or more of lead or lead components, or 100 tons per year or more of PM10, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds.

MIRATECH can help
Contact MIRATECH for stationary engine emission solutions in New Mexico.