• HAP&Hg_Letter_Regular+Mandatory_Hg_2008

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    • Abstract: If your facility is required to keep records of HAP emissions as a condition of its permit, then you must submit HAP emission ... If your facility is not required to keep HAP emission records, then you are strongly encouraged to join the majority of ...

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December 19, 2008
Dear Air Permit Holder
In addition to collecting criteria pollutant data for the annual air emission inventory, the Minnesota Pollution Control
Agency (MPCA) is collecting air toxics emissions data for the air toxics emission inventory (ATEI) and mercury
emissions data for the voluntary mercury emissions inventory for calendar year 2008.
The ATEI is produced every three years, and it includes air toxics emission data for permitted facilities, smaller businesses,
consumer activities, and a variety of vehicles, small engines, and movable equipment.
The mercury emission inventory is a new annual inventory that includes mercury emissions data for electricity producing
facilities, municipal waste combustors, utilities, sewage sludge incinerators, foundries, facilities with industrial boilers that
burn wood or coal, and taconite facilities. This inventory is separate from the mandatory Mercury Emissions Report which
electricity producing/selling facilities are required by Minn. Stat. § 116.925 to complete. Since you received both the
Mercury Emission Inventory form and the Mercury Emissions Report, the MPCA is encouraging you to include data for all
units that were exempted from being reported on the Mercury Emissions Report. For the units your facility reported on the
Mercury Emissions Report, Minn. Stat. § 116.925, you do not need to provide the same information on the Mercury Emission
Inventory form.
1. Mercury Emission Inventory
In 2007 the MPCA established aggressive goals for reducing the mercury in Minnesota’s environment over the next couple of
decades. In 2008 the MPCA along with Minnesota stakeholders developed a strategy for ensuring that these mercury
reduction goals will be met. It is necessary to track mercury emissions over several years to determine progress towards these
goals. Completion of the enclosed Mercury Emission Inventory form will assist the MPCA in more accurately tracking
statewide mercury emissions.
Please report mercury emissions generated from any processes at your facility that were exempted from inclusion on the
Mercury Emission Report, including combustion processes. It is only necessary to report your facility’s mercury emissions
on the Mercury Emissions Inventory form. Mercury emissions do not need to be reported on the HAP Emissions Inventory
2. HAP Emission Inventory
The Minnesota Legislature and the U.S. Environmental Protection Agency (EPA) require the MPCA to provide air toxics
data to support and evaluate emission reduction strategies and to respond to public inquiries. The information is also used to
develop the National Emissions Inventory and the Minnesota portion of the Great Lakes Regional Emission Inventory for Air
Toxics. Therefore, the MPCA is obligated to provide the information, and your information is a vital part of completing a
reliable inventory.
Air toxics include the 188 Hazardous Air Pollutants (HAPs) listed in Section 112(b) of the Clean Air Act, pollutants
identified as significant contributors to the contamination of the Great Lakes, and other pollutants monitored in the Minnesota
environment. A list of all the pollutants included in the ATEI is provided along with the attached instructions. ATEI data is
also included in the Environmental Data Access (EDA) system available through the MPCA’s Web site (
http://www.pca.state.mn.us/data/edaAir/index.cfm ).
If your facility is required to keep records of HAP emissions as a condition of its permit, then you must submit HAP emission
data. If your facility is not required to keep HAP emission records, then you are strongly encouraged to join the majority of
individual air permit holders and submit air toxics emission data voluntarily.
December 16, 2008
Page 2
All facilities with individual air permits are included in the ATEI, even if the facility does not submit data. MPCA staff will
estimate air toxics emissions for facilities not required to submit air toxics data using any of the following:
• Emission Factors from AP-42 or Factor Information REtrieval (FIRE) Data System
• Data from the Toxic Release Inventory (TRI) database
• Information in air permits and air permit applications
• Information in other documents
• MPCA staff judgment
Directly reported emissions data from facilities is preferred over MPCA staff estimates. Using data submitted by facilities
results in a more reliable emission inventory.
For boilers, heaters, and internal combustion engines, it is not necessary to report air toxics emissions if your facility does not
have process-specific emission factors calculated from performance test results or other methods. The MPCA can estimate air
toxic emissions from combustion processes for you by using the most current emission factors in the FIRE database and your
fuel usage data reported to the MPCA for the 2008 AEI. Process-specific fuel heating values, however, can be used to derive
more accurate estimates.
If you are among the majority of air permit holders that provide data for the ATEI, the MPCA thanks you and your
organization for contributing to a higher quality emission inventory that is increasingly relied on for a wide variety of
purposes. If you have not submitted an inventory in the past, please consider making this your first year.
Instructions for the data submission for mercury and for air toxics are attached. You may submit data by regular mail or via
e-mail. If you would like to submit your data electronically, you may download the example HAP spreadsheets in
Microsoft® Excel format (2008ATEI_Form_Regular.xls) from the MPCA web site
( http://www.pca.state.mn.us/air/toxics/toxics-dataguidance.html ) or complete the electronic version of the mercury emission
inventory form that was e-mailed to you and email the completed forms to Chun Yi Wu ([email protected]).
Electronic submissions are encouraged. The deadline for air toxics emission inventory and mercury emission
inventory submittals is May 1, 2009. Please direct any questions or information to Chun Yi Wu:
Chun Yi Wu
Environmental Analysis and Outcomes Division
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55155-4194
(651) 757-2833
[email protected]
Frank Kohlasch, Manager
Air Assessment and Environmental Data Management Section
Environmental Analysis and Outcomes Division

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