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Your business operation is currently covered by a registration operation permit (ROP) issued by the Wisconsin Department of Natural Resources (DNR) Air Management Program. The DNR’s Small Business Environmental Assistance Program (SBEAP) and the Air Management Program work together to provide services and assistance to small businesses. Copies of this and previous reminder emails are available online.
Air Emissions Inventory Reporting System Changes For 2024 - Webinar Dec. 6
The DNR will host a webinar on Wednesday, Dec. 6 from 10:30–11:30 a.m. to walk through the system, highlight the updates and answer questions from attendees. This is an opportunity for ARS users to view the system updates before the reporting season and ask any questions they may have. Register to attend via ZOOM.
Facility Changes
Making changes at a facility can impact the ROP eligibility. Operational changes like adding or expanding a process line can lead to additional evaluations to establish whether the facility still qualifies for the ROP. If stopping operations, transferring an air permit to a new owner is a simple administrative process and can have value in the sale of a facility. If the facility will shut down soon and not operate at all during 2024, notify the Air Management program about the closure before the end of the calendar year to avoid being invoiced for the annual fee in 2025. However, if a new owner will restart operations, do not file a closure notification.
Calculating Actual Emissions
The actual annual facility-wide emissions must be calculated for two purposes:
- to demonstrate compliance with air permit eligibility thresholds and other emission limits
- to report to the annual air emissions inventory.
To show continued eligibility with the ROP, at the end of the calendar year, or the end of each month for ROP Types B and G sources, the facility must calculate the actual emissions. All facilities with a ROP must submit an air emissions inventory annually, even if under reporting thresholds.
There are distinct differences between the calculations for ROP compliance and the calculations for submitting emissions inventory reports:
- To demonstrate compliance with the ROP emission limits, use the collection efficiency allowed by the permit for the appropriate control device (see Section G of each ROP).
- Emission units listed in Attachment 1 of ROP Types A, B and G or Attachment 3 of ROP Type C are not required to be included in the calculations used to demonstrate compliance with the ROP emission limits.
- Include air emissions from convenience space heating when the combined heat input capacity exceeds 5 million Btu per hour.
- To calculate the annual emissions for the annual Air Emissions Inventory, use the measured or demonstrated collection efficiency of the device.
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All emission units shall be included in the inventory of annual air emissions, including fugitive dust emissions and emissions from units listed in Attachment 1 of ROP Types A, B and G or Attachment 3 of ROP Type C.
For assistance with actual emissions calculations, review the SBEAP example calculations (SB-301)
IMPORTANT: The U.S. Environmental Protection Agency (U.S. EPA) added 1-bromopropane (1-BP) to the list of Clean Air Act hazardous air pollutants (HAP). All ROP sources must maintain records and calculate actual emissions for the new HAP to demonstrate permit thresholds are met. Review all Safety Data Sheets for 1-BP (CAS# 106-94-5).
Records When Exempt From A Requirement
Facilities covered by a ROP are required to understand which rules in NR 400-499 apply to their operations. Most rules have an applicability or exemption threshold. If a ROP facility is exempt from a requirement, they must maintain records to demonstrate that the facility is below the threshold at all times.
Malfunction Prevention And Abatement Plan
Each facility with a direct or portable source that may emit any amount of hazardous air pollutants or emits more than 15 pounds a day or three pounds an hour of any air contaminant with an emission limit must prepare a Malfunction Prevention and Abatement Plan to ensure the emission limit is met during any malfunction of the equipment.
- Review the rule in s. NR 439.11, Wis. Adm. Code, for details on what to include in the plan.
- Example plans are available at dnr.wi.gov by searching for "malfunction prevention and abatement plan.”
Federal Standards
When a source is affected by a federal New Source Performance Standard (NSPS) or National Emission Standard for Hazardous Air Pollutants (NESHAP) allowed under the ROP, the facility is responsible for understanding and demonstrating compliance with the rule.
- Learn if a rule affects the facility:
- Review lists of the NESHAP and NSPS categories on the U.S. EPA website to determine whether a category fits the facility’s operations.
- The U.S. EPA created compliance guides for many of the NESHAP categories. Each rule has its own set of webpages accessible from the lists above.
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Before each new construction project that could subject the facility to a federal standard, contact the DNR to confirm that this standard is allowed under the ROP.
- If affected by a rule, some tips on demonstrating compliance:
- Include examples of how the facility is complying in the annual monitoring summary report. There are tips in Questions 4 and 5 of the Application Guides for ROP A, ROP B and ROP G, and Question 6 for ROP C. Also, in the Monitoring Summary & Compliance Checklist, form 4530-179.
- Some federal standards require initial notifications and compliance certifications to be sent to the U.S. EPA. Review information on the NESHAP FAQ webpage to determine where to send the certifications.
Keep Facility Contacts Up To Date
It is important to maintain current contact information for facility roles within the Air Reporting System to receive these and other communications from the DNR.
- To update contact information, follow the instructions on the DNR’s Notifying the Air Program about Facility Changes webpage.
- Consider creating a dedicated email address like EHS@xyzcompany.com, Compliance@xyzcompany.com or a group email that allows multiple people to access the messages. This can help ensure the company receives regulatory information, billing and other notifications when staffing changes occur.
Questions
- Questions about compliance requirements can be directed to the facility assigned DNR air compliance engineer. Use the air permit search tool to find the facility, then under “DNR Air Contacts,” look for the staff listed as “DNR Compliance Engineer.”
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General questions about ROPs can be directed to the Registration Program Coordinator.
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Other questions can be directed to the SBEAP at DNRsmallbusiness@wisconsin.gov or 855-889-3021.
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