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Dear Registration Permit Holder:
Your business operation is currently covered by a Registration Operation Permit (ROP) issued by the Department of Natural Resources (DNR) Air Program. The DNR’s Small Business Environmental Assistance Program (SBEAP) and the Air Program work together to provide services and assistance to small businesses. Copies of this and previous reminder emails are available online: https://dnr.wi.gov/topic/AirPermits/Registration.html#tabx5.
Air Emissions Inventory Reporting System Changes For 2023 - Webinar Dec. 8
The DNR will host a webinar on Thursday, Dec. 8 from 10–11 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 reporting season and ask any questions they may have. To register for the webinar, visit https://us02web.zoom.us/webinar/register/WN_ZhhsNlrfQBy8_JfdyRpi9w.
Facility Closure Or Transfer Of Ownership
When a facility closes down, there are multiple issues to take into consideration. If you are planning to shut down soon and will not be operating in 2023 at all, notify the air program before the end of the calendar year to avoid being invoiced for the annual fee in 2024. However, if there is the potential for a new owner to restart your operations, do not cancel your air permit or file the closure notification. Transferring an air permit to a new owner is a simple administrative process and can have value in the sale of your facility.
Reporting Deviations – Due Next Business Day
Facilities are required (s. NR 439.03(4), Wis. Adm. Code) to report any deviation from permit requirements by the next business day. Deviations may include certain malfunctions or other unscheduled events (e.g. accidental release of pollutants) at the source that were not reported in advance. Review the guidance memo on how deviations must be reported.
- Use DNR form 4530-182 in these situations.
- Two examples are provided:
Calculating Actual Emissions
Facilities must calculate actual emissions for two purposes; one is to demonstrate compliance with air permit limits and the other is to report to the air emissions inventory. 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 for the appropriate time period and show continued compliance with the ROP. There are distinct differences between the two calculations:
- 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.
- To calculate the annual emissions for the annual Air Emissions Inventory, use the measured/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, SBEAP provides example calculations in SB-301.
IMPORTANT: U.S. Environmental Protection Agency (US 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 to demonstrate permit thresholds for the new HAP 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.
- Learn more about good record-keeping practices in SB-118.
- Use a spreadsheet to calculate monthly volatile organic compound (VOC) emissions to demonstrate that emissions are below a regulatory exemption. SBEAP provides an example in SB-302.
- Find the information needed on a Safety Data Sheet to calculate VOC emissions, as explained in SB-112.
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 US EPA website to determine whether a category fits the facility’s operations.
- US 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 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 US EPA. Review information on the NESHAP FAQ webpage to determine where to send the certifications.
Keep Facility Contacts Up To Date
To receive these and other communications from the DNR, it is important to maintain current contact information for facility roles within the Air Reporting System.
- To update the Responsible Official information, follow the instructions on Notifying the Air Program about Facility Changes webpage.
- For all other air contacts, facilities can update any new information (Name, Title, Phone, Email, etc.) through the DNR Switchboard.
- Consider creating a dedicated e-mail address like EHS@xyzcompany.com, Compliance@xyzcompany.com or some type of group email that allow multiple people to access the messages. This can help ensure the company receives regulatory information, billing and other notifications when staffing changes occur.
Questions
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