Reminders For Facilities Covered By A Registration Permit

Dear registration operation permit holder:

This facility’s 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 service and assistance to small businesses. Copies of this and previous reminder emails are available online in PDF format.

This email is a general resource for facility contacts; if these reports have been filed, no further action is required. 

Air Emissions Inventory – Due March 1

All facilities covered by a ROP must submit an annual air emissions inventory (EI) report or an Under-Threshold Notification (UTN):

• All emission units shall be included in the EI, including insignificant units and fugitive dust emissions.
• Businesses with air emissions below the reporting thresholds listed in Table 1 of Chapter NR 438 should submit an UTN to notify the DNR their air emissions are below reporting levels.
• The UTN should be generated and submitted electronically within the Air Reporting System (ARS).  
• Before the UTN function is active, submitters must review and update the facility information and contacts in ARS. 
• Starting in 2023, all facilities should report emissions of 1-bromopropane (1-BP). U.S. Environmental Protection Agency (EPA) added 1-BP to the list of Clean Air Act hazardous air pollutants (HAPs) in 2021. Review all Safety Data Sheets for 1-BP (CAS #106-94-5). To calculate emissions, follow the examples for other coating related HAPs on the HAP Emissions tab in the spreadsheet SB-301.

Resources to help with submitting the EI or UTN can be found on the Tutorials webpage. For direct assistance, contact the facility-assigned DNR compliance engineer - refer to the Questions information below. Requesting an extension of the March 1 deadline must be done within ARS, do not email the compliance engineer or emissions inventory or ROP coordinators. 

Annual Permit Compliance Certification And Annual Summary Of Monitoring – Due March 1

Facilities covered by a ROP must submit an annual summary of monitoring and compliance certification to DNR for each calendar year’s operations.     

These reports shall include enough information to determine the compliance status of the source with each applicable permit condition.

• The DNR developed the Annual Compliance Certification form (Form 4530-178) for facilities covered by a ROP, which also serves as the annual summary of monitoring report. Use of this form is not mandatory. However, any report submitted by the facility must meet the requirements discussed above.
• The report can be submitted and signed electronically; follow the instructions under “Electronic reporting” below. If the facility uses their own format, all compliance documents should be combined and submitted as a single report.

• The annual compliance certification report and Under-Thresholds Notification are two different compliance requirements that shall be submitted separately. Refer to the previous section for the UTN submittal procedure.
• The responsible official is required to certify whether compliance was continuous or intermittent for each condition. All deviations from, and violations of, any requirement shall be identified in the report.
• Additional assistance determining compliance, including examples and links to resources, can be found in Form 4530-179. This form is not required to be submitted to the DNR and is not a substitute for Form 4530-178.

Electronic Reporting

Online reporting streamlines the process through use of the DNR Switchboard and Air Reporting System. The electronic signature for reports is only available to the facility’s responsible official.

• The facility’s responsible official, air management contact and any delegated reporters must obtain a Web Access Management System (WAMS) ID to access the DNR Switchboard.
• Next, facility contacts need to request access to the compliance and air emission inventory roles to file reports electronically.
• Learn about all electronic submittal options on DNR’s Compliance Reporting webpage.

Keep Facility Contacts Up To Date

To receive these and other communications from 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 email 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

• Questions about these reporting requirements can be directed to the 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.”
• General questions about ROPs can be di­rected to the registration program coordinator at DNRAMROPSAIRPERMIT@wisconsin.gov.
• Other questions can be directed to the SBEAP at DNRsmallbusiness@wisconsin.gov or 855-889-3021.