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This reminder email is for facilities currently covered by a registration operation permit (ROP) issued by the 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 in PDF format on the Registration Permit webpage, Compliance Resources tab.
Malodorous emissions
Certain chemical compounds have low detection thresholds which means their odor can be perceived by humans at very low concentrations. A human’s sensitivity to a specific smell differs from person to person, and some odors could cause discomfort to a portion of the population. The DNR frequently receives odor complaints, and facilities are required to address these complaints. In order to simplify the facility’s response to an odor complaint and to document their efforts to control odors, the DNR recommends having an Odor Control Plan.
- Malodorous emissions control regulations are available in NR 429, Wis. Adm. Code.
- Review the SBEAP controlling odors (SB-110) publication for information and suggested best management practices.
Facility expansions
Registration permits allow a facility to add new equipment or make operational changes without having to undergo additional air permitting. However, if a facility plans to expand operations outside the current property or to a building that was previously determined to be a separate operation on the same property or nearby, the plans should be discussed with the assigned DNR air compliance engineer before submitting an application. The DNR will make a determination of whether or not the operations in off-property locations or separate buildings can be covered by the same permit.
- Use the air permit search tool to find the facility, then under “DNR Air Contacts,” look for the staff listed as “DNR Compliance Engineer.”
Maintain records
The facility is responsible for maintaining all records necessary to demonstrate compliance or continued eligibility with the ROP.
- Records must be maintained for at least five years.
- Records might include information such as monthly material usage, calibration of monitoring equipment, control device monitoring logs or a one-time documentation of stack parameters (i.e., height, diameter).
- Regardless of format or storage location, all records must be made available to DNR staff upon request and within a reasonable time period.
- Learn more about good record keeping practices in Recordkeeping: What’s Involved and Why It’s Important (SB-118).
Stack testing
Testing the amount of emissions from exhaust stacks is one method the DNR uses to determine if a facility is meeting requirements. Some sections of the Wisconsin Administrative Code require periodic stack testing.
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. Many ROP facilities have only one contact listed for all four of the contact roles (responsible official, air management, air permit, and billing contact). To avoid missing reports and deadlines, it is recommended that more than one person be listed in the event of staff changes. Or for the air management and permit contacts, consider creating a dedicated email address like EHS@xyzcompany.com or compliance@xyzcompany.com or some type of group email that allow multiple people to access the messages.
- To update the responsible official information, follow the instructions on Notifying the Air Program about Facility Changes webpage. To use the e-Signature function for compliance and permits, the responsible official should request access to Air Compliance, Air Emission Inventory and Air Permit Action submittals.
- For all other air contacts, facilities can update any new information (Name, Title, Phone, Email, etc.) through the DNR Switchboard.
Questions?
- Questions about compliance requirements can be directed to the DNR 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 registration operation permits can be directed by email 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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