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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 on providing services and assistance to small businesses. This email is provided as a general resource for facility contacts. If current on all requirements, there is no action required. Copies of this and previous reminder emails are available online in PDF format.
Volatile Organic Compounds (VOC) Control Requirements
Any facility that emits VOC from materials such as coatings, solvents or mixtures, is responsible for proper handling of materials by taking precautions to prevent spills or other releases to the environment under NR 419, Wis. Adm. Code. In addition, facilities subject to any section in chapters NR 421 to NR 423 shall meet those requirements. Review RACT applicability below for more details.
Facilities that are not subject to any section in chapters NR 421 to NR 423 but operate a process line with organic compound emissions greater than 15 pounds per day, or greater than 30 pounds per day if sprayed in an enclosed booth, must control emissions by meeting one of the following:
- Apply 85% overall control of organic compounds by using air pollution control devices.
- Adopt the Lowest Achievable Control Techniques and operating practices (LACT) conditions included in the ROP (more details included below).
- If operating a surface coating or printing process, the facility can adopt the control requirements in any section from NR 422.05 to 422.155.
RACT Applicability
Activities regulated in chapters NR 421 to NR 423, Wis. Adm. Code, can include surface coating operations, printing, manufacturing of chemicals, coating and rubber products, and solvent cleaning operations. These regulations, also known as Reasonably Available Control Technology (RACT), require process specific VOC controls or emission limits. Some of these regulations only apply in certain counties.
LACT Requirements
A facility with a process line that is not subject to RACT and has emitted more than 15 pounds per day of VOC may elect to operate under an applicable RACT or must either control emissions by 85% or demonstrate LACT. LACT under the ROP is an emissions cap on each organic process line of 10 tons of VOC per year. Certain types of process lines have additional requirements.
- To use the ROP LACT, keep records of VOC emissions from each organic process line to demonstrate compliance with the emissions cap.
- For an explanation of LACT requirements, review information under Part II, Question 1 in the ROP A or ROP B application guides.
- The DNR’s fact sheet, The Organic Compound Rule in NR 424.03 (AM-478), has more information.
Recordkeeping Requirements
A facility that emits VOC shall maintain records that demonstrate compliance with applicable emission limitations and operating requirements. Any facility claiming to be exempt from an emission limitation or other requirement shall maintain records adequate to support each exemption claim. The following records are typically required:
- Name of material/product/solvent
- VOC content in pounds VOC per gallon, or grams VOC per liter, as found on Safety Data Sheet (SDS) or Product/Technical Data Sheet from the supplier
- Amount of material used each day, in pounds or gallons
- Monitoring data from any control device
- Maintenance log of any control device
The ROPs and s. NR 439.04, Wis. Adm. Code, contain specific recordkeeping requirements.
Calibration Of Monitoring Equipment
All instruments used for measuring equipment operational variables (e.g., pressure drop, temperature, air flow) shall be calibrated annually or at a frequency based on good engineering practice as established by operational history, whichever is more frequent. Calibration records shall be retained for a period of 5 years or for such other period as may be specified by the DNR.
- Data transmitters should be calibrated.
- Thermocouple replacement can substitute for calibration of the device.
- Equipment inspections, maintenance and calibration schedule shall be included in a Malfunction Prevention and Abatement Plan (s. NR 439.11, Wis Adm. Code).
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 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 or 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.
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