Are you a manufacturing facility that generates air pollution? Air pollution is generated by activities like: using adhesives, paints, inks, other solvents or solvent containing materials; using a furnace that burns fuels like natural gas, fuel oil, kerosene, or coal; or having any grinding, sanding, welding, material handling, or similar activities that create dust (particulate matter) or fumes. Facilities that generate air pollution are usually required to obtain a permit from the Wisconsin Department of Natural Resources (DNR) to operate. An air pollution permit will identify rules and regulations that apply to the operations to reduce air pollution.

A registration operation permit (ROP) is a new type of standardized air pollution permit that will soon be available from the DNR. Most facilities with emissions of less than 25% of major source levels will be eligible. Under current rules that emission level is at 25 tons per year of pollutants like volatile organic compounds, particulate matter, nitrogen oxides, sulfur dioxide, and carbon monoxide or less than 2.5 tons per year of any hazardous air pollutant. Detailed eligibility criteria will be available online from the DNR in late summer. For more information, check the DNR's website.

DNR will hold public hearings and take comments on the proposed ROP permit template during September, 2005. After making any changes based on the comments, the ROPs should be available for use in October of this year.

What Conditions are in the ROP?
A ROP will contain:

• a cap on facility emissions at 25% of major source thresholds
• requirements for keeping records that will show the facility meets the emission caps
• requirements to operate, maintain, and monitor pollution control equipment (if they have any), and
• annual reporting requirements that include a compliance certification and air emission inventory (AEI) reporting.

What Are the Benefits of a ROP?
Having a ROP rather than a traditional operation permit will give a facility the flexibility to make additions, modifications, and replacements without obtaining construction permits. It doesn't matter how many changes you make, provided you can continue to meet all the eligibility criteria for the ROP.

The proposed annual fee for a ROP will be lower than traditional permits. It also has more flexibility for some record keeping requirements, where a facility would have to keep certain records less frequently than under the traditional permit.

Another benefit is that the ROP does not expire, resulting in less administrative work. The simple web-based ROP application process will reduce both administrative and turn-around time. In most cases, the DNR will make the decision to grant or deny the ROP within 15 days.

What Are the Drawbacks to ROPs?
ROPs do not spell out all the requirements that can apply to a facility. It is the responsibility of the facility to identify what rules might apply. To offset this problem, the DNR is working with the Small Business Clean Air Assistance Program (SBCAAP), here at the Department of Commerce, to develop a compliance assistance program designed to help facilities identify and meet their applicable requirements. This program will include web-based tools, guidance documents, inspection reports, and annual workshops.

What Should I Do If I'm Interested in a ROP?
The DNR will work with Wisconsin Manufacturers and Commerce to conduct training sessions in October, 2005 that will help you through the process. For details on the training sessions, check our Events page later this summer.

--Renee Lesjak Bashel

The newsletter is issued electronically every other month.

Please send comments or questions to Barbro McGinn, editor.