On February 23, 2016, the Wisconsin Department of Natural Resources (WDNR) finalized a Type B Registration Operation Permit (ROP) for qualified stationary sources with criteria pollutant and hazardous air pollutant (HAP) emissions that do not and will not exceed 50% of the major source thresholds, except for lead emissions.  Facilities qualify for the Type B ROP if their emissions remain below the following emission thresholds:

  • 50 tons per year for particulate matter with an aerodynamic diameter less than or equal to 10 micrometers (PM10);
  • 50 tons per year for sulfur dioxide (SO2);
  • 50 tons per year for carbon monoxide (CO);
  • 50 tons per year for nitrogen oxides (NOx);
  • 50 tons per year for volatile organic compounds (VOC);
  • 0.5 tons per year for lead;
  • 5 tons per year for single HAPs; and
  • 12.5 tons per year for all HAPs.

The WDNR already has a Type A ROP for qualified sources that do not exceed 25% of major source thresholds for criteria pollutants and HAPs.  Other than the items listed below, the new Type B ROP enjoys many of the same benefits of the Type A ROP:  less fees due to the freedom to make certain changes at the facility (e.g., construct, modify, or replace equipment) without a construction permit, revision, or renewal as long as the facility continues to meet all conditions of the ROP afterwards, simpler permit application, faster WDNR response regarding permitting, and less frequent monitoring and recordkeeping.

In addition to the higher facility-wide emissions limits in the Type B ROP, the Type B ROP is different than the Type A ROP in the following ways:

  • Rolling 12-month totals are used rather than calendar year totals for facility-wide emission limits;
  • Facility emissions must be calculated on a monthly basis, rather than an annual basis;
  • Type B ROP has facilities conduct air quality analyses for PM10, rather than total suspended particulate (TSP);
  • An air quality analysis is also required for facilities with maximum controlled emissions of 25 tons per year or more of nitrogen dioxide (NO2) and SO2;
  • Specific WDNR-prescribed emission calculation methods must be used;
  • Acceptable monitoring techniques for baghouses and cartridge collectors includes baghouse leak detection systems; and
  • Latest Available Control Techniques (LACT) for coating process lines includes flow coating.

The WDNR has a Type B Registration Permit Fact Sheet that contains helpful information about this new registration operation permit type.  If you have any questions about the Type B ROP or want to discuss if your facility might benefit from this new permit type, please contact Jon Frost at (651) 275-9900 x6.