Wisconsin Air Permitting Issues

Written October 17, 2019

Wisconsin has developed the General Operation Permit (GOP), General Construction Permit (GCP) and Registration Permit for the printing industry, both which cover screen and digital printing operations. These permits allow screen and digital printing industries an easy to understand and a fast and straight-forward way to obtain an air permit that also offers increased operational flexibility.

Printing operations are however qualified for exemption from the General Permits if they emit at or below certain emission limits. In order to qualify for exemption from the GOP, the operation must emit 10 tons/year or less of PM, Sulfur dioxide, CO, Nitrogen oxides, VOCs, and 0.5 tons/year or less of Lead. In order to qualify for exemption from the GCP, the operation must emit 1,666 pounds/month or less of PM, Sulfur dioxide, CO, Nitrogen oxides, VOCS, and 10 pounds/month or less of Lead.

A registration permit allows small emitters to quickly register themselves for a permit in return for keeping emissions low. The permits contain facility-wide emission caps as well as monitoring, recordkeeping and reporting requirements. Registration permits use an On-Line Application and Tracking System that ensures a review time of no more than 15 days on all applications received by the DNR. There are two types of registration permits.

Type A Registration Permit - available for qualifying facilities that have emissions below 25 tons per year of each criteria pollutant, 2.5 tons per year of each federal hazardous air pollutant, 6.25 tons per year of all federal hazardous air pollutants combined, and 0.5 tons per year lead.

Type B Registration Permit - available to stationary sources with emissions that do not and will not exceed 50% of the major source threshold, except for lead emissions. The eligibility threshold stands at 50 tons of VOC per year or 0.5 tons of lead per year, or 12.5 tons of totally federally regulated HAP per year. Type C Registration Permit - available only for qualified printing facilities that have emissions below 25 tons per year VOC, 5 tons per year of each federal hazardous air pollutant, 12.5 tons per year of all federal hazardous air pollutants combined, and 0.5 tons per year lead. It contains permit conditions specific to the printing industry.

The state's program does contain provisions for a synthetic minor designation. Synthetic minors are those facilities that agree to federally enforceable limits that restrict their potential to emit to less than the major source threshold. Wisconsin has implemented the Green Tier Program that is a voluntary environmental rewards program where facilities exceed the legal requirements to better the environment.