Air Matters, October 2008

Volume 3, Issue 5

Bureau of Air Management
Wisconsin Department of Natural Resources
PO Box 7921
Madison WI 53707

• Sources Affected by Vacated Boiler MACT Should Submit Permit Applications
• FET Seminar: DNR Information Technology Improvements and Other Air Pollution Updates
• New Air Permit Search Tool Available Online
• Air Program Guidance and Policy Now Available Online
• Air Quality Education for Wisconsin’s K-12 Teachers
• Wisconsin Company Reduces CO2 Emissions

Sources Affected by Vacated Boiler MACT Should Submit Permit Applications
By Roger Fritz

Boilers and process heaters at major sources of hazardous air pollutants were subject to regulation under the Clean Air Act (CAA), National Emission Standards for Hazardous Air Pollutants (NESHAP), commonly known as the Boiler MACT (maximum achievable control technology). However, on July 31, 2007, EPA’s Boiler MACT was vacated by the D.C. Circuit Court of Appeals. Now, many regulatory officials including EPA, feel that the absence of the Boiler MACT triggers the requirement of s. 112(j)(2) of the CAA which generally requires affected facilities to submit a permit application for a case-by case MACT determination. Under the 112(j) requirement, the latest date for submittal of an application would be 18 months after the Boiler MACT was vacated.

The Department of Natural Resources is developing an application form for sources affected by vacatur of the Boiler MACT. The form will be available by early 2009 to help sources demonstrate compliance with section 112(j)(2) of the CAA. The Department will process these applications in accordance with EPA rules and any further guidance provided by the agency. The Department strongly recommends that any major source of federal hazardous air pollutant (HAP) emissions that operates a boiler or process heater complete the application and submit it to the DNR Bureau of Air Management by January 27, 2009. This includes sources that only burn gaseous or liquid fuels that had no substantive requirements under the vacated EPA rule.

In the absence of current guidance from EPA, the National Association of Clean Air Agencies (NACAA) has collected stack test data from its members and provided NACAA Model Permit Guidance [exit DNR]. This guidance should save permit authorities from the redundant effort to research multiple data bases, and should provide some national consistency in the case-by-case MACT determinations for affected boilers. The data suggests in most cases the emission standards for case-by-case MACT will be significantly more stringent than the vacated EPA rule. Also, the “low-risk” or “health-based” alternative for hydrogen chloride and Manganese emissions, which the courts have vacated in another MACT, is not available under the NACAA model permit guidance.

The implications of the more stringent NACAA model permit guidance, which is based on far more data than EPA considered in the vacated rule, is that additional sources, including sources with affected natural gas-fired or fuel oil-fired boilers or process heaters, may want to cap HAP emissions to avoid application of more stringent requirements under a s. 112(j) case-by-case MACT. Sources interested in capping their emissions should include with their s. 112(j) application, a request to limit facility-wide HAP emissions below 10 tons per year for any individual HAP and below 25 tons per year for all HAPs. Sources may also submit additional emissions data, beyond that considered in the NACAA guidance, which the sources would like to have considered during the case-by-case MACT determination process.

For more information on this topic, please contact Roger Fritz at 608/266-1201; or Roger.Fritz@Wisconsin.Gov.

Fritz is the MACT Team Leader in the DNR’s Bureau of Air Management and is located in Madison.

FET Seminar: DNR Information Technology Improvements and Other Air Pollution Updates
By Renee Bashel

DNR and Commerce have partnered with the Federation of Environmental Technologists, Inc (FET) to provide a series of seminars around the state in late October and early November. The seminars will provide insights into the DNR's new air permit on-line application system as well as the air emission inventory and hazardous waste reporting system. Anyone attending the upcoming seminars will be among the first to gain access to the new system and be able to submit applications electronically. The seminars will be offered at 5 locations around the state. To view exact dates and locations and to register, please see the FET Seminar Agenda [exit DNR].

Please note that FET will not offer their usual Air Issues Updates in January 2009. Don't miss this opportunity to learn about DNR's new permit application and reporting systems, and other key air pollution topics.

Bashel works in the Small Business Clean Air Assistance Program at the Wisconsin Department of Commerce in Madison.

New Air Permit Search Tool Available Online
By Autumn Sabo

Is your company anxious to learn the status of a permit application? Are you a citizen interested in learning which local businesses have, or are applying for, an air permit? Are you part of the environmental community wanting to stay current on air emission sources? Information on air permits has always been available by either searching the internet or contacting your DNR regional office, but now the process is even easier. In order to facilitate public access to information on air permits, DNR’s Air Management program has unveiled a new online Permit Tracking Search site.

You can search for permits a variety of ways such as:

• Facility Identification Number (FID)
• Facility name or address
• County or DNR region
• Dates
• Permit milestones (e.g. application received in full, public notice published)
• Type of Permit (e.g. operation permit, construction permit, registration permit)
• Type of Facility (e.g. by industry classification codes)

After searching and selecting a permit to view, available information will be displayed including the search criteria listed above, facility description, and contacts for the facility and DNR. You can then download related documents including draft and approved permits, public notices, and other correspondence.

The DNR strives to be transparent in its actions and is required to allow public access to its records to comply with the Freedom of Information Act. The new online Permit Tracking Search will be a useful tool for anyone who wants to keep informed about air permits.

For more information on the Permit tracking Search tool, please contact Barb Pavliscak at 608/267-7540; or Barbara.Pavliscak@Wisconsin.Gov.

Sabo is a writer in the DNR Bureau of Education and Information and is located in Madison.

Air Program Guidance and Policy Now Available Online
By Autumn Sabo

A new tool is now available on DNR’s web -- a database of procedural and technical guidance, policies, contacts, and web links related to the air program in one easy-to-use site. The DNR hopes that this new tool will improve the efficiency by streamlining both customers’ and air program staff’s searches for information. Prior to this new system, relevant air program guidance and policy documents were either scattered on the web or simply unavailable online.

The Guidance and Policy tool contains a wealth of detailed information on everything from air quality management acronyms to stack test requirements for certain industries. The tool has a detailed table of contents and can be searched in multiple ways including by key words, pollutants, code/regulation, or published date.

This dynamic tool allows companies with permitting and compliance questions to find answers quickly and should lead to greater consistency across permitted facilities, DNR regions, and specific industries. It will also save DNR staff time as they too can access necessary air program related information more efficiently. Please access Air Program Guidance and Policy to view the new tool.

Sabo is a writer in the DNR Bureau of Education and Information and is located in Madison.

Air Quality Education for Wisconsin’s K-12 Teachers
By Mary Hamel

Across the state, Wisconsin teachers spend part of their summer brushing up skills, gathering ideas and classroom materials, and earning graduate credits at a series of Teacher Academies. Each year air quality educators visit two of the academies to bring teachers resources they use to help their students learn about Wisconsin’s resources and environment. For the last three summers, Wisconsin DNR’s environmental education program has been the course of choice at these Academies. DNR’s air quality educators join other DNR educators in putting on week-long courses, incorporating lecture, hands-on activities, field trips and teaching practice.

Learning about bioaccumulation of mercury in the Great Lakes.

This past June, at the Sally Ride Academy in West Allis, 28 teachers participated in the course “Explore the Great Lakes.” Air educators Lindsay Haas and Mary Hamel spent an afternoon with the teachers exploring how the Great Lakes affect air quality and how air pollution affects the Great Lakes. The teachers came away with activities and materials to use in their own classroom.

At the Northwoods Academy in Rhinelander in August, 23 teachers took the course “Explore Nature While You Teach and Learn.” Academies around the state have been strongly requesting that DNR bring them this popular workshop, which includes a variety of hands-on air activities and an introduction to all our air educational materials.

Air Education material is also available on DNR’s web site.

Additional Information

• Sally Ride Academy [exit DNR]
• Northwoods Academy [exit DNR]

For more information on air education, please contact Mary Hamel at 608.267.7409 or e-mail Mary.Hamel@Wisconsin.Gov.

Hamel is a Natural Resources Educator with the Bureau of Education and Information and is located in Madison.

Wisconsin Company Reduces CO2 Emissions
By Ed Jepsen

The Governor’s Global Warming Task Force recently issued a recommendation to increase the use of renewable energy. However, renewable energy comes at a higher price and businesses usually have to pay a premium to voluntarily purchase it. Despite the premium, Coating Excellence International (CEI), a manufacturer of flexible packaging, recently signed an agreement to purchase renewable electrical energy from the Wisconsin Public Service (WPS) NatureWise® program. This agreement between CEI and WPS represents the largest quantity of NatureWise®, renewable energy purchased in the WPS service territory.

This NatureWise purchase will result in 30% of CEI’s electrical energy coming from renewable sources. This commitment to renewable energy will reduce CEI’s CO2 emissions by more than 8,640 tons per year.

George Fickau, Manager of Sustainable Packaging at CEI, said, “CEI’s purchase of renewable energy from WPS, our local provider, enforces our commitment of being a responsible manufacture to customers, employees, and local communities.”

Ed Jepsen, the Voluntary Emission Reduction Registry coordinator, said, “We are glad to work with companies like CEI because they demonstrate that companies can provide high quality products, good jobs and reduce their emissions of greenhouse gases and other pollutants too. CEI’s purchase of renewable energy and adoption of energy efficiency measures is helping Wisconsin move toward lower carbon emissions.”

CEI has 650,000 square feet of manufacturing space in Wrightstown and has over 400 employees. CEI’s environmental innovation, leadership and use of environmentally clean production technologies earned them a 2007 Wisconsin Business Friend of the Environment Award from the Wisconsin Environmental Working Group, an affiliate of The Wisconsin Manufacturers and Commerce. CEI is also a member of EPA’s Leadership Club.

CEI goals include:

• Achieve carbon-neutrality for their energy inputs by year-end 2009
• Increase employee and customer awareness of sustainability solutions through education and leadership by example
• Participate in nationally-recognized carbon registry programs
• Provide guidance to not-for-profit trade organizations with environmental and sustainability focused agendas

For more information about CEI, the NatureWise program or voluntary emissions reductions, please contact these individuals:

George Fickau, CEI, 920.843.1193 or 920.996.1956

Chip Bircher, WPS NatureWise, 920.433.5518

Ed Jepsen, DNR, 608.266.3538

 

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