Detailed Analysis of Wisconsin Air Quality Regulations: CAA Assignment

This document presents solutions to a CAA assignment focusing on Wisconsin's air quality regulations. The assignment addresses various aspects of air quality control, including the definitions of PM10 and PM2.5, fugitive emissions, and the role of RACT emission limitations. It explores the requirements for sources in nonattainment areas, the air quality control regions, and the standards for criteria pollutants. The assignment also delves into construction permits, innovative control technologies, and the regulations for major stationary sources in attainment areas, including Class I and Class II increment analysis. Furthermore, it examines hazardous air pollutants, ozone transport regions, and emission fees, providing a comprehensive overview of the regulations. Finally, the document also covers the frequency of emission inventories and the control of specific air pollution emissions.

CAA Assignment
Question 1: Using the definitions of PM10 and PM2.5, what is the difference between PM10 and
PM2.5?
Answer: PM10 can be defined as a particulate matter with an aerodynamic diameter less than or
equal to a nominal 10 micrometers as measured in the ambient air for measuring mass
concentration of particulate matter.
1. Quality Assurance Handbook for Air Pollution Measurement Systems, Volume I, Principles.
EPA-600/9-76-005, March 1976. Available from CERI, ORD Publications, U.S. Environmental
Protection Agency, 26 West St. Clair Street, Cincinnati, OH 45268.
2. Quality Assurance Handbook for Air Pollution Measurement Systems, Volume II, Ambient
Air Specific Methods. EPA-600/4-77-027a, May 1977. Available from CERI, ORD Publications,
U.S. Environmental Protection Agency, 26 West St. Clair Street, Cincinnati, OH 45268.
PM2.5 means particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5
micrometers as measured in the ambient air for measuring mass concentration of particulate
matter.
Quality Assurance Guidance Document 2.12. Monitoring PM2.5 in Ambient Air Using
Designated Reference or Class I Equivalent Methods. U.S. EPA, National Exposure Research
Laboratory. Research Triangle Park, NC, November 1988 or later edition. Currently available
at: http://www.epa.gov/ttn/amtic/pmqainf.html.
Question 2: When a source determines its potential to emit a contaminant, are restrictions on
hours of operation considered a limitation on the capacity of the source to emit an air
contaminate?
Answer: Any physical or operational limitation on the capacity of a source to emit an air
contaminant, including air pollution control equipment and restrictions on hours of operation or
on the type or amount of material combusted, stored or processed, shall be treated as part of its
design if the limitation is enforceable by the administrator.
https://docs.legis.wisconsin.gov/code/admin_code/nr/400/400/02/127.
Question 3: What is a fugitive emission?

CAA Assignment
Answer: Fugitive emission means an emission from any emission point within a facility other
than a flue or stack.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20400.02 (71).
Question 4: In Wisconsin those sources that are listed in or near a nonattainment area that must
comply with RACT emission limitations must meet the limitations specified in which chapters of
the Wisconsin Administrative Code?
Answer: Chapters NR 415 to 418 as specified in Wisconsin Administrative code states that the
sources that are listed in or near a nonattainment area, must comply with RACT emission
limitations.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20401.025 (2).
Question 5: In what air quality control region is UW‐Whitewater?
Answer: UW- Whitewater is listed in The Southeastern Wisconsin Intrastate Air Quality Control
Region.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20404.03 (2) (b).
Question 6: Are the ambient air quality standards for the criteria pollutants the same in
Wisconsin as the rest of the country? If not, which ones are different?
Answer: The air quality standards for the criteria pollutants are not same Wisconsin as compared
to rest of country because of variation in population, transportation, and industrial densities, in
addition to variation in terrain and meteorology, equal air quality may not be achieved
throughout a region or area. The different region includes Minnesota, Illinois, and Dubuque.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20404.03 (2).
Question 7: No major stationary source or major modification in an attainment area may begin
actual construction unless the requirements of 405.08 to 405.16 have been met. What are those
requirements/titles of those chapters?
Answer: Requirements for beginning construction in an attainment area which fall under
requirements listed in 405.08 to 405.16:-

CAA Assignment
 Control technology review
 Source impact analysis
 Air quality models
 Air quality analysis
 Source information
 Additional impact analyses
 Sources impacting federal Class I areas — additional requirements
 Public participation
 Source obligation
https://docs.legis.wisconsin.gov/code/admin_code/nr/400/405/08.
Question 8: A major stationary source in an attainment area may use innovative control
technologies, if they follow the Wisconsin Administrative code requirements for innovative
control technologies, instead of which type of control technologies listed in the book?
Answer: the determination of best available control technology shall be reviewed and modified
as appropriate at the latest reasonable time which occurs no later than 18 months prior to
commencement of construction of each independent phase of the project. At such time, the
owner or operator of the applicable stationary source may be required to demonstrate the
adequacy of any previous determination of best available control technology for the source.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20405.08 (4).
Question 9: If a major stationary source is located 15 miles from the geographic center of the
Forest County Potawatomi Class 1 area, must the major source meet Class I or Class II
increment analysis and maximum allowable increase levels?
Answer: A major stationary source is located 15 miles from the geographic center of the Forest
County Potawatomi Class 1 area, are subjected to an increment analysis and limited to the
maximum allowable increase levels of a Class I area.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20405.19 (2).
Question 10: Why is a construction permit sometimes required?
Answer: For using indirect sources, sometimes construction permit is required.

CAA Assignment
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20406.01(1).
Question11: Does a direct source that is not required to obtain a construction permit under ch.
NR 405, 408 or 446.03 (2) (a) need to obtain a construction permit if the project is to replace an
external combustion furnace that only burns wood at a rate of 2.0 million Btu per hour?
Answer: In the above-mentioned scenario, no construction permit is required as it complies with
the regulations and the emissions are limited within 5.0 million Btu per hour.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20406.04(1)(a)2.
Question 12: Do the amounts of hazardous air pollutants in the definition of a major source in
the Wisconsin Administrative code match the federal amounts of hazardous air pollutants?
Answer: No, the amounts of hazardous air pollutants in the definition of a major source in the
Wisconsin Administrative code and the federal amounts of hazardous air pollutants does not
match as trading of emissions increases which decreases at the stationary source.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20407.025(2)(a).
Question 13: Can a source that has the potential to emit only 12 tpy of vinyl chloride (and no
other air pollutants) qualify for a natural minor source exemption? Defend your answer and
include the citations for all portions of your answer.
Answer: Yes, vinyl chloride qualify for a natural minor source exemption as
 Is not a major stationary source and is not a major source
(https://docs.legis.wisconsin.gov/document/administrativecode/NR%20407.02(4m)(a)).
 Is not a synthetic minor source under this chapter and does not have a permit containing
conditions that allow the source to avoid being either a major stationary source or a major
source (https://docs.legis.wisconsin.gov/document/administrativecode/NR
%20407.02(4m)(b)).
 Is not a part 70 source (https://docs.legis.wisconsin.gov/document/administrativecode/NR
%20407.02(4m)(c)).
Question 14: What is an ozone transport region? Why is it included under chapter NR 408?

CAA Assignment
Answer: All new direct major sources and all major modifications to direct major sources
located in areas are referred to as ozone transport regions.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20408.01(1).
Question 15: There are fees associated with applying for and receiving a permit. How much is
the initial fee submitted with the application for a person submitting an application for an
individual construction permit for a direct source?
Answer: 300$.
https://docs.legis.wisconsin.gov/document/statutes/285.69(1d).
Question 16: An annual emission fee is required to be paid to the DNR for air contaminates
listed in Table 1 of s. NR 438.03 based on the actual emissions recorded in the annual emission
inventory. When should the annual emission fees be paid to the department?
Answer: The annual emission fees should be paid in preceding year.
https://docs.legis.wisconsin.gov/document/statutes/285.69(2)(e).
Question 17: There are entire chapters dedicated to the control of specific air pollution
emissions. Which chapter is dedicated to particulate emissions?
Answer: Chapter NR 415 is dedicated to particulate emissions.
http://docs.legis.wisconsin.gov/code/admin_code/nr/400/415/04.
Question 18: How often does a person owning or operating a facility that emits air contaminates
at quantities above applicable reporting limits need to submit an emission inventory of actual
emissions?
Answer: Any person owning or operating a facility that emits an air contaminant in quantities
above applicable reporting levels, except indirect sources of air pollution, shall annually submit
to the department.
https://docs.legis.wisconsin.gov/document/administrativecode/NR%20438.03(1)(a).