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Complying with the regulations

Environmental regulations established by Wisconsin Department of Natural Resources or U.S. Environmental Protection Agency all have procedures by which a business has to demonstrate to the agencies that it meets each of the requirements. When the DNR or the EPA perform an inspection or request records and find you are not in compliance with any requirement, you can be found in violation and can face an enforcement action by one or both agencies. The following fact sheets and tools are intended to help you comply with the requirements.

The SBEAP staff provide a basic level of expertise with environmental regulations. We partner with other programs and organizations that have additional expertise in environmental regulation and pollution prevention. The links provided below will take you to other web sites with information or contacts that may help you understand environmental regulations or help you find ways to reduce emissions and improve your environmental performance overall. In addition, there are resources to help you minimize your liability by conducting audits of environmental requirements.

Preparing to file reports

Facilities may be required to file permit applications or other reports or notifications with other agencies to meet their environmental obligations. Some reports do not have an online option, but many of those will be electronic soon. Spills reporting must be done immediately upon finding a reportable spill volume. It can take time to gain access to reporting systems for EPA, Wisconsin Emergency Management (WEM), and others. Before a deadline is imminent, be sure to have all the required logins set up for any staff or officials for your company that will be required to file or certify or sign off on the submittals.

EPA electronic systems

Facilities will need access to MyRCRAid for waste reporting and notifications and to TRI-me for the annual Toxic Release Inventory reports.

MyRCRAid Online Application

Enrollment in MyRCRAid allows facilities to prepare and submit initial and subsequent notification forms electronically and requires a registration process that uses an electronic signature. Once the registration is complete, approval as a Wisconsin user is typically granted within one to three business days by receipt of a confirmation email. Once you have received this confirmation, the MyRCRAid application can be used notify the DNR of waste activities and obtain an EPA ID number by completing the 8700-12 form. MyRCRAid allows site managers to view, create and electronically sign manifests in e-Manifest.

TRI Reporting

To gain access to the Toxic Release Inventory report system, the facility will need a user account for EPA's Central Data Exchange (CDX). Anyone, whether staff or a consultant, can set up a user account to enter data but the facility's Responsible Official must have an account to complete the final certification of the report. Tutorials are available for both the CDX account set up as well as filing out the TRI report at: Electronic Submissions of TRI Reporting Forms.

Wisconsin Emergency Management reports

The Emergency Planning and Community Right to Know (EPCRA) requirements include a chemical inventory report filed with Wisconsin Emergency Management (WEM). WEM uses an online system called Wisconsin Hazmat Online Planning and Reporting System (WHOPRS) to collect the information for that report. WHOPRS is accessed through a separate application. Only one account is needed for a facility. Forms and resources are available as well, including a short guide to explain who is required to report: WDMA Forms and Resources.

Other agencies' regulatory programs and requirements

Those responsible for their company's environmental requirements may also be responsible for things like chemical inventory and emergency response, as well as their worker's safety programs. DNR does not enforce those programs, but the following resources can help you find out what is required:

Environmental, health and safety assistance providers

Environmental assessments, audit policies and consulting resources

There are programs available that may help to limit your liability if you conduct an audit and find areas that do not comply with environmental regulations; you may want to review the DNR and EPA compliance audit policies to see if you are eligible first. Unfortunately, assistance with environmental audits and other compliance services are usually NOT available as a free resource. You need to hire a professional to focus on your individual business needs. The SBEAP has provided a list of environmental consultants with offices in Wisconsin, but the program has not evaluated any claims regarding their ability to provide the listed services.

  • DNR's Enviro-Check Program — Available to businesses that follow the steps required by statute, as explained on the webpage.
  • The EPA has a general Audit Policy as well as a specifically designed Small Business Policy.
  • Basic Elements of Phase I and II Environmental Site Assessments (SB-007) — Development on an old commercial or industrial site should be preceded by a Phase I ESA to determine if there is any contamination of the site. If contamination is found, then a Phase II ESA would determine the extent of contamination.
  • Before purchasing property you may need to know more about the history of the site to ensure you are not disturbing an important resource. The Wisconsin Historical Society has a list of Historic Preservation and Archaeological consultants available.
  • Tips on Hiring an Environmental Consultant (SB-005) — A brief overview on what to look for and questions to ask when seeking the services of an environmental consultant for your air pollution issues.
  • Consultants List (SB-004) — A partial listing of Wisconsin companies that provide environmental consulting services to small businesses. The specific services they provide are identified, including emissions inventory reporting, stack testing, air permit applications, air dispersion modeling, hazardous waste, soil remediation, wastewater and storm water.

National compliance assistance resources

There are many compliance assistance links available from federal as well as other state and local sources. We will attempt to provide as many as seem useful to small businesses.

National industry sector-based resources

EPA supported National Compliance Assistance Centers help businesses, colleges and universities, local governments, tribes and federal facilities understand and comply with environmental requirements and save money through pollution prevention techniques. The Compliance Assistance Centers offer easy access to plain-language materials and other resources on environmental compliance.

EPA also assists certain business sectors through the Smart Sectors Program. EPA's Smart Sectors include aerospace, agriculture, automotive, cement, chemical manufacturing, concrete, construction, electronics and technology, forestry/paper/wood products, iron and steel, mining, oil and gas, ports and maritime transportation, and utilities and power generation.

The following are some resources to help you manage air pollution requirements.

Filing permits and reports

Before filing documents with DNR, facility contacts should be sure to have a Wisconsin User ID set up for the Web Access Management System, which is also called your WAMS ID. To get started, go to the DNR's Switchboard Instructions webpage. You can print off initial instructions that may be helpful to follow along as you go through the process. Refer to the FAQ on the Instructions page if you get stuck.

While setting up your WAMS ID, request access to all the systems you think you may need access to for reporting or future permit applications. Its best to have it set up in advance of any deadlines.

The following table includes common reports and notifications for the air program. Links in the first column will open up fact sheets or other descriptive information about the report/notification/certification. Submittals still filed with fillable PDF forms will have a link in the Forms column. Others will be available through the Switchboard and selecting the respective program access links. Additional instructions or tutorials/training are linked in the last column.

DNR Reports & Notifications Deadline Access Forms Training/Resources
Air Permit Certification (AM-529 and AM-536) Jan 31 – March 1, as written in permit Fillable PDF, submit via Switchboard ROPs 4530-178
Others 4530-184

Instructions for 4530-178

Air Compliance Submittal Actions Electronic Reporting

Air Permit Monitoring Summary (AM-529 and AM-537) Jan 31 - March 1, as written permit Switchboard Facility documents in PDF; ROP optional 4530-179 Instructions for 4530-179
Air Emissions Inventory Report or Under-Threshold Notification March 1 Switchboard   Help with Online Monitoring Report Forms
Environmental Fees Due May E-pay   Air fees, Waste generator fees, Storm water fees
Air Emissions Certification (AM-529) July 1 Switchboard   Air Emissions Inventory (EI) - Generating and Submitting an EI Certification
Air Permit - Next Day Deviation Report (AM-591) Next business day following discovery of deviation Fillable PDF, submit via Switchboard 4530-182 Example 1
Example 2

The following table lists the most common and most likely permits required by a printing facility to operate in compliance with the requirements. The first columns have links to resources and information to explain the permit or exemption criteria. The last column has links to instructions or online submittal portals for the specific permit or exemption to be filed. Where the application forms are fillable PDFs, there will be a link in the Forms column.

Permits/ Exemptions Eligibility Access Expiration/renewal Forms Process/Resources
Air Pollution Permit Exemption Range of eligibility thresholds Fillable PDF, submit via email No expiration or renewal. Apply for permit if no longer eligible AM-597
AM-593
4530-100
1. Review thresholds
2. Complete exemption checklist
   - Operation Permit exemption AM-597
   - Construction Permit exemption AM-593
3. File exemption request/notification
Air Pollution Construction Permit Any new air pollution source, needs a permit if not exempt Fillable PDF, submit via email 18 months, with 18-month extension upon request AM-592
AM-594
AM-595
4530-100 thru 4530-135 as needed
1. Review construction
2. Complete permit revision
  - Construction permit revision AM592
  - Major construction permit AM594
  - Minor construction permit AM595
3. Submit permit application and pay application fee
4. Start construction when permit issued and pay remainder of review fee
Air Pollution Registration Operation Permit ROPA - 25% major ROPB - 50% major ROPC - Printer specific
ROPG - Green Tier source, 80% major Eligibility details
Fillable PDF, submit via email Permanent until source no longer eligible 4530-156 /a>
4530-183
4530-172
4530-185
1. Review ROP options
2. Review ROP application guide for type selected
   - ROP A guide AM-539
   - ROP B guide AM-546
   - ROP C guide AM-582
   - ROP G guide AM-569
3. Complete application
4. Pay $400 annual fee when invoiced
Air Pollution Operation Permit Any existing air pollution source needs permit unless exempt. Permit may need revision or renewal. Fillable PDF, submit via email Check permit for expiration. Synthetic minor usually do not expire. AM-578
AM-598
4530-100 thru 4530-135 as needed
1. Review process for revisions vs renewal applications
2. Complete permit checklist
   - Renewal checklist AM-578
   - Revision checklist AM-598
3. Submit permit application
4. Pay annual fee when invoiced
   - Major source fees
   - Minor source fees

Fugitive dust control

"Fugitive dust" is a term used to describe any particulate matter (PM) emissions released through any means other than a stack or duct of some kind. Any business creating enough dust, smoke or fumes to be a noticeable source of air pollution must control those emissions. The following are examples of activities that would create fugitive dust:

  • large trucks transporting materials along unpaved roads;
  • unpaved parking lots;
  • piles of materials stored on site, like grain; and
  • dry materials directed to equipment not collected by another device, whether by baghouse, cyclone, wet scrubber, etc.

Any business that creates fugitive dust must do as much as possible to control those emissions and keep them from escaping into the environment. The following are a few suggestions based on the type of activity. Other best management practices recommended by industry experts are provided in the fact sheet Fugitive Dust Management (AM-556).

  • For roads or storage piles, this may mean using water or chemicals to prevent dust plumes. Paving roads will reduce dust. Storage piles can be kept within a three-sided building to minimize emissions.
  • To know how much of an additive is allowed in water for dust prevention, refer to the storm water standards for Water quality review procedures for additives, and the two companion documents: Allowable usage rates for water applied additives and Allowable usage rates for land applied additives.
  • Mechanical collection devices (i.e., cyclones and dry filters) are effective, low-cost ways to control PM emissions from processing equipment. Unfortunately, higher collection efficiency in any type of equipment can often mean higher costs. For example, a baghouse can be a very high efficiency control option but is more expensive than the others.

Document your compliance actions

  • Recordkeeping: What's Involved and Why It's Important (SB-118) — Do you need to maintain records even when you don't need a permit? Yes. Find out what you need to do by reading this fact sheet.
  • Facilities with VOC emissions may be required to maintain monthly, 12-month rolling average, or daily records. The following spreadsheets have example calculations for these requirements:
  • Annual emissions calculations (SB-301 [XLSX] – Calculate emissions at the end of the year for permit compliance, completing the air emissions inventory report or Under-Threshold Notification.
  • Monthly Emissions Example Calculations (SB-302) [XLS] — Examples of how to calculate monthly emissions for a range of operations. The file will download onto your computer.
  • A DNR Air Program Inspector is Coming... What Can I Expect? (SB-120) — A fact sheet describing the things you might expect during an inspection and some items you should be prepared with upon the arrival of the inspector.
  • Dust, Smoke and Fumes — Particulate Matter Emissions (SB-111) — This fact sheet summarizes the air pollution requirements for those sources with particulate matter emissions and discusses some of the ways to reduce those emissions as well.
  • Controlling Odors (SB-110) — A fact sheet summarizes the requirements that no business may allow emissions from their business that create an objectionable odor off their property. There are a couple ways the DNR may determine if an odor is objectionable and some suggestions for how to avoid or control odors.
  • Stack Testing Requirements (SB-119) — The DNR may require you to perform emissions testing at your exhaust stacks at any time. Testing may be required after receiving a construction permit, if a new regulation applies to a process, or to confirm emissions factors used to calculate your emissions. It's best to know all the elements summarized in this fact sheet because you do not want to repeat any testing due to misunderstanding the process.
    • If you are required to perform stack testing by an air pollution permit, there are a number of resources you can try for stack testing firms. The first one is the yellow pages. There is also a state-by-state listing online at ActiveSET.org. The DNR's Air Program maintains a list of stack test facilities in the Wisconsin area. Contact Andy Seeber at 608-267-0563 for a copy.
    • Or you can check Consultants List (SB-004). We recently asked those on the list to update the services they have available, whether they be permits, emissions testing, etc. (SBEAP has not reviewed the firms on this list, and their inclusion does not imply any endorsement. The information is provided for your assistance.) We also have a fact sheet on Tips for Hiring an Environmental Consultant (SB-005), which gives information about the questions to ask when hiring an outside consulting firm.

This section will provide compliance resources for hazardous waste and solid waste requirements, and other specific topics for demolition/renovation.

  • The waste program has created many fact sheets and guidance documents on a range of topics. You can find a list of publications on Hazardous Waste resources, on the Guidance tab.
  • Questions on Solid Waste requirements can be found on the Solid Waste overview webpage.
  • Reading the rules is an important step in complying with the parts of the waste requirements that may apply to your business. The DNR has provided a list of direct links to the different waste rule chapters here: solid and hazardous waste codes and statutes
  • In order to keep up with new or changing rules, the DNR Waste programs provide newsletters from many of their topic areas. Go to the main managing waste and materials page and look for the Subscribe box on the right side of the page.
  • The first step in complying with the waste requirements is for each business to identify their wastes and determine whether it is a hazardous waste. The fact sheet Waste Determination and Recordkeeping (WA-1152) describes the four-step process to help you determine if your waste is hazardous waste. This determination should be updated periodically, as processes or materials change.

Hazardous waste

Solid waste

Demolition/construction/renovation wastes

Reporting and Notifications for Waste Requirements

Enrollment in EPA's MyRCRAid allows facilities to prepare and submit initial and subsequent notification forms electronically and requires a registration process that uses an electronic signature. Once the registration is complete, approval as a Wisconsin user is typically granted within one to three business days by receipt of a confirmation email. Once you have received this confirmation, the MyRCRAid application can be used notify the DNR of waste activities and obtain an EPA ID number by completing the 8700-12 form. MyRCRAid allows site managers to view, create and electronically sign manifests in e-Manifest.

The following table is a list of the most common and most likely submittals required. There may be other one-time or occasional submittals needed for activities not listed here.

Links in the first column will open up fact sheets or other descriptive information about the report/notification/certification. Submittals still filed with fillable PDF forms will have a link in the Forms column. Others will be available through the Switchboard and selecting the respective program access links. For instructions on setting up access through Switchboard, go to the Air tab on this page. Additional instructions or tutorials/training are linked in the last column.

DNR Reports & Notifications Deadline Access Forms Training/Resources
Hazardous Waste Generator
Report and Fees
March 1 Switchboard  

Wisconsin Hazardous Waste Annual Report

Tutorial video

Environmental Fees Due May E-pay   Air fees, Waste generator fees, Storm water fees
Hazardous Waste (HW) - Generator Notification
  • Before generating hazardous waste, or VSQG planning to manifest waste
  • Biennial renotification
MyRCRAID or Fillable PDF MyRCRAID
8700-12
Notification of Hazardous Waste Activities
HW - Episodic Generation notification Planned Event: - notification no later than 30 calendar days prior to initiating event
Unplanned Event: within 72 hours of the unplanned event
MyRCRAID or Fillable PDF 8700-12, with episodic addendum MyRCRAID
8700-12

Notification of Hazardous Waste Activities

Episodic Generation of Hazardous Waste (WA-1972)

HW - VSQG to LQG consolidation Prior to an LQG receiving hazardous waste from VSQGs under the control of the same person MyRCRAID or Fillable PDF 8700-12, with consolidation addendum MyRCRAID
8700-12

Notification of Hazardous Waste Activities

LQG Consolidation of VSQG Hazardous Waste (WA-1870)

HW - Hazardous Secondary Materials Prior to managing hazardous secondary materials MyRCRAID or Fillable PDF 8700-12, with HSM addendum MyRCRAID
8700-12

Notification of Hazardous Waste Activities

Changes to Hazardous Waste Generator Regulations

This section provides compliance resources for both wastewater discharge and storm water runoff/discharge requirements.

Wastewater

  • The DNR has many of the wastewater permit application systems available electronically, or if not fully electronic there are PDF fillable forms available on the water permit application page.
  • In case you need help getting started with the electronic application process there are instructional videos available.
  • There is a long list of guidance documents available on the wastewater discharge requirements.
  • If you need help understanding the water data reporting system, go to the eReporting page.
  • For information on industrial pretreatment system requirements and guidance on the permitting process, go to the construction of industrial wastewater pretreatment systems page.
  • The DNR has a page specific to all of the industrial and municipal wastewater general discharge permits that are available, including fact sheets that describe the permit and application forms. Review the fact sheet if you have questions on a particular general permit or contact the wastewater permit specialist listed on the page.

Storm water runoff

Reporting and notifications

The following table is a list of the most common and most likely submittals required for facilities. There may be other one-time or occasional submittals needed for activities not listed here.

Links in the first column will open up fact sheets or other descriptive information about the report/notification/certification. Submittals still filed with fillable PDF forms will have a link in the Forms column. Others will be available through the Switchboard and selecting the respective program access links. For instructions on setting up access through Switchboard, go to the Air tab on this page. Additional instructions or tutorials/training are linked in the last column.

DNR Reports & Notifications Deadline Access Forms Training/Resources
Storm water construction site inspections Weekly and <24 hours after 0.5-inch rain event Fillable PDF 3400-187  
Wastewater discharge - long form DMR Monthly or more frequent - see permit "Summary of Reports Due" section Switchboard   Instructions for Completing Long Electronic Discharge Monitoring Reports (eDMRs)
Storm water Visual Monitoring Quarterly, four times yearly, within 30 minutes of rain event Fillable PDF 3400-176a  
WW discharge - sludge/septage land application Jan 31, or as needed for new request Switchboard 3400-49
3400-52 or - 55&
Help with Online Monitoring Report Forms
Environmental Fees Due May E-pay   Air fees, Waste generator fees, Storm water fees
Storm water Facility Site Compliance Inspection Annually, 12 months following permit issuance Fillable PDF 3400-176  
Wastewater discharge - short form DMR Annual, semi-annual or quarterly - see permit "Summary of Reports Due" section Switchboard   Instructions for Completing Short Electronic Discharge Monitoring Reports (eDMRs)

Permits and Exemptions

The following table lists the most common and most likely permits required by a printing facility to operate in compliance with the requirements. The first columns have links to resources and information to explain the permit or exemption criteria. The last column has links to instructions or online submittal portals for the specific permit or exemption to be filed. Where the application forms are fillable PDFs, there will be a link in the Forms column.

Permits/ Exemptions Eligibility Access Expiration/renewal Forms Process/Resources
Storm water No Exposure Certification 11 criteria Switchboard Every 5 years, facility reapply ePermit

1. If eligible, file Notice of Intent
2. Help on water permits
3. Reapply every 5 years

Storm water Construction Permit If disturb >1 acre, over whole project surface area Switchboard After Notice of Termination submitted ePermit 1. Review general permit
2. Permit information
3. Identify wetlands, endangered resources, historical sites
4. File Notice of Intent 14 days before disturbing land
5. Pay fee
6. Include erosion control and storm water management plans with NOI
7. File Notice of Termination when construction complete
8. Help on water permits
Storm water Industrial Discharge Permit Printing industry under Tier 2 permit Switchboard 5 years, DNR renews and sends to facility ePermit 1. If not eligible for No Exposure, review permit
2. Apply for permit
3. Help on water permits
4. Develop storm water pollution prevention plan (SWPPP)
5. Pay annual fee when invoiced
Wastewater General Discharge Permits

Two likely permits for printing operations:

NCCW - Switchboard 5 years, DNR renews and sends to facility Low Impact Discharge - Form 3400-241 1. Complete WWGP questionnaire to establish which permit applies
2. Low Discharge not ePermit yet so complete PDF form
3. NCCW questionnaire to decide if needed
4. Help on water permits
Wastewater Industrial Discharge Permit If have a wastewater discharge not eligible for General Permit, and not going to local WWTP Switchboard 5 years, DNR renews and sends to facility ePermit 1. Contact local WW staff to discuss permit needs and complete pre-application checklist
2. Apply for WPDES
3. Help on water permits

Both the DNR and EPA provide a range of resources to help small public drinking water sources manage their systems.

Public water systems

It is important to first know whether you have a public or private water system. All but the smallest businesses will likely be defined as a public water system, even if members of the public do not enter your facility, because of the number of employees that may access your water supply. Businesses that might be a small public water system are those with 25 employees for at least six months of the year. Or in DNR's terms, a Non-transient, Non-community (NN) water system. If your business fits that description, here are some resources to help you comply with state and federal rules.

Other resources available from outside the DNR:

  • The EPA offers a compliance assistance page for the Safe Drinking Water Act regulations.
  • Training available for homeowners may also assist small businesses owning their own well.
  • The EPA has resources to help you reduce your water use.
  • For operators of small systems, the WaterOperator.org page offers a range of resources. You can subscribe to their newsletter and blog. They have videos for training.

Water quality data

Whether you own a water system or use one at your business, you may want to check on the water quality data available on your system or neighboring systems.

  • Do you know if your system is reporting contamination? Check out the water quality data page.

Pollution prevention (P2)

  • Companies looking to switch materials for lower impact options have multiple options:
  • Cascade Asset Management provides an asset management program for businesses or institutions in the Madison and southeast Wisconsin area that need assistance in managing their electronic equipment. While Cascade does charge a fee for processing the equipment, they also provide a rebate to you from the recycling or reuse value of the equipment. They will also pick up the equipment you wish to recycle for a fee. For a list of all their fees and services, you can contact Cascade Asset Management at 1-888-222-8399.
  • If you need to find a place to recycle some of your wastes, you can search the Recycling Markets Directory, which is managed by the UW Extension Solid and Hazardous Waste Education Center.
  • Green Tier facilities that recycle electronics:

Improve your environmental performance

Additional resources