Chapter NR 438 Pollutant Reporting Level Changes on July 1, 2004

Chapter NR 438, Wis. Adm. Code, effective July 1, 2004, contained many changes to the pollutants companies should consider reporting for their annual air emissions. NR 438 contains Table 1- Reporting Levels for Calendar Years 2003 and Earlier and Table 2-Reporting Levels for Calendar Years 2004 and Later. For the 2004 data year, DNR requests companies complete the reporting of the pollutants in Table 2 to the best of their ability. If you would like to download an Excel spreadsheet that summarizes all of the information listed below click here (XLS, 291KB). This web page contains information comparing the pre-July 2004 an post-July 2004 information:

  • 182 air contaminants did not change reporting thresholds. Lists of these pollutants are organized alphabetically and by Chemical Abstract Symbol (CAS).
  • Reporting thresholds increased for 50 air contaminants. Lists of these pollutants are organized alphabetically and by Chemical Abstract Symbol (CAS). The pre-July 2004 reporting level is listed in Column 3, the post-July 2004 reporting level is listed in Column 4, and the increase in reporting level is listed in Column 5 of both tables.
  • Reporting levels decreased for 356 pollutants. Lists of these pollutants are organized alphabetically and by Chemical Abstract Symbol (CAS). The pre-July 2004 reporting level is listed in Column 3, the post-July 2004 reporting level is listed in Column 4, and the decrease in reporting level is listed in Column 5 of both tables.
  • 114 new pollutants were added. Lists of these pollutants are organized alphabetically and by Chemical Abstract Symbol (CAS).
  • Although there were 702 air contaminant entries in Table 2 of NR 438.03, Wis. Adm. Code, the actual number of unique pollutants in this table is 623. Because some of the air contaminants are commonly known by more than one name, the NR 438 lists contains 53 air contaminants with two entries, eight air contaminants with three entries, and three air contaminants with four entries.
  • A total of 81 billable air pollutants exist. The number of billable air pollutants did not change with the amending of NR 438.
  • PM2.5 reporting. On July 17, 1997, USEPA promulgated national ambient air quality standards for fine particulate, which is also known as PM2.5 (exit DNR). Because of litigation concerning this pollutant, states were not able to incorporate these new standards into their state implementation plans in a timely manner. Wisconsin has yet to complete rulemaking on this new pollutant. If Wisconsin had incorporated this pollutant into its SIP then the July 1, 2004 version of chapter NR 438, Wis. Adm. Code, would have included PM2.5. Consequently, PM2.5 is not listed as a reportable pollutant under Table 2 of NR 438.03, Wis. Adm. Code.
  • However, USEPA promulgated the Consolidated Emissions Reporting Rule (CERR) on June 10, 2002 (67 FR 39602) (exit DNR)CERR requires each state to annually report (exit DNR) PM2.5 point source emission data to USEPA. DNR has reported PM2.5 information to USEPA to meet requirements of CERR for emissions in 2002 and 2003. DNR has only reported emissions based on PM2.5 emission factors supplied by USEPA. DNR will continue to report PM2.5 point source emissions to meet the CERR requirements and PM2.5 will be included in an amended ch. NR 438, Wis. Adm. Code, once the PM2.5 air quality standards become part of DNR's adminitrative code.

An Excel spreadsheet containing the information discussed above is available for downloading (ZIP, 82KB)onto your computer. This file is a zipped file and you will need to unzip it before you can use the information in the Excel spreadsheet.

Last Revised: Wednesday January 09 2008