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Air Permits for Painting and Coating Operations

Basic Questions

Do I need a permit for my painting or coating operation?

If you are building a new facility to carry out an industrial process, or if you are making significant changes to your current process it's best to assume that you do. If you emit only small quantities into the air, due to the nature of your process (for example, if your operations are restricted to powder coating), or if your emissions are otherwise restricted or controlled, you may be exempt from some requirements. But even if a permit is not required, you may still have to meet other obligations, such as reporting your emissions periodically or keeping your equipment and your records in good order (they may be subject to inspection).

Whether you need a permit and the type of permit you may need depends on:

If your emissions are small enough and your operation does not fall into one of the regulated categories, you may be exempt from federal permit requirements. Your state or local agency may have other rules which apply to you. Even if you do not have to comply with any of the formal requirements described here, it might be to your advantage to consider changing the process to take advantage of new pollution prevention opportunities.

What types of permit will I need?

A comparison between construction and operating permits appears below.

Which regulatory agency will issue my permit?

In general, the federal government (EPA) sets national air quality standards, and the states decide in detail how to meet those standards. Some states issue permits directly, and some have passed that responsibility to local agencies, or to special air quality districts. You may be able to determine the situation in your area from the agency descriptions in the State Regulations Locator.

What kind of information will I need to submit?

The form of the permit application will differ from state to state, but at minimum the agency will probably want to see:

  • an overall description of your process(es), including the raw materials and fuels going into the process, the emissions coming out of it, and the expected production rate and operating schedule
  • a description of any air pollution control equipment you are using
  • a plan for assuring that you are complying with the limits which will be established for your facility

The agency will use your process description to determine what quantity of air pollutants your facility has the potential to emit. This is considered more reliable than actual emissions, since operating rates can vary depending on business conditions, no matter what they have been in the past.

The agency will look for a compliance plan that will assure them that your emissions are within the specified limits. This is generally not spelled out in advance -- you can suggest whatever methods make sense for your process, ranging anywhere from periodic inspections of equipment up to continuous monitoring. But you will have to satisfy the agency that your plan is reasonable.

Pollutants which are subject to special regulation

There are several types of pollutants to which special rules apply. They include:

Types of coating operations which are subject to special regulation

 EPA is developing regulations for a number of different categories of surface coating operations. Current information on the status of these rules is available from EPA.

Comparison between construction permits and operating permits

Item

Construction permit

Operating permit

Applicability

Applies to specific facility or process line.

Applies to your entire operation.

Duration until renewal

Unlimited

Typically five years

 

 

 

 

 

 


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