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NSR Guidance for Surface Coating Operations

Overview of air permitting requirements and options for surface coating operations. Links to relevant rules, guidance, and forms.

What type of authorization do I need?

In Texas, there are three options for obtaining authorization to emit air contaminants from a surface coating facility: De Minimis claim, Permits by Rule (PBRs), or a Case-by-Case Permit. The type of authorization required will depend on the materials and chemicals used at the facility, the processes that are conducted, and the amount of air contaminants that are emitted.

TCEQ’s Small Business and Local Government Assistance program provides guidance for the authorization of surface coating facilities, which will help you determine the appropriate authorization mechanism for your facility. This guidance includes information about air, water, and waste regulations, as well as helpful resources such as calculation spreadsheets, application checklists, etc. It is recommended that you review this guidance and determine if your facility meets the requirements for either de minimis or PBR.

Any site that does not qualify as De Minimis or cannot be authorized under a PBR must obtain a Case-by-Case permit, which requires a more stringent review. Additional guidance to assist in obtaining a Case-by-Case permit is provided below.

Case-by-Case Permit Guidance

The following guidance documents and resources are intended to supplement the instructions provided in the PI-1 form (initial/amendment) or PI-R form (renewal) and assist permit applicants in preparing a complete application. A complete application will ensure a quicker review.

  • Application Checklist Adobe Acrobat PDF Document
  • Guidance for Calculating Surface Coating Emissions (includes an emission calculation discussion, testing procedures, etc.) (Under Construction)
  • Emission Calculation Spreadsheets Microsoft Excel – spreadsheets with instructions for calculating emissions from surface coating operations and thermal oxidizers for Case-by-Case permit applications.
    Use of these spreadsheets is recommended and will be required for all permit applications received after January 1, 2019.
    Example spreadsheets Microsoft Excel are provided for clarification.
  • Impacts Analysis – A complete and acceptable impacts analysis MUST be submitted with the application. The impacts analysis must demonstrate compliance with the NAAQS and protectiveness of public health, general welfare, and physical property. This may be determined using either Modeling and Effects Review Applicability (MERA) Adobe Acrobat PDF Document or air dispersion modeling.
  • Applicable Rules and Regulations - Specific state and federal rules and regulations that may pertain to this type of facility.
  • Guidance for Rules and Regulations – A guidance discussing applicable regulations. (Under Construction)
  • Applicable Forms and Tables - Required forms and tables to apply for authorization.
  • Boilerplate Conditions Adobe Acrobat PDF Document - The following are examples of permit conditions that may be applicable for this type of facility.

Best Available Control Technology (BACT)

The TCEQ uses a three-tiered approach to evaluate air pollution control technology for new and modified facilities or sources, discussed in Air Pollution Control Guidance Adobe Acrobat PDF Document. Additionally, the Coatings team provides BACT Guidelines for Coating Sources.

Potential Additional Sources

The following are additional facilities that are commonly permitted during a permit action for the facility: Abrasive Blasting; Degreasing; Boilers, Heaters, and Other Combustion; Soldering, Brazing, Welding, Hand-held and Manually Operated Machines.

Additional Information

Questions? We Can Help

The Small Business and Local Government Assistance program provides assistance to local governments and small businesses to comply with environmental regulations. If you still have questions, please contact us. Please indicate whether your question is regarding a De Minimis claim, Permit by Rule, or a Case-by-Case permit.