Additional Requirements

These requirements may apply to your surface coating operation even if you are not required to obtain a permit.

Section 129 of the PA Code contains conditions to control VOC emissions from a variety of types of equipment and coatings. 

  • Section 129.52 specifies VOC content limits for coatings and mixtures and recordkeeping requirements for surface coating processes.  It is important to review the subsections in Section 129 to ensure you are using compliant coatings and maintaining the proper records. 
  • Section 123.13(c) specifies particulate matter concentration limits from processes.

In addition, EPA has developed two rules that cover surface coating at sources that have the potential to emit less than 10 tons per year of an individual HAP or 25 tons per year of all HAPs combined.   The federal standards are as follows:

  • National Emission Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous Surface Coating Operations under 40 CFR 63 Subpart 6H 
  • National Emission Standards for Hazardous Air Pollutants for Nine Metal Fabrication and Finishing Source Categories under 40 CFR 63 Subpart 6X

In addition, these are not the only NESHAPs that may apply so to your operations so it is important to review the list of NESHAPs found on EPA's website.