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Notice: Public Comment Period, Public Hearing: Proposed Updates to Surface Coating Regulation

UPDATE: Virtual Hearing on May 6, 9:30 am — Access Information and presentation slides:

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Meeting ID: 969 7198 3789
Passcode: 970593

Presentation Slides: Proposed changes -slides that will be presented at the 5/6 hearing

Notice of Public Comment/Public Hearing
Surface Coating Rule Updates

Public Comment Period ends May 6


Last summer we updated some of our regulations, including establishing two categories of surface coating operations and a de minimis level for determining registration and permitting for these categories. This is described below under “Recap Phase 1.”

Current Proposed Updates to the Surface Coating rule (Article VI, Section 6.13) – we are referring to this as Phase 2 because it mainly serves to incorporate what was done under Phase 1 into the surface coating rule.

There are no new fees or new requirements for surface coaters proposed. 

Recap PHASE 1:  In July 2020, revisions were made to Article IV, Section 4.04 (Source Categories Required to Register) including dividing surface coating operations into two categories: motor vehicle (auto body) and general (which covers everything that is not motor vehicle).

In addition, a de minimis level was established of: Potential to Emit (PTE) is less than 100 lbs./yr. or PTE toxic air emissions does not exceed any Small Quantity Emission Rate (SQER) listed in Chapter 173-460 WAC. The de minimis level becomes effective after surface coating regulation updates are completed under Phase 2, described below. The de minimis level established is to be applied as follows:

  • Motor Vehicle – ALL motor vehicle (auto body) facilities will continue to be required to register regardless of their emissions. However, facilities with emissions below the de minimis level will no longer be required to file a Notice of Construction (NOC) permit. For existing motor vehicle (auto body) facilities with NOC permits that have emissions below the proposed threshold, we propose to void their NOC permits for their paint booths, but they still have to be registered.
  • General: General surface coaters with emissions below the de minimis level will not be required to file a NOC permit and will no longer be required to register.

Proposed in PHASE 2: The proposed rulemaking is simply “closing the loop” on what was done under Phase 1 by updating the surface coating regulation (Article VI, Section 6.13) because it still requires all surface coating facilities to have a paint booth/room. We propose putting the same de minimis thresholds into the surface coating regulation so that a booth is not required for sources that are below the de minimis thresholds for permitting.

Public Comment Period:  Written comments are being accepted up until the close of the public hearing on May 6, 2021. Written comments may be submitted by mail or email:  SRCAA, Attention Margee Chambers, 3104 E. Augusta Ave., Spokane, WA 99207, or PublicComment@spokanecleanair.org.

Public Hearing: SRCAA will host a public hearing during their regularly scheduled Board of Directors meeting on Thursday, May 6, 2021, at 9:30 a.m. The public hearing will be held remotely, pursuant to Governor Inslee’s Order 20-28, dated March 24, 2020, as extended and amended. Providing public testimony info sheet.

Detailed materials regarding the proposed updates to the surface coating regulation:

  • Full regulation document marked with proposed changes
  • This flow chart illustrates the two categories of surface coaters and de minimis levels (link to flow chart)
  • The table below summarizes the proposed changes:
Article, Section Proposed Amendments

Section 6.13(A) Purpose

Clarification updates 

Section 6.13(B) Applicability

Add “commercial” to clarify the regulation is applicable to commercial surface coating operations, therefore excluding non-commercial operations such as hobbyist 


Section 6.13(C) Definitions

Add several new terms: commercial surface coating; general surface coating; motor vehicle/motor vehicle component surface coating; non-spray application; portable surface coating; potential to emit; spray application  

Section 6.13(D) Prohibition on Emissions

Clarification updates

Section 6.13(E) Requirements

Clarification updates including: enclosure and control equipment properly operated and maintained according to manufacturer recommendations and operations manuals (required in Article IV); simplify clean up requirements; simplify record keeping requirements

Section 6.13(F) Exemptions

Add powder coating that does not exhaust outside to process exemption; update low usage exemption to be based on emissions (potential to emit below 100 lbs/yr and toxics below small quantity emission rate) and exempt from enclosure and control requirements; eliminate hobbyist exemption, add portable surface coating that complies with GOA to enclosure exemption; reorder exemptions list by like exemptions 

Section 6.13(G) Compliance with Other Laws and Regulations

Clarification updates

Section 10.08 Misc. Fees

Update citing of Section 6.13

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