General Permit to Construct for Automotive Coating Operations
Under the Rules for the Control of Air Pollution in Idaho (IDAPA 58.01.01.201– 228), facilities that apply paint to vehicles as a commercial business in Idaho are subject to Idaho's air permitting requirements.
Depending on the volume of coating materials used per day, facilities are required to do one of the following:
- Obtain a General Permit to Construct for Automotive Coating Operations, or
- Obtain a Permit to Construct specific to the facility, or
- Demonstrate that they qualify for an exemption.
All facilities subject to the air quality permit requirements outlined below were required to apply for a permit by December 31, 2010.
Who May Apply for a General Permit to Construct?
Facilities that use a maximum of 4 gallons or less of coating materials, including but not limited to pretreatment wash primer, primer, topcoat, clear coat, reducer, and hardener, per calendar day are eligible to apply for a General Permit to Construct for Automotive Coating Operations. The general permit is a standard permit template that applies to automotive coating operations in this category. Because a general permit requires less time to process than a facility-specific permit to construct, it incurs a lower processing fee.
Facilities that use more than 4 gallons of coating materials per calendar day are not eligible to obtain a general permit and are required to obtain a permit to construct specific to the facility. In addition, facilities that paint vehicles other than cars and trucks most likely would need to obtain a facility-specific permit.
One-time occurrences, such as painting a vehicle in a garage or shop, do not require an air quality permit. Exemptions for facilities that use less coating materials may also be granted.
General Permit Requirements
The general permit includes the following requirements:
- Spray Booth and Prep Station: All painting at this facility, including application of primer, shall be conducted inside the booth(s) or preparation station(s) with filter system in place, exhaust fan(s) operating, and door(s) or curtain(s) closed.
- For complete vehicles, the booth must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or side curtains.
- For coating miscellaneous parts and products or vehicle subassemblies, the preparation station must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the preparation station.
- Spray Gun: All painting shall be conducted with a high volume-low pressure (HVLP) spray gun, or equivalent technology, with a minimum 65% transfer efficiency as documented by the spray gun manufacturer.
- Filter System: The permittee is required to install, maintain, and operate according to the manufacturer's specifications and recommendations, a spray booth filter system or a preparation station filter system with a minimum control efficiency of 98% for PM10 emissions as documented by the filter manufacturer.
- Record Keeping: The permittee is required to maintain material purchase records and material data safety sheets as well as daily coating materials usage records.
Permit Documents
How to Apply and Pay Fees
To apply for a General Permit to Construct for Automotive Coating Operations, complete these forms:
- Form GI: General Information
Form EU 6: Automotive Spray Paint Booth
Applications must be signed and certified by the facility's responsible official.
Submit an application fee of $1,000 and a one-time processing fee of $500, for a total of $1,500, with application forms. Payment may be made by check, credit card/e-check, or bank wire transfer.
Pay by check
Make check payable to the Idaho Department of Environmental Quality, and send completed application and check to the following:
Idaho Department of Environmental Quality
Attn: Fiscal Office - Air Quality Program
1410 N. Hilton
Boise, ID 83706
Pay by credit card/E-check
Send completed application to the following:
Idaho Department of Environmental Quality
Attn: Air Quality Program
1410 N. Hilton
Boise, ID 83706
To pay fees, link to Access Idaho website at
https://www.accessidaho.org/ai/payport/online/deq/index.html
(Note: Convenience fee of 3% applies to credit card payments, $5 to E-check payments.)
Pay by bank wire transfer
Send completed application to the following:
Idaho Department of Environmental Quality
Attn: Air Quality Program
1410 N. Hilton
Boise, ID 83706
To pay fees, contact Katie Bennett, DEQ Fiscal Office
katie.bennett@deq.idaho.gov
(208) 373-0446
Exemptions
Certain facilities may be exempt from air permitting requirements. To assist facilities in the exemption process, DEQ has created a boiler-plate exemption concurrence request. To meet this boiler-plate exemption, the following criteria must be met:
- The maximum capacity for applying all coating materials, without the effect of any physical or operational limitations, for the operation is 1.25 gallons per day or less (based upon a 24-hour day).
- That high volume-low pressure (HVLP) paint guns are used for all application of coatings at the facility.
- No coating materials containing silicon dioxide (CAS 60676-86-0) or kaolin (CAS 1332-58-7) will ever be used at the facility.
- The maximum heat input for a natural gas or LPG-fired paint booth heater is 3.30 MMBtu/hr.
Note: Even if your facility is exempt from the state permitting requirement, it may still be subject to the federal requirements of Subpart HHHHHH. See 40 CFR 63.11170 (a)(2). In addition, even if the facility is exempt from the federal requirements of Subpart HHHHHH, it may still be subject to state permitting requirements.
DEQ does not administer the exemption provisions of Subpart HHHHHH and any such exemption request must be filed with EPA (see “Related Federal Requirements” heading below). In part, to qualify for the exemption, a facility must certify to EPA that it does not spray apply coatings containing compounds of chromium, lead, manganese, nickel, or cadmium.
Facilities may also be exempt from state permitting requirements on a case-by-case basis for a specific operation. Call the Air Quality Permitting Hotline at 1-877-5Permit (1-877-573-7648) for assistance.
Exemption Documents
- Self-Exemption Acknowledgement Statement of Basis
- Emissions Inventory Exemption Spreadsheet
- Self-Exemption Acknowledge Request Form: Word | PDF
Where to Send Exemption Request Form
Idaho Department of Environmental Quality
Attn: Air Quality Program
1410 N. Hilton
Boise, ID 83706
Signed exemption form may also be faxed to (208) 373-0340.
Related Federal Requirements
On January 9, 2008, EPA issued Subpart HHHHHH (see http://www.epa.gov/collisionrepair/pdfs/20080701_CFR_HHHHHH.pdf), commonly called the Autobody Shop Rule. The rule regulates emissions from paint stripping and miscellaneous surface coating operations. Requirements under Subpart 6H are incorporated into DEQ's General Permit to Construct for Automotive Coating Operations.
EPA also has a website with information on the 6H Rule (see http://www.epa.gov/collisionrepair/) that can be of assistance to auto body shop owners. Included on this site are links to an Example Notification, Petition for Exemption, and Notification of Compliance Status (as required by 6H) as well as a brochure summarizing the rule.
Note: Even if your facility is exempt from federal permitting
requirements of Subpart HHHHHH, it may still be subject to the
state permitting requirement.
Compliance Assistance
For assistance with complying with automotive coating permit requirements, contact your nearest DEQ regional office.
To assist in complying with permit requirements, DEQ has prepared the following forms:
- Daily Coating/Material Usage Log: Word | PDF
- Air Quality Inspection Checklist for Automotive Coating Facilities: Word | PDF