Welding-Operations

Welding operations emit air contaminants and require a permit to operate unless they are exempt under District Rule 11. The following information will assist in the completion and submittal of an application. Each section of the page contains important information needed to process an application. 

Permit applicability for welding operations is more complex than some other equipment types and is based on multiple factors including the dates that welding operations began or emissions increased at each facility as well as the type and quantity of toxic emissions and health impacts to the surrounding community. Please see the Rules and Regulations section below for a detailed explanation of permit applicability or contact the District for assistance.

IMPORTANT NOTE: If you are applying for a permit due to receiving a permit applicability letter, see notes added in relevant sections to assist with the application process.

The District collects information about equipment and processes that are required to have a permit by asking for completion of application forms. These forms tell us about your operation and allow us to permit your process. It is very important that these forms are filled out completely and accurately. Errors and missing information may lead to delayed processing time and additional charges if revisions are required. Please carefully review and complete the forms. You may contact the District with any questions.

General Application: Word PDF

Welding Operations Supplemental Form Word PDF

Toxics Form: Word PDF

Other required attachments:

  • Historical welding rod usage data (if claiming an exemption from Rule 1200 for any emissions)
  • SDS or other composition data for welding rods where custom emission factors are proposed

The general and equipment specific application forms must be submitted with each application packet.

NOTE: For applications submitted in response to a permit applicability determination letter, applications are not required to include any information that has already been submitted to the District such as welding usage data and historical records.

NOTE 2: If your application will include an emission increase beyond historical existing emissions/operations, please list existing and proposed new material usage on two separate supplemental forms for clarity.

The correct application fee, as calculated using the fee estimate form tool below, must be submitted along with your application in order for it to be accepted.  Additionally, please include the completed estimate form with your application.

Note: The estimate is designed to provide a good starting point for work on most applications; however, certain situations may require specific types of review that require additional fees. The District will review your application and determine if any of these specific considerations apply and will contact you and provide an invoice if additional fees are necessary.

Fee Estimate Form (see instructions below)

Instructions: In order to determine the proper application fee, please complete the Fee Estimate Form using the instructions below based on the specifics of your application.

1. "Applicant Site ID/EIF ID” – For applications at existing facility please provide the Site ID number.

2. “Reason for Submittal” - Identify the reason for application submittal from the indicated options:
   a. New/ Existing Unpermitted (Do not select for replacements and modifications)
   b. Modification – Includes both physical modifications of equipment and condition changes.
   c. Replacement
   d. Change of Location
   e. Amendment - Used when modifying an open application
   f.  Additional Identical Unit, Applying Same Time - See instructions below
   g. Permit Activation
   h. Permit Reactivation
   i. Like Kind Replacement – review requirements to ensure the replacement meets the requirements specified in Rule 11*
   j. other

(*If you are indicating the reason for submittal is Like Kind Replacement, this will result in a lower fee, but please ensure you are familiar with the requirements to qualify under this provision as not all replacements are eligible. If you have a question regarding applicability of this application type, please contact the District.)

3. “Equipment Type” - Using the dropdown menu, select the equipment type that describes your equipment. 

4. “Applicant DBA” - Enter the company name/DBA of the owner/operator of the equipment

5. “Existing Site” - Select whether the location (site) is new or existing (i.e. has existing permits with the District).

6. “Affected Permit Number” - For changes to existing permits, enter the permit number. For amendments, enter the application number being amended.

7. "Estimate Date” – This is the date the form is filled out.

8. “Equipment Description” – Please enter a brief description of the equipment for which the permit is being applied for.

9. “Special Considerations” - Complete any of the special consideration drop downs that apply
   a. "Number of Units". Indicate the number of permits you are applying for. If you are applying for multiple identical equipment at the same time, see instructions below for using multiple estimate sheets.
   b. "Outstanding Permit Fees." If your permit was previously retired for non-payment, you may owe back fees. Indicate yes in this box, and contact the District to determine what total amount is owed. This must be paid prior to apply to reactive your permit.
   c. "Split Payment". The District has a split payment option. This allows the application to be paid in two installments. If you wish to request this option, indicate yes and the total fee will be divided in two, plus an additional processing fee is paid with the first application.
   d. "HRA Fee not applicable...District Rule 1200 requires that an HRA be conducted for any project that results in an increase in Toxic Air Contaminants. The estimate sheet assumes that most applications require this fee; however, certain applications may not increase emissions or a project may consist of multiple applications where only one fee is required. If either of these is the case for your application, use this box to remove the HRA fee, but note that if this fee is required an invoice will be issued for the additional amount.

The specific fees that must be included are determined by District Rule 40 and can include fixed fees and/or time and material (T&M) based fees. Please note that T&M based fees are estimates and can vary based on the amount of work necessary to complete the review of the application. Additionally, review of certain requirements, including Health Risk Assessments (HRA), New Source Review (NSR), California Environmental Quality Act (CEQA), and others are also assessed on a Time & Material basis.

Note for Multiple Applications - If you are submitting multiple applications simultaneously, a single fee estimate sheet can be used if all equipment is within the same fee schedule and you are applying for multiple permits. However, note that a single application record will be created for each individual application.

If you are submitting multiple applications simultaneously and wish to take advantage of the multiple identical equipment lower fee provisions of Rule 40, complete an estimate form for the first unit, and then a separate form for the subsequent units, with the reason for submittal as “Additional Identical Unit, Applying Same Time”.

NOTE:   The fees listed in this estimate are intended to be the deposit necessary to begin work on your application. In most cases, fees will be accurate; however, some fees are estimates of time & material based fees and the final fee may be more or less than the estimated amount. If additional fees are owed, you will be invoiced for these fees and if any fees are remaining after approval, these will be refunded. Work records are kept for purposes of establishing time and material based fees.

How to Pay

These fees may be paid by check payable to "Air Pollution Control District" or by credit card (Visa, MasterCard, Discover, and American Express).

If you choose to email or fax your application and intend on paying with a credit card, ensure that you have obtained your fee estimate and have it in hand, and then after submitting the application, you must contact the District over the phone at (858)586-2600 to provide payment information.

Please note that credit card payments are assessed a transaction fee of 2.19% that is charged by the credit card provider.

Citizen Access
Select equipment type applications can now be submitted online.

Fax: (858) 586-2601

SDAPCD
Permit Processing
10124 Old Grove Rd
San Diego, CA 92131-1649

The District will act on complete applications as soon as possible but at most within 180 days. The engineer assigned to your application will review it and contact you within 30 days of receipt to confirm that it is complete or request additional information. Typically permits are issued in about 60 days. More complex processes will take longer. Common reasons that applications may take longer than 60 days to evaluate include: the project is a complex project specifically at a major source, if the project requires a mandatory public notice period due to being installed within 1000 feet of a school or triggering the requirement for a air quality impact analysis (AQIA), if they do not initially pass a health risk assessment (HRA) or AQIA, if BACT is not proposed or complete BACT analysis is not submitted or for major sources if actual emission data is not included.

Ensuring your application is complete is the best way to reduce processing time. Complete emissions data is the most important factor in minimizing application processing time and iterative information requests. If you have any questions about what information is required, please contact the District using the information on the Assistance tab.

Sign up for Citizen Access to get up to date information on the status of your application.

Learn more about the permitting process and what to expect.

Best Available Control Technology

If a piece of equipment or a process emit more than 10 pounds per day of particulate matter (PM10), oxides of nitrogen (NOx), volatile organic compounds (VOC) or oxides of sulfur (SOx), the application must include a best available control technology (BACT) analysis. Large coating operations have the potential to emit more than 10 pounds per day of VOC. Please indicate on your application if your operation will emit more than 10 pounds per day of VOC.

If you have questions or need assistance reference the  BACT Guidance Document  or the contact information on the assistance tab.  Please review District Rules 20.1 and 20.2.

Note: Most welding operations are not subject to BACT requirements.

Toxics

District Rule 1200 applies to any new, relocated, or modified emission unit which may increase emissions of one or more toxic air contaminant(s). The proposed project must comply with Rule 1200. Proposed equipment may require toxics best available control technology (TBACT) depending on the project. Please review District Rule 1200 for further details.

Note: Rule 1200 requirements apply to emission increases only, so do not apply to existing operations not applying to increase emissions.

Trade Secret

District rules address how information that is submitted to the District is managed. District Regulation IX contains District Rules 176 and 177. Please refer directly to these rules when submitting trade secret information. However, be aware that you will need to submit:

  1. You must indicate on the general application form that your submittal includes trade secret information to ensure that it is not inadvertently made publicly available.
  2. A letter disclosing the proprietary information. Ideally, this information should be separated from your application and clearly identifiable. This can be submitted electronically, and can be a separate submittal from the main application package.
  3. A letter for the  public record explaining why the information needs to be held as trade secret or is otherwise exempt from disclosure.

Applications submitted with incomplete material composition data due to failure to include proprietary information can significantly delay permit applications. In an effort to expedite the permit application process it is recommended that you contact the manufacturer or vendor of any proprietary materials that are used in the process and prepare the required letters as part of your application submittal.

AB3205

In 1989, the California state legislature passed a law, AB 3205, designed to protect schoolchildren from hazardous air contaminants. The law, as currently written, requires the District to notify parents of schoolchildren, neighboring businesses and residents of all new or modified equipment that emits any hazardous air contaminant into the air which will be installed within 1,000 feet of a school site. The law also requires the District to consider any comments before authorizing construction. Please review your proposed location. If a school property boundary is located within 1,000 feet of the proposed emissions point, the AB3205 process will be initiated. This process requires a 30 day public comment period and the overall process will delay projects by at least six weeks.

NESHAP/NSPS/ATCM

NESHAP, NSPS and ATCMs are federal and state rules that apply to certain equipment types. Most welding operations are not subject to requirements under one of these rules unless part of a larger operation that is otherwise subject.

District Rules

Some welding operations are exempt from permitting and some require permits. There are two provisions of District rules that control whether or not your operation requires a permit.

Rule 11(d)(7)(iv) exempts “Brazing and welding equipment, including arc welding equipment and laser welding” from requiring a permit.

However,

Rule 11(a)(5) states that the above exemption does not apply to equipment that was constructed or modified to increase emissions after November 15, 2000 and emits toxic air contaminants which may cause health impacts above thresholds which are described in Rule 1200.

The meaning of these two provisions together is that:

(a) Older welding operations (those which have not been modified and have not increased emissions since November 15, 2000) are exempt from permitting.
(b) All other welding operations that do not cause excessive health impacts to the surrounding community are also exempt from permitting.
(c) Any operation which does not fit unto the above categories requires a permit.

Additionally, because permit applicability is based on health risk, certain factors impact the need to obtain a permit including amount and type of welding materials used, and distance to nearby residences and businesses.

To assist with permit applicability, the District has made a calculation tool available on it’s website to show how health risk from your facility is determined. 

General rules that may apply to welding operations include Rules 50 and 51.

A complete listing of the District's rules can be found here.

Calculation Procedures and Additional Resources

Equipment Calculation Procedures - This page contains procedures to be used for calculating emissions from this equipment that should be submitted with each application.

Use of these calculation procedures will aid in minimizing application review time and costs.  The correct emission factors should be selected from the list based on equipment. If available, manufacturer provided equipment specific emission data or source test results should be utilized before using default emission factors. Sources of all emission data used must be included as attachments to the application.

AP-42 - An alternative compilation of emission factors and calculation procedures prepared by the EPA that may be utilized by the District in some situations for some equipment types.

Compliance Information

Call Duty Engineer
(858) 586-2600

District Small Business Assistance Program Coordinator
(858) 586-2650