Welding

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.

Welding Permit Screening Tool: Excel  (this tool can be used to help determine if you welding operation is exempt from permit requirements. Follow included instructions.)

General Application: Word PDF

CEQA Supplemental Form: 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.  See Welding Operations Advisory for more details. 

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. This may occur immediately or as SDAPCD begins processing the application.

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.

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

Reason for Submittal” - Each application must list a reason for submittal. This should be indicated by selecting a numerical category and a subcategory. The reason for submittal is a critical piece of information as it is necessary to create the fee estimate for your application. You will enter this same information into the general application form. Please utilize the following for guidance on selecting the appropriate option.

1 - New Equipment/Permit - This category includes any application for an authority to construct, permit to operate or certificate of registration for new equipment or existing equipment which does not currently have one.
     a. New Installation - Use for installation of equipment which has not been installed and that is not a replacement of equipment which currently has a permit.
     b. Existing Unpermitted - Use for equipment which has already been installed and either previously had a permit or never had one. Does not include equipment replacement.
        i. Equipment already installed - Includes equipment which has already been installed which required an authority to construct or certificate of registration at the time of installation.
        ii. Loss of Exemption - Use for applications for existing equipment which newly require a permit or registration due to a change in District Rule 11 or other loss of permit exemption.
        iii. Re-permitting - Select for equipment which previously had a permit to operate but the permit was cancelled or retired.

2 - Modification to permit or application – Use this category for any application to change or revise an existing permit, including equipment replacement and change of location.
     a. Equipment Modification/Replacement - Physical modification of existing equipment, including replacement of equipment.
     b. Like-Kind Replacement - Replacement of equipment with “Like Kind” as defined in District Rule 11 which does not require an authority to construct
     c. Change to Permit Conditions - Changes to existing permits which do not propose any physical modifications.
     d. Amend Existing Application - Used when applying for a revision or change to an existing open application or authority to construct.
     e. Change of Location - Used to change the location of an existing permit, which requires an authority to construct.
     f. Change Permit Status - Used to inactivate or reactivate an existing permit. Select the appropriate category.

3 - Other - Use this category for special categories of applications outside of standard authority to construct and permit applications.
     a. Change of Ownership - Required when changing ownership of a permit or piece of equipment. Provide proof of ownership with application. (List affected PTO Record ID(s))
     b. Title V - Use when applying for a new Title V permit and for any revisions to an existing Title V Permit.
     c. Risk Reduction Plan - Use for applications to implement or revise Rule 1210 Requirements.
     d. Emission Reduction Credits (ERCs) - Select this option when requesting the issuance of new ERCs and for transfer or surrender of ERCs.
     e. Other - Includes applications which do not fit into any other categories (please describe in “Equipment Description” section of form)

(*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.)

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

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

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

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

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

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

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 four installments. If you wish to request this option, indicate yes and the total fee will be divided in four, plus an additional processing fee is paid with the first application.
   d. "Application is a minor modification" - The estimate sheet assumes a certain amount of engineering review time for each type of T&M permit revision; however, applications that don't significantly alter the equipment or emission often require less time to review. This box can be selected to reduce the estimated review time and engineering service fees for this type of minor revision. Please note that even if this box is selected an invoice will be issued for any additional engineering time needed to complete the evaluation beyond the initial estimate.
   e. "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

Fees may be paid by check payable to "Air Pollution Control District" or by credit card. Checks can be mailed or dropped off to SDAPCD, 10124 Old Grove Rd, San Diego, CA 92131. Please include your APCD SITE Record ID with the payment.
 
The San Diego County APCD (District) accepts VISA, Master Card, and American Express Cards. Credit card payments will be assessed a processing fee of 2.19% of the amount paid by credit card. This processing fee covers only costs assessed to the District by credit card providers. If you pay by credit card, please contact our Accounting department by calling (858) 586-2600 between the hours of 9a-12p or 1p-4p. Accounting can also be reached at APCDFiscal@sdapcd.org.

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

Need Assistance With:

When contacting us, have your SITE ID, permit/application numbers (if applicable), and equipment details ready.

Submitting Forms and Fees: 

For assistance on submitting forms, please reach our to Permit Processing.  For assistance with making payments, please contact our Fiscal Department.

Phone: (858) 586-2600 
Permit Processing Email: apcdpermits@sdapcd.org
Fiscal Email: apcdfiscal@sdapcd.org

Completing Forms or Compliance:

For assistance filling out application forms or help understanding your permit conditions to stay in compliance, contact our Business Assistance specialist.

Phone: (858) 586-2650
Email: APCDSBA@sdapcd.org

Technical Questions and Fee Estimates:

For fee estimates see the "FEES" tab above.  For additional assistance, mention your inquiry is related to a fee estimate for an application. 

For other technical questions related to your equipment, please contact the Engineering Division.  Please be prepared to describe your equipment and reason for applying so we can connect you to the right engineer

Phone: (858) 586-2600
Email: apcdengineering@sdapcd.org