The Texas Commission on Environmental Quality (TCEQ) Surface Coating Workbook has been part of the permitting landscape for several years, but its role has recently expanded in ways that all surface coating permit holders must know. Back in 2019, the surface coating workbook became mandatory for New Source Review (NSR) permit applications, creating a standardized format for emission calculations and simplifying review for regulators. At the time, Permit by Rule (PBR) registrations were unaffected. That changed on November 1, 2024, when TCEQ extended the requirement to PBR filed under 30 Texas Administrative Code (TAC) §106.431 – §106.436. This expansion means that whether a facility is operating under NSR or PBR, the workbook must now be included with every new or amended application.

Regulatory Background & Timeline

NSR Requirements: Since January 1, 2019, all NSR permit applications for surface coating have been required to use the TCEQ Surface Coating Workbook. This tool standardizes emission calculations and ensures consistency in how surface coating operations report emissions.

PBR Requirements: Beginning November 1, 2024, registration applications submitted under 30 TAC §106.431 through §106.436 must also prepare and submit the TCEQ PBR Surface Coating Workbook.

• 30 TAC §106.431 – Milling and Grinding of Coatings and Molding Compounds
• 30 TAC §106.432 – Dipping Tanks and Containers
• 30 TAC §106.433 – Surface Coat Facility
• 30 TAC §106.434 – Powder Coating Facility
• 30 TAC §106.435 – Classic or Antique Automobile Restoration Facility
• 30 TAC §106.436 – Auto Body Refinishing Facility

Scope: This applies to new permit applications and mended ones; modifications to existing NSR or PBR permits that change emission relevant processes or drastically different coatings speciation will trigger the workbook requirement.

Why the Surface Coating Workbooks Matter

Surface coating operations like spraying, dripping, baking, etc. often involve volatile organic compounds (VOCs), hazardous air pollutants (HAPs), exempt solvents (ESs), and particulate matter (PM). Regulatory bodies like the TCEQ rely on precise, uniform methodologies for estimating emissions to:

• Ensure that emissions are accurately quantified, so state and federal air quality standards are met;
• Facilitate consistent review and comparison among different permit applications;
• Streamline the permitting process, avoiding back-and-forth due to missing or inadequate data;
• Reduce the risk of regulatory non-compliance, which can lead to enforcement action, fines, or forced changes in operations.

The workbook ensures that everyone from facility engineers to consultants to permitting staff is fully understanding when it comes to how emission factors, coating solids content, control efficiencies, operating schedules, and other inputs are treated.

What You Need to Do: Practical Steps

To stay compliant and avoid delays, businesses that have coating operations should take the following actions immediately:

Audit Your Permit Applications. If you are currently in the process of preparing a new or amended NSR or PBR permit, check whether your emissions calculations are being prepared using any format other than the official TCEQ Surface Coating Workbook. If so, revise those calculations.

Train Your Team. Make sure environmental staff, engineers, and third-party consultants know about the workbook requirement. Understand what inputs are needed (coating types, solids content, application method, control equipment, etc.), and ensure your data is accurate and traceable.

Update Internal Templates. If your organization uses its own spreadsheets or calculation templates, phase them out or bring them into alignment with the TCEQ format.

Collect & Prepare Supporting Data. To complete the workbook properly, you will need accurate data: coating solids content, usage rates, VOC/HAP/ES content, operating hours, control device efficiency, etc. Ensure lab certification, vendor data sheets, and historical usage records are up to date.

Pre-Submit Check. Before submitting verify that the workbook is filled in completely; ensure consistency among all sections; double-check units, assumptions, and control efficiencies. An incomplete or incorrect workbook is common cause for permit delays.

Implications & Consequences

Failing to include the workbook with required permit applications or submitting incomplete/inaccurate workbooks can lead to several negative outcomes:

• Application Delays. The TCEQ may return the application, request additional data, or consider the submission incomplete until the workbook is properly completed. This extends project timelines and can increase costs.
• Risk of Non-Approval. Without a compliant workbook, a permit application might be denied or not meet required emission thresholds or control requirements.
• Enforcement Exposure. If operations are modified without formally amending permits (and hence without using the required workbook when they should), companies may face regulatory risk.
• Competitive Disadvantage. Delays or non-compliance can hamper business growth, especially when required permits are critical to new project, expansion, or process changes.

Where to Find the Workbooks & Resources

The TCEQ Surface Coating Workbooks (for both NSR and PBR) are publicly available through the TCEQ website. They include instructions, example entries, and detailed guidance on how to fill out all the required sections.

Download the Surface Coating Workbook: (link to official TCEQ page)

• NSR TCEQ Surface Coating Workbook.
• PBR Surface Coating Workbook

Additionally:

• Review TCEQ’s regulatory guidance related to 30 TAC §106.431 – §106.436
• Check previous permit decisions or TCEQ permit application reviews to see how the workbooks have been evaluated in practice.
• Consult with environmental experts or technical consultants familiar with Texas air permitting if your operations are complex (multiple coatings, custom operations, etc.).

If your business is involved in surface coating operations, the workbook requirement isn’t just a bureaucratic checkbox. It is a reflection of how Texas is ensuring environmental protection while maintaining clarity and consistency in permitting. The sooner you integrate the workbook requirements into your process for NSR and PBR permits, the more efficiently your application will move forward, the lower the risk of costly delays or rework, and the better you’ll be able to demonstrate compliance.

Compliance Tracking for Surface Coating Operations

Maintaining compliance with TCEQ’s surface coating requirements doesn’t stop at submitting the workbook, it’s an ongoing responsibility. Surface coating facilities must implement a robust compliance tracking system to ensure all permit conditions are consistently met. This includes tracking usage of coatings, solvents, and other regulated materials, monitoring emissions, and documenting any process changes that could impact VOC, ES, HAP or PM emissions.

Key elements of an effective compliance tracking program include:

• Material Usage Records. Maintain accurate records of all coatings, solvents, and additives, including VOC/ES/HAP/Solids content, batch sizes, and daily usage. This helps ensure reported emissions in the workbook match actual facility operations.
• Equipment and Process Tracking. Document the operation of spray booths, ovens, powder coating systems, and other emission generating equipment. Include maintenance logs and control device efficiency records.
• Permit Condition Checklist. Develop a checklist aligned with permit conditions (NSR or PBR) to ensure no obligations are overlooked. This should include emission limits, operational restrictions, recordkeeping, and reporting requirements.
• Periodic Review. Regularly review all records to identify discrepancies, trends, or potential non-compliance. Internal audits or third-party reviews can help catch issued before they escalate.
• Reporting and Submissions. Ensure that required reports, including the workbook for new or amended permits, are prepared accurately and submitted on time. Compliance tracking systems should integrate reminders and alerts for reporting deadlines.

Compliance with TCEQ’s surface coating requirements goes beyond simply submitting the workbook; it requires ongoing tracking of coatings, solvents, and emissions, careful monitoring of process parameters, and maintaining accurate, audit-ready records. Facilities that implement structured compliance tracking not only reduce the risk of delays or permit issues but also ensure that all NSR and PBR submissions remain fully aligned with regulatory expectations. To support businesses in meeting these obligations, our team offers comprehensive services, including emissions calculations, permit documentation, and compliance tracking solutions, helping surface coating operations maintain efficiency, accuracy, and confidence in their regulatory compliance. Contact your local Trinity Texas Office today to discuss your surface coating permitting and compliance needs!