Abrasive Blast Cleaning

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March 2001 Draft RG-169

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The TCEQ is an equal opportunity/affirmative action employer. The agency does not allow discrimination on the basis of race, Authorization for use or reproduction of any original material contained in this publication, i.e., not obtained from other sources, is freely granted. The Commission would appreciate acknowledgment.

Copies of this publication are available for public use through the Texas State Library, other state depository libraries, and the TCEQ Library, in compliance with the state depository law. For more information on TCEQ publications call (512) 239-0028 or visit our Web site at:

www.tceq.state.tx.us

Published and distributed by:

Texas Commission on Environmental Quality P.O. Box 13087

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Overview of Technical Guidance Package for Dry Abrasive Blast

Cleaning

This package discusses the different types of authorizations to construct and operate dry abrasive blast cleaning facilities as well as provides technical information necessary for

completing an air permit application. In addition, a list of potentially applicable state and federal rules are listed.

This package does not:

(1) ... address dry abrasive blast cleaning of water storage tanks. We have a specific regulation for this type of operation under Abrasive Blasting of Water Storage Tanks Performed by Portable Operations (30 TAC § 111.131-111.139). Contact our Engineering Services Division at (512) 239-1051 for more information.

(2) ... include Wet Blast Cleaning or Water Slurry Blast Cleaning. These operations can generally be exempt from permitting.

(3) ... include technical guidance for spray painting facilities. Please request a copy of the

Technical Guidance Package for Surface Coating Facilities from our

administrative section of the New Source Review Permits Division at (512) 239-1250 for a copy of this package.

(4) ... address questions of an administrative nature, application forms, registration forms, and general publications. Contact our administrative section of the New Source Review Permits Division at (512) 239-1250 for more information.

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Obtaining Authorization to Operate

TCEQ has three ways to obtain authorization to construct and operate your abrasive blast cleaning facility:

Grandfathered from Permitting

Grandfathered facilities are those that were in operation prior to September 1, 1971 and have not undergone modification to their operation. If grandfathered, no authorization is required.

Exempt from Permitting

A facility may be exempt from the requirement to obtain an air permit if the emissions are insignificant. The following is a list of exemptions that are applicable to abrasive blast cleaning:

C Wet Blast Cleaning (30 TAC § 106.451) C Dry Abrasive Cleaning (30 TAC § 106.452)

To qualify, the conditions of each exemption must be met exactly. In addition, registration may be required as well.

Required to have a Permit

If your facility is not grandfathered and cannot meet the conditions of an exemption, then you must obtain an air quality permit. We have the following types of air quality permits:

C Permit to Construct (30 TAC § 116.116 Subchapter B) C Standard Permits (30 TAC § 116.116 Subchapter F) C Flexible Permits (30 TAC § 116.116 Subchapter G)

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However, most abrasive blast cleaning facilities that require an air quality permit only require a Permit to Construct.

Review of an Air Quality Permit

The three basic parts of the technical review of an air permit application are:

(1) Review of any proposed source reduction or proposed add-on control methods. This is known as the Best Available Control Technology (BACT) review.

(2) Calculation of estimated hourly and annual emission rates accounting for any controls proposed for the BACT review.

(3) Estimation and evaluation of off-property concentrations of each chemical/compound that may be emitted.

Note: Even though we may accept a BACT proposal, the resulting off-property

concentrations may still be too high. In this case, additional levels of control above the BACT proposal may be required to reduce the off-property concentrations.

Best Available Control Technology (BACT) Review

For dry abrasive blast cleaning facilities, our current BACT Guidelines for Dry Abrasive Blast Cleaning Operations do not require process controls or add-on controls.

Emission Rate Calculations

Hourly and annual emission calculations of particulate matter are necessary for the off-property impacts review. In addition, these emission rates are used to determine the applicability of other rules and regulations. The emissions are separated into two categories: total suspended particulate matter (PM) and particulate matter less than or equal ten microns in size (PM10).

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Enclosed Operations

If you will be operating an enclosed blast cleaning operation, you will most likely be able to be exempt from permitting under Dry Abrasive Cleaning (30 TAC § 106.452).

The following equation can be used to calculate hourly and annual PM and PM10 emission

rates:

where

Usage is the blast media usage,

Emission Factor is selected from the following:

Particle Size Silica Sand Coal Slag

PM 0.00590 lb PM/lb usage 0.00286 lb PM/lb usage

PM10 0.00140 lb PM10/lb usage 0.00034 lb PM10/lb usage

NOTE: For other types of blast media, please consult the manufacturer for this data.

Removal Efficiency is the manufacturer’s average weight arrestance efficiency for

fabric filters. For baghouses or cartridge filters, a 95% average weight arrestance efficiency may be used if the outlet grain loading is less than or equal to 0.01 grains per dry standard cubic foot.

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The following is an example of calculating hourly PM and PM10 emissions of coal slag:

example usage rate = 1000 pounds per hour

example control device is a baghouse with a 0.002 gr/dscf outlet grain loading select PM Emission Factor of 0.00286 for coal slag

select PM10 Emission Factor of 0.00034 for coal slag

NOTE: An enclosure, building, or room is considered to be enclosed if it can maintain a face velocity of at least 100 feet per minute (fpm) as follows:

Non-enclosed Operations

These equations are for calculating emission from facilities that operate outdoors or cannot achieve a 100-fpm face velocity. The following equation can be used to calculate hourly and annual emission PM and PM10 emission rates:

where

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Emission Factor is selected from the following:

Particle Size Silica Sand Coal Slag

PM 0.00590 lb PM/lb usage 0.00286 lb PM/lb usage

PM10 0.00140 lb PM10/lb usage 0.00034 lb PM10/lb usage

NOTE: For other types of blast media, please consult the manufacturer for this data.

The following is an example of calculating hourly PM and PM10 emissions of silica sand:

example usage rate = 4000 pounds per hour

select PM Emission Factor of 0.0059 for silica sand select PM10 Emission Factor of 0.0014 for silica sand

Impacts Review

For facilities under permit review, we evaluate the predicted off-property concentrations of particulate matter that may be emitted. Computerized air dispersion models are used for this analysis (Environmental Protection Agency (EPA) Screen or EPA ISCST3).

Since these analyses are specific to each facility and the density of the blast media used, it is not feasible to provide general guidance for the impacts review. Also, there are specific rules

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regarding marine vessel maintenance and repair facilities. Please request a copy of our Air Quality Modeling Guidelines or contact the Coatings Section at (512) 239-1250 for more guidance.

For small businesses, we will normally perform the air dispersion modeling for you.

Applicable Rules and Regulations

Even if you can operate as grandfathered, exempt, or permitted, there are several other regulations that directly apply to dry abrasive blast cleaning facilities.

State Regulations

Abrasive Blasting of Water Storge Tanks (30 TAC Chapter 111, Division 3). See Appendix A.

Ground Level Concentrations (30 TAC § 111.155)

The off-property concentrations of PM cannot exceed 400 µg/m3_{for any}

one-hour period and cannot exceed 200 µg/m3_{for any three-hour period.}

Federal Regulations

National Ambient Air Quality Standards (NAAQS) for Lead and PM10

NAAQS for Lead (if removing lead-based paint): The off-property concentrations of lead cannot exceed 1.5 µg/m3_{over any three-month}

period.

NAAQS for PM10: The off-property concentrations of PM10 cannot

exceed 150 µg/m3_{over any 24-hour period and cannot exceed 50}

µg/m3_PM

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Depending on the specific operation of your facility, other regulations may also apply. See our web site at www.tceq.state.tx.us/nav/permits/air_permits.html to obtain the entire list of regulations or contact the Coatings Section at (512) 239-1250.

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Appendix A

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Technical Notes for Abrasive Blasting of Water Storage Tanks

TCEQ Air Quality Rules

TCEQ does NOT require an air quality permit to perform this type of maintenance activity. However, the TCEQ Office of Air Quality has specific rules in Regulation I (30 TAC Chapter 111) which apply to maintenance operations using abrasive blasting to remove coatings from water storage tanks.

Testing Requirements, Rule 111.133

Before removal, the concentration of lead in the coating must be determined (given in :g/g). This concentration must be made available to TCEQ staff at blasting site for the duration of the blasting job.

Control Requirements, Rules 111.135 & 111.137 If lead concentration $ 1% (10,000 :g/g), or if lead concentration < 1% (10,000 :g/g) and nearest residence is < 500 feet away or less than ten times the height of the water tower away, any one of the following controls are required:

º vacuum blasting or

º shrouded wet abrasive blasting or

º shrouded dry abrasive blasting (if $ 500 feet or 10 times the height of the water tower away from nearest residence or public area and blasting $ 1% lead concentration) or

º shrouded hydro blasting or

º equivalent method approved in advance by TCEQ

No controls are required for blasting < 1% lead concentration if there are no private residences or public areas within 500 feet or within ten times the height of storage tank.

Exemptions, Rule 111.139

Testing and control requirements specified in above-mentioned rules not required for the following:

º abrasive blasting of the interior of the water storage tank if there are no visible emissions

º abrasive blasting using less than 500 pounds per day of abrasive media

º alternate control method approved by TCEQ executive director

Nuisance, Rule 101.4 of TCEQ General Rules The operation may not create a nuisance condition. This means additional controls may be needed even if applicable control requirements or exemption conditions are met. The TCEQ regional office determines whether a nuisance condition exists.

TCEQ Waste Disposal Guidelines

The TCEQ does not specifically regulate the generation or disposal of non-hazardous, non-industrial waste. Waste generated during abrasive blasting of a water tank at a non-industrial facility is not regulated unless it is hazardous. For regulated waste (hazardous/industrial), the Waste Evaluation Section of the TCEQ Office of Waste

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numbers, and waste codes to help facilities classify and dispose their waste. Determination of Hazardous Waste

Waste is considered hazardous if it is listed in 40 CFR Part 261 or if it exhibits one or more hazardous waste characteristics listed in 40 CFR Part 261. To make a determination:

º assume waste is hazardous or

º perform a toxic characteristics leaching procedure (TCLP) on the waste and compare to 40 CFR Part 61 or

º use “process knowledge” such as MSDS or data sheets and compare to 40 CFR Part 61

Disposing of Hazardous Waste

EPA regulates all hazardous waste. Hazardous waste must be disposed at a permitted hazardous waste facility: º request a “one-time” waste disposal form

(Form 0757) and state registration and EPA identification numbers from the TCEQ Waste Evaluation Section

º complete the form and send back to the TCEQ Waste Evaluation Section

º TCEQ will evaluate the information and assign state registration and EPA identification numbers (disposal sites will require these)

Disposing of Non-Hazardous Waste

Neither TCEQ nor EPA regulates non-hazardous waste from non-industrial operations. Check with the local government agency that has jurisdiction over disposal of