Abrasive Blast Cleaning
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Transcript of Abrasive Blast Cleaning
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A i r P e r m i t s D i v i s i o n
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
March 2001Draft RG-169
Abrasive Blast Cleaning
The TCEQ is an equal opportunity/affirmative action employer. The agency does not allow discrimination on the basis of race,color, religion, national origin, sex, disability, age, sexual orientation or veteran status. In compliance with the Americans withDisabilities Act, this document may be requested in alternate formats by contacting the TCEQ at (512)239-0028, Fax 239-4488,or 1-800-RELAY-TX (TDD), or by writing P.O. Box 13087, Austin, TX 78711-3087.
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
Austin, Texas 78711-3087
Draft Page i
Table of Contents
Overview of Technical Guidance Package for Dry Abrasive Blast Cleaning . . . . . . . . . . 1
Obtaining Authorization to Operate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Review of an Air Quality Permit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Best Available Control Technology (BACT) Review . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Emission Rate Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Impacts Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Applicable Rules and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Appendixes
Appendix A - Abrasive Blasting of Water Storage Tanks . . . . . . . . . . . . . . . . . . . . . 9
Draft Page 1 of 11
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.
Draft Page 2 of 11
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)
Draft Page 3 of 11
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).
Draft Page 4 of 11
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.
Draft Page 5 of 11
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
Usage is the blast media usage rate,
Draft Page 6 of 11
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
Draft Page 7 of 11
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 PM 10
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 PM10 over any 12-month period.
Draft Page 8 of 11
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.
Draft Page 9 of 11
Appendix A
Abrasive Blasting of Water Storage Tanks
Draft Page 10 of 11
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
Management provides information, forms, registration
Draft Page 11 of 11
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
non-hazardous, non-industrial waste.