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Draft RG-169
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
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 with
Disabilities 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.
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
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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.
(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)
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However, most abrasive blast cleaning facilities that require an air quality permit only
require a Permit to Construct.
(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.
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.
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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
Particle Size
Silica Sand
Coal Slag
PM
PM10
NOTE: For other types of blast media, please consult the manufacturer for this
data.
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The following is an example of calculating hourly PM and PM10 emissions of coal slag:
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
Silica Sand
Coal Slag
PM
PM10
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:
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.
State Regulations
Abrasive Blasting of Water Storge Tanks (30 TAC Chapter 111, Division 3). See
Appendix A.
Federal Regulations
National Ambient Air Quality Standards (NAAQS) for Lead and PM 10
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
Abrasive Blasting of Water Storage Tanks
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storage tank.
Testing
and
control
requirements
specified
in
is < 500 feet away or less than ten times the height of the
required:
vacuum blasting or
shrouded wet abrasive blasting or
$ 1% lead concentration) or
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:
assume waste is hazardous or
perform a toxic characteristics leaching procedure
(TCLP) on the waste and compare to 40 CFR
Part 61 or
use process knowledge such as MSDS or data
sheets and compare to 40 CFR Part 61