1.8        Abrasive Blasting Operations Permitting Process

1.8.1            Permitting Requirements for Abrasive Blasting Operations

The MDOT MAA or tenant consultant is responsible for obtaining an MDE/ARMA Air Quality Permit to Construct if they meet the regulatory definition of abrasive blasting operations, specifically dry abrasive blasting operations which are regulated under 40 CFR Part 63 (National Emissions Standards for Hazardous Air Pollutants [NESHAPs]), Subpart XXXXXX. Entities potentially affected by NESHAP Subpart XXXXXX at MDOT MAA include owners or operators of an area source (see Chapter 1.7 Paint Booths and Abrasive Blasting Operations for definition of area source) that is primarily engaged in the operations in one of the following source categories: (1) Fabricated Metal Products; (2) Industrial Machinery and Equipment Finishing Operations; and (3) Valves and Pipe Fittings. More specifically, NESHAP Subpart XXXXXX applies to area sources in these source categories that use or have the potential to emit compounds of cadmium, chromium, lead, manganese, or nickel from metal fabrication or finishing operations.

Neither BWI Marshall nor Martin State Airports are primarily engaged in the operations of any of the nine source categories listed in this subpart; therefore, the regulations of NESHAP Subpart XXXXXX may not be applicable. However, obtaining a permit to construct for abrasive blasting operations in MD predates the promulgation of Subpart XXXXXX, therefore, a permit to construct may still be required. In addition, there may be tenant operations that require compliance with NESHAP Subpart XXXXXX. Tenant operations are commonly not included in the facility’s permit because they are considered under separate ownership and would be required to operate under separate permits. For example, equipment owned/operated by an airline would be permitted under the airline and compliance would be the responsibility of the airline and not MDOT MAA.

Abrasive blast cleaning equipment using a suspension of abrasive in water is exempt from obtaining a Permit to Construct per COMAR 26.11.02.10O(1). Furthermore, per COMAR 26.02.07.03, open abrasive blasting for the abatement of lead-containing substances (i.e., lead-based paint) is prohibited.

1.8.2            Design Guidelines for Abrasive Blasting Operations

Particulate matter (PM) and (particulate) HAPs are typically emitted from abrasive blasting operations. These emissions are dependent on both the abrasive material and the targeted surface. COMAR 26.11, Air Quality, regulates visible emissions (VEs), as well as PM emissions. The consultant must ensure that the abrasive blasting operation:

·        Does not cause or permit the discharge of emissions from any installation or building, other than water in an uncombined form, which is visible to human observers as required under the general provisions in COMAR 26.11.06.02.C.

·        Does not cause or permit to be discharged (from a confined source) into the outdoor atmosphere from any other installation, PM in excess of 0.03 gr/SCFD (68.7 mg/dscm) as required by COMAR 26.11.06.03.B(2). Confined sources are defined as installations that discharge into the atmosphere through a stack, duct, hood, flue, or other conduit.

·        Does not cause PM emissions to be emitted from unconfined sources without taking reasonable precautions (i.e., installation and use of hoods, fans, and dust collectors to enclose, capture, and vent emissions) to prevent PM from becoming airborne. Unconfined sources are defined as installations that cause emissions which are not enclosed in a stack, duct, hood, flue, or other conduit but which escape into the atmosphere through openings such as windows, vents or doors, ill-fitting closures, or poorly maintained equipment.

·        Does not cause or permit any material to be handled, transported, or stored, or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent PM from becoming airborne.