### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA’s Notice of Direct Final Rulemaking

For the

California State Implementation Plan

South Coast Air Quality Management District

Rule 11 40

- Abrasive Blasting

Christine Vineyard

August 2 2, 2014

### Agency: South Coast Air Quality Management District (SCAQMD)

Rule 1140: Abrasive Blasting

SIP

- approved version : September 28, 1981

Amended by SCAQMD : August 2, 1985

Submitt ed by CARB : November 12, 1985

EPA Completeness: May 12, 1986

Rule Summary The purpose of this rule is to limit emissions of particulate matter (PM) from abrasive blasting activities and set standards for the abrasives that may be used in different blasting operatio ns. Among other things t he rule requires a visible emission evaluation to determine the impact of abrasive blasting operations on visibility.



### Rule Changes The following changes were made to Rule 1140: (a) Definitions

- added definitions for brush

- off blasting, facility and steel or iron shot/grit to improve the clarity of the rule. (b) Operating Requirements

– specifications were added for confined abrasive blasting and abrasive blasting of stucco and concrete operations. (c) Requirements for Abrasives

– a re quirement was added to stipulate that a blend of
certified abrasives shall be considered certified. (d) Test Methods

– detailed protocols were added for the evaluation of visible emissions.



### Rule Evaluation

a. Rule Stringency

– Abrasive blasting results in emissions of particulate matter of ten microns or less (PM 10 ) and particulate matter of 2.5 microns or less (PM 2.5 )

. In PM 2.5 and

PM 10 nonattainment areas classified as moderate, the SIP must include Reasonably Available Control Measures (RACM) (see Clean Air Act ( CAA ) section 189(a)(1)). The SCAQMD regulates a PM 2.5 nonattainment area classified as moderate (see 40 CFR 81.305), so the RACM requirement applies to this area. Rule 1140 largely implements reasonably available controls requirements because it s requirements are substantively
similar to the California Code of Regulations, Title 17, Subchapter 6

– Abrasive Blasting provisions

, which have been adopted by most California Air Districts and help define RACM for this activity

. EPA will act on the State’s RACM demonstrations separately
based on an evaluation of the control measures submitted as a whole and their overall potential to advance the applicable attainment dates for PM 2.5

.b. Enforceability

– CAA § 110 (a ) ( 2 ) ( A) requires that regulations submitted to EPA for SIP

approval must be clear and legally enforceable. Rule 1140’s requirements for submission of data on dust collection systems, suppression systems and certification are
clear and enforceable.

c. Anti

- Backslidi ng

– CAA § 110 (l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirements concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition CAA §

193 prohibi ts relaxing existing requirements in some circumstances . The submitted rule 1140 strengthens the SIP rule by adding operating requirements for confined abrasive blasting and abrasive blasting of stucco and concrete operations; and a detailed protocol
for the evaluation of visible emissions. As a result, w e do not expect any negative impacts to SCAQMD ’s ongoing efforts to attain and maintain the National Ambient Air Quality S tandards.

d. Additional Recommendations for the next rule revision

– The following revisions to the currently SIP

- approved rule are not currently the basis for the submitted rule disapproval, but are recommended for the next time the rule is amended:

We recommend that SCAQMD remove the director’s discretion from the defi nition of wet abrasive blasting and the reference d test method : (a) Definitions

– (15) Wet Abrasive Blasting is any abrasive blasting using compressed air as the propelling force, which in the judgment of the Executive Officer uses an amount of water adeq uate to minimize the plume.

(d) Test Method

- All abrasives used for dry unconfined blasting shall comply with the performance requirements of sections (c ) ( 1 ) ( A) and (c) (1) (B) when tested in accordance with "Method of Test for Abrasive Media Evaluation, Test Method No. Calif.

371

- A", or other test method approved by the Executive Officer

.



### EPA Action The submitted rule strengthens the SIP and fulfills the relevant CAA requirements regarding enforceability , anti

- backsliding and rule stringency. Therefore, submitted Rule 1140 should be given full approval.



### Attachments

1. SCAQMD Rule 1140

– Abrasive Blasting, amended August 2, 1985.

2. SIP

- Approved Rule 1140, Abrasive Blastin g, adapted February 1, 1980.