8-PTO_13968.pdf

OCT 0 7 2013

Certified Mail 7011 3500 0002 7298 7482 Return Receipt Requested

Thomas de V enoge Vandenberg Air Force Base, 30 CES/CEA 1 028 Iceland A venue Vandenberg AFB, CA 93437-6010

Re: Final Part 70 Permit 13968 Fee Due: $ 3,180

Dear Mr. deVenoge:

FID: 00201

Permit: P7 13968

SSID: 01195

Enclosed is the final Part 70 Permit (PT-70) No. 13968 for Vandenberg Air Force Base.

Please carefully review the enclosed documents to ensure that they accurately describe your facility and that the conditions are acceptable to you. Note that your permitted emission limits may, in the future, be used to determine emission fees.

You should become familiar with all District rules pertaining to your facility. This permit does not relieve you of any requirements to obtain authority or permits from other governmental agencies.

This permit requires you to:

• Pay a fee of$3,180, which is due immediately and is considered late after 30 calendar days from the date stamped on the permit. This fee is the remainder due after crediting your earlier payment of the estimated permit fee. Pursuant to District Rule 210.IV.B, no appeal shall be heard unless all fees have been paid. See the attached invoice for more information.

Follow the conditions listed on your permit. Pay careful attention to the recordkeeping and reporting requirements.

• Ensure that a copy of the enclosed permit is posted or kept readily available near the permitted equipment.

• Promptly report changes in ownership, operator, or your mailing address to the District.

If you are not satisfied with the conditions of this permit, you have thirty (30) days from the date of this issuance to appeal this permit to the Air Pollution Control District Hearing Board (ref:

California Health and Safety Code, §42302.1). Any contact with District staffto discuss the terms ofthis permit will not stop or alter the 30-day appeal period.

ECEIVEn OCT_ 8 2013 u

~v:-_-------.,- L 0 u i s D . v a n M u I I e m I J r . A i r p 0 I I u t i 0 n c 0 n t r 0 I 0 -f f i c e r

260 North San Antonio Road, Suite A • Santa Barbara, CA • 93110 • www.sbcapcd .org • 805.961.8800 • 805.961.8801 (fax)

Please include the facility identification (FID) and permit numbers as shown at the top of this letter on all correspondence regarding this permit. If you have any questions, please contact Ben Ellenberger of my staff at (805) 961-8879.

Sincerely, Michael Goldman, Manager Engineering Division enc: Final PT-70 13968 Final Permit Evaluation Invoice # P7 13968 Air Toxics "Hot Spots" Fact Sheet District Form 12B cc: Vandenberg AFB 30 CES/CEA 00201 Project File ECD Chron File Accounting (Invoice only) Craig Strommen (Cover letter only) Mr. Joe Naputi, Vandenberg Air Force Base, 30 CES/CEA (Cover Letter Only) Ms. Kimberlee Harding, Vandenberg Air Force Base, 30 CES/CEA (Cover Letter Only)

\\sbcapcd.org\shares\Groups\ENGR\WP\V AFB\Reevals\PT-70 13968\PT-70 13968 -Final Letter- 9-30-2013.doc

Santa Barbara County Air Pollution Contro l District

FINAL

PERMIT to OPERATE 13968

Vandenberg Air Force Base, 30th Space Wing

OWNERS

United States Air Force, National Aeronautics and Space Administration, Missile Defense Agency, National Reconnaissance Office, Army Air Force

Exchange Service

OPERATORS

United States Air Force, Excelis Federal Services, a.i. solutions, United Launch Alliance, The Boeing Company, EMCOR, Lockheed Martin IS&GS, Northrup Grumman, Army Air Force Exchange Service, Fort Mojave Services II, LLC, Corporate Allocation Services, Inc., United Paradyne

Corporation, Alliance Technical Services, Inc.

Santa Barbara County Air Pollution Control District

OCTOBER 2013

This Page Left Blank

Permit No. 13968 Page i

Contents

ABBREVIATIONS/ACRONYMS ••.•..•.•.•........•....•....•.•.••.•.......................•..•.••....•...•...•.•........•..•.•...•...•..•

1.0 INTRODUCTION ...............................................................••.........................................................•. 5

1.1. PURPOSE

1.2. STATIONARY SOURCEIF ACILITY OVERVIEW

1.3 EMISSION SOURCES

1.4 EMISSION CONTROL OVERVIEW

1.5 OFFSETS/EMISSION REDUCTION CREDIT OVERVIEW

2.0 DESCRIPTION OF PROJECT AND PROCESS DESCRIPTION

3.0 REGULATORY REVIEW .•.•........•.•................•.....•....•....•......•.•..•....•.•.•.........•.•...•.........•...•

3 .1. PERMIT EXEMPTIONS CLAIMED

3 .2. COMPLIANCE WITH APPLICABLE FEDERAL RULES AND REGULATIONS

3.3. COMPLIANCE WITH APPLICABLE STATE RULES AND REGULATIONS ... .. ............•

3 .4. COMPLIANCE WITH APPLICABLE LOCAL RULES AND REGULATIONS

3.5. COMPLIANCE HISTORY ..... . ..... ... .. .... ..... ........ . .. ..... ............... ..... . ..... ... ......... .. ..... .. ..........•

4.0 ENG·INEERING ANALYSIS .••.•.•.•...••.•....•......•...••••....•.••.•.•.••.•.•.•..•..•.•..•.•.•.••.•.•.•...••.••.•.•......•

4.1. GENERAL ...... .. ... ........................ ........ .....•

4.2. EXTERNAL COMBUSTION UNITS

4.3. RECIPROCATING INTERNAL COMBUSTION ENGINES

4.4. TuRBINES ...................................................................... . ... ............. . .. . ...... . ... . .. . ......... ...... .. . .... ·

4.5. BULKFUELSTORAGE ...................................................•

4.6. ABRASIVE BLASTING

4.7. COATING OPERATIONS

4.8. SOLVENTUSAGE

4.9. LANDFILL GAS ........... ....... ......... .. .. ..... .. ... .. ......... :

4.10. GASOLINEDISPENS·ING

4.11. HYDROGEN SULFIDE D EGASIFYING

4.12. HYPERGOLIC FUEL STORAGE AND HANDLING .........................................................•

4.13. PERMITEXEMPTEQUIPMENT

4.14. PROCESS MONITORING .•

4.15. BEST AVAILABLE CONTROL TECHNOLOGY (BACn ......... .... . ...•

4.1 6. SOURCE TESTING/TuNING/SAMPLING

4.17. PART 70 ENGINEERING REVIEW: HAzARDOUS AIR POLLUTANT EMISSIONS

5.0 EMISSIONS •.•.••..•...•....•.•...••.•..•.•........•••.........•....•....................•....••.................•.................•••..•.•.•.. 44

5.1 . GENERAL

5 .2. PERMITTED EMISSION LIMITS - EMISSION UNITS

5.3. PERMITTED EMISSION LIMITS- FACILITY TOTALS

5.4 GREENHOUSE GASES ...... . ..... .. ...... . .........•

5.5 NET EMISSIONS INCREASE CALCULATION

5 .6 PART 70: HAP POTENTIAL TO EMIT EMISSION ESTIMATES

6.0 AIR QUALITY IMPACT ANALYSES ..•..•.•..•.•.....................•.•...•..•..•.••.•.....•.•.•

6.1 . MODELING

6.2 INCREMENTS ................................... ,

6.3 MONITORING

6.4 HEALTH RISK ASSESSMENT ...................... ..... . . .......•

7.0 CAP CONSISTENCY, OFFSET REQUIREMENTS AND ERCS

Final Pennit to Operate 13968 Page 1 of315

7.1. GENERAL ... .. ... ...... . ..................... ... ... . .. .... .. .. ..... .. .. .... .... .... .... . .. .. ... . ... .. . ............... .. ... . .. .. .. ..... ........ . .. l01

7 .2. CLEAN AIR PLAN

7.3. EMISSION REDUCTION CREDITS (ERCS)

7.4. OFFSET REQUIREMENTS

8.0 LEAD AGENCY PERMIT CONSISTENCY

9.0 PERMIT CONDITIONS

Final Permit to Operate 13968 Page 2 of3l5

AP-42

A-50

AQMM

ASTM

ATC

ATCM

ATEIP

ATEIR

BACT

BTDC

Btu

CAAA

CARB

CAM

CEMS

CAP

CFR

co C02 C02e

CPI

DAS

DICE

District

DLA-E

DOT

DPF

DRPIISC

EF

ENVVEST

E/S

ERC

oF

FID

FUMP

FVSS

gr

GDF

GHG

HAP

HC

HRA

HSF

H&SC

H2S I&M

IPA

lSD k l lb lbs/day lbs/hr

ABBREVIATIONS/ ACRONYMS

USEPA's Compilation of Emission Factors Aerozine-50 Air Quality and Meteorological Monitoring American Society for Testing Materials Authority to Construct Air Toxic Control Measure Air Toxics Emission Inventory Plan Air Toxics Emission Inventory Report Best Available Control Technology Below top dead center British thermal unit California Clean Air Act Amendment California Air Resources Board compliance assurance monitoring Continuous Emissions Monitoring System Clean Air Plan Code of Federal Regulations Carbon Monoxide Carbon Dioxide Carbon Dioxide Equivalent Consumer Price Index Data Acquisition System Diesel Internal Combustion Engine Air Pollution Control District Defense Logistics Agency-Energy Department of Transportation Diesel Particulate Filter Demand Response Program/Interruptible Service Contract Emission factor Environmental Investment Emergency Service Emission Reduction Credit degree Fahrenheit facility identification Fuel Use Monitoring Plan Fuel Vapor Scrubbing System grain Gasoline Dispensing Facility Greenhouse Gases hazardous air pollutant (as defmed by CAAA, Section 112(b)) Hydrocarbon Health Risk Assessment Hypergolic Fuel Storage Facility Health and Safety Code hydrogen sulfide Inspection & Maintenance Iso-Propyl Alcohol In-Station Diagnostics kilo (thousand) liter pound pounds per day pounds per hour

Final Permit to Operate 13968 Page 3 of315

LPG

LFG

M

MACT

MM

MMH

MRS

M&T

MVFF

MW

N2H4

NAR

NEI

NSR

NSPS

NESHAP

NFPA

NMOC

NOV

ORVR

ovss Oz

PM

PMIO

ppm(vd orw)

PSD

psi a psig

PTE

PTO

PUC

PN

QA/QC

RACT

RICE

RPM

RSV

ROC

S02 scf scfd (or scfm)

SIP

SOx

SSID

SVPP

TPQ

TPY

TVP

UDMH

ULA

USEPA

VAFB

VRS

Liquified Petroleum Gas Landfill Gas mega (million) Maximum Achievable Control Technology million Mono-Methyl Hydrazine Microwave Reactor System Maintenance and Testing Motor Vehicle Fueling Facility molecular weight Hydrazine Nonattainment Review net emissions increase New Source Review New Source Performance Standards National Emissions Standards for Hazardous Air Pollutants National Fire Protection Association Non-methane Organic Compounds Notice of Violation Onboard Refueling Vapor Recovery Oxidizer Vapor Scrubbing System oxygen particulate matter particulate matter less than I 0 microns parts per million (volume dry or weight) Prevention of Significant Deterioration pounds per square inch absolute pounds per square inch gauge Potential to Emit Permit to Operate Public Utility Commission PressureNacuum Quality Assurance/Quality Control Reasonably Available Control Technology Reciprocating internal combustion engine Revolutions per Minute Ready Storage vessel reactive organic compounds, same as "VOC" as used in this permit Sulfur Dioxide standard cubic foot standard cubic feet per day (or per minute) State Implementation Plan Oxides of Sulfur stationary source identification South Vandenberg Power Plant Tons per quarter Tons per Year true vapor pressure Unsymmetrical Dimethylhydarzine United Launch Alliance United States Environmental Protection Agency Vandenberg Air Force Base vapor recovery system

Final Permit to Operate 13968 Page 4 of315

1.0 Introduction

1.1. Purpose

General. The Santa Barbara County Air Pollution Control District ("District") began issuing permits to Vandenberg Air Force Base (VAFB) in the 1980s for boilers, water heaters and miscellaneous equipment for abrasive blasting, solvent use and fuel storage operations. Due to the loss of rule exemptions and new rules and regulations, an increased number of external combustion units and internal combustion engines have since become subject to permit. This Part 70 permit consolidates all active permits associated with the facilities that comprise the V AFB stationary source. Most of the permitted equipment consists of emergency standby generators and small boilers and water heaters.

Part 70 Permitting. This is the initial Part 70 permit for the V AFB stationary source (SSID =

1195), which is a major source for NOx, CO, and GHGs, based on a federal potential to emit greater than 100 tons per year ofNOx and CO and 100,000 tons per year GHGs. The conditions listed in this permit are based on federal, state or local rules and requirements. Sections 9.A, 9.B and 9.C of this permit are enforceable by the District, the United States Environmental Protection Agency (USEPA) and the public since these sections are federally enforceable under Part 70.

Where any reference contained in Sections 9.A, 9.B or 9.C refers to any other part of this permit, that part of the permit referred to is federally enforceable. Conditions listed in Section 9.D are only enforceable by the District.

Pursuant to the stated aims of Title V of the CAAA (Clean Air Act Amendment) of 1990 (i.e., the Part 70 operating permit program), this permit has been designed to meet two objectives. First, compliance with all conditions in this permit would ensure compliance with all federally enforceable requirements for the facility. Second, the permit would be a comprehensive document to be used as a reference by the permittee, the regulatory agencies and the public to assess compliance.

Tailoring Rule. On January 20, 2011 , the District revised Rule 1301 to include GHGs that are "subject to regulation" in the definition of "Regulated Air Pollutants". District Part 70 operating permits now include GHG potential to emit (PTE) calculations to determine whether a facility is a major source for GHGs.

1.2. Stationary Source/Facility Overview

1.2.1 Stationary Source/Facility Overview: V AFB is located on the south-central coast of California

(Figure 1.1) and is headquarters for the 30th Space Wing (30 SW). The Air Force's primary missions at V AFB are launching and tracking satellites in space, testing and evaluating America's intercontinental ballistic missile systems, and supporting aircraft and space operations in the Western Range. The 30 SW hosts several other Federal agencies that conduct activities independent of 30 SW operations.

Military installations are intrinsically more organizationally complex than traditional industrial facilities and include a wider variety of functions and activities, such as residential housing, schools, churches, recreational parks, shopping centers, industrial operations, training ranges, airports, gas stations, utility plants, police and fire departments, and hospitals and clinics.

Additionally, they host various tenants, including other Department of Defense (DoD) services, non-DoD Federal agencies, contractors, and leased areas for commercial activities. These entities own and operate their own separate industrial processes. The DoD and other federal agency operations on V AFB are considered part of the V AFB stationary source. The commercial space

Final Permit to Operate 13968 Page 5 of315 activities located at V AFB are not owned and operated by the federal government, therefore they are not considered part of the VAFB stationary source.

Figure 1.1.

Pacific Ocean

Final Permit to Operate 13968

- VAFB Property

River, stream, creek

--=::::::11---===::::J Milos 0 6 9

N w"'";tr-E s

Page 6 of315

1.2.2 Facility New Source Review Overview (NSR): Existing equipment at V AFB that requires a permit solely due to the loss of permit exemption is not subject to NSR. New and modified equipment at VAFB is subject to NSR. A list of the permits that are being incorporated into this Part 70 permit is provided in Attachment 1 0.11. Those permit actions which are subject to NSR are identified in the attachment.

1.2.3 Project Ownership: The equipment at the stationary source is owned by the following entities:

United States Air Force, National Aeronautics and Space Administration, Missile Defense Agency, National Reconnaissance Office, Army Air Force Exchange Service.

The equipment at the source is operated by the following entities: United States Air Force, Excelis Federal Services, a.i . solutions, United Launch Alliance, The Boeing Company, EMCOR, Lockheed Martin IS&GS, Northrup Grumman, Army Air Force Exchange Service, Fort Mojave Services II, LLC, Corporate Allocation Services, Inc. , United Paradyne Corporation, Alliance Technical Services, Inc.

1.3 Emission Sources

1.3.1 External Combustion Units: Multiple hot water boilers and heaters provide space heating and hot water service for base operations. See Attachment 10.2 for a list ofthese units.

1.3 .2 Stationary Internal Combustion Engines. Multiple internal combustion engines provide emergency standby power for the operating systems at V AFB or water for fire suppression. One prime engine is used for training. See Attachment 10.3 for a list of these units.

1.3.3 South Vandenberg Power Plant CSVPP): The SVPP consists of five turbine generators that produce a total of 15,000 kW of electricity and serves as an alternate source of power for V AFB.

Each turbine is equipped with a diesel powered pony starter engine. Grid power is the primary source of power at V AFB.

1.3.4 Bulk Fuel Storage:

RP-1 Storage: RP-1 is delivered to SLC-2W by USAF or commercial tanker trucks at a temperature between 30°F and 102°F, depending upon ambient weather conditions. The delivered RP-1 is normally pumped into the Ready Storage Vessel (RSV) for storage at the delivered temperature, using pumps which are integral to the tanker truck. When the configuration or condition of the delivery tanker truck does not provide for pumping, the material may be pumped into the RSV using the recirculation pump contained in the RP-1 transfer skid.

Within a typical launch cycle, the RSV ullage is occasionally vented during the performance of required system operation and maintenance functions. The RSV is vented only for the duration of these functions, after which the gaseous nitrogen blanket pressure is reapplied. It is during these functions that the permitted emissions occur.

In order to accomplish transfer of RP-1 propellant to the launch vehicle, the RSV is pressurized with gaseous nitrogen to create a pressure differential between the RSV and the launch vehicle.

A pressure differential of between 75 psig and 120 psig is used for this transfer.

JP-8 Storage: JP-8 is delivered to aboveground storage tanks 1240 and 1238 at the bulk storage facility by tanker trucks or trailers. An unloading rack is used to transfer the fuel into the tanks.

Final Permit to Operate 13968 Page 7 of315

The fuel is metered from the tanks through fillstands into mobile delivery vehicles for delivery to the flight line. The fillstands are equipped with filter separators and bottom loading arms.

1.3 .5 Abrasive Blasting: Abrasive blasting equipment is utilized for abrasive blasting needs at the base, such as repair, maintenance, and construction activities.

1.3.6 Coating Operations: Spray booths are utilized for various spray painting needs conducted at the base.

1.3.7 Solvent Usage: Wipe cleaning and miscellaneous reactive organic compounds (ROC) containing solvent use occurs at the base. As used in this permit, the term solvent is defined to include solvents, adhesive, sealants and all other ROCs used with this equipment and processes. Cold solvent cleaners and degreasing equipment and processes that are subject to Rule 321 or other applicable District rules are permitted as separate emission units.

1.3.8 Landfill. The landfill has been in operation since 1941. Waste can be accepted 9 hours per day and 6 days per week. Landfill gas (LFG) emissions result from anaerobic biological decomposition of organic matter deposited in the landfill escaping to the surface. LFG consists primarily of methane (CH4) and carbon dioxide (C02) with smaller amounts of non-methane organic compounds (NMOC). Some NMOCs are ROC.

1.3.9 Gasoline Dispensing Facilities: There are two gasoline dispensing facilities subject to this permit that provide fuel for the automobiles and trucks servicing the base. One station provides fuel for vehicles serving the base. The other (AAFES) provides fuel for the privately owned vehicles of military members, dependents, and retirees. Government vehicles may be fueled at AAFES on rare occasions.

1.3 .10 Hydrogen Sulfide CH2S) Degasifiers: State water provides the primary water demands at V AFB.

An alternate source of water is provided by four (4) wells located on Air Force property, about four miles northeast of the main gate. Groundwater containing H2S is pumped from each of the four wells and treated prior to use. H2S removal is achieved through the use of two degasifiers.

Each degasifier serves two wells. A pump elevates the water to the top of each of the degasifiers, as the water cascades down through three layers of "plastic saddles" separating the H2S from the water H2S is released and vented to atmosphere.

1.3.1 1 Hypergolic Propellant Storage and Handling.

Hypergolic Storage Facility (HSF): The HSF is a consolidated area for Vandenberg AFB to store and handle Defense Logistics Agency- Energy (DLA-E) hypergolic fuels and oxidizers.

The facility is divided into two separate facilities, one used to store fuels (hydrazines) and the other to store oxidizer (nitrogen tetroxide). The fuel and oxidizer are used to propel launch vehicles and payloads at various launch facilities on V AFB and other launch facilities throughout the country/world.

The primary hypergolic fuels stored at the facility are Aerozine-50 (A-50), a 50/50 blend of unsymmetrical dimethyl hydrazine (UDMH) and anhydrous "neat" hydrazine (N2H4), and Mono methyl hydrazine (MMH). Additionally, small amounts of fuel, typically hydrazine (N2H4) and High Purity/Ultra Pure hydrazine used for spacecraft propulsion systems is stored in Department of Transportation (DOT) cylinders.

Final Permit to Operate 13968 Page 8 of315

The primary hypergolic oxidizers stored at the facility are different concentrations of nitrogen tetroxide called Mixed Oxides of Nitrogen (MON) referenced with the level of nitric oxide by percentage. These are primarily MON-1 and MON-3 with smaller quantities contained in cylinders ofMON-10 or MON-25.

Bulk quantities of product are delivered to the HSF's 28,000 gallon capacity tanks via commercial trailer. Trailers arrive at the respective facility with their cargo under a pressure blanket of gaseous nitrogen. The operator connects the trailers by flexible hose to the loading/unloading transfer "hardstand" piping system at the facility. Nitrogen gas is used to pressurize and maintain a higher pressure in the trailer during transfer operations to the facility bulk storage tanks. All product transfer operations are performed by pressurizing the supply tank and pushing product into the receiving tank.

At the completion of unloading operations, the operator purges the transfer lines into the liquid/vapor separators and back into the 28,000 gallon capacity tanks with nitrogen gas.

The trailer, storage tank and piping system are vented through each facilities unique vapor scrubber system and then re-blanketed with nitrogen to bring the transfer system to an inert condition. Trailers may also be purged with nitrogen gas. Trailers transfer commodity as needed from the storage tanks to space launch complexes on V AFB and other launch facilities throughout the country/world. The same procedure used for trailer unloading is followed for trailer loading, except the flow is reversed. A higher pressure is maintained in the storage tank relative to the trailer during fuel transfer operations. After the fuel is delivered to the space launch complexes, the trailers are returned to the HSF and may be unloaded of excess fuel and/or purged with nitrogen gas.

A relatively small amount of hypergol product is delivered to the HSF in DOT approved cylinders and stored for use by the space launch community. These cylinders are transported to the various launch complexes and various V AFB locations and other launch complexes throughout the country/world. Some of the commodity in these cylinders will be transferred between cylinders using the facility venting and scrubbing systems in the process. This source will contribute a negligible rate of emissions. All bulk fuels at the HSF are stored under a nitrogen blanket.

The following activities may produce ROC emissions at the HSF:

1. transfer between storage tanks,

2. storage tank purging,

3. trailer loading/unloading,

4. trailer purging, and

5. miscellaneous events that include:

a. liquid/vapor separator vessel drainage,

b. filter change,

c. pressure relief valve change,

d. pressure gauge change,

e. commodity sampling,

f. scrubber waste emptying,

g. flexhose purging,

h. sample bottle draining/flushing, and

1. system decontamination procedure.

Final Permit to Operate 13968 Page 9 of315

The system decontamination procedure utilizes Isopropyl Alcohol (IPA) for flushing out pipes and lines on trailers and associated fixed and portable propellant handling equipment. The operator pumps IPA from a 55 gallon capacity drum into the various portable equipment, pressurizes the equipment using nitrogen, thereby moving the IP A through the closed loop system piping, into a waste drum. The procedure involves the following three steps:

1. Initial opening and dispensing from the 55 gallon (capacity) IPA drum into the piping system.

2. Moving IPA through the pipes by means of pressurized nitrogen and dispensing into a waste drum.

3. Venting/purging of the equipment lines with nitrogen. To remove residual IP A, the operator vents the equipment piping, followed by purging with gaseous nitrogen and/or helium, and/or vacuum pump evacuation. The system controls emissions from the venting, purging or vacuum evacuation procedure using each side's vapor scrubber system.

Microwave Reactor Systems (MRS): Portable MRS are also used to safely control vapors generated during the unloading of hypergolic propellant from launch/re-entry vehicles. Each MRS consists of a microwave reactor, cooling water handling system, gaseous helium or nitrogen pressurization system, and associated lines, valves, and in-line sensors and monitors. Each MRS is skid mounted so it can be used at various locations on V AFB. After propellant off-loading, the MRS is used to decontaminate the propellant transfer equipment and the vehicles so that they can be further processed without the need for a high level of personal protective equipment.

SLC-2 Portable Scrubbers: Two portable scrubber systems will be used to control emissions while loading hypergolic fuel into the second stage of Delta II launch vehicles. One scrubber system will be used to control Aerozine 50 fuel emissions and the second scrubber system will be used to control nitrogen tetroxide oxidizer emissions. The fuel and oxidizer will be loaded from separate tanker trucks into separate tanks on the launch vehicle. The loading is accomplished by pressurizing the tanker truck with helium to 160 psig and flowing the liquid to the launch vehicle.

One set of scrubbers will be used for loading fuel and one set of scrubbers will be used for loading oxidizer during the following operating scenarios:

Case Ll - Normal Loading: While the second stage is loading, vapor displaced from the liquid and vent lines will be will be vented to the portable scrubber. After loading is complete, the tanker pressure will be vented to 20 psig through the portable scrubber. The process lines will be drained back to the tanker and the system will be purged and vented through the portable scrubber. The tanker and scrubber will be removed from the pad to prepare for launch. Normal loading operations are completed in 8 hours during one day.

Post Launch: The portable scrubbers will be returned to the pad for final second stage loading system purging and cleaning after the launch. Purging and cleaning operations are completed in 8 hours during one day.

Case L2 - Worst Case Vent: The mobile tanker must be vented through the portable scrubber to atmospheric pressure (instead of 20 psi g) to allow repairs while on the pad. This operation is completed in 8 hours during one day.

Case L3 - Launch Abort: Sometimes operational problems cause a launch abort that requires a loaded Delta II vehicle to be unloaded back into a mobile tanker. During unloading, the system is vented to a portable scrubber. Once unloading is completed and process lines are drained back to the tanker, the system will be purged and cleaned and vented through the portable scrubber.

Launch abort loading operations are complete in 8 hours during one day.

Final Permit to Operate 13968 Page 10 of315

1.4 Emission Control Overview

1.4.1 External Combustion Units: Many ofthe external combustion units are equipped with Low-NOx burners. These units are identified in Attachment 10.2. (i.e., NOx concentration limit of30 ppm @ 3%02 or less).

1.4.2 Internal Combustion Engines: Emissions from diesel-fired emergency-standby internal combustion engines are controlled by limiting the hours of maintenance and testing operations.

Newly installed emergency standby IC engines must also be certified to meet current USEPA Tier standards. Diesel particulate filters are installed on the following IC engines: Device #111765, #114491, #110738 and #109236. The DPFs are verified by the California Air Resources Board (CARB) and must be operated consistent with the requirements of the verification executive orders.

1.4.3 South Vandenberg Power Plant: Stainless steel alloy precious metal oxidation catalysts are used on each turbine. These catalysts operate within the temperature range of the turbine eXhaust gases and oxidize carbon monoxide (CO) and non-methane hydrocarbon (NMHC) to water and carbon dioxide (C02). A fugitive hydrocarbon inspection and maintenance (I&M) program is used for additional ROC control. NOx emissions are controlled through the use of water injection. The five diesel-fired starter engines associated with the turbines are controlled by limiting the hours of operations.

1.4.4 Bulk Fuel Storage: A gaseous nitrogen blanket pressure of 5 to 25 psig is maintained in the RP-1 RSV at SLC-2 during all times except when performing system operational or maintenance functions. The nitrogen blanket prevents ingress of moisture from the atmosphere and prevents propellant vapor loss.

The POL Bulk Storage Facility stores JP-8 fuel in tanks #1240 and #1238. These tanks are equipped with floating roofs with primary and secondary seals and geodesic dome fixed roofs.

The loading and unloading racks at the facility are not equipped with vapor recovery.

1.4.5 Abrasive Blasting: A dust filtration system with a minimum control efficiency of95.0 percent is utilized at Building #1800. Operations at Building #7438 are conducted in a tented structure to control particulate matter (PM and PM10). There are two abrasive blasting operations in Building #9320. The VACU-Blast abrasive blasting operation (Device ID 9890) employs a direct-pressure blast generator and a pneumatic recovery and reclaiming system. The dust collector has a minimum control efficiency of 98.0 percent and uses a mechanical shaker mechanism to clean the filters. The ABS Blast abrasive blasting operation in Building #9320 (device ID 110229) has a dust collector with a minimum control efficiency of99.0 percent. It uses a pulse cleaning system and mechanical recovery system with a rotary screen and aspirator to separate recyclable media from debris. It is equipped with a digital photohelic gauge to monitor the differential pressure across the dust collector.

1.4.6 Coating Operations: Spray booths are equipped with overspray filters and water curtains. ROC emissions are controlled by using compliant coatings required by District Rules 330 and 351.

Some reduction in particulates is achieved via filters in the spray booth and with use of water curtains.

Final Permit to Operate 13968 Page 11 of315

1.4. 7 Solvent Usage: Add on emission controls are not utilized. The solvents used must comply with District prohibitory rules.

1.4.8 Landfill: The landfill is not equipped with a landfill gas control system.

1.4.9 Gasoline Dispensing Facilities: The gasoline dispensing facilities are equipped with CARE certified Phase I and Phase II Vapor Recovery Systems. The E-85 system is not equipped with a Phase II Vapor Recovery system because all vehicles served by the E-85 system are equipped with onboard refueling vapor recovery (ORVR).

1.4.1 0 Hydrogen Sulfide Degasifiers: There are no emissions controls for these Degasifiers.

1.4.11 Hypergolic Propellant Storage and Handling:

HSF: The HSF is used for the transfer, handling and bulk storage of liquid propellant fuels and oxidizers. Fuel emissions are controlled with a 350 gallon capacity, stainless steel Illinois Institute of Technology/Research Institute Fuel Vapor Scrubbing System (FVSS). Oxidizer emissions are controlled with an 850 gallon capacity, stainless steel Kennedy Space Center model S70-1095 Oxidizer Vapor Scrubbing System (OVSS). The OVSS is rated at 400 standard cubic feet per minute (SCFM) and consists of a four tower packed bed scrubbing system, 850 gallon capacity recirculating sump tank, conductivity monitor, and electrical and mechanical control systems.

MRS: Two MRSs are used to safely control hypergolic propellant vapors generated during the unloading of hypergolic propellant from satellites and launch/re-entry vehicles. One MRS controls hypergolic fuel and the second controls hypergolic oxidizer. For the hypergolic oxidizer, the MRS is connected to the vent on the oxidizer propellant tank of the vehicle and the propellant receiving cylinder. The tank on the vehicle is pressurized and valves are opened to allow the liquid propellant to flow from the vehicle into the receiving cylinder. Once the propellant transfer is complete, excess pressure in the tank on the vehicle is vented along with the receiving cylinder.

After the tank and cylinder are vented, the propellant lines are aspirated to remove both liquid and vapor propellant in the transfer lines. To further remove propellant, the propellant lines are purged with gaseous helium or nitrogen. At this point, the propellant tank is purged dry to remove the residual propellant until the concentration of the propellant vapors in the tank is essentially zero. · To complete the decontamination process, the propellant lines are purged dry until the concentration of the propellant vapors in the lines is essentially zero. Afterward during the ground equipment decontamination process, the aspiration tank is subjected to a series of tank pressurization/vacuum cycles using the helium/nitrogen source and the aspirator. This series of pressurization/vacuum cycles removes the majority of the residual propellant.

For the hypergolic fuel, the MRS is used to clean the tank on the vehicle but IPA is introduced into the tank to flush the tank after the propellant lines are aspirated and purged following propellant off-load. The IPA flush removes most ofthe residual hypergolic fuel from the system.

The IP A contaminated with hypergolic fuel is transferred back into drums and sent off-base for disposal as hazardous waste. After removal of the bulk IP A from the tank, the above process is used to decontaminate the propellant tank and transfer equipment.

SLC-2 Portable Scrubbers: Each scrubber trailer is equipped with four multistage, counter flow, packed scrubbers connected in series, manufactured by American Alloy Fabricators. The fuel scrubber uses a citric acid solution to neutralize Aerozine 50. The oxidizer scrubber uses a

Final Permit to Operate 13968 Page 12 of315 solution of sodium bicarbonate to neutralize nitrogen tetroxide. After scrubbing the liquids are sent to a sump tank. The minimum control efficiency of these scrubbers is 95 percent.

1.5 Offsets/Emission Reduction Credit Overview

This stationary source triggers offsets for NOx and ROC. See Attachment 10.7 for a calculation of the source' s Net Emission Increase (NEI). See Section 7.0 for a detailed description of offset liabilities and corresponding emission reduction credits.

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1.6 Part 70 Operating Permit Overview

1.6.1 Federally-Enforceable Requirements: All federally enforceable requirements are listed in 40

CFR Part 70.2 (Definitions) under "applicable requirements." These include all SIP-approved District Rules, all conditions in District-issued Authority to Construct permits issued pursuant to SIP-approved District Rules, and all conditions applicable to major sources under federally promulgated rules and regulations. All these requirements are enforceable by the public under CAAA. (See Section 3 for a list of the federally enforceable requirements).

1.6.2 Insignificant Emissions Units: Insignificant emission units are defined under District Rule 1301 as any regulated air pollutant emitted. from the unit, excluding HAPs, that are less than 2 tons per year based on the unit ' s potential to emit and any HAP regulated under section 112(g) of the Clean Air Act that does not exceed 0.5 ton per year based on the unit' s potential to emit.

Insignificant activities were listed in the Part 70 application with supporting calculations.

Applicable requirements may apply to insignificant units.

1.6.3 Federal Potential to Emit: The federal potential to emit (PTE) of a stationary source does not include fugitive emissions of any pollutant, unless the source is: (1) subject to a federal NSPS/NESHAP requirement which was in effect as of August 7, 1980, or (2) included in the 29-category source list specified in 40 CFR 51.166 or 52.21. The federal PTE does include all emissions from any insignificant emissions units. See Table 5.3 for the federal PTE for this source.

1.6.4 Permit Shield: The operator of a major source may be granted a shield: (a) specifically stipulating any federally-enforceable conditions that are no longer applicable to the source and (b) stating the reasons for such non-applicability. The permit shield must be based on a request from the source and its detailed review by the District. Permit shields cannot be indiscriminately granted with respect to all federal requirements. V AFB made no requests for a permit shield.

1.6.5 Alternate Operating Scenarios: A major source may be permitted to operate under different operating scenarios, if appropriate descriptions of such scenarios are included in its Part 70 permit application and if such operations are allowed under federally-enforceable rules. V AFB made no requests for alternative operating scenarios.

1.6.6 Compliance Certification: Part 70 permit holders must certify compliance with all applicable federally-enforceable requirements including permit conditions. Such certification must accompany each Part 70 permit application and be re-submitted annually before March 1st or on a more frequent schedule specified in the permit. A "responsible official" of the owner/operator company whose name and address is listed prominently in the Part 70 permit signs each certification. (See Section 1.6.9 below)

1.6. 7 Permit Reopening: Part 70 permits are re-opened and revised if the source becomes subject to a new rule or new permit conditions are necessary to ensure compliance with existing rules. The permits are also re-opened if they contain a material mistake or the emission limitations or other conditions are based on inaccurate permit application data.

1.6.8 Hazardous Air Pollutants CHAPs): The requirements of Part 70 permits also regulate emission of HAPs from major sources through the imposition of maximum achievable control technology (MACT), where applicable. The federal PTE for HAP emissions from a source is computed to determine MACT or any other rule applicability. (See Section 5.5)

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1.6.9 Responsible Official: The designated responsible official and his/her mailing address is:

Colonel Keith Balts, Commander, 30th Space Wing U.S. Air Force 747 Nebraska Ave.

Vandenberg Air Force Base, CA 93437

2.0 Description of Project and Process Description

The V AFB Stationary Source contains numerous permitted and non-permitted stationary and mobile individual emission units and processes that affect air quality. Most V AFB stationary emission units consist of boilers, internal combustion engines, and paint spray booths. Processes include using solvents and storing and transferring various fuels . Mobile sources include aircraft, commercial lawn mowers, motor vehicles (on and off-road), spacecraft launch equipment, and portable units registered under the State's Portable Equipment Program (PERP).

3.0 Regulatory Review

All enforceable requirements are listed in this section, and include all District Rules, all conditions in the District-issued Authority to Construct permits and applicable federally promulgated rules and regulations.

3.1. Permit Exemptions Claimed

V AFB is not required to obtain a permit to operate for the following equipment:

District Rule 202.D (General Provisions): Pursuant to Section D.14, applying architectural coating for repair and maintenance is exempt.

District Rule 202.F (Internal Combustion Engines):

Pursuant to Sections F .l.a and c, engines used in aircraft, locomotives, and to propel vehicles are exempt.

Pursuant to Section F .l.d, spark ignited engines used exclusively for emergency electrical power generation or emergency pumping of water are exempt if the engine operates less than 200 hours per year.

Pursuant to Sections F .l.e and f, compression ignition and spark ignition engines rated less than 50 brake horsepower are exempt.

Pursuant to Section F .2, portable internal combustion engines registered in the Statewide Registration Program are exempt.

District Rule 202.G (Combustion Equipment): Pursuant to Section H.l, combustion equipment with a maximum rated heat input of less than or equal to two MMBtu/hr is exempt.

District Rule 202.H (Abrasive Blasting Equipment): Pursuant to Section H.l , abrasive blast cabinet-dust filter integral combination units where the total internal volume of the blast section is 50 ft3 or less are exempt.

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District Rule 202.P (Explosive Ordnance Detonation): Pursuant to Section P.13, explosive ordnance detonation is exempt.

District Rule 202.U (Solvent Application Equipment and Operations): Pursuant to Section U.4, solvent cleaning to disinfect and decontaminate surfaces and equipment at health care activities is exempt. Pursuant to Section U.S, solvent cleaning associated with janitorial cleaning is exempt.

Federal Facility Site Remediation Agreement: Soil Vapor Extraction Systems at Buildings 1788 and 1930.

See Attachment 10.12 for a list of permit exempt equipment at the facility.

3.2. Compliance with Applicable Federal Rules and Regulations

3 .2.1 40 CFR Parts 51/52 {New Source Review (Nonattainment Area Review and Prevention of Significant Deterioration)}: V AFB was originally permitted in the 1980s under District Rule 205 .C. That rule was superseded by District Regulation VIII (New Source Review) in April1997.

Compliance with Regulation VIII ensures that this facility will comply with federal NSR requirements.

3.2.2 40 CFR Part 60 {New Source Performance Standards) Subpart GG: This subpart applies to stationary gas turbines with a heat input at peak load equal to or greater than 10 million Btu per hour that commence construction, modification, or reconstruction after October 3, 1977. The turbines at the SVPP are subject to this NSPS. Compliance with the stricter NSR emission limits ensures compliance with the emission limits of the NSPS. The SVPP is equipped with Continuous Emissions Monitors (CEMS) to ensure ongoing compliance with the NSPS.

3.2.3 40 CFR Part 60 {New Source Performance Standards) Subpart IIII: This Subpart applies to owners and operators of stationary compression ignition engines that are constructed, modified, or reconstructed after July 11, 2005. Engines subject to this subpart are required to meet 6.9 g/bhp NOx and 0.40 g/bhp PM emission standards. New engines at the source are subject to this subpart and meet these standards.

3.2.4 40 CFR Part 63 {National Emission Standards for Hazardous Air Pollutants) Subpart ZZZZ:

This Subpart applies to owners and operators of stationary reciprocating internal combustion engines (RICE). For area sources of HAP emissions, stationary RICE are "existing" if construction or reconstruction commenced before June 12, 2006. Engines that are not categorized as existing are considered "new". The V AFB stationary source is an area source of HAP emissions.

Existing emergency standby compression ignition RICE at area sources of HAP emissions must comply with the applicable emission and operating limits by no later than May 3, 2013. The following operating requirements apply:

(1) change the oil and filter every 500 hours of operation or annually, whichever comes first;

(2) inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first;

(3) inspect all hoses and belts every 500 hours of operation or annually, whichever comes first.

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Emission limits are not established for existing emergency-standby CI RICE at area sources of HAP emissions.

The pony starter engines at the SVPP are existing stationary black start RICE. A black start engine is an engine whose only purpose is to start up a combustion turbine. Existing stationary black start compression ignition RICE at area sources of HAP emissions must comply with the applicable emission and operating limits by no later than May 3, 2013. The following operating requirements apply:

(1) change the oil and filter every 500 hours of operation or annually, whichever comes first;

(2) inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first;

(3) inspect all hoses and belts every 500 hours of operation or annually, whichever comes first.

In lieu of changing the oil, V AFB may instead conduct an oil analysis. The analysis measures the Total Base Number, the oil viscosity, and the percent water content. The oil and filter will be changed if any of the following limits are exceeded:

(1) The tested Total Base Number is less than 30 percent of the Total Base Number of the oil when new;

(2) The tested oil viscosity has changed by more than 20 percent from the oil viscosity when new;

(3) The tested percent water content (by volume) is greater than 0.5 percent.

The Total Base Number is the amount acid necessary to neutralize the base reserve in one gram of oil. It is expressed in the equivalent number of milligrams of potassium hydroxide. It is a measure ofthe ability ofthe oil to neutralize acids created during combustion. IfVAFB chooses to change the oil at the specified frequencies, no analysis is required.

Per Section 63 .6625( e) the engines must be operated and maintained according to the manufacturer's written instructions, or VAFB must develop their own maintenance plan to minimize emissions.

Per Section 63.6645, existing stationary RICE that are not subject to numerical emission standards do not have to submit an initial notification. No reporting requirements are identified in Section 63.6650 for these units. Per Section 63 .6655, V AFB must keep records of maintenance on the engines.

3.2.5 40 CFR Part 63 Subpart HHHHHH: On January 9, 2008, the EPA adopted National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (Subpart HHHHHH). This Subpart does not apply to surface coating or paint stripping performed on site at V AFB pursuant to 40 CFR 63.11169(d)(l).

3.2.6 40 CFR Part 70 {Operating Permits} : This Subpart is applicable to V AFB. In its Part 70 permit application (Form I), V AFB certified compliance with all existing District rules and permit conditions. This certification is also required ofV AFB semi-annually. Issuance of this permit

Final Permit to Operate 13968 Page 17 of315 and compliance with all its terms and conditions will ensure that V AFB complies with the provisions of all applicable Subparts.

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3.3. Compliance with Applicable State Rules and Regulations

3.3.1 Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition CCI) Engines (CCR Section 93115, Title 17): Except for the requirements of Section 93115 .9, this ATCM applies to all stationary diesel-fueled engines rated greater 50 brake horsepower (bhp) at this facility. Section 93115.9 applies to the sale or lease of engines rated 50 bhp and less.

3.3 .1.1 Emergency Standby Diesel Engines: Owners of in-use stationary diesel internal combustion engines (DICE) for emergency use are subject to the requirements ofTable 3 of the ATCM.

In-use emergency fire pump engines may operate the number of hours necessary to comply with the testing requirements of the National Fire Protection Association standards (NFPA-25). By limiting annual maintenance and testing hours, these engines are not required to meet any new emission standards (e.g. engine retrofits are not required). The ATCM does require that the hours of operation be monitored with a non-resettable hour meter, that CARB Diesel Fuel be used (or approved alternative) and that detailed records of use be recorded and reported.

Owners and operators of new stationary DICE engines for emergency use are subject to the emission standards of Table 1 of the A TCM and the operating requirements of Section 93115.6.

Owners and operators of new stationary DICE fire pump engines are subject to the emission standards of Table 2 of the A TCM and the operating requirements of Section 93115 .6.

3.3.1.2 Prime Diesel Engines: The generator providing primary power to the Launch Facility Electrical Power and Air Conditioning Systems Trainer (Device #112253) qualifies for the exemption in §93115.3(f) of the State' s ATCM for Stationary Compression Ignition Engines. This exemption excludes this engine from the requirements of §93115.5 Fuel and Fuel Additive Requirements and §93115.7 Stationary Prime Diesel-fueled CI Engine Emission Standards ofthe ATCM.

3.3 .1.3 Pony Starter Engines: The operation of each pony starter engine is limited to no more than 20 hours/year and therefore the engines qualify for the Low-Use Prime Engines Outside of School Boundaries exemption in Section 93115.3 U) in the DICE A TCM. The sulfur content for diesel burned in prime engines, such as the pony starter engines, is 15 ppm on a weight basis based on the requirements of Section 93115.5 in the DICE ATCM. This requirement became effective in January 2006.

3.3.2 Hexavalent Chromium and Cadmium Airborne Toxic Control Measure CATCM) --Motor Vehicle and Mobile Equipment Coatings (17 CCR § 93112): This regulation became effective on September 19, 2002. Each air pollution control and air quality management district was required to implement and enforce the ATCM by no later than January 19, 2003. Among other things, this ATCM prohibits the use of automotive coatings containing cadmium and hexavalent chromium.

This prohibition does not include coatings such as Arnerlock 2/400 resin and Arnerlock 400 Cure which contain trace amounts of hexavalent chromium and/or cadmium because the hexavalent chromium or cadmium was not introduced as…