TL PTO 13968R4 and Part 70 Dec 2025v2.pdf

PERMIT TO OPERATE 13968-R4

AND

PART 70 OPERATING PERMIT 13968

Vandenberg Space Force Base, Space Launch Delta 30

OWNERS

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

OPERATORS

United States Space Force, a.i. solutions, The Boeing Company, EMCOR Government Services, Lockheed Martin Space, Northrop Grumman, Army Air Force Exchange Service, Call Henry, Inc., Katmai Government Services, Amentum, Valiant.

Santa Barbara County Air Pollution Control District

December 2025

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Contents

ABBREVIATIONS/ACRONYMS

1.0 INTRODUCTION

1.1. PURPOSE

1.2. STATIONARY SOURCE/FACILITY OVERVIEW

1.3 EMISSION SOURCES

1.4 EMISSION CONTROL OVERVIEW

1.5 OFFSETS/EMISSION REDUCTION CREDIT OVERVIEW

1.6 PART 70 OPERATING PERMIT 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 ENGINEERING ANALYSIS

4.1. GENERAL

4.2. EXTERNAL COMBUSTION UNITS

4.3. RECIPROCATING INTERNAL COMBUSTION ENGINES

4.4. TURBINES

4.5. BULK FUEL STORAGE

4.6. ABRASIVE BLASTING

4.7. COATING OPERATIONS

4.8. SOLVENT USAGE

4.9. LANDFILL GAS

4.10. GASOLINE DISPENSING

4.11. HYPERGOLIC FUEL STORAGE AND HANDLING

4.12. PERMIT EXEMPT EQUIPMENT

4.13. PROCESS MONITORING

4.14. BEST AVAILABLE CONTROL TECHNOLOGY (BACT)

4.15. CEMS/PROCESS MONITORING

4.16. SOURCE TESTING/TUNING/SAMPLING

4.17. PART 70 ENGINEERING REVIEW: HAZARDOUS AIR POLLUTANT EMISSIONS

5.0 EMISSIONS

5.1. GENERAL

5.2. PERMITTED EMISSION LIMITS - EMISSION UNITS

5.3. PERMITTED EMISSION LIMITS - FACILITY TOTALS

5.4. GREENHOUSE GASES

5.5 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

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7.1. GENERAL

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

9.A STANDARD ADMINISTRATIVE CONDITIONS

A.1 CONSISTENCY WITH ANALYSIS

A.2 COMPLIANCE

A.3 CONFLICT BETWEEN PERMITS

A.4 ACCESS TO RECORDS AND FACILITIES

A.5 EMISSION FACTOR REVISIONS

A.6 GROUNDS FOR REVOCATION

A.7 COMPLIANCE WITH PERMIT CONDITIONS

A.8 EMERGENCY PROVISIONS

A.9 COMPLIANCE PLAN

A.10 RIGHT OF ENTRY

A.11 PERMIT LIFE

A.12 PAYMENT OF FEES

A.13 DEVIATION FROM PERMIT REQUIREMENTS

A.14 REPORTING REQUIREMENTS/COMPLIANCE CERTIFICATION

A.15 FEDERALLY-ENFORCEABLE CONDITIONS

A.16 RECORDKEEPING REQUIREMENTS

A.17 CONDITIONS FOR PERMIT REOPENING

9.B GENERIC CONDITIONS

B.1 EQUIPMENT IDENTIFICATION

B.2 EQUIPMENT MAINTENANCE

B.3 CIRCUMVENTION (RULE 301)

B.4 VISIBLE EMISSIONS (RULE 302)

B.5 NUISANCE (RULE 303)

B.6 ORGANIC SOLVENTS (RULE 317)

B.7 SOLVENT CLEANING OPERATIONS (RULE 321)

B.8 METAL SURFACE COATING THINNER AND REDUCER (RULE 322)

B.9 ARCHITECTURAL COATINGS (RULE 323.1)

B.10 DISPOSAL AND EVAPORATION OF SOLVENTS (RULE 324)

B.11 ADHESIVES AND SEALANTS (RULE 353)

9.C REQUIREMENTS AND EQUIPMENT SPECIFIC CONDITIONS

C.1 TURBINE GENERATORS AND PONY ENGINES

C.2 EXTERNAL COMBUSTION EQUIPMENT

C.3 STATIONARY EMERGENCY STANDBY INTERNAL COMBUSTION ENGINES

C.4 HYPERGOLIC STORAGE FACILITIES (HSF)

C.5 MICROWAVE REACTOR SYSTEM (MRS)

C.6 COATING OPERATIONS

C.7 SOLVENT USAGE

C.8 STORAGE TANKS

C.9 GASOLINE DISPENSING FACILITY

C.10 ABRASIVE BLASTING

C.11 RECORDKEEPING

C.12 SEMI-ANNUAL COMPLIANCE VERIFICATION REPORTS

C.13 SOLVENT RECOVERY PLAN

C.14 BEST AVAILABLE CONTROL TECHNOLOGY (BACT)

C.15 OFFSETS

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C.16 SOURCE TESTING

C.17 AMBIENT AIR QUALITY STANDARD VIOLATION

C.18 AMBIENT MONITORING REQUIREMENTS

C.19 CONTINUOUS EMISSION MONITORING

C.20 DATA ACQUISITION SYSTEM (DAS)

C.21 DATA TELEMETRY

C.22 DATA ACQUISITION SYSTEM (DAS) OPERATION AND MAINTENANCE FEE

C.23 DOCUMENTS INCORPORATED BY REFERENCE

9.D DISTRICT-ONLY CONDITIONS

D.1 STATIONARY EMERGENCY STANDBY INTERNAL COMBUSTION ENGINES

D.2 NOTIFICATION OF LOSS OF EXEMPTION

D.3 ENROLLMENT IN A DRP/ISC - JANUARY 1, 2005

D.4 TITLE 17-SUBCHAPTER 6-ABRASIVE BLASTING - CALIFORNIA CODE OF REGULATIONS

COMPLIANCE

D.5 LANDFILL OPERATIONS

D.6 ABRASIVE BLASTING

D.7 TEMPORARY ENGINE REPLACEMENTS – DICE ATCM

D.8 PERMANENT ENGINE REPLACEMENTS

D.9 DE-PERMITTED EQUIPMENT

D.10 NUISANCE (RULE 303)

D.11 CIRCUMVENTION (RULE 301)

D.12 VISIBLE EMISSIONS (RULE 302)

D.13 ORGANIC SOLVENTS (RULE 317)

D.14 METAL SURFACE COATING THINNER AND REDUCER (RULE 322)

D.15 DISPOSAL AND EVAPORATION OF SOLVENTS (RULE 324)

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ABBREVIATIONS/ACRONYMS

AP-42 USEPA’s Compilation of Emission Factors A-50 Aerozine-50 AQMM Air Quality and Meteorological Monitoring ASTM American Society for Testing Materials ATC Authority to Construct ATCM Air Toxic Control Measure ATEIP Air Toxics Emission Inventory Plan ATEIR Air Toxics Emission Inventory Report BACT Best Available Control Technology BTDC Below top dead center Btu British thermal unit CAAA California Clean Air Act Amendment CARB California Air Resources Board CAM compliance assurance monitoring CEMS Continuous Emissions Monitoring System CAP Clean Air Plan CFR Code of Federal Regulations CO Carbon Monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent CPI Consumer Price Index DAS Data Acquisition System DICE Diesel Internal Combustion Engine District Santa Barbara County Air Pollution Control District DLA-E Defense Logistics Agency-Energy DOT Department of Transportation DPF Diesel Particulate Filter DRP/ISC Demand Response Program/Interruptible Service Contract EF Emission factor ENVVEST Environmental Investment E/S Emergency Service ERC Emission Reduction Credit °F degree Fahrenheit FID facility identification FUMP Fuel Use Monitoring Plan FVSS Fuel Vapor Scrubbing System gr grain GHG Greenhouse Gases HAP hazardous air pollutant (as defined by CAAA, Section 112(b)) HC Hydrocarbon HRA Health Risk Assessment HSF Hypergolic Fuel Storage Facility H&SC Health and Safety Code H2S hydrogen sulfide I&M Inspection & Maintenance IPA Iso-Propyl Alcohol ISD In-Station Diagnostics k kilo (thousand) l liter lb pound lbs/day pounds per day lbs/hr pounds per hour LPG Liquefied Petroleum Gas LFG Landfill Gas

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M mega (million) MACT Maximum Achievable Control Technology MM million MMH Mono-Methyl Hydrazine MRS Microwave Reactor System M&T Maintenance and Testing MVFF Motor Vehicle Fueling Facility MW molecular weight N2H4 Hydrazine NAR Nonattainment Review NSPS New Source Performance Standards NESHAP National Emissions Standards for Hazardous Air Pollutants NFPA National Fire Protection Association NMOC Non-methane Organic Compounds NOV Notice of Violation ORVR Onboard Refueling Vapor Recovery OVSS Oxidizer Vapor Scrubbing System O2 oxygen PM particulate matter PM10 particulate matter less than 10 microns PM2.5 particulate matter less than 2.5 µm in size ppm(vd or w) parts per million (volume dry or weight) PSD Prevention of Significant Deterioration psia pounds per square inch absolute psig pounds per square inch gauge PTE Potential to Emit PTO Permit to Operate PUC Public Utility Commission P/V Pressure/Vacuum QA/QC Quality Assurance/Quality Control RACT Reasonably Available Control Technology RICE Reciprocating internal combustion engine RPM Revolutions per Minute RSV Ready Storage vessel ROC reactive organic compounds, same as “VOC” as used in this permit SO2 Sulfur Dioxide scf standard cubic foot scfd (or scfm) standard cubic feet per day (or per minute) SIP State Implementation Plan SOX Oxides of Sulfur SSID stationary source identification SVPP South Vandenberg Power Plant TPQ Tons per quarter TPY Tons per Year TVP true vapor pressure UDMH Unsymmetrical Dimethylhydrazine ULA United Launch Alliance USEPA United States Environmental Protection Agency VSFB Vandenberg Space Force Base VRS vapor recovery system

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1.0 Introduction

1.1. Purpose

General. The Santa Barbara County Air Pollution Control District (District) began issuing permits to Vandenberg Space Force Base (VSFB) 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 VSFB stationary source. Most of the permitted equipment consists of emergency standby generators, small boilers, and water heaters.

Santa Barbara County is designated as a non-attainment area for the state PM10 ambient air quality standard. On July 1, 2020, the County achieved attainment status for the ozone state ambient air quality standards, however in February 2021, the California Air Resources Board took action at a public hearing to change Santa Barbara County’s designation from attainment to nonattainment for the State ozone standard. This change was based on data measured at multiple locations in the County for the 3-year period from 2017 to 2019. The California Office of Administrative Law (OAL) finalized the designation change on September 27, 2021.

Part 70 Permitting. This is the fourth renewal of the Part 70 permit for the VSFB 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 of NOX and CO and 100,000 tons per year GHGs.

The District triennial permit reevaluation has been combined with this Part 70 Permit renewal.

This permit incorporates previous Part 70 revision permits (ATC/PTOs, PTOs, PTO Modifications, and Administrative Modifications) that have been issued since the last permit renewal was issued on June 9, 2023. These permits are listed in Section 1.2.2 of this permit. 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.

Greenhouse Gases - Rule 810. This reevaluation incorporates greenhouse gas emission calculations for the stationary source. These emissions establish baseline conditions under Rule 810, Federal Prevention of Significant Deterioration. The facility’s potential to emit has been estimated; however, the greenhouse gas PTE is not an emission limit. The facility will not become subject to emission limits for GHGs unless a project triggers federal Prevention of Significant Deterioration requirements under Rule 810.

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1.2. Stationary Source/Facility Overview

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

(Figure 1.1) and is the headquarters for Space Launch Delta 30 (SLD 30). The Space Force’s primary missions at VSFB 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. SLD 30 hosts several other Federal agencies that conduct activities independent of SLD 30 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 VSFB are considered part of the VSFB stationary source. The commercial space activities located at VSFB are not owned and operated by the federal government, therefore they are not considered part of the VSFB stationary source.

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Figure 1.1.

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1.2.2 Facility New Source Overview: Since the third renewal of the Part 70 permit was issued for this facility in June 2023, the following permitting actions have taken place:

PERMIT TYPE ISSUE DATE DESCRIPTION

PT-70 ADM 16148 2/21/2024

Change of responsible official from Colonel Robert A. Long to Colonel Mark A. Shoemaker.

PTO 15926 6/14/2024

Operation of a prime diesel engine stored at Building 3000 and used at Building 3010 and the flight line at VSFB; 2016.

Cummins QSB4.5 rated at 155 bhp. This engine has since been depermitted as it is exempt from District permit and listed on the VSFB PERP TSE Registration.

PTO 15365 6/17/2024

Operation of 2 new diesel-fired emergency backup generators at Building 23215; 2017. Cummins QST30-G5 NRS rated at 1,490 bhp each.

PTO 15830 6/17/2024

Operation of a new diesel-fired emergency backup generator at Building 1900; 2021. John Deere 6135HFG84A rated at 617 bhp.

PTO 15839 6/17/2024

Operation of a new diesel-fired emergency backup generator at Building 8337; 2022. John Deere 6135HFG84A rated at 617 bhp.

PTO 15840 6/17/2024

Operation of a new diesel-fired emergency backup generator at Building 8339; 2022. John Deere 6135HFG84A rated at 617 bhp.

PTO 16047 10/31/2024

Operation of 2 new diesel-fired emergency backup generators at Building 8425; 2010. Isuzu BJ-4JJ1X rated at 98 bhp.

PTO 16225 11/26/2024

Operation of a previously installed diesel-fired emergency backup generator at Building 13850; 2014. Cummins QSL9-G7 rated at 464 bhp which was inadvertently depermitted in a previous permit reevaluation.

PTO 16037 5/29/2025

Operation of a new diesel-fired emergency firewater pump at Building 2307; 2022. John Deere 6068HFC28A rated at 237 bhp.

PTO 16210 6/16/2025

Operation of new diesel-fired emergency backup generator at Building 9360; 2024. John Deere 4045HFG04 rated at 107 bhp.

PTO 16218 6/16/2025

Installation of new dispensers and associated hardware. Bldg #14400. Phase I and II upgrade. VR-102-W and VR-204-AD.

Assist to balance. 4,8000,000/yr.

PTO 16257 6/16/2025

Operation of a new diesel-fired emergency backup generator at Building 185; 2020. Cummins QSZ13-G7 rated at 626 bhp.

PTO 16292 6/16/2025

Operation of a previously exempt LPG-fired emergency backup generator at Building 51; 1998. Ford LSG-8751-6005-A rated at 104 bhp which lost its Rule 202.F.1.d exemption due to exceeding the annual 200-hour operating limit.

PTO 16297 6/16/2025

Operation of new diesel-fired emergency backup generator at Building 501; 2023. Cummins QSB7-G5 NR3 rated at 324 bhp.

PTO 16295 TBD**

Increase in the daily hours of a diesel-fired prime engine at Building 1731 from 3 to 8 hours per day; 2018. John Deere 4045HFC04 rated at 139 bhp.

PT-70 ADM 16471 TBD**

Change of responsible official from Colonel Mark A. Shoemaker to Colonel James T. Horne, III.

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PTO 16320 TBD**

Operation of a new diesel-fired emergency backup generator at Building 15502; 2023. Cummins QSX15-G9 NR2 rated at 755 bhp equipped with a DPF.

** = Final PTOs issued at issuance of this permit.

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

United States Space 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 Space Force, a.i.

solutions, The Boeing Company, EMCOR Government Services, Lockheed Martin Space, Northrop Grumman, Army Air Force Exchange Service, Call Henry, Inc., Katmai Government Services, Amentum, Valiant.

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 of these units.

1.3.2 Stationary Internal Combustion Engines. Multiple internal combustion engines provide emergency standby power for the operating systems at VSFB or water for fire suppression.

One prime engine is used for training. One prime engine used for wet abrasive blasting. See Attachment 10.3 for a list of these units.

1.3.3 South Vandenberg Power Plant (SVPP): 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 VSFB.

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

1.3.4 Bulk Fuel Storage:

RP-1 Storage: RP-1 is delivered to the internal floating roof storage tank 1701 at the bulk storage facility by tanker trucks or trailers. The tank provides additional RP-1 storage capacity for the facility.

JP-8/Jet-A Storage: JP-8 or Jet-A is delivered to aboveground storage tanks 1702 and 1703 at the bulk storage facility by tanker trucks or trailers. An unloading rack is used to transfer the fuel into the tanks. 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.

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1.3.8 Landfill: The landfill began operations in 1941. Landfill gas (LFG) emissions result from anaerobic biological decomposition of organic matter deposited in the landfill escaping to the surface. LFG consisted primarily of methane (CH4) and carbon dioxide (CO2) with smaller amounts of non-methane organic compounds (NMOC). Some NMOCs are ROC. On February 2, 2021, VSFB submitted a closure notification in accordance with Section 95470(b)(1) of the State’s Landfill Methane Regulation (LMR). As a result, the landfill no longer accepts new waste.

The last waste accepted at the landfill occurred on June 7, 2019, with a final estimated waste in-place of 2,834,100 cubic yards.

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 gasoline and E-85 fuel for vehicles serving the base. The other (AAFES) provides fuel for the privately owned vehicles of military members, dependents, retirees and DOD-civilian employees.

Government vehicles may be fueled at AAFES on rare occasions.

1.3.10 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 VSFB 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), and monopropellant (hydrazine). Additionally, small amounts of fuel, typically hydrazine (N2H4) and high purity/ultra-pure hydrazine and various grades of hydrazine used for spacecraft/aircraft propulsion systems is stored in Department of Transportation (DOT) drums and cylinders.

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 of MON-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 VSFB and other launch facilities throughout

Part 70/Permit to Operate 13968-R4 Page 12 of 326 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 hypergolic 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 VSFB 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

i. system decontamination procedure.

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 IPA 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 IPA, 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.

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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 VSFB. 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.

1.4 Emission Control Overview

1.4.1 External Combustion Units: Many of the external combustion units are equipped with Low-NOX burners. These units are identified in Attachment 10.2. (i.e., NOX concentration limit of 30 ppm @ 3% O2 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, #114491 (Bldg 511), #111765 (Bldg 929), #384066 (Bldg 2520), #109236 (Bldg 21203), #395011 (Bldg 13730), #398950 (Bldg 15502), #395662 (Bldg 1900), #395664 (Bldg 8337), and #395666 (bldg. 8339). 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 (CO2). 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: The POL Bulk Storage Facility stores JP-8 and Jet-A fuel in tanks #1702 and

#1703. The facility also stores RP-1 propellant in tank #1701. These tanks are equipped with floating roofs with primary and secondary seals. 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 of 95.0 percent is utilized at Building 2007. 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 of 99.0 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 322, 323.1, 330, 337, 339 and 351. Some reduction in particulates is achieved via filters in the spray booth and with use of water curtains.

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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 closed landfill is not equipped with a landfill gas control system.

1.4.9 Gasoline Dispensing Facilities: The gasoline dispensing facilities are equipped with CARB-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).

1.4.10 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 of the residual hypergolic fuel from the system.

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

1.5 Offsets/Emission Reduction Credit Overview

This stationary source triggers offsets for NOX, ROC, SOX and PM/PM10 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

i

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. VSFB 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. VSFB 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 (HAPs): 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 James T Horne III, Space Launch Delta 30 U.S. Space Force 747 Nebraska Ave.

Vandenberg Space Force Base, CA 93437

2.0 Description of Project and Process Description

The VSFB Stationary Source contains numerous permitted and non-permitted stationary and mobile individual emission units and processes that affect air quality. Most VSFB 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, aerospace vehicles, 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

VSFB 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.1.a engines used in aircraft and in locomotives are exempt.

Pursuant to Sections F.1.b Engines used to propel marine vessels, except vessels associated with a stationary source which shall be regulated as specified under the provisions of Regulation VIII are exempt.

Pursuant to Sections F.1.c engines used to propel vehicles, as defined in Section 670 of the California Vehicle Code, but not including any engine mounted on such vehicles that would otherwise require a permit under the provisions of these Rules and Regulations are exempt.

Pursuant to Section F.1.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.1.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.

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Pursuant to Section F.4 a permit shall not be required for engines with a rated brake horsepower of less than 50 used:

a. for military tactical support operations including maintenance and training for such operations;

b. to power temperature and humidity control systems on cargo trailers used to transport satellites and space launch equipment;

c. exclusively for space launch facility support and which power hoists, jacks, pulleys, and other cargo handling equipment permanently affixed to motor vehicles or trailers pulled by motor vehicles.

District Rule 202.G (Combustion Equipment): Pursuant to Section G.1, 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.1, abrasive blast cabinet-dust filter integral combination units where the total internal volume of the blast section is 50 ft3 or less are exempt. Pursuant to Section H.3, all portable abrasive blast equipment, excluding any internal combustion engine associated with such equipment which must comply with the requirements of Rule 202.F.

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.5, solvent cleaning associated with janitorial cleaning is exempt.

Federal Facility Site Remediation Agreement: Soil Vapor Extraction Systems at Vandenberg Space Force Base conducted under the Federal Facilities Site Remediation Agreement.

See Attachment 10.10 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)}: VSFB was originally permitted in the 1980s under District Rule 205.C. That rule was superseded by District Regulation VIII (New Source Review) in April 1997, which was revised in August 2016. 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.

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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 60 {New Source Performance Standards} Subpart WWW: This Subpart applies to landfills that commenced construction, reconstruction, or modification on or after May 30, 1991 but before July 18, 2014. The landfill subject to this permit was initially opened in 1941 and has not undergone any construction, reconstruction, or modification, as defined by the regulation, since May 30, 1991. Therefore, this Subpart is not applicable. This landfill was closed June 7, 2019 and no longer accepts waste.

3.2.4 40 CFR Part 62 (Approval and Promulgation of State Plans for Designated Facilities and

Pollutants):

Subpart OOO Federal Plan Requirements for Municipal Solid Waste Landfills That

Commenced Construction On or Before July 17, 2014 and Have Not Been Modified or Reconstructed Since July 17, 2014

As discussed above, the requirements of Subpart OOO came into effect on September 27, 2021 if the requirements of 40 CFR Part 60 Subpart Cf were not fully addressed by a State Plan.

California’s State Plan received partial approval from the EPA. Therefore, only sections §62.16716(c), §62.16720(a)(4), §62.16722(a)(2),§62.16722(a)(3), §62.16724(k), §62.16726(e)(2) and §62.16726(e)(5) of this Subpart are applicable to this landfill.

3.2.5 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 VSFB 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. The following operating requirements apply:

(1) change the oil and filter every 500 hours of operation or within 1 year and 30 days, whichever comes first;

(2) inspect the air cleaner every 1,000 hours of operation or within 1 year and 30 days,

(3) inspect all hoses and belts every 500 hours of operation or within 1 year and 30 days, whichever comes first.

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

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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. The following operating requirements apply:

(1) change the oil and filter every 500 hours of operation or within 1 year and 30 days,

(2) inspect the air cleaner every 1,000 hours of operation or within 1 year and 30 days,

(3) inspect all hoses and belts every 500 hours of operation or within 1 year and 30 days, whichever comes first.

In lieu of changing the oil, VSFB 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 of the ability of the oil to neutralize acids created during combustion. If VSFB 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 VSFB 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, VSFB must keep records of maintenance on the engines.

3.2.6 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 VSFB pursuant to 40 CFR 63.11169(d)(1).

3.2.7 40 CFR Part 70 {Operating Permits}: This Subpart is applicable to VSFB. In its Part 70 permit application (Form I), VSFB certified compliance with all existing District rules and permit conditions. This certification is also required of VSFB semi-annually. Issuance of this permit and compliance with all its terms and conditions will ensure that VSFB complies with the provisions of all applicable Subparts.

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3.2.8 40 CFR Part 68 {Chemical Accident Prevention Provisions}. VSFB is required to comply with the requirements of this regulation. Their Section 112r Risk Management Plan (RMP) was last submitted to the EPA on September 12, 2023. The annual compliance certification must include a statement regarding compliance with this part, including the registration and submission of the RMP. The 5-year anniversary date for the next plan submission is September 12, 2028.

3.3. Compliance with Applicable State Rules and Regulations

3.3.1 Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition (CI) 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 of Table 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 ATCM 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 ATCM 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 of the 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 (j) in the DICE ATCM. 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…