TECH LIBRARY 6-PTO-13968-R2-Final.pdf

air pollution control district

SANTA BARBARA COUNTY

PERMIT TO OPERATE 13968-R2

AND

PART 70 OPERATING PERMIT 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, RGNext, a.i. solutions, United Launch Alliance, The Boeing Company, EMCOR Government Services, Lockheed Martin, Northrup Grumman, Army Air Force Exchange Service, Call Henry, Inc., Katmai Government Services, United Paradyne Corporation, Alliance

Technical Services, Inc.

Santa Barbara County Air Pollution Control District

November 2019

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 ST A TE 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 ······················································································································32

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 ········································································································36

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 ·······················································································································43

5.5 PART 70: HAP POTENTIAL TO EMIT EMISSION ESTIMATES

6.0 AIR QUALITY IMP ACT ANALYSES

6.1. MODELING

6.2 INCREMENTS

6.3 MONITORING

6.4 HEAL TH RISK ASSESSMENT

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7.0 CAP CONSISTENCY, OFFSET REQUIREMENTS AND ERCS

7.1. GENERAL

7.2. CLEAN AIR PLAN····························································································································· 74

7.3. EMISSION REDUCTION CREDITS (ERCS)

7.4. OFFSETREQUIREMENTS

8.0 LEAD AGENCY PERMIT CONSISTENCY

9.0 PERMIT CONDITIONS

9 .A ST AND ARD ADMINISTRATIVE CONDITIONS

A. I 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.JO 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 ·····················································································································84 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 Su,face 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 .............................................. JOO C.4 Hypergolic Storage Facilities (HSF) C.5 Microwave Reactor System (MRS) ........................................................................................ 1 I 1 C. 6 Coating Operations ............................................................................................................... I 13 C. 7 Solvent Usage C.8 Storage Tanks C.9 Gasoline Dispensing Facility C. JO Abrasive Blasting C.11 Recordkeeping C.12 Semi-Annual Compliance Verification Reports ..................................................................... 12 5 C.13 Solvent Recovery Plan C.14 Best Available Control Technology (BACT)

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C.15 Offsets 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 Telemehy C.22 Data Acquisition System (DAS) Operation and Maintenance Fee C.23 Documents Incorporated by Reference

9. D DISTRICT-ONLY CONDITIONS······································································································· 134 D. I Stationary Emergency Standby Internal Combustion Engines D.2 Notification of Loss of Exemption D.3 Enrollment in a DRP/JSC - Janua,y I, 2005 ......................................................................... I 34 D.4 Title 17-Subchapter 6-Abrasive Blasting - California Code of Regulations Compliance D.5 Landfill Operations D. 6 Abrasive Blasting D. 7 Tempora,y Engine Replacements - DICE ATCM D.8 Permanent Engine Replacements D.9 De-Permitted Equipment D. IO 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 ofSolvents (Rule 324)

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AP-42

A-50

AQMM

ASTM

ATC

ATCM

ATEIP

ATEIR

BACT

BTDC

Btu

CAAA

CARB

CAM

CEMS

CAP

CFR

co

CO2

CO2e

CPI

DAS

DICE

District

DLA-E

DOT

DPF

DRP/ISC

EF

ENVVEST

E/S

ERC

Of

FID

FUMP

FVSS

gr

GHG

HAP

HC

HRA

HSF

H&SC

H2S I&M

IPA

ISD

k I lb lbs/day lbs/hr

LPG

LFG

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 Santa Barbara County 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 Greenhouse Gases hazardous air pollutant (as defined by CAAA, Section l 12(b)) Hydrocarbon Health Risk Assessment Hypergolic Fuel Storage Facility Health and Safety Code hydrogen sulfide Inspection & Maintenance lso-Propyl Alcohol In-Station Diagnostics kilo (thousand) liter pound pounds per day pounds per hour Liquefied Petroleum Gas Landfill Gas

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M

MACT

MM

MMH

MRS

M&T

MVFF

MW

N2Ht

NAR

NSPS

NESHAP

NFPA

NMOC

NOV

ORVR

ovss

PM

PM10

PM2.s ppm(vd orw)

PSD

psia 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

YRS

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 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 IO microns particulate matter less than 2.5 µm in size 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 PressureN acuum 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 Dimethylhydrazine United Launch Alliance United States Environmental Protection Agency Vandenberg Air Force Base 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 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 petmits associated with the facilities that comprise the V AFB stationary source. Most of the permitted equipment consists of emergency standby generators, small boilers, and water heaters.

Santa Barbara County is designated as an ozone non-attainment transitional area for the state ambient air quality standards. The County is also designated a non-attainment area for the state PM10 ambient air quality standard.

Part 70 Permitting. This is the second renewal of the Part 70 permit for the VAFB stationary source (SSID I 195), which is a major source for NOx, CO, and GHGs, based on a federal potential to emit greater than I 00 tons per year ofNOx 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 June 23, 2017 These permits are listed in Section I .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 pennit, that pa1t 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.

1.2. Stationary Source/Facility Overview

I .2.1 Stationary Source/Facility Overview: VAFB 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 VAFB 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.

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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 activities located at V AFB are not owned and operated by the federal government, therefore they are not considered part of the V AFB stationary source.

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Figure 1.1.

N River, stream, creek

--==----===:I MIies "' ""' C: ··~~

3 9 s

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1.2.2 Facility New Source Overview: Since the first renewal of the Part 70 permit was issued for this facility in June 2017, the following permitting actions have taken place:

PERMIT TYPE ISSUE DATE DESCRIPTION

PTO 14362 8/24/2018

Conversion of Tank 1701 from a diesel Tank to a RP-1 Tank.

PTO 15012 9/7/2018 Replace clean air separator at Bldg 14400.

PTO 14969 9/18/2018

Installation of a new diesel-fired emergency fire water pump at Building 23209. 2016. 324 bhp Cummins.

PTO Mod 13968-02 2/28/2019 Revise ambient air monitoring language

PTO 14246 5/17/2019

Convert existing exempt diesel tank to E-85 and install a new dispenser at Building 10726.

Operation ofa new diesel-fired emergency backup PTO 15181 5/24/2019 generator at Building 8401. 2017, Cummins Model

QSX15-G9 rated at 755 bhp

Installation of two new diesel-fired emergency backup PTO 15175 5/29/2019 generator at Building 3000. 2017, Cummins Model

QST30-G% NR2 rated at 1,490 bhp each.

PTO 14926 7/1/2019

Operation ofa new diesel-fired emergency backup generator at Building 10525. 2016. 324 bhp Cummins.

PT-70 ADM 15437 9/18/2019

Change Title V Responsible Official from Colonel Michael S. Hough to Colonel Anthony J. Mastalir.

PTO 14968 ** Installation of a new paint spray booth and exempt booth heater at Building 1731.

Operation ofa new diesel-fired emergency backup PTO 15043 ** generator at Building 1581. 2016. 69 bhp Cummins.

Replaces Device ID 10737.

PTO 15065 ** Replace boilers with two new hot-water boilers in building 7000.

PTO 15141 ** Operation ofa new diesel-fired emergency backup generator at Building 21150. 2017 382 bhp Volvo Penta.

PTO 15258 ** Identical replacement ofa burner in one of two boilers located in building 13850.

Convert emissions from the existing paint booth at Bldg

PTO 15283 ** 7137 (Device #384072) to a surface coating operation used to coat oversized and mobile equipment outside of a paint booth.

**=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 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, RGNext, a.i. solutions, United Launch Alliance, The Boeing Company, EMCOR Government Services, Lockheed Martin, Northrup Grumman, Army Air Force Exchange Service, Call Henry, Inc., Katmai Government Services., United Paradyne Corporation, Alliance Technical Services, Inc.

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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 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 {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 VAFB.

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- I 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- I 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.

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 (CO2) 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 gasoline and E-85 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.

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1.3. IO 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), 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-I and MON-3 with smaller quantities contained in cylinders of MON-IO 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 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 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.

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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.

The system decontamination procedure utilizes Isopropyl Alcohol (IP A) 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 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.

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.

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 of30 ppm @ 3% 02 or less).

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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 ce1tified to meet current USEPA Tier standards. Diesel paiticulate filters are installed on the following IC engines: Device, #114491 (Bldg 511), #111765 (Bldg 929), #384066 (Bldg 2520) and #109236 (Bldg 21203).

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 (l&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- I propellant in tank # 170 I. 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. Operations at Building #7438 are conducted in a tented structure to control particulate matter (PM, PM10, and PM2.s). There are two abrasive blasting operations in Building #9320. The V ACU-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, 3 3 7, 3 3 9 and 3 51. Some reduction in particulates is achieved via filters in the spray booth and with use of water curtains.

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 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).

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I .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 IP A 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.

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).

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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 l 12(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 Patt 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 Patt 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 pe1mit 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 Patt 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)

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

Colonel Anthony J. Mastalir, Commander, 30th Space Wing U.S. Air Force 747 Nebraska Ave.

Vandenberg Air Force Base, CA 93437

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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 VAFB stationary emission units consist of boilers, internal combustion engines, and paint spray booths. Processes include using solvents and storing and transfeITing 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

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 engines used in aircraft and in locomotives are exempt.

Pursuant to Sections F. l .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. l .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. 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.

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;

Final Part 70/Permit to Operate 13968-R2 Page 16 of270

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. 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. 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 Air Force Base conducted under the Federal Facilities Site Remediation Agreement.

See Attachment 10.11 for a list of permit exempt equipment at the facility.

3.2. Compliance with Applicable Federal Rules and Regulations

3 .2.1 40 CFR Patts 51/52 {New Source Review (Nonattainment Area Review and Prevention of Significant Deterioration)}: VAFB 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 IO 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 subpat1 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.

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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.

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 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. The following operating requirements apply:

(I) 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.

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. The following operating requirements apply:

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

(2) inspect the air cleaner eve1y 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, VAFB 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 VAFB chooses to change the oil at the specified frequencies, no analysis is required.

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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.

3.2.6 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 V AFB pursuant to 40 CFR 63 .11169( d)( 1 ).

3.2.7 40 CFR Patt 70 {Operating Permits}: This Subpart is applicable to VAFB. 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 of VAFB semi-annually. Issuance of this permit and compliance with all its terms and conditions will ensure that V AFB complies with the provisions of all applicable Subparts.

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.J(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 G) in the DICE ATCM. The sulfur content for

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1231723443C Highlight 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 (ATCM) -- 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 A TCM prohibits the use of automotive coatings containing cadmium and hexavalent chromium.

This prohibition does not include coatings such as Amerlock 2/400 resin and Amerlock 400 Cure which contain trace amounts of hexavalent chromium and/or cadmium because the hexavalent chromium or cadmium was not introduced as a pigment or as an agent that imparts any property or characteristic to the coating during manufacturing, distribution, or use of the applicable coating. A CARB email pe1iaining to this exclusion is located in District permit files.

3 .3 .3 Title 17 California Code of Regulations, Subchapter 10, Article 4, Subaiticle 6, §95460 to §95476: The California Methane Emissions from Municipal Solid Waste Landfills regulation applies to active, inactive and closed MSW landfills which have 450,000 tons or greater of waste-in-place and received waste after January 1, 1977. The landfill subject to this permit is an active landfill with more than 450,000 tons of waste in place. Per §95463(b), landfills with a calculated gas heat input capacity of less than 3 .0 million Btu per hour are not required to install and operate landfill gas capture and control systems. The landfill gas heat input capacity shall be calculated annually using the procedures specified in this regulation to ensure this threshold is not exceeded.

If any annual landfill gas heat input calculation shows that that the 3 .0 million Btu per hour threshold is exceeded, the permittee shall comply with Sections 95464 through 95476 of the regulation, or demonstrate to the Executive Officer that a collection and control system are not need based…