2016-11-30_MAFB_TitleVRenewal_Part1_SIGNED.pdf

FINAL SUBMITTAL

U.S. Air Force Title V Permit Renewal Application

Prepared for

Malmstrom AFB, Montana

October 2016

Prepared by

CH2M HILL INC

322 E. Front St. suite 200

Boise, Idaho 83702 a TPMC/ARM Environmental Solutions r c l c

U.S. Air Force Title V Permit Renewal Application

Table of Contents Page

Definitions ................................................................................................................................................... iv

Abbreviations ................................................................................................................................................ x

Notification Addresses ................................................................................................................................ xii

Air Quality Inspector Information ............................................................................................................. xiii

Letter of Intent. ............................................................................................................................................ xv

1.0 General Facility Information and Site Description

2.0 Emitting Unit Listing

3 .0 Emissions Inventory

4.0 Emitting Unit and Control Equipment Information

5.0 Project and Site Information

6.0 Instructions on Public Notice For Montana Air Quality Permit

7.0 Applicable Requirements

8.0 Certification of Truth, Accuracy, and Completeness

Attachment 1-Title V Operating Permit Application

Appendix A - Insignificant Emission Units

Appendix B - Landfill Closure Documents

Appendix C- De Minimus Determination Letters

Appendix D - New Emergency Generator PTE

Appendix E-Air Force PTE Justification

Appendix F - PSD Lookback and GHG Emission Summary/Emergency Engine Emissions Data Sheets

Appendix G - NSPS 40 CFR 60 Subpart IIII Applicability Review

Appendix H - NESHAP 40 CFR 63 Subpart ZZZZ Applicability Review

Appendix I - Master Inventory of MAFB Emergency Generators and Fire Pumps

Appendix J - NESHAP 40 CFR 63 Subpart CCCCCC Applicability Review

Attachment 2- Application Fee

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U.S. Air Force Title V Permit Renewal Application

Definitions

Administrative Rules of Montana (ARM), Title 17, Chapter 8, Air Quality, Subchapter 12- 0perating Permit Program

17.8.1201 Definitions:

(1) "Administrative permit amendment" means an air quality operating permit revision that:

(a) corrects typographical errors;

(b) identifies a change in the name, address, or phone number of any person identified in the air quality operating permit, or identifies a similar minor administrative change at the source;

(c) requires more frequent monitoring or reporting by the permittee;

( d) allows for a change in ownership or operational control of a source if the department has determined that no other change in the air quality operating permit is necessary, consistent with ARM 17.8.1225; or

(e) incorporates any other type of change which the department and the U.S. Environmental Protection Agency (EPA) have determined to be similar to those revisions set forth in (l)(a) through (d).

(2) "Affected source" means a source that includes one or more affected units under Title IV of the Federal Clean Air Act (FCAA).

(3) "Affected states" means all states that are:

(a) contiguous to Montana and whose air quality may be affected by a source requiring an air quality operating permit, permit modification, or permit renewal; or

(b) within 50 miles of a source requiring an air quality operating permit, permit modification, or permit renewal.

(4) "Affected unit" means a unit that is subject to emission reduction requirements or limitations under Title IV of the FCAA.

(5) "Air quality operating permit" or "permit" means any permit or group of permits issued, renewed, revised, amended, or modified pursuant to this subchapter.

(6) "Air quality operating permit modification" or "permit modification" means a revision to an air quality operating permit that does not meet the definition of an administrative permit amendment under this subchapter.

(7) "Air quality operating permit renewal" or "permit renewal" means the process by which an air quality operating permit is reissued at the end of its term.

(8) "Air quality permit revision" or "permit revision" means any air quality operating permit modification or administrative permit amendment.

(9) "Montana air quality permit" (MAQP) means a permit issued, altered, or modified pursuant to subchapters 7, 8, 9, or 10 of this chapter.

(10) "Applicable requirement" means all of the following as they apply to emissions units in a source requiring an air quality operating permit (including requirements that have been promulgated or approved by the department or the administrator through rulemaking at the time of issuance of the air quality operating permit, but have future-effective compliance dates, provided that such requirements apply to sources covered under the operating permit):

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U.S. Air Force Title V Permit Renewal Application

(a) any standard, rule, or other requirement, including any requirement contained in a consent decree or judicial or administrative order entered into or issued by the department, that is contained in the Montana State Implementation Plan approved or promulgated by the administrator through rulemaking under Title I of the FCAA;

(b) any federally enforceable term, condition or other requirement of any Montana air quality permit issued by the department under subchapters 7, 8, 9, and 10 of this chapter, or pursuant to regulations approved or promulgated through rulemaking under Title I of the FCAA, including parts C and D;

( c) any requirement under section 111 of the FCAA;

(d) any requirement under section 112 of the FCAA, including any requirement concerning accident prevention under section 1 l 2(r)(7), but excluding the contents of any risk management plan required under section 112(r);

(e) any standard or other requirement of the acid rain program under Title IV of the FCAA or regulations promulgated thereunder;

(f) any requirements established pursuant to section 504(b) or section 114(a)(3) of the FCAA;

(g) any requirement governing solid waste incineration, under section 129 of the FCAA;

(h) any requirement for consumer and commercial products, under section 183(e) of the FCAA;

(i) any requirement for tank vessels, under section 183(f) of the FCAA;

(j) any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the FCAA, unless the administrator determines that such requirements need not be contained in an air quality operating permit;

(k) any national ambient air quality standard, increment, or visibility requirement under part C of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to section 504(e) of the FCAA; or

(I) any federally enforceable term or condition of any air quality open burning permit issued by the department under subchapter 6.

(11) "Designated representative" means a responsible person or official authorized by the owner or operator of an affected source and of all affected units at the source, to represent and legally bind each owner and operator in matters pertaining to the holding, transfer, or disposition of allowances allocated to a source, and the submission of and compliance with permits, permit applications, and compliance plans for the unit and all other matters pertaining to Title IV of the FCAA. Proof of such status shall be evidenced by a certificate of representation submitted pursuant to subpart B of 40 Code of Federal Regulations (CFR) Part 72, specifically 40 CFR 72.24 (58 FR 3590, January 11, 1993).

( 12) "Draft air quality operating permit" or "draft permit" means the version of an air quality operating permit which the department offers for public participation under ARM 17 .8.1232 or affected state review under ARM 17.8.1233.

(13) "Emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the air quality operating permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of reasonable preventative maintenance, careless or improper operation, or operator error.

(14) "Emissions allowable under the permit" means a federally enforceable air quality operating permit

EN0728161132BOI v term or condition determined at issuance to be required by an applicable requirement that establishes an emissions limit (including a work practice standard) or a federally enforceable emissions cap that the source has assumed to avoid an applicable requirement to which the source would otherwise be subject.

(15) "Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit (PTE) any regulated air pollutant or any pollutant listed under section l 12(b) of the FCAA. This term is not meant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA.

(16) "FCAA" means the Federal Clean Air Act, as amended.

(17) "Federally enforceable" means all limitations and conditions which are enforceable by the administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana State Implementation Plan, and any permit requirement established pursuant to 40 CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, subpart I, including operating permits issued under an EPA-approved program that is incorporated into the Montana State Implementation Plan and expressly requires adherence to any permit issued under such program.

(18) "Final air quality operating permit" or "final permit" means the version of an air quality operating permit issued by the department that has completed all review procedures required by ARM 17 .8.1220 through 17.8.1228, and 17.8.1231through17.8.1233.

(19) "Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening.

(20) "General air quality operating permit" or "general permit" means an air quality operating permit that meets the requirements of ARM 17 .8.1222, covers multiple sources in a source category, and is issued in lieu of individual permits being issued to each source.

(21) "Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to section 112(b) of the FCAA.

(22) The following apply to the definition of the term "insignificant emissions unit (IEU)":

(a) "IEU" means any activity or emissions unit located within a source that:

(i) has a PTE of less than five tons per year (tpy) of any regulated pollutant;

(ii) has a PTE of less than 500 pounds per year of lead;

(iii) has a PTE of less than 500 pounds per year of hazardous air pollutants listed pursuant to section 112(b) of the FCAA; and

(iv) is not regulated by an applicable requirement, other than a generally applicable requirement that applies to all emission units subject to this subchapter.

(b) Fugitive sources associated with an emissions unit are to be quantified with that emissions unit and are not considered IEUs.

(23) "Major source" means any stationary source (or any group of stationary sources that are located on one or more contiguous or adjacent properties, and are under common control of the same person (or persons under common control)) belonging to a single major industrial grouping and that are described in (23)(a) through (c). For the purposes of defining "major source," a stationary source or group of stationary sources shall be considered part of a single industrial grouping if all of the pollutant emitting activities at such source or group of sources on contiguous or adjacent properties belong to the same major group (i.e., all have the same two-digit code) as described in the Standard Industrial Classification Manual, 1987.

(a) A major source under section 112 of the FCAA, which is defined as:

(i) for pollutants other than radionuclides, any stationary source or group of stationary

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I r l

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U.S. Air Force Title V Permit Renewal Application sources located within a contiguous area and under common control that emits or has the PTE, in the aggregate, ten tpy or more of any hazardous air pollutant which has been listed pursuant to section l l 2(b) of the FCAA, 25 tpy or more of any combination of such hazardous air pollutants, or such lesser quantity as the board may establish by rule.

Notwithstanding the preceding sentence, emissions from any oil or gas exploration or production well (with its associated equipment) and emissions from any pipeline compressor or pump station are not aggregated with emissions from other similar units, whether or not such units are in a contiguous area or under common control, to determine whether such units or stations are major sources; or

(ii) for radionuclides, "major source" shall have the meaning specified by the department by rule.

(b) A major stationary source of air pollutants that directly emits or has the PTE, I 00 tpy or more of any air pollutant. The fugitive emissions of a stationary source shall not be considered in determining whether it is a major stationary source, unless the source belongs to one of the following categories of stationary source:

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(i) coal cleaning plants (with thermal dryers);

(ii) kraft pulp mills;

(iii) Portland cement plants;

(iv) primary zinc smelters;

(v) iron and steel mills;

(vi) primary aluminum ore reduction plants;

(vii) primary copper smelters;

(viii) municipal incinerators capable of charging more than 250 tons of refuse per day;

(ix) hydrofluoric, sulfuric, or nitric acid plants;

(x) petroleum refineries;

(xi) lime plants;

(xii) phosphate rock processing plants;

(xiii) coke oven batteries;

(xiv) sulfur recovery plants;

(xv) carbon black plants (furnace process);

(xvi) primary lead smelters;

(xvii) fuel conversion plant;

(xviii) sintering plants;

(xix) secondary metal production plants;

(xx) chemical process plants;

(xxi) fossil-fuel boilers (or combination thereof) totalling more than 250 million British thermal units (MMBtu) per hour heat input;

(xxii) petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels;

vii

(xxiii) taconite ore processing plants;

(xxiv) glass fiber processing plants;

(xxv) charcoal production plants;

(xxvi) fossil-fuel-fired steam electric plants of more than 250 MMBtu per hour heat input;

or

(xxvii) any other stationary source category, which as of August 7, 1980, is being regulated under section 111 or 112 of the FCAA.

(c) For particulate matter (PM-10) nonattainment areas classified as "serious" under Title I of the FCAA or regulations promulgated thereunder, sources with the PTE of 70 tpy or more of PM- I 0.

(24) The following apply to the definition of the term "nonfederally enforceable requirement":

(a) "nonfederally enforceable requirement" means, as applicable to emissions units in a source requiring an air quality operating permit, any requirement, including any requirement contained in a consent decree, or judicial or administrative order entered into or issued by the department, that is not contained in the Montana State Implementation Plan approved or promulgated by the administrator through rulemaking under Title I of the FCAA;

(b) "nonfederally enforceable requirement" does not include any Montana ambient air quality standard contained in subchapter 2 of this chapter.

(25) "Permittee" means the owner or operator of any source subject to the permitting requirements of this subchapter, as provided in ARM 17 .8.1204, that holds a valid air quality operating permit or has submitted a timely and complete permit application for issuance, renewal, amendment, or modification pursuant to this subchapter.

(26) "Potential to emit" and "PTE" mean the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design only if the limitation is federally enforceable. As used in this subchapter, this definition does not alter the use of this term for any other purposes under the FCAA, or the term "capacity factor" as used in Title IV of the FCAA or rules promulgated thereunder.

(27) "Proposed air quality operating permit" or "proposed permit" means the version of an air quality operating permit that the department proposes to issue and forwards to the administrator for review in compliance with ARM 17.8.1233. This includes any final permit which has been appealed to the Board of Environmental Review, if the board has directed the department to issue a permit that differs from the proposed permit previously forwarded to the administrator for review in compliance with ARM 17.8.1233.

(28) "Regulated air pollutant" means the following:

(a) nitrogen oxides or any volatile organic compounds (VOCs);

(b) any pollutant for which a national ambient air quality standard has been promulgated;

(c) any pollutant that is subject to any standard promulgated under section 111 of the FCAA;

(d) any Class I or II substance subject to a standard promulgated under or established by Title VI of the FCAA; or

( e) any pollutant subject to a requirement established or promulgated under section 112 of the FCAA including, but not limited to, the following:

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U.S. Air Force Title V Permit Renewal Application

(i) any pollutant subject to requirements under section 112(j) of the FCAA. If the administrator fails to promulgate a standard by the date established pursuant to section 112(e) of the FCAA, any pollutant for which a subject source would be major is considered to be regulated on the date 18 months after the applicable date established pursuant to section 112( e) of the FCAA; and

(ii) any pollutant for which the requirements of section 112(g)(2) of the FCAA have been met, but only with respect to the individual source subject to the section 112(g)(2) requirement.

(29) "Responsible official" means one of the following:

(a) For a corporation:

(i) a president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function;

(ii) any other person who performs similar policy or decision-making functions for the corporation; or

(iii) a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and either:

(A) the facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or

(B) the delegation of authority to such representative is approved in advance by the department.

(b) For a partnership or sole proprietorship, a general partner or the proprietor, respectively.

(c) For a municipality, state, federal, or other public agency:

(i) a ranking elected official; or

(ii) a principal executive officer. A principal executive officer of a federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a regional administrator of the EPA).

(d) For affected sources, the designated representative concerning actions, standards, requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated thereunder, and the designated representative for any other purposes under this subchapter.

(30) "Section 502(b)(10) changes" are changes that contravene an express permit term. Such changes do not include changes that would violate applicable requirements or contravene federally enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements.

(31) "Source requiring an air quality operating permit" means any source subject to the permitting requirements of this subchapter, as provided in ARM 17.8.1204.

(32) "State" means any nonfederal air quality permitting authority, including any local agency, interstate association, or statewide program. Where such meaning is clear from the context, "state" shall have its conventional meaning.

(33) "Stationary source" means any building, structure, facility, or installation that emits or may emit any regulated air pollutant or any pollutant listed under section 112(b) of the FCAA.

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Abbreviations

ACFM

AF

AFC EC

ARM

BACT

BIFs

Btu

CAM

CEMS

CFR

COMS

dscf

EIAD

EPA

FCAA

gpm

HAP

hp hr/yr

IEU

kW

LAER

Lb/hour

MACT

MAFB

MAQP

MCA

MDEQ

MFG

MM Btu

NAAQS

NESHAP

NOx

NSPS

NSR

Pb

PM10

PSD

PSEU

psi

PTE

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actual cubic feet per minute

Air Force

Air Force Civil Engineer Center

Administrative Rules of Montana best available control technology boilers and industrial furnaces

British Thermal Unit

Compliance Assurance Monitoring continuous emission monitoring system

Code of Federal Regulations continuous opacity monitoring system dry standard cubic foot

Equipment Inventory Authorized Data

U.S. Environmental Protection Agency

Federal Clean Air Act gallons per minute hazardous air pollutant horsepower hours per year insignificant emissions unit kilowatt lowest achievable emission rate pounds per hour maximum achievable control technology

Malmstrom Air Force Base

Montana Air Quality Permit

Montana Code Annotated

Montana Department of Environmental Quality

Engine Manufacturer

Million British thermal units

National Ambient Air Quality Standards

National Emissions Standards for Hazardous Air Pollutants oxides of nitrogen

New Source Performance Standard

New Source Review lead particulate matter less than 10 microns in size prevention of significant deterioration pollutant specific emitting unit pounds per square inch absolute potential to emit

QIP Quality Improvement Plan

RICE reciprocating internal combustion engine

[ SDA spray dryer absorber SIC Standard Industrial Classification

SSM startup, shutdown, and malfunction c S02 sulfur dioxide

SOx oxides of sulfur tpy tons per year voe volatile organic compound

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Notification Addresses

Compliance Notifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau P.O. Box 200901 Helena, MT 59620-0901

United States EPA Air Program Coordinator Region VIII, Montana Office Federal Building, 10 West 15th Street, Suite 3200 Helena, MT 59626

Permit Modifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau P.O. Box 200901 Helena, MT 59620-0901

Office of Partnerships and Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P-AR 1595 Wynkoop Street Denver, CO 80202-1129

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[ Air Quality Inspector Information

L

Disclaimer: The information in this appendix is not State or Federally enforceable but is presented to assist Malmstrom Air Force Base (MAFB), permitting authority, inspectors, and the public.

1. Direction to Plant: Exit Interstate 15 on 10th A venue South and go approximately six miles east to 57th Street. Go north on 57th Street approximately 1 mile to 2nd A venue North. Go east on 2nd Avenue North approximately one mile to Base gate.

2. Safety Equipment Required: Hard hats, steel toe boots, and hearing protection are required in various locations at the base according to Air Force Occupational Safety and Health requirements.

3. Facility Plot Plan: A facility plot plan is on file with the Department.

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DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 341 ST MISSILE WING (AFGSC)

Colonel Ronald G. Allen, Jr.

Commander, 341 st Missile Wing 21 77th Street North, Suite 144 Malmstrom AFB MT 59402-7538

Mr. Grant Radway Montana Department of Environmental Quality Box 200901 Helena MT 59620-0901

Dear Mr. Radway

This letter of intent and the attached permit renewal package are intended to satisfy the renewal requirements for Air Quality Title V Operating Permit #OP1427-11 (TRD 1427-11) in accordance with the Administrative Rules of Montana (ARM) 17.8.1205(3)(a). The renewal package provides information on any modifications or additions since the last permit renewal. With respect to the existing permit, Malmstrom Air Force Base (MAFB) has added five new emission sources since the last Title V Operating Permit renewal and proposes to remove EU006 and EU007 from #OP1427-11.

Five new emergency /backup diesel generators have been added to MAFB since receiving #OP1427-11. MAFB received determination letters from the Montana Department of Environmental Quality (MDEQ) confirming that each of the five emergency generators comply with the de minimus rule ARM 17.8.745 but are not considered insignificant emissions units (IEUs) under ARM 17.8.1201(22)(a)(iv).

EU006 and EU007 are closed landfills. Supporting documentation is provided from MDEQ that references landfill closure for justifying removal of these sources from #OP1427-11.

An applicability review of the federal New Source Performance Standard (NSPS) 40 Code of Federal Regulations (CFR) 60, Subpart 1111identified11 stationary emergency engine generators that are subject to this subpart. Additionally, an applicability review of the federal National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63, Subpart ZZZZ identified 19 stationary emergency engine generators that are solely subject to this subpart.

There are no proposed changes to the Compliance Assurance Monitoring (CAM) Plan for the Central Heat Plant boilers and no other significant changes proposed in this permit application renewal.

As shown in the attached annual compliance certification, the sources included in #OP1427-11 are currently in compliance with the regulatory requirements specified within the permit. If you have any questions regarding this information, please contact Mr. Bob Richards at (406) 731-7148. Thank you for your consideration of this permit renewal.

A copy of the Title V Operating Permit renewal application has been mailed to the United States Environmental Protection Agency (EPA) Region VIII.

DETER .. .ASSURE. .. STRJKE!

I certify under penalty of law that, based on information and belief formed after reasonable inquiry, the statements and information contained herein are true, accurate, and complete.

Sincerely, ~1}(,Q~£:USAF

Commander, 341st Missile Wing

CC: Office of Partnerships and Regulatory Assistance Air and Radiation Program

US EPA Region VIII SP-AR 1595 Wynkoop Street Denver, CO 80202-1129

Attachments:

1. Title V Renewal Application

2. Application Fee

ATTACHMENT 1 - Title V Operating Permit Renewal Application

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p~~o.

of Environmental Quality lb Air Quality Bureau • P.O. Box 200901 • Helena MT 59620-0901 • (406) 444-3490

AIR QUALITY PERMIT APPLICATION FOR STATIONARY SOURCES

Montana Department of Environmental Quality Air Resources Management Bureau Permitting Section Supervisor 1520 E. Sixth Avenue P.O. Box 200901 Helena, MT 59620-0901 Phone: (406) 444-3490 FAX (406) 444-1499 Email: DEQ-ARMB-Admin@mt.gov

_For St3te of Montana Use Onlv Permit Application #: AFS #: ___ _

D D Application Fee Paid with Application? Yes Amount Paid: Check#: ____ _

No

Three complete copies of this application, any associated fees, and the affidavit of publication of the attached public notice must be delivered to the address above. The application may be submitted electronically to the email address provided above; however, the application will not be considered complete until the appropriate permit application fee, affidavit of publication, and certification of truth, accuracy, and completeness are submitted to the Department. Any checks, affidavits, and certifications submitted separately from the application should be clearly identified. The applicant is encouraged to contact the Department with any questions related to this application/arm.

Note: This application form should not be used for portable sources or oil and gas registrations. Permit application forms for portable sources and oil and gas registrations are available on the Department's website.

Applications for Acid Rain permits must be made on nationally standardized forms available from the U.S.

Environmental Protection Agency (EPA) as well as through the Department's application for a Title V Operating Permit.

§1.0 General Facility Information and Site Description lH .1 FACILITY NAME AND ADDRESS (As ref!istered with the Montana Secretarv of State )

Company Name Deoartment of the Air Force

Facility Name Malmstrom Air Force Base. Montana

Mailing Address Physical Address (if different from mailing address) B41CES/CEANQ,39 - 78th Street North Address

Address Malmstrom AFB MT 59402-7536 City State Zip City State Zip

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§1.2 Contact Information

Name Title Telephone Email

Owner Department of the Malmstrom Air Force

Air Force Base

Facility Manager

Responsible Colonel Ronald G. 341 st Missile Wing (406) 731-3411 Ronald.allen.1@

Official Allen, Jr. Commander us.af.mil

Alternate

Responsible Official

Contact Person Robert Richards, Environmental (406) 731-7148 Robert.richards.

P.E. Engineer 12@us.af.mil

Alternate Contact Tony Lucas Chief, Environmental ( 406) 731-3665 Tony.lucas@us.

Person af.mil

[Note: If email address is provided, the Department will send all permit notices (i.e. Preliminary

Determination, Department Decision, and Final Permit) electronically.

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§1.3 PERMIT TYPE (Check all that apply)

D Montana Air Quality Permit (MAQP)

MAQP Permit Action: D New Facility D Modification to Existing Permit #

D Synthetic Minor (major source usingfederally enforceable permit conditions to avoid MACT, NSR, or Title V Operating Permit requirements)

D New Source Review

D Prevention of Significant Deterioration

D Nonattainment Area

Air Quality Operating Permit (Title 11

Title V Permit Action: D Initial Air Quality Operating Permit

[gl Renewal of Air Quality Operating Permit #OP 1427-11, TRD1427-11

D Modification of Air Quality Operating Permit #OP ________ _

D Minor Modification

D Significant Modification

Note: The applicant must also send one copy of the Title V Operating Permit application to the EPA at the following address:

Office of Partnerships and Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P-AR 1595 Wynkoop St.

Denver, Colorado 80202-1129

A statement certifying that a copy of the Title V Operating Permit application has been mailed to EPA must accompany the Title V Operating Permit application .

§1.4 Physical Location and Facility Information

Qtr/Qtr Section NW~NE ~ Section 2. Township 20 North Range 4 East

Latitude (in decimal degrees) 47.504958 Longitude (in decimal degrees) 111.188025

County Cascade

Will the facility be operating in (or impacting) a nonattainmentarea? Yes D No [gl

(Note: Maps of the state's nonattainment areas can be found at the following website:

http://deg.mt.gov/ AirOuality/Planning/AirNonattainment.asp.)

If yes, which pollutant(s) is the area nonattainmentfor?

Total Property Area (acres) 3,260 Year Facility Began Operation at Site: 1942

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Standard Industrial Classification (SIC) Codes(s): 9711 SIC Description(s): National Security

(Note: SIC Codes can be found at the following website: http://www.osha.gov/pls/imis/sicsearch.html.)

For MAQP only, a drawing, sketch, or topographic map of appropriate scale must be submitted (maximum scale l "=500 ', measurement to the nearest 20 '), showing at least the following:

a. The property boundaries on which the source is located;

b. The outlines and dimensions of all existing and proposed buildings and stacks;

c. The locations of existing and proposed emitting units, including /at/long coordinates (in NAD83) and elevation (in feet above mean sea level) for each emitting unit. The emissions units and points should be identified as existing or proposed;

d. Any nearby streets, highways, and waterbodies;

e. Any nearby sensitive areas, such as schools, hospitals, parks, residential areas, etc.;

f A true north arrow; and

g. A graphically displayed scale.

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§1.5 Project Summary (Not Required for Title V Operating Permit applications)

Overview of project, including any new or modified equipment (attach additional information as necessary):

Include a process flow diagram showing material balances.

Construction/Installation Schedule:

Expected Construction Start Date: _____ _ Expected Operation Start Date: _____ _

Duration (if a temporary source): -------------------------

Optional Information:

Estimate of Capital Expenditure for Proposed Project: $ _____ Estimate of Cost of Air Pollution

Control Equipment:$ _________________ _

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§2.0 Emitting Unit Listing

List all existing and proposed emitting units.

For Title V Operating Permits only, note all IEUs.

Note: An /EU includes any activity or emissions unit that has the potential to emit less than 5 tons per year (tpy) of any regulated pollutant, less than 500 pounds per year of lead, less than 500 pounds per year of a hazardous air pollutant, and is not regulated by an applicable requirement, such as a NSPS or maximum achievable control technology (MACT) standard.

There are no new IEUs proposed for this Title V Operating Permit renewal. For clarification purposes, MAFB is requesting to re-define IEU031 from "Small Engine Generators" to "Emergency Generators not subject to Regulation". A summary table identifying the IEUs are provided in Appendix A.

MAFB is requesting to remove EU006 and EU007 from #OP1427-10. EU006 and EU007 are closed landfills identified as LF-18 and LF-19, respectively. Documented landfill closure by MDEQ is provided in Appendix B.

Five new emergency/backup diesel generators have been added to MAFB since receiving #OP1427-10.

MAFB received determination letters from MDEQ confirming that emergency generators comply with the de minimus rule under ARM 17.8.745 for the following:

• Building 1836 (97.6 horsepower [hp]) dated February 3, 2012

• Building 219 (145 hp) dated September 18, 2013

• Building 165 (162 hp) and Building 429 (25 hp) dated July 13, 2016

• Building 1840 (497 hp) dated October 14, 2016

The five new emergency/diesel backup emergency generators are considered significant emission units because they are each subject to the NSPS 40 CFR 60 Subpart III!. MDEQ de minimus determination letters are provided in Appendix C.

Based on applicability review of NSPS 40 CFR 60 Subpart IIII, a total of 11 emergency engines are subject to this subpart. The IEU identified in #OP1427-10 as IEU034 (Building 18902 -35 kilowatt [kW]) is a de minimus source per ARM 17.8.745 and should be reclassified as a significant emission unit because it is a stationary emergency engine generator subject to Subpart IIII manufactured and installed in 2008. In addition, EU004 and EUO 10 are also emergency engine generators subject to Subpart !III manufactured and installed in 2009. Refer to the applicability review of 40 CFR 60 Subpart IIII in Appendix G.

Based on applicability review of 40 CFR 63 Subpart ZZZZ, a total of 19 emergency engines are solely subject to this subpart. There are a total of five MAFB emergency generators not subject to regulation for existing institutional emergency stationary reciprocating internal combustion engines (RICE) located at an areas source of hazardous air pollutant (HAP) emissions in accordance with 40 CFR

63.6585 (f)(3):

• Weapons Storage Area - Building 1831 (Police Station)

• Fire Station - Building 348 (Fire Station)

• Hospital - Building 2040 (Medical Center)

• Law Enforcement - Building 294 (Police Station)

• Maintenance Ops& KCCC - Building 1439 (Police Station)

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An institutional emergency stationary RICE is defined as ( ... an emergency stationary RICE used in institutional establishments such as medical centers, nursing homes, research centers, institutions of higher education, correctional facilities, elementary and secondary schools, libraries, religious establishments, police stations, and fire stations.) Refer to the applicability review of 40 CFR 63 Subpart ZZZZ in Appendix H.

A master inventory of MAFB emergency engine generators and fire pumps are included in Appendix I. Note that the master list of emergency engine generators includes 10 Equipment Inventory Authorized Data (EIAD) units. These EIAD units include emergency engine generators kept on base for mission essential emergency use only in the event that an existing emergency generator malfunctions and is not operational. EIAD units are maintained by MAFB and used in a portable manner. At no time have these units remained in place and operated at a single location for more than 12 months. Therefore, the use of these EIAD units satisfy the non-road engine definition and are considered to be mobile sources of emissions that do not need to be included in this Title V Operation Permit renewal. In addition, Mr.

Warner from the Montana Department of Environmental Quality (MDEQ) provided an email to MAFB supporting this determination on September 26, 2016. A copy of this email correspondence is included in Appendix I.

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EMITTING UNIT Pollution New Existing Insignificant ID Name Control Device Source Source Yes No

EU001-EU005, See Permit #OP1427-10 for D ~ D D EU008- EUOlO a list of existing sources

EU006 Landfill 11 D ~ D D EU007 Landfill 21 D ~ D D TBD007 Building 1836 Less than 160

Emergency/Backup Diesel hours/year5 ~ D D ~ Generator (97.6 hp)2

TBD003 Building 219 Less than 160 Emergency/Backup Diesel hours/year5 ~ D D ~ Generator (145 hp)3

TBDOOl Building 165 Less than 160 Emergency/Backup Diesel hours/year5 ~ D D ~ Generator ( 162 hp )4

TBD005 Building 429 Less than 160 Emergency/Backup Diesel hours/year5 ~ D D ~ Generator (25 hp )4

TBD028 Building 1840 Less than 160 Emergency/Backup Diesel hours/year5 ~ D D ~ Generator (497 hp)6

Notes:

1 MAFB Landfill closure letters are provided in Attachment 5 (MDEQ 1998).

2 On February 3, 2012, MAFB received a determination letter from MDEQ for a 97.6 hp emergency generator located at Building 1836 to confirm that the potential to emit (PTE) is below the 5 tpy de minimus threshold for any pollutant specified in ARM l 7.8.745(a) and not considered an insignificant unit with respect to Title V.

3 On September 18, 2013, MAFB received a determination letter from MDEQ for a 145 hp emergency generator located at Building 219 to confirm that the PTE is below the 5 tpy de rninimus threshold for any pollutant specified in ARM 17 .8. 745(a) and not considered an insignificant unit with respect to Title V.

4 On July 13, 2016, MAFB received a determination letter from MDEQ for a 25 hp emergency generator and a 162 hp emergency generator located at Building 429 and Building 219, respectively to confirm that the PTE is below the 5 tpy de rninimus threshold for any pollutant specified in ARM l 7.8 .745(a) and are not considered insignificant units with respect to Title V.

5 Based EPA guidance (Seitz 199 5) authorizing source owners to make case-by-case historical data-driven PTE estimates, the Air Force (AF) established an AF-specific emergency generator PTE of 160 hours per year (hr/yr) (AFCEC 2014, AF-PTE Guide).

6 On October 14, 2016, MAFB received a determination letter from MDEQ for a 497 hp emergency generator located at Building 1840 to confirm that the PTE is below the 5 tpy de minimus threshold for any pollutant specified in ARM 17.8.745(a) and are not considered insignificant units with respect to Title V.

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§3.0 Emissions Inventory

A separate Section 3.0 must be completed/or each emitting unit listed in Section2.0.

Attach calculations:

The source(s) of all emissions estimates must be indicated (e.g. manufacturer's data, AP-42, source tests, etc.). If possible, calculations should be submitted electronically using an Excel spreadsheet.

Potential or allowable emission calculations for the four new emission units are summarized below based on building number and included in Appendix D. The hierarchy of emission factors used for estimating PTE were based on available manufacturer emission data sheets, Montana Department of Environmental Quality (MDEQ) emission factors, and EPA AP-42 emission factors.

In a DEQ memorandum dated January 16, 2004, MDEQ determined that MAFB is a major source as defined under the New Source Review (NSR) permitting program and that potential emissions from any modifications were below the NSR/Prevention of Significant Deterioration (PSD) significance thresholds for all pollutants. MAFB has provided a PSD lookback table to document that potential emissions from modifications to MAFB since 2004 were below the NSR/PSD significance thresholds for all pollutants. Refer to prevention of significant deterioration (PSD) lookback tables in Appendix F. Manufacturer emission data sheets for emergency engines installed since 2004 accompany the PTE calculations in Appendix F.

In addition, MAFB is requesting to use a potential-to-emit (PTE) of 160 hours per year (hr/yr) for emergency generators based on justification determination provided by the Air Force Civil Engineer Center (AFCEC) documented in the Air Force PTE Guide dated December 2014. AFCEC made reference to the EPA published memorandum for calculating PTE for emergency generators (Seitz, 1995) limiting the potential hours of operation to 500 hr/yr. However, in this same memorandum the EPA authorized emergency generator owners to make case-by case historical data-driven PTE estimates. Therefore, the AF performed an analysis based on historic data use and developed an AF-specific PTE of 160 hr/yr for emergency generators. The AF emergency generator PTE justification is provided in Appendix E. Additionally, MAFB included a comparison of these emergency generator PTE estimates using 160 hr/yr versus 500 hr/yr to illustrate that the results are negligible.

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EU ID: TBDOOl Emitting Unit Name: Building 165 Emergency Generator

Regulated Air Pollutant Allowable Emission Rate(s)1•2 Actual Emission Rate(s) (if applicable)3

(Lb/Hour) (Tons/Year) (Lb/Hour) (Tons/Year)

PM10 0.04 0.003 0.04 0.003

PM2.s 0.04 0.003 0.04 0.003

S02 0.06 0.005 0.06 0.005

NOx 0.69 0.06 0.69 0.06 co 0.30 0.02 0.30 0.02 voe 0.04 0.003 0.04 0.003

Pb4 NA NA NA NA

Other (specify): Total hazardous air 3.61E-04 3.6IE-04 pollutants (HAPs)

Notes:

1 Allowable emission rate(s) should equal the PTE, unless a federally enforceable permit limit is proposed. Potential emissions are to be calculated based on production at the maximum capacity for 8,760 hr/yr. Only control practices or equipment which is proposed to be made federally enforceable may be used to limit the PTE of the unit.

2 The AF proposes a site-specific PTE of 160 hr/yr for the stationary emergency generators.

3 Actual emission rate(s) should equal the average rate at which the unit actually emitted the pollutant during a two-year period which precedes the particular date and which is representative of normal source operation. Actual emissions shall be calculated using the unit's actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

4 No lead emission factors available from manufacturer or AP 42, Section 3.

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EU ID: TBD007 Emitting Unit Name: Building 1836 Emergency Generator

Regulated Air Pollutant Allowable Emission Rate(s)1•2 Actual Emission Rate(s) (if applicable)3

(Lb/Hour) {TonsNear) (Lb/Hour) {TonsNear)

PM10 0.06 0.005 0.06 0.005

PM2.s 0.06 0.005 0.06 0.005

S02 0.20 0.02 0.20 0.02

NOx 1.16 0.09 1.16 0.09 co 0.36 0.03 0.36 0.03 voe 0.07 0.01 0.07 0.01

Pb4 NN NN NN NN

Other (specify) : Total HAPs 2.16E-04 2.16E-04

Notes:

1 Allowable emission rate(s) should equal the PTE, unless a federally enforceable permit limit is proposed.

Potential emissions are to be calculated based on production at the maximum capacity for 8,760 hr/yr. Only control practices or equipment which is proposed to be made federally enforceable may be used to limit the PTE of the unit.

2 The AF proposes a site-specific PTE of 160 hr/yr for the stationary emergency generators.

3 Actual emission rate(s) should equal the average rate at which the unit actually emitted the pollutant during a two year period which precedes the particular date and which is representative of normal source operation. Actual emissions shall be calculated using the unit's actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

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EU ID: TBD003 Emitting Unit Name: Building 219 Emergency Generator

Regulated Air Pollutant Allowable Emission Rate(s)1 2 Actual Emission Rate(s)

(if applicable)3

(Lb/Hour) (TonsNear) (Lb/Hour) (TonsNear)

PM10 0.02 0.002 0.02 0.002

PM2.s 0.02 0.002 0.02 0.002

S02 0.04 0.004 0.04 0.004

NOx 0.76 0.06 0.76 0.06 co 0.16 0.01 0.16 0.01 voe 0.01 0.001 0.01 0.001

Pb4 NN NAa NN NN

Other (specify): Total HAPs 2.37E-04 2.37E-04

Notes:

1 Allowable emission rate(s) should equal the PTE, unless a federally enforceable permit limit is proposed.

Potential emissions are to be calculated based on production at the maximum capacity for 8,760 hr/yr. Only control practices or equipment which is proposed to be made federally enforceable may be used to limit the PTE of the unit.

2 The AF proposes a site-specific PTE of 160 hr/yr for the stationary emergency generators.

3 Actual emission rate(s) should equal the average rate at which the unit actually emitted the pollutant during a two year period which precedes the particular date and which is representative of normal source operation. Actual emissions shall be calculated using the unit's actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

EN0728161132BOI 12

EU ID: TBDOOS Emitting Unit Name: Building 429 Emergency Generator

Regulated Air Pollutant Allowable Emission Rate(s)1.2 Actual Emission Rate(s) (if applicable)3

(Lb/Hour) (Tons/Year) (Lb/Hour) (Tons/Year)

PM10 0.01 0.0005 0.01 0.0005

PM2.s 0.01 0.0005 0.01 0.0005

S02 0.05 0.004 0.05 0.004

NOx 0.19 0.02 0.19 0.02 co 0.02 0.001 0.02 0.001 voe 0.01 0.0004 0.01 0.0004

Pb4 NA a NA8 NA a NA8

Other (specify): Total HAPs 5.82E-05 5.82E-05

Notes:

1 Allowable emission rate(s) should equal the PTE, unless a federally enforceable permit limit is proposed.

Potential emissions are to be calculated based on production at the maximum capacity for 8,760 hr/yr. Only control practices or equipment which is proposed to be made federally enforceable may be used to limit the PTE of the unit.

2 The AF proposes a site-specific PTE of 160 hr/yr for the stationary emergency generators.

3 Actual emission rate(s) should equal the average rate at which the unit actually emitted the pollutant during a two year period which precedes the particular date and which is representative of normal source operation. Actual emissions shall be calculated using the unit's actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

EN0728161132BOI 13

EU ID: TBD028 Emitting Unit Name: Building 1840 Emergency Generator

Regulated Air Pollutant Allowable Emission Rate(s)1,2 Actual Emission Rate(s) (if applicable)3

(Lb/Hour) (Tons/Year) (Lb/Hour) (Tons/Year)

PMio 0.02 0.0013 0.02 0.0013

PM2.s 0.02 0.0013 0.02 0.0013

S02 0.002 0.0002 0.002 0.0002

NOx 0.24 0.02 0.24 0.02 co 0.02 0.001 0.02 0.001 voe 0.002 0.0002 0.002 0.0002

Pb4 NN NN NN NN

Other (specify): Total HAPs 4.E-04 4.E-04

Notes:

1 Allowable emission rate(s) should equal the PTE, unless a federally enforceable permit limit is proposed.

Potential emissions are to be calculated based on production at the maximum capacity for 8,760 hr/yr. Only control practices or equipment which is proposed to be made federally enforceable may be used to limit the PTE of the unit.

2 The AF proposes a site-specific PTE of 160 hr/yr for the stationary emergency generators.

3 Actual emission rate(s) should equal the average rate at which the unit actually emitted the pollutant during a two year period which precedes the particular date and which is representative of normal source operation. Actual emissions shall be calculated using the unit's actual operating hours, production rates, and types of materials processed, stored, or combusted during the selected time period.

EN0728161132BOI 14

§4.0 Emitting Unit and Control Equipment Information

A separate Section 4.0 must be completed for eaclr emitting unit listed in Section 2.0. Applications for Title V Operating Permits must address significant emission units individually. Insignificant emission units may be addressed as a group. For information that has been previously submitted, the applicant may instead reference the previously submitted information, including the date the material was submitted and the source (i.e. permit application number, etc.)

A comprehensive evaluation of the MAFB inventory of emergency engine generators and fire pumps have been performed to identify each significant emission unit. A total of 10 significant emission units are identified as being subject to 40 CFR 60 Subpart IIII included in the table below and summarized in Appendix G. A total of 19 significant emission units are identified as being subject to 40 CFR 63 Subpart ZZZZ included in the table below and summarized in Appendix H. In addition, there are a total of five IEUs not subject to regulation for existing institutional emergency stationary RICE. Refer to the summary table in Appendix H.

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MAFB Stationary Emergency CI ICE NSPS 40 CFR 60 Subl!.att lllLApp_licabilif.2!_ - Summary Xable

GenSet 40 CFR60 (Rated) Engine Gen set ©en set Year Subpart IlII Title V Permit

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