PERMIT TO OPERATE Number Valid July 1, 2004 to June 30, 2005

Transcription

1 HDMSP PERMIT TO OPERATE Number RAF7 Valid July 1, 2004 to June 30, 2005 This Permit Has Been Issued To The Following : Company Name / Address : Facility Name / Address : The Boeing Company Santa Susana Field Laboratory P.O. Box 7922 MS T487 Facility FESOP Permi t Canoga Park, CA Simi Valley, CA Permission Is Hereby Granted To Operate The Following : Rocket Engine and Component Testing Operation s Alfa Test Are a 2 - Rocket Engine and Component Test Stands (Alfa-1 and Alfa-3) 1 - Gaseous Nitrogen (GN2) Flushing System, used to flus h residual propellants from the engines and components after testing Bravo Test Are a 2 - Rocket Engine and Component Test Stands (Bravo-1 and Bravo-2 ) Advanced Propulsion Test Facility (APTF ) 4 - Rocket Engine and Component Test Stands (LIMA, MIKE, PETER, and NAN ) 3 - Afterburners, two located PETER Stand and one located at NAN Stan d 5 - Hydrogen Flare Stacks, one each located at Tank No. 1156, Hilltop High Pressure, Hydrogen Storage Tank No. V-650, Hydrogen Storage Tank No. V-122, and NAN Stand Liquid Hydrogen Exhaus t Systems Test Laboratory No. 4 (STL-4 ) 4 - Rocket Engine and Component Test Cells (Nos. 24, 29, 35, and 37 ) 1 - Nitrogen Tetroxide (NTO) Venting Syste m 1 - Monomethyl Hydrazine (MMH) Venting System, using a 20' high x 7' diameter water tank as a scrubbe r Hypergol.Facilit y 1 - Flushing System, using RP-1 to flush excess hypergolic ignitor material from the ignitor casing loading equipment at this facilit y Page 1 Draf t

2 HDMSP Rocket Engine and Component Assembly Operation s Remote Reservoir Cold Cleaner s 1-88" x 26" x 14" Remote Reservoir Cold Degreasing Tan k (Building No. 301 ) using isopropyl alcohol ( IPA) and cyclohexane 1-48" x 22 " x 8" Remote Reservoir Cold Degreasing Tan k (Building No. 324 ) using isopropyl alcohol ( IPA) and cyclohexane Cold Cleaner s 1-55" x 54 " x 34" (outer dimensions ) Cold Degreasing Tan k (Building No. 984 ) using Turco 6802 solvent and Axarel 56 solvent 1-56" x 56" x 48 " ( outer dimensions ) Cold Degreasing Tan k (Building No. 984 ) using Turco 6802 solvent and Axarel 56 solvent 1-49" x 68" x 45 " Cold Degreasing Tank ( Building No. 984 ) using Turco 6802 solvent and Axarel 56 solvent Solvent Cleaning Operation s Surface Coating Operations including the following Spray Booths : 1 - Binks, Model WE - 10, Dry Filter Spray Booth, equipped with a three stage ATI OSM Dry Filter System (Booth No. 1, Building No. 796 ) 1 - Binks, Model AA530, Dry Filter Spray Booth (Booth No. 2, Building No. 206 ) Adhesive and Sealant Operation s Portable Diesel Engine s BHP Generac, Model GT125, Diesel Engines, for the generation of electricity, NR08055 & NRO BHP Generac, Model GT85, Diesel Engine, for the generation of electricity, NROO BHP John Deere, Model 3179D, Diesel Engine, used to drive an air compressor, N BHP Deutz, Model F3L912, Diesel Engine, used to drive an air compressor, Z Emergency Diesel Engine s BHP G. M. Diesel, Model DASE , Diesel Engine, emergency electrical generation, M BHP Caterpillar, Serial 1M128111, Diesel Engine, emergency electrical generation, N BHP Caterpillar, Model T (D50P2 ), Diesel Engine, emergency electrical generation, BN Page 2 Draft

3 HDMSP BHP Caterpillar, Serial 29A00587, Diesel Engine, emergency electrical generation, Z BHP Generac, Model 99A , Diesel Engine, emergency electrical generation for telecommunication system, BN BHP Onan, Model RDJF, Diesel Engine, emergency electrical generation for radio system, M Ground Water and Remediation Operation s At Water Supply Well 9A, Delta Area, Area II : 1 - Tankinetics Air Stripping System, 200 gallon per minute capacity, consisting of : Cubic Feet Per Minute Primary Air Stripper Tower, 36 feet high x 36 inches diamete r Cubic Feet Per Minute Secondary Air Stripper Tower, 28 feet high x 36 inches diamete r 1 - Carbon Adsorption System, equipped with 8 carbon canisters, 55 gallon capacity each, operated in parallel, controlling exhaust from the primary towe r At Deep Well RD-1, Happy Valley, Area I : 1 - Tankinetics Air Stripping System, 40 gallon per minute capacity, consisting of : 1-60 Cubic Feet Per Minute Primary Air Stripper Tower, 27 feet high x 18 inches diamete r Cubic Feet Per Minute Secondary Air Stripper Tower, 23 feet high x 18 inches diamete r 1 - Carbon Adsorption System, equipped with 2 carbon canisters, 55 gallon capacity each, operated in parallel, controlling exhaust from the primary towe r At Water Supply Well 6 behind Alfa, Area I : 1 - Tankinetics Air Stripping System, 200 gallon per minute capacity, consisting of : feet feet Cubi c high Cubic Feet Per Minute Primary Air Stripper Tower, 3 6 x 36 inches diamete r Feet Per Minute Secondary Air Stripper Tower, 2 8 high x 36 inches diamete r 1 - Carbon Adsorption System, equipped with 8 carbon canisters, 55 gallon capacity each, operated in parallel, controlling exhaust from the primary tower At Water Supply Well 9, Bravo Area, Area I : 2 - Tankinetics Air Stripping Systems, 40 gallon per minute capacity each, with each system consisting of : 1-60 Cubic Feet Per Minute Primary Air Stripper Tower, 27 feet high x 18 inches diamete r Cubic Feet Per Minute Secondary Air Stripper Tower, 23 feet high x 18 inches diamete r 1 - Carbon Adsorption System, equipped with 2 carbon canisters, 55 gallon capacity each, operated in parallel, controlling Page 3. Draft

4 HDMSP exhaust from the primary towe r At Area I Road, Area I : 1 - Tankinetics Air Stripping System, 40 gallon per minute capacity, consisting of : 1-60 Cubic Feet Per Minute Primary Air Stripper Tower, 27 feet high x 18 inches diamete r Cubic Feet Per Minute Secondary Air Stripper Tower, 23 feet high x 18 inches diamete r 1 - Carbon Adsorption System, equipped with 2 carbon canisters, 55 gallon capacity each, operated in parallel, controlling exhaust from the primary towe r At STL IV, Area III : 1 - Tankinetics Air Stripping System, 40 gallon per minute capacity, consisting of : 1-60 Cubic Feet Per Minute Primary Air Stripper Tower, 27 feet high x 18 inches diamete r Cubic Feet Per Minute Secondary Air Stripper Tower, 23 feet high x 18 inches diamete r 1 - Carbon Adsorption System, equipped with 2 carbon canisters, 55 gallon capacity each, operated in parallel, controlling exhaust from the primary towe r Gasoline Dispensing Facility, Area I I Gallon Aboveground Gasoline Storage Tank, with a two point Phase I and a Convault balance Phase II vapor recovery syste m Boilers and Heaters (Approximately 40 units rated at less than 1 MMBTU per hour ) This Permit Has Been Issued Subject To The Following Conditions : 1. Permitted Emissions Tons/Year Pounds/Hou r Reactive Organics Nitrogen Oxides Particulate Matter Sulfur Oxides Carbon Monoxide , The combined emissions from all rocket engine and component testing and auxiliary operations shall not exceed the following annual limits in tons per year : ROC NOx PM SOx CO Tons per Year : Rocket engine and component testing includes all testing at the Alfa and Bravo test areas, APTF, and STL-4. Rocket engine an d Page 4 Draf t

5 HDMSP component testing means the testing of fully assembled rocket engines, partially assembled rocket engines or rocket engine components. Rocket engine components include but are not limite d to gas generators, injectors, and pumps. Auxiliary operations include emissions from gaseous nitrogen flushing operations, propellant blowdowns, the use of afterburners and hydrogen flares, nitrogen tetroxide (NTO) and monomethyl hydrazine ( MMH) venting at STL - 4, and the hypergol flushing operation. In order to comply with this condition, the permittee shall maintain a rolling twelve calendar month total of ROC, NOx, PM, SOx, and CO emissions from the rocket engine and component testing and auxiliary operations. The emissions from each testing operation and auxiliary operation shall be monitored and recorded as specified in the following conditions. This condition, and Condition Nos. 3 to 12 below, are federally - enforceable pursuant to Rule 35. C.2 as adopted by the District on November 12, These conditions were established pursuant to Permit to Operate Application No Rocket Engine and Component Testing and Auxiliary Operations - Emission Factors : The permittee shall quantify emissions from all rocket engine and component testing and auxiliary operations using emission factors determined from source testing or publicl y available, industry and government accepted models ; or the emission factors or emission quantification methods approved by the District listed in the conditions below. 4. Rocket Engine and Component Testing - Recordkeeping : The permittee shall maintain the following records for each rocket engine or component test : date, time, location, type of hardware tested or flushed, volume and /or pounds of propellants used or vented, test duration as applicable, test emission factor, and the resultant emissions. 5. Gaseous Nitrogen Flushing - Monitoring and Recordkeeping : The permittee shall quantify residual fuel ROC emissions from gaseous nitrogen flushing operations at the Alfa Test Area by using an emission factor of lb ROC per flush. This emission factor is derived from an analysis of the flushing of RP - 1 fuel from an RS27 Engine. The permittee shall maintain the following records for each gaseous nitrogen flushing operation : date, time, location, number of flushes, and the resultant emissions. 6. Propellant Blowdowns - Monitoring and Recordkeeping : The permitee shall quantify ROC emissions from propellant blowdowns at the Advanced Propulsion Test Facility ( APTF ) by material balance methods. The permittee shall maintain the following records for each blowdown operation : date, time, location, propellant used, amount of propellant used, test duration, and the resultan t Page 5 Draf t

6 HDMSP emissions. Blowdowns of the following propellants are not permitted : monomethyl hydrazine, nitrogen tetroxide, and inhibited red fuming nitric acid. 7. Afterburners - Monitoring and Recordkeeping : The permittee shall quantify criteria pollutant emissions from propane combustion in the afterburners at APTF using emission factors from the mos t recent version of EPA AP-42 in the units of lb emissions per 1000 gallons propane. The quantity of propane used shall be calculated from the pressure change of the propane cylinder. In the event that hydrogen released from a test must be burned in the afterburners, the permittee shall quantify the additional NOx emissions using an emission factor of pound NOx per pound hydrogen consumed. The permittee shall maintain the following records for each afterburner use : date, time, location, propane cylinder pressure change, propane afterburner emission factors used, amount of propane used, amount of hydrogen consumed in the afterburners (if any), and the resultant emissions. 8. Hydrogen Flaring - Monitoring and Recordkeeping : The permittee shall quantify NOx emissions from hydrogen flaring performed during hydrogen transfer operations associated with rocket engine testing at APTF using an emission factor of pound NOx per pound hydrogen transferred. The permittee shall maintain the following records for each hydrogen flaring operation : date, time, location, initial and final hydrogen storage volumes, pounds hydrogen flared, and the resultant emissions. 9. NTO Venting - Monitoring and Recordkeeping : The permittee shall quantify NOx emissions from NTO venting at Systems Test Laboratory No. 4 (STL-4) by mass balance calculations. The amount of NTO vented shall be determined from the initial and final tank pressures, tank temperature, and ullage. The permittee shall maintain the following records for each NTO venting operation : date, time, location, initial and final tank pressure, tank temperature, tank ullage, amount NTO vented, NOx emission factor (lb NOx / lb NTO vented), and the resultant emissions. 10. MMH Venting - Monitoring and Recordkeeping : The permittee shall quantify ROC emissions from MMH venting controlled by the water tank scrubber at STL-4 by using an emission factor of 0.04 lb ROC per MMH venting operation. The permittee shall maintain the following records for each MMH venting operation : date, time, location, number of MMH venting operations, and the resultant emissions. 11. Hypergol Flushing - Monitoring and Recordkeeping : The permittee shall quantify ROC emissions from hypergol flushing operations by using an emission factor of 1 lb ROC per lb RP-1 used. Th e permittee shall maintain the following records for each hypergol flushing operation : date, time, location, gallons and pounds RP-1 used, and the resultant emissions. Page 6 Draf t

7 HDMSP Rocket Engine and Component Testing and Auxiliary Operations - Monthly Report : The resultant emissions for rocket engine and component testing and auxiliary operations shall be compiled into a monthly report. The report shall include the emissions in tons per year for the previous twelve (12) calendar months. The report shall also include a referenced list of all emission factors determined from source testing or publicly available, industry and government accepted models. This report and all recordkeeping required above for all rocket engine testing and auxiliary operations shall be maintained for five years and be made available to District personnel upon request.. The only liquid propellants that are permitted for use in rocket 13 engine testing are the following : RP-1, JP-8, JP-10, ethanol, methanol, hydrogen, monomethyl hydrazine, oxygen, hydrogen peroxide, nitrogen tetroxide with a maximum of 25% nitrogen oxide, and inhibited red fuming nitric acid. No solid rocket engine propellants may be used at the facility. This condition does not limit the materials that may be used in the rocket engine ignitors at the facility. 14. All flushing operations at Alfa Test Area shall use the gaseous nitrogen flushing system. All hypergol flushing operations shall be done using RP-1. All other flushing of aerospace components shall comply with the applicable requirements of Rule 74.13, "Aerospace Assembly and Component Manufacturing". Specifically, the ROC composite partial pressure of the solvent used for flushing operations shall be no greater than 25 mm Hg at 20 degrees Celsius The Monomethyl Hydrazine (MMH) Venting System shall only vent MMH through the 20' high x 7' diameter water tank as a scrubber. The number of MMH ventings shall not exceed 170 ventings per rolling twelve calendar month period as demonstrated by the monitoring and recordkeeping requirements of Condition No. 10 above.. No rocket engine testing or component testing or auxiliary operations shall take place at the existing Coca Area. 17. Remote Reservoir Cold Cleaners : The ROC emissions from the use of isopropyl alcohol and cyclohexane in the remote reservoir cold cleaners in Building Nos. 301 and 324 shall not exceed 3,328.5 pounds per year. These remote reservoir cold cleaners are subjec t it to Rule 74.6, "Surface Cleaning and Degreasing. In order to comply with this condition, the permittee shall maintain monthly records of isopropyl alcohol and cyclohexane consumption. The consumption of these solvents in pounds of ROC shall be considered to be equal to the ROC emissions. Solvent consumption does not include solvent that is recycled or properly disposed of. The monthly records shall be summed for the previous twelve (12) calendar months. Solvent consumption for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. Page 7 Draf t

8 HDMSP Cold Cleaners : The ROC emissions from the use of Turco 6802 solvent and Axarel 56 solvent in the cold cleaners in Building No. 984 shall not exceed pounds per year. These cold cleaners are subject to Rule 74. 6, "Surface Cleaning and Degreasing. " In order to comply with this condition, the permittee shall maintain monthly records of Turco 6802 solvent and Axarel 56 solvent consumption. The consumption of these solvents in pounds of ROC shall be considered to be equal to the ROC emissions. Solvent consumption does not include solvent that is recycled or properly disposed of. The monthly records shall be summed for the previous twelve (12) calendar months. Solvent consumption for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. 19. Solvent Cleaning Operations : The ROC emissions from the use of solvents for cleaning and degreasing purposes shall not exceed 2, pounds per year. This includes all ROC solvents used outside of the remote reservoir cold cleaners and cold cleaners, including substrate surface preparation cleaning prior to surface coating and painting. This includes solvent cleaning subject Rule 74.6, "Surface Cleaning and Degreasing " ; Rule 74.12, " Surface Coating of Metal Parts and Products " ; and Rule 74.13, "Aerospace Assembly and Component Manufacturing". In order to comply with this condition, the permittee shall maintain monthly records of ROC solvent consumption. The consumption of these solvents in pounds of ROC shall be considered to be equal to the ROC emissions. Solvent consumption does not include solvent that is recycled or properly disposed of. The monthly records shall be summed for the previous twelve (12) calendar months. Solvent consumption for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. 20. Surface Coating Operations : The ROC emissions from the use of paints, coatings, and solvents used for thinning, stripping, and cleanup, including the cleaning of application equipment, shall not exceed 11, pounds per year. This includes surface coating operations subject to Rule 74. 2, "Architectural Coatings" ; Rule 74.12, " Surface Coating of Metal Parts and Products " ; and Rule 74.13, " Aerospace Assembly and Component Manufacturing". In order to comply with this condition, the permittee shall maintain monthly records of paint, coating, and solvent consumption. The consumption of these materials in pounds of ROC shall be considered to be equal to the ROC emissions. Consumption does not include material that is recycled or properly disposed of. The monthly records shall be summed for the previous twelve (12) calendar months. Consumption totals for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. Page 8 Draft

9 HDMSP Adhesive and Sealant Operations : The ROC emissions from the use of adhesives, adhesive primers, sealants, substrate surface preparation materials, and solvents used for thinning, stripping, and cleanup, including the cleaning of application equipment, shall not exceed 1,581.0 pounds per year. This includes adhesive and sealant operations subject to Rule 74.13, "Aerospace Assembly and Component Manufacturing", and Rule 74.20, "Adhesives and Sealants". In order to comply with this condition, the permittee shall maintain monthly records the consumption of adhesives, adhesive primers, sealants, substrate surface preparation materials, and solvents used for thinning, stripping, and cleanup. The consumption of these materials in pounds of ROC shall be considered to be equal to the ROC emissions. Consumption does not include material that is recycled or properly disposed of. The monthly records shall be summed for the previous twelve (12) calendar months. Consumption totals for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. 22. The cold cleaners shall comply with all applicable provisions of Rule 74.6, "Surface Cleaning and Degreasing." This condition does not apply to the remote reservoir cold cleaners. This includes, but is not limited to, the following requirements : a) Each cold cleaner shall be equipped with a freeboard height of at least six inches. This freeboard height requirement is based on the use of low volatility solvent. Low volatility solvent is defined as unheated solvent with an ROC composite partia l pressure of 2 mm Hg or less at 20 degrees Celsius. (74.6.C.l.c) b) Each cold cleaner shall be equipped with a drying rack suspended above the solvent, or other facility for draining cleaned parts such that the drained solvent is returned to the cleaner. (74.6.C.l.a ) c) Each cold cleaner shall be equipped with a cover which prevents the solvent from evaporating when not processing work in the cold cleaner. The cover must be designed so that it can be easily operated with one hand. Covers for larger cold cleaners may require mechanical assistance. (74.6.C.l.b and EPA CTG Guidelines ) d) Each, cold cleaner shall be equipped with a permanent conspicuous label or sign summarizing the applicable operating requirements appropriate for cold cleaners. (74.6.C.l.f ) e) Solvent shall not leak from any portion of the cold cleaners. (74.6.B.3.a ) f) The operator shall drain cleaned parts of all solvent until dripping ceases to ensure that the drained solvent is returne d Page 9 Draf t

10 HDMSP to the cold cleaner. ( 74.6.D.1 ) g) Sovent agitation, where necessary, shall be achieved using pump recirculation, a mixer, or ultrasonics. Air agitation shall not be used. ( 74.6.D..2 ) h) If a solvent flow is utilized, only a solid fluid stream (not a fine, atomized, or shower type spray ) shall be used. ( 74.6.D.3 ) 23. The remote reservoir cold cleaners shall comply with all applicable provisions of Rule 74. 6, "Surface Cleaning and Degreasing." This includes, but not limited to, the following requirements : a) Each remote reservoir cold cleaner shall be equipped with a freeboard height of at least six inches. ( 74.6.C.2.d ) b) Each remote reservoir cold cleaner shall be equipped with a sinklike work area which is sloped sufficiently towards the drain to preclude pooling of solvent. ( 74.6.C.2.b ) c) Each remote reservoir cold cleaner shall be equipped with a single drain hole, less than 15.5 square inches in area, for the solvent to flow from the sink into the enclosed reservoir. (74.6.C.2.c ) d) Each remote reservoir cold cleaner shall be equipped with a cover for the drain when no work is being processed in the remote reservoir cold cleaner. ( 74.6.C.2.e ) e) Each remote reservoir cold cleaner shall be equipped with a permanent conspicuous label or sign summarizing the applicable operating requirements appropriate for the remote reservoir cold cleaner. ( 74.6.C.2.a ) f) Solvent shall not leak from any portion of the cold cleaners. (74.6.B.3.a ) g) The operator shall drain cleaned parts of all solvent until dripping ceases to ensure that the drained solvent is returned to the cold cleaner. (74.6.D.1 ) h) Solvent agitation, where necessary, shall be achieved using pump recirculation, a mixer, or ultrasonics. Air agitation shall not be used. ( 74.6.D.2 ) i) If a solvent flow is utilized, only a solid fluid stream (not a fine, atomized, or shower type spray ) shall be used. ( 74.6.D.3 ) 24. Solvent cleaning operations shall comply with all applicable provisions of Rule 74.6, "Surface Cleaning and Degreasing." This includes, but is not limited to, the following requirements : a) Solvents used for cleanup shall have an ROC composite partia l Page 10 Draft

11 HDMSP pressure of less than 33 mm Hg at 20 degrees Celsius and an ROC content of less than 900 grams per liter as applied. ( 74.6.B.1) b) Solvents used for cleaning electronic components, electria l apparatas components, medical devices, or aerospace components shall have an ROC composite partial pressure of 33 mm Hg at 20 degrees Celsius or less and shall have an ROC content of 900 grams per liter or less. The use of isopropyl alcohol complies with this requirement. ( 74.6.B.1 ) c) Solvents used for solvent cleaning other than operations listed in a) and b ), above, shall have a ROC content of 25 gramps per liter or less. ( 74.6.B.1 ) d) The permittee shall use one of the cleaning devices or methods listed in Rule B.2. This includes wipe cleaning and non-atomized solvent flow, dip, or flush methods where pooling is prevented or drained. ( 74.6.B.2 ) e) The permittee shall not allow liquid cleaning solvent to leak from any equipment or container. ( 74.6.B.3.a ) f) All ROC - containing solvents shall be stored in non - absorbent, non-leaking containers which shall be kept closed at all times except when filling or emptying. ( 74.6.B.4.a ) g) Waste solvent and waste solvent residues shall be disposed of in a manner conforming with Division 20, Chapter 6.5 of the California Health and Safety Code. ( 74.6.B.4.b ) h) The permittee shall maintain a current material list showing each ROC containing material used in solvent cleaning activities as detailed in Rule F. The list shall summarize the solvent name and manufacturer ' s description, all intended uses of the solvent at the facility, the ROC content ( and ROC composite partial pressure if applicable ) of the solvent, and the mix ratio if the solvent is a mix of materials blended by the operator. ( 74.6.F ) Rule 74.6 shall not apply to cleaning materials using Clean Air Solvent, or a solvent with an ROC content no more than 25 grams per liter as applied, the use of nonrefillable aerosol cleaning products, or to the use of organic solvents for janitorial cleaning. Rule B.1 shall not apply to the cleaning of aerospace assembly and subassembly surfaces that are exposed to strong oxidizers or reducers such as nitrogen tetroxide, liquid oxygen or hydrazine. 25. The manufacturing, assembling, coating, masking, bonding, paint stripping, and surface cleaning of aerospace components and the cleanup of equipment associated with these operations shall compl y Page 11 Draf t

12 HDMSP with all applicable provisions of Rule 74.13, " Aerospace Assembly and Component Manufacturing ". An aerospace component is defined as any raw material, partial or completed fabricated part, assembly of parts, or completed unit of any aircraft, helicopter, missile, or space vehicle, including mockups and prototypes. This includes, but is not limited to, the following requirements : a) The ROC content of coatings and adhesives applied to aerospace components shall not exceed the applicable limits in Rule B.1 in the units of pounds per gallon ( or grams per liter) of coating or adhesive, less water and exempt organic compounds. (74.13.B.1 ) b) All coatings shall be applied through the use of hand application methods, high volume low pressure (HVLP ) spray guns, electrostatic spray guns, or any other method allowed by the rule. ( B.5 ) c) Solvents used for surface cleaning, clean - up, or engine gas path cleaning shall have an ROC content of less than 200 grams per liter of material as applied, or, shall have an ROC composite partial pressure of less than or equal to 25 mmhg at a temperature of 20 degrees Celsius. Isopropyl alcohol (IPA) diluted with water at a ratio of 1 part water (or greater) to 9 parts IPA ( or less ) complies with the 25 mmhg requirement. Surface cleaning is defined as any cleaning outside of a degreaser, including but not limited to wipe cleaning and equipment flushing. This requirement does not apply to the cleaning of aerospace assembly and subassembly surfaces that are exposed to strong oxidizers or reducers such as nitrogen tetroxide, liquid oxygen, or hydrazine. ( B.2.a ) Page 12 d) An enclosed gun washer or low emission spray gun cleaner shall be properly used when using materials containing ROC for spray equipment cleaning. ( B.2.b.1 ) e) The ROC composite partial pressure of organic solvent used for the cleaning of coating application equipment shall be less than 45 mmhg at a temperature of 20 degrees Celsius. ( B.2.b.2 ) f) Coating strippers shall have an ROC content of less than 300 grams per liter, as applied, or, shall have an ROC composite partial pressure of less than or equal to 9.5 mmhg at a temperature of 20 degrees Celsius. A stripper is a volatile liquid applied to remove : a maskant for chemical processing, cured or dried paint, cured or dried paint residue, or a temporary protective coating. ( B.3 ) g) Records of the name, type, and amounts of coatings, adhesives, strippers and cleaning materials used shall be maintained as detailed in Rule D. For coatings and adhesives, this includes the ROC content and for cleaning materials an d strippers, this includes the ROC content and ROC composit e Draft

13 HDMSP partial pressure as applicable. (74.13.D ) 26. The metal parts and products surface coating operations shall comply with all applicable provisions of Rule 74.12, "Surface Coating of Metal Parts and Products". A metal part or product is defined as any component or complete unit fabricated from metal, not including stationary structures or their appurtenances, marine vessel exteriors, aerospace vehicles and components, and motor vehicles and mobile equipment. This includes, but is not limited to, the following requirements : a) The ROC content of general (non-specialty) air-dried coatings shall not exceed 2.8 pounds per gallon of coating (340 grams per liter) as applied, less water and exempt organic compounds. (74.12.B.1 ) b) The ROC content of extreme performance and heat resistant air-dried specialty coatings shall not exceed 3.5 pounds per gallon of coating (420 grams per liter) as applied, less water and exempt organic compounds. Other specialty coatings shall comply with Rule B.1 as applicable. (74.12.B.1 ) c) All coatings shall be applied through the use of hand application methods, high volume low pressure (HVLP) spray guns, electrostatic spray guns, or any other method allowed by the rule. (74.12.B.3 ) d) The ROC content of material used for substrate surface cleaning shall not exceed 70 grams per liter of material. (74.12.B.4.a) e) The ROC composite partial pressure of organic solvent used fo r cleanup, including spray equipment cleaning, shall be less than 45 mmhg at 20 degrees Celsius. (74.12.B.4.b.2 ) f) An enclosed gun washer or low emission spray gun cleaner shall be properly used when using organic solvent for spray equipment cleaning. (74.12.B.4.b.1 ) g) Records of the name, type, and amounts of coatings and cleaning materials used shall be maintained as detailed in Rule D. For coatings, this includes the ROC content and for cleaning materials this includes the ROC content and ROC composite partial pressure as applicable. (74.12.D ) 27. The architectural surface coating operations shall comply with all applicable provisions of Rule 74.2, "Architectural Coatings". An architectural coating is a coating to be applied to stationary structures or their appurtenances at the site of installation, to portable buildings at the site of installation, to pavements, or to curbs. This includes, but is not limited to, the following requirements : a) The volatile organic compound (VOC) content of flat coatings, Page 13 Draft

14 HDMSP nonflat coatings, and nonflat high gloss coatings, except specialty coatings, shall not exceed 250 grams per liter of coating excluding water, exempt organic compounds and any colorant added to tint bases. (74.2.B.1 ) b) Effective January 1, 2003, the VOC content of flat coatings shall not exceed 100 grams per liter of coating excluding water, exempt organic compounds and any colorant added to tint bases. (74.2.B.1 ) c) Effective January 1, 2003, the VOC content of nonflat coatings shall not exceed 150 grams per liter of coating excluding water, exempt organic compounds and any colorant added to tint bases. (74.2.B.1 ) d) The VOC content of specialty architectural coatings shall not exceed the VOC limits in the Table of Standards in Rule Specifically, the VOC content of industrial maintenance coatings shall not exceed 250 grams per liter of coating excluding water, exempt organic compounds and any colorant added to tint bases. (74.2.B.1 ) e) Records of the name, type, VOC content, and amounts of architectural coatings used shall be maintained. 28. The adhesive and sealant operations shall comply with all applicable provisions of Rule 74.20, "Adhesives and Sealants". This includes, but is not limited to, the following requirements : a) The ROC content of adhesives, sealants, and primers shall no t exceed the applicable limits in Rules B.1 and B.2 in the units of grams per liter of adhesive, sealant, or primer less water and exempt organic compounds. (74.20.B.1 and B.2 ) b) The ROC content of materials used for substrate surface preparation shall not exceed 70 grams per liter of material. This limit does not apply to single ply roof membrane installation where the ROC composite partial pressure shall not exceed 45 mm of Hg at 20 degrees Celsius. (74.20.B.4 ) c) ROC-containing materials used for the removal of adhesives or coatings from surfaces, other than spray application equipment, shall have a ROC composite partial pressure of less than 45 mm of Hg at 20 degrees Celsius. (74.20.B.5 ) d) Cleaning of adhesive spray application equipment shall comply with the requirments of Rule B.7. If an enclosed gun washer or low emission spray gun cleaner is used, the ROC composite partial pressure of organic solvents used shall be less than 45 mm Hg at 20 degrees Celsius. If an enclosed gun washer or low emission spray gun cleaner is not used then a solvent containing no more than 70 grams ROC per liter o f Page 14 Draf t

15 HDMSP material shall be used for cleaning, flushing or soaking of filters, flushing lines, pipes, pumps, and other parts of the application equipment. Parts containing dried adhesive may be soaked in an organic solvent as long as the ROC composit e partial pressure of the solvent is 9.5 mm of Hg or less at 20 degrees Celsius. ( B.7 ) e) Adhesive strippers shall have an ROC composite partial pressure of 9.5 mm Hg or less at 20 degrees Celsius. ( B.9 ) f) Primers, sealants, or adhesives containing methylene chloride or 1,1,1- trichloroethane shall not be used. This requirement does not apply to adhesives containing methylene chloride used to plastic weld plastic substrates as listed in Rule B.10. (74.20.B.10 ) g) Records of the name, type, and amounts of adhesives, sealants, primers, strippers, and solvents used shall be maintained as detailed in Rule D. For adhesives, sealants, and primers this includes the ROC content and for strippers and solvents this includes the ROC content and ROC composite partial pressure as applicable. ( D ) These requirements do not apply to the assembling, manufacturing and repairing of aerospace components subject to Rule 74.13, "Aerospace Assembly and Component Manufacturing ", excluding manufacturing of aircraft tires. ( C.2.a ) 29. Paint Spray Booth Nos. 1 and 2 shall not be operated unless all exhaust air passes through the filter media. Gauges shall be installed and maintained across the first and third filter stages of Booth No. 1 to indicate the static pressure differential across the exhaust filters. A gauge shall be installed at Booth No. 2 to indicate the static pressure differential across the exhaust filter system. While Booth No. 1 is in operation, the pressure differentia l across the first filter stage shall not exceed 0.25 inches of water and the pressure differential across the third filter stage shall not exceed 1.5 inches of water. While Booth No. 2 is in operation, the pressure differential across the filter system shall not exceed 0.5 inches of water column. 30. Annual hours of operation for the portable engines and emergency engines shall not exceed the following limits : a) 199 hours of operation for each of the two Generac Model GT HP engines for all locations combined at the Santa Susana Field Laboratory. b) 197 hours of operation combined for the Generac Model 64238GT85 96 HP engine for all locations at the Santa Susana Field Laboratory. Page 15 Draft

16 HDMSP c) 197 hours of operation combined for the three Generac engine s at each of Building Nos. 543, 600, and 760. These hours are not in addition to the hours specified in (a) and (b) above, but are a further restriction of the hours of operation at specific locations. d) 200 hours of operation combined for the three Generac engines within the portion of Service Area I north of Building No These hours are not in addition to the hours specified in (a) and (b ) above, but are a further restriction of the hours of operation for a specific area. e) 200 hours of operation combined for the John Deere Model 3179D 58 HP engine and the Deutz Model F3L HP engine. f) 200 hours of operation for the combined use of the six diesel engines used for emergency electrical generation only. Limits applicable to the Generac engines ensure compliance with APCD Rule 51, "Nuisance ", based on a health risk assessment conducted under Permit to Operate Application No Pursuant to Rule D.2, each engine is exempt from Rule 74.9, "Stationary Internal Combustion Engines", if the unit is operated less than 200 hours per calendar year. In order to comply with this condition, the permittee shall maintain monthly records of hours of operation for each engine. These records shall be compiled into a monthly summary. The monthly usage records shall be summed for the previous 12 calendar months. Total hours of operation for any of these rolling 12 calendar month periods in excess of the specified limits shall be considered a violation of this condition. This condition is federally - enforceable, pursuant to Rule 35.C.2 as adopted by the District on November 12, This condition was established pursuant to Permit to Operate Application No All diesel fuel consumed shall contain 0.05 percent sulfur, by weight, or less. In order to comply with this condition, for each fuel delivery, the permittee shall obtain documents certifying compliance, or shall test the sulfur content of a representative sample of the fuel. This requirement does not apply to use of ARB-certified diesel fuel. Permittee shall maintain records of the diesel fuel sulfur content or the use of ARB-certified diesel fuel. These records shall be maintained for five years and shall be mad e available to APCD upon request. 32. The following only : diesel engines shall be used for emergency purposes Page 16 Draf t

17 HDMSP VCAPC D Permit To Operate Number BHP G.M. Diesel, Model DASE , M BHP Caterpillar, Serial 1M12811]., N BHP Caterpillar, Model T (D50P2), BN BHP Caterpillar, Serial 29A00587, Z BHP Generac, Model 99A , BN BHP Onan, Model RDJF, M Pursuant to Rule 23.D.7, an emergency engine is either a portable engine used for emergency purposes ; an engine that is used only when electrical power line or natural gas service fails ; or an engine used for the emergency pumping of water for either fire protection or flood relief. These engines have been permitted pursuant to Rule 35, "Elective Emission Limits". 33. The following records shall be maintained for the engines : a) Date, duration (hours), and location of operation for each portable engine ; b) Twelve month rolling records of hours of operation for each portable engine ; c) Twelve month rolling records of hours of operation of each of the three Generac engines at each of Building Nos. 543, 600, and 760, and the the portion of Service Area I north of Building No. 543 ; d) Twelve month rolling records of hours of operation for the combined use of the emergency engines. These records shall be maintained at the facility for the previous five years and shall be made available to District personnel upon request. This permit condition is federally-enforceable pursuant to Rule 35.C.2 as adopted by the District on November 12, The Ground Water Remediation Operations shall be operated in compliance with the following conditions : a) The Reactive Organic Compound (ROC) concentration in the exhaust from each primary tower carbon adsorption system shall not exceed 6 ppmv, as methane. The ROC concentration in the exhaust from each secondary tower shall not exceed 1 ppmv, as methane. Additional controls or operation modifications will be required if these concentrations are exceeded. b) ROC concentration measurements shall be conducted and recorded once per week of operation at the exhaust of each carbon adsorption system and at the exhaust of each secondary tower. The frequency of sampling may be adjusted based on review of the required sampling records and determination of the carbon adsorption system breakthrough periods. Written approval from the District in the form of a permit application shall be obtained prior to modifying the sampling frequency. Tests shal l Page 17 Draf t

18 HDMSP be conducted using a portable analyzer approved by the District. c) The maximum exhaust flow rate from each tower shall not exceed the values specified in the above equipment description. The exhaust flow rate in cubic feet per minute from each tower shall be established by a mechanical setting based on the water flow rate to the tower. If a change in water flow rate to any tower greater than 25~ occurs, the mechanical setting shall be redetermined and adjusted to insure that the exhaust flow rate does not exceed the specified level. A description of the method used to determine the mechanical setting has been submitted to the District and approved. This method is described in a letter dated November 14, 1990, Reference number 90RC Alternatively, the exhaust flow rate in cubic feet per minute from each tower may be calculated based on velocity pressure measurements. The measurements shall be recorded from a Pitot tube magnehelix gauge in inches of water. The permittee shall establish and maintain data relating the velocity pressure measurements to flow rate. d) All spent carbon must be disposed at a Class I Hazardous Waste Facility or reclaimed by a certified regeneration facility. e) Samples shall be taken on a monthly basis of the influent groundwater, the primary tower effluent water, and the secondary tower effluent water from each air stripping system. These samples shall be analyzed by a certified independent laboratory for ROC. f) The permittee shall maintain records of sample analyses, results of ROC exhaust concentrations, and air and water flow rates for each air stripping system. Records of mechanical settings used to limit air flow rates or velocity pressure measurements may be substituted for the required air flow rate records. These records shall be maintained for a period of five years and be made available to District personnel upon request The permitted emissions for the gasoline dispensing facility at the Santa Susana Field Laboratory are based on a gasoline throughput of 32,000 gallon per year. Either a higher or a lower throughput may be requested the next time the permit is renewed.. The gasoline dispensing facility shall comply with all applicable provisions of Rule 70, "Storage and Transfer of Gasoline". This includes, but is not limited to, the following requirements : Page 18 a) All open vent pipes on gasoline storage tanks shall be equipped with a California Air Resources Board ( CARS ) certified pressure -vacuum relief valve. ( 70.B.6 ) b) All gasoline storage tanks shall be equipped with a permanently installed submerged fill pipe which extends to within six inches of the tank bottom. ( 70.B.1 ) Draft

19 HDMSP c) The permittee shall use a permanently installed CARB certified two point Phase I vapor recovery system when transferring gasoline from a delivery vessel to a gasoline storage tank. (70.B.2 ) d) The permittee shall use a permanently installed CARB certified balance Phase II vapor recovery system when transferring gasoline from a gasoline storage tank into any motor vehicle fuel container with more than 5 gallons capacity. ( 70.B.9 ) e) The permittee shall demonstrate compliance with the GARB static pressure performance standards for the Phase II vapor recovery system at least once every 12 months using CARB Test Procedure TP b. (70. H.1.c and 70.H.8 ) f) The permittee shall demonstrate compliance with the GARB dynamic pressure performance standards for the Phase II vapor recovery system at least once every 4 years using GARB Test Procedure TP This testing requirement shall not apply to an aboveground gasoline storage tank with a dispenser mounted directly to the tank as detailed in Rule 70. H.2. (70. H.2.b ) 37. Combined natural gas consumption for all boilers and heaters at the Santa Susana Field Laboratory shall not exceed million cubic feet ( MMCF ) per year. In order to demonstrate compliance with this condition, the permittee shall maintain monthly records of fuel consumption as measured by the main facility gas meter. The monthly records shall be summed for the previous 12 calendar months. Fuel consumption totals for any of these rolling 12 calendar month periods in excess of the specified limit shall be considered a violation of this condition. These records shall be maintained for five years and shall be made available to District personnel upon request. These boilers and heaters that have heat input ratings of less than 1 MMBTU/Hr are permitted pursuant to Rule 35, " Elective Emission Limits ". This condition is federally - enforceable, pursuant to Rule 35. C.2 as adopted by the District on November 12, This condition was established pursuant to Permit to Operate Application No Within 10 days after receipt of this permit, the permittee may petition the Hearing Board to review any new or modified condition ( Rule 22). This permit, or a copy, shall be posted reasonably close to the subject equipment and shall be accessible to inspection personnel ( Rule 19). This permit is not transferable from one location to another unless the equipment is specifically listed as being portable ( Rule 20). Page 19 Draf t

20 HDMSP This Permit to Operate shall not be construed to allow any emission unit to operate in violation of any state or federal emission standard or any rule of the District. For : Karl E. Krause, Manager Michael Villegas Engineering Division Air Pollution Control Office r Page 20 Draf t