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1 Facility Name: US Army Signal Center and Fort Gordon City: Fort Gordon County: Richmond AIRS #: Application #: TV Date Application Received: September 10, 2014 Date Application Deemed Administratively Complete: September 10, 2014 Date of Draft Permit: Permit No: V-03-0 Program Review Engineers Review Managers SSPP Wei-Wei Qiu Hamid Yavari ISMP Dave Sheffield Dave Sheffield SSCP Don Holder Michael Odom Toxics Don Holder Michael Odom Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 operating permit. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality Act, O.C.G.A , et seq. and (2) Georgia Rules for Air Quality Control, Chapter , and (3) Title V of the Clean Air Act Amendments of Section (10) of the Georgia Rules for Air Quality Control incorporates requirements of Part 70 of Chapter I of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air requirements applicable to US Army Signal Center and Fort Gordon and to provide practical methods for determining compliance with these requirements. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. It initially describes the facility receiving the permit, the applicable requirements and their significance, and the methods for determining compliance with those applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information only. It has no legal standing. Any revisions made to the permit in response to comments received during the public participation and EPA review process will be described in an addendum to this narrative. Printed: April 13, 2016 Page 1 of 35

2 I. Facility Description A. Facility Identification 1. Facility Name: US Army Signal Center and Fort Gordon 2. Parent/Holding Company Name: United States Army 3. Previous and/or Other Name(s) 4. Facility Location Fort Gordon is located in Richmond County. The nearest town to Fort Gordon is Augusta, Georgia. It borders Fort Gordon on the east side. 5. Attainment or Non-attainment Area Location B. Site Determination The facility is located in an attainment area for all criteria pollutants. There are no other facilities which could possibly be contiguous or adjacent and under common control. C. Existing Permits Table 1 below lists all current permits (including Part 71 permits), as amended, issued to the facility. Based on a comparative review of Item 19 in Section 1.10 of the Title V application and the "Permit" file(s) on the facility found in the Air Branch office, comments are listed in Table 2 below." Table 1: List of Current Permits as Amended Permit Number and/or Purpose of Issuance V-02-0 Date of Issuance and Date of Amendments (if any) Comments Yes No D. Process Description Table 2: Comments on Specific Permits Permit Number n/a Comments none Printed: April 13, 2016 Page 2 of 35

3 1. SIC Codes(s): 9711 The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for purposes pursuant to the Georgia Air Quality Act and related administrative purposes only and are not intended to be used for any other purpose. Assignment of SIC Codes by EPD's Air Protection Branch for these purposes does not prohibit the facility from using these or different SIC Codes for other regulatory and non-regulatory purposes. Should the reference(s) to SIC Code(s) in any narratives or narrative addendum previously issued for the Title V permit for this facility conflict with the revised language herein, the language herein shall control; provided, however, language in previously issued narratives that does not expressly reference SIC Code(s) shall not be affected. 2. Description of Product(s) Fort Gordon is a military installation with a primary mission of training and supporting signal soldiers. The facility does not produce hard good products on an ongoing basis, as would be generated in a manufacturing facility, but on occasion produces products to support specific missions of the Army. 3. Overall Facility Process Description Fort Gordon is the home of the United States Signal Corps and Signal Center. The main component of the post is the Advanced Individual Training for Signal Corps military occupational specialties. The post is home to a multitude of active-duty tenant units. The Dwight D. Eisenhower Army Medical Center, a 100-bed hospital, is also located on the base. Fort Gordon has approximately 30,000 military and civilian employees. Majority of the emission sources at Fort Gordon are equipment such as natural gas firedboilers and air condition units used for heating and cooling buildings and housing to support the base mission. The main support services for the base also contain emission sources, mostly related to maintaining and making available material, equipment and vehicles to army personnel. These include vehicle maintenance and support equipment such as fueling stations, storage tanks, painting booths and parts washers. Because of the strategic mission of this base, the facility requires significant emergency power. This is supplied by over 60 generators driven by stationary reciprocating compression or spark ignition internal combustion engines (CI or SI RICEs) with various power ratings. Among them, 10 diesel engines/generators/ci RICES are also used for peak shaving. The compression and spark ignition reciprocal internal combustion engines driving the generators combust fossil fuel and emit combustion byproducts, and are considered as emission sources of air pollutants. 4. Overall Process Flow Diagram (optional) The facility provided a process flow diagram in their Title V permit application. Printed: April 13, 2016 Page 3 of 35

4 E. Regulatory Status 1. PSD/NSR Fort Gordon has the potential to emit nitrogen oxides (NO x ), carbon monoxide (CO) and sulfur dioxide (SO 2 ) at a rate in excess of 100 tons per year. Since it is a 28 source category facility for having total fossil fuel fired boiler capacity greater than 250 MMBtu/hr, Fort Gordon is considered a major source under the pertinent PSD/NSR regulations and is subject to PSD/NSR review for modifications in which any pollutant increase is greater than the corresponding the significance level under PSD/NSR rules. Fort Gordon has avoided PSD/NSR review for facility modifications in the past by accepting the following emission limits: Caps taken in order to limit the production of VOC: Emission Units P006 and P007 limited below 39.0 tons per year (tpy) of VOC. Caps taken in order to limit the production of NO x : Emission Unit Group 1 (G001) limited to 2,039,200 kwh per 12 month period; effectively limiting NO x below tons per year. Emission Unit Group 2 (G002 G007) limited to 2,331,000 kwh per 12 month period; effectively limiting NO x below tons per year. Emission Unit Group 3 (G008 G010) limited to 3,118,500 kwh per 12 month period; effectively limiting NO x below tons per year. 1 Fuel oil fired in Emission Unit Group 4 (B003 B005) is limited to 300,000 gallons per 12 month period and firing natural gas is limited to 125,000,000 cubic feet per 12 month period. 1 Emission Unit Group 8 (B006 B008, and G011) limited below 39.9 tons per year of NO x. Caps taken in order to limit the production of SO 2 : Fuel fired in boilers listed in Table 1 (Emission Units B001 B008) has been limited to containing less than 0.5% sulfur by weight. Fuel fired in peaking engines listed in Table 1 (Emission Units G001 - G010) has been limited to containing less than 0.05% sulfur by weight. 1 These fuel oil and natural gas limits are part of the netting analysis allowing the Group 3 engines to emit more than 40tpy NOx. The total unlimited potential from these boilers is 31 tpy NO x. After the limits are applied the emissions are limited to below 2.9 tpy NO x when firing fuel oil and below 6.24 tpy NO x when firing natural gas. Printed: April 13, 2016 Page 4 of 35

5 Emission Unit Group 8 (B006 B008, and G011) limited below 39.9 tons per year of SO 2. Fuel fired in backup engine generator G011 has been limited to containing less than 0.5% sulfur by weight. 2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status Pollutant Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the pollutant? Major Source Status Major Source Requesting SM Status Non-Major Source Status PM PM 10 PM 2.5 SO 2 VOC NO x CO TRS n/a H 2 S n/a Individual HAP Total HAPs Total GHGs 3. MACT Standards The Title V permit renew application No indicated that this facility as a whole had potential to emit no greater than 10 tons per year of any individual hazardous air pollutants (HAP) and no greater than 25 tons per year of all HAPs combined. These potential HAP emission rates were confirmed by subsequent HAP emission estimations performed during the review of the permit application No Among all the HAP emissions from the facility, combined potential hexane emissions from all the boilers and water and air heaters are the highest, approximately 5.01 tons per year, followed by aldehydes, formaldehyde and benzene emitted from stationary RICEs, approximately 1.24, 0.30 and 0.08 tons per year respectively. Potential HAP emissions from use of paintings, adhesives and solvents are insignificant due to the 100 gallon per month usage limit and the use of low or no VOC/HAP containing materials and chemicals. Consequently, this facility is an area source for HAP emissions under 40 CRR Part 63 NESHAP. As an area source under 40 CFR Part 63 NESHAP, all the existing stationary reciprocating compression ignition (CI) or spark ignition (SI) internal combustion engine Printed: April 13, 2016 Page 5 of 35

6 (RICE) constructed or reconstructed before June 12, 2006 are subject to the applicable requirements under 40 CFR 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. All the new or reconstructed stationary CI and SI RICEs whose construction or reconstruction was commenced on or after June 12, 2006 shall meet the requirements of 40 CFR Part 63, Subpart ZZZZ by meeting the applicable requirements of 40 CFR Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, or 40 CFR Part 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. Per 40 CFR (a)(2)(iii), (a)(3)(iii) and (c)(1).no further requirements apply for such engines under 40 CFR Part 63, Subpart ZZZZ. All the new, reconstructed or existing stationary SI or RI RICEs at this facility are used to drive generators either for peak shaving or for emergency electricity generating, except one for fire pump and three for wastewater pumps. 40 CFR Part 63, Subpart ZZZZ has different emission, testing, monitoring, compliance, record keeping, operating practice and/or notification requirements for the RICEs involved, depending mainly on the feature, capacity, operation and/or compliance status of each RICE. However, since this military base is considered an institutional establishment, per 40 CFR (f) and (a)(1)(iii), any existing emergency stationary CI RICE at this site is not subject to 40 CFR, Part 63, Subpart ZZZZ provided that the CI RICE is operated exclusively for the emergency situations and maintenance checks and readiness testing, as specified in Condition According to the Permittee, all the existing emergency CI RICEs at Fort Gordon are not obligated and therefore will not be operated for any emergency demand response or in non-emergency situations as specified in 40 CFR (f). Therefore, they are not subject to Subpart ZZZZ per 40 CFR (f)(3). Since those existing CI RICEs are not subject to 40 CFR Part 60, Subpart IIII, their operation shall be regulated by pertinent SIP rules. This facility was initially subject to 40 CFR 63, Subpart T, National Emission Standards for Halogenated Solvent Cleaning. However, since the facility no longer uses the halogenated solvents that are subject to this NESHAP standard, it is no longer subject to the requirements of 40 CFR Part 63, Subpart T. This facility was potentially subject to 40 CFR 63, Subpart JJ, National Emission Standards for Wood Furniture Manufacturing Operations, and chose to remain exempt by qualifying to be an incidental wood manufacturer. As per 40 CFR63.801, facilities that use no more than 100 gallons per month of finishing material and adhesives in the manufacture of wood furniture or components are considered to be incidental wood furniture manufacturers. Such facilities are not subject to any of the provisions (including emission limits) of the MACT Subpart JJ. To qualify for this exemption, the facility must demonstrate this low usage on a continuous basis. As required by the current Title V permit, the facility has been demonstrating compliance with the low usage limit by maintaining the usage records to show that the facility is using less than or equal to 100 gallons per month of finishing material or adhesives in the wood furniture or components manufacturing such as the paint spray operations/booths listed in the permit. Printed: April 13, 2016 Page 6 of 35

7 All the boilers at this facility were constructed or reconstructed on or before June 4, 2010, and therefore are considered as existing affected sources under 40 CFR 63, Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Source. of the boilers will be subject to 40 CFR Part 63, Subpart JJJJJJ or any requirements of 40 CFR Part 63 per 40 CFR (e) and , because the facility will be operating each of the boilers exclusively as a gas-fired boiler that: Burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. And Tests firing liquid fuel for no more than a combined total of 48 hours during any calendar year. According to 40 CFR (c)(4), spray painting booths with ID Nos. P003, P004 and P005 are not subject to NESHAP Subpart MMMM because they are owned and operated by the Armed Forces of the United States. These activities are to be subject, instead, to the National Emission Standard of Hazardous Air Pollutants for Defense Land Systems and Miscellaneous Equipment (DLSME). Since this rule has not yet been issued, or even proposed, these painting booths are not currently subject to any NESHAP MACT. 4. Program Applicability Program Code Program Code 6 - PSD Program Code 8 Part 61 NESHAP Program Code 9 - NSPS Program Code M Part 63 NESHAP Program Code V Title V Applicable (y/n) No Yes Yes Yes Yes Printed: April 13, 2016 Page 7 of 35

8 Regulatory Analysis II. Facility Wide Requirements A. Emission and Operating Caps: Current Title V Permit No V-02-0 included a facility wide cap on usage of VOC and HAP containing coatings and adhesives used in furniture manufacturing so that the facility can qualify to be an incidental wood manufacturer, and therefore exempt from the HAP emissions limitations contained in the Wood Furniture Manufacturing MACT standard, i.e., 40 CFR Part 63, Subpart JJ, per 40CFR through of the Subpart. B. Applicable Rules and Regulations The facility is subject to 40 CFR Part 61 Subpart M, the NESHAP for Asbestos, which is applicable facility-wide. In particular the facility is subject to the standard for demolition and renovation found in 40 CFR and the standard for waste disposal for manufacturing, fabricating, demolition, renovation, and spraying operations found in 40 CFR The facility is potentially subject to the Wood Furniture MACT, 40 CFR Part 63, Subpart JJ. The facility will remain exempt from this MACT by qualifying to be an incidental wood manufacturer. As per 40 CFR , facilities that use no more than 100 gallons per month of finishing material and adhesives in the manufacture of wood furniture or components are considered to be incidental wood furniture manufacturers. Such facilities are not subject to any of the provisions (including emission limits) of the MACT. To qualify for this exemption, the facility must demonstrate this low usage on a continuous basis. This is already being done by maintaining the records to show that they use less than or equal to 100 gallons per month of finishing material or adhesives in the manufacture of wood furniture or components. The 100- gallon limit was included in Condition C. Compliance Status Section forms did not indicate that the facility was operating out of compliance with any of the facility-wide rules or regulations described above. However, a number of peaking generators/stationary CI RICEs are not in compliance with the applicable emission standards under 40 CFR part 63, Subpart ZZZZ, as discussed in Section III. D. Operational Flexibility Subsection 7.1 of the current Title V operating permit No V-02-0 includes conditions relating to national security emergencies. The specific reason for these conditions is to provide for relief to the military during what is called surge events. These occur when activities the facility has to perform due to a national security emergency make it impracticable to meet one or more of the limits contained in the permit. Specifically, Conditions thru establish requirements allowing the facility to operate during unusual surge events, without being considered out of compliance with permit limits. Printed: April 13, 2016 Page 8 of 35

9 E. Permit Conditions Condition is carried over from the current Title V operating permit No V This condition limits the amount of finishing material and adhesives used facility wide in the manufacture of wood furniture or wood products. The monthly usage limitation confirms that the facility qualifies as an incidental wood furniture manufacturer, and therefore is exempt from the requirements under wood furniture MACT standard, i.e., 40 CFR Part 63, Subpart JJ. Condition is a carryover from the current Title V operating permit No V This condition subjects the facility to 40 CFR Part 61 Subpart M, National Emission Standards for Asbestos, and applies to the demolition or removal of regulated asbestoscontaining material (RACM) at the base. Printed: April 13, 2016 Page 9 of 35

10 III. Regulated Equipment Requirements A. Brief Process Description The main regulated emission sources at this facility are CI and SI RICE-driven generators and water and fire pumps, natural gas-fired boilers, water and air heaters, and miscellaneous army base support activities such as paint coating spray booths and metal parts cleaners. These emission sources emit criteria air pollutants and/or HAPs in various amounts. B. Equipment List for the Process Table 1: Emission Units And Associated Air Pollution Control Devices Emission Units ID No. B001 B002 B003 (Group 4) B004 (Group 4) B005 (Group 4) B006 (Group 8) Description Boiler # 1 located at Building 25330/The South Heating Plant. 35 MMBtu/hr water tube boiler fired with natural gas and having No. 2 fuel oil as backup fuel (Installed 1976) Boiler # 2 located at Building 25330/The South Heating Plant. 35 MMBtu/hr water tube boiler fired with natural gas and having No. 2 fuel oil as backup fuel (Installed 1976) Boiler # 1 located at Building 310/The Hospital Plant. 17 MMBtu/hr fire tube boiler fired with natural gas and having No. 2 fuel oil as backup fuel(installed 1998) Boiler # 2 located at Building 310/The Hospital Plant. 17 MMBtu/hr fire tube boiler fired with natural gas and having No. 2 fuel oil as backup fuel (Installed 1998) Boiler # 3 located at Building 310/ the Hospital Plant. 17 MMBtu/hr fire tube boiler fired with natural gas and having No. 2 fuel oil as backup fuel(installed 1998) Boiler located at main heating plant/building MMBtu/hr water tube boiler having low NO x burners fired with natural gas and having No. 2 fuel oil as backup fuel (Installed 2004) Specific Limitations/Requirements Applicable Requirements/ Standards Rule (2)(d) Rule (2)(g) Rule (2)(d) Rule (2)(g) Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Corresponding Permit Conditions 3.2.5, , 3.4.2, 3.4.3, 6.1.7, 6.2.2, 6.2.3, 6.2.4, , , 3.4.2, 3.4.3, 6.1.7, 6.2.2, 6.2.3, 6.2.4, , 3.2.5, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , 3.2.5, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , 3.2.5, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , 3.2.6, 3.2.7, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 5.2.5, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , Air Pollution Control Devices ID No. Description Printed: April 13, 2016 Page 10 of 35

11 Table 1: Emission Units And Associated Air Pollution Control Devices Emission Units ID No. B007 (Group 8) B008 (Group 8) G001 (Group 1) G002 (Group 2) G003 (Group 2) G004 (Group 2) Description Boiler located at main heating plant/building MMBtu/hr water tube with low NO x burners fired with natural gas and having No. 2 fuel oil as backup fuel (Installed 2004) Boiler located at main heating plant/building MMBtu/hr water tube with low NO x burners fired with natural gas and having No. 2 fuel Oil as backup fuel (Installed 2004) Peaking Generator at Building 310 (hospital) HP output (2100kW e, gph input; manufactured in 1971). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kW e, gph input; manufactured in 1967). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kW e, gph input; manufactured in 1967). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1967). Specific Limitations/Requirements Applicable Requirements/ Standards Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Rule (2)(d) Rule (2)(g) 40CFR60 Subpart Dc 40 CFR 52.21/PSD Avoidance Rule 391o (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Corresponding Permit Conditions 3.2.5, 3.2.6, 3.2.7, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 5.2.5, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , , 3.2.6, 3.2.7, , 3.3.1, 3.3.2, 3.4.2, 3.4.3, 5.2.1, 5.2.5, 6.1.7, 6.2.2, 6.2.3, 6.2.4, 6.2.9, , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , Air Pollution Control Devices ID No. Description Printed: April 13, 2016 Page 11 of 35

12 Table 1: Emission Units And Associated Air Pollution Control Devices Emission Units ID No. G005 (Group 2) G006 (Group 2) G007 (Group 2) G008 (Group 3) G009 (Group 3) Description Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Specific Limitations/Requirements Applicable Requirements/ Standards Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Corresponding Permit Conditions 3.2.1, 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , Air Pollution Control Devices ID No. Description Printed: April 13, 2016 Page 12 of 35

13 Table 1: Emission Units And Associated Air Pollution Control Devices Emission Units ID No. G010 (Group 3) G011 (Group 8) P001 (Group CB01) P002 (Group CB01) P003 (Group CB01) P004 (Group CB01) P005 (Group CB01) Description Peaking Generator at GENTS Facility/the main power plant/building HP output (1500kWe, gph input; manufactured in 1966). Emergency Generator at GENTS Facility/the main power plant/building HP output (300kW e, gph input; manufactured in 2003). Paint Spray Booth #1, Build Vehicle and equipment maintenance. Installed after Paint Spray Booth #2, Build Vehicle and equipment maintenance. Installed after Paint Spray Booth #3, Build Miscellaneous coating operations. Installed after Paint Spray Booth #4, Build Miscellaneous coating operations. Installed after Paint Spray Booth #5, Build Miscellaneous coating operations. Installed after Specific Limitations/Requirements Applicable Requirements/ Standards Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(g) 40 CFR 52.21/PSD Avoidance 40 CFR Part 63, Subpart ZZZZ Rule (2)(e) 40CFR (Wood Furniture MACT) avoidance Rule (2)(e) 40CFR (Wood Furniture MACT) avoidance Rule (2)(e) Rule (2)(ii) avoidance 40CFR (Wood Furniture MACT) avoidance Rule (2)(e) Rule (2)(ii) avoidance 40CFR (Wood Furniture MACT) avoidance Rule (2)(e) Rule (2)(ii) avoidance 40CFR (Wood Furniture MACT) avoidance Corresponding Permit Conditions 3.2.1, 3.2.2, , , 3.3.3, 3.3.4, 3.3.6, 3.4.1, 4.2.1, 4.2.2, 5.2.1, 5.2.3, 5.2.6, 5.2.7, 5.2.8, 5.2.9, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, 6.2.7, 6.2.8, , , , , , , , , 3.2.6, 3.2.9, , , , 3.3.6, 3.4.1, 5.2.4, 6.1.7, 6.2.1, 6.2.3, 6.2.5, 6.2.6, , 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , 3.4.1, 3.4.4, 3.4.5, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , , , , , 3.4.1, 3.4.4, 3.4.5, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, , , , , , , , 3.4.1, 3.4.4, 3.4.5, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , , , , Air Pollution Control Devices ID No. DF01 DF02 DF03 DF04 DF05 Description Dust and over-spray dry filters. Dust and over-spray dry filters. Dust and over-spray dry filters. Dust and over-spray dry filters. Dust and over-spray dry filters. Printed: April 13, 2016 Page 13 of 35

14 Table 1: Emission Units And Associated Air Pollution Control Devices Emission Units ID No. P006 Description TASC Paint Spray Booth #6 (HVLP spray gun with capacity of 5.6 gph), Building Coating plastic and extruded foam props such as rifles, machine guns, pistols, bombs, grenades and mines. Specific Limitations/Requirements Applicable Requirements/ Standards Rule (2)(e) Rule (2)(a) Toxic Guideline 40CFR52.21/PSD avoidance Corresponding Permit Conditions 2.1.1, 3.2.8, 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , , , , , Air Pollution Control Devices ID No. DF06 Description Dry Type, Class 2 over-spray paint arrestors with at least 94% control efficiency for lacquer. P007 Installed in TASC Paint Spray Booth #7 (HVLP spray gun with capacity of 5.6 gph), Building Coating wood furniture. Installed in CFR (Wood Furniture MACT) avoidance Rule (2)(e) Rule (2)(a) Toxic Guideline 40CFR52.21/PSD avoidance 2.1.1, 3.2.8, 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , , , , , DF07 No VOC control. Dry Type, Class 2 over-spray paint arrestors with at least 94% control efficiency for lacquer. BL01 Sponge-Jet Blasting operation/ equipment in Building CFR (Wood Furniture MACT) avoidance, Rule (2)(e), Rule (2)(n) 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , FIL01 No VOC control. Filter M002 Training Support Center (TASC). Wood Shop producing training aides for the Army. Rule (2)(e) Rule (2)(a) Toxic Guideline 40CFR52.21/PSD avoidance 2.1.1, 3.4.1, 3.4.4, 3.5.1, 3.5.2, 3.5.3, 5.2.1, 5.2.2, 6.1.7, , , , , , , , BH01 Baghouse for TASC shop area. N/A N/A N/A 13 HP Lift Station/Water Pump Diesel Engine located in Building No (manufactured in 2011) 13 HP Lift Station/Water Pump Diesel Engine located in Building No (manufactured in 2011) 34 HP Lift Station/Water Pump Diesel Engine located in Building No. 256-A (manufactured in 2011) 40CFR (Wood Furniture MACT) avoidance 40 CFR Part 60, Subpart IIII Rule (2)(g) Rule (2)(b) , 3.3.5, 3.3.6, 3.3.7, 3.3.8, 3.4.1, * Generally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable requirements/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. Printed: April 13, 2016 Page 14 of 35

15 C. Equipment & Rule Applicability Emission and Operating Caps - Section 3.2 of this permit carries over, from the current Title V operating permit No V-02-0, a number of emission and operating limits/caps for certain equipment and equipment groups. These limits/caps kept increases in emissions of PM, PM 10, CO, NO x, and/or SO 2 below the corresponding significant levels of PSD/NSR rules in the past, and ensured previous modifications to the facility to remain avoiding PSD/NSR review. All the limits incorporated into permit conditions are federally enforceable. To assure PM 10, CO, NO x, and SO 2 emissions from equipment installed after 1977 to remain below 100 tpy, the facility has been required to monitor facility-wide fuels used in the fuel burning equipment, as well as to keep operating records for the engine driven generators and pumps. The following table contains a list of limitations for facility-wide PSD avoidance, as well as other limits, operational caps and requirements. The table was updated from the same table in the permit narrative associated with Title V permit No V Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. The following are operating limits and caps contained in the Limit and Operating Caps, Section 3.2, of the permit 1 Diesel Engine Driven Generator Groups on RTP; total outputs of energy are limited to: Group 1: 2,039,200 kwh 2 Group 2: 2,331,000 kwh Group 3: 3,118,500 kwh (per 12 month rolling total.) 2 Sulfur in Diesel Fuel Oil used in the Peaking Generator Nos. G001 thru G010 is limited to 0.05% sulfur by weight. Reduce PM, CO, NO x, and SO 2 potential. The pollutant being most limited is NO x. The engines are limited from a NO x potential of 2334 tpy to tpy. The limits equate to the following for: Group 1, limit equals tpy. Group 2, limit equals tpy. Group 3, limit equals tpy. These limits assured that the PSD significance thresholds were not exceeded when these engines were installed during the period of 10 years before the issuance of the initial Title V operating permit No V-01-0 as the facility being considered a major source under PSD. This condition reduces the SO 2 potential from the engines firing diesel fuel oil to 2.3 tpy. This limit, along with the boiler, engine and fuel oil usage cap (see Item 4 below), limit SO 2 from the specified units below the PSD major source significance level of 40tpy. It also prevents the peaking engines from being subject to the acid rain rules contained in 40 CFR Part The Group 1 limit was lowered slightly in this permit from 2,278,500 kwh to 2,039,200 kwh to account for the engine fuel factor. The fuel factor for the 1500kWe engine/generator had been used by mistake for the SIP permit, instead of the 2100kWe engine fuel factor. The Group 3 limit was raised slightly to give the facility the full tons determined from the netting analysis instead of the ton value which had been determined by rounding down during the original calculations. Printed: April 13, 2016 Page 15 of 35

16 Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. 3 Sulfur in Diesel Fuel Oil used in the CI RICE driven emergency generator G011 is limited to 0.05% sulfur by weight. 4 Group 4 boiler fuel oil usage limited to 300,000 gallons per 12- month period. Group 4 boiler natural gas usage limited to 125,000,000 cubic feet per 12- month period. 5 Sulfur in No. 2 Fuel Oil limited to 0.5% sulfur by weight. 6 Group 8 emission units limited to 39.9 tons of NOx during any 12-month period. 7 Group 8 emission units limited to 39.9 tons of SO2 during any 12-month period. 8 Paint Spray Booth Nos. P006 and P007 VOC emission limit of 39.9 tpy 9 Operation limitations /requirements for emergency stationary RICEs 10 Exemption of the existing emergency stationary CI RICEs from MACT Subpart ZZZZ This condition reduces the SO 2 potential from the engine firing diesel fuel oil to below the PSD major source significance level of 40tpy. This fuel oil usage limit is part of a previous netting analysis allowing the Group 3 engines to emit more than 40 tpy NO x. The limit also reduces PM, CO, and SO 2 potential. The total unlimited potential from these boilers is 111 tpy SO 2 and 31 tpy NO x. After the limits are applied by this condition the emissions are limited to below 10.6 tpy SO 2 and 2.9 tpy NO x. This natural gas usage limit is part of the netting analysis allowing the Group 3 engines to emit more than 40 tpy NO x. The limit also reduces PM, CO, and SO 2 potential. The total unlimited potential from these boilers is111 tpy of SO 2 and 31 tpy NO x. After the limits are applied by this condition, the emissions are below 0.03 tpy SO 2 and 6.24 tpy NO x. This limit, along with the fuel oil usage limit, keeps the SO 2 potential emissions from the boilers that use fuel oil to tpy. This limit is for the new heating plant boilers and engines installed during 2003 and The limit will ensure that the NO x emissions from the addition will be below the PSD significance increase level of 40 tpy. This limit is for the new heating plant boilers and engines installed during 2003 and The limit will ensure that the potential SO 2 emissions from the addition will be below the PSD significance increased level of 40 tpy. This limit ensures that the VOC emissions from Paint Spray Booth Nos. P007 and P008 remain below the PSD significance increase level of 40 tpy, and allows the addition of the paint booths without a need for a PSD/NSR review. These newly added operating limitations and requirements will ensure all the emergency stationary RICEs at this facility be operated only in emergency situations, and therefore are not subject to the complicated requirements for non-emergency RICEs under NSPS Subpart IIII, Subpart JJJJ or MACT Subpart ZZZZ. At this facility, all existing emergency stationary CI RICEs whose construction or reconstruction were commenced before June 12, 2006 are considered as existing institutional emergency stationary CI RICEs. Per 40 CFR (f) and (a)(1)(iii), if any of the CI RICEs is operated exclusively during emergency situations and maintenance checks and readiness testing, the engine will not be subject to MACT Subpart ZZZZ; and those existing emergency Printed: April 13, 2016 Page 16 of 35

17 Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. 11 Startup idle time limited to 30-minute. 12 Operating and maintenance requirements for RICEs including associated air pollution control equipment subject to MACT ZZZZ or NSPS IIII or JJJJ. 13 Operating limitation to allow all boilers to qualify as Gas-fired Boilers under 40 CFR Part 63, Subpart JJJJJJJ stationary CI RICEs are not subject to NSPS Subpart IIII either. According to the facility, all existing emergency stationary CI RICEs are operated this way. Idle during startup of any stationary RICE at this site subject to MACT Subpart ZZZZ is limited to no more than 30 minutes, after which time applicable emission standards shall apply all times per 40 CFR (h). At all times the Permittee shall operate and maintain RICEs subject to MACT ZZZZ or NSPS IIII or JJJJ, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. To ensure that Boiler Nos. B001 through B008 qualify as Gas-fired Boilers, and therefore avoid 40 CFR Part 63, Subpart JJJJJJ, these boilers can only burn: a. Gaseous fuels include, but are not limited to, natural gas, process gas, landfill gas, coal derived gas, refinery gas, hydrogen, and biogas b. Distillate fuel oil that complies with the specifications for fuel oil number 1 or 2. c. Distillate fuel oil for fuel testing for no more than 48 hours during any calendar year. The following are Operational limits contained in Equipment Federal Rule Standards, Section 3.3, of the Permit 14 Comply with Subpart A of 40CFR Part 60 (NSPS General Conditions) 15 Comply with Subpart Dc of 40CFR Part 60 (NSPS for Boilers) 16 MACT Subpart ZZZZ CO emission limits/reduction requirements for existing stationary peaking generators driven by CI RICEs (G001 to G011), and operating parameter requirements. General provisions for all applicable NSPS standards Standard permit language informing the facility that they must comply with all the requirements of the NSPS for boilers installed after June 1989 with input capacities from 10 million Btu/hr to 100 million Btu/hr. As required by MACT Subpart ZZZZ, each existing stationary peaking CI RICE-driven generators (G001 thru G010) shall comply with, as elected by the Permittee, either the applicable CO emission concentration limit or the CO reduction requirement, depending on its site rating. In addition, each of the peaking generator Nos. G001 to G010 has to maintain the change of pressure drop across its CO catalyst to more than 2 inches of water column, and its exhaust temperature between 450 F and 1350 F Printed: April 13, 2016 Page 17 of 35

18 Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. 17 Comply with the applicable MACT Subpart ZZZZ emission limitations, operating limitations, and other requirements at all times. 18 New or reconstructed stationary CI and SI RICEs constructed or reconstructed on or after June 12, 2006 are subject to NSPS Subpart IIII or Subpart JJJJ, instead of MACT Subpart ZZZZ. 19 The sulfur content, cetane index and aromatic content limits for diesel fuel running the CI RICEs subject to MACT Subpart ZZZZ or NSPS Subpart IIII. 20 Each Lift Station CI RICE is subject NSPS Subpart IIII, and shall be certified by the manufacturer to the certification emission standards for new nonroad CI RICE. The Permittee is required to comply with all the applicable the emission limitations, operating limitations, and other requirements in MACT Subpart ZZZZ at all times per 40 CFR (a). Per 40 CFR (a)(2)(iii), (a)(3)(iii) and (c)(1), new or reconstructed stationary CI and SI RICEs shall meet the requirements of MACT Subpart ZZZZ by meeting the applicable requirements of NSPS Subpart IIII and Subpart JJJJ. No further requirements apply for such engines under MACT Subpart ZZZZ. Per 40 CFR (a) or 40 CFR (b), diesel fuel running CI RICEs subject to MACT Subpart ZZZZ or NSPS Subpart IIII shall have a maximum sulfur content of 15 ppm (0.0015% wt.) and either a minimum cetane index of 40 or maximum aromatic content of 35 volume percent. Per 40 CFR (a)(2)(i), 4201(a) and 4204(b), each non-emergency stationary 2011 model year Lift Station CI RICE is subject to NSPS Subpart IIII, and is required to be certified by the manufacturer to the certification emission standards for new nonroad CI RICE in 40 CFR , 40 CFR , 40 CFR , 40 CFR , 40 CFR , 40 CFR , 40 CFR , and 40 CFR , as applicable, for all pollutants and for the same model year and maximum engine power. The Permittee shall obtain records of the certification from the engine manufacturer and keep a copy of such records on site Operating requirements and limitations for the Lift Station CI RICEs. Per 40 CFR (a), the Permittee shall comply with, as applicable, the following requirements for each nonemergency stationary 2011 model year Lift Station CI RICE subject to NSPS Subpart IIII: a. Operate and maintain the CI RICE and associated control device according to the manufacturer's emission-related written instructions; b. Change only those emission-related settings that are permitted by the manufacturer; c. Meet the requirements of 40 CFR Parts 89, 94 and/or 1068, as applicable. Printed: April 13, 2016 Page 18 of 35

19 Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. The following are Operational limits contained in Equipment SIP Rule Standards, Section 3.4, of the Permit 22 Opacity from peak shaving engines/generators, paint booths, blasting operations, and any other stacks or vents that are not subject to other opacity standards are limited to below 40%. The 40% opacity limit of Rule (b) for visible emissions applies to the PM emissions from peak shaving engines/generators, paint booths, blasting operations, and any other stacks or vents that are not subject to other opacity standards any stacks or vents located at Fort Gordon Opacity from new boilers limited to below 20% except one 6-minute per hour of not more than 27% opacity. This condition limits the visible emissions, and consequently PM emissions, from new boilers per Rule (d) PM limited to below the calculated levels for new fuel burning equipment under Rule (d). The applicable PM emission standards for new boilers built after January 1, 1972 are determined based on heat input of the boiler and the use of the equation PM limited to below the calculated levels for certain manufacturing processes with PM emissions The PM emissions from Sponge-Jet Blasting Operation BL01, Paint Spray Booth Nos. P001 through P007, and Wood Shop M002 limited by emission standards determined based on the hourly process weigh input rate, per Rule (e) The VOC emissions from the three metal part paint booths are limited to below 100 tpy. The 100 tpy VOC emission limit for the metal coating operations/paint Spray Booth Nos. P003, P004 and P005 would allow the metal coating operation at this site to avoid Rule (ii) The following are Equipment Standards Not Covered by a Federal or State Rule and not Instituted as an Emission Cap or Operating Limit, Section 3.5, of the Permit 27 Filter Systems employed at Paint Spray Booth Nos. P001 through P007, Sponge-jet Blasting Operation BL01 and Wood Shop in the Training Support Center M002 shall always be operational when the sources are in operation. This operating requirement is based on good air pollution control practices for minimizing emissions which helps the facility to reduce the PM emissions from the sources identified Maintenance of an inventory of spare filters/bags for filter systems employed. This requirement is considered a good air pollution control practice for minimizing emissions by increasing the reliability of the filter systems Printed: April 13, 2016 Page 19 of 35

20 Emission Limitations, Operating Caps and/or Operating Limits for Fort Gordon Found in Sections 3.2, 3.3, 3.4 and 3.5 of the Title V Operating Permit No V-03-0 Item No. Description of emission limitations, Operating Caps and/or Operating Limits Brief Reason for the emission limitations, Operating Caps and/or Operating Limits Permit Condition No. 29 Filters used in the filter systems serving Paint Spray Booth Nos. P001 through P007, Sponge-jet Blasting Operation BL01 and Wood Shop M002 shall be changed according to manufacturer s recommendations or locally prepared operating procedures. A record shall be kept of the dates filter changes were performed. Considered a good air pollution control practice for minimizing PM emissions, this maintenance requirement chosen by the facility ensures the proper operation of the filtrations systems, increases the reliability of the filter systems, therefore ensures consistent emissions reduction during operation of the sources involved Applicable Rules and Regulations Rule (2)(d) Fuel Burning Equipment Facility has various fuel burning equipment, including boilers and water heaters, subject to Rule (d). Fuel burning equipment built before January 1, 1972 is subject to Rule (d)1. Fuel burning equipment built on and after January 1, 1972 is subject to Rule (d)2. Rule (d) establishes the applicable PM emission limits (in pounds per MM Btu heat input) based the construction date and heat input capacity of the source, and limits the visible emissions from the source to 20% opacity except for one 6-minute period per hour of not more than 27% opacity. Built after June 9, 1989, each of the Boiler Nos. B001 to B008 is considered as a significant emission unit and subject to both Rule (d)2 and NSPS Subpart Dc. The issuance of this permit will make these boilers to be operated as gas-fired boilers with No. 1 or 2 fuel oil as backup during natural gas curtailment. Therefore, these boilers are exempt from requirements of NSPS Subpart Dc except fuel usage records. Burning only natural gas and No. 1 or 2 fuel oil as back up, these boilers are expected to be in compliance the applicable Rule (d) limits (2)(e), Particulate Matter from Manufacturing Process Rule (e) applies to sources with PM emissions at this facility such as paint applying, wood working, surface blasting, and stationary SI and CI RICEs if the source was constructed after July 12, Rule (e) establishes the PM emission limit/allowable in pound per hour using equations based on the process weight input rate and construction date of the source involved. The facility is using various dry filter systems to control PM emissions from paint booths, surface blasting as well as wood working shop, and SI and CI RICEs emit relatively small quantities of PM. Therefore, the facility is in compliance with Rule (e) (2)(b), Visible Emissions Rule (b) limits the visible emissions from a stationary source's vent or stack to 40% opacity or less if the source is not subject to other visible emission limit. Because of having PM emissions which exhibit opacity, paint booths, wood working shop, surface blasting operation, and Printed: April 13, 2016 Page 20 of 35