DAQ-2025-002015

DAQE-AN104020061-25

{{$d1 }}

Blair Palmer
Northrop Grumman Systems Corporation
PO Box 707
Brigham City, UT 84302-0707
[e-mail]

Dear Mr. Palmer:

Re: Approval Order: Modification to Approval Order DAQE-AN104020060-24 to Update Equipment
List
Project Number: N104020061

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
November 13, 2024. Northrop Grumman Systems Corporation must comply with the requirements of this
AO, all applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Tad Anderson, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as
the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TA:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 9, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN104020061-25
Modification to Approval Order DAQE-AN104020060-24
to Update Equipment List

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
Northrop Grumman Systems Corporation - Bacchus Works - Plant 1 NIROP
Bacchus West

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 9, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-AN104020061-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Northrop Grumman Systems Corporation Northrop Grumman Systems Corporation - Bacchus Works - Plant 1 NIROP Bacchus West

Mailing Address Physical Address
PO Box 707 5000 South 8400 West
Brigham City, UT 84302-0707 West Valley City, UT 84044

Source Contact UTM Coordinates
Name: Allia Abdallah 409,700 m Easting
Phone: [phone],502,100 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3761 (Guided Missiles & Space Vehicles)

SOURCE INFORMATION
General Description
Northrop Grumman Systems Corporation (NGSC) operates the Bacchus site, an existing rocket
propulsion plant in West Valley City, Salt Lake County. The NGSC Bacchus site manufactures solid fuel
rocket motors for NASA and the Department of Defense. The manufacturing operations at this plant
include rocket case preparation buildings, cyclotetramethylene-tetranitramine (HMX) grinding and drying
processes for making solid rocket fuel, propellant sampling and machining, and an open burning ground
for the routine burning of explosive and flammable wastes.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
DAQE-AN104020061-25
Page 4

MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities

Project Description
NGSC has requested to update the Bacchus site, approval order, and equipment list by adding a
464-horsepower diesel-fired emergency generator engine in Building 50A and removing a pulse jet
baghouse and two spray booths. The emissions increase from this permit change is the result of the
addition of the emergency generator, which is limited to 100 hours per year of operations for testing and
maintenance. The addition of the emergency generator will not result in additional requirements in the
permit since the most recent emergency generator requirements are already included in the existing
permit. The emissions reduction from the removal of the baghouse and spray booths was not taken into
consideration in this permit change.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 27 32791.00
Carbon Monoxide 0.13 27.91
Nitrogen Oxides 0.15 49.79
Particulate Matter - PM10 0.01 51.33
Particulate Matter - PM2.5 0.01 51.26
Sulfur Oxides 0.01 0.61
Volatile Organic Compounds 0.01 46.78

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1-Bromopropane (CAS #106945) 0 1500
2,4-Toluene Diisocyanate (CAS #584849) 0 1960
4,4-Methylenedianiline (CAS #101779) 0 500
Chlorine (CAS #7782505) 0 400
Chromium Compounds (CAS #CMJ500) 0 200
Ethyl Benzene (CAS #100414) 0 3000
Ethylene Dichloride (1,2-Dichloroethane) (CAS #107062) 0 500
Formaldehyde (CAS #50000) 0 200
Generic HAPs (CAS #GHAPS) 0 3980
Glycol Ethers (CAS #EDF109) 0 500
Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 1900
Hexane (CAS #110543) 0 4600
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 7000
Maleic Anhydride (CAS #108316) 0 500
DAQE-AN104020061-25
Page 5

Methanol (CAS #67561) 0 2000
Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 2000
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 2000
Methylene Chloride (Dichloromethane) (CAS #75092) 0 1000
Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 1160
Toluene (CAS #108883) 0 6000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8000
Change (TPY) Total (TPY)
Total HAPs 0 24.45

SECTION I: GENERAL PROVISIONS

I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.2 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.3 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two years. [R307-401-8]

I.4 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.7 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

I.8 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]

DAQE-AN104020061-25
Page 6

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Bacchus Works: Plant 1/NIROP/Bacchus West Rocket propulsion plant in West Valley City
II.A.2 Building 8501
Powerhouse Boilers

A. Nebraska natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr)

B. Murray natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr)

II.A.3 Building 4B Ammonium Perchlorate Processing Control: Pulse jet baghouse and HEPA filtration system Baghouse maximum flow rate: 400 acfm Baghouse pressure drop range during processing: Between 1 and 5.2 inches of H2O
II.A.4 Building 17A
Fiberglass Cutting

Vacuum dust collector

II.A.5 Building 2387 HMX Dryer Building HMX Dryer Control: Condenser Dryer Stack V-1 (emits IPA and water vapor) IPA vapor ventilation hood Vents inside, listed for informational purposes only
II.A.6 Building 2440
3-D Carbon/Carbon

Process control: Fume incinerator, 1 MMBtu/hr rate
Process control: Central vacuum system

II.A.7 Building 2471 Case Preparation Three spray lance robot booths: SLR-1, SLR-2, and SLR-3 Control: Fabric filters
DAQE-AN104020061-25
Page 7

II.A.8 Diesel-Fired Emergency Generators >600 Hp Building Location Maximum Hp rating 35A 755* 55, Stores 755* 2428, Al/AP Prep 804 2444, Mix #1 1340 2449, Cast Cure #1 (south) 1005 2484, Mix #3 1474 2489(A), Cast Cure #2 (west) 1005 2489(B), Cast Cure #2 (east) 1005 2500, Mix #2A 1340 2609, MBC#4 755* 2617, 2618, Cast Cure #3 & #4 4309* 8608, Plt.#1 Powerhouse 755* *NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ (applies to all)
II.A.9 Diesel-Fired Emergency Generators 100-600 Hp (NEW)
Building Location Maximum Hp rating
27-A, Laboratory 335*
50A 464*(NEW) 56, Compressor Building 402
2430, Al-Premix 469
2450, Control House 268 2466, Mix Bowl Clean #2 469
2498, Mix Bowl Clean #3 536
2507, Subscale ReCast 469 8501, Powerhouse 464*
8503, Compressor House 268
8569, Wastewater 335 8695, Pumphouse #3 268

*NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ (applies to all)

II.A.10 Diesel-Fired Emergency Generators <100 Hp Building Location Maximum Hp rating 55, Material 72 8100D, (Admin)PBX 81 MACT Applicability: Subpart ZZZZ (applies to all)
II.A.11 Natural Gas-Fired Emergency Generator

Building Location Maximum Hp rating
2440, 3D Carbon 163

NSPS Applicability: Subpart JJJJ
MACT Applicability: Subpart ZZZZ

DAQE-AN104020061-25
Page 8

II.A.12 Propane-Fired Emergency Generator Building Location Maximum Hp rating 8275, Microwave Station 16 MACT Applicability: Subpart ZZZZ II.A.13 Area 32A
Burning Grounds
II.A.14 Miscellaneous Natural Gas-fired Equipment Natural gas-fired boilers, air handlers, heaters, and water heaters less than 5 MMBTU/hr II.A.15 Miscellaneous Buildings Includes: miscellaneous operations, spray booths, baghouses, ovens, dust collectors, gasoline and
diesel tanks, and other processes
Gasoline storage tank MACT applicability: Subpart CCCCCC

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Sitewide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values:

A. Diesel-fired emergency generators - 20% opacity
B. All other point or fugitive emission sources, excluding the burning grounds - 10%
opacity.
[R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources, except haul roads, shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.a.2 Visible emission determinations for fugitive dust from haul roads shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a
six-minute period, however, shall not apply. Visible emissions shall be measured at the densest
point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]
II.B.1.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers. [R307-401-8]

DAQE-AN104020061-25
Page 9

II.B.1.d The owner/operator shall not emit more than the following for plant-wide emissions of HAPs: A. 0.98 tons per rolling 12-month period for 2,4 Toluene Diisocyanate B. 0.58 tons per rolling 12-month period for Methylene Diphenyl Diisocyanate C. 1.00 tons per rolling 12-month period for Methyl Chloroform D. 1.00 tons per rolling 12-month period for Methanol E. 0.10 tons per rolling 12-month period for Chromium Compounds F. 1.00 tons per rolling 12-month period for Methyl Isobutyl Ketone G. 0.95 tons per rolling 12-month period for Hexamethylene-1,6-Diisocyanate H. 1.50 tons per rolling 12-month period for Ethyl Benzene I. 2.30 tons per rolling 12-month period for Hexane J. 3.00 tons per rolling 12-month period for Toluene K. 3.50 tons per rolling 12-month period for Hydrochloric Acid L. 4.00 tons per rolling 12-month period for Xylene. [R307-401-8]
II.B.1.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. HAP emissions shall be determined by maintaining a record of HAP-emitting materials used, burned,
or destroyed each month. [R307-401-8]

II.B.2 Building 4B - Ammonium Perchlorate Processing Building II.B.2.a The owner/operator shall control emissions from the ammonium perchlorate process with a
baghouse and HEPA filtration system in series. Emissions from the ammonium perchlorate
process shall be routed to the operating baghouse and HEPA filtration system before being discharged to the atmosphere. [R307-401-8]

II.B.2.a.1 The owner/operator shall install and maintain a high-pressure differential interlock in the HEPA filtration system to shut down the ammonium perchlorate process when the pressure differential goes above the maximum operating set point of 5.2 inches of water column for more than 60 seconds. The ammonium perchlorate process shall not operate without the operating HEPA filtration system interlock. [R307-401-8]
II.B.2.a.2 The owner/operator shall record the pressure drop readings from the differential pressure
transmitters on a daily basis. [R307-401-8]

II.B.3 Building 2387 (CD3A) - HMX Dryer Building Requirements
II.B.3.a The owner/operator shall control emissions from the HMX dryer with the condenser. Emissions
from the HMX dryer shall be routed to the operating condenser before being discharged to the
atmosphere. [R307-401-8]

II.B.3.b The owner/operator shall not exceed 450 drying cycles of HMX per rolling 12-month period. [R307-401-8]
DAQE-AN104020061-25
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II.B.3.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Drying cycles of HMX shall be determined by an operations log. [R307-401-8] II.B.4 Building 2440 - 3D Carbon Building Requirements
II.B.4.a The fume incinerator shall control carbon vapor deposition (CVD) emissions from the 3D carbon process. All CVD emissions shall be routed to the operating fume incinerator before being discharged to the atmosphere. [R307-401-8]
II.B.4.b At all times while incinerating CVD emissions, the owner/operator shall maintain a temperature at or above 1,500 degrees Fahrenheit in the fume incinerator. [R307-401-8]
II.B.4.b.1 The owner/operator shall install, calibrate, maintain, and operate a device to monitor the operating temperature of the fume incinerator. The monitoring device shall be located such that an inspector/operator can safely read the output at any time. The operating temperature of the fume incinerator shall be recorded on a daily basis when the incinerator operates. [R307-401-8] II.B.4.c The owner/operator shall operate the fume incinerator at a minimum residence time of 0.5
seconds. [R307-401-8]

II.B.4.c.1 The owner/operator shall maintain the manufacturer's specifications or analysis documenting an incinerator design residence time of no less than 0.5 seconds at maximum flow rate. This documentation shall be kept on-site and be readily available for inspection upon request. [R307-401-8]
II.B.4.d The owner/operator shall equip each weaving machine's ventilation exhaust with particulate
filters to control particulate emissions. All exhaust exiting the weaving machines shall pass through this control system before being vented to the atmosphere. [R307-401-8]

II.B.4.e The owner/operator shall equip the central vacuum system with particulate filters to control particulate emissions. All air exiting the central vacuum system shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.5 Building 2471 - Case Preparation Building Requirements
II.B.5.a The owner/operator shall not exceed 14.0 tons of VOC emissions per rolling 12-month period for all operations in Building 2471. [R307-401-8]
DAQE-AN104020061-25
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II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC-emitting material, such as, paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each VOC-emitting material used (lbs per gallon) C. Maximum percent by weight of all VOC in each material used D. Mass of each VOC-emitting material used E. The emission release factor (ERF) associated with each type of VOC-emitting material F. The amount of VOC emitted monthly from each material used. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure: VOC = (%VOC by Weight)/100 x [Density (lb/gal)] x (Gal Consumed) x (1 ton/2,000 lb) x ERF (example if unit of measure is gallons) G. The total amount of VOC emitted monthly from all materials used H. The amount of VOCs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8] II.B.5.b The owner/operator shall vent all air exiting the Building 2471 spray lance robot booth SLR-1
with a stack release height of no less than 39' 3'' as measured from the base of the stack.
[R307-401-8]
II.B.6 Fuel Requirements
II.B.6.a The owner/operator shall not exceed a total natural gas consumption limit of 633,000 MMBtu
per rolling 12-month period for all natural gas-fired equipment on site. [R307-401-8]
II.B.6.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Natural gas consumption shall be determined by gas billing records. [R307-401-8]
II.B.6.b The owner/operator shall use only natural gas as the primary fuel in all fuel-burning furnaces,
ovens, boilers, and fume incinerators, and only use fuel oil as a backup fuel in all fuel-burning boilers. [R307-401-8]

II.B.6.c The owner/operator shall limit fuel oil usage in all fuel-burning boilers to 48 hours each per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the fuel-burning boilers during periods of natural gas curtailment, gas supply interruption, or startups. [R307-401-8]
DAQE-AN104020061-25
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II.B.6.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting fuel oil usage in each fuel-burning boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours C. The reason for fuel oil usage. [R307-401-8] II.B.6.d The sulfur content of any fuel oil burned in all fuel-burning boilers on-site shall not exceed
0.50% by weight. [R307-401-8]
II.B.6.d.1 The sulfur content shall be determined by the American Standard for Testing and Materials (ASTM) Method D2880-71, D-4294-89, or approved equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by test reports from the fuel oil marketer. [R307-401-8]
II.B.7 Emergency Engine Requirements
II.B.7.a The owner/operator shall not operate each emergency engine on-site for more than 100 hours per year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [R307-401-8] II.B.7.a.1 To determine compliance with a yearly total, the owner/operator shall update records
documenting generator usage by January 30th for the preceding year. Records documenting the
operation of each emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used
B. The duration of operation in hours

C. The reason for the emergency engine usage.
[R307-401-8]

II.B.7.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8]
II.B.7.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each stationary diesel emergency engine. [R307-401-8]

II.B.7.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.7.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.8 Area 32A - Burning Ground Requirements
II.B.8.a The owner/operator shall use the open burning site to destroy only scrap explosive and hazardous
material. The size of the open burning site shall not exceed five acres. [R307-401-8]

DAQE-AN104020061-25
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II.B.8.b The owner/operator shall not exceed a daily limit of 4,500 lbs of waste propellant and contaminated waste burned or destroyed per day. [R307-401-8] II.B.8.b.1 To determine compliance with the daily limit, the owner/operator shall maintain a record of the quantity of waste burned or destroyed on a daily basis. [R307-401-8]

II.B.8.c When a Salt Lake County "No Burn" order is in effect for wood-burning stoves, open burning of waste propellant and contaminated wastes shall not be performed, except for unstable wastes. [R307-401-8] II.B.8.c.1 The owner/operator shall maintain, with the record of waste burned or destroyed on a daily basis, a record of whether or not a Salt Lake County "No Burn" order was in effect for that day.
[R307-401-8]
II.B.8.d When a Salt Lake County "No Burn" order is in effect, the owner/operator is allowed to perform open burning of the most unstable wastes, including nitroglycerin wastes, laboratory-generated wastes, and unburned reactive wastes from a previous burn attempt. The open burning of unstable wastes during a Salt Lake County "No Burn" order shall not exceed 400 lbs per day. [R307-401-8] II.B.8.d.1 The owner/operator shall maintain a record of the quantity of unstable waste burned or destroyed
during a Salt Lake County "No Burn" order. The record shall include the type of waste burned or
destroyed. [R307-401-8]
II.B.8.e The owner/operator is allowed to destroy the backlog of wastes not burned during the Salt Lake County "No Burn" order up to a total of 6,000 lbs per day on the days following the burning restrictions. [R307-401-8]
II.B.8.e.1 The owner/operator shall maintain a record of the quantity of backlogged waste burned or
destroyed on the days following a Salt Lake County "No Burn" order. The record shall include the date and reason for open burning. [R307-401-8]

II.B.8.f The owner/operator shall not burn wastes exceeding 5% chlorine content unless the following conditions are all met: A. Surface wind direction at Building 32A is less than or equal to 112 degrees or more than or equal to 270 degrees B. Elevated wind direction has been verified by a helium balloon C. Wind speed does not exceed 15 miles/hr. [R307-401-8]
II.B.8.f.1 The owner/operator shall verify and record the wind speed and direction measurements prior to
the burn. The owner/operator shall not verify and record the measurements more than ten
minutes before the burn. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN104020060-24 dated June 5, 2024 Is Derived From NOI dated November 13, 2024
DAQE-AN104020061-25
Page 14

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN104020061-25

February 27, 2025

Blair Palmer
Northrop Grumman Systems Corporation
PO Box 707
Brigham City, UT 84302-0707
[e-mail]

Dear Mr. Palmer:

Re: Intent to Approve: Modification to Approval Order to DAQE-AN104020060-24 to Update
Equipment List
Project Number: N104020061

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Tad Anderson, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Tad Anderson, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:TA:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — A E v A ? A D @ E w B D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN104020061-25
Modification to Approval Order to DAQE-AN104020060-24
to Update Equipment List

Prepared By
Tad Anderson, Engineer
[phone]
[e-mail]

Issued to
Northrop Grumman Systems Corporation - Bacchus Works - Plant 1 NIROP
Bacchus West

Issued On
February 27, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — A E v A ? A D @ E w B D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-IN104020061-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Northrop Grumman Systems Corporation Northrop Grumman Systems Corporation - Bacchus Works - Plant 1 NIROP Bacchus West

Mailing Address Physical Address
PO Box 707 5000 South 8400 West
Brigham City, UT 84302-0707 West Valley City, UT 84044

Source Contact UTM Coordinates
Name: Allia Abdallah 409,700 m Easting
Phone: [phone],502,100 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3761 (Guided Missiles & Space Vehicles)

SOURCE INFORMATION
General Description
Northrop Grumman Systems Corporation (NGSC) operates the Bacchus site, an existing rocket
propulsion plant in West Valley City, Salt Lake County. The NGSC Bacchus site manufactures solid fuel
rocket motors for NASA and the Department of Defense. The manufacturing operations at this plant
include rocket case preparation buildings, cyclotetramethylene-tetranitramine (HMX) grinding and drying
processes for making solid rocket fuel, propellant sampling and machining, and an open burning ground
for the routine burning of explosive and flammable wastes.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-IN104020061-25
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MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities

Project Description
NGSC has requested to update the Bacchus site, approval order, and equipment list by adding a
464-horsepower diesel-fired emergency generator engine in Building 50A and removing a pulse jet
baghouse and two (2) spray booths. The emissions increase from this permit change is the result of the
addition of the emergency generator, which is limited to 100 hours per year of operations for testing and
maintenance. The addition of the emergency generator will not result in additional requirements in the
permit since the most recent emergency generator requirements are already included in the existing
permit. The emissions reduction from the removal of the baghouse and spray booths was not taken into
consideration in this permit change.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 27 32791.00
Carbon Monoxide 0.13 27.91
Nitrogen Oxides 0.15 49.79
Particulate Matter - PM10 0.01 51.33
Particulate Matter - PM2.5 0.01 51.26
Sulfur Oxides 0.01 0.61
Volatile Organic Compounds 0.01 46.78

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1-Bromopropane (CAS #106945) 0 1500
2,4-Toluene Diisocyanate (CAS #584849) 0 1960
4,4-Methylenedianiline (CAS #101779) 0 500
Chlorine (CAS #7782505) 0 400
Chromium Compounds (CAS #CMJ500) 0 200
Ethyl Benzene (CAS #100414) 0 3000
Ethylene Dichloride (1,2-Dichloroethane) (CAS #107062) 0 500
Formaldehyde (CAS #50000) 0 200
Generic HAPs (CAS #GHAPS) 0 3980
Glycol Ethers (CAS #EDF109) 0 500
Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 1900
Hexane (CAS #110543) 0 4600
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 7000
Maleic Anhydride (CAS #108316) 0 500
Methanol (CAS #67561) 0 2000
Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 2000
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 2000
DAQE-IN104020061-25
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Methylene Chloride (Dichloromethane) (CAS #75092) 0 1000
Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 1160
Toluene (CAS #108883) 0 6000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8000
Change (TPY) Total (TPY)
Total HAPs 0 24.45

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution-producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Salt Lake Tribune and Deseret News on March 2, 2025. During
the public comment period, the proposal and the evaluation of its impact on air quality will be available
for the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.2 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.3 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.4 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All maintenance
performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
DAQE-IN104020061-25
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I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.7 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

I.8 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 Bacchus Works: Plant 1/NIROP/Bacchus West Rocket propulsion plant in West Valley City
II.A.2 Building 8501 Powerhouse Boilers A. Nebraska natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr) B. Murray natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr) II.A.3 Building 4B Ammonium Perchlorate Processing Control: Pulse jet baghouse and HEPA filtration system Baghouse maximum flow rate: 400 acfm Baghouse pressure drop range during processing: Between 1 and 5.2 inches of H2O
II.A.4 Building 17A Fiberglass Cutting Vacuum dust collector II.A.5 Building 2387 HMX Dryer Building
HMX Dryer Control: Condenser
Dryer Stack V-1 (emits IPA and water vapor) IPA vapor ventilation hood
Vents inside, listed for informational purposes only
DAQE-IN104020061-25
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II.A.6 Building 2440 3-D Carbon/Carbon Process control: Fume incinerator, 1 MMBtu/hr rate Process control: Central vacuum system II.A.7 Building 2471 Case Preparation
Three (3) spray lance robot booths: SLR-1, SLR-2, and SLR-3 Control: Fabric filters

II.A.8 Diesel-Fired Emergency Generators >600 Hp Building Location Maximum Hp rating 35A 755* 55, Stores 755* 2428, Al/AP Prep 804 2444, Mix #1 1340 2449, Cast Cure #1 (south) 1005 2484, Mix #3 1474 2489(A), Cast Cure #2 (west) 1005 2489(B), Cast Cure #2 (east) 1005 2500, Mix #2A 1340 2609, MBC#4 755* 2617, 2618, Cast Cure #3 & #4 4309* 8608, Plt.#1 Powerhouse 755* *NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ (applies to all) II.A.9 Diesel-Fired Emergency Generators 100-600 Hp (NEW)

Building Location Maximum Hp rating 27-A, Laboratory 335*
50A 464*(NEW)
56, Compressor Building 402 2430, Al-Premix 469
2450, Control House 268
2466, Mix Bowl Clean #2 469 2498, Mix Bowl Clean #3 536
2507, Subscale ReCast 469
8501, Powerhouse 464* 8503, Compressor House 268
8569, Wastewater 335
8695, Pumphouse #3 268

*NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ (applies to all)

II.A.10 Diesel-Fired Emergency Generators <100 Hp Building Location Maximum Hp rating 55, Material 72 8100D, (Admin)PBX 81 MACT Applicability: Subpart ZZZZ (applies to all)
DAQE-IN104020061-25
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II.A.11 Natural Gas-Fired Emergency Generator Building Location Maximum Hp rating 2440, 3D Carbon 163 NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ
II.A.12 Propane-Fired Emergency Generator Building Location Maximum Hp rating
8275, Microwave Station 16 MACT Applicability: Subpart ZZZZ

II.A.13 Area 32A Burning Grounds
II.A.14 Miscellaneous Natural Gas-fired Equipment Natural gas-fired boilers, air handlers, heaters, and water heaters less than 5 MMBTU/hr

II.A.15 Miscellaneous Buildings Includes: miscellaneous operations, spray booths, baghouses, ovens, dust collectors, gasoline and diesel tanks, and other processes. Gasoline storage tank MACT applicability: Subpart CCCCCC

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Sitewide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. Diesel-fired emergency generators - 20% opacity B. All other point or fugitive emissions sources, excluding the burning grounds - 10% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources, except haul roads, shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.a.2 Visible emission determinations for fugitive dust from haul roads shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]
DAQE-IN104020061-25
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II.B.1.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8] II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAP-containing materials
and VOC- and/or HAP-laden rags in covered containers. [R307-401-8]
II.B.1.d The owner/operator shall not emit more than the following for plant-wide emissions of HAPs: A. 0.98 tons per rolling 12-month period for 2,4 Toluene Diisocyanate B. 0.58 tons per rolling 12-month period for Methylene Diphenyl Diisocyanate C. 1.00 tons per rolling 12-month period for Methyl Chloroform D. 1.00 tons per rolling 12-month period for Methanol E. 0.10 tons per rolling 12-month period for Chromium Compounds F. 1.00 tons per rolling 12-month period for Methyl Isobutyl Ketone G. 0.95 tons per rolling 12-month period for Hexamethylene-1,6-Diisocyanate H. 1.50 tons per rolling 12-month period for Ethyl Benzene I. 2.30 tons per rolling 12-month period for Hexane J. 3.00 tons per rolling 12-month period for Toluene K. 3.50 tons per rolling 12-month period for Hydrochloric Acid L. 4.00 tons per rolling 12-month period for Xylene. [R307-401-8]
II.B.1.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. HAP emissions shall be determined by maintaining a record of HAP-emitting materials used, burned,
or destroyed each month. [R307-401-8]

II.B.2 Building 4B - Ammonium Perchlorate Processing Building II.B.2.a The owner/operator shall control emissions from the ammonium perchlorate process with a
baghouse and HEPA filtration system in series. Emissions from the ammonium perchlorate
process shall be routed to the operating baghouse and HEPA filtration system before being discharged to the atmosphere. [R307-401-8]

II.B.2.a.1 The owner/operator shall install and maintain a high-pressure differential interlock in the HEPA filtration system to shut down the ammonium perchlorate process when the pressure differential goes above the maximum operating set point of 5.2 inches of water column for more than 60 seconds. The ammonium perchlorate process shall not operate without the operating HEPA filtration system interlock. [R307-401-8]
II.B.2.a.2 The owner/operator shall record the pressure drop readings from the differential pressure
transmitters on a daily basis. [R307-401-8]

DAQE-IN104020061-25
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II.B.3 Building 2387 (CD3A) - HMX Dryer Building Requirements II.B.3.a The owner/operator shall control emissions from the HMX dryer with the condenser. Emissions
from the HMX dryer shall be routed to the operating condenser before being discharged to the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall not exceed 450 drying cycles of HMX per rolling 12-month period. [R307-401-8] II.B.3.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Drying cycles of HMX shall be determined by an operations log. [R307-401-8]
II.B.4 Building 2440 - 3D Carbon Building Requirements
II.B.4.a The fume incinerator shall control carbon vapor deposition (CVD) emissions from the 3D carbon process. All CVD emissions shall be routed to the operating fume incinerator before being
discharged to the atmosphere. [R307-401-8]

II.B.4.b At all times while incinerating CVD emissions, the owner/operator shall maintain a temperature at or above 1,500 degrees Fahrenheit in the fume incinerator. [R307-401-8]
II.B.4.b.1 The owner/operator shall install, calibrate, maintain, and operate a device to monitor the operating temperature of the fume incinerator. The monitoring device shall be located such that
an inspector/operator can safely read the output at any time. The operating temperature of the
fume incinerator shall be recorded on a daily basis when the incinerator operates. [R307-401-8]
II.B.4.c The owner/operator shall operate the fume incinerator at a minimum residence time of 0.5 seconds. [R307-401-8] II.B.4.c.1 The owner/operator shall maintain the manufacturer's specifications or analysis documenting an
incinerator design residence time of no less than 0.5 seconds at maximum flow rate. This
documentation shall be kept on site and be readily available for inspection upon request. [R307-401-8]

II.B.4.d The owner/operator shall equip each weaving machine's ventilation exhaust with particulate filters to control particulate emissions. All exhaust exiting the weaving machines shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.4.e The owner/operator shall equip the central vacuum system with particulate filters to control particulate emissions. All air exiting the central vacuum system shall pass through this control
system before being vented to the atmosphere. [R307-401-8]

II.B.5 Building 2471 - Case Preparation Building Requirements II.B.5.a The owner/operator shall not exceed 14.0 tons of VOC emissions per rolling 12-month period for
all operations in Building 2471. [R307-401-8]

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II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used: A. Name of the VOC-emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each VOC-emitting material used (lbs per gallon) C. Maximum percent by weight of all VOC in each material used D. Mass of each VOC-emitting material used E. The emission release factor (ERF) associated with each type of VOC-emitting material F. The amount of VOC emitted monthly from each material used. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure: VOC = (%VOC by Weight)/100 x [Density (lb/gal)] x (Gal Consumed) x (1 ton/2,000 lb) x ERF (example if unit of measure is gallons) G. The total amount of VOC emitted monthly from all materials used H. The amount of VOCs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8] II.B.5.b The owner/operator shall vent all air exiting the Building 2471 spray lance robot booth SLR-1
with a stack release height of no less than 39' 3'' as measured from the base of the stack.
[R307-401-8]
II.B.6 Fuel Requirements
II.B.6.a The owner/operator shall not exceed a total natural gas consumption limit of 633,000 MMBtu
per rolling 12-month period for all natural gas-fired equipment on site. [R307-401-8]
II.B.6.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Natural gas consumption shall be determined by gas billing records. [R307-401-8]
II.B.6.b The owner/operator shall use only natural gas as the primary fuel in all fuel-burning furnaces,
ovens, boilers, and fume incinerators, and only use fuel oil as a backup fuel in all fuel-burning boilers. [R307-401-8]

II.B.6.c The owner/operator shall limit fuel oil usage in all fuel-burning boilers to 48 hours each per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the fuel-burning boilers during periods of natural gas curtailment, gas supply interruption, or startups. [R307-401-8]
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II.B.6.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting fuel oil usage in each fuel-burning boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours C. The reason for fuel oil usage. [R307-401-8] II.B.6.d The sulfur content of any fuel oil burned in all fuel-burning boilers on site shall not exceed
0.50% by weight. [R307-401-8]
II.B.6.d.1 The sulfur content shall be determined by the American Standard for Testing and Materials (ASTM) Method D2880-71, D-4294-89, or approved equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by test reports from the fuel oil marketer. [R307-401-8]
II.B.7 Emergency Engine Requirements
II.B.7.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [R307-401-8] II.B.7.a.1 To determine compliance with a yearly total, the owner/operator shall update records
documenting generator usage by January 30th for the preceding year. Records documenting the
operation of each emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used
B. The duration of operation in hours

C. The reason for the emergency engine usage.
[R307-401-8]

II.B.7.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8]
II.B.7.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each stationary diesel emergency engine. [R307-401-8]

II.B.7.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.7.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.8 Area 32A - Burning Ground Requirements
II.B.8.a The owner/operator shall use the open burning site to destroy only scrap explosive and hazardous
material. The size of the open burning site shall not exceed five (5) acres. [R307-401-8]

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II.B.8.b The owner/operator shall not exceed a daily limit of 4,500 lbs of waste propellant and contaminated waste burned or destroyed per day. [R307-401-8] II.B.8.b.1 To determine compliance with the daily limit, the owner/operator shall maintain a record of the quantity of waste burned or destroyed on a daily basis. [R307-401-8]

II.B.8.c When a Salt Lake County "No Burn" order is in effect for wood-burning stoves, open burning of waste propellant and contaminated wastes shall not be performed, except for unstable wastes. [R307-401-8] II.B.8.c.1 The owner/operator shall maintain, with the record of waste burned or destroyed on a daily basis, a record of whether or not a Salt Lake County "No Burn" order was in effect for that day.
[R307-401-8]
II.B.8.d When a Salt Lake County "No Burn" order is in effect, the owner/operator is allowed to perform open burning of the most unstable wastes, including nitroglycerin wastes, laboratory-generated wastes, and unburned reactive wastes from a previous burn attempt. The open burning of unstable wastes during a Salt Lake County "No Burn" order shall not exceed 400 lbs per day. [R307-401-8] II.B.8.d.1 The owner/operator shall maintain a record of the quantity of unstable waste burned or destroyed
during a Salt Lake County "No Burn" order. The record shall include the type of waste burned or
destroyed. [R307-401-8]
II.B.8.e The owner/operator is allowed to destroy the backlog of wastes not burned during the Salt Lake County "No Burn" order up to a total of 6,000 lbs per day on the days following the burning restrictions. [R307-401-8]
II.B.8.e.1 The owner/operator shall maintain a record of the quantity of backlogged waste burned or
destroyed on the days following a Salt Lake County "No Burn" order. The record shall include the date and reason for open burning. [R307-401-8]

II.B.8.f The owner/operator shall not burn wastes exceeding 5% chlorine content unless the following conditions are all met: A. Surface wind direction at Building 32A is less than or equal to 112 degrees or more than or equal to 270 degrees B. Elevated wind direction has been verified by a helium balloon C. Wind speed does not exceed 15 miles/hr. [R307-401-8]
II.B.8.f.1 The owner/operator shall verify and record the wind speed and direction measurements prior to
the burn. The owner/operator shall not verify and record the measurements more than ten (10)
minutes before the burn. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN104020060-24 dated June 5, 2024 Is Derived From NOI dated November 13, 2024
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Page 14

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
northrop
Notice Authentication Number:
202503040927425604340
2892905420
Notice URL:
Back
Notice Publish Date:
Sunday, March 02, 2025
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Northrop Grumman Systems Corporation Location: Northrop Grumman Systems
Corporation - Bacchus Works - Plant 1 NIROP Bacchus West – 5000 South 8400 West, West Valley City, UT Project Description: Northrop
Grumman Systems Corporation operates the Bacchus site, an existing rocket propulsion plant in West Valley City, Salt Lake County. Northrop
Grumman Systems Corporation has requested to install an emergency generator in building 50A to support building operations in emergency
situations. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of
federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public
comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection
and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division
at this same address on or before April 1, 2025, will be considered in making the final decision on the approval/disapproval of the proposed
project. Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to
challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment
period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance
of the issue. Date of Notice: March 2, 2025 SLT0031714
Back

DAQE-NN104020061-25

February 27, 2025

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on March 2, 2025.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Salt Lake County
cc: Wasatch Front Regional Council

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN104020061-25
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Northrop Grumman Systems Corporation
Location: Northrop Grumman Systems Corporation - Bacchus Works - Plant 1 NIROP
Bacchus West – 5000 South 8400 West, West Valley City, UT
Project Description: Northrop Grumman Systems Corporation operates the Bacchus site, an existing
rocket propulsion plant in West Valley City, Salt Lake County. Northrop
Grumman Systems Corporation has requested to install an emergency generator
in building 50A to support building operations in emergency situations.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before April 1, 2025, will be considered in making the
final decision on the approval/disapproval of the proposed project. Email comments will also be accepted
at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: March 2, 2025

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN104020061 February 20, 2025 Blair Palmer
Northrop Grumman Systems Corporation PO Box 707 Brigham City, UT 843020707
[e-mail] Dear Blair Palmer,
Re: Engineer Review: Modification to Approval Order to DAQE-AN104020060-24, to Update Equipment List Project Number: N104020061 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Northrop Grumman Systems Corporation should complete this review within 10 business days of receipt. Northrop Grumman Systems Corporation should contact Tad Anderson at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Tad Anderson at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Northrop Grumman Systems Corporation does not respond to this letter within 10 business days, the
project will move forward without source concurrence. If Northrop Grumman Systems Corporation has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N104020061 Owner Name Northrop Grumman Systems Corporation Mailing Address PO Box 707
Brigham City, UT, 843020707 Source Name Northrop Grumman Systems Corporation - Bacchus Works-
Plant 1 NIROP Bacchus West Source Location 5000 South 8400 West West Valley City, UT 84044
UTM Projection 409,700 m Easting, 4,502,100 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 3761 (Guided Missiles & Space Vehicles) Source Contact Allia Abdallah Phone Number [phone] Email [e-mail] Billing Contact Blair Palmer
Phone Number 435-279-7049 Email [e-mail]
Project Engineer Tad Anderson, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted November 13, 2024 Date of Accepted Application February 4, 2025

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 2
SOURCE DESCRIPTION General Description
Northrop Grumman Systems Corporation (NGSC) operates the Bacchus site, an existing rocket propulsion plant in West Valley City, Salt Lake County. The NGSC Bacchus site manufactures solid fuel rocket motors for NASA and the Department of Defense. The manufacturing
operations at this plant includes rocket case preparation buildings, cyclotetramethylene-tetranitramine (HMX) grinding and drying processes for making solid rocket fuel, propellant sampling and machining, and an open burning ground for the routine burning of explosive and flammable wastes. NSR Classification: Minor Modification at Minor Source Source Classification Located in, Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA, Salt Lake County
Airs Source Size: SM Applicable Federal Standards
NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities Project Proposal Modification to Approval Order to DAQE-AN104020060-24, to Update Equipment List Project Description NGSC has requested to update the Bacchus site, approval order, equipment list by adding a 464-horsepower diesel-fired emergency generator engine in Building 50A and removing a pulse jet
baghouse and two spray booths. The emissions increase from this permit change are the result of the addition of the emergency generator which is limited to 100 hours per year of operations for testing and maintenance. The addition of the emergency generator will not result in additional
requirements in the permit since the most recent emergency generator requirement are already included in the existing permit. The emissions reduction from the removal of the baghouse and spray booths were not taken into consideration in this permit change.
EMISSION IMPACT ANALYSIS Modeling is not required as R307-410-4 and R307-410-5. The emission rates from the additional emergency generator are below all modeling thresholds. [Last updated February 4, 2025]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 27 32791.00
Carbon Monoxide 0.13 27.91
Nitrogen Oxides 0.15 49.79
Particulate Matter - PM10 0.01 51.33
Particulate Matter - PM2.5 0.01 51.26
Sulfur Oxides 0.01 0.61 Volatile Organic Compounds 0.01 46.78 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
1-Bromopropane (CAS #106945) 0 1500
2,4-Toluene Diisocyanate (CAS #584849) 0 1960
4,4-Methylenedianiline (CAS #101779) 0 500
Chlorine (CAS #7782505) 0 400 Chromium Compounds (CAS #CMJ500) 0 200 Ethyl Benzene (CAS #100414) 0 3000
Ethylene Dichloride (1,2-Dichloroethane) (CAS #107062) 0 500
Formaldehyde (CAS #50000) 0 200
Generic HAPs (CAS #GHAPS) 0 3980
Glycol Ethers (CAS #EDF109) 0 500
Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 1900 Hexane (CAS #110543) 0 4600 Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 7000
Maleic Anhydride (CAS #108316) 0 500
Methanol (CAS #67561) 0 2000
Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 2000
Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 2000
Methylene Chloride (Dichloromethane) (CAS #75092) 0 1000 Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 1160 Toluene (CAS #108883) 0 6000
Xylenes (Isomers And Mixture) (CAS #1330207) 0 8000
Change (TPY) Total (TPY)
Total HAPs 0 24.45
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding BACT
Diesel-fired Emergency Generators The following control technologies were reviewed for the diesel-powered emergency generator engine:
Limited Hours of Operation, Good Combustion Practices, Use of a Tier Certified Engine, Exhaust Gas Recirculation, Diesel Particulate Filter, Ultra-Low Sulfur Fuel, Diesel Oxidation Catalyst (DOC), and Selective Catalyst Reduction (SCR).
All control technologies are technically feasible except for DOC, Exhaust Gas Recirculation and
SCR for the diesel-fired emergency generator engine. DOC requires the engine to have an exhaust temperature of at least 150 degrees C for engines with high rates of PM10. Both engines are limited to 100 hours of operation for maintenance and testing. Due to the limited hours of operation the
exhaust temperature does not attain the minimum temperature requirement for a long enough time to make DOC technically feasible. Exhaust Gas Recirculation control technology exhaust gas recirculation can also result in heat rejection, reduced power density, and lower fuel economy
making exhaust gas recirculation technically infeasible. The diesel-fired emergency generator engine is too small (less than 600 hp) for SCR to operate correctly. The following control technologies are determined to be technically feasible; Limited Hours of Operation, Good Combustion Practices, Use of a Tier Certified Engine, Diesel Particulate Filter,
and Ultra-Low Sulfur Fuel. Due to the limited hours of operation and the emissions associated with the limited hours all control technologies control technologies are determined to be economically infeasible except ; Limited Hours of Operation, Good Combustion Practices, Use of
a Tier Certified Engine, and Ultra-Low Sulfur Fuel.
BACT for the diesel-fired emergency generators is: Limited Hours of Operation, Good Combustion Practices, Use of a Tier Certified Engine, Ultra-Low Sulfur Fuel, 20 % Opacity limit
[Last updated February 5, 2025]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 5

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
I.1 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.2 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.3 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.4 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.5 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.6 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.7 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
I.8 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 6
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Bacchus Works: Plant 1/NIROP/Bacchus West Rocket propulsion plant in West Valley City II.A.2 Building 8501 Powerhouse Boilers
A. Nebraska natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr)
B. Murray natural gas-fired boiler - rated at 50,000 lb/hr (66 MMBtu/hr) II.A.3 Building 4B Ammonium Perchlorate Processing Control: Pulse jet baghouse and HEPA filtration system Baghouse maximum flow rate: 400 acfm
Baghouse pressure drop range during processing: Between 1 and 5.2 inches of H2O II.A.4 Building 17A Fiberglass Cutting
Vacuum dust collector
II.A.5 Building 2387
HMX Dryer Building HMX Dryer Control: Condenser Dryer Stack V-1 (emits IPA and water vapor)
IPA vapor ventilation hood Vents inside, listed for informational purposes only
II.A.6 Building 2440 3-D Carbon/Carbon Process control: Fume incinerator, 1 MMBtu/hr rate Process control: Central vacuum system

II.A.7 Building 2471 Case Preparation Three spray lance robot booths: SLR-1, SLR-2, SLR-3 Control: Fabric filters

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 7
II.A.8 Diesel-Fired Emergency Generators >600 Hp Building Location Maximum Hp rating 35A 755*
55, Stores 755* 2428, Al/AP Prep 804 2444, Mix #1 1340
2449, Cast Cure #1 (south) 1005 2484, Mix #3 1474 2489(A), Cast Cure #2 (west) 1005
2489(B), Cast Cure #2 (east) 1005 2500, Mix #2A 1340 2609, MBC#4 755* 2617, 2618, Cast Cure #3 & #4 4309* 8608, Plt.#1 Powerhouse 755* *NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ (applies to all)

II.A.9 Diesel-Fired Emergency Generators 100-600 Hp (NEW) Building Location Maximum Hp rating 27-A, Laboratory 335* 50A 464*(NEW) 56, Compressor Building 402 2430, Al-Premix 469
2450, Control House 268 2466, Mix Bowl Clean #2 469 2498, Mix Bowl Clean #3 536
2507, Subscale ReCast 469 8501, Powerhouse 464* 8503, Compressor House 268
8569, Wastewater 335 8695, Pumphouse #3 268 *NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ (applies to all)

II.A.10 Diesel-Fired Emergency Generators <100 Hp Building Location Maximum Hp rating 55, Material 72 8100D, (Admin)PBX 81
MACT Applicability: Subpart ZZZZ (applies to all)

II.A.11 Natural Gas-Fired Emergency Generator Building Location Maximum Hp rating 2440, 3D Carbon 163
NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 8
II.A.12 Propane-Fired Emergency Generator Building Location Maximum Hp rating 8275, Microwave Station 16
MACT Applicability: Subpart ZZZZ
II.A.13 Area 32A
Burning Grounds II.A.14 Miscellaneous Natural Gas-fired Equipment Natural gas-fired boilers, air handlers, heaters, and water heaters less than 5 MMBTU/hr
II.A.15 Miscellaneous Buildings Includes: miscellaneous operations, spray booths, baghouses, ovens, dust collectors, gasoline and diesel tanks, and other processes Gasoline storage tank MACT applicability: Subpart CCCCCC

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Sitewide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:
A. Diesel-fired emergency generators - 20% opacity B. All other point or fugitive emissions sources, excluding the burning grounds - 10%
opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources, except haul roads, shall be
conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.a.2 Visible emission determinations for fugitive dust from haul roads shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over
a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than one-half vehicle length behind the vehicle and not less than one-half the height of the vehicle. [R307-401-8]

II.B.1.b The owner/operator shall equip each paint spray booth with paint arrestor particulate filters, or equivalent, to control particulate emissions. All air exiting the booths shall pass through this control system before being vented to the atmosphere. [R307-401-8]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 9
II.B.1.c Except when in use, the owner/operator shall store all VOC- and/or HAPs-containing materials and VOC- and/or HAPs-laden rags in covered containers. [R307-401-8]
II.B.1.d The owner/operator shall not emit more than the following for plant-wide emissions of HAPs: A. 0.98 tons per rolling 12-month period for 2,4 Toluene Diisocyanate B. 0.58 tons per rolling 12-month period for Methylene Diphenyl Diisocyanate
C. 1.00 tons per rolling 12-month period for Methyl Chloroform D. 1.00 tons per rolling 12-month period for Methanol E. 0.10 tons per rolling 12-month period for Chromium Compounds
F. 1.00 tons per rolling 12-month period for Methyl Isobutyl Ketone G. 0.95 tons per rolling 12-month period for Hexamethylene-1,6-Diisocyanate H. 1.50 tons per rolling 12-month period for Ethyl Benzene I. 2.30 tons per rolling 12-month period for Hexane J. 3.00 tons per rolling 12-month period for Toluene K. 3.50 tons per rolling 12-month period for Hydrochloric Acid L. 4.00 tons per rolling 12-month period for Xylene. [R307-401-8] II.B.1.d.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
HAP emissions shall be determined by maintaining a record of HAP-emitting materials used, burned, or destroyed each month. [R307-401-8]
II.B.2 Building 4B - Ammonium Perchlorate Processing Building
II.B.2.a The owner/operator shall control emissions from the ammonium perchlorate process with a baghouse and HEPA filtration system in series. Emissions from the ammonium perchlorate process shall be routed to the operating baghouse and HEPA filtration system before being discharged to the atmosphere. [R307-401-8]
II.B.2.a.1 The owner/operator shall install and maintain a high-pressure differential interlock in the
HEPA filtration system to shut down the ammonium perchlorate process when the pressure differential goes above the maximum operating set point of 5.2 inches of water column for more than 60 seconds. The ammonium perchlorate process shall not operate without the operating HEPA filtration system interlock. [R307-401-8] II.B.2.a.2 The owner/operator shall record the pressure drop readings from the differential pressure transmitters on a daily basis. [R307-401-8]

II.B.3 Building 2387 (CD3A) - HMX Dryer Building Requirements
II.B.3.a The owner/operator shall control emissions from the HMX dryer with the condenser. Emissions from the HMX dryer shall be routed to the operating condenser before being discharged to the atmosphere. [R307-401-8]
II.B.3.b The owner/operator shall not exceed 450 drying cycles of HMX per rolling 12-month period.
[R307-401-8] II.B.3.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
Drying cycles of HMX shall be determined by an operations log. [R307-401-8]

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II.B.4 Building 2440 - 3D Carbon Building Requirements
II.B.4.a The fume incinerator shall control carbon vapor deposition (CVD) emissions from the 3D carbon process. All CVD emissions shall be routed to the operating fume incinerator before being discharged to the atmosphere. [R307-401-8]
II.B.4.b At all times while incinerating CVD emissions, the owner/operator shall maintain a
temperature at or above 1,500 degrees Fahrenheit in the fume incinerator. [R307-401-8] II.B.4.b.1 The owner/operator shall install, calibrate, maintain, and operate a device to monitor the operating temperature of the fume incinerator. The monitoring device shall be located such
that an inspector/operator can safely read the output at any time. The operating temperature of the fume incinerator shall be recorded on a daily basis when the incinerator operates. [R307-401-8]
II.B.4.c The owner/operator shall operate the fume incinerator at a minimum residence time of 0.5 seconds. [R307-401-8] II.B.4.c.1 The owner/operator shall maintain the Manufacturer's specifications or analysis documenting an incinerator design residence time of no less than 0.5 seconds at maximum flow rate. This
documentation shall be kept on site and be readily available for inspection upon request. [R307-401-8]
II.B.4.d The owner/operator shall equip each weaving machine's ventilation exhaust with particulate
filters to control particulate emissions. All exhaust exiting the weaving machines shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.4.e The owner/operator shall equip the central vacuum system with particulate filters to control particulate emissions. All air exiting the central vacuum system shall pass through this control system before being vented to the atmosphere. [R307-401-8]
II.B.5 Building 2471 - Case Preparation Building Requirements II.B.5.a The owner/operator shall not exceed 14.0 tons of VOC emissions per rolling 12-month period for all operations in Building 2471. [R307-401-8]

II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used:
A. Name of the VOC- emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each VOC-emitting material used (lbs per gallon) C. Maximum percent by weight of all VOC in each material used D. Mass of each VOC-emitting material used E. The emission release factor (ERF) associated with each type of VOC-emitting
material F. The amount of VOC emitted monthly from each material used. The amount of VOC
emitted monthly by each material used shall be calculated by the following procedure: VOC = (%VOC by Weight)/100 x [Density (lb/gal)] x (Gal Consumed) x (1 ton/2,000 lb) x

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 11
ERF
(example if unit of measure is gallons) G. The total amount of VOC emitted monthly from all materials used
H. The amount of VOCs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC
emissions. [R307-401-8]

II.B.5.b The owner/operator shall vent all air exiting the Building 2471 spray lance robot booth SLR-1 with a stack release height of no less than 39' 3'' as measured from the base of the stack. [R307-401-8]
II.B.6 Fuel Requirements
II.B.6.a The owner/operator shall not exceed a total natural gas consumption limit of 633,000 MMBtu per rolling 12-month period for all natural gas-fired equipment on site. [R307-401-8] II.B.6.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Natural gas consumption shall be determined by gas billing records. [R307-401-8]
II.B.6.b The owner/operator shall use only natural gas as the primary fuel in all fuel-burning furnaces, ovens, boilers, and fume incinerators, and only use fuel oil as a backup fuel in all fuel-burning boilers. [R307-401-8]
II.B.6.c The owner/operator shall limit fuel oil usage in all fuel-burning boilers to 48 hours each per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the fuel-burning boilers during periods of natural gas
curtailment, gas supply interruption, or startups. [R307-401-8] II.B.6.c.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting fuel oil usage in each fuel-burning boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours C. The reason for fuel oil usage. [R307-401-8]
II.B.6.d The sulfur content of any fuel oil burned in all fuel-burning boilers on site shall not exceed 0.50% by weight. [R307-401-8]
II.B.6.d.1 The sulfur content shall be determined by the American Standard for Testing and Materials
(ASTM) Method D2880-71, D-4294-89, or approved equivalent. Certification of fuel oil shall be either by the owner/operator's own testing or by test reports from the fuel oil marketer. [R307-401-8]

II.B.7 Emergency Engine Requirements
II.B.7.a The owner/operator shall not operate each emergency engine on site for more than 100 hours
per year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [R307-401-8]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 12
II.B.7.a.1 To determine compliance with a yearly total, the owner/operator shall update records documenting generator usage by January 30th for the preceding year. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [R307-401-8] II.B.7.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8]

II.B.7.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each stationary diesel emergency engine. [R307-401-8]
II.B.7.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.7.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.8 Area 32A - Burning Ground Requirements II.B.8.a The owner/operator shall use the open burning site to destroy only scrap explosive and hazardous material. The size of the open burning site shall not exceed five acres. [R307-401-8]
II.B.8.b The owner/operator shall not exceed a daily limit of 4,500 lbs of waste propellant and contaminated waste burned or destroyed per day. [R307-401-8]
II.B.8.b.1 To determine compliance with the daily limit, the owner/operator shall maintain a record of
the quantity of waste burned or destroyed on a daily basis. [R307-401-8]
II.B.8.c When a Salt Lake County "No Burn" order is in effect for wood-burning stoves, open burning of waste propellant and contaminated wastes shall not be performed, except for unstable wastes. [R307-401-8]
II.B.8.c.1 The owner/operator shall maintain, with the record of waste burned or destroyed on a daily basis, a record of whether or not a Salt Lake County "No Burn" order was in effect for that day. [R307-401-8]

II.B.8.d When a Salt Lake County "No Burn" order is in effect, the owner/operator is allowed to perform open burning of the most unstable wastes, including nitroglycerin wastes, laboratory-generated wastes, and unburned reactive wastes from a previous burn attempt. The open
burning of unstable wastes during a Salt Lake County "No Burn" order shall not exceed 400 lbs per day. [R307-401-8]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 13
II.B.8.d.1 The owner/operator shall maintain a record of the quantity of unstable waste burned or destroyed during a Salt Lake County "No Burn" order. The record shall include the type of waste burned or destroyed. [R307-401-8]

II.B.8.e The owner/operator is allowed to destroy the backlog of wastes not burned during the Salt Lake County "No Burn" order up to a total of 6,000 lbs per day on the days following the burning restrictions. [R307-401-8]
II.B.8.e.1 The owner/operator shall maintain a record of the quantity of backlogged waste burned or
destroyed on the days following a Salt Lake County "No Burn" order. The record shall include the date and reason for open burning. [R307-401-8]
II.B.8.f The owner/operator shall not burn wastes exceeding 5% chlorine content unless the following conditions are all met:
A. Surface wind direction at Building 32A is less than or equal to 112 degrees or more
than or equal to 270 degrees B. Elevated wind direction has been verified by a helium balloon C. Wind speed does not exceed 15 miles/hr. [R307-401-8] II.B.8.f.1 The owner/operator shall verify and record the wind speed and direction measurements prior to the burn. The owner/operator shall not verify and record the measurements more than ten minutes before the burn. [R307-401-8]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 14
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN104020060-242 dated June 5, 2024
Is Derived From NOI dated November 13, 2024
REVIEWER COMMENTS

1. Comment regarding Emission Estimates: Emergency Generator Engine The PTE emissions estimate for Emergency Generator Engine used EPA Tier 3 standards for Nonroad Compression-Ignition Engines. A California Air Resources Board (CARB) emission factors policy memo was used to determine the breakdown of the non-methane hydrocarbon (NMHC) + NOx emission factor, which is assumed to be 5% NMHC and 95% NOx (CARB, 2008). The SOx emissions were generated using ultra-low sulfur diesel (ULSD) sulfur content (15 ppm). The CO2e calculated used table A-1 "Global Warming Potentials" from 40 Code of Federal Regulations (CFR) Part 98. The emergency generator engine is limited by hours of operation. [Last updated February 4, 2025]
2. Comment regarding Requirements: The addition of the emergency generator will not result in additional requirements in the permit. NGSC has the most recent emergency generator requirement already included in the existing permit
and there is no need to add additional requirements. [Last updated February 4, 2025] 3. Comment regarding Removed Equipment:
The emissions reduction from the removal of the baghouse and spray booths were not taken into consideration in this permit change. [Last updated February 4, 2025] 4. Comment regarding Emissions Offsets: This facility is a minor source located in Salt Lake County which is a Nonattainment area for Ozone, PM10 and PM2.5. A minor source conducting a minor modification does not trigger offsets under UAC R307-420-3 or UAC R307-421-3. This permit modification does not trigger offsets of either Ozone, PM10 or PM2.5. [Last updated February 5, 2025] 5. Comment regarding Source Classification: NGSC is located in a serious ozone nonattainment area. The Bacchus Works facility has the PTE emissions of NOx and VOC below the major threshold values of 50 TPY for either pollutant. This makes this facility a minor source and the increase in emissions are below the significant levels making this a minor modification. [Last updated February 4, 2025]

Engineer Review N104020061: Northrop Grumman Systems Corporation - Bacchus Works- Plant 1 NIROP Bacchus West February 20, 2025 Page 15
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
'-I.--.' OF rj. -
. ,,-....,
State of Utah
SPENCER J. COX
(;ovcrnor
DEIDRE HENDERSON
cutenani Governor
February 20, 2025
Blair Palmer
Northrop Grumman Systems Corporation
P0 Box 707
Brigham City, UT 843020707
[e-mail]
Dear Blair Palmer,
RN 10402006 1
Re: Engineer Review:
Modification to Approval Order to DAQE-AN104020060-24, to Update Equipment List
Project Number: N 104020061
The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Northrop Grumman
Systems Corporation should complete this review within 10 business days of receipt.
Northrop Grumman Systems Corporation should contact Tad Anderson at [phone] if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Tad Anderson at [e-mail] the signed cover letter. Upon receipt of the signed
cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the
comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for
signature by the DAQ Director.
If Northrop Grumman Systems Corporation does not respond to this letter within 10 business days, the
project will move forward without source concurrence. If Northrop Grumman Systems Corporation has
concerns that cannot be resolved and the projectecomes stagnant, the DAQ Director may issue an Order
prohibiting construction. A I I
Approval Signature
Department of
Environmental Quality
Kimberly D. Shelley
E,<ecutive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
(Signature & Date)
195 North 1950 West " Salt Lake City. UT
Mailing Address: P.O. Box 144820 " Salt Lake City. UT 84114-4820
Telephone [phone] " Fax [phone] " T.D.D. [phone]
wvisdeq.,uah.goi'
Printed on 100% recycled paper
-2j-2-o2
Source:ATK
Site:Bacuus
Project #:N10402-0060
AN104020059-22 permit new
change AO
TPY TPY TPY
PM10 Total 51.32 0.01 51.33
PM10 point 51.32 0.01 51.33
PM10 fugtive 0.00 0.00 0.00
PM2.5 Total 51.25 0.01 51.26
NOx 49.64 0.15 49.79
CO 27.78 0.13 27.91
SOx 0.60 0.01 0.61 HAP Summary Sheet
VOC Total 46.77 0.01 46.78 Existing Change New
VOC point 46.77 0.01 46.78 TPY TPY TPYVOC Fugtive 0.00 0.00 0.00 24.45 0 24.45
HAPs 24.45 0.00 24.45
GHGs 32764.00 26.60 32790.60
Source:ATK
Site:Bacuus modeling number are from 2014 ACG
Project #:N10402-0060 Source permitted 24.9 TPY of combi
Existing Change New
TPY TPY TPY
HAPs Totals 24.45000 0.00000 24.45000
Kinda
Existing Change New Existing ChangeHAPTPYTPYTPYlb/yr lb/yr1, Bromopropane 0.750 0.000 0.750 1500.00 0.00
Ethylene Dichloride 0.250 0.000 0.250 500.00 0.00Chlorine0.200 0.000 0.200 400.00 0.00
Formaldehyde 0.100 0.000 0.100 200.00 0.00
2,4
‐
Toluene Diisocyanate 0.980 0.000 0.980 1960.00 0.004,4'
‐
Methylenedianiline 0.250 0.000 0.250 500.00 0.00
Methylene Chloride 0.500 0.000 0.500 1000.00 0.00
Glycol Ethers 0.250 0.000 0.250 500.00 0.00Methylene Diphenyl Diisocyanate 0.580 0.000 0.580 1160.00 0.00
Methyl Chloroform 1.000 0.000 1.000 2000.00 0.00
Maleic anhydride 0.250 0.000 0.250 500.00 0.00Methanol1.000 0.000 1.000 2000.00 0.00
Chromium Compounds 0.100 0.000 0.100 200.00 0.00
Methyl Isobutyl Ketone 1.000 0.000 1.000 2000.00 0.00Hexamethylene1,6 Diisocyanate 0.950 0.000 0.950 1900.00 0.00
Ethyl Benzene 1.500 0.000 1.500 3000.00 0.00Hexane2.300 0.000 2.300 4600.00 0.00
Toluene 3.000 0.000 3.000 6000.00 0.00
Hydrochloric acid 3.500 0.000 3.500 7000.00 0.00Xylenes4.000 0.000 4.000 8000.00 0.00
Generic 1.990 0.000 1.990 3980.00 0.00Total24.45000 0.00000 24.45000
HAP's Modeling Existing Increase New
Source Source Source
HAP lb/hr lb/hr lb/hr <20m 20-50 50-1001, Bromopropane 0.17123 0.00000 0.17123 new new newEthylene Dichloride 0.05708 0.00000 0.05708 2.06420 2.67131 4.97836
Chlorine 0.04566 0.00000 0.04566 0.07396 0.09571 0.17836
Formaldehyde 0.02283 0.00000 0.02283 0.01400 0.01879 0.03390
2,4
‐
Toluene Diisocyanate 0.22374 0.00000 0.22374 0.01400 0.01879 0.03390
4,4'
‐
Methylenedianiline 0.05708 0.00000 0.05708 22.14000 28.66000 53.41000Methylene Chloride 0.11416 0.00000 0.11416 5.26583 6.81460 12.69994
Glycol Ethers 0.05708 0.00000 0.05708
Methylene Diphenyl Diisocyanate 0.13242 0.00000 0.13242 0.00261 0.00338 0.00629Methyl Chloroform 0.22831 0.00000 0.22831 97.40479 126.05325 234.91742
Maleic anhydride 0.05708 0.00000 0.05708 0.02045 0.02647 0.04933
Methanol 0.22831 0.00000 0.22831 14.20074 18.37742 34.24883
Vert. Restricted (lb/hr)
Chromium Compounds 0.02283 0.00000 0.02283 0.00017 0.00022 0.00041Methyl Isobutyl Ketone 0.22831 0.00000 0.22831 4.76417 6.16540 11.49006
Hexamethylene
‐
1,6
‐
Diisocyanate 0.21689 0.00000 0.21689 0.00175 0.00227 0.00423
Ethyl Benzene 0.34247 0.00000 0.34247 4.42876 5.73134 10.68113Hexane0.52511 0.00000 0.52511 8.98810 11.63166 21.67718
Toluene 0.68493 0.00000 0.68493 3.84346 4.97389 9.26952Hydrochloric acid 0.79909 0.00000 0.79909 0.11336 0.15214 0.27446
Xylenes 0.91324 0.00000 0.91324 22.14380 28.65669 53.40564
Generic
The fence line for ATK Baccuss is at >100 meters
assuming vertically restricted
GIH TLVs
ined HAP and 9.9 TPY of a single HAP, DAQE-AN104020059-22
New Change hr/yr=8760
lb/yr lb/hr
1500.00 0.00000
500.00 0.00000
400.00 0.00000
200.00 0.00000
1960.00 0.00000
500.00 0.00000 Listing for tracking in new AO
1000.00 0.00000 Modling Issues
500.00 0.00000
1160.00 0.00000
2000.00 0.00000
500.00 0.00000
2000.00 0.00000
200.00 0.00000
2000.00 0.00000
1900.00 0.00000
3000.00 0.00000
4600.00 0.00000
6000.00 0.00000
7000.00 0.00000
8000.00 0.00000
3980.00 0.00000
24.45000
Modeling
>100 <50 50-100 >100 Requirednewnewnewnew This chemical was added to the
10.88762 8.01394 9.87576 14.89459
0.39008 0.28712 0.35382 0.53364
0.06632 0.05674 0.08254 0.11422
0.06632 0.05674 0.08254 0.11422
116.80000 85.97000 97.26000 159.78000
27.77466 20.44380 25.19337 37.99656
This chemical has no modeling
0.01377 0.01013 0.01249 0.01883
513.76249 378.15975 466.01505 702.84237
0.10789 0.07941 0.09786 0.14759
74.90192 55.13227 67.94078 102.46806
Vert. Unrestricted (lb/hr)
0.00090 0.00066 0.00081 0.00123
25.12867 18.49620 22.79329 34.37677
0.00925 0.00681 0.00839 0.01266
23.35954 17.19401 21.18858 31.95655
47.40781 34.89497 43.00188 64.85530
20.27237 14.92167 18.38832 27.73320
0.53698 0.45942 0.66824 0.92480
116.79771 85.97006 105.94290 159.78274
e HAP list on 1/5/2022
NORTHROP1GRUMMANI
Northrop Grumman Systems Corporation
5000 South 8400 W
West Valley City,UT 84044
ngc.com
November 13,2024
Bryce C.Bird,Director
Utah Department of Environmental Quality
Division of Air Quality
P.O.Box 144820
Salt Lake City,Utah 84114-4820
Re:Modification to Approval Order DAQE-AN104020060-24;
Notice of Intent Application —Install 50A Emergency Generator
Dear Mr.Bird:
Northrop Grumman Systems Corporation (NGSC)is submitting this Notice of Intent (NOl)to request
the following changes to the Bacchus Works facility Approval Order (AO)DAQE-AN104020060-24:
1.Install and operate a 464 hp diesel-fired emergency generator at Building 50A;and
2.Remove the Building 2471 pulse jet baghouse and two paint spray booths listed under
Condition II.A.7.
Enclosed is the NOl application,including the emergency generator emission compliance statement,
best available control technology (BACT)analysis,and potential to emit (PTE)calculations.
If there are any questions,please contact Allia Abdallah at [phone].
Sincerely,
~aA~‘~
Blair Palmer
Manager,Environmental Services
Northrop Grumman Systems Corporation
Enclosures
cc:Tad Anderson
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
3URMHFW __________________Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number †
2. Company contact (Name, mailing address, and telephone number)†
3. Name and contact of person submitting NOI application (if different than 2)†
4. Source Universal Transverse Mercator (UTM) coordinates †
5. Source Standard Industrial Classification (SIC) code †
6. Area designation (attainment, maintenance, or nonattainment)†
7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)†
8. Source size determination (Major, Minor, PSD)†
9. Current Approval Order(s) and/or Title V Permit numbers †
NOI Application Information:[R307-401]
†
†
†
†
†
†
†
†
†
†
†N/A †
†N/A †
A. Air quality analysis (air model, met data, background data, source impact analysis) †N/A †
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
$BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
$Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5,NOx, SO2, CO, VOCs, HAPs, and GHGs)
%References/assumptions, SDS, for each calculation and pollutant
&All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
$Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
$NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
%Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
%Visibility impact analysis, Class I area impact
6LJQDWXUHRQ$SSOLFDWLRQ
†N/A †
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
Company __________________
N/A
November 2024
Northrop Grumman Systems
Corporation
■
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50A Emergency Generator
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0ç ENyj~04+
.4
rw
0
Form 2
Company InformationlNotice of Intent (NOl)
Utah Division of Air Quality
New Source Review Section
AIR QUALITY Application for:Initial Approval Order
General Owner and Sou ce Information
AuthorizationlSignature
I hereby certify that the information ai~d data submitted in and with this application is completely true,accurate and
complete,based on reas able inqufr~’made by me and to the best of my knowledge and belief.
Siqnature:1?2A)—/L~c~.Title:Manager,Environmental Services
J.,J—
Telephone Number:Date:
Blair Palmer Email:((43~)863-2430 11 ~~
Name (Type or print)Blair.PaImer~ngc.com
Date November2024
Approval Order Modification
I Company name and mailing address:2.Company**contact for environmental matters:
Northrop Grumman Systems Corporation Blair Palmer
M/S F/1/EV;P.O.Box 98 Phone no.:([phone]
Magna,UT 84044-0098 Email:Blair.Palmer~ngc.com
Phone No.:~80~D)251-2221
Fax No (**Company contact only;consultant or independent contractor contact•‘/information can be provided in a cover letter
3.Source name and physical address (if different from 4.Source Property Universal Transverse Mercator
above):coordinates (UTM),including System and Datum:
Northrop Grumman Syste Bacchus Works -Plant I NIROP Bacchus West UTM•12
5000 S.8400 W.
X:409,700 mMagna,UT 84044
Phone no.:([phone] Y:4,502,100 m
Faxno.:()
5.The Source is located in:Salt Lake County 6.Standard Industrial Classification Code (SIC)
~
7.If request for modification,AO#to be modified:DAQE #AN104020060-24 DATED:06~O5~24
8.Brief (50 words or less)description of process.
NGSC proposes to install an emergency generator at Building 50A.
Electronic NOl
9.A complete and accurate electronic NOl submitted to DAQ Permitting Mangers Jon Black ([e-mail])or Alan
Humpherys (ahumpherys~utah.gov)can expedite review process.Please mark application type.
Hard Copy Submittal Electronic Copy Submittal U Both~
1 of 1
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data -For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7. New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s)Capacity(s)Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Northrop Grumman Systems Corporation
Bacchus Works - Plant 1 NIROP Bacchus West
AN104020060-24
See application text.
See application text.
✔
✔
NGSC proposes to install an emergency
generator at Building 50A.
NGSC proposes to install an emergency generator at Building 50A.
N/A
Cummins Diesel-Fired Emergency Generator 464 hp TBD
Form 5
Emissions Information
Criteria / GHGs / HAPs
Utah Division of Air Quality
New Source Review Section
Company Northrop Grumman Systems Corporation
Site Bacchus Works - 50A Emergency Generator
Permitted
Emissions
(tons/yr)
Emissions
Increases
(tons/yr)
Proposed
Emissions
(tons/yr)
PM10 51.32 0.01 51.33
PM2.5 51.25 0.01 51.26
NOx 49.64 0.15 49.79
SO2 0.60 0.0003 0.60
CO 27.78 0.13 27.91
VOC 46.77 0.01 46.78
NH3 NA 0.00 NA
Greenhouse Gases CO2eCO2eCO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e 32,764 26.6 32,791
*Potential to emit to include pollution control equipment as defined by R307-401-2.
HAP
Permitted
Emissions
(tons/yr)
Emission
Increase
(tons/yr)
Proposed
Emissions
(tons/yr)
Emissions
Increase
(lb/hr)
2,4 TDI 0.98 - 0.98 -
MDI 0.58 - 0.58 -
Methyl Chloroform 1.00 - 1.00 -
Methanol 1.00 - 1.00 -
Chromium Compounds 0.10 - 0.10 -
MIBK 1.00 - 1.00 -
1,6 HDI 0.95 - 0.95 -
Ethyl Benzene 1.50 - 1.50 -
Hexane 2.30 - 2.30 -
Toluene 3.00 6.64E-05 3.00 1.33E-03
Hydrochloric Acid 3.50 - 3.50 -
Xylenes 4.00 4.63E-05 4.00 9.26E-04
Total HAPs 24.45 0.00a 24.45 0.00a
a - Project HAPs will be rolled into the existing HAP limits
Criteria Pollutants
Potential to Emit* Criteria Pollutants & GHGs
Hazardous Air Pollutants (HAPs)
GHGs calculated on equipment worksheet.
NorthropGrummanSystemsCorporation(NGSC)
BacchusWorksSite Page1of1
NOIApplication
50AEmergencyGenerator
November 13, 2024
Owner: Northrop Grumman Systems Corporation
Facility: Bacchus Works – Plant 1 / NIROP / Bacchus West
Approval Order: DAQE-AN104020060-24
Contact: Allia Abdallah (801-251-2221)
Notice of Intent
50A Emergency Generator

Notice of Intent Application
50A Emergency Generator
Site: Bacchus Works

Table of Contents
UDAQ Forms
1. Facility Description ........................................................................................................................ 1
2. Project Information ........................................................................................................................ 1
3. Potential To Emit (PTE) Emissions ............................................................................................... 1
3.1. Emissions Methodology ....................................................................................................... 2
4. Best Available Control Technology (BACT) Analysis.................................................................... 2
4.1. Top-Down Analysis Process ................................................................................................ 2
4.2. NOx / Particulate / VOC / CO Emissions ............................................................................. 2
4.3. SO2 Emissions ..................................................................................................................... 4
5. Regulatory Analysis ...................................................................................................................... 4
6. References .................................................................................................................................... 4

List of Tables

Table 1. PTE Summary ......................................................................................................................... 1

List of Attachments
Attachment 1: Site Plan
Attachment 2: UDAQ Process Information Form and
Attachment 3: Emission Calculations

Notice of Intent Application
50A Emergency Generator
Site: Bacchus Works

Page 1 of 4

1. Facility Description
Northrop Grumman Systems Corporation (NGSC) operates the Bacchus Works site, an existing rocket
propulsion plant in West Valley City. The Bacchus Works site manufactures solid fuel rocket motors for
NASA and the Department of Defense. The manufacturing operations at this plant include rocket case
preparation buildings, cyclotetramethylene tetranitramine (HMX) grinding and drying processes for making
solid rocket fuel, propellant sampling and machining, and an open burning ground for the routine burning
of explosive and flammable wastes. The site is divided in three sections: Plant 1, NIROP, and Bacchus
West. A facility site plan is included in Attachment 1.
2. Project Information
NGSC is requesting the following changes to is Bacchus Works approval order (AO):

1. Install and operate a 464 hp diesel-fired emergency generator at Building 50A; and

2. Remove the Building 2471 pulse jet baghouse and two paint spray booths listed under Condition
II.A.7 in DAQE-AN104020060-24.

Emergency Generator
The proposed emergency generator will support operations in Building 50A during emergencies or when
power is interrupted by the local utility. Building 50A is located on the NIROP section of Bacchus Works, as
shown in Attachment 1, Figure 2.

Approval Order Conditions
Due to operational changes and planning, as described in a New Equipment Construction Status letter sent
to UDAQ (dated April 3, 2024), the pulse jet baghouse and SLR-4 were removed and the two paint spray
booths were not installed. The SLR-4 was already removed from the AO, and now NGSC would like the
baghouse and paint booths removed from the AO, as well.
3. Potential To Emit (PTE) Emissions
NGSC requests to update the site’s potential to emit (PTE) emissions to reflect the information in this NOI
application. Emission calculations are included in Attachment 3 and the existing PTE, the change in PTE,
and the new facility PTE emissions are shown in Table 1.

Table 1. PTE Summary
Pollutant

Existing PTE
(tpy)
Change in PTE
(tpy)
New PTE
(tpy)
PM10 51.32 0.01 51.33
PM2.5 51.25 0.01 51.26
NOx 49.64 0.15 49.79
SO2 0.60 0.0003 0.60
CO 27.78 0.13 27.91
VOCs 46.77 0.01 46.78
CO2e 32,764 26.6 32,791
Total HAPs* 24.45 -- 24.45
Notes:
*Project HAPs will be rolled into existing HAP limits
Notice of Intent Application
50A Emergency Generator
Site: Bacchus Works

Page 2 of 4

3.1. Emissions Methodology
The emergency generator emissions were calculated using EPA Tier 3 standards for Nonroad
Compression-Ignition Engines. A California Air Resources Board (CARB) emission factors policy memo
was used to determine the breakdown of the non-methane hydrocarbon (NMHC) + NOx emission factor,
which is assumed to be 5% NMHC and 95% NOx (CARB, 2008). The SO2 emissions were calculated using
the ultra-low sulfur diesel (ULSD) sulfur content (15 ppm). HAP emissions were estimated using EPA AP-
42 Chapter 3.3 emission factors for diesel industrial engines. Greenhouse gas emissions were estimated
using 40 CFR Subpart C. Emissions are based on 100 hours per year for maintenance and non-emergency
run time.
4. Best Available Control Technology (BACT) Analysis
4.1. Top-Down Analysis Process
A top-down BACT evaluation requires documentation and ranking of performance levels achievable for
each technically feasible pollutant control technology. The top-down BACT review process involves
determining the most stringent control technique available for a similar or identical emission source. If it can
be shown that the control technology is technically, environmentally, or economically impractical on a case-
by-case basis for the source under evaluation, then the next most stringent level of control is determined
and similarly evaluated. This process continues until a control technology and associated emission level is
determined that cannot be eliminated by any technical, environmental, or economic objections.

A top-down approach was used to evaluate available pollution controls for the proposed emergency
generator.
4.2. NOx / Particulate / VOC / CO Emissions
Step 1: Identify Control Technologies for NOx / Particulate / VOC / CO Emissions
NGSC considered the following control technologies:

1. Use of natural gas-fired engine
2. Use of propane-fired engine
3. Use of Tier Certified (Tier 2 or 3) diesel-fired engine
4. Selective Catalytic Reduction (SCR) and Diesel Particulate Filters (DPF) (Tier 4 Certified)

These controls are described below.
Use of natural gas-fired engine
Natural gas may be used as an alternate fuel source to traditional diesel emergency engines. Natural gas
engines typically emit less emissions than an equivalent-sized diesel-fired engine.
Use of propane-fired engine
Similar to natural gas, propane fuel may be used as an alternate fuel source to traditional diesel emergency
engines. Propane engines typically emit less emissions than an equivalent-sized diesel-fired engine.
Use of Tier-Certified (Tier 2 or 3) diesel-fired engine
Diesel engines utilize ultra-low sulfur diesel fuel, which helps eliminates fuel-bound NOx associated with
combustion. Much of the fuel-bound nitrogen is removed during the sulfurization process. Tier-Certified
engines satisfy EPA’s New Source Performance Standards (NSPS) IIII and Maximum Achievable Control
Notice of Intent Application
50A Emergency Generator
Site: Bacchus Works

Page 3 of 4

Technology (MACT) ZZZZ emission standards. These engines are limited to 100 hours per year for
maintenance and non-emergency use.
Selective Catalytic Reduction (SCR) and Diesel Particulate Filters (DPF) (Tier 4 Certified)
The Tier 4 diesel engine standards require that emissions of PM and NOx be further reduced by about
90%. Such emission reductions can be achieved using control technologies, including SCR and DPF. SCR
is a post-combustion NOx reduction technology that uses ammonia to react with NOx in the gas stream in
the presence of a catalyst.
Step 2: Eliminate Technically Infeasible Options
1. Use of natural gas-fired engine

The emergency engines at Bacchus Works must meet the National Fire Protection Association Standard
for Emergency and Standby Power Systems (NFPA 110). NFPA 110 states that diesel fuel is the preferred
choice in Level 1 installations where the probability of interruption to fuel supplies is high.

The Bacchus Works site is located in West Valley City, which is recognized as having a high likelihood of
interruption due to earthquakes, based on the University of Utah’s seismicity risk map (University of Utah,
2022). With a high likelihood for natural gas supply interruption, a natural gas emergency engine may not
meet the NFPA 110 Standard. For this reason, a natural gas-fired engine is not considered technically
feasible.

2. Use of propane-fired engine

Through discussion with vendors, NGSC determined propane engines are not manufactured in the required
size. For example, the Cummins vendor stated propane-fired generators are manufactured up to 200 kW,
which is smaller than the required size. Building 50A requires a 250 kW (464 hp) engine and for this reason,
a propane engine is not considered technically feasible.

3. Use of Tier Certified (Tier 2 or 3) diesel-fired engine

As stated above, the NFPA 110 Standard states that diesel fuel is the preferred choice in Level 1
installations where the probability of interruption to fuel supplies is high. Ultra-low sulfur diesel engines are
manufactured in the required size (464 hp) and therefore considered a technically feasible option.

NGSC discussed available tier ratings with Cummins vendor and the vendor confirmed that 464 hp engines
are manufactured as both Tier 2 and Tier 3-certified. Since Tier 3 engines emit less emissions, NGSC only
considered the Tier 3 engine as a technically feasible option. Because certified Tier 3 engines meet NSPS
IIII and MACT ZZZZ, further evaluation is not warranted.

4. Selective Catalytic Reduction (SCR) and Diesel Particulate Filters (DPF) (Tier 4 Certified)

While Tier 4 engines are designed to reduce emissions, generators used for emergency standby power are
exempt from the final Tier 4 regulations. Additionally, SCR and DPF technologies have technical challenges
when applied to emergency engines. Since emergency engines typically operate for short periods at no or
low load during monthly O&M, the engine exhaust would not reach the temperature required for the catalyst
to operate (UDAQ, 2018). For this reason, Tier 4 engines are not considered a technically feasible option.
Step 3: Rank Technically Feasible Control Options
An ULSD Tier 3-certified diesel engine is considered technically feasible.
Step 4: Energy, Environmental, and Economic Feasibility of Remaining Controls
An ULSD Tier 3-certified diesel engine is considered economically feasible.
Notice of Intent Application
50A Emergency Generator
Site: Bacchus Works

Page 4 of 4

Step 5: Proposed BACT
NGSC proposes an ULSD Tier 3-certified diesel engine as BACT.
4.3. SO2 Emissions
Step 1: Identify Control Technologies for SO2 Emissions
NGSC considered the used of ULSD as control for SO2 emissions.
Use of ULSD
Diesel engine emissions contain sulfur, which is emitted from the exhaust as SO2. SO2 emissions are
directly proportional to the amount of sulfur in the diesel. NGSC only uses ULSD, which contains less than
15 parts per million (ppm) sulfur. This represents the top level of possible control.
Step 2: Eliminate Technically Infeasible Options
ULSD is available for use and is considered feasible.
Step 3: Rank Technically Feasible Control Options
Use of ULSD fuel is the top level of control for SO2 emissions.
Step 4: Energy, Environmental, and Economic Feasibility of Remaining Controls
ULSD is commonly available and does not cost extra or affect energy efficiency.
Step 5: Proposed BACT
The use of ULSD is feasible and provides the highest level of control for SO2 emissions. ULSD is therefore
selected as BACT.
5. Regulatory Analysis
The proposed emergency generator will be subject to New Source Performance Standards Subpart A
(General Provisions) and Subpart IIII (Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines).
6. References
CARB (2008). Policy: CARB Emission Factors for CI Diesel Engines – Percent HC in Relation to NMHC +
NOx. https://www.baaqmd.gov/~/media/files/engineering/policy_and_procedures/engines/emission
factorsfordieselengines.pdf?la=en

UDAQ (2018). Utah Division of Air Quality. Appendix A.: BACT for Various Emission Units at Stationary
Sources. DAQ-2018-007161.

University of Utah (2022). U of U Seismograph Stations. Utah’s Earthquake Threat.
https://quake.utah.edu/outreach-education/utahs-earthquake-threat

Attachment 1: Site Plan




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Attachment 2: UDAQ Process Information Form and
EPA Compliance Statement

Utah Division of Air Quality
New Source Review Section Company: ___________________
Site/Source: _________________
Form 17 Date: _______________________
Diesel Powered Standby Generator
Company Information
1. Company Name and Address:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
2. Company Contact:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
3. Installation Address:
____________________________________________ County where facility is located: __________________
____________________________________________
____________________________________________ Latitude, Longitude and UTM Coordinates of Facility
____________________________________________ __________________________________________
Phone Number: _______________________________ __________________________________________
Fax Number: _______________________________
Standby Generator Information
4. Engines:
Maximum Maximum Emission Rate Date the engine
Manufacturer Model Rated Hours of Rate of NOx was constructed
Horsepower or Kilowatts Operation grams/BHP-HR or reconstructed
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
Attach Manufacturer-supplied information
5. Calculated emissions for this equipment:
PM10____________ Lbs/hr _____________Tons/yr PM2.5____________ Lbs/hr _____________Tons/yr
NOx_____________Lbs/hr______________Tons/yr SOx ____________ Lbs/hr______________Tons/yr
CO _____________Lbs/hr______________Tons/yr VOC ____________Lbs/hr______________Tons/yr
CO2 ____________Tons/yr CH4 ____________ Tons/yr
N2O ____________Tons/yr
HAPs___________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Northrop Grumman
Systems Corporation
Bacchus Works - Plant 1 NIROP Bacchus West
November 2024
Northrop Grumman Systems Corporation
M/S F/1/EV; P.O. Box 98
Magna, UT 84044-0098
Blair Palmer / [e-mail]
(and)
Allia Abdallah / [e-mail]
801-251-2221 435-863-2430 / 801-251-2221
Northrop Grumman Syste Bacchus Works - Plant 1 NIROP Bacchus West
5000 S. 8400 W.
Magna, UT 84044
Salt Lake County
See Form 2
Cummins 250DQDAA 464 hp 100 Hours Tier 3; 2.85 g/hp-hr TBD
See emissions calculation table.
50A Emergency Generator
2024 EPA Tier 3 Exhaust Emission
Compliance Statement
250DQDAA
Stationary Emergency
60 Hz Diesel Generator Set
Cummins Inc.Data and specification subject to change without notice EPA-1101u
(10/23)
Compliance Information:
The engine used in this generator set complies with Tier 3 emissions limit of U.S. EPA New Source Performance
Standards for stationary emergency engines under the provisions of 40 CFR 60 Subpart IIII.
Engine Manufacturer:Cummins Inc.
EPA Certificate Number:RCEXL0540AAB-009
Effective Date:05/01/2023
Date Issued:05/01/2023
EPA Engine Family (Cummins Emissions Family):RCEXL0540AAB
Engine Information:
Model:QSL/QSL9/QSL9-G7 NR3 Bore:4.49 in. (114 mm)
Engine Nameplate HP:464 Stroke:5.69 in. (145 mm)
Type:4 Cycle, In-line, 6 Cylinder Diesel Displacement:543 cu. in. (8.9 liters)
Aspiration:Turbocharged and CAC Compression ratio:16.1:1
Emission Control Device:Exhaust stack diameter:6 in. (152 mm)
Diesel Fuel Emission Limits
D2 Cycle Exhaust Emissions Grams per BHP-hr Grams per kWm-hr
NOX +
NMHC CO PM NOX +
NMHC CO PM
EPA Emissions Limit 3.0 2.6 0.15 4.0 3.5 0.20
Test methods: EPA emissions recorded per 40 CFR Part 60, 89, 1039, 1065 and weighted at load points prescribed in the
regulations for constant speed engines.
Diesel fuel specifications:Cetane number: 40-50, Reference: ASTM D975 No. 2-D, 300-500 ppm Sulfur
Reference conditions:Air Inlet Temperature: 25 °C (77 °F), Fuel Inlet Temperature: 40 °C (104 °F). Barometric Pressure:
100 kPa (29.53 in Hg),Humidity: 10.7 g/kg (75 grains H2O/lb) of dry air; required for NOx correction, Restrictions: Intake
Restriction set to a maximum allowable limit for clean filter; Exhaust Back Pressure set to a maximum allowable limit..
Tests conducted using alternate test methods, instrumentation, fuel or reference conditions can yield different results.
Engine operation with excessive air intake or exhaust restriction beyond published maximum limits, or with improper
maintenance, may result in elevated emission levels.

Attachment 3: Emission Calculations
50AEmergencyGenerator
PM10 PM2.5 NOx SO2 CO VOC TotalHAPs CO2e
0.01 0.01 0.15 0.0003 0.13 0.01 0.001 26.6
EquipmentList
Location MFR Model
Size
(kW)
Outputa
(hp) FuelType TierRating
Building50A Cummins DQDAA 250 464 Diesel Tier3
TotalOutput(hp)a 464 FuelConsumption(MMBtu/hr)3.2
Maxhoursperyear 100 NOxtoNMHC+NOxratiob 95%
BSFC(Btu/hpͲhr)c 7,000
EmissionsEstimate
g/hpͲhr lb/hpͲhr lb/hr tpy
NOx 2.85 6.28EͲ03 b,e 2.92 0.15
PM 0.15 3.31EͲ04 e 0.15 0.01
PM10 0.15 3.31EͲ04 e 0.15 0.01
PM2.5 0.15 3.31EͲ04 e 0.15 0.01
CO 2.60 5.73EͲ03 e 2.66 0.13
VOC 0.15 3.31EͲ04 b,e 0.15 0.01
SO2 5.50EͲ03 1.21EͲ05 f 0.006 0.000
HAPS Reference lb/hr tpy
1.31EͲ02 6.56EͲ04
1,3ͲButadiene g 1.27EͲ04 6.35EͲ06
Acetaldehyde g 2.49EͲ03 1.25EͲ04
Acrolein g 3.00EͲ04 1.50EͲ05
Benzene g 3.03EͲ03 1.52EͲ04
Formaldehyde g 3.83EͲ03 1.92EͲ04
Toluene g 1.33EͲ03 6.64EͲ05
Xylenes g 9.26EͲ04 4.63EͲ05
TotalPAHs g 5.46EͲ04 2.73EͲ05
Naphthalene g 2.75EͲ04 1.38EͲ05
Acenaphthylene g 1.64EͲ05 8.22EͲ07
Acenaphthene g 4.61EͲ06 2.31EͲ07
Fluorene g 9.48EͲ05 4.74EͲ06
Phenanthrene g 9.55EͲ05 4.77EͲ06
Anthracene g 6.07EͲ06 3.04EͲ07
Fluoranthene g 2.47EͲ05 1.24EͲ06
Pyrene g 1.55EͲ05 7.76EͲ07
Benz(a)anthracene g 5.46EͲ06 2.73EͲ07
Chrysene g 1.15EͲ06 5.73EͲ08
Benzo(b)Fluoranthene g 3.22EͲ07 1.61EͲ08
Benzo(k)fluoranthene g 5.03EͲ07 2.52EͲ08
Benzo(a)pyrene g 6.11EͲ07 3.05EͲ08
Indeno(1,2,3Ͳcd)pyrene g 1.22EͲ06 6.09EͲ08
Dibenzo(a,h)anthracen g 1.89EͲ06 9.47EͲ08
Benzo(g,h,i)Perylene g 1.59EͲ06 7.94EͲ08
2.85EͲ04
8.48EͲ05
5.06EͲ06
1.42EͲ06
2.92EͲ05
2.94EͲ05
1.87EͲ06
7.61EͲ06
1.88EͲ07
EmissionsSummary(ton/yr)
EmissionFactor
(lb/MMBtu)
7.67EͲ04
9.25EͲ05
9.33EͲ04
TotalHAPS
Tier3EmissionFactors
3.91EͲ05
EstimatedEmissions
ReferencePollutantc,d
1.68EͲ04
1.18EͲ03
4.78EͲ06
1.68EͲ06
9.91EͲ08
1.55EͲ07
4.09EͲ04
3.53EͲ07
3.75EͲ07
5.83EͲ07
4.89EͲ07
NorthropGrummanSystemsCorporation(NGSC)
BacchusWorksSite Page1of2
NOIApplication
50AEmergencyGenerator
GreenhouseGases Reference lb/hr tpy
CO2 h 530 26.5
CH4 h 0.021 0.001
N2O h 0.004 0.000
CO2e h Ͳ 26.6
Notes:
aͲPerdesignspecifications
bͲCARBEmissionFactorsforCIDieselEngines
(https://www.baaqmd.gov/~/media/Files/Engineering/policy_and_procedures/Engines/EmissionFactorsforDieselEngines.ashx)
cͲEPAAPͲ42,VolumeI,FifthEdition,APͲ423.4Ͳ1
dͲAssumedPM=PM10=PM2.5
gͲEPAAPͲ42,VolumeI,FifthEditionͲOctober1996,Table3.3Ͳ3,SpeciatedOrganicCompoundEmissionFactorsforUncontrolledDieselEngines
hͲ40CFR98SubpartC,TableCͲ1andCͲ2.;GWPfrom40CFRPart98,TableAͲ1
Calculation:
SeeEPAAPͲ42,Chapter3.3andtheNotessectiononthistab.
Acronyms:
BSFCͲbrakeͲspecificfuelconsumption kWͲkilowatt
GWPͲglobalwarmingpotential MMBtuͲmillionBritishthermalunits
lb/hrͲpoundsperhour NMHCͲnonͲmethanehydrocarbon
hpͲhorsepower tpyͲtonsperyear
CO2GWPh 1
2.2046 lb/kg Methane(CH4)GWPh 25
453.592 gperlb NitrousOxide(N2O)GWPh 298
Conversions
73.96
0.003
0.0006
Ͳ
EmissionFactor
(kg/MMBtu)
fͲSulfurcontentofUltraLowSulfurDiesel(15ppmsulfur)andEPAAPͲ42,VolumeI,FifthEditionͲOctober1996,Table3.4Ͳ1,EmissionFactors
forlargeStationaryDieselEngines;(EF=8.09EͲ03*sulfur%)
eͲEPATier3standardsforNonroadCompressionͲIgnitionEngines(EPA420ͲPͲ04Ͳ009RevisedApril2004).SeeNoteb(above)
forbreakoutofNOxandNMHCemissions.
NorthropGrummanSystemsCorporation(NGSC)
BacchusWorksSite Page2of2
NOIApplication
50AEmergencyGenerator